2

The Agency is concerned about non-listed and listed nontarget terrestrial invertebrates 

from the use of dinotefuran. The chemical is highly toxic to bees through oral (LD50 = 

0.0076 g a.i./bee, MRID 45639727) and direct contact (LD50 = 0.024 g a.i./bee, MRID 

45639727). Dinotefuran applied at 0.13 lbs a.i./A will remain toxic to bees for more than 

24 hours (MRID 45639728) after the application, if dinotefuran residues contact 

blooming, pollen-shedding or nectar-producing parts of plants. This means that 

dinotefuran should not be applied to blooming, pollen-shedding, or nectar-producing 

parts of plants. When translocated from pollen and nectar to bee hives, residues of 

dinotefuran can be detected in stored honey inside hives at least 85 days after application 

(MRID 48120501), which suggests the occurrence of long-term chronic exposure inside

the hive and has implications for overwintering success. In addition, higher application 

rates are expected to cause longer residual toxicity time. Furthermore, the chemical is 

systemic (may persist in the plant post-bloom, potentially contaminating nectar in 

extrafloral nectaries), and persistent in the field (average field dissipation half-life ~46.83 

days), meaning there is the possibility of acute and long-term exposure to terrestrial 

invertebrates. Should exposure occur, EFED expects dinotefuran to be a potential risk to 

non-listed and listed terrestrial invertebrates, and any listed species that relies on 

terrestrial invertebrates during its life-cycle.

For the proposed tree injection use, the total mass of dinotefuran applied to treated trees 

ranges from 1,600 mg a.i. to 28,800 mg a.i.. Therefore, there is sufficient mass applied to 

trees to potentially affect birds, mammals, and terrestrial invertebrates. For example, the 

fraction of the mass of dinotefuran applied to a tree consumed by a 20-gram bird would 

need to be < 0.002 (0.2%) of the total mass applied for a small tree and <0.0001 (0.01%) 

of the total mass applied for a large tree to result in no LOC exceedances for birds. 

Similarly, the fraction of the mass of dinotefuran applied to a tree consumed by a 15-

gram mammal would need to be < 0.004 (0.4%) of the total mass applied for a small tree 

and <0.0002 (0.02%) of the total mass applied for a large tree to result in no LOC 

exceedances for birds. 

Consideration of dilution within the tree did not reduce potential risks to levels that are 

below concern levels. Estimated leaf concentrations were sufficient to result in risk 

concerns for organisms that may eat leaves of treated trees. This evaluation assumed that 

100% of the injected chemical was translocated to the leaves. However, even 

translocation of a relatively small fraction of dinotefuran to the leaves could result in 

potential effects to terrestrial organisms (particularly, the invertebrates). Estimates of 

whole-tree pesticide concentrations assuming that the chemical is evenly distributed 

throughout the above ground biomass were also above levels that may be of concern to 

non-target terrestrial invertebrates. Therefore, the available data suggest that potential 

risks as a result of tree injection to non-target terrestrial organisms are of concern. 

Submission of a magnitude of residues study that quantifies potential exposure levels 

after tree injection would be of high value to this risk assessment. Risks may be further 

quantified and refined if a magnitude of residues study in treated trees is submitted that 

evaluates concentrations of dinotefuran in edible parts of treated trees, including leaves,

fruit, seeds as well as blooming, pollen-shedding, and nectar producing parts of plants.
3

The above analysis only considered potential acute effects. However, there is also 

potential for repeated or prolonged exposures to terrestrial animals because dinotefuran is 

not expected to rapidly dissipate from trees after it is injected and translocated. Therefore, 

there is also potential risk to reproduction and/or growth endpoints from the proposed 

tree injection use. 

Past Ecological Risk Assessments

The Environmental Fate and Effects Division (EFED) most recently evaluated a proposed 

new use of the insecticide dinotefuran in the products Dinotefuran 20SG (EPA Reg. No. 

33657-17), Starkle 70SG (EPA Reg. No. 33657-38) and Dinotefuran 70SG (EPA Reg. 

No. 59639-135) on leafy Brassica (Subgroup 5B), including turnip greens. EFED had 

reviewed the IR-4 petition (DP Barcode: D358860; 2009) and found that the application 

rate, number of applications and interval between applications were similar to crops 

already assessed such as cotton, head and stem brassica, grapes and leafy vegetables. 

That assessment extensively relied on the work of previous risk assessments (USEPA 

reviews dated 6/30/04, 8/9/04, 10/16/06 and 10/31/06; DP Barcodes D285633, D304957, 

D324854 and D332829, respectively). Previous assessments would contain the most 

detail on the available data, data needs, and risk characterization.
4

EFED evaluated dinotefuran‟s potential risks to non-target species for aquatic and 

terrestrial (other than invertebrates) organisms (including plants) in the USEPA 6/30/04 

and 10/31/06 reviews (DP Barcodes D285633 and D304957). These screening-level 

assessments show that the proposed uses of dinotefuran do not trigger acute risks to nontarget non-listed or listed terrestrial (e.g., birds, mammals, plants) and aquatic species 

(e.g., fish, aquatic invertebrates, plants). Additionally, no chronic risks are expected to 

these taxa, with the exception of fish (no data available). However, the assessment of 

June 30, 2004 (D285633) for the proposed uses of dinotefuran (i.e., leafy vegetables, turf, 

which were also a surrogate for ornamental uses) raised a precautionary note with regard 

to the possibility of honey bee concerns and future dinotefuran uses. It was a generic 

precaution at the time reflecting the family of neonicotinoid compounds and their 

potential for risk to honey bees and other beneficial insects. Since the completion of that 

assessment, an interim LOC (0.05) for listed terrestrial invertebrates has been established. 

A risk concern for listed terrestrial invertebrates implies risk to other listed as well as 

non-listed species that rely on them. Similarly, the assessment of August 9, 2004 

(D304957) concluded that the Agency was concerned about the protection of pollinators 

from chemicals in the neonicotinoid class (which includes acetamiprid, thiacloprid, 

dinotefuran, clothianidin, thiamethozam, and imidacloprid). The neonicotinoid chemicals 

are systemic and EFED was concerned about the possibility of acute and chronic 

exposure to bees from residues that remain in pollen and nectar of flowering crops. In 

addition, dinotefuran is persistent in the field (average field dissipation half-life ~ 46.83 

days); higher application rates would cause longer residual toxicity time. Again, it was 

recommended that dinotefuran should not be applied to blooming, pollen-shedding or 

nectar-producing parts of plants. 

