UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

OFFICE OF CHEMICAL SAFETY 

AND POLLUTION PREVENTION 

September 15, 2015 

MEMORANDUM 

Subject: 

To: 

From: 

Reviewer: 

Through: 

Preliminary Ecological Risk Assessment for Registration Review for 

Bromuconazole (PC Code: 120503; DP Barcode: D427264) 

James Parker, Chemical Review Manager 

Thomas Moriarty, Team Leader 

Neil Anderson, Branch Chief . 

Risk Management and Implementation Branch 1 

Pesticide Re-Evaluation Division (7508P) 

Jose L. Melendez, Chemist p&te.,,.. bc-4-~4 Geoffrey Sinclair, Ph.D., Biologist ,,/,,,.,., 

Environmental Risk Branch 5 ,,__/ 

Environmental Fate and Effects Division (7507P) 

\) 

Allen Vaughan, Biologist 

Environmental Risk Branch 5 

Environmental Fate and Effects Division (7507P) 

Mah T. Shamim, PhD., Branch Chief 

Environmental Risk Branch 5 

Environmental Fate and Effects Division (750 

The Environmental Fate and Effects Division (EFED) has completed an Ecological Risk 

Assessment for Registration Review for bromuconazole. The single registered use of 

bromuconazole is for roses in an enclosed, indoor greenhouse environment with an 

impem1eable roof and floor, and as such, there is a lack of a complete exposure pathway 

from the use site to non-target terrestrial and aquatic organisms. 

In addition to an incomplete exposure pathway based on the use pattern, bromuconazole 

has a low total usage amount nationally, based on information provided by the Biological 

and Economic Analysis Division (BEAD), and a relatively limited geographic use. 

Therefore, EFED has determined that a fu ll ecological risk assessment for bromuconazole 

is not necessary based on de minimis exposure. 
2

This document summarizes the available use, environmental fate, and toxicity data 

submitted for bromuconazole and highlights potential areas of concern or uncertainty for 

the single currently registered use.

Based on the indoor-only use pattern for bromuconazole and EPA's determination that 

when the fungicide is used according to the label there is an incomplete exposure pathway 

and, therefore, no environmental exposure, there is low potential to adversely affect both 

non-listed and listed (endangered species).

The expectation of no exposure, and therefore no risk, to non-target organisms in this 

assessment is based on the presumption that bromuconazole use is limited to indoors, as is 

specified on the label. However, if contaminated potting soil is composted outdoors 

(although bromuconazole should be highly adsorbed to soil) or contaminated water is 

washed out of the greenhouse into surface waters, the assessment might not be protective. 

Therefore, it is recommended that the label state that any potential runoff from 

contaminated potting soil or water discharged from a greenhouse be contained by a 

hydrologically isolated site that does not produce runoff capable of entering any 

irrigation or drainage ditch, canal, or other body of water.

If, in the future, bromuconazole is considered for additional uses that could result in 

environmental releases, further analysis will need to be undertaken to determine potential 

effects to non-target organisms, including listed species and their designated critical 

habitat.
3

1. Executive Summary

The Environmental Fate and Effects Division (EFED) has completed the preliminary

ecological risk assessment as part of the registration review of bromuconazole. As part of 

the implementation of the Registration Review program pursuant to Section 3(g) of FIFRA, 

the Agency evaluates all current and active registrations for bromuconazole to determine 

whether it continues to meet the FIFRA standard for registration. The structure of this risk 

assessment is based on guidance contained in U.S. EPA’s Guidance for Ecological Risk 

Assessment (USEPA, 1998a), taking into account criteria presented by the Office of 

Pesticide Program’s Science Policy Council/Risk Management Forum De Minimis

Subgroup. 

Laboratory and field data indicate that bromuconazole is relatively persistent in the 

environment. For bromuconazole, aqueous photolysis is not an important dissipation 

pathway. Photodegradation on soil occurs slowly. Aerobic soil and anaerobic aquatic 

metabolism half-lives of >1 year were confirmed by field dissipation persistence data from 

four sites where half-lives of 7 to 14 months were reported. Of the two diastereoisomers, 

LS850647 appears to be more persistent than LS850646. Freundlich KF values of 4.5 to 

37.5 and KFOC values of 474 to 1539 were reported in four soils, with adsorption weakest 

in soils low in organic matter, making bromuconazole moderately to slightly mobile (FAO 

2000). Despite its high KOW, bromuconazole did not bioconcentrate significantly in 

bluegill sunfish.

Laboratory data indicate that bromuconazole is practically non-toxic to birds on an acute 

oral and subacute dietary basis and moderately toxic to mammals on an acute basis. There 

were not any studies found to be submitted for avian or mammalian chronic toxicity. There 

was also not any data on terrestrial insects. If exposure should occur, lack of these studies 

would constitute an uncertainty in determining potential risk. Bromuconazole is classified 

as moderately toxic to freshwater fish on an acute basis and would impact fish on a chronic 

basis should exposure occur. A study with a formulated product indicates that 

bromuconazole is very highly toxic to freshwater fish on an acute basis. Chronic studies 

with Daphnia magna suggest that freshwater invertebrates are sensitive to bromuconazole 

on a chronic basis as well. Freshwater algae also appear sensitive to bromuconazole with 

EC50s ranging from 0.16 for Lemna gibba to 0.053 for Selenastrum capricornum. There 

were not any studies submitted for estuarine/marine animals.

Based on the indoor-only use pattern for bromuconazole and EPA's determination that 

when the fungicide is used according to the label there is an incomplete exposure pathway 

and, therefore, no environmental exposure, there is low potential to adversely affect both 

non-listed and listed (endangered species).

The expectation of no exposure, and therefore no risk, to non-target organisms in this 

assessment is based on the presumption that bromuconazole use is limited to indoors, as is 

specified on the label. However, if contaminated potting soil is composted outdoors or 

contaminated water is washed out of the greenhouse into surface waters, the assessment 

might not be protective. Therefore, it is recommended that the label state that any 
4

potential runoff from contaminated potting soil or water discharged from a 

greenhouse be contained by a hydrologically isolated site that does not produce runoff 

capable of entering any irrigation or drainage ditch, canal, or other body of water.

If, in the future, bromuconazole is considered for additional uses that could result in 

environmental releases, further analysis will need to be undertaken to determine potential 

effects to non-target organisms, including listed species and their designated critical 

habitat.

2. Introduction

EFED investigated the most recent environmental fate assessments and ecological effects

assessments for bromuconazole in association with the available toxicity, exposure, and 

usage information to determine if sufficient data are available and if further updates are 

needed to support Registration Review. In addition, EFED considered the latest Agency 

science policies and risk assessment methodologies. The structure of bromuconazole, as 

well as the chemical names and other identifiers can be found below (Figure 1 and Table 

1).

Bromuconazole is a triazole fungicide. Its mode of action (MOA) classification is G, a

sterol biosynthesis inhibitor (SBI) in membranes. The target site and code are G1, or C14-

demethylase in sterol biosynthesis (erg11/cyp51). Its Group Name is DMI-fungicides 

(DeMethylation Inhibitors) (SBI: Class I). Its FRAC Code is 3.1 The DMI fungicides pose 

a medium resistance risk.

3. Use Characterization

Bromuconazole was registered in the United States in 2002. It is formulated in only one 

end-use product. Bromuconazole Fungicide (EPA Reg. No. 59639-146, formerly Reg. No. 

264-548, CHIPCO® Bromuconazole Fungicide) is an emulsifiable concentrate formulation

(20% a.i.; 1.67 lb a.i./gallon). Bromuconazole is applied in a diluted form to roses only in 

greenhouses to control black spot (Diplocarpon rosoea) at rates of 1.0 to 1.5 fluid ounces 

of product in 100 gallons of water. The use of higher rates is recommended when disease 

pressure is high. According to the label, applications may be repeated for as long as needed 

to maintain control. Repeat applications at 14-day intervals are allowed for as long as 

needed to maintain control. An application rate in units of pounds a.i./acre is not provided 

on the label. The fungicide is used as a foliar treatment applied in sufficient water to cover 

all above ground plant surfaces. If it is assumed that 100 gallons of water are applied per 

acre, the maximum application rate would be 0.020 lb a.i./A/application. Since the 

maximum number of applications is 26, the annual rate would be 0.504 lb a.i./A/year.

Bromuconazole should not be applied through any type of irrigation system. Furthermore, 

the following ENVIRONMENTAL HAZARDS statements appear in the label:

 1 Source: Fungicide Resistance Action Committee FRAC Code List® 2015, updated February 2015.
5

“This pesticide is toxic to aquatic invertebrates. Do not apply directly to water, to 

areas where surface water is present or to intertidal areas below the mean high water 

mark. Do not contaminate water when disposing of equipment wash water. Drift 

or runoff may be hazardous to aquatic invertebrates in neighboring areas.”

Additionally, the following STORAGE AND DISPOSAL statements are present in the 

label:

“STORAGE

Do not contaminate water, food, or feed by storage or disposal.

PESTICIDE DISPOSAL

Wastes resulting from the use of this product may be disposed of on site or at an 

approved waste disposal facility.

CONTAINER DISPOSAL

Triple rinse (or equivalent). Then puncture and dispose of in a sanitary landfill or 

by other procedures approved by State and 1ocal authorities.”

The chemical profile produced by the Biological and Economic Analysis Division

(BEAD), located in the docket, lists the use pattern for the current use of bromuconazole

(USEPA 2015a). It should be pointed out that the profile indicates that...“California state 

registration information is not found in the National Pesticide Information Retrieval 

System (NPIRS, 2015). The lack of a state registration could limit a pesticide's availability 

for use to control black spot on roses in greenhouses if a state registration is required for 

its use in a state.”

