Data Evaluation Record on the Acute Toxicity of Tebufenozide (Confir"m 2F TEP) to 

Terrestrial Vascular Plants: Seedling Emergence 

------------------------=EP::...;.A MRID Number 485330-01 

Data Requirement: EPA DP Barcode: 

OECD Data Point: 

EPA MRID: 

EPA Guideline: 

0392144 

liA 8.12 (TGAI) and IliA 10.8. 1.1 (EP) 

485330-01 

850.4100 

Test material: Tebufenozide technical endproduct (Confirm 2F) 

Common name 

Purity: 22.84% w/w 

Chemical name: IUPAC 

CAS name: 3,5-dimethylbenzoic acid 1-(l,l-dimethylethyl)-2-( 4-ethylbenzoyl)hydrazide 

CAS No.: 112410-23-8 

Synonyms 

Primary Reviewer: Joan Gaidos Signature: 

Senior Scientist, Cambridge Environmental, Inc. Date: 3/1 5/12 

Primary Reviewer: Andrew Sayer ~~ _k~( Date: 5/10/12 

EP A/OPP/EFED/ERB4 

Secondary Reviewer(s): Thomas Steeger, Ph .D~ $}y Date: 5/ 10/1 2 

EP A/OPP/EFED/ERB4 

EPA PC Code 129026 

Date Evaluation Completed: 5/10/ 12 

CITATION: Porch, J. 2011. Confirm 2F TEP: Toxicity Effects on the Seedling Emergence ofTen Species of Plants. 

Unpublished study performed by Wildlife International, Ltd., Easton, Maryland. Stud) Project Number: 437-120. 

Study sponsored by Nippon Soda Co., Ltd., Chiyoda-ku, Tokyo, Japan. Study completed July 7, 20 II. 

EXECUTIVE SUMMARY: 

The effect oftebufenozide technical end product (Confirm 2F TEP; 22.84% active ingredien1) on the seedling emergence 

ofmonocotyledenous (corn, Zea mays; onion, Allium cepa; ryegrass, Lolium perenne; and wheat, Triticum aestivum) and 

dicotydenous (radish, Raphanus sativus; cabbage, Brassica oleracea; lettuce, Lactuca sativa; sugarbeet, Beta vulgaris; 

soybean, Glycine max; and tomato, Lycopersicon esculentum) crops was studied at a nor:.tinal application rates of 0 

(negative control), 9.6, and 1.91 1bs active ingredient/A (lbs ai/A maximum label rate). 

The measured concentration for onion and tomato was <LOQ ( <0. 18, control), 1.15 and 1.95 lbs ai/ A. The measured 

concentration for all others was <LOQ ( <0.18, control), 0.98 and 1.94 1bs ail A. 

On day 21, the surviving plants per pot were recorded and cut at soil level for measuring the plant height and dry weight. 

Emergence, survival, shoot height, and dry weight per plant were not affected endpoint<; fo r any species tested. The% 

inhibition in seedling emergence in the treated species as compared to the control ranged from -18 to 14% none of which 

were statistically different (a=0.05) from their respective controls. 

The most sensitive monocot and dicot species could not be determined due to lack of a s;gnificant effect of the test 

material, resulting in overall NOAEC and EC25 values for most crops was 1.94 and> 1.94 lbs ai/A, which is equivalent to 

8.51 and >8.51 lb TEP/A. The NOAEC and EC25 values for onion and tomato were 1.95 ;md > 1.95 lbs ai/A which is 

equivalent to 8.55 and >8.55 lb TEP/A. 

Page I of 17 
Data Evaluation Rec:ord on the Acute Toxicity of Tebufenozide (Confirm 2F TEP) to 

Terrestrial Vascular Plants: Seedling Emergence 

EPA MRID Number 485330-01 

Phytotoxic effects observed in the treatment group tested included necrosis, chlorosis, and leaf curl. These effects did not 

appear to be treatment reli.lted. 