Summary of Risk conclusions 

a. Foliar, Airblast & Broadcast spray application, soil application (i.e., soil 

media drench, chemigation), basal trunk spray application

These particular application types (ground/aerial spray, soil incorporation) and/or 

maximum application rates (0.54 lbs a.i./A) are found in the 2004 risk assessments (DP 

Barcodes: D285633, D304957) with use on ornamental plants, which are listed on the 

current label in conjunction with the proposed forestry uses. The risk conclusions 

described above for the 2004 assessments apply to the proposed uses as well. 

b. Tree injection

Overall, the screening level analysis conducted for the tree injection use pattern, which 

assumes total mass of chemical applied to the terrestrial and aquatic environments as well 

as distribution of concentrations in tree trunks and leaves, suggests that translocation of
5

dinotefuran from the site of injection to edible portions of a tree may result in effects to 

birds, mammals, and terrestrial invertebrates. Potential risks to saltwater invertebrates 

could not be precluded given the sensitivity of the mysid shrimp to relatively low 

concentrations of dinotefuran. Additional data, including a chronic study on the saltwater 

invertebrate, magnitude of residues study in injected trees and treated plants, and an 

additional bee field study would allow for refinements of potential risks. 

New Data

Due to risk concerns for terrestrial invertebrates, additional studies were required as part 

of the conditional registration of dinotefuran. Three studies were submitted (MRIDs 

48120501, 48120502, and 48120503) by Landis, International on behalf of Mitsui 

Chemicals Agro, Inc. in 2010. The three new studies were reviewed by EFED; the 

outcomes of the reviews are included in this assessment (Table 1). Respectively, these 

include studies with the following titles: Field Evaluation of Foraging Honey Bees (Apis 

mellifera) and Hives after Exposure to Dinotefuran Applied to Cotton [Landis lab 

protocol No. 43421F008]; Evaluation of the Freezer Storage Stability of Dinotefuran in 

Cotton Nectar, Honey, Beeswax, and Pollen [Wildlife Int lab study No. 236C-157]; and, 

Laboratory Validation of Methods for the Analysis of Dinotefuran in Nectar, Honey, 

Beeswax, and Pollen Obtained from Hives of Bees Foraging on Cotton. These studies 

apply to the following OCSPP Guidelines: 850.3040 Field Testing for Pollinators, 

860.1380 Storage Stability Data, and 860.1340 Residue Analytical Method. The 

honeybee field study and the studies that accompany it utilized a different dinotefuran 

formulation (Venom® Dinotefuran 70SG; 70% a.i.; Reg No. 59639-135) than the 

formulation currently being assessed (Dinotefuran 20%; Reg. No. 86203-11). 

It is very important to note that as a result of the Field Evaluation of Foraging Honey 

Bees study (MRID 48120501) having a poor study design, inadequate raw data reporting, 

and multiple additional considerations (see Table 1, environmental toxicity section, and 

Appendix C for a fuller description), the toxicity determinations cannot be used for risk 

assessment purposes. However, information regarding residue detections may be 

informative assuming freezer stability (MRID 48120502) was conducted at -20oC (as 

reported in the field study) or at an alternative, representative temperature. Therefore, 

solely on the basis of the residue data, the field study may still be utilized to address longterm exposure (but not toxicity) of honey bees to dinotefuran.
6

Table 1. Classification of Environmental Fate and Effects Data Submitted for Dinotefuran

Guideline 

Number MRID Study Title Classification Remarks

860.1340 48120503

Data Evaluation Record on 

the Laboratory Validation of 

Methods For The Analysis 

of Dinotefuran in Cotton 

Nectar, Honey, Beeswax 

and Pollen Obtained From 

Hives of Bees Foraging In 

Cotton

Supplemental No independent laboratory 

validation was provided.

860.1380 48120502

Data Evaluation Record on 

the Evaluation of the 

Freezer Storage Stability of 

Dinotefuran in Cotton 

Nectar, Honey, Beeswax 

and Pollen

Unacceptable1

but may be 

upgraded

No details on the freezer storage 

conditions (temperature, etc.) 

were provided. 

850.3040 48120501

Field evaluation of Foraging 

Honey Bees (Apis mellifera) 

and Hives After Exposure to 

Dinotefuran Applied to 

Cotton

Supplemental

(qualitative use 

only; not 

upgradable)

Poor study design (e.g., evidence 

for cross contamination between 

control and treatment plots). 

Toxicity endpoints are not to be 

used in risk assessment.

1 The study is a fate study and under a different classification system than the bee field study, which is an effects 

study.

Endangered Species

Since dinotefuran is toxic to honeybees, it is assumed that it may be toxic to listed

terrestrial invertebrates (those that are federally listed as endangered or threatened) 

leading to direct effects on these populations. In addition, should invertebrate prey 

populations decline to a point where they would negatively impact predator populations, 

then dinotefuran applications could have indirect effects on various insectivorous taxa 

including mammals and birds. In other words, any listed species that relies on terrestrial 

invertebrates during its life-cycle is potentially at risk. A listing of threatened and 

endangered species occurring in the counties throughout the U.S. where dinotefuran is 

applied is provided in Appendix E.

Incidents

Four incidence databases are available: 1) maintained and catalogued by EFED in the 

Ecological Incident Information System v. 2.1.1 (EIIS), which was last updated Oct. 15, 

2010 but contains incident reports since 1994; 2) maintained by ITRMD in the Aggregate 

Incident Reports v.1.1, which was last updated Jan. 26, 2011; 3) and the American Bird 

Conservancy and USEPA program maintaining the Avian Incident Monitoring System 

(AIMS), which was last updated June 2005; and, 4) the Incident Data System (IDS), a 

component of the PRISM database, which was checked for incidences occurring in the 

last three years.
7

No incidents have been reported (i.e., no records were found) in which dinotefuran has 

been associated with some type of environmental effect; this is the case for all four

incident databases searched. The absence of documented incidents does not necessarily 

mean that such incidents did not occur. Mortality incidents must be seen, reported, 

investigated, and submitted to the Agency in order to be recorded in the incident 

databases. 

Incidents may not be noticed because the carcasses decayed, were removed by 

scavengers, or were in out-of-the-way or hard-to-see locations. Due to the voluntary 

nature of incident reporting, an incident may not be reported to appropriate authorities 

capable of investigating it. In addition, incident reports for non-target organisms typically 

provide information only on mortality events and plant damage. Sublethal effects in 

organisms such as abnormal behavior, reduced growth and/or impaired reproduction are 

rarely reported, except for phytotoxic effects in terrestrial plants. EPA‟s changes in the 

registrant reporting requirements for incidents in 1998 may account for a reduced number 

of reported incidents. Registrants are now only required to submit detailed information 

on „major‟ fish, wildlife, and plant incidents. Minor fish, wildlife, and plant incidents, as 

well as all other non-target incidents, are generally reported aggregately and are not 

included in EIIS. In addition, there have been changes in state monitoring efforts due to a

lack of resources. Reporting by states is only voluntary, and individuals discovering 

incidents may not be informed on the procedure of reporting these occurrences. 