4. Conclusions from Previous Risk Assessments

a. Ecological Risk Assessment 

Bromuconazole was first registered in 2002 and there is only one label for the chemical 

(EPA Reg. No. 59639-146). It is registered only for use on greenhouse roses. EFED did 

not locate an ecological risk assessment relative to this sole use pattern for bromuconazole. 

At the time of registration, no formal ecological risk assessments were routinely performed 

for greenhouse uses since this is considered an indoor use pattern with limited wildlife 

exposure potential. However, studies that examine the environmental fate and ecological 

effects of bromuconazole have been submitted to the Agency. For a summary of 

environmental fate see Section 5; and for a summary of ecological effects see Section 9.

b. Drinking Water Exposure Assessments
6

A drinking water exposure assessment for the use on greenhouse roses has not been

conducted for bromuconazole. Since there are no food uses, and due to the limited use 

pattern, a dietary risk assessment is not anticipated.

c. Clean Water Act Programs

Bromuconazole is not identified as a cause of impairment for any water bodies listed as 

impaired under section 303(d) of the Clean Water Act. No Total Maximum Daily Load 

(TMDL) criteria have been developed for bromuconazole. Aquatic benchmarks have not 

been established for bromuconazole

(http://www.epa.gov/oppefed1/ecorisk_ders/aquatic_life_benchmark.htm).

5. Environmental Fate and Transport

Laboratory and field data indicate that bromuconazole [1-[[4-bromo-2-(2,4-dichlorophenyl)tetrahydro-2-furanyl]methyl]-1H-1,2,4-triazole; CAS No. 116255-48-2; PC code 

120503] is moderately to highly persistent in the environment. Bromuconazole 

(LS860263) is a mixture of two diastereoisomers with code numbers LS850646 and 

LS850647 (typical isomeric ratio is 54:46) (Figure 1). Several of the environmental fate 

studies tracked these isomers separately.

Figure 1. Structures of Diastereoisomers of Bromuconazole (source: handout from the 

registrant in a meeting held August 10, 1993).

A selection of environmental fate and transport properties of bromuconazole is summarized

in Table 1. It should be pointed out that all the environmental fate studies available were 

deemed acceptable at the time of their review in the 1990’s. Although some issues were 

noted, for bromuconazole’s current use pattern, the only studies required are hydrolysis, 

aerobic soil metabolism and batch equilibrium (adsorption/desorption).
7

Table 1. Chemical Properties and Environmental Fate Parameters of Bromuconazole

Parameter Value A Description Source

Selected Physical/Chemical Parameters

CAS chemical 

name

1-[[4-bromo-2-(2,4-dichlorophenyl)

tetrahydro-2-furanyl]methyl]-1H-1,2,4-

triazole

--- Bromuconazole 

data sheet B

CAS No. Bromuconazole: 116255-48-2

LS850646: 114544-80-8

LS850647: 114544-819

--- Bromuconazole 

data sheet B

DAR dated 10/09

Molecular mass 

(molecular formula)

377.1 g/mol (C13H12BrCl2NO3) --- (Calculated)

SMILES Code C1=CC(=CC(=C1C2(OCC(Br)C2)C[N]3

N=CN=C3)Cl)Cl

c1cc(Cl)cc(Cl)c1C2(Cn3ncnc3)CC(Br)C

O2

--- Pesticide Chemical 

Search C

EPI Suite v.4.11

Vapor pressure 

(25°C)

Bromuconazole

3 x 10-8 torr (4 x 10-8 hPa)

LS850646

2 x 10-8 torr (3 x 10-8 hPa)

LS850647

1 x 10-8 torr (1 x 10-8 hPa)

Non-volatile from a 

field condition

Summary report 

provided by the 

registrant and 

Product Chemistry 

review dated 1994

Aqueous solubility 

(20°C)

LS850646

60.9 mg/L in distilled water

52.3 mg/L in water (pH 5)

59.4 mg/L in water (pH 9)

LS850647

20.8 mg/L in distilled water

17.0 mg/L in water (pH 5)

22.1 mg/L in water (pH 9)

Relatively soluble EPA Fact Sheet 

dated 2002, and 

Product Chemistry 

review

Henry’s Law 

Constant (20°C)

LS850646

8.1 x10-11 atm-m3/mol

LS850647

9.5 x10-11 atm-m3/mol

Not expected to

volatilize from water 

or wet surfaces

Summary report 

provided by the 

registrant

Log octanol-towater partition 

coefficient (log 

KOW) (20°C)

Bromuconazole 3.24

LS850646 3.12

LS850646 3.48

Hydrophobic Summary report 

provided by the 

registrant and 

Product Chemistry 

review

Persistence

Hydrolysis half-life 

(25°C)

No degradation observed for LS850646

and LS850647 @ pH 4, 5, 7, and 9.

Stable at all pH values. MRID 42937143

(A)

Aqueous photolysis 

half-life (25°C)

18.2 d (FL summer sunlight equivalent)

at pH 4; Stable at pH 9.

Not an important

degradation pathway

MRID 42937144

(A)

Soil photolysis 

half-life (25°C, 

50°N)

11 weeks (extrapolated beyond the study 

duration)

Not an important

degradation pathway

MRID 43153401

(A)
8

Parameter Value A Description Source

Aerobic soil 

metabolism halflife (10 and 22°C)

French LS 770 d @ 10°C;

339 d @ 22°C (SFO) for bromuconazole;

LS850646 and LS850647 degraded with 

calculated ha1f-1ives of 411 and 282 d, 

respectively;

German LS – degradation was too slow to 

establish a half-life. 

Persistent under these 

conditions

MRID 42937145, 

42937146, 

42937147 (A)D

Anaerobic soil

metabolism halflife (25°C)

No study available, but not required for 

the current greenhouse use pattern.

--- ---

Aerobic aquatic 

metabolism halflife (25°C)

No study available, but not required for 

the current greenhouse use pattern.

--- ---

Anaerobic aquatic 

metabolism halflife (22°C)

French LS 370 d (bromuconazole); 

LS850646 and LS850647 degraded with 

calculated ha1f-1ives of 530 and 360 d, 

respectively.

Persistent under these 

conditions

MRID 42937148

(A)

Mobility

Freundlich soilwater partition 

coefficients (KF)

LS850646

French LS 2: 6.2 L/Kg; 1/n=0.85

French SL 5: 4.5 L/Kg; 1/n=0.78

French L 6: 5.0 L/Kg; 1/n=0.81

German LS 8: 26.5 L/Kg; 1/n=0.85

LS850647

French LS 2: 8.9 L/Kg; 1/n=0.85

French SL 5: 5.0 L/Kg; 1/n=0.76

French L 6: 6.5 L/Kg; 1/n=0.83

German LS 8: 37.5 L/Kg; 1/n=0.86

French LS 2: pH=8.0, 

%OM=2.2;

French SL 5: pH=6.3; 

%OM=0.8;

French L 6: pH=6.4; 

%OM=1.8;

German LS 8: pH=5.7; 

%OM=4.2

MRID 42937151

(A) D

Organic carbonnormalized 

Freundlich partition 

coefficients (KFOC)

LS850646

French LS 2: 489 L/KgOC

French SL 5: 978 L/KgOC

French L 6: 474 L/KgOC

German LS 8: 1086 L/KgOC

LS850647

French LS 2: 697 L/KgOC

French SL 5: 1084 L/KgOC

French L 6: 627 L/KgOC

German LS 8: 1539 L/KgOC

LS850646

Moderately mobile to 

slightly mobile

LS850647

Moderately mobile to 

slightly mobile

MRID 42937151

(A)

Leaching (unaged) Unaged bromuconazole showed low 

mobility in columns of LS, SL and loam 

soi1s, that were leached with 50.8 cm of 

distilled water. In all soi1 columns, 

>62% AR remained in the upper 6 cm of 

soi1, and <1.1% leached below a depth 

of 18 cm. The column leachates 

contained a maximum of 0.6% of the 

applied radioactivity.

--- MRID 42937149, 

42937150 (A)

Leaching (aged) Aged (30 days) bromuconazole residues 

showed low mobility in columns of SL 

soil and relatively immobile in columns 

---
9

Parameter Value A Description Source

of low- and high-organic LS and loam 

soils that were leached with 50.8 cm of 

distilled water. In the sandy 1oam 

columns, approximately 72% of the 

applied radioactivity remained in the 

upper 6 cm of soil, and <3.3% leached 

below a depth of 18 cm. The column 

leachates contained a maximum of 2.3% 

of the applied radioactivity. In the loamy 

sand and loam soil columns, >94% of the 

applied radioactivity remained in the 

upper 6 cm of soil, and ≤3.2% leached 

below a depth of 12 cm; the column 

leachates contained a maximum of 2.4%. 

Bromuconazole diastereoisomers were 

the predominant compounds present in 

the soils prior to and following leaching

Field Dissipation

Terrestrial field 

dissipation half-life; 

leaching depth

Half-lives for bromuconazole, LS850646

and LS850647, respectively, applied on 

turf plots:

9.4, 11.8, 7.1 months (0-15 cm” depth; 

CA loam);

7.8, 8.8, 7.0 months (0-15 cm depth; MS 

silt loam);

7.3, 8.7, 5.8 months (0-15 cm depth; NC 

loamy sand);

13.8, 13.5, 14.1 months (0-15 cm depth; 

WA loamy sand);

Generally there was no leaching below 

the 15 cm depth, except in WA, where 

there was some movement to the 15-30 

cm soil depth.

Persistent in the field MRID 43093501

(A)

Fish Bioconcentration

Fish 

bioconcentration 

factors (steadystate); depuration 

rate (Bluegill 

sunfish)

56x (edible),

277x (inedible),

160x (whole) for bromuconazole total 

residues;

70-86% depuration in 1 day; 

[

14C]bromuconazole was not isolated 

from the fish tissue. See next section for 

identified transformation products.