Maximum Labeled Rate: I.9l lb ai/A 

Results Synopsis 

Monocot 

EC5o/IC50: >1.94/ 1.95 lbs ai/A 

ECzs/IC25: > 1.94/1.9:5 lbs ail A 

ECos/lC05: > 1.94/ 1.9:5 lbs ai/A 

NOAEC: 1.94/ 1.95 lbs ai/A 

95% C.l.: N/A 

95% C.l.: N/A 

95% C.I.: N/A 

Slope: N/A 95% C.l.: N/A 

Most sensitive monocot: Could not be determined 

Most sensitive parameter: Could not be determined 

Dicot 

ECsofiCso: >1.94/ 1.9:5 lbs ai/A 

ECzs/IC25: > 1.94/ 1.9:5 lbs ail A 

EC05/IC05: > 1.94/1.95 lbs ai/A 

NOAEC: 1.94/ 1.95 lbs ai/A 

95% C.I.: N/A 

95% C.l.: N/A 

95% C.I.: N/A 

Slope: N/A 95% C.l.: N/A 

Most sensitive dicot: Could not be determined 

Most sensitive parameter: Could not be determined 

This toxicity study is classified as ACCEPT ABLE and is consistent with the guideline recommendations for a Tier I 

seedling emergence toxicity study. 

I. MATERIALS AND M ETHODS 

GUIDELINE FOLLOWED: This study was conducted using methods based on procedures specified in the 

U.S. Environmental Protection Agency Series 850 - Ecological Effects Test 

Guidelines OPPTS Number 850.4 100 and OECD Guideline 208. Deviations 

froth OPPTS 850.4100 were noted: 

I. The physico-chemical properties of the test material were not reported. 

COMPLIANCE: 

This deviation did not have an impact on the acceptability of the study. 

Signed and dated GLP, Quality Assurance and Data Confidentiality statements 

were provided. This study was conducted in compliance with the Good 

Laboratory Practice Standards as published by the U.S. Environmental 

Protection Agency, 40 CFR Part 160 (1989); OECD Principles of GLP 

(ENY/MC/CHEM (98) 17); and Japan MAFF (II NohSan, Notification No. 

6283, Agricultural Production Bureau, 1999), with the following exception: 

• Periodic analyses of well water and soil for potential contaminants 

were not performed in accordance with GLP standards, but were 

performed using a certified laboratory and standard U.S. EPA 

Page 2 of 17 
Data Evaluation Record on the Acute Toxicity of Tebufenozide (Confirm 2F TEP) to 

Terrestrial Vascular Plants: Seedling Emergence 

A. MATERIALS: 

l. Test Material 

Description: 

Lot No./Batch No. : 

Purity: 

Stability of compound 

under test conditions: 

Storage conditions of 

test chemicals: 

analytical methods. 

Tebufenozide technical endproduct (Confmn 2F; TEP) 

Liquid 

HIIALOOl (Lot no.) 

22.84%w/w 

Analytical verification performed on control and treatment solution samples 

collected prior to and following application (June 29, 2011) yielded an 

recoveries of93-l 01% of the nominal test concen1ration. No further analysis 

was conducted on subsequent dates, and the stability of the test material could 

not be verified. 

(OECD recommends chemical stability in water and light) 

The test material and analytical standard were stored at room temperature. 

Table 1 lists the chemical physical properties oftebufenozide. 

T a e bl 1 . Ph IYStca . 1/ c h . I emtca properttes o fT e u b fi enozt "d e . 

Parameter Values Comments 

Water solubility 0.83 ppm DP Barcode 

D226011 

Vapor pressure 2.25 X 1 0"8 mm Hg 

DP Barcode 

D226011 

UV absorption Not reported --

pK. Not reported -

log K0w 4.25 DP Barcode 

D226011 

2. Test organism: 

Monocotyledonous (monocot) species: Com (Zea mays, Poaceae; Jarvis Golden Prolific), Onion (Allium cepa, 

Liliaceae; Yellow Granex Hybrid 33), Ryegrass (Lolium perenne, Poaceae; Gator 3 Perennial), and Wheat 

(Triticum aestivum, Poaceae; Glenn Hard Red Spring); EPA recommends four monocots in two families, 

including corn. 

Dicotyledonous (dicot) species: Radish (Raphanus sativus, Brassicaceae; Cherry Belle), Cabbage 

(Brassica oleracea, Brassicaceae; Late Flat Dutch), Lettuce (Lactuca sativa, Asteraceae; 

Summertime), Sugarbeet (Beta vulgaris, Chenopodiaceae; Beta 4609R), Soybean (Glycine max, 

Page 3 of 17 
Data Evaluation Reeord on the Acute Toxicity of Tebufenozide (Confirm 2F TEP) to 

Terrestrial Vascular Plants: Seedling Emergence 

EPA MRID Number 485330-01 

Fabaceae; Maverick), and Tomato (Lycopersicon esculentum, Solanaceae; Rutgers); EPA recommends 

six dicots infour.families, including soybean and a root crop. 