Therefore, the number of reports listed in the EIIS database is believed to be only a small 

fraction of the total incidents involving mortality and other damage to non-target plants 

and animals from pesticide use. Although there were no reported incidences for this 

chemical, this does not rule out any existing risks that may potentially impact nontarget 

organisms.

I. Use Characterization

Dinotefuran is used in a variety of crops, such as cotton, head and stem brassica, leafy 

brassica greens (including turnip greens), cucurbits, fruiting vegetables, grapes, leafy 

vegetables, potato, turfgrass, vegetable transplants grown in enclosed structures,

ornamental plants. The chemical may be soil applied or applied foliarly; however, the 

use of both soil and foliar applications on the same use site generally is not allowed. 

Ground and aerial foliar applications are allowed for most crops. The maximum 

application rate is on turf, with a single application at 0.54 lb a.i./A.

Mitsui Chemicals Agro, Inc., through Landis International, has requested to add use of 

dinotefuran on Christmas trees, trees in plantations, reforestation nurseries, forests, and 

woodland areas to its Dinotefuran 20% Turf, Ornamental, and Vegetable Transplants in 

Enclosed Structures label (EPA Reg. No. 86203-11). Applications are proposed by 

foliar or broadcast spray, soil drench (i.e. soil media drench for containerized plants), 

basal bark spray, and tree trunk injection. 
8

For the proposed crops, the maximum seasonal application rate is 0.54 lb a.i./A, with 

the exception of tree injection, which has no maximum seasonal application rate limit. 

A summary of the current and proposed use patterns for dinotefuran is shown in 

Appendix A; whereby the shaded area of Table A1 shows the new use pattern for the 

chemical. A detailed summary of proposed use patterns addressed in this assessment is 

shown in Table 2 below.

Table 2. Proposed Use Pattern

Crop Sites Max. Single Application Rates Remarks

Foliar, airblast & broadcast spray application

Christmas Trees

Trees in Plantations including 

Conifers & Deciduous Trees

Reforestation Nurseries

Forests & Wooded Areas 

(National, Private & State)

0.2 lb ai/A

0.1 lb ai/100 gal

A second application may be 

made after 14-21 days. 

Maximum seasonal application 

rate of 0.54 lb ai/A/year.

Soil application (i.e. soil media drench for containerized plants)

Christmas Trees

Trees in Plantations including 

Conifers & Deciduous Trees

Reforestation Nurseries

Forests & Wooded Areas 

(National, Private & State)

0.3 lb ai/100 gal

0.003 lb ai/gal

2.4 g ai/inch of trunk diameter at 

breast height

Maximum seasonal application 

rate of 0.54 lb ai/A/year.

Chemigation

Christmas Trees

Trees in Plantations including 

Conifers & Deciduous Trees

Reforestation Nurseries

Forests & Wooded Areas 

(National, Private & State)

0.1 to 0.2 lb ai/A

0.05 to 0.1 lb ai/100 gal

Maximum seasonal application 

rate of 0.54 lb ai/A/year.

Basal trunk spray application

Christmas Trees

Trees in Plantations including 

Conifers & Deciduous Trees

Reforestation Nurseries

Forests & Wooded Areas 

(National, Private & State)

0.0003 lb ai/gal

2.12 g ai/inch of trunk diameter at 

breast height

Maximum seasonal application 

rate of 0.54 lb ai/A/year.

Tree trunk injection

Ornamental trees

Trees in Plantations including 

Conifers & Deciduous Trees

Forests & Wooded Areas 

(National, Private & State)

2 g ai (0.83 tsp, or 0.001 lb) per 

inch of trunk diameter at breast 

height

Do not inject trees less than 2 

inches in diameter.

Do not inject trees more than 

once per year. 
9

III. Environmental Fate and Toxicity

The environmental fate and toxicity of dinotefuran have been discussed in depth in a 

previous risk assessment (D332829, 2006; esp.D285633, 2004); a brief summary is 

provided below. No new environmental fate data have been submitted.

Mode of Action

Dinotefuran is a furanicotinyl insecticide and member of the neonicotinoids that were 

developed as an analog of nicotine. Dinotefuran acts as an agonist at (i.e., it binds to) the 

nicotinic acetylcholine receptor (nAChR) to which the neurotransmitter acetylcholine

(ACh) would otherwise bind. Acetylcholine (ACh) is the endogenous agonist and 

excitatory neurotransmitter of the cholinergic nervous system. 

1. Environmental Fate Summary

Nomenclature and structures of dinotefuran and its transformation products are presented 

in Appendices B1 and B2. A selection of important physicochemical and environmental 

fate properties are given in Table 3. Dinotefuran has a very high water solubility (39,830 

ppm) and a low octanol/water partition coefficient (Log Kow of -0.549), which suggests

the potential for runoff and low bioaccumulation. The low vapor pressure (1.275 x 10-8

mm Hg) and a low Henry‟s Law Constant (8.63 x 10-14 Atm • M3/mol) suggest that this 

compound is not expected to volatilize substantially from water or soils in natural 

environment. 

Table 3. Summary Results of Environmental Fate and Physico/Chemical Parameters for 

Dinotefuran

Parameter Value Reference/Comments *

Selected Physical/Chemical Parameters

Chemical Name [CAS] N-methyl-N‟-nitro-N”-

((tetrahydro-3-

furanyl)methyl)guanidine]

[IUPAC] (EZ)-(RS)-1-methyl-2-nitro3-(tetrahydro-3-furylmethyl)guanidine

Pesticide Fact Sheet (Sept. 2004); 

and, 

http://www.alanwood.net/pesticide

s/dinotefuran.html

Common Name Dinotefuran Pesticide Fact Sheet (Sept. 2004)

Trade Name Dinotefuran, MTI-446 Pesticide Fact Sheet (Sept. 2004)

Chemical Abstracts 

Service (CAS) No.