Low bioconcentration 

potential

MRID 42937152, 

42937153, 

43033101 (A)

A LS = loamy sand; L = loam; SL = sandy loam; (A) = acceptable study. B URL: http://www.alanwood.net/pesticides/bromuconazole.html (accessed April 6, 2015). C URL: http://iaspub.epa.gov/apex/pesticides/f?p=chemicalsearch:1:6674704495021::::: (accessed April 16, 

2015).

D Even though the studies were conducted using foreign soils, and no comparison with domestic soils was 

provided, no additional data is required for the limited current use pattern of bromuconazole. Should the 

registrant wish to register additional uses, EFED may request additional data or information.
10

Laboratory and field data indicate that bromuconazole is moderately persistent to persistent 

in the environment. Bromuconazole photolyzes in shallow, clear surface waters with a halflife = 18 days, indicating that this is not an important dissipation pathway. 

Photodegradation on soil occurs slowly. Aerobic soil and anaerobic aquatic metabolism 

half-lives of >1 year were confirmed by field dissipation persistence data from four sites 

where half-lives of 7 to 14 months were reported. Of the two diastereoisomers, LS850647

appears to be more persistent than LS850646. Freundlich KF values of 4.5 to 37.5 and 

KFOCs of 474 to 1539 were reported in four soils, with adsorption weakest in soils low in 

organic matter, making bromuconazole moderately to slightly mobile (FAO 2000). 

Although adsorption data show relatively low potential for residues to leach to ground 

water in most soils, the compound's persistence indicates that movement of bromuconazole 

with water is possible, particularly in soils with low in organic matter content. Despite its 

high KOW, bromuconazole did not bioconcentrate significantly in bluegill sunfish.

Bromuconazole is moderately persistent to persistent with a surface degradation half-life 

of ≥1 year in aerobic soil metabolism experiments conducted in two European soils. In 

both soils, the diastereoisomer LS-850647 degraded somewhat more rapidly than LS850647. In addition to parent, CO2 and soil-bound residues accounted for the bulk of the 

applied radioactivity in these laboratory experiments. Photodegradation is not likely to be 

an important route of bromuconazole dissipation in the environment. On soil, 

photodegradation proceeds slowly (approximately 25% of the applied bromuconazole 

degraded in a sandy loam irradiated with simulated sunlight for 6.7 hours per day for 30 

days); in water, photodegradation was observed at pH 4 (half-life = 18.2 days) but did not 

occur at pH 9. Aqueous photolysis, however, is not likely to be a significant process in pH 

levels found in the environment (the active ingredient did not absorb light in solution at pH 

7). Degradation of bromuconazole with depth will also occur slowly as the compound was 

stable to hydrolysis at pH 5, 7, and 9 and degraded in an anaerobic aquatic metabolism 

study with a half-life of approximately 1 year.

Bromuconazole showed low mobility in soil. Freundlich Kads values of 4.5 to 37.5 were 

reported in four European soils. The potential mobilities of the individual diastereoisomers 

(LS-850646 and LS-850647) were comparable in each soil tested. Adsorption appeared to 

be positively associated with soil organic matter content: the potential for bromuconazole 

residues to be transported with water seems to be greatest in soils low in organic matter. 

Soil column leaching studies of unaged and aged (30 days) bromuconazole residues

showed low mobility in 30-cm soil columns containing unaged bromuconazole residues 

leached with 50.8 cm of distilled water. >62% of the applied radioactivity remained in the 

upper 6-cm soil layer. 4.1% leached below a depth of 18 cm. and. column leachates 

contained a maximum of 0.6% of the applied radioactivity. A parallel study using 

bromuconazole residues aged in soil for 30 days yielded similar results. In the sandy loam 

column. 72% of the applied radioactivity was recovered from the 0-6 cm soil layer, ≤3.3% 

leached below 18 cm. and 2.3% was retrieved from the leachate. In a loamy sand and loam 

columns, ≥94% of the applied radioactivity, was recovered from the 0-6 cm soil layer. 

≤3.2% moved greater than 12 cm in the column, and 2.4% was recovered from the leachate. 

The vapor pressure reported by the registrant for parent bromuconazole (3.0x10-8 mm Hg 
11

at 25°C) indicates that volatilization of residues is not likely to occur significantly in the 

environment.

Terrestrial field dissipation data submitted for four sites are consistent with laboratory data. 

In field studies conducted on plots of loam, silt loam, and loamy sand soils planted with 

turfgrass in Mississippi, California, North Carolina and Washington, bromuconazole was 

applied four times at weekly intervals at a rate of 1.9 kg a.i./ha (1.7 1b a.i./A) per 

application. At these sites, the fungicide dissipated from the upper 15 cm soil layer with

reported half-lives of 7.3-13.8 months. The individual isomers, LS-850646 and LS850647, dissipated with calculated half-lives of 8.7-13.5 and 5.8-14.1 months, respectively. 

Residue concentrations accumulated in soil with repeated applications. Generally, 

bromuconazole was not detected at appreciable concentrations below the 15-cm soil depth, 

although some movement into the 15-30 cm soil depth was observed at the Washington 

site.

Residues did not accumulate significantly in bluegill sunfish exposed to bromuconazole in 

a flow-through system. The maximum reported bioconcentration factors were 277x for 

visceral tissue, 56x for muscle tissue, and 160x for whole fish. Maximum mean 

concentrations of bromuconazole residues were 9.53 μg/g i n the nonedible tissue after 7 

days of exposure, 1.92 μg/g in the edible tissue after 3 days, and 5.50 μg/g in the whole

fish after 7 days. The degradates identified in the fish were LS 850920-glucuronide, LS 

850920, LS 860550-glucuronide, LS 860550, and LS 860364. Bromuconazole was not 

isolated in the fish tissue. Near complete depuration of accumulated residues was reported 

when fish were transferred to non-contaminated water for 21 days,

a. Transformation Products

In the aqueous photolysis study, eight unidentified degradates were isolated from the 

solution, with Unknown 6 comprising 7.78-10.48% of the applied radioactivity. However, 

other unknowns comprised ≤6.14% of the applied. In the soil photolysis study, 13 

degradates were observed at ≤2.9% AR, of which 7 were identified using MS: RPA401527; 

LS860551; LS860550; LS870353; LS860364; LS830730; "Structure II” and "Structure 

III” (no attempt was made to relate the 13 isolated compounds with the identified 

structures, and the chemical names were not provided).

In the aerobic soil metabolism study, two nonvolatile extractable [14C] compounds ("M2" 

and "M3") each averaged 1.15-1.41% AR. In a separate aerobic soil metabolism study, 

using a higher rate of 5.05 mg/kg, the degradates LS-86055 and RPA-40152 were identified 

at 0.0015 and 0.0012 ppm, respectively (chemical names not provided). In the anaerobic 

aquatic metabolism study, two nonvolatile, unidentified, organoextractable 

[

14Clcompounds ("M2" and "M3") averaged ≤0.46% and ≤1.53% AR, respectively. The 

degradate 2-(2.4-dichlorophenyl-2-(1,2,4-triazol-l-yl-methyl)tetrahydrofuranne or 

LS871387, was a maximum average of 10.10% AR at 6 months, and 7.11% AR at 12 

months. This degradate corresponds to the loss of a bromine atom from the parent LS 

860263 as shown below:
12

Figure 2. Proposed Metabolic Pattern for the Anaerobic Aquatic Metabolism Study

(Source: MRID 42937148)

The degradates identified in the fish tissue were LS-850920-glucuronide, LS850920,

LS860550-glucuronide, LS860550, and LS860364. LS850920-glucuronide was 

completely eliminated from the fish tissue during depuration; the remaining compounds 

were partially eliminated (quantitative data not provided).

b. Uncertainties

The aerobic soil metabolism and batch equilibrium studies were conducted using foreign 

soils. No comparison with domestic soils was available. At this time, given the very 

limited use pattern for bromuconazole, no additional information is required; however, 

should the registrant wish to add uses to the chemical, additional data or studies may be 

required.

In the soil photolysis study, the maximum levels of unextracted radioactivity reached 

14.99% at 30 days in one of the replicates. All samples were Soxhlet extracted for 3 hours

with methanol. For the 30 day samples, additional extractions with methanol/water (1:1) 

were conducted and it was found that the same products previously observed were present 

in the additional extracts. After the additional extraction, only 11% AR remained 

unextracted. In the aerobic soil metabolism study, a maximum of 34.07% AR was found 

to be unextracted radioactivity at 365 days, for an individual sample. For the same soil, 
13

the mineralization was 14.21% by the end of the study (365 days). Samples were either 

extracted with acetone and methanol or Soxhlet extracted with methanol (both types of 

extractions were not used simultaneously at any interval). It appeared that the extraction 

scheme did not change the overall conclusion that bromuconazole persists in soil 

environments. In the anaerobic aquatic metabolism study, the maximum levels of 

unextracted radioactivity reached 38.25% for an individual replicate at 365 days (last test 

interval). Sediment was extracted three times with acetone and once with methanol for 15 

minutes each.

6. Exposure Pathways of Concern

Based on the current single use pattern for bromuconazole on greenhouses roses, the only

exposure pathway for the chemical appears to be through incidental runoff of water 

containing bromuconazole that could reach adjacent receiving surface waters. Given the 

restrictions in the label, it appears that this route of exposure would be minimized in most 

cases and this would appear to be an unlikely event. Typical transport mechanisms for 

conventional pesticides, such as spray drift to adjacent fields, do not apply to greenhouse 

uses.

