Page 1 of 3 OFFICE OF CHEMICAL SAFETY AND POLLUTION PRE VENTION UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON D.C., 20460

PC Code: 004005
DP Barcod e : D 420151
Date: September 5, 2014

MEMORANDUM

SUBJECT: Registration Review : Draft Ecological Risk Assessment and Endangered S pe cies

Effects Determination for d

- Allethrin

TO: M arianne Mannix

, Chemical Review Manager

Avivah Jakob, Team Leader Patricia Parrott, Branch Chief
R isk Management and Implementation Branch 3
Pesticide Re

- evaluation D ivi sion ( 750 8 P )

FROM: Sarah Winfield, Acting Branch Chief

Environmental Risk Branch IV Environmental Fate and Effects Division (7507P )

REVIEWED
BY : Cheryl Sutton, Ph.D., Environmental Scientist

Ed ward Scollon, Ph.D., Toxicologist
T homas Steeger , Ph.D., Senior Advisor Environmental Risk Branch IV (ERB4) Environmental Fate and Effects Division (7507P)

The Environmental Fate and Effects Division (EFED) has completed the draft ecological risk assessment and endangered species effects dete rmination for the pyrethroid insecticide d

allethrin (PC code 004005 )

. d

- Allethrin is one of the active ingredients (a.i.) considered in the
broader Registration Review of allethrins that includes multiple active ingredients 1 . However

, d

allethrin is the only a .i. contained with in allethrin products that is not currently pending
cancellation.

1 The Allethrins Registration Review case includes multiple active ingredients (bioallethrin, PC Code 004003; esbiothrin, PC Code 004007; esbiol, PC Code 004004; and d

- allethrin) that contain varyi ng amounts of two to four
isomers. d

- A llethrin is an enrichment contain ing 4 of the possible 8 allethrin isomers.Page 2 of 3

The use pattern for allethrins has changed through the Registration Review process. After the
General Data Call

- In ( GDCI ) was published in October 2011 to address uncertainties identified in the final work plan for the Regist r ation Review of allethrins , the technical and end

- use registrants indicated that they would no longer support any of the registrations as of December
2016 . The only exceptions were the end

- use registrants for three products: EPA Registration
Numbers 71910

- 2,

- 3, and

- 4. In July 2013, the registrants for these products submitted to the Registration Divis i on ( RD ) a Pesticide Registration Improvement Act ( PRIA ) action to amend
their Confidential Statement of Formulas ( CSFs ) so that their products could be sold after 2016. The Registration R eview G DCI for the allethrins issued in 2011 required a number of ecological and human health data requirements. These studies were identified as data gaps base d on the pre

cancellation use pattern. At the time of the EFED problem formulation 2 , the allethrins were used in residential indoor and outdoor space and surface sprays, total release foggers, and as a foliar spray for plants. The registrant s for the three remaining products submitted waiver request s or data to address all of the Registration R eview data requirements applicable to their products ; the waiver request s have been reviewed 3 and granted by EPA and the submitted studies have been
reviewed and foun d to be acceptable by EPA ; therefore, all Registration R evi ew data requirements for these three products have been addressed

.

For the currently registered uses ( i.e. , repellant candle lanterns intended for small outdoor settings), d

- allethrin is released into the air via vaporization of the compound by a heat source (dispersal appliance) , allowing the chemical to rise in to the air in the immediate vicinity of the dispersal appliance . For this use , the a.i. is volatilized by the heat source and is expected to dissipate rapidly via degradation and by dilution in the large volume of air into which it is
released. Ba sed on the available data, the use pattern, and conservative assumptions regarding exposure, none of the acute or chronic risk Levels of Concern (LOC s ) are exceeded for fish (and by extension to aquatic

- phase amphibians for which fish serve as surrogates ), aquatic invertebrates, birds (and by extension to terrestrial

- phase amphibians and reptiles for which birds serve as surrogates ), or mammals.

Because d

- allethrin is used as an insect repellant and has potential insecticidal properties, it is assumed that any terrestrial invertebrate ( e.g. , flying terrestrial invertebrate species) that is exposed to sufficient quantities of d

- allethrin ( i.e. , fl ying through the d

- allethrin released by the repellent candle lantern ) has the potential to be affected. However, g iven the relatively limited “repellency affect area” around the d

- allethrin dispensing device ( the label indicates the repellency affect are a is a 15

- foot diameter, that lasts for up to 4 hours ), the likely setting of use ( i.e. , in residential areas such as backyards , camp sites or hunting sites ), and the short half

- life of
d

- allethrin in air (<1 hour) , the likelihood of adversely affecting F e derally listed
threatened/ endangered (hereafter referred to as “listed”) terrestrial invertebrates is considered to

2 USEPA 2010. Registration Review: Preliminary Problem Formulation for Environmental Fate, Ecological Risk, and Endangered Species Assessments for the Allethrin . March 9, 2010, D371344. http://www.regulations.gov/#!documentDetail;D=EPA

- HQ

- OPP

- 2010

- 0022

- 0002

3 USEPA 2010b. EFED Review of the Data Waiver Request for Allethrins an d Terrestrial Plant and Honey Bee Toxicity Data Requirements for Registration Review . June 29, 2010, D 379419

. http://www.regulations.gov/#!documentDetail;D=EPA

- HQ

- O PP

- 2010

- 0022

- 0015Page 3 of 3

be low. For the same reasons , the likelihood of exposure and subsequent adverse effects to honey bees (

Apis mellifera ) or other pollinat ing insect species is considered low

. Furthermore

, the likelihood of bees being drawn to humans with in the repellent ’s effective area is considered
low.

There are currently no data available to assess the potential risk to terrestrial or aquatic plants
fro m the remaining registered use of d

- allethrin

. However, t he l ikelihood of adverse effects to pla nts is considered low because of the low exposure potential.

Therefore, d ue to a combination of low exposure and relative insensitivity to the active ingredi ent (for many taxa), the likelihood of adverse effects on species other than target organisms is expected to be low

. Because direct adverse effects are not expected for birds, reptiles, amphibians, mammals, fish, or aquatic invertebrates, and there is no reasonable expectation of adverse effects to plants or terrestrial invertebrates from exposure to d

- allethrin from its remaining use , the EPA makes a No Effect (NE) determination for all listed species.
EPA also has determined that no Habitat Modification is likely for designated critical habitats of listed species from the use of d

- allethrin.Page 1 of 27 REGISTRATION REVIEW

Draft Ecological Risk Assessment and Endangered Species Effects Determination for:

d

- Allethrin

(CAS No

. 584

- 79

- 2 ; USEPA PC # 00400 5 )

Cyclopropanecarboxylic acid, 2,2

- dimethyl

- 3

- (2

- methyl

- 1

- propen

- 1

- yl)

- , 2

- methyl

- 4

- oxo

- 3

- (2

- propen

- 1

- yl)

- 2

- cyclopenten

- 1

- yl ester

Prepared by: Sarah Winfield, Acting Branch Chief
EPA /OCSPP /OPP/EFED/ERB4

Reviewed by: Cheryl Sutton, Ph.D., Environmenta l Scientist Edward Scollon, Ph.D., Toxicologist
T homas Steeger, Ph.D., Senior Advisor
EPA /OCSPP /OPP/EFED/ERB4

U. S. Environmental Protection Agency Office of Pesticide Programs
Environmental Fate and Effects Division
Environmental Risk Branch IV
1200 Penn sylvania Ave., NW
Mail Code 7507P Washington, DC 20460

September 5 , 2014Page 2 of 27 TABLE OF CONTENTS

1. PROBLEM FORMULATION

................................ ................................ ................................ .......................... 3

N ATURE OF R EG ULATORY A CTION

................................ ................................ ................................ ............................ 3
P REVIOUS A SSESSMENTS

................................ ................................ ................................ ................................ ........... 4 Ecological Risk Assessments

................................ ................................ ................................ ................................ 4 Drinking Water Exposure Assessments