165252-70-0 Pesticide Fact Sheet (Sept. 2004)

Chemical Class Neo-nicotinoid Pesticide Fact Sheet (Sept. 2004)

Year of Initial Registration 2004 Pesticide Fact Sheet (Sept. 2004)

Registrant Mitsui Chemicals, Inc. Pesticide Fact Sheet (Sept. 2004)

Chemical Classification Nitroguanidine

Pesticide Classification Systemic Insecticide
10

Table 3. Summary Results of Environmental Fate and Physico/Chemical Parameters for 

Dinotefuran

Parameter Value Reference/Comments *

Chemical Formula C7H14N4O3 http://www.alanwood.net/pesticide

s/dinotefuran.html

Chemical Structure http://www.alanwood.net/pesticide

s/dinotefuran.html

Molecular Weight 202.2 g/mol MRID # 45640101

Water Solubility (20oC) 39,830 ppm MRID# 45640112

Vapor pressure (30oC) <1.275x10-8 mm Hg MRID# 45640105

Henry's Law Constant 8.63 x 10-14 Atm m3/mol Calculated

Octanol/Water Partition, 

Kow

0.283 MRID # 45639702

log KOW -0.549 MRID # 45639702

Koc 6-45 (very highly mobile – ASTM 

classification)

MRID # 45640114, 45640115

Hydrolysis t1/2 Parent and degradates are stable at 

environmental temperatures and pHs

No major transformation products 

were identified in any buffer solution

Minor degradate 1-methyl-3-

(tetrahydro-3-furylmethyl) urea (UF) 

was <0.2% of the applied

MRID# 45640101 (s),

MRID# 45640102 (c)

MRID# 45640103 (s)

MRID# 45640104 (s)

Photolysis t1/2 in water 

Parent

1.8 days (pH 7 buffer solution)

Major products: UF, MG hydrogen 

chloride,

DN-2-OH, DN-3-OH, BCDN 

succinate, CO2, 

Minor Product : DN

MRID# 45640105 (s)

Photolysis t1/2 in water 

MNG

2.4 days (assuming 12-hr light/dark 

cycle) in pH 7.1-7.2 buffer solution.

Major products: G (max. 50.6% @ 6.8 

days), MU (max. 18.6% @ 6.8 days).

Minor Products: NG, and MG

MRID# 45640107 (s)

Photolysis t1/2 in water 

DN-PhosphatepH 5

pH 7

pH 9

53.4 days (12-hr light/dark cycle); 

major product: MG; 533.2 (12-hr. 

Light/dark cycle), minor product: MG;

stable

MRID# 45640108 (s)
11

Table 3. Summary Results of Environmental Fate and Physico/Chemical Parameters for 

Dinotefuran

Parameter Value Reference/Comments *

Aerobic Soil metabolism 

t1/2

parent

US Soil - LS 63 days (neutral 

extraction)

100 days (total extraction of residues) 

major degradate MNG (max. 13.7% @ 

225 d.)

Five US soils, half-lives range: 17 - 89 

days

major degradates MNG (max. 23.96% 

@ 42days) and NG (max. 14.3% @ 42 

days)

nitroguanidine (NG),

1-methyl-3-(tetrahydro-3-

furylmethyl)urea (UF), and

2-nitro-1-(tetrahydro-3-

furylmethyl)guanidine (FNG),

Major transformation products:

1-Methyl-2-nitroguanidine (MNG, 

maximum 15.7% of applied)

CO2 (maximum 52.1% of applied)

Minor transformation products:

Minor transformation products: Nitroguanidine (NG, maximum 5.2%)

1-Methyl-3-(tetrahydro-3-

furylmethyl)urea (UF, maximum 

1.5%)

2-Nitro-1-(tetrahydro-3-

furylmethyl)guanidine (FNG, 

maximum 1.3%)

MRID# 45640112 (s)

MRID# 45640111 (s)

MRID# 46711201 (s)

Anaerobic Soil/Aquatic 

metabolism t1/2 parent

SiL soil from Switzerland 62 days;

water 51 days, major degradate-DN 

(max. 29.2%@120 d)

MRID# 45891616 (s)

Aerobic Aquatic 

metabolism t1/2 parent

Study using two radiolabeled

materials:

79.3 days (total river system); 76 days 

(total pond system); major degradate: 

DN [max. 23.1% (17.6% in sediment + 

5.5 % in water)@ 180d in river system 

and 32.6%(31.1% in sediment+1.5% in 

water) @ 103d in pond system]

MRID # 45640117 (s)
12

Table 3. Summary Results of Environmental Fate and Physico/Chemical Parameters for 

Dinotefuran

Parameter Value Reference/Comments *

Anaerobic Aquatic 

metabolism t1/2 parent

Study using radiolabeled material.

The total system half-life was 65 days: 

51 days (water), 62 days (soil); major 

degradate: none in water phase.

MRID# 45891616 (s)

The major route of dissipation for dinotefuran appears to be aqueous photolysis (half-life 

1.8 days) and leaching. Since there is no valid soil photolysis data, it is unknown if 

dinotefuran parent residues break down quickly in soil via photolysis. Dinotefuran 

appears to be relatively persistent to metabolism, both in aerobic (half-life = 63-100 days) 

and anaerobic soil (half-life = 65 days) conditions. It appears that under metabolic 

conditions, dinotefuran degrades to MNG and subsequently to NG. Dinotefuran is stable 

to hydrolysis in a range of pH‟s of 4-9. It is considered to be very highly mobile (Koc = 6 

- 45) in various soil types. It is also very highly soluble (39,830 ppm). Since dinotefuran 

may persist in soils, it may have a high potential to leach to subsurfaces. Furthermore, it 

can migrate to adjacent bodies of water through spray drift and in runoff events, probably 

dissolved in the water column. Once in the rivers, ponds, or other bodies of water, the 

fate of dinotefuran is somewhat uncertain. Aqueous photolysis should be important in 

clear and shallow bodies of water; however, in deep ponds or rivers or flowing bodies of 

water, it is more likely to dissipate via dissolution, and subsequently via metabolism.

As indicated earlier, it appears that the major route of dissipation for dinotefuran is 

aqueous photolysis (half-life 1.8 days), with the formation of multiple photolysates. Due 

to the fast dissipation of dinotefuran by aqueous photolysis, there is a likelihood that it 

may also dissipate via soil photolysis, but no data are available at this time. The 

photolysis half-life of a major transformation product, MNG, in a pH 7 buffer was 2.4 

days, assuming a 12-hour light/dark cycle. A separate aqueous photolysis study of DNphosphate2

, another transformation product of dinotefuran, in pH 7 buffer, resulted in an 

extrapolated half-life of 533 days assuming a 12-hour light/dark cycle. 

There were six major transformation products (Figure 1, Appendix B) identified in the 

laboratory studies (MNG, DN, UF, MG-HCl, DN-2-OH + DN-3-OH, and BCDN 

succinate). The degradate MNG was identified as a major product in aerobic soil 

metabolism and in the terrestrial field dissipation studies. The degradate, DN, was 

identified as a major product in anaerobic soil metabolism and aerobic aquatic 

metabolism studies. The other degradates were mostly photolysates. 