7. Analysis Plan

a. Stressors of Concern

i. Ecological Risk Assessment

The stressor of concern for aquatic organisms is parent bromuconazole. Although one 

major degradate (at ~10% AR) was detected in the anaerobic aquatic metabolism study, 

for the preliminary analysis presented in this risk assessment, the parent compound was 

considered to be a good surrogate.

For currently registered the use pattern of bromuconazole on greenhouse roses, no 

substantial exposure to terrestrial wildlife is expected.

ii. Drinking Water

Since there are no food uses, and due to the limited use pattern, a dietary risk assessment

is not anticipated.

b. Conceptual Model

For a pesticide to pose an ecological risk, it must reach ecological receptors in biologically 

significant concentrations. An exposure pathway is the means by which a pesticide moves 

in the environment from a source to an ecological receptor. For an ecological pathway to 

be complete, it must have a source, a release mechanism, an environmental transport 

medium, a point of exposure for ecological receptors, and a plausible route of exposure. 

The conceptual model is intended to provide a written description and visual representation 
14

of predicted relationships between bromuconazole, potential routes of exposure, and the 

effects related to the Agency assessment endpoints. The conceptual model consists of two 

major components: the risk hypothesis and a conceptual diagram.

i. Risk Hypothesis

Risk hypotheses are specific assumptions about potential adverse effects (i.e., changes in 

assessment endpoints) and may be based on theory and logic, empirical data, mathematical 

models, or probability models (USEPA 1998). For this assessment, the risk is stressorinitiated, where the stressor is the release of bromuconazole into the environment. The 

following risk hypothesis is presumed for this screening-level assessment:

Bromuconazole, when used indoors in greenhouses, in accordance with current 

labels, is not expected to result in adverse effects on the survival, growth, and 

reproduction of non-target terrestrial and/or aquatic organisms (plants and 

animals).

ii. Conceptual Diagram

A conceptual diagram/model is established for chemicals with likely outdoor 

environmental exposure pathways. This is not the case for bromuconazole, which is used 

indoors and does not have outdoor uses. For the sole currently registered use of 

bromuconazole, potential ecological exposure is expected to be de minimis based on the 

lack of a complete exposure pathway from the use site to non-target terrestrial and aquatic 

organisms. The label states under the ‘Pesticide disposal’ heading that “Wastes resulting 

from the use of this product may be disposed of on site or at an approved waste disposal 

facility.” 

Nevertheless, a worst-case scenario of potential risks of bromuconazole to aquatic 

organisms may entail disposal in such a way that could potentially end up in an adjacent 

body of water is depicted in Figure 3. The stressor is the chemical of concern

(bromuconazole). It is noted that the transport pathway would be runoff erosion, the 

exposure media is the receiving water body, and the exposure point or route, receptor and 

attribute changes for aquatic organisms are similar to the conceptual model for agricultural 

applications.
15

Figure 3. Conceptual diagram for potential risks of bromuconazole to aquatic organisms for 

the indoor use on greenhouse roses of the chemical that could potentially end up in adjacent 

bodies of water

c. Methods of Conducting Ecological Risk Assessment

The primary method used to assess risk in this screening-level assessment is the risk 

quotient (RQ) and follows closely methods outlined in the EPA Overview Document 

(USEPA, 2004). The RQ is the risk value for the screening-level assessment and is the 

result of comparing measures of exposure to measures of effect. A commonly used 

measure of exposure is the estimated exposure concentration (EEC) and commonly used 

measures of effect include toxicity values such as the median lethal dose to 50% of the 

organisms tested (LD50), medial lethal concentration to 50% of tested organisms (LC50), 

the no observed adverse effect level (NOAEL), and the no observed adverse effect 

concentration (NOAEC). The resulting ratio of the point estimate of exposure and the point 

estimate of toxicity, i.e., the RQ, is then compared to a specified level of concern (LOC), 

which represents a threshold for concern; if the RQ exceeds the LOC, risks concerns are 

Stressor Bromuconazole Applications on Greenhouse Roses

Source/

Transport

Pathways

Runoff Erosion

Source/

Exposure

Media

Receiving Water Body/ 

Sediment

Exposure

Route

Gill/

Integument 

Uptake

Receptor

Attribute

Changes

Aquatic 

Invertebrates,

Vertebrates

Individual 

Vertebrates and 

Invertebrates

Reduced survival, 

growth or 

reproduction

Plant Population

Reduced 

population 

growth

Aquatic 

Plants

Uptake/ 

Adsorption
16

triggered. Risk presumptions, along with the corresponding RQs, equations, and LOCs are 

summarized in Section 10 of this assessment.

d. Measures of Exposure 

Currently EFED does not have a specific tool to assess exposure related to greenhouse 

uses. Since this is an indoor use pattern, exposure to non-target terrestrial organisms is not 

anticipated for this use pattern, since greenhouses are enclosed. Incidental exposure to 

bodies of water adjacent to greenhouses could occur in cases where substantial irrigation 

is used and runoff occurs to adjacent bodies of water. In order to get an upper bound 

estimate the potential exposure, a back of the envelope calculation was performed 

assuming treatment at the maximum rate of 1.5 fluid ounces of product per 100 gallons of 

water (the range is 1.0-1.5 fluid ounces of product per 100 gallons of water) and that 100 

gallons of diluted product runoff and reach the standard 20,000,000 L pond. 

 Measures of Effect 

Toxicity data presented in Section 9 of this document will be used to calculate risk 

quotients. Any additional information submitted by the registrant or found in the open 

literature prior to conduct of the risk assessment will also be considered. The open 

literature studies are identified using EPA’s ECOTOXicology database (ECOTOX) 

(USEPA, 2007), which employs a literature search engine for locating chemical toxicity 

data for aquatic life, terrestrial plants, and wildlife. The evaluation of both sources of data 

can also provide insight into the direct and indirect effects of pesticides on biotic 

communities from loss of species that are sensitive to the chemicals and from changes in 

structure and functional characteristics of the affected communities.

8. Exposure Assessment

a. Modeling Approach

EFED typically evaluates the likelihood of an adverse effect, i.e., risk, using a quantitative 

approach where conservative exposure estimates are compared to the most sensitive 

toxicity endpoints. However, the single registered use of bromuconazole is for roses in an 

enclosed, indoor greenhouse environment with an impermeable roof, and as such, there is 

a lack of a complete exposure pathway from the use site to non-target terrestrial organisms. 

Therefore, for this indoor use pattern, exposure to non-target terrestrial organisms is not 

anticipated.

Currently EFED does not have a specific tool to assess exposure related to greenhouse uses

to adjacent aquatic environments. While exposure routes are not anticipated, incidental 

exposure to bodies of water adjacent to greenhouses could conceivably occur in cases 

where substantial irrigation is used, causing runoff events. In order to estimate the potential 

exposure, a back of the envelope calculation was performed with the following 

assumptions to provide context to the de minimis approach in this assessment:
17

• The application is made at the maximum rate of 1.5 fluid ounces of end-use product 

per 100 gallons of water (the application rate range is 1.0-1.5 fluid ounces of product 

per 100 gallons of water, depending on pest pressure).

• 100 gallons of diluted product runoff towards the standard 20,000,000 L pond.

• EECs are calculated based on the above assumptions, assuming no degradation or 

partitioning with soil or sediment.

b. Modeling Results

Based on the assumptions stated above, the hypothetical EEC would be as shown in the 

following calculations:

The amount of product used per 100 gallons is 1.5 fluid ounces (maximum rate).

Amount of A.I. in 100 gallons of diluted solution:

 = (1.5 oz product) (1 gallon/128 oz) (1.67 lb a.i./gallon product) (4.53592x108 μg/lb)

 = 8877 μg a.i.

Concentration of A.I. in the standard pond (EEC):

 = 8877 μg a.i./20,000,000 L

EEC = 0.444 μg/L

c. Available Monitoring Data

The Agency is not aware of any monitoring conducted by federal and/or state agencies for 

bromuconazole. The NAWQA database was searched by constituent finder 

(http://cida.usgs.gov/nawqa_public/apex/f?p=136:23:0, accessed 06/11/2015) and 

bromuconazole is not in the database. The CADPR monitoring database was not consulted 

since BEAD’s Chemical Profile indicated that bromuconazole does not have California 

state registration.

9. Receptors

Table 4 and Table 5 provide a summary of the aquatic and terrestrial taxonomic groups, 

respectively, and most sensitive surrogate species tested to characterize the potential acute 

and chronic ecological effects of bromuconazole. In addition, the tables provide a 

preliminary overview of the potential acute toxicity of bromuconazole by providing the 

acute toxicity classifications. Based on the available ecotoxicity information, 

bromuconazole is moderately toxic to freshwater fish. One study with a formulated 

product suggests that bromuconazole is very highly toxic to aquatic freshwater 

invertebrates. Bromuconazole is practically non-toxic to avian species and moderately 

toxic to mammals. Additional detail is included in the following tables.

a. Effects to Aquatic Organisms
18

Table 4. Summary of the Most Sensitive Endpoints from Aquatic Toxicity Studies for 

Bromuconazole

Taxonomic 

Group

Study 

Type Surrogate Species

Toxicity Value

Acute 

Toxicity 

Classification 

Source

(all units in 

terms of 

measured 

active 

ingredient)

Freshwater 

fish1

Acute

Rainbow Trout

LC50 = 1.7 mg/L Moderately 

toxic 42937117

(Oncorhynchus mykiss)

Chronic 

(Early LifeStage)Fathead minnow

NOAEC = 0.034 

mg/L

N/A 42937119

LOAEC = 0.047 

mg/L

Endpoint: 30 

day wet weight

Freshwater 

invertebrates

Acute

Water Flea 

EC50 = 0.085

mg/L

Very Highly 

Toxic 42938009

(Daphnia magna)