................................ ................................ ................................ ................ 5
S TRESSOR S OURCE AND D ISTRIBUTION

................................ ................................ ................................ ..................... 5
P ESTICIDAL M ECHANISM OF A CTION

................................ ................................ ................................ ........................ 6
O VERVIEW OF P ESTICIDE U SE AND U SAGE

................................ ................................ ................................ ................ 7
E NVIRONMENTAL F ATE AND T RANSPORT

................................ ................................ ................................ .................. 9
Mobilit y

................................ ................................ ................................ ................................ .............................. 10 Degradation

................................ ................................ ................................ ................................ ....................... 11
Bioaccumulation

................................ ................................ ................................ ................................ ................ 12 Monitoring

................................ ................................ ................................ ................................ ......................... 12
E COLOGICAL E FFECTS

................................ ................................ ................................ ................................ ............. 13 Effects to Aquatic Organisms

................................ ................................ ................................ ............................. 13 Effects to Terrestria l Organisms

................................ ................................ ................................ ........................ 14
Terrestrial Plants

................................ ................................ ................................ ................................ ............... 15
E COLOGICAL I NCIDENTS

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

2. RISK CHARACTERIZATIO N

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

R ISK E STIMATION

................................ ................................ ................................ ................................ .................... 16 Aquatic Animals

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

T errestrial Animals

................................ ................................ ................................ ................................ ............ 17
Plants

................................ ................................ ................................ ................................ ................................ . 18
R ISK D ESCRIPTION

................................ ................................ ................................ ................................ .................. 18
Uncertaintie s and Assumptions

................................ ................................ ................................ .......................... 19
E NDANGERED S PECIES A SSESSMENT

................................ ................................ ................................ ....................... 19
E NDOCRINE D ISRUPTOR S CREENING P ROGRAM

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

APPENDIX A: EPISUITE OUTPUT FOR ALLETHRIN S (CAS NO. 548

- 79

- 2)

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

APPENDIX B: INCIDENT DATA SYSTEM (IDS) FO R ALLETHRINS

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

APPENDIX C: T

- REX OUTPUT FOR ALLET HRINS

................................ ................................ ........................ 26Page 3 of 27

1. Problem Formulation

Nature of Regulatory Action

As part of the implementation of the Registration Review program pursuant to Section 3(g) of FIFRA, the Agency is evaluating all current and active registrations for allethrins 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 Ecologi c al Risk
Assessment

. 1

At the outset of Registration Review for allethrins, the allethrins , consisting of multiple active ingredients (a.i), were used in residential indoor and outdoor space and surface sprays, total release foggers, and as a foliar appli cation to plants. However, after the General Data Call

- In (GDCI 2 ) was published in October 2011 to address uncertainties identified in the final work plan for the Regist r ation Review of allethrins , t he technical and end

- use registrants indicated that they would no longer support any of the technical product registrations effective in September 2015
and the end

- use products in December 2016

. 3 The only exceptions were the end

- use registrants for three products: EPA Registration Numbers 71910

- 2,

- 3, and

- 4. The registrants for these products submitted to the Registration Divis i on (RD) a Pesticide Registration Improvement Act (PRIA) action to amend their Confidential Statement of Formulas (CSFs) so that their products
could be sold after 2016 . Additionally, t h e registrant for the three remaining products submitted
waiver request s for the Registration Review ecological effects data requirements applicable to the mat products, which have been granted 4

.

Additionally, although the Registration Review case for all ethrins involved multiple closely related active ingredients, the only active ingredient contained in the remaining supported uses is
d

- a llethrin . Consequently, although data involving all allethrin active ingredients are relied on to support th is assessm ent, the focus of this assessment is on d

- allethrin.

1 USEPA 1998

. Guidelines for Ecological Risk Assessment . U.S. Environmental Protection Agency, Risk Assessment Forum, Washington, DC, EPA/630/R095/002F, 1998. http://w ww.epa.gov/raf/publications/pdfs/ECOTXTBX.PDF

2 USEPA 2013. d

- Allethrin Generic Data Call In (GDCI

- 004005

- 1020). http://www.regulations.gov/#!documentDetail;D=E PA

- HQ

- OPP

- 2010

- 0022

- 0017

3 https://www.federalregister.gov/articles/2014/05/20/2014

- 11685/no tice

- of

- receipt

- of

- requests

- to

- voluntarily

cancel

- certain

- pesticide

- registrations

4 USEPA 2010b

. EFED Review of the Data Waiver Request for Allethrins and Terrestrial Plant and Honey Bee Toxicity Data Requirements for Registration Review

. June 29, 2010, D 379419

. http://www.regulations.gov/#!documentDetail;D=EPA

- HQ

- OPP

- 2010

- 0022

- 0015Page 4 of 27

Previous Assessments

For a more detailed review of previous assessments, please refer to the Registration Review: Preliminary Problem Formulation for Environmental Fate, Ecological Risk, and Endanger ed Species Assessments for the Allethrins 5

.

Ecological Risk Assessments

T he first synthetic pyrethroid, collectively referred to as “allethrins” was first registered in 1949.
Because the allethrin compounds are nearly identical except in the ratios an d amounts of the isomers, the ecological and environmental fate data for the allethrins have been bridged ( i.e

., allowing data on one compound to represent another compound) in previous Agency risk

assessments. The most recent national

- level ecological ri sk assessment was completed to support the R eregistration E ligibility D ecision (RED) for the allethrins in 2007 6

.

The RED indicated that , a lthough there were uncertainties regarding the extent of use in residential settings, the combined exposure from th e supported outdoor uses ( i.e ., spot treatments) wa s not likely to be substantial. Therefore, b ased on th e analysis in the assessment done for the RED, the supp orted outdoor allethrin s uses were expected to result in exposure levels below Agency acute ris k Levels of Concern ( LOCs ) for non

- target organisms in both aquatic and terrestrial environments. Therefore , the likelihood of adverse effects from acute

exposure wa s con sidered to be low. The likelihood of adverse effects from chronic exposure to
mammal s was also considered low; however, the potential risk to all other taxa from chronic exposure to allethrins could not be assessed due to a lack of data. T he RED concluded that potential risk to aquatic organisms from acute exposure in surface water resul ting from indoor

uses of allethrins ( e.g ., pet shampoos being washed down the drain) could not be dis counted; however, the pet shampoo use was cancelled as of April 2009.

Regarding Federally

- listed threatened/endangered species (hereafter referred to as listed species )

, the relationship of risk quotients (RQs) to acute and chronic risk LOCs could not be evaluated for the supported uses of allethrin s because RQs were not calculated in the assessment
conducted for the RED ; however, acute risks to listed species from outdoor uses of allethrins (with the possible exception of the fogger use) were not expected due to low application rates and the types of uses being assessed. T he potential for chronic risk s could not be dismissed
because of a lack of availab le data.

5 USEPA 2010. Registration Review: Preliminary Problem Formulation for Environ mental Fate, Ecological Risk, and Endangered Speci es Assessments for the Allethrins. March 9, 2010, D371344. http://www.regulations.gov/#!documentDetail;D=EPA

- HQ

- O PP

- 2010

- 0022

- 0002

6 USEPA, 2007

. Reregistration Eligibility Decision for Allethrins . June 29, 2007. http://www.epa.gov/pesticides/reregistration/REDs/allethrin_red.pdfPage 5 of 27

Drinking Water Exposure Assessments

The Agency has not previously conducted a drinking water assessment for the allethrins because
the chemical was considered to have mainly indoor non

- food use s and was labelled for only limited outdoor uses ( e.g., spot treatments, foggers). The likelihood of t he single remaining use pattern of d

- allethrin, i.e

., as a repellant candle lantern

, contaminating human drinking water

sources is considered low; therefore a drinking water assessment has not b e e n conduc ted to support a human dietary risk assessment for d

- allethrin.

