BIOPESTICIDES REGISTRATION ACTION DOCUMENT



## Bacillus amyloliquefaciens strain D747

Pesticide Chemical (PC) Code: 016 482

U.S. Environmental Protection Agency Office of Pesticide Programs Biopesticides and Pollution Prevention Division

December 8 , 2011 versionBacillus amyloliquefaciens strain D747 Page 2 of 30 Biopesticides Registration Action Document

TABLE OF CONTENTS

I. EXECUTIVE SUMMAR Y

................................ ................................ ................................ ...... 4

II. ACTIVE INGREDIE NT OVERVIEW

................................ ................................ ................ 5

III. REGULATORY BACKGROUN D

................................ ................................ ................. 6

A. Applications for Pesticide Product Registration

................................ ................................ ................................ . 6

B. Food Tolerance Exemption

................................ ................................ ................................ ................................ ... 6

IV. RISK ASSESSMENT

................................ ................................ ................................ ...... 6

A. Product Analysis Assessment (40 CFR § 158.2120)

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

B. Human Health Assessment (40 CFR § 158.2140)

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

C. Environmental Assessment (40 CFR § 158.2150)

................................ ................................ .............................. 12

V. ENVIRONMENTAL JU STICE

................................ ................................ .......................... 14

VI. RISK MANAGEMENT DECISION

................................ ................................ ................. 15

VII. ACTIONS REQUIR ED BY THE REGISTRANT

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

VIII. GLOSSARY OF A CRONYMS AND ABBREVIA TIONS

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

IX. BIBLIOGRAPHY

................................ ................................ ................................ ................ 18

A. Studies Submitted to Support Pesticide Product Registrations

................................ ................................ ....... 18

B. Environmental Protection Agency Risk Assessment Memoranda and Other Documents

............................ 20

C. Other References

................................ ................................ ................................ ................................ ................. 20

APPENDIX A. MICROBI AL PESTICIDES DATA R EQUIREMENTS

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

APPENDIX B. PESTICI DE PRODUCTS

................................ ................................ ............... 30Bacillus amyloliquefaciens strain D747 Page 3 of 30 Biopesticides Registration Action Document

BIOPESTICIDES REGISTRATION ACTION DOCUMENT TEAM

Office of Pesticide Programs (OPP) Biopesticides and Pollution Prevention Division

Microbial Pesticides Branch

Science Reviews

Joel V. Gagliardi , Ph.D. Product Analysis, Human Health

John L. Kough, Ph.D. Product Analysis, Human Health

Gail Tomimatsu

, Ph.D. Environmental Effects Shannon Borges Environmental Effects

Regulations

Sheryl K. Reilly, Ph.D. Chief, Microbial Pesticides Branch

Susanne Cerrelli Regulatory Action LeaderBacillus amyloliquefaciens strain D747 Page 4 of 30 Biopesticides Registration Action Document

I. EXECUTIVE SUMMARY

Certis USA, LLC

, (“Certis” or “applicant) submitted data to support the registr ation of Bacillus amyloliquefaciens strain D747 i s the active ingredient in two end

- use pesti cide products, CX

9030 (EPA File Symbol 70051

- 107 ) and CX

- 9032 (EPA File Symbol 70051

- 108 ). The products

are intended for use to control fungi and bacteria in outdoor agricultural crops, greenhouses, nurseries, shadehouses, ornamentals, and turfgrass. B

. amyloliquefaciens strain D747 was initially identified by Certis as “ Bacillus subtilis variant amyloliquefaciens strain D747 ,” since B.

subtili s and B. amyloliquefaciens were originally classified as subtypes or variants of the same species

. B. amyloliquefaciens is now considered a separate species , and the correct taxonomic designation is used in this Biopesticides Registration Action Document ( “ BRAD ” ) (Priest et. al., 1987; Logan and de Vos , 2009; and Murray et. al

. , 2007)

.

EPA scientists reviewed pr oduct analysis, mammalian and nontarget organism toxicity data, and

other information submitted by Certis to support the registration of the two aforementioned product registration s

. The p roduct analysis data requirements for B. amyloliquefaciens strain

D747 , including product chemistry and composition, analysis of samples, and physical and

chemical characteri stics

, were fulfilled by acceptable stu dies conducted in accordance with Agency guidelines. M amm alian toxic ity data (acute oral, injection, and pulmonary toxicity / pathogenicity) and information from peer

- reviewed scientific literature demonstrated

that B. amyloliquefaciens strain D747 is not toxic, infective or pathogeni c in laboratory rats

. Acceptable non target organ ism data also demonstrated that B

. amyloliquefaciens strain D747 is not toxic to estuarine and marine fish and invertebrates, nontarget insects (including honey bees),

and nontarget plants

.

We have assessed human health an d environmental risk s of B. amyloliquefaciens strain D747

, and determined that the pesticide would not cause unreasonable adverse effects to nontarget organisms when used in accordance with the directions on the label s, and in accordance with good agricultural practices. Additional mammalian and nontarget organism toxicity data are not required for the registered uses and application methods.

Bacillus species, including B

. amyloliquefaciens

, are commonly found in soils, including agricultural settings, and are naturally presen t on fresh produce. The Manual of Clinical Microbiology (9 th E dition) states that dried food s, such as spices, milk powder and grains

, often contain large amounts of Baci llus spores. B. amyloliquefaciens is not known to produce any

mammalian toxins

, and no food

- borne disease outbreaks associated with B. amyloliquefaciens have been reported. Given that the microorganism occurs naturally in soils, exposure to B. amyloliquefaciens from surface and groundwater may occur

. No adverse effects have been reported , and none are expected from exposure to B. amyloliquefaciens through drinking water.

Despite the low toxicological profile of B. amyloliquefaciens strain D747 , personal protective equipment (PPE) is required for pesticide handlers that are frequently exposed to the active ingredient for prolonged periods. Handlers will be directed to wear a long

- sleeved shirt, long pants, socks, shoes, waterproof gloves, and a dust/mist filtering respirator meeting National Institute for Occupational Safety and Health (NIOSH) standards of at least N

- 95, R

- 95, or P

- 95.

EPA may require additional PPE, other than the standard described above, if additional pesticide uses resulting in increased exposures are propose d in the future

.

EPA has concluded that , based upon the results of the toxicity tests and lack of adverse incidents,Bacillus amyloliquefaciens strain D747 Page 5 of 30 Biopesticides Registration Action Document

there is a reasonable certainty that no harm will result to the United States population, including

i nfants and children, from aggregate exposure to residues of B. amyloliquefaciens strain D747

. No dietary risks (including drinking water) are expected from use of B. amyloliquefaciens strain

D747 as a n active ingredient in pesticide products

. The two end

- use pesticide products, CX

9030 and CX

- 9032 meet the standards for registration under Section 3(c)(5) of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA)

.

On October 1, 2009, EPA announced a new policy to provide a more meaningful o pportunity for the public to participate i n major registration decisions before they occur. According to this policy, EPA intends to provide a public comment period prior to making a registration decision for, at minimum, the following types of appli cation s: new active ingredients; first food uses; first outdoor uses; first residential use s; or any other registration actions for which EPA believes there may be significant public interest

.

Consistent with the policy of making registration actions more tra nsparent, the pesticide products containing B. amyloliquefaciens strain D747 , a new active ingredient, were subject to a 30

- day comment period.

. During this comment period, no comments were received on EPA’s preliminary decision to register the two end

- use pesticide products containing B. amyloliquefaciens strain D747

, CX

- 9030 and CX

- 9032

. Therefore, EPA maintained that, based upon the risk assessment and information submitted in support of registration of such pesticide products, it was in the best interest of the public and the environment to issue the end

- use pesticide product registrations for B. amyloliquefaciens strain D747

, CX

- 9030 and CX

- 9032

. The basis for this preliminary decision can be found in the risk assessment for B. amyloliquefaciens

strain D747 , which is presented in this document

.

II. ACTIVE INGREDIENT OVERVIEW

Biological Name: Bacillus amyloliquefaciens strain D747

Culture Deposit: Agricultural Research Service Culture Collection (also

known as the Northern Regional Research Laboratory (NRRL) Collection) in Peoria

, Illinois

, under Accession

Number NRRL B

- 50405

.

OPP Chemical Code: 016 482

Type of Pesticide: Microbial Pesticide

– Insecticide

See Appendix B for specific information (e.g., use sites, application rate s , methods of application, formulation type s , and target pests) regarding

the registered pesticide products containing this active ingredient.Bacillus amyloliquefaciens strain D747 Page 6 of 30 Biopesticides Registration Action Document

III. REGULATORY BACKGROUND

A. Applications for Pesticide Product Registration

Certis USA

, LLC (address: 9145 Guilford Road, Suite 175, Columbia, MD

, 21046)

, submitted application s to register two end

- use pesticide product, CX

- 9032 and CX

- 9030

, under FIFRA

section 3 (c)(5) on July 26, 2010

. EPA announced receipt of these application s to register pesticide product s containing a new active ingredient on February 2, 2011 ( 76 Federal Register (FR) 5805 )

, and opened a 3 0

- day public comment period

, pursuant to the provisions of FIFRA section 3(c)(4). No comments were received following this publication.

