### UNITED STATES ENVIRONMENTAL PROTE C TION AGENCY
WASHI N GTO N

, D.C. 20460

OFFICE OF CHE M ICAL SAFETY AND P O L LUTI O N P RE VE N T I O N

September 15, 2015

MEMORAN D UM

Su bj ect:



### To:

Fro m :

R ev i ewe r :

T hr oug h : Preliminary Eco l ogical Risk Assessment for Registration Review for
Bromuconazole (PC Code: 12 0503 ; DP Barcode: D 42726 4 )

James Parker

, Chemica l Review Manager
Thomas Moriarty

, Team Leader
Neil Anderson

, Branch Chief

. Risk Management and Implementation Branch 1
Pesticide Re-Eva l uation Division (7508P)

Jose 

### L. Melendez

, Chemist 

# p&te

.,,.. bc-4-**~4** Geoffrey Sinclair

, Ph.D., Biologist ,,/,,,.,.,
Environmental Risk Branch 5 ,,__/
E nvironmental Fate and Effects Division (7507P)

\) Allen Vaughan

, Biolog i st 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 Rev i ew 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 l ack of a complete exposure pathway
from the use s i te to non

- target terrestria l and aquatic organisms.

In addition to an incomp l ete 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 D i vision (BEAD)

, and a relative l y lim i ted geographic use

. Therefore, EFED has determ i ned that a fu ll ecological risk assessment for bromuconazole
is not necessary based on 

### d e 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 aff ect 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 reco mmended 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, ca nal, 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 list ed species and their designated critical habitat

.

### 3 

## 1. Executive Summary

The Environmental Fate and Effects Division (EFED ) has completed the preliminary ecological risk assessment a s part of the registration review of b romuconazole

. 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 F orum De Minimis Subgroup.

Laboratory and field data indicate that bromuconazo le is relatively persisten t in the environment. For bromuconazole, aqueous photolysis is not an important dissipation pathway. Photodegradation on soil occurs slowly. Aerobi c 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 L S850646. Freundlich K F 

### values of 4.5 to 37.5 and K FOC 

### 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 K OW 

### , bromucona zole 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 fre shwater invertebrates are sensi tive 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 Selenastr um 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 th e 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 pr otective. 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 i rrigation 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

- t arget organisms, including listed species and their designated critical habitat

.



## 2. Introduction

EFED investigated the most recent environmental fate assessments and ecological effects assessments for b romuconazole 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 R egistration R eview . In addition, EFED considered the latest Agency science policies and risk assessment methodologies. The structure of b romuconazole , 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) classifi cation i s G

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

- demethylase in sterol biosynthesis ( erg11/cyp51 )

. I ts Group Name is DMI

- fungicides ( D e M ethylation I nhibitors) (SBI: Class I) . I ts FRAC Code is 3. 1 

### The DMI fungici des 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 f or 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 s urfaces. 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,

t he 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 o r 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 state ments are present in the label:

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

PESTICI DE DISPOSAL Wastes resulting from the use of this product may be disposed of on site or at an approved waste disposal facility.

CONTAINER DIS POSAL Triple rinse (or equivalent). Then puncture and dispose of in a sanitary landfill or by other procedures approved by State and 1 ocal 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 2015 a )

. It should be pointed out that the profile indicates that... “ California state registration information is not found in the National Pesticide Information Retrieval System (NPIR S, 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 b romuconazole

. Since there are no food uses , and due to the limite d 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 b romuconazole

. Aquatic benchmarks have not been establishe d 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

- dichloro

phenyl) tetrahydro

- 2

- furanyl]methyl]

- 1 H

- 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 c ode 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 Bromucona zole (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]

- 1 H

- 1,2,4

- triazole --- Bromuconazole data sheet B

CAS No. Bromuconazole: 116255

- 48

- 2 LS850646 : 114544

- 80

- 8 LS85064 7: 114544

- 819 --- Bromuconazole data sheet B
DAR dated 10/09

Molecular mass (molecular formula) 377.1 g/mol ( C 13 H 12 BrCl 2 NO 3 )