Stressor Source and Distribution

A lthough the current assessment focuses on d

- allethrin , data from all of the allethrin mixtures are utilized for bridging to d

- allethrin

. The allethrin co mpounds from which data were bridged for
d

- allethrin are composed of mixtures of eight stereoisomers ( see Table 1 ). Following the approach used in the b ioallethrin r egistration s tandard and the allethrins RED 7

, it is assumed that
the allethrin mixtures are nearly identical except in the ratios and amounts of the isomers, which are assumed to be equipotent

. Additionally, to more fully characterize the environmental fate and transport of the allethrins in spite of numerous data gaps, data for t he structurally similar but naturally occurring compound

, pyrethrin 1 (PC Code 069008; CAS No. 121

- 21

- 1) are utilized in
the assessment in addition to the submitted data for the allethrins.

7 Ibid USEPA 2007

.Page 6 of 27

TABLE 1: Composition of the Allethrins 1

ISOMER Allethrin [PC C ode(s)]

Esbiol [004004] Esbiothrin

[004007] [formerly 004003/004004] Bioallethrin

[004003] d

- Allethrin 2

[004005] Allethrin

[004001]

d

- trans chrysanthemic acid of
d

- allethrolone 3 >90% 72% ≥46.5% 36.5% 18%

d

- trans chrysanthemic acid of
l

- allethrolone 5% 21% ≥46.5% 36.5% 18%

d

- cis chrysanthemic acid of d

allethrolone - 4

- - 9% 4.5%

d

- cis chrysanthemic acid of l

allethrolone - - - 9% 4.5%

l

- trans chrysanthemic acid of
d

- allethrolone - - - - 18%

l

- trans chrysanthemic acid of
l

- allethrolone - - - - 18%

l

- cis chrysanthemic acid of d

allethrolone - - - - 4.5%

l

- cis chrysanthemic acid of l

allethrolone - - - - 4.5%

1 Adapted from USEPA 1997 (D222638) 8

2 Trade Name is Pynamin Forte ® , and has been used in past EFED assessments to refer to this a.i.

3 Most insecticidally active isomer

4 Indicates <2%

Pesticidal Mechanism of Action

d

- A llethrin is a pyrethroid insecticide that acts on target pests by delay ing the closing of the voltag e

- gated sodium channel, prolonging the return of the neuron membrane potential to its resting state 9 . This delay in return to the resting state leads to hyperactivity of the nervous system which, in turn, can result in paralysis and/or death. P yre throids, such as d

- allethrin, are characterized by their ability to quickly immobilize insect pests, referred to as ‘knockdown’ capacity 10

.

8 USEPA 1997. Allethrin Stereoisomers: AgrEvo Environmental Health (AEH) Rebuttal of Agency requirements Concerning the Test Substance for Plant Metabolism Studies. From William O. Smith (HED) to Paula Deschamp (HED) D222638.

9 Soderl und

. 2002

. Toxicology 171:3

- 59

. 10 Ibid Soderlund 2002.Page 7 of 27

Overview of Pesticide Use and Usage

The main use of d

- allethrin is as a knockdown agent (de fined here as an agent that causes rapid paralysis that may be reversible and that may or may not lead to death) against a variety of flying and crawling insects, mites and spiders; however, they can also result in outright insect mortality ( i.e

., function as insecticides ) when used at higher rates. Outdoor uses of d

- allethrin will be limited to localized space “lanterns” that emit the compound from a n infused mat for up to 4
hours across a 15

- foot diameter space ; whereas all other uses will be cancelled b y December
2016

.

d

- A llethrin differs from most other pyrethroids previously assessed by the Agency’s Office of Pesticide Programs (OPP) because the outdoor use of the compound is limited strictly to small

scale residential use ( i.e ., there are no lar ge

- scale d

- allethrin uses such as agricultural or public health/mosquito abatement uses). Standard use rates typically reported for agricultural chemicals ( i.e ., lb/acre [lb/A] ) are not appropriate for end

- use products of d

- allethrin , due to the types o f uses for which they are registered; however

, to help characterize the use pattern, a conservative application rate of 0.0088 lb a.i./A has been calculated ( see Table 2 ).Page 8 of 27

Table 2 : Registered d

- Allethrin End

- use Products and Associated Use Patterns

Product Name (EPA Reg. No.) Active

Ingredient Type of Product and

Use Sites Label Language Relevant to Environmental Exposure Application
Rate **

ThermaCELL ® Mosquito Repellant

(71910

- 2) d

- allethrin

(21.97%) Repellant Candle

Lantern (pesticide infused mat, that is heated by
butane

- filled cartridge to dispense repellant)

Use sites are an average size deck, or patio, or outdoor campsite

. Pesticide Disposal and Container Handling:

- Non

- refillable container; do not
refill or reuse this container.

- If cartridge is empty or for used

mats: Do not reuse empty packaging, envelopes [wrappers] or cartridges. Do not puncture or incinerate empty cartridges. Place in trash or offer for recycling if
available.

- If cartridge is partly filled or for
unused mats: Call your lo cal solid waste agency for disposal
instructions.

- Never place unused mats down any
indoor or outdoor drain.

- For unwanted appliance [lantern]: Place in trash or offer for recycling if available

.

- Do not expose appliance/lantern or
mats to rain

Environmenta l Hazards:

- This product is toxic to fish
and aquatic invertebrates.

- Do not apply directly to

water. Do not contaminate

water when clean i ng equipment or disposing of equ i pment wash

water or rinsate

.

- Dr i ft may be hazardous to aquatic organisms in water adja cent to treated areas

. Pesticide infused

m ats last a
maximum of 4
hours

O ne appliance/lantern
for each 225 ft 2

Provides 15

- ft
diameter repellency

Mat weight* is
0.08 oz each

(0.017576 oz a

. i

. in each mat ; or 0.498 g/mat ) ThermaCELL ® Mosquito Repelle nt with
Earth Scent

(71910

- 3) d

- allethrin

(21.97%) Replacement mat

Use site inte nded for
where hunters may wait for game

.

ThermaCELL ® Mosquito Repellent
Candle Lantern

(71910

- 4) d

- allethrin

(21.97%) Repellant Candle

Lantern (pesticide infused ma t, that is heated by
butane

- filled cartridge to dispense repellant)

Use sites are backyards, yards, decks, patios, gardening, social events, spectator sports, sporting events and outdoor campsites

.

*Mat weight only specified on 71910

- 4, and assumed th e same for other products.

** For modeling purposes to assess exposure, an application rate of 0.14 oz a

. i

. /A or 0.0088 lb a.i./A was estimated for the candle use by assuming there are houses on quarter acre lots throughout a watershed; and that each house h ad two candles in the yard ( consistent with the Registration Revi ew Ecological Risk Assessment for metofluthrin, which has a similar use pattern ) 11 . Additionally, it was assumed that the entire
amount of a.i. from each candle is released into the environm ent at the same time, which leads to a very conservative estimate of potential

exposure.

11 USEPA 2013 b

. Registration Review: Preliminary Ecological Risk Assessment and Endangered Species Effects Determination for Metofluthrin . April 16, 2013, D403437.Page 9 of 27

Environmental Fate and Transport

While the environmental fate database for d

- allethrin is sparse, there are sufficient data available
to assess the environmental f ate of t he compound for the labeled use

. The physical/chemical and the environmental fate properties for the allethrins as a whole are presented in Table 3 . The majority of the data reported are for the isomer, d

- trans chrysanthemic acid of d

- allethrolon e ( d

trans allethrin ; which is 36.5% of d

- allethrin, see Table 1 ). Based on these data, the allethrins are low to moderately volatile compounds that are non

- persistent to slightly persistent in aerobic soil and are expected to have low mobility in most so ils. T he main transformation product s of
the allethrins are carbon dioxide ( CO 2

, maximum of 71% in an aerobic soil metabolism study), allethrolone (maximum of 18.9% in the hydrolysis study), and dihydroxyallethrolone (maximum of 34.9% in the photolysis st udy). There were also un extract ed residues in some studies and
there is uncertainty as to the extent to which the un e xtracted residues consist of parent compound 12

.