OECD recommends a minimum of three species selected for testing, at least one from each of the following categories: 

Category 1: ryegrc.1ss, rice. oat, wheat, and sorghum; Category 2: mustard, rape, radish, turnip, and Chinese cabbage; 

Category 3: vetch, mung bean, red clover, fenugreek, lettuce, and cress. 

Seed source: w;1eat obtained from Johnny's Selected Seeds, Winslow, ME; onion obtained from Park Seed 

Co., Greenwood, SC; ryegrass, radish, cabbage, and tomato obtained from The Meyer Seed Co., Baltimore, 

MD; lettuce obtained fi·om Territorial Seed Co., Cottage Grove, OR; com obtained from New Hope Seed Co., 

Bon Aqua, TN; sugarbeet obtained from Betaseed, Inc., Tangent, OR; and soybean obtained from Missouri 

Foundation Seeds, Columbia, MO. 

Prior seed treatment/sterilization: Seeds were not treated with fungicides, insecticides, or repellents prior to 

test initiation. 

Historical % gt:rmination of seed: Com, 100%; onion, 98%; ryegrass, 90%; wheat, 94%; radish, 85%; 

cabbage, 85%; kttuce, 98%; sugarbeet, 97%; soybean, 94%, and tomato, 80%. 

Seed storage, if any: None reported 

B. STUDY DESIGN: 

1. Experimental Conditions 

a. Limit test None. 

b. Range-finding study No range-finding study was reported. 

c. Definitive Study 

T a bl e 2 : E xperimental >arameters - See dl ing E mergence. 

Parameters Seedling Emergence 

Details Remarks 

-------------- ----------------------------------- - Criteria 

·- Duration of the test 21 days 

-------- ------------------------------------------ Recommended test duration is 14-21 days. 

OECD recommends that the test be terminated no 

sooner than 14 days after 50 percent of the control 

seedlings have emerged 

Page 4 of 17 
Data Evaluation Record on the Acute Toxicity of Tebufenozide (Confirm 2F TEP) to 

Terrestrial Vascular Plants: Seedling Emergence 

Parameters 

Number of 

seeds/plants/species/ 

replicate 

Number of replicates 

Control: 

Adjuvant control: 

Treated: 

Test concentrations 

Nominal: 

Measured: 

Method and interval of 

analytical verification 

LOQ: 

LOD: 

EPA MRID Number 485330-01 

Seedling Emergence 

Details 

l 0 seeds per replicate 

4 

N/A 

4 

Remarks 

Criteria 

Ten seeds per replicate should be used. 

OECD recommend.~ a minimum of jive seeds planted 

in each replicate within 24 hours of incorporation of 

the test substance. All seeds of each species for each 

test should be of the san··e size class. The seed should 

not be imbibed. 

Four replicates per do.w should be used. 

OECD recommends a mfnimum of four replicates per 

treatment 

0 (negative control), 0.96 and 1.91 

lbai/A Five test concentrations should be used with a dose 

0 (negative control), 4.20 and 8.36 range of2X or 3Xprogression 

lb fonnulation/A 

OECD recommends three concentrations, preforably 

with application rates equivalent to 0.0 (control), 1.0, 

Ryegrass, wheat. radish, com, 10.0 and 100 mg substa:1ce per kg of oven-dried soil. 

sugarbeet. soybean, lettuce, and 

cabbage: 

<LOQ (<0.18, control), 0.98 and 

1.94 lbs ail A 

Onion and tomato: 

<LOQ (<0.18, controls), 1.15 and 

1.95 lbs ai/ A 

Samples collected from the control 

and the single treatment level spray 

mixtures were analyzed 

concurrently with calibration 

standards via HPLC with variable 

wavelength detection (234 nm). 

0.18 lbs ai/A 

Set at the lowest analytical standard 

analyzed, 1.0 !Jg ai/ml 

Page 5 of 17 
Data Evaluation Rec;ord on the Acute Toxicity of Tebufenozide (Confirm 2F TEP) to 

Terrestrial Vasculal' Plants: Seedling Emergence 

EPA MRID Number 485330-01 

~~-.mm----a------~----------~~------~--------------------------------~ Parameters 

Adjuvant (type, percentage, 

if used) 

Test container (pot) 

Size/Volume 

Material: 

(glass/polystyrene) 

Growth facility 

Method/depth of seeding 

Test material application. 