B. Food Tolerance Exemption

Concurrent with its registration application s
, and under the Federal Food, Drug, and Cosmetic Act (FFDCA) section 408(d), Certis USA

, LLC

, submitted a petition to establish an exemption

from the requirement of a tolerance for Bacillus subtilis variant amyloliquefaciens strain D747 (Pesticide Petition (PP) 0F7760)

. In the Federal Register of February 4, 2011 (76 FR 6465)

, EPA

announced that Certis USA

, LLC

, propose d to establish an exemption from the requirement of a tolerance for residues of the insecticide, Bacillus subtilis variant amyloliquefaciens strain D747

, in or on all food commodities, and opened a 30

- day comment period. No c omments were received following this publication. T he correct taxonomic designation of the microorganism is Bacillus amyloliquefaciens strain D747 ; therefore, the tolerance exemption, when established,

will reflect the correct name of the active ingredient.

IV. RISK ASSESSMENT

In the Federal Register of October 26, 2007, EPA issued a Final Rule establishing changes to the data requirements that support the registration of microbial pesticides . The rule also updated the definition for microbial pesticides ( 72 FR 61002 ) , and became effective on December 26, 2007.

The data and information evaluated for this BRAD were considered in accordance with these requirements.

The classifications or ratings that are given for each data requirement in this BRAD were assigned by the EPA scien tists who reviewed the data, and convey the usefulness of the

information for the human health and nontarget risk assessment purposes

. “A cceptable ” indicates

that a study is scienti fically sound and is useful for risk assessment. A “ supplemental ”

classification indicates the studies provide d some information that can be useful for risk

assessment

. “ Supplemental ” ratings are given to studies that a re not required for registration, as

well as those that are required. In the latter case, the study lack s information that should have

been obtained if it was conducted according to the guideline associated with the data requirement

. Sometimes the missing information would not add anything ne cessary to inform a risk assessment, and the study classification remains “supplemental.” A classification of

“ s upplemental: u pgradable” indicates the study lacks necessary information, but if it is made available by the applicant , the study may be upgraded to “ a cceptable

. ” An “ u nacceptable ” rating

indicates that new data must be submitted.

Toxicity c ateg ories are assigned to acute toxicity studies, based upon any signs of toxicity (hazards) observed in the test animals during the course of the study, whether the study wasBacillus amyloliquefaciens strain D747 Page 7 of 30 Biopesticides Registration Action Document

conducted in accordance with test guidelines or comes from other sources, such as peer

reviewed, scientific literature. The active ingredient or particular product is classified into Toxicity Category I, II, III, or IV, where Toxicity Category I indicates the highest toxicity

, and Toxicity Category IV indicates the lowest toxicity (see 40 CFR § 156.62 )

.

A. Product Analysis Assessment ( 40 CFR § 158.2120 )

A ll product analysis data requirements for B. amyloliquefaciens strain D747 have been fulfilled

for the current product registrations . Refer to Tables 1, 2, 3, and 4 in Appendix A for a brief summary of the data requirements, including both generic and product

- specific information.

B. Human Health Ass essment ( 40 CFR § 158.2140 )

1. Toxicity

All Tier I mammalian toxic it y data requirements for B. amyloliquefaciens strain D747 have been

fulfilled for the current product registrations

. Refer to Tables 5, 6 and 7. Based on the lack of acute toxicity/pathogenicity, Tier II and Tie r III studies were not required.

For a compr ehensive summary of the generic and product

- specific toxic ity data requirements

described below , refer to Tables 5, 6 and 7 in Appendix A

.

a. Acute Toxicity/Pathogenicity

– Tier I

Acute Oral Toxicity/Pathogenicity (O ffice of Chemical Safety and Pollu tion Prevention (O CSPP ) Guideline 885.3050; Master Record Identification Number ( MRID No. 481657

- 04 )

B. amyloliquefaciens strain D747 was administered once orally to 14 rats of both sexes (5

- week s old) at a single dosage of 10 8 colony

- forming units ( CFU ) per animals

. No deaths occurred

, and

no abnormalities (clinical signs, body weight) were observed

, during the study or at necropsy. The test microbe was detected at 10 3

– 10 5 CFU/g in feces 1 day after administration of the test

material , but was not det ected on day 14. The examination for internal persistence did not detect the test microbe in any organs or tissues

, such as the kidney, brain, liver, lung, spleen, stomach, small intestine (duodenum), large intestine (cecum), mesenteric lymph nodes, or bloo d

, throughout the experiment al period. Fecal c learance occurred by day 14

, and no viable organisms were recovered from blood or other organ s or tissue s

. The results of this acceptable study demonstrated that B. amyloliquefaciens strain D747 was not infective

, pathogenic , or toxic

to rats when oral ly dosed with 1. 0 x10 8 CFU / animal. :

Acute Pulmonary Toxicity/Pathogenicity (OCSPP Gui deline 885.3150; MRID No. 481657

- 06 )

B. amyloliquefaciens strain D747 was administered once intratracheally to 20 male and female Sprague

- Dawley rats (5

- week old) at a dosage of 10 7 CFU per animal

. N o deaths occurred

, and

no abnormalities (clinical signs, body weight) were observed during the study or at necropsy. The examination for internal persistence showed that the test microbe was detected shortly after

administration in the lung, trachea, and nasal cavity. The test microbes w ere not detected in the

nasal cavity on day 7, and almost completely cleared from the trachea by day 60, when the study

ended. The presence of the test microbes decreased in the lungs by approximately 10 2

- 10 3 CFU/g from day 0 to day 60. The test microbes were detected in the bronchial lymph node s on day 3. Since many test microbes remained in the trachea on day 3, their presence i n the bronchial lymph nodes on day 3 was attributed to transfer by macrophages from the respiratory tract to the lymph :Bacillus amyloliquefaciens strain D747 Page 8 of 30 Biopesticides Registration Action Document

nodes. This conclusion was supported by the observation that a particle larger than 1 **μ** m in

diameter administered into the trachea and br onchi was phagocytized by a macrophage and

carried to a lymph node. The presence of the microbes in the lungs, though decreasing throughout the observation period

, was attributed to the c ontinuous transfer of viable test organisms to the bronchial lymph no de s

. This result is not unusual for spore

- forming bacteria, since bacterial spores are extremely tolerant of adverse conditions , and take a longer time for the immune system to clear than bacteria that do not form spores. Since a pattern of clearance was

d emonstrated, the remaining viable cells were considered to be spores, which take longer for a healthy immune system to clear. Th is a cceptable study demonstrated that B. amyloliquefaciens

strain D747 was not toxic or pathogenic to rats when dosed intratracheally at 1.0 x10 7 CFU/

animal.

Acute Injection Toxicity/ Pathogenicity (Intravenous)

– Rat (OCSPP Guidel ine 885.3200; MRID

No. 481657

- 05 ) : In an acute intravenous injection toxicity and pathogenicity study, groups of 17

male and female Sprague

- Dawley rats (5

- week s old) were injected with B. amyloliquefaciens

strain D747 at a dosage of 10 7 CFU per animal

, and the influence on the animals was investigated. No deaths occurred

, and there were no observed abnormal it i es (clinical signs, body weight) during the study or at necropsy. The examination for internal persistence of the test microbe showed that the test microbes were mainly detected in the kidney, liver, spleen, and blood shortly after administration. The test microbe decreased after that and was not detected in the blood from day14 ; clearance from the kidney occurred by day 60. McClintock et al. previously reported that when B. thuringiensis and B. subtilis , which are both spore

- forming bacteria, were administered intravenously to rats, clea rance from the liver and spleen is difficult

. In this study, the test microbe did not completely disappear from these organs by day 60. No test

microbes w ere detected in the brain, and only a few viable microbes at the limit level were sporadically detecte d in the small and large intestine s, and lymph nodes , but were cleared by day

60. This acceptable study demonstrated that B. amyloliquefaciens strain D747 was not toxic, infective, or pathogenic to rats when injected intravenously with 1.0 x10 7 CFU/ animal.

Hypersensitivity Incidents (OCSPP Guideline 885.3400; MRID No. 481655

- 05 ) : No hypersensitivity incidents in humans have been reported, and none occurred during research, development, or testing of B. amyloliquefaciens strain D747 . Should hypersensitivity or other

adverse incidents in humans occur in the future, Certis must report them to EPA, in accordance with FIFRA section 6(a)(2)

.

Cell Culture (OCSPP Guideline 885.3500) : This study was not required because B. amyloliquefaciens strain D 74 7 is not a virus (refer to test note #4 of 40 CFR § 158.2140(d)).

b. Acute Toxic ity and Subchronic Toxicity/Pathogenicity

– Tier II; Reproductive Fert ility Effects, Carcinogenicity, Immunotoxicity, and Infectivity/Pathogenicity Analysis

– Tier III

Tier II and Tier III studies were not required for B. amyloliquefaciens strain D747 based on the lack of acute toxicity/pathogenicity in the Tier I studies.

c. Endocrine Disruptors

As required under FFDCA section 408(p), EPA has developed the Endocrine Disruptor Screening Program (EDSP) to determine whether certain substances (including pesticide activeBacillus amyloliquefaciens strain D747 Page 9 of 30 Biopesticides Registration Action Document

and other ingredients) may have an effect in humans or wildlife similar to an eff ect produced by a “naturally occurring estrogen, or other such endocrine effects as the Administrator may designate.” The EDSP employs a two

- tiered approach to making the statutorily required determinations. Tier 1 consists of a battery of 11 screening ass ays to identify the potential of a chemical substance to interact with the estrogen, androgen, or thyroid (E, A, or T) hormonal systems. Chemicals that go through Tier 1 screening and are found to have the potential to interact with E, A, or T hormonal sys tems will proceed to the next stage of the EDSP wh ere EPA will determine which, if any, of the Tier 2 tests are necessary based on the available data. Tier 2 testing is designed to identify any adverse endocrine

- related effects caused by the substance, and establish a quantitative relationship between the dose and the E, A, or T effect.