 

2 DN phosphate (1-methyl-3-(tetrahydro-3-furylmethyl)guanidinium dihydrogen phosphate) was identified 

as a degradation product of dinotefuran in photodegradation in soil (MRID 45640109), photodegradation in 

water (MRID 45640106, 45640105) and anaerobic soil metabolism (MRID 45891616) studies. Although 

the phosphorus is not an elemental constituent of parent dinotefuran, DN phosphate was formed as a salt of 

orthophosphate and 1-methyl- 3-(tetrahydro-3-furylmethyl)guanidinium. Because the DN phosphate salt 

will dissociate in soil and aquatic environments to form (1-methyl-3-(tetrahydro-3-

furylmethyl)guanidinium) and phosphoric acid, it is not expected to alter the environmental fate or toxicity 

of the organic moiety of DN phosphate (1-methyl-3-(tetrahydro-3-furylmethyl)guanidinium). 
13

Figure 1. Dinotefuran and degradates of dinotefuran (MTI-466)

MNG contains the nitro guanidine structure and therefore is considered to possess similar 

toxicity as the parent. DN is also structurally similar to the parent and therefore 

considered to share similar toxicity as the parent. None of the dinotefuran degradates are 
14

expected to have any higher toxicity than the parent (HED Memo of 01/20/04. L. Cheng, 

D293759).

Dinotefuran, and its degradates, MNG and DN-phosphate are highly soluble in water 

(39,830 ppm, 11,480 ppm and 619,400 ppm, respectively). Similar to the parent 

compound MNG and DN are stable to hydrolysis and have high metabolic persistence. 

DN-phosphate, a salt of DN, was used by the registrant in lieu of DN, because it is a 

stable substance, to conduct laboratory studies.

The batch equilibrium - adsorption/desorption studies conducted on the parent and major 

degradates MNG and DN-phosphate, indicate that the parent dinotefuran, and MNG are 

very highly mobile (Koc<50), while DN is slightly to highly mobile. Koc values for 

dinotefuran ranged from 6 to 45 for eight soils tested (four from Japan and four 

domestic). Koc values for MNG ranged from 8 to 31 for five domestic and foreign soils. 

The study on DN-phosphate yielded a wide range of Koc values (between 58 and 2502).

In field dissipation studies dinotefuran was sprayed twice (at 14-day interval) using 

ground application equipment at three different sites (California, Georgia, and New 

York) at an application rate of 0.268 lb a.i./A/application. Rainfall was supplemented 

with irrigation to exceed the 10-year average rainfall at each test site. All soils were silt 

loams. The soil pHs at these sites ranged from 6.5 (GA) to 8.8 (CA). The half-lives of 

dinotefuran were 65.2 days (CA), 19.4 days (GA), and 55.9 days (NY), indicating 

moderate persistence for the parent. These results are in agreement with the results 

observed in the laboratory. In these field studies, the degradate MNG was the only one 

detected in substantial amounts. At the California site, MNG was 31.5% of the applied at 

45 days after the second application in the 0-15 cm soil depth. MNG was also detected at 

lower concentrations at the GA (5.3%) and NY (6.6%) sites. Even though the field 

studies did not show substantial leaching, EFED believes that leaching of both 

dinotefuran, and MNG are highly possible and may have gone undetected.

2. Environmental Toxicity Summary

An ecological effects characterization for dinotefuran has been previously conducted by 

EFED. A more robust discussion of toxicity to aquatic and terrestrial organisms is 

presented in previous risk assessments (esp. US EPA 2004; DP Barcode: D285633). The 

toxicity endpoints for available studies are summarized in Tables 4 - 10 below. Values in 

bold indicate definitive endpoints and, of these, some were used as inputs for risk 

quotient calculations for the tree injection screening assessment. The default 35-day foliar 

dissipation half-life was assumed due to dinotefuran‟s persistence; this value was used in 

a previous risk assessment (US EPA 2006; DP Barcode: D324854). Prior assessments 

cited an acute contact honey bee study 48-hour LD50 of 0.047 g a.i./bee (MRID 

45639725) as the most sensitive terrestrial invertebrate endpoint. Instead, this assessment 

uses an even more sensitive endpoint (48-hour LD50 of 0.0076 g a.i./bee) obtained from 

an acute oral honey bee study (MRID 45639727). In addition, a new study was submitted 
15

and reviewed for this assessment. The field study of foraging honey bees after exposure 

to dinotefuran applied to cotton fields in Georgia (MRID 48120501) is supplemental and 

is only used for qualitative purposes in this assessment. 

Terrestrial Toxicity Summary (Acute/ Chronic)

Terrestrial Invertebrates

Dinotefuran technical, MTI-446, (MRID 45639725) is highly toxic to bees on an acute 

contact basis (48-hr LD50 = 0.047 g ai /bee) and on an acute oral basis (48-hr LD50 = 

0.023 g ai/bee). Similarly, the dinotefuran formulation, MTI-446 20%WG (MRID 

45639726, with control; MRID 45639727, without negative but with solvent control) is 

also highly toxic to bees on an acute contact (48-hr LD50 = 0.061 g a.i./bee and 0.024 g 

a.i./bee, respectively) and on an acute oral basis (48-hour LD50 = 0.032 g a.i./bee and 

0.0076 g a.i./bee, respectively). The RT25 (or residual time to cause 25% mortality) 

derived from the exposure to residues on alfalfa study (MRID 45639728) with the 

formulation MTI-446 20% WG indicated that bees were most sensitive to the 8 hour aged 

residue (RT25 = 4.8 hours) and least sensitive to treatment when exposed to 48 hour aged 

residue (RT25 = 90 hours). In addition, exposure to dinotefuran formulation MTI-446 

20% SG applications (of varying exposure periods) led to survivorship and reproductive 

effects on non-Apis terrestrial invertebrates including parasitoid wasp (MRID 45640121), 

predaceous bug (MRID 45640122), and predatory mite (an arachnid, MRID 45640120)

indicating LC50 values of 6.89x10-5lbs a.i./A, 1.19x10-5lbs a.i./A, and 0.027 lbs a.i./A, 

respectively. It is important to note that the lowest non-definitive chronic endpoint 

NOAEC (<1.21 x 10-6lbs a.i./A) reported for the predaceous bug study implies that we 

do not know, at this time, how much lower the application would need to be to elicit no 

response in terrestrial invertebrates. For additional comparative analyses including a 

comparison of dinotefuran and imidacloprid toxicities to insects refer to USDA Forest 

Service risk assessment (Durkin 2009; MRID 47814402).

Table 4. Acute effect (mortality) concentrations (LD50/ LC50) for terrestrial invertebrates following 

exposure to Dinotefuran (Technical MTI-446, Formulation MTI-446 20% WG, Formulation MTI446 20% SG) and Dinotefuran (Formulation MTI-446 20% SG) residues on alfalfa. 