Application time including 

the plant growth stage 

Number of application 

Application interval 

Method of application 

Seedling Emergence 

Details 

N/A- none was used 

16 em diameter; 12 em depth 

Plastic 

Greenhouse 

A template was used to indent the 

soil surface. Once the seeds were 

placed in each hole, they were 

covered by depressing the soil 

surface. Com, wheat, and soybean 

were planted at a depth of 20 mm, 

while all other species were planted 

at a depth of 6 mm. 

The test material was applied on the 

soil surface the same day the seeds 

were planted. 

Nl A; single application 

Applied using an overhead DeVries 

Research Tracksprayer equipped 

with a moveable spray nozzle 

suspended 41 em above the soil 

surface. 

Page 6 of 17 

Remarks 

Criteria 

Non~porous containers should be used. 

OECD recommends that non-porous plastic or glazed 

pot be used. 
Data Evaluation Record on the Acute Toxicity ofTebufenozide (Confi1·m 2F TEP) to 

Terrestrial Vascular Plants: Seedling Emergence 

Parameters 

Detai Is of soil used 

Geographic location 

Depth of soil collection 

Soil texture 

pH: 

%sand 

%silt 

%clay 

% organic carbon 

CEC 

Moisture at 1/3 atm (%) 

Details of nutrient medium, 

if used 

Watering regime and 

schedules 

Water source/type: 

Volume applied: 

Interval of application: 

Method of application: 

Any pest control 

method/fertilization, if used 

Test conditions 

Temperature: 

EPA MRID Number 485330-01 

Seedling Emergence 

Details 

NIA; artificial soil 

N/A 

Loamy sand 

85 

6 

9 

6.2 

Not reported 

Not reported 

Not reported 

N/A 

Well water from greenhouse. 

Not reported. 

Every 2 to 8 days. 

The plants were bottom-watered 

using sub-irrigation trays. 

None reported. 

Page 7 of 17 

Remarks 

Criteria 

Soil was a mixture o f kaolinite clay, industrial 

quartz sand, and peat with limestone added. 

A slow-release fertili2·er was added to the soil to 

provide nutrients essential for plant growth. 

Organic matter: 1.2% 

Soil mixes containing sa"'dy loam. loam, or clay loam 

soil with no greater titan 2% organic matter are 

preferable. Glass bfads, rock wool, and 100% acid 

washed sand are not prtferred. 

OECD prefers the soiltc be sieved (0.5 em) to remove 

coarse fragments. Carb.m content should not exceed 

1.5% (3% organic ma•ter). Fine particles (under 

20um) makeup should te between 10 and 20%. The 

recommended pH is betveen 5.0 and 7.5. 

EPA prefers that bottc..m watering be utilized for 

seedling emergence studies so that the chemical is not 

leached out of the soil dttring the test. 
Data Evaluation Reeord on the Acute Toxicity of Tebufenozide (Confirm 2F TEP) to 

Terrestrial Vasculal' Plants: Seedling Emergence 

EPA MRID Number 485330-01 

Parameters Seedling Emergence 

Details Remarks .................................................. 

Criteria 

Photoperiod: 16L:8D EPA prefers that the cold vs warm loving plants be 

Light intensity and quality: Artificial lighting was used to tested in two separate groups to optimize plant 

supplement natural sunlight. growth. 

11.2-16.6 PAR 

OECD prefers that the temperature, humidity and 

Relative humidity: 11.9-93.1% light conditions be suitable for maintaining normal 

growth of each species for the test period. 

Reference chemical (if 

used) N/A 

Name: 

Concentrations: 

Other parameters, if any 

None 

2. Observations: 

Table 3: Observation Parameters- Seedling Emergence 

Parameters Seedling Emergence 

Details Remarks 

Parameters measured (e.g., number - Emergence 

- Survival of germinated seeds, em~rged - Phytotoxicity seedlings, plant height, dry weight -Dry weight or other endpoints) - Height 

Measurement technique for each Emergence, survival, and 

phytotoxicity were parameter detennined visually. 

Height was measured with 

a ruler to the nearest whole 

centimeter from the soil 

surface to the tip of the 

apical meristem or to the 

tip of the tallest leaf. Dry 

weight was taken after the 

shoots of all living 

seedlings in a replicate 

were dried in an oven and 

weighed as a group. 

Observation intervals Emergence was measured 

weekly. Survival, 

Page 8 of 17 
Data Evaluation Record on the Acute Toxicity of Tebufenozide (Confil'm 2F TEP) to 

Terrestrial Vascular Plants: Seedling Emergence 

EPA MRID Number 485330-01 - phytotoxicity, height, and 

dry weight were detennined 

at study tennination. 