In order to more fully characterize the environmental fate and transport of the d

- allethr in , EFED
utilized data for the structurally similar but naturally occurring compound pyrethrin 1 (PC Code 069008; CAS No. 121

- 21

- 1)

. Additionally, because pyrethroids are known to readily photolyze in air, but no atmospheric photo lyisis data were submitte d, the rate of photo lysis was estimated using Quantitative Structure / Activity Relationship (QSAR) Estimation Program Interface (EPI)
Suite 13 software

.

TABLE 3 . General Physical/ Chemical Properties and Environmental Fate Parameters of
Allethrins.
Property Value Source and/or Comments
Chemical Name [(4'RS)

- 3

- allyl

- 2

- methyl

- 4

- oxocyclopent

- 2

- enyl (1R)

- trans

chrysanthemate; CAS name: [1R

- [α(S*),3ρ]]

- 2,2

- dimethyl

- 3

- 2(2

- methyl

- 1

- propenyl)cyclopropanecarboxylic
acid 2

- methyl

- 4

- oxo

- 3

- (2

- propenyl)

- 2

- cylcopenten

- 1

- yl ester d

- trans allethrin 1 is the most insecticidally active isomer and is present at 72% in esbiothrin,

> 46.5% in bioalleth rin, >90% in esbiol, and 36% in d

- allethrin

Molecular Weight 302.4 Product Chemistry Data Reviews Solubility in Water (20 ° C) 4.6 mg/L

5.0 mg/L Bioallethrin, Esbiothrin, Esbiol Product Chemistry Data Reviews ( d

- trans allethrin); 42193303(Esbiol)

41115302; Pynamin Forte Product Chemistry Data Review Vapor Pressure (25 ° C) 3.3 X 10

- 4 Torr Bioallethrin, Esbiothrin, Esbiol Product Chemistry Data Reviews ( d

- trans allethrin); 42193303(Esbiol)

12 Ibid USEPA 2010

13 USEPA 2014. Estim ation Program Interface (EPI) Suite. http://www.epa.gov/opptintr/exposure/pubs/episuite.htmPage 10 of 27 Property Value Source and/or Comments

1.24 X 10

- 6 Torr 41115307; Pynamin Forte Product Chemistry Data Review Photodegradation in Air (half

life) <1 hour Estimated value (EPISuite) 2

Henry’s Law Constant 1.4 3 X 10

- 5 atm

- m3/mole Estimated value (EPISuite) Hydrolysis Half

- life (half

- life; 25°C) stable @ pH 5, 7; 4.3 days at pH 9 MRID 41504401; study on d

- t rans allethrin Aqueous Photolysis Half

- life (pH 5) No data 2 MRID 41504402; study on d

- trans allethrin; half

- life could not be
calculated and the study was classified unacceptable for multiple reasons. However, study did show fairly rapid photolysis in water. Soil Photolysis Half

- life No data 3

-- Aerobic Soil Metabolism Half

- life ( 25 °C) H alf

- lives of 16 .9

- 22.0 days (acid

labeled moiety) and 40.1

- 42.5 days (alcohol

- labeled moiety) MRIDs 42336501, 42336502; study on d

- trans allethrin

Anaerobic Soil Metabolism Half

life (days) No data 3

--

Aerobic Aquatic Metabolism
Half

- life (days) No data 3

--

Anaerobic Aquatic Metabolism
Half

- life (days) No data 3

--

Organic Carbon

- Normalized Soil Partition Coefficient (K oc ) 1409, 1358, 1134, 1718 MRID 41900401; study on d

- trans allethrin; compound is slightly
mobile in soil based on the FAO Soil Mobility Classification
Scheme Soil Adsorption Coefficient (K d ; mL/g) 4.1, 6.2, 15.8, 25.9 MRID 41900401; study on d

- trans allethrin
Octanol/Water Partition Coefficient Log Kow (pH 7) >5

4.95 Bioallethrin , Esbiothrin Product

Chemistry Data Review s ( d

- trans allethrin)

411 15302; Pynamin Forte Product Chemistry Data Review Terrestrial Field Dissipation No data 3

Bioconcentration Factor in Fish (BCF) 203 3 Estimated BCF Arnot

- Gobas method (upper trophic; EPISuite)

. 1 d

- trans allethrin is a synonym for d

- trans chrysanthemic acid of d

- allethrolone

2 The EPISuite output file is presented in APPENDIX A

. 3 These data are not required under 40 CFR 158.1300 (Environmental Fate Data Requirements) for outdoor residential uses.

Mobility

In a n acceptable batch equilibrium study, org anic carbon partition coefficients ( K oc ) values ranged from 1134 to 1718 (mean of 1405 from four soils; MRID 41900401). Based on the Food and Agriculture Organization ( FAO ) Soil Mobility Classification Scheme, these K oc values
indicate that d

- trans alleth rin can be expected to be slightly mobile in soil, with greater mobility in soils with lower organic matter content.Page 11 of 27

While there is some potential for the d

- allethrin to reach surface water through drift

, it is likely to
be minimal based on the single su pported use ( i.e

., a repellent candle lantern ) which should result in very low total a pplication rate for a given time and place of use. For groundwater, the potential for contamination is considered even less likely , based on the supported use, the rate of aerobic soil degradation, and the low mobility in soils.

Degradation

The allethrins are stable to hydrolysis at pH 5 and 7, but undergo es fairly rapid hydrolysis (half

life of 4.3 days) at pH 9, with degradation to major degradates including two uni dentified compounds. This is more rapid than, but somewhat similar to, the hydrolysis r ates observed for pyrethrin 1.

Although aqueous photolysis data are not required for outdoor residential uses, b ased on

a vailable information, aqueous photolysis is po tential ly a significant degradation pathway for the
allethrins , as for other synthetic pyrethroids, if the compounds reach surface water and are present in an unsorbed state in clear and shallow surface water. Under such conditions, the allethrins are exp ected to photodegrade fairly quickly in water based on the known photola bility of synthetic pyrethroids . However, the submitted aqueous photolysis study (MRID 41504402) was classified “not acceptable

, ” and an accurate aqueous photodegradation half

- life ca nnot be calculated from the data provided. The assumption of rapid aqueous photodegradation would be consistent with the rapid degradation observed for pyrethrin 1 (PC Code 069008; CAS No. 121

- 21

- 1) , which underwent photo

- initiated isomerization (to the ( E)

- isomer) with an observed half

life of approximately 1 hour in sterile aqueous 0.01 M buffer solutions (pH 7) (MRIDs 43096601, 43567601 ).

Allethrins are expected to photodegrade rapidly in air, based on an estimated photo

- oxidation
half

- life of <1 hou r ( Table 3 )

. Photodegradation in air is expected to be a significant dissipation pathway in the environment.

It is not known whether the allethrins will photodegrade on surface soil; data have not been
submitted and are not required for outdoor residenti al uses . In aerobic soil, the allethrins biodegraded with half

- lives of 16.9

- 22.0 days (acid

- labeled moiety; MRID 42336501) and 40.1

- 42.5 days (alcohol

- labeled moiety; MRID 42336502). Although the two studies have discrepancies between the reported half

- lives, the data indicate that aerobic metabolism will be a significant degradation process for these compounds in soils. Based on a published classification scheme of persistence in soil 14 , the allethrins are expected to be non

- persistent to slightly persi stent in aerobic soil. In the acid

- labeled moiety study, 39% of the applied d

- trans allethrin
had mineralized to CO 2 by 6 months, and unextractable, unidentified residues accounted for greater than 40% of the applied by that time. In the alcohol

- labeled moiety study, CO 2 was 71%

14 Goring et. al. 1975. Goring, C.A.I., D.A. Laskowki, J.H. Harnaker, and R.W. Meikle. Princ iples of pesticide degradation in soil. In Environmental Dynamics of Pesticides, R. Haque and V.H. Freed, eds. Plenum Press; New York. Pp. 13 5

- 1 72.Page 12 of 27

of the applied by 6 months and unextractable, unidentified residues accounted for a maximum of 19% of the applied by 4 months. The conclusion that aerobic metabolism will occur readily and will be a significant degradation pathwa y for the allethrins is relatively consistent with what has been reported for pyrethrin 1, which was metabolized in aerobic soil with a half

- life of 10 days, yielding similar levels of CO 2 and unextractable residues as those seen in the acid

- labeled d

tran s allethrin study. It is also consistent with the increased persistence expected of the allethrins relative to pyrethrin 1 due to the presence of a more stable side chai n in the former

. 15

Information on metabolism in anaerobic soil or in either aerobic a quatic or anaerobic aquatic environments is not available, as data have not been submitted and are not required for outdoor
residential uses

.