Species %a.i. Study Parameters LD50/LC50; NOAEL/NOAEC MRID Classification 

/Category

Technical MTI-446

Honey bee

Apis mellifera

99.5 48-hour, acute 

contact toxicity

Worker bees, 1-7 

days old

3 reps; 10 bees/rep

Solvent: 0.1% triton 

x-100

48-hour LD50: 0.047 g a.i./bee 

(95% CI: 0.039-0.057 g a.i./bee)

48-hour NOAEL: 0.0063 g 

a.i./bee

Probit slope: 2.60

Endpoint(s) affected: Mortality.

45639725 Acceptable / 

Highly toxic1
16

Nominal 

concentrations: 0 

(negative, solvent 

control), 0.0063, 

0.0125, 0.025, 0.05, 

0.1, and 0.2 g 

a.i./bee

(Sub)lethal effects: By 48 hours, 0, 

10, 16.7, 46.7, 76.7, and 100% 

mortality was observed in the test 

treatments, respectively. Negative 

conrol mortality was 3.3%; solvent 

control mortality was 0%. After 24 

hours, symptoms of ataxia were 

observed in the 0.1 g a.i./bee 

group.

Honey bee

Apis mellifera

99.5 48-hour, acute oral

toxicity

Worker bees, 1-7 

days old

3 reps; 10 bees/rep

Solvent: 0.1% triton 

x-100

Nominal 

concentrations: 0 

(negative, solvent 

control), 0.00315, 

0.0063, 0.0125, 

0.025, 0.05, and 0.1 

g a.i./bee

Mean-measured 

concentrations: 0, 

0.003, 0.006, 0.012, 

0.023, 0.046, 0.09 g 

a.i./bee

48-hour LD50: 0.023 g a.i./bee 

(95% CI: 0.019-0.027 g a.i./bee)

48-hour NOAEL: 0.003 g a.i./bee

Probit slope: 3.75

Endpoint(s) affected: Mortality.

(Sub)lethal effects: By 48 hours, 

30, 26.7, 56.7, 86.7, and 100% 

mortality was observed in the test 

treatments, respectively. Negative 

control mortality was 13.3%; 

solvent control mortality was 

16.7%.

*An important note is that the control 

mortality exceeded 10% (an OECD 

requirement), but not the 20% guideline 

limit set for an acute contact study (OPPTS 

850.3020).

45639725 Supplemental2/ 

Highly toxic1

Formulation MTI-446 20%WG

Honey bee

Apis mellifera

21.4 48-hour, acute contact

toxicity

Worker bees, 1-7 

days old

3 reps; 10 bees/rep

Solvent: Triton x-100 

(wetting agent), 1 g/L

Nominal 

concentrations: 0 

(negative, solvent 

control), 0.0125, 

0.025, 0.05, 0.1, 0.2, 

and 0.4 g a.i./bee

48-hour LD50: 0.061 g a.i./bee 

(95% CI: 0.05 – 0.073 g 

a.i./bee)

48-hour NOAEL: 0.0125 g 

a.i./bee

Probit slope: 3.48

Endpoint(s) affected: Mortality.

(Sub)lethal effects: By 48 hours, 

0, 6.7, 36.7, 73.3, 100, and 

100% mortality was observed in 

the test treatments, respectively. 

Negative conrol mortality was 

0%; solvent control mortality 

was 0%. After 4 hours, 

symptoms of ataxia were 

observed in the 0.2 and 0.4 g 

a.i./bee groups.

45639726 Acceptable / 

Highly toxic1
17

Honey bee

Apis mellifera

21.4 48-hour, acute oral

toxicity

Worker bees, 1-7 

days old

3 reps; 10 bees/rep

Solvent: Triton x-100 

(wetting agent), 1 g/L 

Nominal 

concentrations: 0 

(negative, solvent 

control), 0.0063, 

0.0125, 0.025, 0.05, 

0.1, and 0.2 g 

a.i./bee

Mean-measured 

concentrations: 0, 

0.005, 0.011, 0.021, 

0.046, 0.088, 0.173 

g a.i./bee

48-hour LD50: 0.032 g a.i./bee 

(95% CI: 0.025 – 0.041 g 

a.i./bee)

48-hour NOAEL: 0.005 g 

a.i./bee

Probit slope: 2.26

Endpoint(s) affected: Mortality.

(Sub)lethal effects: By 48 hours, 

6.7, 16.7, 43.3, 53.3, 90, and 

100% mortality was observed in 

the test treatments, respectively. 

Negative control mortality was 

3.3%; solvent control mortality 

was 6.7%.

45639726 Supplemental2/ 

Highly toxic1

Formulation MTI-446 20%WG - no negative control

Honey bee

Apis mellifera

21.4 48-hour, acute contact

toxicity

Adult worker bees, 

age not specified

3 reps; 10 bees/rep

Solvent: Triton x-100 

(wetting agent), 1 g/L

Nominal 

concentrations: 0 

(solvent control), 

0.0014, 0.0032, 

0.0072, 0.016, 0.036, 

0.08 g a.i./bee

*No negative (water) 

control was used

48-hour LD50: 0.024 g a.i./bee 

(95% CI: 0.018 – 0.031 g 

a.i./bee)

48-hour NOAEL: 0.0032 g 

a.i./bee

Probit slope: 2.0

Endpoint(s) affected: Mortality.

(Sub)lethal effects: By 48 hours, 

3, 3, 7, 43, 63, and 87% 

mortality was observed in the 

test treatments, respectively. 

Solvent control mortality was 

0%. At 4 hours, there were 

stumbling and knockdown bees 

in the 0.036 and 0.08 g a.i./bee 

groups.

45639727 Acceptable / 

Highly toxic1

Honey bee

Apis mellifera

21.4 48-hour, acute oral

toxicity

Adult worker bees, 

age not specified

3 reps; 10 bees/rep

Solvent: Triton x-100 

(wetting agent), 1 g/L 

48-hour LD50: 0.0076 g 

a.i./bee (95% CI: 0.004 – 0.012 

g a.i./bee)

48-hour NOAEL: 0.0013 g 

a.i./bee

Probit slope: 3.0

Endpoint(s) affected: Mortality.

45639727 Supplemental2/ 

Highly toxic1
18

Nominal 

concentrations: 0 

(solvent control), 

0.00056, 0.0013, 

0.0028, 0.0064, 

0.014, and 0.032 g 

a.i./bee

Mean-measured 

concentrations: 0 

(solvent control), 

0.00056, 0.0013, 

0.0028, 0.0061, 

0.013, and 0.029 g 

a.i./bee

*No negative (water) 

control was used

(Sub)lethal effects: By 48 hours, 

13, 3, 17, 43, 97, and 90% 

mortality was observed in the 

test treatments, respectively. 

Solvent control mortality was 

20%. However, a concurrent 

dimethoate test had 13% 

mortality in the solvent control. 