Other observations, if any 

None 

Were raw data included? Yes 

Phytotoxicity rating system, if used 0- No effect; Toxicity rating system based on: Frans, R. E. 

10-30- Slight effect; and R. E. Talbert. 1977. Design of Field 

40-60- Moderate effect; Experiments and the Measurement and Analysis 

70-90- Severe effect; of Plant Responses. Pages 15-23 in B. Truelove, 

I 00- Complete effect ed. Research Methods in Weed Science. Southern 

Weed Science Society, Auburn University, 

Alabama. 

II. RESULTS and DISCUSSION: 

A. INHIBITORY EFFECTS: 

1. Seedling Emergence: 

According to the study authors, negative control emergence ranged from 40 to l OOYo. There was no statistical 

difference in emergence for ryegrass, wheat, com, lettuce, and radish as compared to the negative control 

(Table 5a). There was promotion in cabbage at the 1.91 lb ail A treatment level, but inhibition at the 0.96 lb 

ai/ A. Inhibitions in emergence for all other species ranged from 5 to 15%. 

Survival was defined by the study authors as the number survived of the number emerged. Survival in the 

negative control ranged from 86 to 100% (Table 5b ). There was no inhibition or promotion of survival for 

ryegrass, sugarbeet, and cabbage. Inhibitions for all others ranged from 0 to 6%. 

According to the study authors, there was no inhibition or promotion of height for onion, ryegrass, com, 

sugarbeet, cabbage, soybean, lettuce, and tomato (Table Sc) In wheat, there was promotion at 0.96lb ai/A and 

inhibition (1 %) at 1.91 lb ail A. In radish, there was promotion at 0.96 lb ai/A and inhibition (9%) at 1.91 lb 

ail A. Inhibitions for all others ranged from I to 9%. 

There was no inhibition or promotion of dry weight per plant for onion, ryegrass, soybean, and tomato (Table 

Sd). In sugarbeet, there was promotion at 0.96 lb ail A and inhibition (4%) at 1.91 lb ail A. In cabbage, there 

was promotion at 0.96 lb ail A and inhibition (1 %) at l.91 lb ai/A. Inhibitions for all others ranged from 1 to 

12%. 

Based on the study authors' results, the most sensitive monocot species could not br: detennined due to a lack of 

toxicity (although the study authors did not conduct statistical analysis). The most sensitive dicot species was 

lettuce based on the presence of inhibitions of greater than 25% for height and dry weight per replicate. The 

study authors reported that the NOAEC was equal to the highest rate tested and that the EC25 and EC50 values 

exceeded the highest rate tested. 

Phytotoxic effects observed in the plants tested included necrosis, chlorosis, and leaf curl. According to the 

study authors effects observed in the various treatment groups were likely not an effect of the test material. 

Page 9 of 17 
Data Evaluation Re ord on the Acute Toxicity ofTebufenozide (Confirm 2F TEP) to 

Terrestrial Vascular Plants: Seedling Emergence 

EPA MRID Number 485330-01 

B. REPORTED STATISTICS: 

Emergence, survival, dry .veight, and height data were visually analyzed using nominal test concentrations. The study 

authors did not report NOAEC or ECx values. 

T a bl e 4 a: M'd I -stu d IY E rr~e ce 

Mid-study emergence 

Control Onion Whell Com Rye grass Cabbage Soybean Tomato Lettuce Radish Sugarbeet Formulation 

blank 

83 60-100 80-100 70-100 60-90 70-100 80-1 00 60-100 50-100 60- 100 40-80 N/A (40-100) 

T a bl e 4b : PI ant I njury . I d n ex 

Plant Injury Index* 

Control Onion Wheu Com Ryegrass Cabbage Soybean Tomato Lettuce Radish Sugarbeet Formulation 

blank 

0-13 0-20 0-HI 0-9 0 0-1 1 0-10 0-11 0-10 0-25 0-25 N/A 

* 0- No effect: I 0-30- Slight effect; 40-60- Moderate effect; 70-90- Severe effect; I 00- Complete effect 

C. VERIFlCA TIOI\ OF STATISTICAL RESULTS BY THE REVIEWER: 

Analysis was conduc ed using Excel® 2003 and mean-measured test concentrations based on the active 

ingredient. The negative control and the single treatment group were compared using two-sample t-tests 

assuming equal variances when differences between the mean values were greater than 5% (two-tail; a=0.05). 