Bioaccumulation

The potential for bioaccumulation of the allethrins in fish is not known; data have not been

s ubmitted and are not required for outdoor residential uses . High log octanol

- water partition
coefficient ( K ow ) values of >5 and 4.95, reported in submitted studies ( Table 3 ) suggest that there may be a potential for bioaccumulation. However

, an estimated BCF of 203 as well as data submitted for pyrethrin 1 indicate that the potential for bioaccumulation is low because of relatively rapid depuration and/or metabolism. P yrethrin 1 residues accumulated in bluegill
sunfish ( Lepomis macrochirus ) continuously ex posed to the compound for 28 days under laboratory flow

- through conditions with m ean bioconcentration factors of 127x for the edible tissue, 873x for the non

- edible tissue, and 471x for the whole fish (pyrethrin 1 MRIDs 43302301,
43884102 ). However, i n th at study, 77% of the accumulated [ 14 C] residues were eliminated from the edible tissues, 66% from the non

- edible tissues, and 68% from the whole fish by D ay 1
and b y D ay 14, residues in edible tissues were below the detection limit (1 ppb) and were close

t o the detection limit (average = 1.29 ppb) in viscera. Based on the current labeled uses, the limited potential for exposure to the allethrins (and expected depuration/ metabolism if exposed)

, bioaccumulation is not expected to be a concern for fish; howev er, there is uncertainty whether the compound might accumulate in other aquatic organisms such as invertebrates given the relatively high log K ow .

Monitoring

d

- Allethrin was not consistently identified in available environmental monitoring studies,
consi stent with the low concern of environmental ex posure based on the l imited use pattern (which is further limited now) . The following databases were evaluated for the potential d

allethrin detections:

 USGS National Water Quality Assessment (NAWQA) Program database ( http://cida.usgs.gov/nawqa_queries_public/ )

– 165 samples returned for “allethrin”, no detects

above limit of detection

15 Worthing 1979. Worthing, C. R. (ed ). Pesticide Manual. 6th ed . British Crop Protection Council, l979;
Wo rcestershire, England. Pp.7.Page 13 of 27

 USGS Community Water System (CWS) data ( h ttp://pubs.usgs.gov/ds/544/ )

– no records of

allethrins

 CDPR surface water and sediment database ( http://cdpr.ca.gov/docs/emon/surfwtr/surfcont.htm )

– 18 samples returned for “allethrin,” o ne abo ve the limit of detection (0.0242 ppb, 2/22/10, St. Johns River, Tulare County)

 USEPA/USGS/NWQMC (National Water Quality Monitoring Council) Water Quality Portal database ( http://www.waterqualitydata.us/ )

– 1,123 sample results from 297 sites returned for “allethrin,” all of which are “not detected” or “*non

- detect.”

Ecological Effects

Consistent with the proces s described in the Overview Document 16 , the risk assessment for the d

allethrin relies on a s urrogate species approach. T oxicological data generated from surrogate test species, which are intended to be representative of broad taxonomic groups, are used to extrapolate the potential effects on a variety of species (receptors) included under these taxonomic g roupings.

Effects to Aquatic Organisms

The allethrins as a whole are considered very highly toxic to freshwater fish ( esbiol LC 50 = 7. 8 μg a.i./L

, MRID 40098001) and freshwater invertebrates ( LC 50 = 2.1 μg a.i./L ; allethrin; MRID
40098001 ) on an acute exposure basis ( Table 4 ). No chronic toxicity data for freshwater
vertebrate s or invertebrate s are available for the allethrins and no acute or chronic toxicity data
are available for estuarine/marine fish or invertebrate s

. Toxicity data are also lacking for
vascular and non

- vascular aquatic plants.

16 USEPA 2004.Overview of the Ecological Risk Assessment Process in the Office of Pesticide Programs, U.S. Environmental Protection Agency. Endangered and Threatened Species Determinations. Office of Chemical Safety
and Pollut ion Prevention formerly the Office of Prevention, Pesticides and Toxic Substances. January 23, 2004. http://www.epa.gov/espp/consultation/ecorisk

- overview.pdfPage 14 of 27

TABLE 4 : Summary of Toxicity Studies for Aquatic Organisms Exposed to Allethrins

SPECIES CHEM./

(PC CODE) E ND

POINT DUR

ATION (hrs) CONC.

MEAN (ppb) EXPO

SURE
TYPE 1 CATEGORY MRID #

Freshwater Fish

Perca flavescens
Yellow Perch Esbiol/ 004004 LC 50 96 7. 8 (6.5

– 9.4) S Supplemental 40098001 2

Oncorhynchus
kisutch
Coho Salmon Bioallethrin/

004003 LC 50 96 9.4 (7.91

– 11.2) F Supplemental 00 122546

Oncorhynchus mykiss
Rainbow Trout Bioallethrin/

004003 LC 50 96 9.7 (8.0

– 11.6) F Supplemental 40098001

Ictalurus
punctatus Channel Catfish Esbiol/
004004 LC 50 96 14.6 (10.1

– 21.0) F Supplemental 4 0098001

Salvelinus namaycush
Lake Trout Bioallethrin/

004003 LC 50 96 17.3 (14.9

– 20.0) S Supplemental 40098001

Lepomis
macrochirus Bluegill Sunfish Bioallethrin/
004003 LC 50 96 22.5 (20.5

– 24.7) F Supplemental 40098001

Pimephales promelas
Fathead Minnow Bioallethrin/
004003 LC 50 96 48.0 (34.9

– 66.0) F Supplemental 40098001

Freshwater Invertebrates Pteronarcys californica Stonefly Allethrin/

004001 LC 50 96 2.1 (1.5

– 2.9) S Supplemental 40098001 2

Gammarus fas ciatus Scud Allethrin/

004001 LC 50 96 8 (5.0

– 12.0) S Supplemental 40098001

Daphnia magna Water F lea Esbiothrin/

004007 EC 50 48 8.9 (7.5

– 11) S Acceptable 43235801

Simocephalus
serrulatus
Water F lea Allethrin/

004001 EC 50 48 56 (40.0

- 78.0) S Suppleme ntal 40098001

1 Exposure type refers to the conditions under which the study was conducted; ‘S’ refers to static conditions, and ‘F’ refers t o flow

- through
conditions.

2 Following EFED guidance on MRID 40098001 [ Mayer, F.L. and M.R. Ellersieck (1986). Man ual of Acute Toxicity: Interpretation and Data Base for 410 Chemicals and 66 Species of Freshwater Animals. United States Department of the Interior, U.S. Fish and Wildlife Service, Resource Publication 160] , the raw data from this study are considered sup plemental.
Bolded endpoints represent the most sensitive endpoint for each taxon.

Effects to Terrestrial Organisms

On an acute oral exposure basis, t he allethrins are categorized as practically non

- toxic to birds
based on a Bobwhite quail ( Colinus virginianus ) study of bioallethrin ( LD 50 = 2030 mg/kg

- bw;
MRID 00 123339 ) . On a subacute dietary exposure basis, the allethrins are also categorized as practically non

- toxic to birds based on a mallard duck ( Anas platyrhynchos) dietary toxic ity study with d

- allethrin ( LC 50 >5,620 mg/kg

- diet

, MRID 000 27548 ) ( Table 5 ). No avian chronic toxicity data are available for the allethrins.