At 4 hours, there were stumbling 

and/or knockdown bees 

observed in every treatment and 

control group, except for the 

0.00056 g a.i./bee

*An important note is that the control 

mortality exceeded 10% (an OECD 

requirement), but not the 20% guideline 

limit set for an acute contact study 

(OPPTS 850.3020).

Formulation MTI-446 20%WG - residues on alfalfa *(OPPTS 850.3030; honey bee toxicity of residues on foliage)

Honey bee

Apis mellifera

Not 

reported

72-hour, toxicity to 

residues on alfalfa 

(foliar spray 

application)

1-7 days old

6 reps; 25 bees/rep

Solvent: water

(i.e., negative 

control)

Single nominal 

application rate: 150 

g a.i./ha (60.75 g 

a.i./A or 0.1338 lbs 

a.i./A†)

Bees exposed to 

residues on leaves 

collected at 3, 8, 24, 

and 48 hours posttreatment

*Foliar residues of MTI446 were not measured

3-hour aged residue

♠RT25 = 6.7 (3.3-14) hour

Probit slope = 2.37 ± 0.431

8-hour aged residue

RT25 = 4.8 (2.4-9.6) hour

Probit slope = 2.66 ± 0.436

24-hour aged residue

RT25 = 24 (14-44) hour

Probit slope = 4.63 ± 1.54

48-hour aged residue

RT25 = 90 (75-110) hour

Probit slope = 6.36 ± 3.78

Endpoints considered: Mortality, 

behavior, toxicological response 

(at 3, 24, 48, 72, and a single obs. 

at 100 hours post-exposure for 48 

hour group)

Endpoint(s) affected: Mortality.

(Sub)lethal effects: After 24 and 

48 hours of exposure to 3, 8, and 

24 hour aged residue, there was 

significant mortality relative to 

the controls for each residue 

group. After 72 hours, mortality 

was 95, 98, and 97% for bees 

exposed to 3, 8, and 24 hour 

residues. There appeared to be no 

significant effect on mortality to 

bees exposed to 48 hour aged 

45639728 Acceptable
19

residue, regardless of exposure 

period. By 72 hours, negative 

control mortality was 7, 12, 73, 

and 12% in the 3-, 8-, 24-, and 

48-hour post-treatment groups, 

respectively. The positive control 

(dimethoate) was only reported 

for the 3-hour residue group and 

had significant mortality in the 

24 and 48 hour exposure periods 

relative to controls and 64% 

mortality after 72 hours of 

exposure.

Hyperactivity observed in bees 

exposed to 3 and 8 hour posttreatment residues. Ataxia in 

some bees exposed to 3, 8, 24, 

and 48 hour post-treatment 

residues and in controls of the 3 

and 8 hour groups. 

Formulation MTI-446 20% SG – Also, nonguideline studies

Parasitoid 

wasp

Aphidius 

rhopalosiphi

(Hymenoptera, 

Braconidae)

21.09 13-day, survival 

(exposure phase: 2 

day exposure; 11 day 

obs) and separate 

repro study 

(fecundity phase: 1 

day exposure; 10 day 

obs)

1-2 days old

Nominal 

applications: 0 

(negative control), 2, 

7, 20, 70, and 200 

mg a.i./ha 

(1.79x10-6, 6.25x10-

6

, 1.79x10-5, 6.25 x 

10-5, and 0.0002 lbs 

a.i./A)

*Only the underlined 

concentrations were used 

for the parasitism effect 

component (i.e., fecundity 

phase), in which aphids 

(Rhopalosiphum padi) 

were fed to ♀ wasps only; 

note: ♂ & ♀ wasps were 

used in presumed equal 

numbers in the mortality 

component (i.e., exposure 

phase)

Note: test substance was 

13-d LC50: 77.2 mg a.i./ha

(6.89x10-5lbs a.i./A)

(95% CI: 59.4 – 102.6 mg a.i./ha; 

5.30 x 10-5– 9.16x10-5lbs a.i./A)

NOAEC: 7 mg a.i./ha

(6.25x10-6lbs a.i./A)

Endpoints considered: Mortality 

and reproductive effects 

(parasitism)

Endpoint(s) affected: Mortality, 

parasitism success.

(Sub)lethal effects: Corrected 

mortality (using SchneiderOrelli‟s fomula4

) was -7, -2, 9, 

50, and 74% in the test 

treatments, respectively. 

Significant mortality obs in the 

two highest concentrations. 

Negative control mortality was 

10%.

Percent reduction in parasitism 

success (#of aphid mummies per 

♀) was -1 and 67% for the two 

concentrations tested (7 and 20 

mg a.i./ha). Significant reduction 

in parasitism obs in 20 mg a.i./ha 

group. Control parasitization 

45640121 Supplemental3
20

sprayed on the top and 

bottom glass plates of the 

test units with a calibrated 

track sprayer; 2 treated 

glass plates were placed in 

ventilated glass cages

success was 8.4 aphid mummies 

per ♀ per 22 hour parasitization 

period.

Predaceous 

bug 

Orius 

laevigatus

(Hemiptera, 

Anthocoridae)

21.09 21 day (9 day 

exposure; 12 day 

obs), survival (9 

days) and 

reproduction (12 

days) study

Nymphs, 5-6 days 

old

Nominal 

applications: 0 

(negative control), 

1.36, 2.72, 5, 8.8, 

and 13.6 mg a.i./ha 

(1.21x10-6, 2.43x10-

6

, 4.46x10-6, 7.86x10-

6

, and 1.21x10-5lbs 

a.i./A)

*Only the underlined 

concentrations were used 

for the reproductive effect 

component (i.e., fecundity 

phase), in which only ♀ 

bugs were present; note: ♂ 

& ♀ bugs were used in the 

mortality component (i.e., 

exposure phase)

Note: The test substance 

was sprayed on all inner 

parts of the test units with 

a calibrated lab track 

sprayer. 

21-d LC50: 13.3 mg a.i./ha

(1.19x10-5lbs a.i./A)

(95% CI: 7.0 - 25.1 mg a.i./ha;

6.25x10-6– 2.24x10-5lbs a.i./A)

NOAEC <1.36 mg a.i./ha

(1.21x10-6 lbs a.i./A)

Probit slope: 2.11

LOAEC: 8.8 mg a.i./ha

Endpoints considered: Mortality 

and reproductive effects 

(oviposition, egg hatch success)

Endpoint(s) affected: Mortality.

(Sub)lethal effects: Corrected 

mortality (using SchneiderOrelli‟s fomula4

) was 15, 1, 13, 

43, and 49% in the test 

treatments, respectively. 

Significant mortality obs in the 

lowest and two highest 

concentrations. Negative control 

mortality was 16%.