Between October 2009 a nd February 2010, EPA issued test orders/data call

- ins for the first group of 67 chemicals, which contains 58 pesticide active ingredients and 9 inert ingredients. This list of chemicals was selected based on the potential for human exposure through pathways such as food and water, residential activity, and certain post

- application agricultural scenarios.

This list should not be construed as a list of k nown or likely endocrine disruptors.

B. amyloliquefaciens strain D747 is not among the group of 58 pesticide active ingredients on the initial list to be screened under the EDSP. Under FFDCA section 408(p), EPA must screen all pesti cide chemicals. Accordi ngly, EPA anticipates issuing future EDSP orders/data call

- ins for all pesticide active ingredients.

For further information on the status of the EDSP, the policies and procedures, the list of 67 chemicals, the test guidelines and the Tier 1 screening ba ttery, please visit our website: http://www.epa.gov/endo/

.

2

. Federal Food, Drug, and Cosmetic Act (FFDCA ) Considerations

Section 408(c)(2)(A)(i) of FFDCA allows EPA to establish an exemption from the requirement for a tolerance (the legal limit for a pesticide chemical resi due in or on a food) only if EPA determines that the exemption is “safe.” Section 408(c)(2)(A)(ii) of FFDCA defines “safe” to mean that “there is a reasonable certainty that no harm will result from aggregate exposure to the pesticide chemical residue, including all anticipated dietary exposures and all other exposures for which there is reliable information.” This includes exposure through drinking water and in

resi dential settings but does not include occupational exposure. Pursuant to section 408(c)(2)(B) of FFDCA, in establishing or maintaining in effect an exemption from the requirement of a tolerance, EPA must take into account the factors set forth in section 408(b)(2 )(C) of FFDCA,

which re quire EPA to give special consideration to exposure of infants and children to the pesticide chemical residue in establishing a tolerance and to “ensure that there is a reasonable certainty that no harm will result to infants and children from aggregate ex posure to the pesticide chemical residue....” Additionally, section 408(b)(2)(D) of FFDCA requires that EPA consider “available information concerning the cumulative effects of [a particular pesticide's]

. . . residues

and other substances that have a comm on mechanism of toxicity.”

EPA performs a number of analyses to determine the risks from aggregate exposure t o pesticide residues. First, EPA determines the tox icity of pesticides. Second, EPA examines exposure to the pesticide through food, drinking water , and through other exposures that occur as a result of pesticide use in residential settings.Bacillus amyloliquefaciens strain D747 Page 10 of 30 Biopesticides Registration Action Document

Consistent with s ection 408(b)(2)(D) of FFDCA, EPA has reviewed the available scientific data and other relevant information, and considered its validity, comple teness, and reliability and the relationship of thi s information to human risk. EPA has also considered available information concerning the variability of the sensitivities of major identifiable subgroups of consumers, including infants and children. All of the data requirements have been fulfilled, as described previously, and are presented in Table 5 in Appendix A . The following summarizes the results of EPA’s dietary risk assessment for B. amyloliquefaciens strain D747

.

a. Aggregate Exposure

In examining aggregate exposure, section 408 of FFDCA directs EPA to consider available information concerning exposures from the pesticide residue in food and all other non

occupational exposures, including drinking water from ground or surface water

, and through pesticide use in re sidential and other indoor uses

.

Food Exposure and Risk Characterization : Bacillus species, including B. amyloliquefaciens

, are commonly found in the soil in agricultural settings

, and are present on fresh produce of all kinds

with no known adverse effects. The Manual of Clinical Microbiology (9 th edition) mentions that dried food such as spices, milk powder and grains often contain large amounts of B. spores. B. amyloliquefaciens i s not known to produce any mammalian toxins

, and no foodborne disease

outbreaks associated with B. amyloliquefaciens have been reported.

Based on the data and other information submitted to satisfy the data requirements for registration of the manufactu ring

- use and end

- use pesticide product s containing the active ingredient, B. amyloliquefaciens strain D747

, no toxicity, infectivity, pathogenicity or other adverse effects from dietary exposure to are expected (see section IV(B)(1)(a) , above, and Table

5 in Appendix A ).

Drinking Water Exposure and Risk Characterization : B. amyloliquefaciens is naturally present in soils (Logan and de Vos, 2009); therefore, B. amyloliquefaciens may occur in surface and possibly groundwater. According to the World Health Organization, Bacillus species are often

detected in drinking water even after going through acceptable water treatment processes, largely because the spores are resistant to these disinfection processes (World Health Organization, 2011). Should this microbial pesticide be present

, no adverse effects are expected from exposure

to B

. amyloliquefaciens through drinking water, b ased on the data and other information

submitted to satisf y the data requirements for registration of the manufacturing

- use and end

- use pesticide product s containing the active ingredient, B. amyloliquefaciens strain D747 (see section IV(B)(1)(a) , above, and Table 5 in Appendix A ).

Non

- occupational, Residential Risk Characterization : The use sites for th ese product s include residential garden sites and agricultural sites. As stated previously, B. amyloliquefaciens is naturally present in soil , and b ased on the data and other information submitted to satisfy the data requirements for registration of the manufacturing

- use and end

- use pesticide product s containing

the active ingredient, B. amyloliquefaciens strain D74 7

, no toxicity, infectivity, pathogenicity or

other adverse eff ects from non

- occupational exposure are expected (see section IV(B)(1)(a)

, above, and Table 5 in Appendix A ).Bacillus amyloliquefaciens strain D747 Page 11 of 30 Biopesticides Registration Action Document

b. Cumulative Effects from Substances with a Common Mechanism of Toxicity

Section 408(b)(2)(D)(v) of FFDCA requires that, when considering whether to establish, modify,

or revoke a tolerance exemption

, EPA consider “

... available information concerning the cumulative effects of [a particular pesticide’s]

... residues and other substances that have a

common mechanism of tox icity.”

EPA has found that B. amyloliquefaciens strain D747 does not share a common mechanism of toxicity with any other microorganism, pesticidal or toxic substance. EPA concludes that there

are no cumulative effects associated with B. amyloliquefaciens strain D747 that need to be

considered. For information re garding how EPA determine s common mechanism s of toxicity

and evaluate s cumulative ef fects , see EPA ’s website at : http://www.epa.gov/pesticides /cumulative

.

c. Determination of Safety for the United States ( U.S. ) Population, Infants and

Children

FFDCA sectio n 408(b)(2)(C) provides that EPA shall assess the available information about consumption patterns among infants and children, special susceptibility of infants and children to pesticide chemical residues, and the cumulative effects on infants and children of the residues

and other subst ances with a common mechanism of toxicity. In addition, FFDCA sectio n 408(b)(2)(C) provides that EPA shall apply an additional tenfold (10X) margin of safety for infants and children in the case of threshold effects to account for prenatal and postnatal to xicity and the complet eness of the database on toxicity and exposure

, unless EPA determines that a different margin of safety will be safe for infants and children. This additional margin of safety is commonly referred to as the Food Quality Protection Act Safety Factor. In applying this provision, EPA either retains the default value of 10X or uses a different additional safety factor when reliable data available to EPA support the choice of a different factor.

EPA concludes that, based upon the results of the toxicity data and other information considered and described in this document, there is a reasonable certainty that no harm will result to the U.S. population, including infants and children, from aggregate exposure to the residues of B. amyloliquefaciens strain D747

. Such exposure includes all anticipated dietary and other exposures for which there is reliable information. With no threshold effects of concern

, an additional margin of safety is not required for infants and children

.

3. Occupational Exposure and Risk Characterization

Occupational exposure to B. amyloliquefaciens strain D747 is not expected to undue risk s to pesticide handlers (mixer/loader/applicators) , but EPA requires appropriate personal protective equipment and precautionary statements to mitigate any potential risks (e.g., respiratory allergenicity) to pesticide handlers from prolonged or repeated exposure s . Handlers applying B. amyloliquefaciens strain D747 end

- use products in agricultural settings must wear a long

- sleeved shirt, long pants, socks, shoes, waterproof gloves, and a dust/mist filtering respirator meeting

NIOSH standards of at least N

- 95, R

- 95, or P

- 95.

4. Human Health Risk Characterization

EPA considered human exposure to B. amyloliquefaciens st rain D747 in light of the registration

standards of FIFRA and the relevant FFDCA safety factors for allowable pesticide residues inBacillus amyloliquefaciens strain D747 Page 12 of 30 Biopesticides Registration Action Document

food and animal feed commodities. EPA has determined that no unreasonab le adverse effects to

the U.S. population in general, and to infants and children in particu lar, will result when the pesticide products containing B. amyloliquefaciens strain D747 as the active ingredient are used

in accordance with EPA

- approved labeling.