-- - (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.4.1 1

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 (2 0 ° 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 ) LS85064 7 20.8 mg/L in distilled water 17.0 mg/L in water (pH 5) 22.1 mg/L in water (pH 9 ) Relatively s oluble EPA Fact Sheet dated 2002, and Product Chemistry review

Henry’s Law Constant (2 0 °C) LS850646 8 .1 x10

- 11 atm

- m 3 /mol LS85064 7 9.5 x10

- 11 atm

- m 3 /mol Not expected to volatil iz e from water or wet surfaces Summary report provided by the registrant

Log octanol

- to

water partition coefficient (log
K OW ) (2 0 °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 LS85064 7 @ pH 4, 5, 7, and 9. Stable at all pH values. MR ID 42937143 (A)
Aqueous photolysis
half

- life (25 ° C) 18.2 d (FL summer sunlight equivalent ) at pH 4; Stable at pH 9. Not a n important degradation pathway MRID 42937144 (A)
Soil photolysis
half

- life (25 ° C

, 50°N ) 11 weeks ( extrapolated beyond the study duration) Not a n important degradation pathway MRID 43153401 (A)

### 8 Parameter Value A Description Source

Aerobic soil metabolism half

life (10 and 22°C) French LS 770 d @ 10°C ; 339 d @ 22°C (SFO) for bromuconazole; LS850646 and LS 850647 degraded with calculated ha1 f

- 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

A na erobic soil metabolism half

life (25 ° C) No study available , but not required for the current greenhouse use pattern. --- ---

Aerobic aquatic metabolism half

life (25 ° C) No study available , but not required for the current greenhouse use pattern. --- ---

Anaerobic aquatic metabolism half

life (22 ° C) French LS 370 d (bromuconazole); LS850646 and LS 850647 degraded with calculated ha1 f

- 1ives of 530 and 360 d, respectively

. Persistent under these conditions MRID 42937148 (A)

Mobility

Freundlich soil

water partition coefficients (K F ) 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 LS85064 7 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

O rganic carbon

normalized Freundlich partition coefficients (K FOC ) LS850646 French LS 2 : 489 L/Kg OC French SL 5 : 978 L/Kg OC French L 6 : 474 L/Kg OC German LS 8 : 1086 L/Kg OC LS85064 7 French LS 2 : 697 L/Kg OC French SL 5 : 1084 L/Kg OC French L 6 : 627 L/Kg OC German LS 8 : 1539 L/Kg OC LS850646 Moderately mobile to slightly mobile

LS85064 7 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 contai ned 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 d istilled water. In the sandy 1 oam 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 di astereoisomers 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 s and) ; 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 (steady

state); depuration

rate (Bluegill sunfish) 56x (edible)

, 277x (inedible)

, 160 x (whole) for bromuconazole total residues ; 70

- 86% depuration in 1 day ; [ 14 C] b romuconazole 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 ::::: (a ccessed April 16, 2015).

D E ven 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 r egister additional uses, EFED may request additional data or information.

### 10 Laboratory and field data indicate that bromuconazol e is moderately persistent to persistent in the environment. Bromuconazole photolyzes in shallow, clear surface waters with a half

life = 18 days , indicating that this is not an important dissipation pathway.
P hotodegradation on soil occurs slowly. Aerobic soil and anaerobic aq uatic 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 K F 

### values of 4.5 to 37.5 and
K F OC 

### s of 474 to 1539 were reported in four soils, with adsorption weakest i n 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 K OW 

### , b romuconazole did not bio concentrate significantly in bluegill sunfish.

Bromuconazole is moderately persistent to persistent with a surf ace 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 LS

850647. In addition to parent, CO 2 

### and soil

- bound residues ac counted 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 l ikely 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, a nd 9 and degraded in an anaerobic aq uatic metabolism study with a half

- life of approximately 1 year.