Chronic Water Flea 

NOAEC = 0.020 

mg/L

LOAEC = 0.054 

mg/L

Endpoint: 

reproduction

N/A 42937120

Estuarine/

marine fish Acute Sheepshead Minnow 

(Cyprinodon variegatus) N/A N/A N/A

Estuarine/

marine 

invertebrates

Acute Mysid Shrimp N/A N/A N/A

Acute Eastern Oyster (Crassostrea 

virginica) N/A N/A N/A

Aquatic 

plants and 

algae

Vascular

Duckweed 

N/A 43018512

(Lemna gibba) EC50 = 0.16 

mg/L
19

Taxonomic 

Group

Study 

Type Surrogate Species

Toxicity Value

Acute 

Toxicity 

Classification 

Source

(all units in 

terms of 

measured 

active 

ingredient)

Nonvascular

Selenastrum capricornutum EC50 = 0.053 

mg/L N/A 42937141

Anabaena flos-aquae

EC50 = 1.27

mg/L N/A 42937142

1 Freshwater fish may be surrogates for aquatic-phase amphibians.

This assessment is using the formulated product study (MRID 42938009) to assess acute 

toxicity of bromuconazole on freshwater invertebrates in lieu of a submitted study with 

TGAI. The European Food Safety Authority (EFSA) risk assessment indicates that other 

daphnid studies with bromuconazole have comparable levels of toxicity (EFSA Journal 

2010; 8(8): 1704). Given minimal anticipated exposure of aquatic organisms, this study is 

sufficient for risk assessment purposes at this time. 

b. Effects to Terrestrial Organisms

Table 5. Summary of the Most Sensitive Endpoints from Terrestrial Toxicity Studies for 

Bromuconazole

Taxonomic 

Group Study Type Surrogate Species

Toxicity Value

Acute 

Toxicity 

Classification

Source 

(all units in 

terms of 

measured 

active 

ingredient)

Birds1

Acute

Bobwhite quail LD50 

>2150mg/kgbw

Practically 

non-toxic 42937112

(Colinus virginianus)

Sub-acute 

dietary

Bobwhite quail

LC50 > 5000 

ppm

Practically 

non-toxic

42937114, 

Pedersen, 

(Colinus virginianus) 1990
20

Chronic N/A N/A N/A N/A

Mammals 

(for 

additional 

studies see 

HED 

assessment)

Acute Oral

Laboratory rat 

LD50 = 328 

mg/kg-bw

Moderately 

toxic 42937121

(Rattus norvegicus)

Insects Acute 

contact

Honey bee 

N/A N/A N/A

(Apis mellifera L.)

Terrestrial 

plants

Seedling 

Emergence

Dicot 

N/A N/A N/A

Monocot 

N/A N/A N/A

Vegetative 

Vigor

Dicot 

N/A N/A N/A

Monocot 

N/A N/A N/A

1 Birds represent surrogates for terrestrial-phase amphibians and reptiles.

Ecological Incidents

The ecological incident information system (EIIS) is an OPP database that houses 

ecological incidents that have been reported to the Agency. When available, EIIS includes 

date and location of an incident, type and magnitude of effects observed in various species, 

use(s) of pesticides known or suspected of contributing to the incident, and results of any 

chemical residue analysis or other analyses conducted during incident investigation. EIIS 

incidents are categorized according to the certainty that the incident resulted from pesticide 

exposure. The Avian Monitoring System (AIMS) is a database administered by the 

American Bird Conservancy that contains publicly available data on reported avian 

incidents involving pesticides. Many of the incidents listed in this database are also in the 

EIIS. 

EIIS did not return any terrestrial or aquatic incidents from the most recent search on April

22, 2015. As of January 22, 2012, AIMS identified no ecological incidents involving 

bromuconazole. There are not any records of bromuconazole being used in the US 

according to BEAD.
21

10. Risk Characterization

Risk characterization provides the final step in the risk assessment process. In this step, 

exposure and effects characterization are integrated to provide an estimate of risk relative 

to established levels of concern (LOCs; Section 10.a). The results are then interpreted for 

the risk manager through a risk description and synthesized into an overall conclusion 

(Section 10.b). In addition, the risk description also contains a discussion of relevant 

sources of uncertainty in the risk assessment and sensitivity of the risk assessment findings 

to important methodological assumptions.

a. Risk Estimation – Integration of Exposure and Effects

As discussed previously, risk characterization integrates EECs and toxicity estimates and 

evaluates the likelihood of adverse ecological effects to non-target species. For 

bromuconazole, a deterministic approach is used to evaluate the likelihood of adverse 

ecological effects to non-target species. In this approach, RQs are calculated by dividing 

EECs by acute and chronic ecotoxicity values for non-target species. 

Risk Quotient (RQ) = Exposure Estimate/Toxicity Estimate 

RQs are then compared to LOCs. These LOCs are criteria used to indicate potential risk 

to non-target organisms and the need to consider regulatory action. LOC exceedance is 

interpreted to mean that the labeled use (or proposed use) of the pesticide has the potential 

to cause adverse effects on non-target organisms. LOCs currently address the following 

risk presumption categories:

Animals: 

• acute risk - potential for acute risk to non-target organisms which may warrant 

regulatory action in addition to restricted use classification, 

• acute risk, restricted use – potential for acute risk to non-target organisms, but 

may be mitigated through restricted use classification, 

• acute risk, listed species – listed species may be potentially affected by use, 

• chronic risk – potential for chronic risk may warrant regulatory action, listed 

species may potentially be affected through chronic exposure, 

Plants 

• non-listed plant risk - potential for effects in non-target (non-endangered) plants, 

and 

• listed plant risk – potential for effects in endangered plants. 

Table 6. Summary of the Levels of Concern Used for the Risk Quotient Method.

Risk Presumption RQ LOC

Aquatic Animals

Acute Risk EEC/LC50 or EC50 0.5

Acute Restricted Use EEC/LC50 or EC50 0.1

Acute Endangered Species EEC/LC50 or EC50 0.05

Chronic Risk EEC/NOAEC 1
22

Risk Presumption RQ LOC

Terrestrial and Semi-Aquatic Plants, and Aquatic Plants

Acute Risk EEC/EC25 1

Acute Endangered Species EEC/EC05 or NOAEC 1

RISK ESTIMATION

EFED did a back of the envelope calculation in order to determine whether exposure would 

be sufficient to indicate environmental risks from an incidental runoff scenario. Risk 

presumptions, along with the calculation of the corresponding RQs and LOCs, are 

tabulated below:

Table 7. Acute and chronic RQs for freshwater fish and invertebrates associated with 

greenhouse rose uses of bromuconazole1

Peak/Chronic

EEC (μg/L)

FW Fish 

Acute RQ

FW Fish

Chronic RQ

FW Invert

Acute RQ

FW Invert

Chronic RQ

0.444 <0.01 0.01 0.01 0.02

1 For freshwater fish, it is based on rainbow trout LC50 = 1700 ug/L and fathead minnow NOAEC = 34 ug/L; 

and for freshwater invertebrates based on Daphnia magna EC50 = 85 ug/L and Daphnia magna NOAEC = 

20 ug/L.

Acute and chronic RQs for estuarine/marine fish and invertebrates could not be calculated 

since there is no toxicity data.

Table 9. RQs for vascular and non-vascular plants associated with greenhouse rose uses of 

bromuconazole1

Peak EEC (μg/L) Vascular Plant 

Acute RQ

Non-vascular Plant 

Acute RQ

0.444 <0.01 0.01

1 For vascular plants, based on duckweed (Lemna gibba) EC50 = 160 μg/L and for non-vascular plants, based 

on Solenastrum capricornutum EC50 = 53 μg/L.

b. Risk Description

In risk description, the results from the risk estimation are interpreted and synthesized into 

overall risk conclusions. This description considers other lines of evidence (e.g., 

monitoring data, field data, refined exposure and effects modeling) for characterizing 

ecological risk. In addition, the risk description also contains a discussion of relevant 

sources of uncertainty in the risk assessment and sensitivity of the risk assessment findings 

to important methodological assumptions. The risk description also addresses other 

concerns including risks to threatened and endangered species, a discussion of uncertainty, 

and the sensitivity of risk conclusions to assumptions made in the assessment.

Given the exclusive use in greenhouses (indoors), and only a single use within the 

greenhouse category (greenhouse roses), there is low potential to adversely affect nontarget terrestrial animals and plants. It is noted that there is no complete exposure pathway

from the use site to these non-target organisms.
23

When the applications are made in diluted water in a greenhouse, applications typically 

range from about 15 to 100 gallons of solution per acre; 100 gallons of solution is usually 

a high end exposure scenario. In order to assess the unlikely event that a substantial portion 

of the applied bromuconazole reaches an adjacent body of water through runoff, EFED did 

a back of the envelope calculation in order to determine whether exposure would be 

sufficient to indicate environmental risks. EFED assumed runoff of 100 gallons of diluted 

bromuconazole solution at the maximum rate. It should be stressed that runoff of 100 

gallons of bromuconazole-containing water is considered a highly unlikely event. It was 

found that none of EFED’s levels of concern were exceeded for aquatic animals and plants. 

In order to estimate how much of the bromuconazole solution needs to reach the standard 

pond in order to exceed the lowest endpoint’s level of concern, it was estimated that around 

958 gallons of bromuconazole-containing water must enter directly the pond to cause the 

RQ to equal or exceed the acute endangered species LOC of 0.05 (based on Daphnia magna

EC50 = 85 μg/L). The runoff volume needs to be above 9,580 gallons to cause the RQ to 

exceed the non-listed LOC of 0.5.