T a e bl SS ummary o f mo t sensthve parameters b >Y spectes 

Table Sa: Emere:ence (%) Table Sb: Survival(% of planted) 

Species Cntrl Trea t. %Diff Treat %Diff Cntrl Treat. %Diff Treat %Diff 

0.96 1.91 0.96 1.91 

Onion 90.0 82.5 8 77.5 14 93 78 16 75 19 

Corn 82.5 92.5 -12 97.5 -18 83 93 -12 98 -18 

Wheat 95.0 97.5 -3 95.0 0 95 95 0 95 0 

Rye grass 72.5 72.5 0 77.5 -7 73 73 0 78 -7 

Sugar beet 65.0 55.0 15 65.0 0 60 53 13 65 -8 

Lettuce 77.5 85.0 -10 85.0 -10 78 85 -10 83 -6 

Cabbage 90.0 77.5 14 82.5 -8 88 78 11 83 6 

Soybean 95.0 90.0 5 95.0 0 95 88 8 95 0 

Tomato 90.0 77.5 14 77.5 14 90 75 17 78 14 

Radish 75.0 85.0 -13 85.0 -13 75 80 -7 85 -1 3 

T l ble Sc: Shoot length (em) Table Sd: Dry wei ht (me) 

Species Cntrl Treat. %Diff Treat %Diff Cntrl Treat. %Diff Treat % Diff 

0.96 1.91 0.96 1.91 

Onion 17.1 17.7 -4 17.8 -4 24.9 27.1 -9 29.8 -20 

Corn 49.1 49.1 0 52.4 -7 574 530 8 563 2 

Page 10 of 17 
Data Evaluation Record on the Acute Toxicity ofTebufenozide (Confirm 2F TEP) to 

Terrestrial Vascular Plants: Seedling Emergence 

EPA MRID Number 485330-01 

Wheat 44.7 45.3 -1 44.2 1 284 260 8 260 8 

Rye grass 13.8 16.0 -16 14.6 -6 23.0 30.2 ·-32 34.4 -6 

Sugarbeet 14.1 16.0 -13 14.2 -1 232 285 ··23 223 4 

Lettuce 10.6 10.7 -1 11.4 -8 146 131 10 140 4 

Cabbage 13.6 14.7 -8 14.8 -9 306 326 -6 304 1 

Soybean 15.6 16.5 -6 16.6 -6 371 396 -7 383 -3 

Tomato 14.7 19.7 -13 17.8 -2 394 511 -30 449 -14 

Radish 13.1 13.4 -2 11.9 9 315 277 12 280 II 

Control emergence ranged from 65.0-95.0%. Treatment emergence ranged from 55 0-97.5% and 65.0-97.5% for 

treatment levels 0. 96 and I .91 lb ail A, respectively. Emergence ranged from 15% inhibition to 18% promotion. Control 

survival ranged from 60-95%. Treatment survival ranged from 53-95% and 65-98% for treat nent levels 0.96 and l.91lb 

ail A, respectively. Survival ranged from 19% inhibition to 18% promotion. Control length ranged from 10.6-49.1 em. 

Treatment length ranged from l0.7-49.lcm and ll.4-52.4cm for treatment levels 0.96 and 1.91 lb ail A, respectively. 

Length ranged from 9% inhibition to 16% promotion. Control dry weight ranged from 23.0-574.0 em. Treatment dry 

weight ranged from 27.1-530 em and 29.8-563 em for treatment levels 0.96 and 1.91 lb ail A, respectively. Dry weight 

ranged from 12% inhibition to 32% promotion. 

T a bl e 6 a: PI ant I n.1ury . I n d ex 

Plant Injury Index* 

Control Onion Wheat Com Rye grass Cabbage Soybean Tomato Lettuce 

0-13 0-20 0-10 0-9 0 0-11 0-10 0-11 0-10 

* 0- No effect; 10-30- Slight effect; 40-60- Moderate effect; 70-90- Severe effect; 100- Complete effecl 

T a bl e 6b : M'd I -stu d E IY mergence 

Mid-study emergence 

Control Onion Wheat Com 

83 60-100 80-100 70-100 

(40-100) 

Monocot 

ECsollCso: > 1.94/ 1.95 lbs ai/A * 

EC2s/IC2s: > 1.94/ 1.95 lbs ai/A* 

ECosfiCos: > 1.94/ 1.95 lbs ai/A * 

NOAEC: 1.94/1.95 lbs ai/A* 

Ryegrass 

60-90 

Slope: N/A 95% C.l.: N/A 

Cabbage Soybean 

70-100 80-100 

95% C.l.: N/A 

95% C.l.: N/A 

95% C.I.: N/A 

Most sensitive monocot: Could not be determined 

Most sensitive parameter: Could not be determined 

Tomato Lettuce 

60-100 50-100 

Rad ish Sugarbeet Formulation 

blank 

0-2 .5 0-25 N/A 

Radish Sugar beet Formulation 

blank 

60-:00 40-80 N/A 

*For most crops the EC5ofiC50 test concentration was 1.94 lbs ai/A. For tomato and onion 1he ECsofiCso concentration 

was 1.95 Jbs ail A. 