C. Environmental Assessment ( 40 CFR § 158.2150 )

The primary habitat of Bacillus species is soil, although they have also been isolated from a w ide variety of other habitats. B. amyloliquefaciens has a wide

- spread distribution

, owed in part to its ability to form endospores that are resistant to greater variation in environmental cond itions than

the vegetative cells , should transfer to other climates occur. B. amyloliquefaciens has been isolated from internal tissues of healthy plants, and is known to promote plant growth. It is not recognized as a pathogen among Bacillus species (Log an and de Vos

, 2009).

The data

, literature citations, and data waiver rationale submitted by the applicant to support the pesticide products containing B. amyloliquefaciens strain D747 fulfill ed the Tier I nontarget organism data requirements

, and were sufficient for risk assessment purposes

. Further testing of nontarget organisms at higher tier levels (i.e., Tiers II, III, and IV) is not required for the EPA

approved use s ites . EPA performed an environmental risk assessment

, and has determined that

the use of B. amyloliquefaciens strain D747 is not expected to cause unreasonable adverse effects to nontarget organisms.

For a compr ehensive summary of the generic data requirements described in sections IV( C)(1) of this BRAD, refer to Table 8 in Appendix A

.

1. Ecological Exposure and Risk Characterization

a. Terrestrial Animals and Plants

The end

- use products include a water

- dispers i ble granul ar formulation and an aqueous suspension, for application to agricultural crops, nurseries, ornamental plants, turf grass
, greenhouses

, and shadehouses. Applications can be made to both foliar surfaces and soil , so exposure to nontarget organisms is possible. The m aximum application rates from the labels of registered products were used in the assessment of nontarget risk

.

Data on the natural ly occurring levels of B. amyloliquefaciens are not available. Many factors influence the environmental fate of microbial pesticides, and resulting population levels in the environment cannot be predicted. EPA expects that B. amyloliquefaciens strain D747 may survive after application if conditions are favorable, but the strain would not significantly add to

the overall levels of B. amyloliquefaciens already pr esent in the environment.

Birds (OCSPP Guideline 885.4050) and Mammals (OCSPP Guideline 885.4150) A supplemental study showed that the acute oral LD 50 for B. amyloliquefaciens strain D747 is > 4.5 x 10 11 spores/kg BW or > 8 x 10 9 spores/bird in Northern bobwhite ( Colinus virginianus ; MRID 48165712). Additionally, B. amyloliquefaciens is intentionally included in some domestic avian food diets as a nutritional additive (e.g., European Food Safety Authority, 2010 ; Wizna et al.

, 2009), and it i s not known to be pathogenic to animals (Logan and de Vos

, 2009). An extensive literature search in several databases returned no reports of toxicity or pathogenicity of B. amyloliquefaciens in birds. Based on these lines of evidence, B. :Bacillus amyloliquefaciens strain D747 Page 13 of 30 Biopesticides Registration Action Document

amyloliquefaciens strain D747 is not expected to pose risk of adverse effects in birds.

A study with laboratory rats (MRID 48165704) also showed that B. amyloliquefaciens strain D747 is not toxic, infective, or pathogenic at the maximum hazard dose of 1.0 x 10 8 CFU /anima l. Therefore, adverse effects to wild mammals are also not expected as a result of the applications

of B. amyloliquefaciens strain D747 in accordance with label instructions.

Nontarget Insects (OCSPP Guideline 885.4340) and Honey Bees (OCSPP Guideline 885.4380)

Studies with Orius stricollis

, Crysoperla carnea , and Phytoseiulus persimilis were submitted for the nontarget insect data requirement (MRID 48165716). While no effects of B. amyloliquefaciens strain D747 were observed in these studies, they w ere not acceptable for use in the ecological risk assessment. Two honey bee studies were also submitted that showed no

adverse effects of B. amyloliquefaciens D747 after 48 hours (MRID 48165717) and 17 days (no MRID currently assigned). These studies were rated S upplemental because they were not of sufficient duration (30 days); however, except in rare cases, bacteria that are pathogenic to insects typically produce toxins that kill the insect within a few days (Tanada and Kaya

, 1993).

A dverse effects resul ting from exposure to B. amyloliquefaciens strain D747 , therefore, would likely have been evident in the bee studies, especially after 17 days. Scientific rationale was submitted to show that adverse effects are not expected to nontarget insects (MRIDs 486 21502 and 48621503)

. Entomopathogenic B. species (e.g., B. thuringiensis

, B. sphaericus ) have been extensively studied, and their pathobiology is well

- known. B. amyloliquefaciens is not among the

B. species recognized as frank pathogens to insects or other animals (Logan and de Vos

, 2009).

There are some accounts in the literature of effects of B. subtilis on insects; however, none of

these were associated with B. amyloliquefaciens or B. subtilis var

. amyloliquefaciens . Therefore, based on the studies and other information provided, B. amyloliquefaciens strain D747 is not expected to pose risk to honey bees and other nontarget insects as a result when applied in

accordance with label instructions.

. :

N

ontarget Plants (OCSPP Guideline 885.4300) Studies with plants exposed to B. amyloliquefaciens strain D747 were u nacceptable

, based on several deficiencies (MRID 48165715). B. amyloliquefaciens is not taxonomically related to any known plant pathogens. A s discussed previously , however, the microorganism has been isolated from tissues of healthy plants and is known as a plant growth

- promoting rhizobacterium. I t is

, therefore, not expected to pose risk to nontarget plants as a result of t applications made in

accordance with label instructions. :

b. Aquatic Animals and Plants

B. amyloliquefaciens strain D747 is not intended to be applied directl y to water, but some of the applied product may reach aquatic habitats through runoff or spray drift. Spray drift at application is t he primary mechanism b y which the pesticide is expected to reach water . A spray drift analysis was included in the aquatic risk assessment to determine exposure, and further detail is provided in the environmental risk assessment for B. amyloliquefaciens strain D747.

Freshwater Fish (OCSPP 885.4200) Guideline and Invertebrates (OCSPP Guideline 885.4240)

In a 30

- day study with rainbow trout ( Oncorhynchus mykiss ), the LC 50 for B. amyloliquefaciens

strain D747 was 8.1 x 10 10 CFU /L, an d the NOEC based on sub

- lethal effects was 1.44 x 10 10

CFU /L. If the maximum broadcast application rate (4 fluid ounces/1000 ft 2 or 2.55 x 10 6

CFU /cm 2 ) is applied directly to a 1

- ha body of water 15 cm deep (the EPA Standard Wetland), :Bacillus amyloliquefaciens strain D747 Page 14 of 30 Biopesticides Registration Action Document

the resulting concent ration would be 1.7 x 10 8 CFU /L. This would be the maximum possible aquatic concentration at this application rate , but this direct application to water is not on the EP

labels

. The NOEC and LC 50 are approximately 85X and 476X higher than this concentratio n, respectively. E xposure in freshwater environments will be well below the concentrations that would produce adverse effects, and the applications of B. amyloliquefaciens strain D747 as presented on EPA

- approved labels are not expected to pose risk s to freshwater fish.

A study with Daphnia magna provided an EC 50 based on mortality/immobility of 3.7 x 10 10

CFU /L

, and a NOEC for sub

- lethal effects of 2.84 x 10 8 CFU /L. Based on the spray drift analysis, the NOEC would be approximately 20X the expected environmental concentration (EEC)

, and the EC 50 would be 218X the EEC ; therefore , the applications of B. amyloliquefaciens

strain D747 D747 as presented on EPA

- approved labels are not expected to result in adverse

effects to freshwater invertebra tes.

Marine/Estuarine Fish (OCSPP 885. 4280) and Invertebrates (OCSPP 885.4240 Concentrations reaching marine or estuarine areas are expected to be less than those calculated

above for freshwater animals

, due to further dilution in deeper water. B. amyloliquefaciens strain D747 is not expected to reach marine or estuarine environments in significant concentrations, and risk to animals in these environments is not anticipated. ):

Aquatic Plants (OCSPP Guideline 885.4300) B. amyloliquefaciens stra in D747 is not related to known plant pathogens ; t herefore , adverse effects to aquatic plants are not anticipated. :

2. Environmental Fate Data

The information provided to support uses and application methods that are presented on EPA

approved labels was sufficient to satisfy the Tier I nontarget organism data requirements and for nontarget organism risk asse ssment for B. amyloliquefaciens strain D747 ; f urther testing at higher tier levels (i.e., Tiers II, III, and IV ) is not required.

3

. Threatened and Endangered Species Assessment

Since EPA has determined that no effects are anticipated for any nontarget species exposed to B. amyloliquefaciens strain D747 as a result of applications made in accordance with EPA

approved labels , effects to federally listed threatened and endangered species and their designated critical habitats are also not expected. Therefore, a “No Effect” determination is made for direct and indirect effects to listed spe cies and their designated critical habitats resulting from the approved uses of B. amyloliquefaciens strain D747

.