Bromuconazole showed low mobility in soil. Freundlich K ads 

### values of 4.5 to 37.5 were reported in four European soils. The potential mobilities of the i ndividual diastereoisomers (LS

- 850646 and LS

- 850647) were comparable i n each s oil tested. Adsorption appeared to be positively associated wi th soi l organi c matter content: the potential for bromuconazole residues to be transported with water seems to be greatest in soi ls low i n organic matter. Soil col umn leaching studies of unaged and aged (30 days) bromuconazole residues showed low mobility in 30

- cm soi l columns containing unaged bromuconazole residues leached with 50.8 cm of d istilled water. >62% o f t he applied radi o activi ty remained i n the upper 6

- cm soi l layer. 4.1% l eached below a de pth o f 18 cm. and. column l eachates contained a maximum of 0.6% of the app l ied radioactivity. A parallel study usin g bromuconazole residues aged i n soi l for 30 days yie lded similar results. In the sandy loam column. 72% of the applied radioactivity was recovered from the 0

- 6 cm soi l layer, ≤ 3.3% leached below 18 cm. and 2.3% was retrieved from the leachate. In a loamy sand and lo am columns, ≥ 94% of the applied radioact ivity, was r ecovered from the 0

- 6 cm soi l layer.
≤ 3.2% moved greater than 1 2 cm in the column, and 2.4% was recovered from the leachate. The vap or pressure reported by the registrant for parent bromuconazole (3.0 x 10

- 8 

### mm Hg

### 11 at 25°C) indicates that volati li zation of residues is not li kely to occur significa ntly i n the

env i ron m ent.

Terrestrial f ield dissipation data submitted for four sites are consistent with laboratory data. In field studies conducted on plots of loam, silt loam, and loamy sand soi l s planted with turfgrass in Mississippi

, Cali forni a, North Carolina and Washington, bromuconazole was appl ied 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 upp er 15 cm soil layer with reported ha lf

- li ves of 7.3

- 13.8 months. The individual isome rs, LS

- 850646 and LS

850647, di ssipated with calculated ha lf

- lives of 8.7

- 13.5 and 5.8

- 14.1 months, respective l y. Residue concent rations accumulated i n soi l w ith re peate d appl ications. Generally, bromuconazole was not detected at appreciable concentrations below the 15

- cm s oil depth, although some movement into the 15

- 30 cm soil depth was observed at the Washington site.

Residues did not accum ulate s ignificantly i n bluegill sunfish exposed t o bromuconazol e in a f low

- through system. The maximum reported bi o concentration factors were 277x for visceral tissue, 56x for muscle tissue, and 160x for who le fish. Maximum mean concentrations of bromuconazole residues were 9.5 3 μ g/g i n the nonedible tissue after 7 days of exposure, 1.92 μg/g i n the edible tissue after 3 days, and 5.50 μ g /g in the whole fish after 7 da ys. The degradates identified i n the fish were LS 850920

- glucuroni de

, LS 850920, LS 860550

- glucuroni de, LS 8605 50, and LS 860364. B romuconazole was not isolated i n the fish tissue. Near complete depuratio n of accumulated residues wa s reported when fis h were transferred t o non

- contami nated water for 21 days

,



## a. **Transformation Products**

In the aqueous photolysis stud y, eight unidentified degradates were isolated from the solution, with Unknown 6 comprising 7.78

- 10.48% of the applied radioactivity. However,

o ther 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; LS 860364; LS 830730; "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 [ 14 

### C] 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 deg radates 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 [ 14 

### Clcompounds ("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) tetrahydrofurann e or LS87138 7, 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 at om f r om 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

- gl ucuroni de, LS 850920, LS 860550

- gl ucuronide

, LS860550, and LS860364. LS 850920

- glucuronide was completely eliminated from the fish tissue during depuration; the remaining compounds were partially eliminated (quantitative data not provided).