The allethrins are c ategorized as moderately toxic to mammals on an acute oral exposure b asis,
based on a laboratory rat study with esbiothrin ( LD 50 = 378 mg /kg

- bw, MRID 00151449 ) ( Table
5 ).Page 15 of 27

In a rat 2

- generation reproduction study (MRID 41246801) with d

- allethrin (PC Code: 004005)

t here was no effect upon reproductive indices . The parental NOAEL is 200 mg/kg diet (13 mg/kg

- bw /day in males and 15 mg/kg

- bw /day in females) and the parental LOAEL is 2

, 000 mg/kg diet (130 mg/kg

- bw /day in males and 145 mg/kg

- bw in females) and were based on
reductions in growth ( i.e ., decreased body weights and b ody weight gains ) and effects on the
liver ( i.e

., increases in absolute and relative liver weights, and hepatocellular hypertrophy ) . The offspring NOAEL is 200 mg/kg diet (15 mg/kg

- bw /day ) and the LOAEL for offspring toxicity is 2,000 m g/kg diet (145 mg/k g

- bw /day ) based on reductions in pup body weights of the F 2 generation.

The allethrins are considered moderately toxic to adult honey bees ( Apis mellifera ) on an acute

contact exposure basis using an LD 50 of 3.4 μg/bee for allethrin s ( MRID 00 162751 ) ( Tabl e 5 )
and on an acute oral exposure basis using an LD 50 of 9.1 μg/bee for allethrin s ( MRID
00 162751).

TABLE 5 : Summary of Submitted Toxicity Studies for Terrestrial Animals Exposed to
Allethrins

SPECIES CHEM./

(P C CODE) END

POINT DUR

ATION (Days) CONC.

MEAN EXPO

SURE
TYPE CATEGORY MRID #

Birds

Colinus virginianus Bobwhite Quail Bioallethrin/
004003 LD 50 14 2030

m g/kg

- bw (1504

– 2738) N/A Acceptable 00 123339

Anas platyrhynchos
Mallard Duck d

- Allethrin /
004005 L C 50 8 >5,620 mg/kg

- diet N/A Acceptable 000 27548

Mammals Rattus norvegicus Laboratory R at Esbiothrin/
004007 LD 50 14 378 mg/kg

- bw N/A Acceptable 00151449

Rattus norvegicus Laboratory R at d

- Allethrin /
004005 NOAEL 2 generation 13 mg/kg

bw N/A Acceptable 4 1246801

Terrestrial Invertebrates Apis mellifera Honey Bee Allethrin/

004001 LD 50 1 3.4 μg/bee Contact Supplemental 00 162751

Terrestrial Plants

No guideline toxicity data were submitted with which to evaluate the effects of alle thrin s exposure to non

- target terrestrial plants. Although in previous assessments risk to plants from
allethrin s use was not expected because of the allethrins’ neural toxic mode of action and the results of efficacy studies provide d by the registrant

, there are 13 ‘minor’ incidents involving terrestrial plants identified in EFED’s Registration Review Problem Formulation for allethrins 17

. These 13 incidents ( APPENDIX B ) involved the use of pressurized liquid spray or ready

- to

- use

so lution formulations containing additional active ingredients and/or inerts. As of August 12, 2014, no a dditional plant incidents have been recorded

.

17 Ibid USEPA 2010Page 16 of 27

Although no terrestrial plant data are available f or d

- allethrin, the chemical’s limited use and
low l ikelihood of exposure for plants renders the need for such data as low

.

Ecological Incidents

Reviews of the Ecological Incident Information System (EIIS, version 2.1), the Avian Incident Monitoring System (AIMS) 18 , and the Incident Data System (IDS) were conducted on August 12, 2014

. As of August 12, 2014, in addition to the plant incidents discussed in the preceding
section

, two additional minor wildlife incidents were reported in the IDS ( APPENDIX B ). These incidents involved the use of an impregna ted material ( i.e. , mosquito coil) or pressurized liquid formulation and are reported in the aggregated IDS; therefore details are not available on the specific species affected

. None of the incidents involved the lantern use (which is the use pattern asse ssed in this document). No incidents were reported in the AIMS or EIIS databases.

2. Risk Characterization

Risk Estimation

Aquatic Animals

To assess the potential for effects of a pesticide use to aquatic organisms, an estimated
environmental concentratio n ( EEC ) is typically determined by modeling the transport of an applied pesticide into the farm pond, which is a water body of defined proportions and volume ( i.e., 20 x 10 6 L) used routinely in EFED in ecological risk assessment

. 19 Given that t he single

r emaining use of d

- allethrin ( i.e

., repellent candle) do es not involve direct application to land or

water and can be used by any number of people in any locations for any length of time , the use
does not lend itself to the modeling tools typically used by EFED to develop aquatic exposure estimates

. However, f

or an LOC not to be exceeded, the RQ calculated from the EEC and the toxicity endpoint must be lower than the LOC. This calculation can be reversed to determine the lowest EEC that would be expected t o lead to an LOC exceedance:

RQ (below LOC) < LOC and RQ (below LOC) = EEC (below LOC) ÷ toxicity value; therefore

EEC (below LOC) < LOC * toxicity value.

All values and equations used in this calculation are summarized in Table 8 . From the available
da ta on the effects of allethrins to aquatic animals (both vertebrates and invertebrates), the most sensitive endpoint is for the stonefly ( Pternoarcys californica ) with an LC 50 of 2.1 μg a.i./L. The highest aquatic risk category is for acute risk to listed species with an LOC of 0.05. Inserting these values into the above equation leads to the result that for an aquatic LOC not to be exceeded, the EEC must be less than 0. 105 μg a.i./L (0.05 * 2.1 μg a.i./L). Based on the quanti t y

18 http://www.abcbirds.org/abcprograms/policy/toxins/aims/aims/login.cfm?CFID=113048231&CFTOKEN=9243482

19 http://www.epa.gov/oppefed1/models/water/Page 17 of 27

of active ingredient in e ach device, the entire mass of a .i. from over 4 candles would need to enter the farm pond (and be solubilized) to exceed the LOC for aquatic animals. Due to dilution in air, low deposition rates due to dissipation in air, low mobility in soil due to the s orbtive properties of d

- allethrin, and subsequent degradation in air, soil, and water via photolysis, the
mass of d

- allethrin that may reach a water body from a single candle is likely to be far lower than
the total amount of a .i. contained in each device. The actual number of devices needed to result in sufficient exposure to trigger to an LOC exceedance, then, can reasonably be expected to be far greater than the number calculated here.