V. ENVIRONMENTAL JUSTICE

EPA seeks to achieve environmental justice

— the fair treatment and meaningful involvement of all people regardless of race, color, national origin, or income

— with respect to the development, implementation, and enforcement of environmental laws, regulations, a nd policies. Fair treatment means that no group of people, including racial, ethnic, or socioeconomic groups, should bear a disproportionate share of the negative environmental consequences resulting from industrial, municipal, and commercial operations or the execution of federal, state, local, and tribal environmental programs and policies. Meaningful involvement means that (1) potentiallyBacillus amyloliquefaciens strain D747 Page 15 of 30 Biopesticides Registration Action Document

affected community residents have an appropriate opportunity to participate in decisions about a

propose d activity th at will affect their environment and/or health; (2) the public’s contribution can influence the regulatory agency’s decision; (3) the concerns of all participants involved will

be considered in the decision

- making process; and (4) the decision

- makers seek out and facilitate the involvement of those potentially affected. EPA has this goal for all communities and persons

across the United States.

EPA sought information on any groups or segments of the population who, as a result their location, cultural pra ctices, or other factors, may have atypical, unusually high exposure to B. amyloliquefaciens strain D747 , compared to the general population. No public comments were received on this particular matter

.

For additional information regarding environmental justice issues, please visit EPA’s web site at http://www.epa.gov/compliance/environmentaljustice/index.html

.

V I

. RISK MANAGEMEN T DECISION

Section 3(c)(5) of FIFRA permits for the registration of a pesticide provided that all the following determinations are made:

(1) Its composition is such as to warrant the propose d c laims for it; (2) Its labeling and other material required to be submitted comply with the requirements of FIFRA; (3) It will perform its intended function without unreasonable adverse effects on the environment; AND (4) When used in accordance with widespread and commonly recognized practice , it will not generally cause unreasonable adverse effects on the

environment.

To satisfy criterion 1, the B. amyloliquefaciens strain D747 pesticide products have well

- known properties. EPA has no knowledge that would contradict the claims made fo r these products

, the

CX

- 9030 and CX

- 9032 EP label s, and we have concluded that such products are not expected to

cause unreasonable adverse effects on the environment when used according to the label instructions. Criterion 2 is satisfied by the current p roduct label s, as well as the data and

information presented in this document. It is believed that the B. amyloliquefaciens strain D747 pesticide products will not cause any unreasonable adverse effects on the environment, and CX

9030 and CX

- 9032 (end

- use pesticide product) , in particular, are likely to provide protection against fungal and bacterial pests as claimed, satisfying criterion 3. Criterion 4 is satisfied in that

the B. amyloliquefaciens strain D747 pesticide products are not expected t o cause unreasonable adverse effects when used according to label instructions. Therefore the end

- use products

, CX

9030 and CX

- 9032, containing B. amyloliquefaciens strain D747 as a new active ingredient, are eligible for registration under FIFRA section 3(c)(5) for the labeled uses. Should uses that are

more extensive be propose d in the future (e.g., aquatic uses), EPA will likely require that

additional data be submitted.Bacillus amyloliquefaciens strain D747 Page 16 of 30 Biopesticides Registration Action Document

V I I

. ACTIONS REQUIRED BY THE REGISTRANT

A. Final Printed Labeling

Before releasing pesticide products containing B. amyloliquefaciens strain D747 for shipment, the registrant is required to provide appropriate final printed labeling to EPA prior to shipment of product

.

B. Terms of Registration

As a term of the registration CX

- 9032 EP, the registrant must submit the follo wing data within one year of th is product ’ s registration:

(1) Storage Stability (OCSPP Guideline 830 .6317) and Corrosion Characteristics (OCSPP Guideline 830.6320) : The results of a one

- year storage stability and corrosion characteristics study.

C . Reporting of Adverse Effects and Hypersensitivity Incidents

Notwithstanding the information stated previously , it should be clearly understood that certain specific data are required to be reported to EPA as a requirement for maintaining the federal registration for a pesticide product. A brief summary of these types of data are described below.

Reports of all i ncidents of adverse effects to the environment must be submitted to EPA under the provisions stated in FIFRA section 6(a)(2). Additionally, all incidents of hypersensitivity (including both suspected and confirmed incidents) must be reported to EPA under t he provisions of 40 CFR § 158.2140(d).

VIII. GLOSSARY OF ACRONYMS AND ABBREVIATIONS

ASAE American Society of Agricultural Engineers

BPPD Biopesticides and Pollution Prevention Division

BRAD Biopesticides Registration Action Document

CFR Code of Federal Regulations

CFU colony

- forming unit (s) cfu/kg colony

- forming units per kilogram

cfu/mL colony

- forming unit s per milliliter

cP centipoise

EDSP Endocrine Disruptor Screening Program

EP end

- use product

EPA Environmental Protection Agency (the “Agency”)

FFDCA Federal Food, Drug, and Cosmetic Act

FIFRA Federal Insecticide, Fungicide, and Rodenticide Act FQPA Food Quality Protection Act

FR Federal Register g/ mL gram per milliliter

LC 50 median lethal concentration. A statistically derived concentration of a

su bstance that can be expected to cause death in 50% of test animals. It isBacillus amyloliquefaciens strain D747 Page 17 of 30 Biopesticides Registration Action Document

usually expressed as the weight of substance per weight or volume of water, air, or feed (e.g., mg/L, mg/kg, or ppm).

LD 50 median lethal dose. A statistically derived single dose that can be expected to cause death in 50% of the test animals when administered by the route indicated (oral, dermal, or inhalation). It is expressed as a weight of substance per unit weight of animal (e.g., mg/kg). mg/kg milligram s per kilogram

mg /L milligram s per liter

MP manufacturing

- use product

mPa·s milliPascal

- second

, term used as the unit of dynamic viscosity

. MRID No. Master Record Identification Number

NIOSH National Institute for Occupational Safety and Health

NRRL Northern Regional Research Laboratory

OCSPP Office of Chemical Safety and Pollution Prevention

OPP Office of Pesticide Programs

PC Code Pesticide Chemical Code

PP Pesticide Petition

PPE personal protective equipment

ppm parts per million

TGAI technical grade of the active ingredient

U.S. United StatesBacillus amyloliquefaciens strain D747 Page 18 of 30 Biopesticides Registration Action Document

I X. BIBLIOGRAPHY

A. Studies Submitted to Support Pesticide Product Registrations

48165500 Certis U.S.A., LLC (2010) Submission of Product Chemistry and Toxicity Data in Support of the Application for Registration of CX

- 9032. Transmittal of 6 Studies.

48165501 Chen, C. (2010) Bacillus subtili s Var. amyloliquefaciens Strain D747 (CX

- 9032):

Product Ide ntity, Manufacturing Process, Discussion of Formation of Unintentional Ingredients: Analysis of Samples: Certification of Limits. Unpublished study prepared by Certis USA, LLC. 120 p.

48165502 DeVane, W. (2010) Bacillus subtilis var. amyloliquefaciencs St rain D

- 747 End

- Use Product: Color: Physical State: Odor: Stability to Normal and Elevated Temperatures, Metals, and Metal Ions: Storage Stability of the Liquid Concentrate: Miscibility: Corrosion Characteristics: pH: Viscosity: Bulk Density. Unpublished st udy prepared by Certis USA, LLC. 8 p.

48165503 Simpson, A. (2010) Bacillus subtilis var. amyloliquefaciens Strain D

- 747 End

- Use Product: 830.6317 Storage Stability

- Interim Study Report. Unpublished study prepared by Certis USA, LLC. 6 p.

48165504 Dively, C. (2010) Bacillus subtilis var. amyloliquefaciens Strain D747: CX

- 9032: Acute Oral Toxicity: Acute Dermal Toxicity: Acute Inhalation Toxicity: Hypersentivity (Sic). Unpublished study prepared by Certis USA, LLC. 6 p.

48165505 Kuhn, J. (2010) Baci llus subtilis CX

- 9032: Acute Eye Irritation Study in Rabbits: Final Report. Project Number: 14046/10. Unpublished study prepared by Stillmeadow, Inc. 17 p.

48165506 Kuhn, J. (2010) Bacillus subtilis CX

- 9032: Acute Dermal Irritation Study in Rabbits: Final Report. Project Number: 14047/10. Unpublished study prepared by Stillmeadow, Inc. 11 p.

48165700 Certis U.S.A., L.L.C. (2010) Submission of Product Chemistry and Toxicity Data in Support of the Pet ition for Tolerance of Bacillus subtilis var. amyloliquefaciens and the Application for Registration of CX

- 9030. Transmittal of 17 Studies.

48165701 Chen, C. (2010) Bacillus subtilis var. amyloliquefaciens Strain D747: (CX

- 9030): Product Identity: Manufac turing Process: Discussion of Formation of Unintentional Ingredients: Analysis of Samples: Certification of Limits. Unpublished study prepared by Certis USA, LLC. 145 p.

48165702 DeVane, W. (2010) Bacillus subtilis var. amyloliquefaciens Strain D

- 747 End

- Use Product (ID Code CX

- 9030): Product Properties: Color: Physical State: Odor: Stability to Normal and Elavated Temperatures, Metals, and Metal Ions: Storage Stability of the TGAI: Miscibility: Corrosion Characteristics: pH: Viscosity: Bulk Density. Unpub lished study prepared by Certis USA, LLC. 10 p.