## b. **Un certainties** 

The aerobic soil metabolism and batch equi librium 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 use s 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

unextracte d. 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

ext racted 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 f or 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 b romuconazole . Although one major degradate (at ~10% AR) was detected in the a na erobic 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 ecol ogical 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 descriptio n 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 majo r components: the risk hypothesi s and a concep tual 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 stressor

initiated, 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 bromuconaz ole, 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 terr estrial and aquatic organisms. The label states under the ‘Pesticide disposal’ heading that “ Wastes resulti ng 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 e nd up in a n 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 th e 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 (LD 50 

### ), medial lethal concentration to 50% of tested organisms (LC 50 

### ), the no observ ed adverse effect level (NOAEL) , and the no obse rved 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, e xposure to non

- target terrestrial organisms is not anticipated for this use pattern , since greenhouses are enclosed. Incidental exposure to bodies o f 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

assum ing 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.



## M **easures 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 ECOT OXicology 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

, u sing 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, i ncidental exposure to bodies of water adjacent to gree nhouses 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 pr essure ).

• 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. 

## Model **ing 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) (4.53592x10 8 

### 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 , access ed 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,

respec tively, and most sensitive surrogate species tested to characterize the potential acute and chronic ecological effects of b romuconazole

. In addition, the tables provide a preliminary overview of the potential acute toxicity of bromuconazole by providing t he acute toxicity classifications. Based on the available ecotoxicity information, bromuconazole is moderatel y toxic to freshwater fish. On e study with a formulated product suggests that bromuconazole is very highly toxic to aquatic freshwater invertebra tes

. 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 fish 1 Acute Rainbow Trout

LC 50 = 1.7 mg/L Moderately toxic 42937117 ( Oncorhynchus mykiss )

Chronic (Early Life

Stage) 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 EC 50 = 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 ) EC 50 = 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)

Non

vascular Selenastrum capricornutum EC50 = 0.053 mg/L N/A 42937141

Anabaena flos

- aquae EC 50 = 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 daph n id studies with bromuconazole have comparable levels of toxicity (EFSA Journal 2010; 8(8): 1704). Given minimal anticipated ex posu re 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)

Birds 1 Acute Bobwhite quail LD 50 >2150mg/kg

bw Practically

non

- toxic 42937112 ( Colinus virginianus )

Sub

- acute dietary Bobwhite quail

LC 50 > 5000

ppm Practically

non

- toxic 42937114, Pedersen, 1990 ( Colinus virginianus )

### 20 Chronic N/A N/A N/A N/A

Mammals (for additional studies see
HED assessment) Acute Oral Laboratory rat

LD 50 = 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 B irds 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 in cident 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 i n 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 d escription 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**

– Integra tion 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 ar e 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/LC 50 or EC 50 0.5
Acute Restricted Use EEC/LC 50 or EC 50 0.1
Acute Endangered Species EEC/LC 50 or EC 50 0.05
Chronic Risk EEC/NOAEC 1

### 22 Risk Presumption RQ LOC

Terrestrial and Semi

- Aquatic Plants, and Aquatic Plants
Acute Risk EEC/EC 25 1 Acute Endangered Species EEC/EC 05 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 risk s from an incidental runoff scenario. Risk presumptions, along with the calculation of the corresponding RQs and LOCs, are tabulated below:

Table 7 . Acute and chron ic RQs for freshwater fish and invertebrates associated with greenhouse rose uses of bromuconazole 1

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 b ased on rainbow trout LC 50 = 1700 ug/L and fathead minnow NOAEC = 34 ug/L; and f or freshwater invertebrates based on Daphnia magna EC 50 = 85 ug/L and Daphnia magna NOAEC = 20 ug/L.



### Acute and chronic RQs for estuarine/marine fish and invertebrates coul d not be calculated since there is no toxicity data.

Table 9

. RQs for vascular and non

- vascular plants associated with greenhouse rose uses of bromuconazole 1

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 ) EC 50 = 160 μ g/L and f or non

- vascular plants, based

on Solenastrum capricornutum EC 50 = 53 μ g/L.