Table 8: Amount of Allethrins in an Aquatic Environment that would exceed the Most
Sensiti ve Level of Concern

Parameter Inputs and Results

Most sensitive endpoints LOC = 0.05 (listed species) Toxicity = 2.1 μg a.i./L ( Stonefly LC 50 )

EEC in farm pond leading to LOC
exceedance 1 0.105 μg a.i./L

Amount of a.i. in farm pon d leading to LOC
exceedance 2 2.1 g

Amount of a.i. per device 3 Candle 0.498 g a.i./device

No. of devices from which entire contents must end up in pond leading to LOC
exceedance 4 ~ 4.2 devices

1 RQ (below LOC) < LOC and RQ (below LOC) = EEC (below LOC) ÷ toxicity value therefore EEC (below LOC) < LOC * toxicity value

2 Volume of pond = 20,000 m 3 or 20,000,000 L. Dissolved compound = EEC * volume.

3 See Table 2

4 (Amount of a.i. in pond) ÷ (Amount of a.i. per device) = No. of devices to exceed the LOC

Terrestrial Animals

The allethrins are considered practically non

- toxic to birds (and by extension to terrestrial

- phase amphibians and reptiles) on an acute oral and subacute dietary exposure basis and are moderately
toxic to mammals on an acute oral ex posure basis. A ll of the exposure values, conservatively
estimated with T

- REX using a rate equivalent to 0.0088 lbs a

. i

. /A , were well below the highest concentrations tested in the available acute toxicity studies for terrestrial animals ( see APPENDIX C fo r details). Exposures were estimated assuming that all of the d

- allethrin in 8 candles (see the ‘ Overview of Pesticide Use and Usage ’ section above) was released at the same time and deposited as residues on terrestrial animal food items. Based on these c onservative assumptions, all of the acute avian and mammalian RQs are <0.01 and are well below the a cute risk LOC s (see APPENDIX C for details).Page 18 of 27

As described earlier

, d

- allethrin is considered moderately toxic to adult honey bees ( Apis mellifera ). Because the d

- allethrin is used as an insect repellent and has potential insecticidal properties, it is assumed that terrestrial invertebrate s ( e.g ., honey bee or listed flying terrestrial invertebrate species) that is exposed by flying through the d

- allethrin re leased by the candle has the potential to be repelled, and perhaps killed. It is possible that a mosquito that flew into a
cloud of allethrins vapor would be repelled and move away unharmed or move away with effects
that would reduce its ability to grow, r eproduce or survive . The same could be true for honey
bees and listed terrestrial invertebrates that enter the treated area.

Mosquitoes actively track humans in order to obtain a blood meal and it is this behavior that the
d

- allethrin is intended to ta rget

. Most b ees and listed terrestrial invertebrate species would not be expected to be attracted to humans. Also, periods when mosquitos are most active, e.g ., dusk do not tend to overlap when honey bees and other insects are typically active. Therefor e, a non

target terrestrial invertebrate would be exposed to the d

- allethrin only by chance, or because it ( e.g. , a moth) was flying toward a light (such as with a burning candle). Although the acute

t oxicity value for bees would trigger a bee advisory sta tement on the label of products, the fact that this compound is not applied to plants and the likelihood of bees coming into contact with sufficient residues of the compound via ingestion of pollen/nectar or through contact with residues on plants, such la nguage is not warranted for the use of d

- allethrin as a repellent

. Furthermore , given the relatively limited area of effects around the d

- allethrin dispensing devices, the likely setting of use ( i.e ., in backyards and other residential areas and where peop le
hunt and otherwise participate in outdoor activities), the sporadic and dispersed use, and dilution by the large volume of air into which it is released, the probability of impacting listed terrestrial
invertebrates is considered low and there is no rea sonable expectation of effects (this is also why

a standard screening

- level assessment for terrestrial invertebrates was not conducted)

.

Plants

There are currently no data available to assess the potential risk to terrestrial or aquatic plants
from d

- a llethrin

. However, t here is no reasonable expectation of effects to plants due to the low exposure potential and no reported incidents for the use pattern being assessed here

.

R isk Description

The risk hypothesis articulated in the preliminary Problem F ormulation written in support of the Registration Review of allethrins in general stated that “ based on mode of action and the sensitivity of non

- target aquatic and terrestrial species, the outdoor, residential use of allethrins (i.e., mosquito repellant c andle lantern) has the potential to reduce survival, reproduction, and/or growth in terrestrial and aquatic non

- target animals through drift and/or runoff. These

non

- target organisms include Federally

- listed threatened and endangered species as well as

no n

- listed species

. ” However, b ased on the available data and the single remaining registered

use of d

- allethrin ( i.e

., candles), none of the LOCs evaluated in this assessment is exceeded for d

allethrin . Where RQs could not be calculated due to the lack o f toxicity data, potential forPage 19 of 27

exposure is considered low. Therefore, the risk hypothesis is rejected (see below for the discussion on listed species)

.

The d

- allethrin released from the repellant candle lantern is expected to dissipate rapidly.
Additio nally, any d

- allethrin released from the candle during daylight hours is expected to ha ve a short half

- life in air given its susceptibility to photolysis . Furthermore, based on conservative estimates of exposure for the candle use, none of the RQs resulte d in LOC exceedances for fish (aquatic

- phase amphibians) , aquatic invertebrates, birds (terrestrial

- phase amphibians, reptiles)

, or mammals. The likelihood of adverse effects to bees and other pollinating insects is also considered low given the relativel y limited area in which exposure is expected to occur and given that the compound is likely to readily dissipate. Therefore, the likelihood of adverse effects

to non

- target species from the use of d

- allethrin is considered low based on the results of th is quantitative and qualitative assessment.

Uncertainties and Assumptions

For the currently registered use of d

- allethrin , the fate of the a.i. in the environment is primarily dependent on its transformation and dissipation in air. Although there were limi ted data to fully
describe the environmental fate of d

- allethrin in air, soil, and water, this assessment’s
consideration of allethrins as a whole in air is largely based on estimates of photodegradation in air determined through QSAR as used in the estima tion software EPI

- Suite, and bridging of data/information for other pyrethroids

. Also, the registered use of d

- allethrin consist s of small devices that do not deposit the a.i. directly on land , plant, animal, or water surfaces and only
affect relatively c onfined areas. EFED conducted terrestrial exposure modeling based on a set of very conservative assumptions, which likely led to overestimates of potential exposure ; however, even with these conservative estimates, RQ values were below LOCs . The amount o f overestimation is uncertain, and so this modeling is intended to establish upper bounds on potential environmental exposure rather than to accurately predict ambient exposure levels

.

Although the available data were adequate for assessing the exposure and potential effects
associated with the candle use , additional data may be needed in the future if the use pattern (and, thus, the exposure potential) for d

- allethrin changes.

E ndangered S

pecies A ssessment

Because direct adverse effects are not expe cted for birds, reptiles, amphibians, mammals, fish, and aquatic invertebrates, and there is no reasonable expectation of effects to plants or terrestrial invertebrates, the EPA makes a No Effects (NE) determination for all listed species and a No
Habitat Modification determination for all designated critical habitats of listed species for the currently registered use of d

- allethrin

.Page 20 of 27

Endocrine Disruptor Screening Program

As required by FIFRA and the Federal Food Drug and Cosmetic Act (FFDCA), EPA review s numerous studies to assess potential adverse outcomes from exposure to chemicals. Collectively, these studies include acute, subchronic and chronic toxicity, including assessments of carcinogenicity, neurotoxicity, developmental, reproductive, and gener al or systemic toxicity. These studies include endpoints which may be susceptible to endocrine influence, including effects on endocrine target organ histopathology, organ weights, estrus cyclicity, sexual maturation, fertility, pregnancy rates, reproducti ve loss, and sex ratios in offspring. For ecological hazard assessments, EPA evaluates acute tests and chronic studies that assess growth, developmental and reproductive effects in different taxonomic groups. As part of its most recent registration decis ion for allethrins, EPA reviewed these data and selected the most sensitive endpoints for relevant risk assessment scenarios from the existing hazard database. However, as required by FFDCA section 408(p), allethrins are subject to the endocrine screening part of the Endocrine Disruptor Screening Program (EDSP).

EPA has developed the EDSP to determine whether certain substances (including pesticide active and other ingredients) may have an effect in humans or wildlife similar to an effect produced by a “ naturally occurring estrogen, or other such endocrine effects as the Administrator may designate.” The EDSP employs a two

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

- related effects caused by the substance, and
establish a dose

- response relationship between the dose and the E, A, or T effect.

Under FFDCA section 408(p), the Agency must screen all pesticide chemicals. Between October 2009 and February 2010, EPA issued test orders/data call

- ins for the first group of 67
chemica ls, which contains 58 pesticide active ingredients and 9 inert ingredients. A second list of chemicals identified for EDSP screening was published on June 14, 2013 20 and includes some pesticides scheduled for R egistration R eview and chemicals found in wate r. Neither of these lists should be construed as a list of known or likely endocrine disruptors.