48165703 Simpson, A. (2010) Bacillus subtilis var. amyloliquefaciens Strain D

- 747 End

- Use Product (ID Code CX

- 9030): Microbial Pesticide Data Requirements: 830.6317 Storage Stability. Unpublished study prepa red by Certis USA, LLC. 6 p.

48165704 Onishi, Y. (2003) Bacillus subtilis var. amyloliquefaciens Strain D747: D747 Single Oral Administration Toxicity Study in Rats: Acute Oral Toxicity/Pathogenicity: FinalBacillus amyloliquefaciens strain D747 Page 19 of 30 Biopesticides Registration Action Document

Report. Project Number: B030504. Unpublished study prepared by Mitsubishi Chemical Safety Institute, Ltd. 25 p.

48165705 Onishi, Y. (2003) Bacillus subtilis var. amyloliquefaciens Strain D747: D747 Single Intravenous Administration Toxicity in Rats: Acute Injection Toxicity/Pathogenicity: Final Repo rt. Project Number: B030506. Unpublished study prepared by Mitsubishi Chemical Safety Institute, Ltd. 29 p.

48165706 Onishi, Y. (2003) D747 Single Endotracheal Administration Toxicity Study in Rats: Acute Pulmonary Toxicity/Pathogenicity: Final Report. Pr oject Number: B030505. Unpublished study prepared by Mitsubishi Chemical Safety Institute, Ltd. 29 p.

48165707 Kuhn, J. (2010) Acute Oral Toxicity Study (UDP) in Rats: Bacillus subtilis CX

- 9030: Final Report. Project Number: 13847/10. Unpublished study pr epared by Stillmeadow, Inc. 11 p.

48165708 Kuhn, J. (2010) Acute Dermal Toxicity Study in Rats: Bacillus subtilis CX

- 9030: Final Report. Project Number: 13848/10. Unpublished study prepared by Stillmeadow, Inc. 12 p.

48165709 Doig, A. (2010) Acute Inhala tion Toxicity Study in Rats: Bacillus subtilis Cx

- 9030: Final Report. Project Number: 13820/10. Unpublished study prepared by Stillmeadow, Inc. 18 p.

48165710 Kuhn, J. (2010) Acute Eye Irritation Study in Rabbits: Bacillus subtilis CX

- 9030: Final Report. Project Number: 13821/10. Unpublished study prepared by Stillmeadow, Inc. 16 p.

48165711 Kuhn, J. (2010) Acute Dermal Irritation Study in Rabbits: Bacillus subtilis CX

- 9030: Final Report. Project Number: 13822/10. Unpublished study prepared by

Stillmeadow , Inc. 11 p.

48165712 Hubbard, P.; Beavers, J. (2010) Bacillus subtilis CX

- 9025: An Acute Oral Toxicity Study with the Northern Bobwhite. Project Number: 671/102. Unpublished study prepared by Wildlife International, Ltd. 33 p.

48165713 Cockroft, R. (200 4) Freshwater Fish Toxicity/Pathogenicity (Prolonged Toxicity to Microbial Pesticides to Fish) (Oncorhynchus mykiss): Bacillus subtilis var. amyloliquefaciens Strain D747: Final Report. Project Number: KCI/275/042551. Unpublished study prepared by Huntingd on Life Sciences, Ltd. 37 p.

48165714 Cockroft, R. (2010) (Prolonged Toxicity of Microbial Pesticides to Daphnia magna): Freshwater Invertebrate Toxicity/Pathogenicity: Bacillus subtilis var. amyloliquefaciens Strain D747: Final Report. Project Number: KC I/276/042552. Unpublished study prepared by Huntingdon Life Sciences, Ltd. 51 p.

48165715 Takagaki, M. (2004) Bacillus subtilis var. amyloliquefaciens Strain D747: Non

Target Plant Test: Final Report. Unpublished study prepared by Kumiai Chemical Industry Co. 13 p.

48165716 Dively, C. (2002) Bacillus subtili s var. amyloliquefaciens Strain D747: Non

- Target Insect Testing: Final Report. Unpublished study prepared by Japan Plant Protection Assoc. Research Institute. 17 p.Bacillus amyloliquefaciens strain D747 Page 20 of 30 Biopesticides Registration Action Document

48165717 Dively, C. (2003) Bacillus subtilis var. amyloliquefaciens Strain D747: An Acute Dietary Pathogenicity and Toxicity Study with the Honey Bee (Apis mellifera): Final Report. Unpublished study prepared by Life Science Research Institute. 5 p.

48621501 Dively, C. (2011) Bacillus subtilis var. Amyloliquefaciens Strain D747: Avian Oral Toxicity/Pathogenicity (in Northern Bobwhites): Addendum to MRID 48165712. Unpublished study prepared by Certis USA, LLC. 10p.

48621502 Dimock, M. (2011) Bacillus subtilis var. amyloliquefaciens Stra in D747: Non

- Target Insect Testing: Addendum to MRID 48165716. Unpublished study prepared by Certis USA, LLC. 20p.

48621503 Dively, C. (2011) Bacillus subtilis var. a myloliquefaciens Strain D747: Acute Dietary Pathogenicity and Toxicity Study with the Hon ey Bee (Apis mellifera): Addendum to MRID 48165717. Unpublished study prepared by Certis USA, LLC. 9p.

B. Environmental Protection Agency Risk Assessment Memoranda and Other Documents

U.S. EPA. 2004. Primer for Municipal Wastewater Treatment Systems. EPA 832

- R

- 04

- 001.

Available from http://www.epa.gov/npdes/pubs/primer.pdf

.

U.S. EPA. 1996. Microbial Pesticide Test Guidelines

– Background for Residue Analysis of Microbial Pest Control Agents (OPPTS 885.2000). Available from http://www.epa.gov/ocspp/pubs/frs/publications/Test_Guidelines/series885.htm

U.S. EPA

. 2010. Bacillus subtilis Case 6012. Final Registration Review Decision; Docket

Number EPA

- HQ

- OPP

- 2007

- 1026

C. Other References

Benitez, LB, et. al. Antimicrobial factor from Bacillus amyloliquefaciens inhibits Paeni B. agent of American foulbrood. Arch. Microbiology August 20, 2010

Centers for Disease Control and Prevention. 2009. Drinking Water

- Water Treatment. Available

from http://www.cdc.gov/healthywater/drinking/public/water_treatment.html

.

Ded j. S., et.al

. Effectiveness of honeybees in delivering the biocontrol agent Bacillus subtilis to blueberry flowers to suppress mummy berry disease. Biol

. Control 31:422

- 427.

European Food SafetyAuthority. 2010. Scientific opinion on the compatibility of Ecobiol (Bacillus amyloliquefaciens CECT 5940) for chickens for fattening with coccidiostats. EFSA

Journal 8: 1918.

Logan, N.A., and P. de Vos. 2009. Genus I. Bacillus, p p. 21

- 128 In: P. de Vos, G.M. Garrity, D. Jones, N.R. Krieg, W. Ludwig, F.A. Rainey, K.H. Schleifer, and W. Whitman (Eds.) Bergey’s Manual of Systematic Bacteriology, Volume 3, 2 nd Ed. Springer, New York.

Maccagnami, B., et. al

. Apis mellifera and Osmia cornuta as carriers for the sec ondary s p read of

Bacillus subtilis on apple flowers. Biocontrol 54: 123

- 133.Bacillus amyloliquefaciens strain D747 Page 21 of 30 Biopesticides Registration Action Document

McClintock, JT., Schaffer, CR., Sjoblad, RD., A comparative review of the mammalian toxicity

of Bacillus thuringensis

- based pesticides. Pestic Sci 1995; 45: pp 95

– 105.

Murray, P

. R

, et al., Manual of Clinical Microbiology

. Washington

, D. C. : ASM Press; 9 th edition, 2007.

Priest, F.G., Goodfellow, M., Shute

, L.A , and Berkeley

, R.C.W. 1987. Bacillus amyloliquefaciens sp. nov., nom. rev. International Journal of Systematic Bacteriology, 37: 69

- 71.

Tanada, Y., and. Kaya

, H.K . 1993. Insect P athology . Academic Press, New York. 666 pages.

Wizna, R. Yose, H.

, Abbas, A.

, Dharma, I.P. Kompiang. 2009. Influence of dietary fermented tapioca by

- products on the performance of br oilers and ducklings. International Journal of Poultry Science 8: 902

- 904.

World Health Organization, Guidelines for Drinking

- water Quality (2011) Fourth Edition

.Bacillus amyloliquefaciens strain D747 Page 22 of 30 Biopesticides Registration Action Document

A PPENDIX A. MICROBIAL PESTICIDES DATA REQUIREMENTS (40 CFR PART 158

– SUBPART V )

TABLE 1

. Product Analysis Data Requirements for the End

- Use Product ( E P), CX

- 9030 (40 CFR § 158.2120)

OCSPP Guideline

Number Data Requirement Results MRID No.