Dicot 

ECso/ICso: > 1.94/ 1.951bs ai/A* 

EC2sfiC2s: > 1.94/ 1.95 lbs ai/A * 

EC0s/IC05: > 1.94/1.95lbs ai/A* 

95% C.l.: N/A 

95% C.I.: N/A 

95% C.l.: N/A 

Page 11 of 17 
Data Evaluation Reeord on the Acute Toxicity ofTebufenozide (Confirm 2F TEP) to 

Terrestrial Vascular· Plants: Seedling Emergence 

EPA MRID Number 485330-01 

NOAEC: 1.94/ 1.95 lbs ail A* 

Slope: N/A 95% C.l.: N/A 

Most sensitive dicot: Could not be determined 

Most sensitive parameter: Could not be determined 

*For most crops the EC IC 0 test concentration was 1.94 lbs ail A. For tomato and onion the EC50/IC50 concentration 

was 1.95 lbs ai/A. 

D. STUDY DEFICIENCIES: 

There was considerable variation in the controls for certain measurement endpoints which likely affecte.d the 

availability of the study to detect treatment effects. This underscores the need to present the actual values and 

percent of controls fo r each of the plants tested. However, even with this deficiency, the data strongly suggests 

there was no much of an effect across the species tested. 

E. REVIEWER'S COMMENTS: 

The reviewer's and the study authors' results were in agreement. The reviewer had difficulty comparing results, 

because the study authors did not conduct statistical analysis or report toxicity values. The study authors visually 

determined that there was no adverse effects on seedling emergence, survival, growth (weight and height), or 

condition of the ten terrestrial plant species tested. There was insufficient data to conduct a regression analysis to 

support the calculation of an ECx value; however, empirically, there did not appear to be a treatment response where 

inhibition was sufficient to support an EC25 and/or EC50. The reviewer's results based on measured concentrations 

are presented in the Executive Summary and Conclusions sections of this DER. 

The study author defi ned survival as the number survived of the number that emerged. The reviewer calculated 

survival based on the 11umber of surviving plants as a proportion of the number planted. The emergence and survival 

data (based on the reviewer's calculations) were not statistically different, indicating that test plants successfully 

emerged and survived similar to controls. Statistically significant differences were not detected for either set of 

survival data. 

The in-life phase of the study was conducted from March 16 to June 13,2011. 

F. CONCLUSIONS: 

This toxicity study is classified as ACCEPTABLE. None of the species tested were significantly affected by the 

technical endproduct oftebufenozide up to the maximum rate tested in this study. The most sensitive monocot and 

dicot species could not be determined due to a lack of an effect of the test material. The variability in the negative 

control emergence ranged from 40-100% making statistical analysis difficult. The resulting overall NOAEC and 

EC50 values for most crops was 1.94 and > 1.94 lbs ail A. The NOAEC and EC50 values for onion and tomato were 

1.95 and >1.95 lbs ai/A. 

Most sensitive monocot and EC25: Could not be determined(> 1.94/ 1.95 lbs ai/A)* 

Most sensitive dicot and EC25: Could not be determined(> 1.94/ 1.95 lbs ai/A)* 

*For most crops the ~st concentration was 1.94 lbs ai/A. For tomato and onion the test concentration was 1.95 Jbs 

ail A. 

III. REFERENCES: 

I. U.S. Environmental Protection Agency. 1996. Series 850 - Ecological Effects Test Guidelines (draft), OPPTS 

Page 12 ofl7 
Data Evaluation Record on the Acute Toxicity of Tebufenozide (Confirm 2F TEP) to 

Terrestrial Vascular Plants: Seedling Emergence 

--------------------- --.;;;;.E~PA~ MlliD Number 485330-01 

Number 850.4100: Terrestrial Plant Toxicity, Tier I (Seedling Emergence). 

2. Frans, Robert E. and Ronald E. Talbert. 1977. Design of Field Experiments and the Measurement and Analysis 

of Plant Responses. Pages 15-23 in B. Truelove, ed. Research Methods in Weea Science. Southern Weed 

Science Society, Auburn University, Alabama. 