## b. **Risk Description**

In risk description, the results from the risk estimation are interpreted and synthesized in to 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 r elevant 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 discus sion 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 non

target 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 th e applications are made in diluted water in a greenhous e , 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 ad jacent 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 risk s. EFED assumed runoff of 100 gallons of diluted bromuconazole solution at the maximu m 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 m uch 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 o r exceed the acute endangered species LOC of 0.05 (based on Daphnia magna EC 50 

### = 85 μ g/L )

. T he runo ff volume needs to be above 9,58 0 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 tre atment 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 fol lowing 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 Assessment s** 

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.
D epartment of Agriculture (USDA) released a summary of their joint Interim Approaches for assessing risks to listed species fr om pesticides. The Interim Approaches were developed jointly by the a g encies in response to the N ational A cademy of S ciences’ (NAS) recommendations and reflect a common approach to risk assessment shared by the a gencies as a way of addressing scientific d ifferences 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 Produce rs. 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 E PA 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 P esticide P rogram D ialogue C ommittee (PPDC) and S tate

- FIFRA Issues Research and Evaluation Group ( SFIREG ) meetings, and held a stakeholder workshop in April 2014, allowing additional opportunities for stake holders 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 Registrati on Review decisions. The details of the joint Interim Approaches are contained in the white paper “Interim Approaches for National

Level 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 al l 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 t o 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 p otential 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 li sted species also will not be affected through indirect effects because of the poten tial 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 P rimary C onstituent E lements (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 h abitats, 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 soluti on, 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 EC 50 

### = 85 μ g/L ) . The runoff v olume was also calculated that would be sufficient to trigger risk to non

- listed aquatic taxa. Using the currently most sensitive endpoints, t he runoff v olume needs to be above 9,000 gallons to cause the RQ to exceed the non

- listed LOC

. Given that the se runoff volume s 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 identif ies 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 nearl y 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 Rev i ew, like for example the presence of high levels of unextracted radioactivity and the use of foreign soils, fo r 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 st udies 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 Barcode s 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 Barcode s 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 Barcode s 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 guid eline 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

- h our 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 presente d 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

850.101 0 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)

850.13 00 Freshwater invertebrate 42937120 Acceptable (N/A) No

--

life cycle 42938010 (N/A)

850.135 0 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)

850.14 00 Freshwater fish 42937119 Acceptable (N/A) No

-- early

- life stage (N/A)

850.14 00 Estuarine/marine fish (None) (N/A) (N/A) No

-- early

- life stage (N/A)

850.15 00 Fish life cycle (None) (N/A) (N/A) No

--

850.44 00 Aquatic plant Toxicity Test using Lemna

spp. 43018512 (N/A) (N/A) No

--

850.45 00 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

--
850.455 0 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

850.21 00 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

### 29 850.22 00 Avian dietary toxicity 42937114 Acceptable Practically

non

- toxic No

-- 42937115 Acceptable Practically

non

- toxic No

850.23 00 Avian reproduction No

-- No

Non

guideline Avian inhalation (None) (N/A) No

--

850.302 0 Honey bee

acute contact toxicity (None) (N/A) No

--

850.303 0 Honey bee residue on

foliage (None) (N/A) No

--

850.304 0 Field testing for pollinators (None) (N/A) No

--

850.41 00 Seedling Emergence and Seedling Growth (None) (N/A) No

--

850.415 0 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/esp p/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. 2015 a

. 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. 2015 b . 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://w ww.epa.gov/oppt/exposure/pubs/efast.htm (accessed April 16 , 2015).

For the environmental fate and ecological effects bibliography, refer to the Appen dix 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 Rhone

Poulenc Agriculture Ltd. 99 p.



### Aerobic Soil Metabolism Guideline 8 35.4100

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

- Poule nc 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 Sect eur Agro. 84 p.

### 32 Anaerobic Aquatic Metabolism Guideline 8 35.4 4 00

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 Agric ulture 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. Unpublish ed 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 Guid eline 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. (19 90) 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.; Hal ls, 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 Springbor n 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.



### Alga l 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 Technic al

- 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) Bromucon azole 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.