885.1 1 00 Product Identity Submitted data fulfill the requirement for product identity

. CX

- 9030 contain s 25.0% by weight Bacillus amyloliquefaciens strain strain D747 (minimum of 5 x 10 1 0 CFU/g) 481655

- 01

CSF dated

10/18/2011

885.1200 Manufacturing Process Submitted data fulfill the requirement for manufacturing process. 481655

- 01

Not applicable Deposition of a Sample in a Nationally Recognized

Culture Collection Submitted data fulfill the requirement for deposition. Culture on deposit under Accession

Number NRRL B

- 50405. 481655

- 01

885.1300 Discussion of Formation of

Unintentional Ingredients Submitted data fulfill the requirement for

discussion of formation of unintentional ingredients. 481655

- 01

885.1400 Analysis of Samples Submitted date fulfill the requirement for analysis of samples

. 481655

- 01

885.1500 Certification of Limits Limits listed on the confidential statement of formula are adequate/acceptable CSF dated

10/18/2011

Additional Studies

830.1800 Enforcement Analytical

Method Submitted data fulfill the requirement for an enforcement analytical method 481655

- 01

TABLE 2 . Product Analysis Data Requirements for the End

- Use Product (EP), CX

- 9032 (40 CFR § 158.2120)

OCSPP Guideline

Number Data Requirement Results MRID No.

885.1 1 00 Product Identity Submitted data fulfill the requirement for product identity

. CX

- 9030 contain s 98.95% by weight Bacillus amyloliquefaciens strain strain D747 (minimum of 1 x 10 1 0 CFU/g) 481655

- 01

CSF dated

10/18/2011

885.1200 Manufacturing Process Submitted data fulfill the requirement for manufacturing process. 48165 7

- 01

481655

- 01 Not applicable Deposition of a Sample in a Nationally Recognized

Culture Collection Submitted data fulfill the requirement for deposition. Culture on deposit under Accession

Number NRRL B

- 50405. 48165 7

- 01

481655

- 01

885.1300 Discussion of Formation of Unintentional Ingredients Submitted data fulfill the requirement for

discussion of formation of unintentional ingredients. 48165 7

- 01

481655

- 01

885.1400 Analysis of Samples Submitted date fulfill the requirement for analysis of samples

. 481655

- 01

48165 7

- 01

885.1500 Certification of Limits Limits listed on the confidential statement of formula are adequate/acceptable CSF dated

10/18/2011

Additional Studies

830.1800 Enforcement Analytical

Method Submitted data fulfill the requirement for an enforcement analytical method 481655

- 01Bacillus amyloliquefaciens strain D747 Page 23 of 30 Biopesticides Registration Action Document

TABLE 3

. Physical and Chemical Characteristics for the Technical Grade of the Active Ingredient (TGAI ) Bacillus

. amyloliquefaciens strain strain D747 / CX

- 90 30 (EP)

. (40 CFR § 158.2120)

OCSPP

G uideline

N umber Data Requirement Results MRID No.

TGAI CX

- 90 30 ( E P )

830.6302 Color Beige Not Applicable 481657

- 02

830.6303 Physical State Fine powder Not applicable 481657

- 02

830.6304 Odor Yeast odor Not applicable 481657

- 02

830.6313 Stability to Normal and E levated Temperatures, Metals,

and Metal I ons Spores inactivated at

54 o C Not applicable 481657

- 02

830.6314 Oxidation/Reduction:

Chemical In compatibility Not applicable, the product does not contain oxidizing or reducing agents 481657

- 02

830.6315 Flammability Not applicable, the product does not contain flammable ingredients 481657

- 02

830.6316 Explodability Not applicable, the product does not contain explosive ingredients 481657

- 02

830.6317 Storage Stability Stable up to one year at 25 o C without loss of viability

. 481657

- 02

481657

- 03

830.6319 Miscibility Not applicable, the product is not an emulsifiable liquid. (refer to test note #2 of 40 CFR § 158.2120(d)). 481657

- 02

830.6320 Corrosion Characteristics Not applicable, the product is a powder

. 481657

- 02

830.6321 e Dielectric Breakdown Voltag e Not applicable, the product is not for use around electrical equipment 481657

- 02

830.7000 pH 6.5

– 7.0 (1% w/w) 7.5

- 8.0 481657

- 02

830.7100 Viscosity Not applicable

, the product is a powder. Not Applicable.CX

- 9030 is not a liquid. 481657

- 02

830.7300 Density/Relative Density/Bulk Density (Specific Gravity) 0.307

- 0.375 g/ml 0.60

- .0.78 g/ cm 3 481657

- 02Bacillus amyloliquefaciens strain D747 Page 24 of 30 Biopesticides Registration Action Document

TABLE 4

. Physical and Chemical Characteristics for CX

- 90 32 (EP)

. (40 CFR § 158.2120)

OCSPP

G uideline

N umber Data Requirement Results MRID No.

TGAI CX

- 90 30 ( EP)

830.6302 Color Beige Light brown 48165 5

- 02

830.6303 Physical State Fine powder Liquid 48165 5

- 02

830.6304 Odor Yeast odor Yeast odor 481655

- 02

830.6313 Stability to Normal

& E levated Temperatures, Metals,

& Metal I ons Spores inactivated at 54 o C

. . 48165 5

- 02

830.6317 Storage Stability Stable up to one year at

25 o C without loss of viability Stable up to 78 days at 25 o C without loss of viability

. As a term of the registration, EPA

is requir ing submission of the

results of a one

- year storage stability and c orrosion characteristics study be submitted within one year. 48165 5

- 02

830.6319 Miscibility Not applicable; product is not an emulsifiable liquid. (refer to test note #2 of 40 CFR § 158.2120(d)). 48165 5

- 02

830.6320 Corrosion Characteristics Not applicable ; product is a powder

. None evident to polyethylene packaging after 78 days. As a

term of the CX

- 9032 (EP) registration, EPA is requir ing

submission of the results of a

one

- year storage stability &

c orrosion characteristics within one year. 48165 5

- 02

830.7000 pH 6.5

– 7.0 (1% w/w) 4.2

- 4.3 (1% w/w). 48165 5

- 02

830.7100 Viscosity Not applicable

, the product is a powder. 4.6

- 16. 0 milliPascal

- second
( mPa s ) at 25 o C 481655

- 02

830.7300 Density/Relative Density/Bulk Density

(Specific Gravity) 0.307

- 0.375 g/ml 1.02

– 1.03 g/mL 48165 5

- 02Bacillus amyloliquefaciens strain D747 Page 25 of 30 Biopesticides Registration Action Document

T ABLE 5

. Toxicology Data Requirements for the Technical Grade of the Active Ingredient (TGAI) (40 CFR § 158.2140)

OCSPP Guideline

N umber Data Requirement Results MRID N o.

TGAI

Tier I

885.3050 Acute Oral Toxicity/Pathogenicity No evidence of infectivity, pathogenicity or toxicity was found

from oral administration of 1.0x10 8 CFU Bacillus amyloliquefaciens strain D747 to rats. Clearance from fecal material occurred by day 14 and no viable organisms were
recovered from blood or any other organ or tissue

. Classification: Acceptable 481657

- 04

885.3150 Acute Pulmonary Toxicity/Pathogenicity No evidence of infectivity, pathogenicity or toxicity was found

from intratracheal administration of 1.0x10 7 spores B

. amyloliquefaciens strain D747 to rats.

Classification: Acceptable 481657

- 06

885.3200 Acute Injection Toxicity/Pathogenicity (Intravenous) N ot toxic, infective, and/or pathogenic to rats when dosed intravenously at 1.0x10 7 spores per animal

. Classification: Acceptable 481657

- 05

885.3400 Hypersensitivity

Incidents No hypersensitivity incidents, including immediate

- type or delayed

- type reactions of humans and domestic animals that

occurred durin g research, development, or testing of the

TGAI /MP , were reported

. F uture hypersensitivity incidents must be repor ted (For reporting format: OCSPP Guideline 885.3400 )

. 479450

- 23

885.3500 Cell Culture Not required

. B

. amyloliquefaciens strain D747 is not a virus (Test note #4 of 40 CFR § 158.2140(d)).

Tiers II and III Not required for Bacillus amyloliquefaciens strain D747 based on the lack of acute toxicity/pathogenicity in the Tier I studies.Bacillus amyloliquefaciens strain D747 Page 26 of 30 Biopesticides Registration Action Document

TABLE 6 . Toxicology Data Requirements for the End

- Use Product (EP), CX

- 9030 (40 CFR § 158.2140)

OCSPP Guideline Number Data Requirement Results MRID No.

885.3400 Hypersensitivity Incidents No hypersensitivity incidents, including

immediate

- type or delayed

- type
reactions of humans and domestic

animals that occurred during research, development, or testing of the EP, were reported by the applicant. Any future hypersensitivity incidents must be reported per OCSPP Guideline

885.3400.