It should be pointed out that EFED believes that over irrigation events are not common

events due to the related water and other irrigation costs. A number of extension service 

reference documents were found, that suggest that in a number of operations a holding or 

retention pond is used to keep the water from the greenhouse. In other instances, the water 

is reused, and in other instances, it is purified prior to being reused.2

 Even though the water 

could be disposed into drains leading to wastewater treatment plants, a permit is required 

prior to discharge.3 Finally, restrictions in the label suggest that aquatic exposure is not 

likely. It specifies, “Do not irrigate treated areas until the foliage is completely dry, usually 

a 4 hour waiting period following treatment is preferred.” Other restrictions specified in 

the use information section are also indicative of the small likelihood of exposure to aquatic 

environments.

c. Endangered Species Assessments

In November 2013, the EPA, along with the U.S. Fish & Wildlife Service (USFWS), the 

National Marine Fisheries Service (NMFS) (collectively, the Services), and the U.S. 

Department of Agriculture (USDA) released a summary of their joint Interim Approaches 

for assessing risks to listed species from pesticides. The Interim Approaches were 

developed jointly by the agencies in response to the National Academy of Sciences’ (NAS)

recommendations and reflect a common approach to risk assessment shared by the agencies 

as a way of addressing scientific differences between the EPA and the Services. The NAS 

 2 See for example, Green, J.L. Practices to Minimize Contamination of Groundwater and Runoff Water in 

Greenhouse and Nursery Production of Container-Grown Plants. Ornamental Northwest Archives. May-June 

1989. Vol. 13, Issue 3, pp. 9-16; and,

Developing a Management Plan for Irrigation Runoff. Water Management Guidelines for Nursery/Floral 

Producers. URL: http://aggie-horticulture.tamu.edu/greenhouse/nursery/environ/wmplan1.html (accessed 

06/11/2015).

3 See for example, Treating and Recycling Irrigation Runoff. Water Management Guidelines for Nursery/

Floral Producers. URL: http://aggie-horticulture.tamu.edu/greenhouse/nursery/environ/wmrecyc.html

(accessed 06/11/2015).
24

report outlines recommendations on specific scientific and technical issues related to the 

development of pesticide risk assessments that EPA and the Services must conduct in 

connection with their obligations under the Endangered Species Act (ESA) and FIFRA. 

The joint Interim Approaches were released prior to a stakeholder workshop held on 

November 15, 2013. In addition, the EPA presented the joint Interim Approaches at the

December 2013 Pesticide Program Dialogue Committee (PPDC) and State-FIFRA Issues 

Research and Evaluation Group (SFIREG) meetings, and held a stakeholder workshop in 

April 2014, allowing additional opportunities for stakeholders to comment on the Interim 

Approaches. As part of a phased, iterative process for developing the Interim Approaches, 

the agencies will also consider public comments on the Interim Approaches in connection 

with the development of upcoming Registration Review decisions. The details of the joint 

Interim Approaches are contained in the white paper “Interim Approaches for NationalLevel Pesticide Endangered Species Act Assessments Based on the Recommendations of 

the National Academy of Sciences April 2013 Report,” dated November 1, 2013. 

Given that the agencies are continuing to develop and work toward implementation of the 

Interim Approaches to assess the potential risks of pesticides to listed species and their 

designated critical habitat, this preliminary risk assessment for bromuconazole does not 

contain a complete ESA analysis that includes effects determinations for specific listed 

species or designated critical habitat. Although EPA has not yet completed effects 

determinations for specific species or habitats, for this preliminary assessment EPA 

conducted a screening-level assessment for all taxa of non-target wildlife and plants that 

assumes for the sake of the assessment that listed species and designated critical habitats 

may be present in the vicinity of the application of bromuconazole. This screening level 

assessment will allow EPA to focus its future evaluations on the types of species where the 

potential for effects exists once the scientific methods being developed by the agencies 

have been fully vetted. This screening-level risk assessment for bromuconazole does not 

indicate any potential risks of direct effects to listed terrestrial or aquatic taxa due to 

incomplete routes of exposure from potential greenhouse use sites. Due to lack of exposure 

listed species also will not be affected through indirect effects because of the potential for

direct effects on listed and non-listed species upon which such species may rely. Potential 

direct effects on no listed species from the use of bromuconazole may be associated with 

modification of Primary Constituent Elements(PCEs) of designated critical habitats, where 

such designations have been made. Once the agencies have fully developed and 

implemented the scientific methods necessary to complete risk assessments for endangered 

and threatened (listed) species and their designated critical habitats, these methods will be 

applied to subsequent analyses for bromuconazole as part of completing this registration 

review.

d. Endocrine Disruptor Screening Program

Bromuconazole was not included in the first group of 67 chemicals issued an order to 

conduct Tier 1 EDSP testing. For additional information the EDSP program, 

visit http://www.epa.gov/endo/.
25

11. Conclusions

Given that bromuconazole is used in greenhouses, exposure to terrestrial compartments 

(birds, mammals and non-target terrestrial plants) is presumed to be low; there is no 

complete exposure pathway from the use site to these non-target organisms.

Based on a back of the envelope calculation of the EECs, EFED found no exceedance of 

LOCs, assuming a runoff event of 100 gallons of diluted bromuconazole at the maximum 

rate. To provide an idea of how much bromuconazole needs to be used in order for there 

to be risk to the environment, over 900 gallons of diluted bromuconazole solution, at the 

maximum rate, need to runoff directly to the standard pond to exceed the acute endangered 

species LOC of 0.05 (based on Daphnia magna EC50 = 85 μg/L). The runoff volume was 

also calculated that would be sufficient to trigger risk to non-listed aquatic taxa. Using the 

currently most sensitive endpoints, the runoff volume needs to be above 9,000 gallons to 

cause the RQ to exceed the non-listed LOC. Given that these runoff volumes are so high 

and the low likelihood of such an event, and exclusive use in greenhouses, it appears that 

there is low potential to adversely affect non-target aquatic plants and animals.

12. Preliminary Identification of Data Gaps

a. Environmental Fate

Table 10 identifies environmental fate studies by MRID that offer data for each guideline 

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

order to support risk assessment.

The environmental fate database for bromuconazole is nearly complete, with the notable 

exception of the absence of an aerobic aquatic metabolism study. Nonetheless, it is not 

required for the current single use pattern of the chemical on greenhouse roses. It should 

be pointed out that all the environmental fate studies available were deemed acceptable at 

the time of their review in the mid 1990’s. Although some issues were noted during 

Registration Review, like for example the presence of high levels of unextracted 

radioactivity and the use of foreign soils, for bromuconazole’s current use pattern, the only 

studies required are hydrolysis, aerobic soil metabolism and batch equilibrium 

(adsorption/desorption). Should the registrant wish to add outdoor uses to the chemical in 

the future, additional data and/or studies may be required.
26

Table 10. Submitted Environmental Fate Data for Bromuconazole

OCSPP 

Guideline

Data 

Requirement

Submitted 

Studies 

(MRID)

Study 

Classifications

Are data 

needed to 

conduct risk 

assessment?

Comments and/or Justification and 

Assumptions EPA will Make in 

Absence of Data

835.2120 Hydrolysis 42937143 Acceptable No --

835.2240 Aqueous 

photolysis

42937144 Acceptable No --

835.2410 Soil photolysis 43153401 Acceptable No --

835.4100 Aerobic soil 

metabolism

42937145, 

42937146, 

42937147

Acceptable No --

835.4200 Anaerobic soil 

metabolism

None Waived No Waived in 1994 since there is an 

anaerobic aquatic metabolism study (DP 

Barcodes D199537 & D200601, dated 

09/26/1994). These data are not 

required for the current use pattern.

835.4300 Aerobic aquatic 

metabolism

None Waived No Waived since the test substance is not 

intended for aquatic uses (DP Barcodes

D199537 & D200601, dated 

09/26/1994). These data are not 

required for the current use pattern.

835.4400 Anaerobic 

aquatic 

metabolism

42937148 Acceptable No --

835.1230

835.1240

Adsorption/ 

desorption and 

leaching

42937151 Acceptable No --

42937149, 

42937150

Acceptable

835.1410 Volatility –

laboratory

None Waived No Waived since the vapor pressure is low 

(DP Barcodes D199537 & D200601, 

dated 09/26/1994).

835.6100 Terrestrial field 

dissipation

43093501 Acceptable No --

835.6200 Aquatic field 

dissipation

None Not applicable No --

850.1730 Fish 

bioconcentration

42937152, 

42937153, 

43033101

Acceptable No --

850.6100 ECM/ILV Water, 

Soil, Sediment

None Not applicable No Not required due to the low exposure 

potential.

ECM/ILV = Environmental Chemistry Method/Independent Laboratory Validation

b. Effects

Table 11 and Table 12 identify ecological effects studies by MRID that offer data for each 

guideline requirement, as well as study classifications and whether or not further data are 

needed in order to support risk assessment. Bromuconazole is practically nontoxic to avian 

species on an acute oral and subacute dietary basis. The results of the 96-hour acute toxicity 

studies indicate that bromuconazole is moderately toxic to fish and very highly toxic to aquatic 

invertebrates in the formulation tested. If additional data examining the toxicity of the TGAI 

of bromuconazole to freshwater invertebrates is not received, future assessments would use 
27

the formulated product study (MRID 42938009) to assess acute toxicity of bromuconazole 

on freshwater invertebrates where exposure levels are of concern. Rationale for the 

additional data requested is presented below the tables.

Table 11. Submitted Aquatic Ecological Effects Data for Bromuconazole

OCSPP Data 

Requirement

Submitted 

Studies 

(MRID)

Study 

Classifications

Toxicity 

Classification

Are data 

needed to 

conduct 

risk 

assessment?