For further information on the status of the EDSP, the policies and procedures, the lists of chemicals, future lists, the test guidelines and the Tier 1 scree ning battery, please visit our
website. 21

20 See http://www.regulations.gov/#!documentDetail;D=EPA

- HQ

- OPPT

- 2009

- 0477

- 0074 for the final seco nd list of
chemicals.

21 http://www.epa.gov/endo/Page 21 of 27

APPENDIX A: EPISUITE OUTPUT FOR ALLETHRINS (CAS No. 548

- 79

- 2)

CAS Number: 000584

- 79

- 2 SMILES : O=C(OC(C(=C(C1(=O))CC=C)C)C1)C(C2(C)C)C2C=C(C)C
CHEM : Allethrin

MOL FOR: C19 H26 O3

MOL WT : 302.42

------------- ----------------- EPI SUMMARY (v4.10)

-------------------------- Physical Property Inputs: Log Kow (octanol

- water):

------ Boiling Point (deg C) :

------ Melting Point (deg C) :

------ Vapor Pressure (mm Hg) :

------ Water So lubility (mg/L):

------ Henry LC (atm

- m3/mole) :

------

Log Octanol

- Water Partition Coef (SRC): Log Kow (KOWWIN v1.68 estimate) = 5.52 Log Kow (Exper. database match) = 4.78 Exper. Ref: HANSCH,C ET AL. (1995)

Boiling Pt, Melt ing Pt, Vapor Pressure Estimations (MPBPVP v1.43): Boiling Pt (deg C): 374.02 (Adapted Stein & Brown method) Melting Pt (deg C): 126.18 (Mean or Weighted MP) VP(mm Hg,25 deg C): 3.53E

- 005 (Modified Grain method) VP (Pa, 25 deg C) : 0 .0047 (Modified Grain method) MP (exp database):

- 40 deg C BP (exp database): 163

- 170 @ 0.15 mm Hg deg C VP (exp database): 3.30E+05 mm Hg (4.40E+007 Pa) at 25 deg C

Water Solubility Estimate from Log Kow (WSKOW v1.42):
Water Solu bility at 25 deg C (mg/L): 0.9838 log Kow used: 4.78 (expkow database)

no

- melting pt equation used Water Sol (Exper. database match) = 4.6 mg/L (25 deg C) Exper. Ref: TOMLIN,C (1997)

Water Sol Estimate from Fragments:

W at Sol (v1.01 est) = 0.29985 mg/L

ECOSAR Class Program (ECOSAR v1.00): Class(es) found:Page 22 of 27

Esters Vinyl/Allyl Ketones Vinyl/Allyl Esters Pyrethroids

Henrys Law Constant (25 deg C) [HENRYWIN v3.20]:
Bond Method : 6. 12E

- 007 atm

- m3/mole (6.20E

- 002 Pa

- m3/mole) Group Method: Incomplete Exper Database: 1.04E

- 07 atm

- m3/mole (1.05E

- 002 Pa

- m3/mole) For Henry LC Comparison Purposes:

User

- Entered Henry LC: not entered Henrys LC [via VP/WSol estimate using U ser

- Entered or Estimated values]:

HLC: 1.428E

- 005 atm

- m3/mole (1.447E+000 Pa

- m3/mole)

VP: 3.53E

- 005 mm Hg (source: MPBPVP) WS: 0.984 mg/L (source: WSKOWWIN)

Log Octanol

- Air Partition Coefficient (25 deg C) [KOAWIN v1.10]: Log K ow used: 4.78 (exp database) Log Kaw used:

- 5.371 (exp database) Log Koa (KOAWIN v1.10 estimate): 10.151 Log Koa (experimental database): None

Probability of Rapid Biodegradation (BIOWIN v4.10): Biowin1 (Linear Model) : 0.6007 Biowin2 (Non

- Linear Model) : 0.6497 Expert Survey Biodegradation Results: Biowin3 (Ultimate Survey Model): 2.4365 (weeks

- months) Biowin4 (Primary Survey Model) : 3.4647 (days

- weeks ) MITI Biodegradation Probability:

Biowin 5 (MITI Linear Model) : 0.4748 Biowin6 (MITI Non

- Linear Model): 0.1153 Anaerobic Biodegradation Probability: Biowin7 (Anaerobic Linear Model):

- 0.3858 Ready Biodegradability Prediction: NO

Hydrocarbon Biodegradation (BioHCwin v1.01): Structure incompatible with current estimation method!

Sorption to aerosols (25 Dec C)[AEROWIN v1.00]: Vapor pressure (liquid/subcooled): 4.4E+007 Pa (3.3E+005 mm Hg) Log Koa (Koawin est ): 10.151 Kp (particle/gas partition coef. (m3/ug)):Page 23 of 27

Mackay model : 6.82E

- 014 Octanol/air (Koa) model: 0.00348 Fraction sorbed to airborne particulates (phi): Junge

- Pankow model : 2.46E

- 012 Mackay model : 5.45E

- 012 Octanol/air (Koa) model: 0 .218

Atmospheric Oxidation (25 deg C) [AopWin v1.92]: Hydroxyl Radicals Reaction:

OVERALL OH Rate Constant = 222.2525 E

- 12 cm3/molecule

- sec Half

- Life = 0.048 Days (12

- hr day; 1.5E6 OH/cm3)

Half

- Life = 0.578 Hrs

Ozone Rea ction:

OVERALL Ozone Rate Constant = 92.259369 E

- 17 cm3/molecule

- sec Half

- Life = 0.012 Days (at 7E11 mol/cm3)

Half

- Life = 17.887 Min Reaction With Nitrate Radicals May Be Important! Fraction sorbed to airborne particulate s (phi):

3.96E

- 012 (Junge

- Pankow, Mackay avg) 0.218 (Koa method) Note: the sorbed fraction may be resistant to atmospheric oxidation

Soil Adsorption Coefficient (KOCWIN v2.00): Koc : 3082 L/kg (MCI method) Log Koc: 3.48 9 (MCI method) Koc : 5001 L/kg (Kow method) Log Koc: 3.699 (Kow method)

Aqueous Base/Acid

- Catalyzed Hydrolysis (25 deg C) [HYDROWIN v2.00]: Total Kb for pH > 8 at 25 deg C : 9.024E

- 003 L/mol

- sec Kb Half

- Life at pH 8: 2.434 years
Kb Half

- Life at pH 7: 24.338 years (Total Kb applies only to esters, carbmates, alkyl halides)

Bioaccumulation Estimates (BCFBAF v3.01): Log BCF from regression

- based method = 1.562 (BCF = 36.45 L/kg wet

- wt) Log Biotransformation Half

- life (HL) =

- 0.3033 days (HL = 0.4974 days) Log BCF Arnot

- Gobas method (upper trophic) = 2.307 (BCF = 202.7) Log BAF Arnot

- Gobas method (upper trophic) = 2.307 (BAF = 202.9) log Kow used: 4.78 (expkow database)

Volati lization from Water:Page 24 of 27

Henry LC: 1.04E

- 007 atm

- m3/mole (Henry experimental database)

Half

- Life from Model River: 9792 hours (408 days)
Half

- Life from Model Lake : 1.07E+005 hours (4457 days)

Removal In Wastewater Treatment: Total removal: 69.53 percent Total biodegradation: 0.62 percent Total sludge adsorption: 68.91 percent Total to Air: 0.00 percent (using 10000 hr Bio P,A,S)

Level III Fugacity Model:
Mass Amount Half

- Life Emissions (percent) (hr) (kg/hr)

Air 0.0104 0.237 1000

Water 17.3 900 1000
Soil 79.6 1.8e+003 1000
Sedi ment 3.05 8.1e+003 0
Persistence Time: 1.08e+003 hrPage 25 of 27

APPENDIX B : Incident Data System (IDS) for Allethrins

Report created on 12 August 2014

.Page 26 of 27

A PPENDIX C : T

- REX Output for Allethrins

InputPage 27 of 27

Output