870.1100 Acute Oral Toxicity Oral LD 50 > 5000 mg/Kg Classification: Acceptable

TOXICITY CATEGORY IV 481657

- 07

870.1200 Acute Dermal Toxicity Dermal LD 50 > 5050 mg/Kg
Classification: Acceptable

TOXICITY CATEGORY IV 481657

- 08

870.1300 Acute Inhalation Toxicity Inhalation LC 50 > 2.18 mg/ L
Classification: Acceptable

TOXICITY CATEGORY I V 481657

- 09

870.2400 Acute Eye Irritation The maximum average irritation score of

18.3 obtained 1 hour after treatment declined to 17.33 after 24 hours, 2 after 48 hours and 0 after 72 hours following

ocular administration of 0.1 mL B

. amyloliquefaciens strain D747 to New

Zealand White rabbits in a 72 hour observation period. Classification: Acceptable

TOXICITY CATEGORY III 481657

- 10

870.2500 Primary Dermal Irritation No evidence of irritation was found from dermal administration of 500 mg B

. amyloliquefaciens strain D747 CX

- 9030 to rabbits during the 4 hour exposure and

72 observation period s . The dermal

irritation score for B

. amyloliquefaciens

strain D747 CX

- 9030 was 0.00. Classification: Acceptable

TOXICITY CATEGORY IV 481657

- 11Bacillus amyloliquefaciens strain D747 Page 27 of 30 Biopesticides Registration Action Document

TABLE 7 . Toxicology Data Requirements for the End

- Use Product (EP), CX

- 9032 (40 CFR § 158.2140)

OCSPP Guideline Number Data Requirement Results MRID No.

885.3400 Hypersensitivity Incidents No hypersensitivity incidents including

immediate

- type or delayed

- type reactions

of humans and domestic animals that occurred during research, de velopment, or testing of the EP were observed or reported

. All hypersensitivity incidents must be reported per OCSPP Guideline

885.3400.

870.1100 Acute Oral Toxicity Waiver request submitted

. Requirement satisfied by submitted MP data. Oral exposure to the MP showed no adverse effects including infectivity

, pathogenicity and toxicity up to the limit

dose. Inert s are exempt from tolerance

. N o additional oral toxicity is expected

from inert s

. Classification: Acceptable 481655

- 04

870.1200 Acute Dermal Toxicity Waiver request submitted

. Requirement adequately addressed by CX

- 9030 EP data as well as, dermal irritation testing

on CX

- 9032

- EP. Dermal toxicity and irritation testing for the CX

- 9030 EP and

dermal irritation data on CX

- 9032 EP showed no adverse effects up to the limit

doses

. No additional dermal toxicity is expected from inert s. Classification: Acceptable 481655

- 04

481655

- 06

4816 55

- 11

481657

- 08

870.1300 Acute Inhalation Toxicity Waiver request submitted

. Pulmonary exposure to the MP showed no adverse effects, including infectivity, pathogenicity or toxicity though slight toxicity lasting 2 days from a 4

- hour

aerosol inhalation administration of 2.18 mg/L, where inert ingredients were also present, was noted in a CX

- 9030 EP study. N o additional toxicity is expected

from th is EP’s inert ingredients

. Classificat ion: Acceptable 481655

- 04

481657

- 06

481657

- 09

870.2400 Acute Eye Irritation The maximum average irritation score of

0.667 at 1 hour after treatment declined to 0 after 24 hours following ocular

administration of 0.1 mL

B

. amyloliquefaciens strain D747 CX

9032 to New Zealand White rabbits ( 72

- hour observation period )

. Classification: Acceptable

TOXICITY CATEGORY I V 481655

- 05Bacillus amyloliquefaciens strain D747 Page 28 of 30 Biopesticides Registration Action Document

TABLE 7 . Toxicology Data Requirements for the End

- Use Product (EP), CX

- 9032 (40 CFR § 158.2140)

OCSPP Guideline Number Data Requirement Results MRID No.

870.2500 Primary Dermal Irritation No irritation occurred from dermal

administration of 0.5 mL undiluted B. amyloliquefaciens strain D747 CX

- 9032

to shaved skin of rabbits during the 4 hour exposure and 72 observation period s . The dermal irritation score for B. amyloliquefaciens strain D747 CX

- 9032

was 0.00.

Classification: Acceptable

TOXICITY CATEGORY I V 481655

- 06

TABLE 8 . Nontarget Organism Toxicity and Environmental Fate Data Requirements for the Technical Grade of the Active Ingredient (TGAI), Bacillus amyloliquefaciens strain D747 (40 CFR § 158.2150)

OCSPP Guideline

Number Data Requirement Results MRID No.

Tier I

885.4050 Avian Oral Toxicity A study showed that B. amyloliquefaciens D747

is not toxic to birds at 8.9 x 10 9 spores/bird. Classification: Supplemental

Scientific rationale is sufficient to conclude that B. amyloliquefaciens D747 is not expected to pose a hazard to birds. Classification: Acceptable 48165712

48621501

885.4100 Avian Inhalation Toxicity/Pathogenicity Not required. B. amyloliquefaciens D747 is not considered to be pathogenic to birds

885.4150 Wild Mammal Toxicity/Pathogenicity Tests required by 40 CFR § 158.2140 are adequate/ appropriate for assessment of hazards

to wild mammals. B. amyloliquefaciens D747 was not infective, toxic or pathogenic to laboratory rats 1.0 x 10 8 CFU/animal 48165704

885.4200 Freshwater Fish Toxicity/Pathogenicity A 30

- day study shows that the LC 50 to rainbow

trout is 8 x 10 10 CFU/L. The NOEC for sublethal

effects is 1.44 x 10 10 CFU/L. Classification: Acceptable 48165713

885.4240 Freshwater Invertebrate Toxicity/ Pathogenicity A 21

- day study shows that the EC 50 to Daphnia

magna based on mortality is 3.7 x 10 10 CFU/L.

The NOEC for sublethal effects is 2.84 x 10 8

CFU/L. Classification: Acceptable 48165714

885.4280 Estuarine/Marine Fish and Invertebrate Testing Not required. B. amyloliquefaciens D747 is not to be applied directly to water and is not expected

to reach estuarine or marine environments in significant quantities.

885.4300 Nontarget Plant Testing A study submitted was determined to be unacceptable ; however, testing is not required

because. B. amyloliquefaciens is not related to known plant pathogens 48165715Bacillus amyloliquefaciens strain D747 Page 29 of 30 Biopesticides Registration Action Document

TABLE 8 . Nontarget Organism Toxicity and Environmental Fate Data Requirements for the Technical Grade of the Active Ingredient (TGAI), Bacillus amyloliquefaciens strain D747 (40 CFR § 158.2150)

OCSPP Guideline

Number Data Requirement Results MRID No.

885.4340 Nontarget Insect Testing Studies with three species of arthropods were

determined to be unacceptable

. Additional scientific rationale was submitted to

show that B. amyloliquefaciens is not expected to be toxic or pathogenic to nontarget insects. Classification: Acceptable 48165716

48621502

885.4380 Honey Bee Testing Two studies showed that B. amyloliquefaciens D747 is not toxic to honey bees. Classification: Supplemental

Additional rationale was sufficient to show that pathogenicity to honey bees is not expected as a result of exposure to B. amyloliquefaciens D747. Classification: Accepta ble 48165717

48621503

Tiers II, III, and IV

Not required for Bacillus amyloliquefaciens strain D747 based on the current uses and application methods

.Bacillus amyloliquefaciens strain D747 Page 30 of 30 Biopesticides Registration Action Document

APPENDIX B. PESTICIDE PRODUCTS

TABLE 9 . Table Title?

EPA Registration

Number Registration

Name Percentage

Active Ingredient Formulation Type Use Site(s) Method(s)

of Application Application

Rate Target Pest

70051

- 107 CX

- 9032 98.35% End Use

– Aqueous Suspension Various agricultural

and greenhouse crops (e.g., vegetables, tree fruits, berries, grapes and tropical fruit,

tree nuts,
herbs and spices, coffee, tobacco, hops, forestry seedlings ornamentals, and turf) Tractor

mounted boom, airblast,

hose

- end, backpack

and other pressurized

sprayers; fogg ers or mist blowers;

water wheel

and other

drench applicators;

soil injection; aerial; and chemigation with drip or sprinkler irrigation and cutting or root dip Rate listed on

label varies depending on

application

method from

O. 5 pints

/acre to 6 quarts/acre Various fungal and bacterial pests listed

on the label including: Alternaria, Botrytis cinerea Didymella bryoniae

Phoma

cucurbitacearum Erisphe,
Fusarium, Macrophomina phaseoli Monosporascus

cannonballus Peronospora , Phytophthora

Pseudomonas syringae pv. tomato Pseudoperonospora

spp.
Puccinia spp.

Pythium,
Rhizoctonia, Sphaerotheca spp. Verticillium

, spp. Xanthomonas spp.

70051

- 108 CX

- 9030 25.0% Water Dispersible

Granule Various agricultural

and greenhouse crops (e.g., vegetables,

ornamental s
,

and turf) Tractor

mounted

boom, airblast,

hose

- end, backpack

and other pressurized

sprayers; foggers or

mist blowers;

water wheel

and other

drench applicators;

shank or

other soil injection equipment; aerial; and

chemi gation with drip or

sprinkler irrigation and cutting or root dip 0.25

– 3 pounds per

acre Various fungal and bacterial pests listed

on the label including: Alternaria, Botrytis cinerea Didymella bryoniae

Phoma

cucurbitacearum Erisphe
Fusarium, Macrophomina phaseoli Monosporascus

cannonballus

Peronospora, Phytophthora

Pseudomonas syringae pv. tomato Pseudoperonospora

spp.
Puccinia spp.

Pythium, Rhizoctonia, Sphaerotheca spp. Verticillium , spp., Xanthomonas spp.