Justification 

and 

Assumptions 

EPA will 

Make in 

Absence of 

Data

Guideline

850.1010

Freshwater 

invertebrate 

acute toxicity

42937118 Invalid Moderately 

toxic No

Given the 

unlikelihood 

of exposure, 

the low 

concentrations 

should 

exposure 

occur, and the 

comparability 

of toxicity of 

the TEP to 

EFSA 

assessments

additional 

data are not 

needed at this 

time.

42938009

Acceptable for 

formulation 

only

Very Highly 

toxic No

850.1025 Estuarine/marine

invertebrate (None) (N/A) (N/A)

No -- 850.1025 acute toxicity (None) (N/A) (N/A)

850.1025 (None) (N/A) (N/A)

850.1075 Freshwater fish 

acute toxicity 

42938008 invalid

No --

42937117 Acceptable Moderately 

toxic

42937116 Acceptable Moderately 

toxic

42938007 Supplemental Moderately 

toxic

850.1075

Estuarine/marine

fish acute 

toxicity 

(None) (N/A) (N/A)

No -- (None) (N/A) (N/A)

850.1300

Freshwater 

invertebrate 42937120 Acceptable (N/A) No --

life cycle 42938010 (N/A)

850.1350 Estuarine/marine

invertebrates (None) (N/A) No --
28

OCSPP Data 

Requirement

Submitted 

Studies 

(MRID)

Study 

Classifications

Toxicity 

Classification

Are data 

needed to 

conduct 

risk 

assessment?

Justification 

and 

Assumptions 

EPA will 

Make in 

Absence of 

Data

Guideline

life cycle (N/A)

850.1400

Freshwater fish 

42937119 Acceptable (N/A)No -- early-life stage (N/A)

850.1400

Estuarine/marine

fish (None) (N/A) (N/A) No --

early-life stage (N/A)

850.1500 Fish life cycle (None) (N/A) (N/A) No --

850.4400

Aquatic plant 

Toxicity Test 

using Lemna 

spp.

43018512 (N/A) (N/A) No --

850.4500 Algal toxicity

42937140 (N/A) (N/A) No --

42937139 (N/A) (N/A) No --

42938012 (N/A) (N/A) No --

42937141 (N/A) (N/A) No --

850.4550 Cyanobacteria 42937142 (N/A) (N/A) No --

Table 12. Submitted Terrestrial Ecological Effects Data for Bromuconazole

OCSPP 

Guideline

Data 

Requirement

Submitted 

Studies 

(MRID)

Study 

Classifications Toxicity

Are data 

needed for 

risk 

assessment?

Current 

Additional 

Data Need

850.2100 Avian oral 

toxicity

42937112 Acceptable Practically 

non-toxic No Passerine test 

is not needed 

due to lack of 

exposure 

pathways. --

42937113 Acceptable Practically 

non-toxic No

Passerine 

species - No
29

850.2200 Avian dietary 

toxicity 

42937114 Acceptable Practically 

non-toxic No

--

42937115 Acceptable Practically 

non-toxic No

850.2300 Avian 

reproduction

No

-- No

NonguidelineAvian 

inhalation (None) (N/A) No --

850.3020

Honey bee 

acute contact 

toxicity

(None) (N/A) No --

850.3030

Honey bee 

residue on 

foliage

(None) (N/A) No --

850.3040

Field testing 

for 

pollinators

(None) (N/A) No --

850.4100

Seedling 

Emergence 

and Seedling 

Growth

(None) (N/A) No --

850.4150 Vegetative 

Vigor (None) (N/A) No --
30

13. References 

NPIRS. 2015. Bromuconazole federal/state registrations. National Pesticide Information 

Retrieval System (NRIRS). Accessed March 2015 at http://npirs.ceris.purdue.edu

(Accessed by BEAD March 2015).

USEPA. 1998. Guidelines for Ecological Risk Assessment. EPA/630/R-95/002F. 

Published in 63 FR 26846; May 14, 1998. U.S. Environmental Protection Agency, 

Washington, DC. April, 1998.

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

Pesticide Programs. United States Environmental Protection Agency (USEPA). 

Environmental Fate and Effects Division. Office of Pesticide Programs. Available 

at http://www.epa.gov/espp/consultation/ecorisk-overview.pdf.

USEPA. 2012. Estimation Programs Interface SuiteTM for Microsoft® Windows, v 4.11. 

United States Environmental Protection Agency, Washington, DC, USA. The 

program can be downloaded from the following URL: 

http://www.epa.gov/oppt/exposure/pubs/episuite.htm (accessed April 16, 2015).

USEPA. 2015a. BEAD Chemical Profile (BCP) for Registration Review: Bromuconazole 

(120503). United States Environmental Protection Agency. Biological and 

Economic Analysis Division. Office of Pesticide Programs. Dated March 31, 2015.

USEPA. 2015b. Exposure and Fate Assessment Screening Tool (E-FAST) Version 2.0 

Documentation Manual. Prepared for the USEPA, Office of Pollution Prevention 

and Toxics. Prepared by Versar, Inc., Springfield, VA. Manual is dated October 

2007, and model E-FAST 2014 is dated March 5, 2015. URL: 

http://www.epa.gov/oppt/exposure/pubs/efast.htm (accessed April 16, 2015).

For the environmental fate and ecological effects bibliography, refer to the Appendix 1.
31

Appendix 1. Bromuconazole Bibliography

Fate Chemistry Bibliography

Hydrolysis Guideline 835.2120

MRID Citation Reference

42937143 Corgier, M. (1990) LS860263 Hydrolyses at 25-degrees C of LS850646 and 

LS850647, the Diastereoisomers of LS860263: Amendment No. 1: Lab Project 

Number: 89-05: AG/CRLD/AN/9016170: CRLD/AN/VP/9316281. Unpublished study 

prepared by Rhone-Poulenc Secteur Agro. 66 p. 

Photodegradation in Water Guideline 835.2240

MRID Citation Reference

42937144 Yeomans, P.; Waring, A. (1990) (Carbon 14)-LS 860263: Photodegradation in 

Sterile, Aqueous Solution: Lab Project Number: 6541-68/108: 68/108: P5817D. 

Unpublished study prepared by Hazleton UK. 187 p. 

Photodegradation in Soil Guideline 835.2410

MRID Citation Reference

43153401 Austin, D.; Fitzmaurice, M.; Smith, E. (1992) Soil Photolysis Study: Bromuconazole 

(carbon 14): Lab Project Number: P91/173. Unpublished study prepared by RhonePoulenc Agriculture Ltd. 99 p. 

Aerobic Soil Metabolism Guideline 835.4100

MRID Citation Reference

42937145 Robles, J.; Adrian, P. (1990) LS860263 Aerobic Soil Metabolism: Amendment No. 

2: Lab Project Number: 88-19: AG/CRLD/AN/9016236: CRLD/AN/VP/9316283. 

Unpublished study prepared by Rhone-Poulenc Secteur Agro. 69 p.

42937146 Robles, J.; Adrian, P. (1990) LS860263 Rate of Degradation in Two Soils Under 

Aerobic Conditions at 10-degrees C and 22-degrees C: Amendment No. 1: Lab 

Project Number: 89-01: AG/CRLD/AN/9016142: CRLD/AN/VP/9316561. 

Unpublished study prepared by Rhone-Poulenc Secteur Agro. 47 p. 

42937147 Adrian, P.; Robles, J. (1991) Carbon 14-LS860263 Aerobic Soil Metabolism (10-

times Dose): Amendment No. 1: Lab Project Number: 91-08: 

AG/CRLD/AN/9116788: CRLD/AN/VP/9316280. Unpublished study prepared by 

Rhone-Poulenc Secteur Agro. 84 p. 
32

Anaerobic Aquatic Metabolism Guideline 835.4400

MRID Citation Reference

42937148 Robles, J.; Adrian, J. (1990) LS860263 Anaerobic Aquatic Soil Metabolism Study: 

Amendment No. 1: Lab Project Number: 88-20: AG/CRLD/AN/9016298: 

CRLD/AN/VP/9316284. Unpublished study prepared by Rhone-Poulenc Secteur 

Agro. 68 p. 

Leaching/adsorption/desorption Guideline 835.1240

MRID Citation Reference

42937149 Ayliffe, J.; Doble, M.; Outram, J.; et al. (1990) Fungicides: LS 860263-(Carbon 14): 

Leaching Study with Four Soils: Lab Project Number: D. AG. 1543: 1543. 

Unpublished study prepared by Rhone-Poulenc Agriculture Ltd. 53 p. 

42937150 Hardy, I.; Outram, J.; Reeves, G. (1991) Fungicides: LS 860263-(Carbon 14): 

Spectroscopic Analysis of Samples from the Leaching Study: Lab Project Number: 

D. AG. 1617: 1617. Unpublished study prepared by Rhone-Poulenc Agriculture Ltd. 

17 p. 

42937151 Dini, A.; Heiderich, D. (1989) LS860263 Soil Sorption Studies: Amendment No. 1: 

Lab Project Number: 88-17: AG/CRLD/AN/8915864: CRLD/AN/VP/9316279. 

Unpublished study prepared by Rhone-Poulenc Secteur Agro. 119 p. 

Terrestrial Field Dissipation 835.6100

MRID Citation Reference

43093501 Norris, F. (1994) A Terrestrial Field Soil Dissipation Study with Bromuconazole: Lab 

Project Number: EC/90/131, RP/1163, 44203. Unpublished study prepared by 

Rhone-Poulenc Ag Co., Colorado Analytical Research & Development Corp., 

Agvise, Inc. 1266 p. 

Fish Bioaccumulation 850.1730

MRID Citation Reference

42937152 Caley, C.; Cameron, B.; Chapleo, S. (1990) Carbon 14-LS 860263 Bioaccumulation 

Test in Bluegill Sunfish: Lab Project Number: 6635: IRI 142985: 142985. 