3. SAS Institute, Inc. 1999. SAS Proprietary Software Version 8, Cary, NC, SAS institute, Inc. 

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Data Evaluation Record on the Acute Toxicity of Tebufenozide (Confirm 2F TEP) to 

Terrestrial Vascula:r Plants: Seedling Emergence 

EPA MRID Number 485330-01 

APPENDIX I. OUTPUT OF REVIEWER'S STATISTICAL VERIFICATION: 

t-Test: Two-Sample Assuming Equal Variances 

Sugarbeet Emergence· 

Cntrl vs. 0.96 Variable 1 Variable 2 

Mean 65 55 

Variance 300 300 

Observations 4 4 

Pooled Variance 300 

Hypothesized Mean 

Difference 0 

df 6 

t Stat 0.816496581 

P(T <=t) one-tail 0.222707778 

t Critical one-tail 1.943180274 

P(T <=t) two-tail 0.445415555 

t Critical two-tail 2.446911846 

t-Test: Two-Sample A:.suming Equal Variances 

Cabbage Emergence 

Cntrl vs. 0.96 Variable 1 Variable 2 

Mean 90 77.5 

Variance 66.66666667 91.66666667 

Observations 4 4 

Pooled Variance 79.16666667 

Hypothesized Mean 

Difference 0 

df 6 

t Stat 1.986798536 

P(T<=t) one-tail 0.047066383 

t Critical one-tail 1.943180274 

P(T<=t) two-tail 0.094132766 

t Critical two-tail 2.446911846 

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Data Evaluation Record on the Acute Toxicity of Tebufenozide (Confirm 2F TEP) to 

Terrestrial Vascular Plants: Seedling Emergence 

t-Test: Two-Sample Assuming Equal Variances 

Soybean Emergence 

Cntrl vs. 0.96 Variable 1 Variable 2 

Mean 

Variance 

Observations 

Pooled Variance 

Hypothesized Mean 

Difference 

df 

t Stat 

P(T <=t) one-tail 

t Critical one-tail 

P(T<=t) two-tail 

t Critical two-tail 

95 

33.33333333 

4 

so 

0 

6 

1 

0.177958842 

1.943180274 

0.355917684 

2.446911846 

90 

66.66666667 

4 

Page 15ofl7 

EPA MRID Number 485330-01 
Data Evaluation Rc:cord on the Acute Toxicity ofTebufenozide (Confirm 2F TEP) to 

Terrestrial Vascular Plants: Seedling Emergence 

t-Test: Two-Sample Assuming Equal Variances 

Corn Weight 

Cntrl vs. 0.96 Variable 1 

Mean 574 

Variance 6143.333333 

Observations 4 

Pooled Variance 9011.166667 

Hypothesized Mean 

Difference 0 

df 6 

t Stat 0.662955683 

P(T <=t) one-tail 0.265993271 

t Critical one-tail 1.943180274 

P(T <=t) two-tail 0.531986543 

t Critical two-tail 2.446911846 

t-Test: Two-Sample Assuming Equal Variances 

Lettuce Weight 

Cntrl vs. 0.96 Variable 1 

Mean 145.75 

Variance 1454.916667 

Observations 4 

Pooled Variance 809.125 

Hypothesized Mean 

Difference 0 

df 6 

t Stat 0. 733329588 

P(T <=t) one-tail 0.24550255 

t Critical one-tail 1.943180274 

P(T<=t) two-tail 0.4910051 

t Critical two-tai l 2.446911846 

Variable 2 

529.5 

11879 

4 

Variable 2 

131 

163.3333333 

4 

Page 16 of 17 

EPA MRID Number 485330-01 
Data Evaluation Record on the Acute Toxicity of Tebufenozide (Confirm 2F TEP) to 

Terrestrial Vascular Plants: Seedling Emergence 

t-Test: Two-Sample Assuming Equal Variances 

Radish Height 

Cntrl vs. 1.91 Variable 1 

Mean 13.075 

Variance 1.1425 

Observations 4 

Pooled Variance 1.1725 

Hypothesized Mean 

Difference 0 

df 6 

t Stat 1.501953241 

P{T <=t) one-tail 0.091895432 

t Critical one-tail 1.943180274 

P{T <=t) two-tail 0.183790864 

t Critical two-tail 2.446911846 

Variable 2 

11.925 

1.2025 

4 

Page 17 of 17 

EPA MRID Number 485330-01