Unpublished study prepared by Inveresk Research International. 83 p. 

42937153 John, A.; Lowden, P.; Savage, E. (1992) Fungicides: Bromuconazole Investigation 

of Metabolites from a (Carbon 14)-Bromuconazole Bioaccumulation Test in Bluegill 

Sunfish: Lab Project Number: 142985: P91/113. Unpublished study prepared by 

Rhone-Poulenc Agriculture Ltd. 36 p. 
33

43033101 John, A.; Lowden, P.; Savage, E. (1993) Fungicides: Bromuconazole: Addendum: 

Investigation of Metabolites from a (carbon 14)-Bromuconazole Bioaccumulation 

Test in Bluegill Sunfish: Lab Project Number: P91/113: 142985. Unpublished study 

prepared by Rhone-Poulenc Agriculture Ltd. 16 p. 

Ecological Effects Bibliography

Avian Acute Oral Toxicity Test Guideline 850.2100 

MRID Citation Reference

42937112 Pedersen, C. (1993) LS 860263 Technical: 21-Day Acute Oral LD50 Study in 

Bobwhite Quail: Revised Report: Lab Project Number: 89 QD 131. Unpublished 

study prepared by Bio-Life Associates, Ltd. 28 p. 

42937113 Pedersen, C. (1993) LS 860263 Technical: 21-Day Acute Oral LD50 Study in 

Mallard Ducks: Revised Report: Lab Project Number: 89 DD 68. Unpublished study 

prepared by Bio-Life Associates, Ltd. 28 p. 

Avian Dietary Toxicity Guideline 850.2200 

MRID Citation Reference

42937114 Pedersen, C. (1993) LS 860263 Technical: 8-Day Acute Dietary LC50 Study in 

Bobwhite Quail: Revised Report: Lab Project Number: 89 QC 129. Unpublished 

study prepared by Bio-Life Associates, Ltd. 84 p. 

42937115 Pedersen, C. (1993) LS 860263 Technical: 8-Day Acute Dietary LC50 Study in 

Mallard Ducklings: Revised Report: Lab Project Number: 89 DC 127: HLA 6012-

274: AR 59-88 (E). Unpublished study prepared by Bio-Life Associates, Ltd. 88 p. 

Avian Reproduction Guideline 850.2300 

MRID Citation Reference

43948001 Jorgensen, K.; Svendsen, O. (1994) Bromuconazole: Avian Reproduction Test: 

(Japanese Quail): Lab Project Number: 14000. Unpublished study prepared by 

Scantox DK. 380 p. 

43908404

Acute Toxicity to Freshwater Fish Guideline 850-1075

MRID Citation Reference
34

42937116 Sousa, J. (1990) LS 860263-Acute Toxicity to Bluegill (Lepomis macrochirus) 

Under Flow-Through Conditions: Final Report: Lab Project Number: 89-11-3151: 

10566.0489.6133.105. Unpublished study prepared by Springborn Labs, Inc. 40 p. 

42937117 Sousa, J. (1990) LS 860263-Acute Toxicity to Rainbow Trout (Oncorhynchus 

mykiss) Under Flow-Through Conditions: Final Report: Lab Project Number: 89-11-

3152: 10566.0489.6133.108. Unpublished study prepared by Springborn Labs, Inc. 

39 p. 

42938007 Douglas, M.; Halls, R.; Anderson, A.; et al. (1993) The Acute Toxicity of LS 860263 

Formulation EXP 10064 to Rainbow Trout (Oncorhynchus mykiss): Lab Project 

Number: RNP 393/911458. Unpublished study prepared by Huntingdon Research 

Centre Ltd. 31 p. 

42938008 Douglas, M.; Halls, R.; Anderson, A.; et al. (1992) The Acute Toxicity of LS 860263 

Formulation EXP 10064 to Common Carp (Cyprinus carpio): Lab Project Number: 

RNP 385/911456. Unpublished study prepared by Huntingdon Research Centre 

Ltd. 27 p. 

Acute Toxicity to Freshwater Invertebrates

Guideline 850-1010 or 850-1020 

MRID Citation Reference

42937118 McNamara, P. (1990) LS 860263-Acute Toxicity to Daphnids (Daphnia magna) 

During a 48-Hour Flow-Through Exposure: Amended Final Report: Lab Project 

Number: 89-10-3130: 10566.0489.6133.115. Unpublished study prepared by 

Springborn Labs, Inc. 40 p. 

42938009 Douglas, M.; Halls, R.; Anderson, A.; et al. (1992) The Acute Toxicity of LS 860263 

Formulation EXP 10064 to Daphnia magna: Lab Project Number: RNP 392/911457. 

Unpublished study prepared by Huntingdon Research Centre Ltd. 28 p. 

Acute Toxicity to Marine Estuarine Fish 

Guideline 850-1075 

MRID Citation Reference

44193701

Sousa, J. (1996) Bromuconazole Technical--Acute Toxicity to Sheepshead 

Minnow (Cyprinodon variegatus) Under Flow-Through Conditions: Final Report: 

Lab Project Number: 96-8-6625: 10566.0396.6389.505: 052295/FIFRA/505. 

Unpublished study prepared by Springborn Labs., Inc. 73 p. 

Acute Toxicity to Estuarine/Marine Crustacean

Guidelines 850-1035 or 850.1045 
35

MRID Citation Reference

44193703

Sousa, J. (1996) Bromuconazole Technical--Acute Toxicity to Mysids (Mysidopsis 

bahia) Under Flow-Through Conditions: Final Report: Lab Project Number: 96-7-

6590: 10566.0396.6390.515: 052295/FIFRA/515. Unpublished study prepared by 

Springborn Labs., Inc. 73 p. 

Acute Toxicity to Estuarine/Marine Mollusk Shell Deposition

Guideline 850.1025 

MRID Citation Reference

44193702 Dionne, E. (1996) Bromuconazole Technical--Acute Toxicity to Eastern Oyster 

(Crassostrea virginica) Under Flow-Through Conditions: Final Report: Lab Project 

Number: 96-7-6591: 10566. 0396.6391.504: 052295/FIFRA/504. Unpublished study 

prepared by Springborn Labs., Inc. 71 p. 

Fish Early Life Stage (Freshwater or Marine)

Guideline 850.1400

MRID Citation Reference

42937119 Machado, M. (1992) Bromuconazole-The Toxicity to Fathead Minnow (Pimephales 

promelas) During an Early Life-Stage Exposure: Final Report: Lab Project Number: 

10566.1291.6214.120: 92-6-4292. Unpublished study prepared by Springborn Labs, 

Inc. 81 p. 

42938011 Douglas, M.; Halls, R.; Anderson, A.; et al. (1992) The Prolonged Toxicity of LS 

860263 Formulation EXP 10064 to Rainbow Trout (Oncorhynchus mykiss): Lab 

Project Number: RNP 382/911528. Unpublished study prepared by Huntingdon 

Research Centre Ltd. 38 p. 

Freshwater Aquatic Invertebrate Life Cycle Study

Guideline 850.1500

MRID Citation Reference

42937120

Douglas, M.; Halls, R.; Anderson, A.; et al. (1993) An Assessment of the Effects of 

LS 860263 on the Reproduction of Daphnia magna: Lab Project Number: RNP 

381/911473. Unpublished study prepared by Huntingdon Research Centre, Ltd. 69 

p. 
36

42938010

Douglas, M.; Halls, R.; Anderson, A.; et al. (1992) An Assessment of the Effects of 

LS 860263 Formulation EXP 10064 on the Reproduction of Daphnia magna: Lab 

Project Number: RNP 386/920211. Unpublished study prepared by Huntingdon 

Research Centre Ltd. 60 p. 

Algal Plant Toxicity Test Tiers I and II Guideline 850.5400

MRID Citation Reference

42937139

Hoberg, J. (1993) Bromuconazole Technical-Toxicity to the Freshwater Alga, 

Selenastrum capricornutum: Final Report: Lab Project Number: 93-4-4713: 

10566.0193.6255.430. Unpublished study prepared by Springborn Labs, Inc. 61 p. 

42937140

Hoberg, J. (1993) Bromuconazole Technical-Toxicity to the Freshwater Diatom, 

Navicula pelliculosa: Final Report: Lab Project Number: 93-4-4717: 

10566.0193.6256.440. Unpublished study prepared by Springborn Labs, Inc. 60 p. 

42937142

Hoberg, J. (1993) Bromuconazole Technical-Toxicity to the Freshwater Alga, 

Anabaena flosaquae: Final Report: Lab Project Number: 93-4-4734: 

10566.0193.6258.420. Unpublished study prepared by Springborn Labs, Inc. 61 p. 

42938012 Douglas, M.; Halls, R.; Anderson, A.; et al. (1992) The Algistatic Activity of LS 

860263 Formulation EXP 10064: Lab Project Number: RNP 383/911512. 

Unpublished study prepared by Huntingdon Research Centre Ltd. 27 p. 

43018512

Hoberg, J. (1993) Bromuconazole Technical--Toxicity to the Marine Diatom, 

Skeletonema costatum: Lab Project Number: 93/4/4732: 10566/0193/6257/450. 

Unpublished study prepared by Springborn Labs, Inc. 62 p. 

Aquatic Plant Toxicity Test using Lemna spp. Tiers I and II

Guideline 850.4400

MRID Citation Reference

42937141 Hoberg, J. (1993) Bromuconazole Technical-Toxicity to Duckweed, Lemna gibba: 

Final Report: Lab Project Number: 93-4-4733: 10566.0193.6259.410. Unpublished 

study prepared by Springborn Labs, Inc. 61 p.