Percent reduction in mean #of 

eggs produced per day per ♀ was 

4 and -2% and percent inhibition 

for egg hatch were 0 and -1% for 

the two concentrations tested 

(2.72 and 5 mg a.i./ha). 

Fecundity was not significantly 

affected by treatment. 

Reproductive success was 6.9 

eggs per ♀ per day and average 

egg hatch success was 92%.

45640122 Supplemental3

Predaceous 

mite

Typhlodromus 

pyri

(Acari: 

Phytoseiidae)

21.09 14 day (7 day 

exposure; 7 day obs), 

survival (7 days) and 

reproduction (7 days) 

study

Protonymphs, 1 day 

old

Nominal 

applications: 15, 20,

30, 40, and 60 g 

a.i./ha (0.013, 0.018, 

14-d LC50: 30.1 g a.i./ha

(0.027 lbs a.i./A)

(95% CI: 26.7- 34.2 g a.i./ha;

0.024 – 0.030 lbs a.i./A)

NOAEC <15 g a.i./ha

(0.013 lbs a.i./A)

Endpoints considered: Mortality 

and reproductive effects (# of 

eggs and oviposition)

Endpoint(s) affected: Mortality, 

45640120 Supplemental3
21

0.027, 0.036, and 

0.053 lbs a.i./A)

*Only the underlined 

concentrations were used 

for the reproductive effect 

component (i.e., fecundity 

phase); note: ♂ & ♀ mites 

were used both in the 

reproductive effect 

component and in the 

mortality component (i.e., 

exposure phase)

Note: The test substance 

was sprayed on inner parts 

of glass cage and petri 

dishes with a calibrated 

lab track sprayer.

fecundity.

(Sub)lethal effects: Corrected 

mortality (using SchneiderOrelli‟s fomula4

) was 39, 32, 79, 

47, and 96% in the test 

treatments, respectively. 

Significant mortality obs in all 

test concentrations. Negative 

control mortality was 10%.

Percent reduction in mean #of 

eggs produced per day per ♀ was 

41 and 51% for the two 

concentrations tested (15 and 20 

g a.i./ha). Fecundity was 

significantly reduced in the 20 g 

a.i./ha treatment. Reproductive 

success was 9 eggs per ♀ per 

day.

1 Based on acute contact LD50 ( g a.i./bee) <2 highly toxic; 2-10.99 moderately toxic; ≥11 practically non-toxic

2 The study is a non-guideline study and does not fulfill an OPP guideline requirement. 

3 The test species is not a US EPA-recommended species for toxicity testing with terrestrial invertebrates; SEP guidelines do not exist 

for this species.

4

Schneider-Orelli‟s formula: Corrected % = (%mortality in treated - %mortality in control) / (100-%mortality in control) *100

† The application is below (constitutes 25% of) the maximum seasonal application rate (0.54 lbs a.i./A/yr) for the proposed label (Reg. 

No. 86203-11) applications (foliar, airblast, broadcast spray; soil applications; chemigation; basal trunk spray).

♠ RT25 = residual time to cause 25% mortality; bees were most sensitive to the 8 hour aged residue and least sensitive to treatment when 

exposed to 48 hour aged residue. Bee mortality on 48 hour aged residues did not differ from bees exposed to control leaves after 48 

hours.

Honey Bee Field Study

Classification and Conclusions

The submitted field study of foraging honey bees (Apis mellifera) after exposure to 

dinotefuran 70 SG (70% a.i.) applied to cotton fields in Georgia, USA (MRID 48120501) 

was deemed supplemental (for qualitative use only and not upgradable). It is very 

important to note that on account of a poor study design, inadequate raw data reporting3, 

and multiple additional considerations (see below and Appendix C), the toxicity 

determinations cannot be used for risk assessment purposes. However, information 

regarding residue detections may be informative assuming freezer stability (MRID 

48120502) was conducted at -20 oC (as reported in the field study), or at an alternative, 

representative temperature. Therefore, solely on the basis of the residue data, the field 

study may still be utilized to address long-term exposure of honey bees to dinotefuran.

Although bees were exposed to dinotefuran, the dinotefuran residue levels detected in 

treatment plot samples of nectar, honey, beeswax, and pollen, did not, for the most part, 

differ greatly from those detected in the control samples, which is indicative of cross 

contamination in the control plot blossoms and hives (of all three trials in pollen and/or 

nectar samples) and likely foraging of treatment groups on control plots and of control 

 

3

Statistical verification of the adult bee mortality was not possible as the raw data counts were not 

provided by the study author.
22

groups on treated plots. For example, only trial 1 samples of nectar in flowers for days 7 

and 17 indicated a clear distinction between no residue detected in controls and detected 

levels (0.012-0.021 ppm) in both treatment plots; and, in trial 3 day 26 flower nectar 

samples where no residues were detected in the control, but were detected in the two 

treatments as 0.013 ppm and <LOQ (0.004 ppm). As a result of the cross-contamination, 

this study is inconclusive in terms of the toxicity of dinotefuran applications on cotton to 

honey bee hives. In addition, the lack of quantitative data rather than simply 

presence/absence on overwintering parameters such as egg abundance, larval abundance, 

pupal abundance renders the study inconclusive in terms of assessing overwintering 

success. The data suggest that all colonies (control and treatment) for all three trials were 

healthy (w/ >4 frames of adults) by approximately 200 days after exposure (i.e., Spring 

colony assessment performed in February for all three trials), with presence of queen, 

larvae, and eggs. However, the numbers on these hive attributes are not included. Instead, 

the quantitative data for this time step indicates that all colonies had adults present in all 

10 frames of each colony; this was the case for all three trials. Also, an estimate of the 

number of capped brood was only provided for trial 1, but the difference between control 

and treatment groups did not appear to be significant. In addition, presence of queens 

may not be an indicator of overwintering success as new queens were added to hives 

when queen loss occurred during the study. While re-queening hives is a common 

management practice, it is not particularly desirable for field studies as it prevents a test 

from quantifying the colony's ability to supersede naturally. 

The data on toxic effects in this study cannot be used for risk assessment purposes on 

account of poor study design. Similarly, residue values below the LOQ (i.e., a <LOQ 

value that was calculated by integration for samples where residue values were 

<0.010mg/kg) cannot be used quantitatively in the risk assessment; therefore, the residue 

analysis is of limited value other than characterizing qualitatively the presence/absence of 

dinotefuran residues over time. In addition, there are two major metabolites, MNG and 

DN, for which no residue data are provided in this study. The presence/absence data for 

residues, particularly in nectar, are important, however, because they suggest that 

residues could potentially be present in extra floral nectaries once flowers have been 

shed, and dinotefuran (or, total) residues will be present in stored food inside hives for 

long periods of time (i.e., at least 85 days after application). Therefore, honeybee adults 

and brood will likely be exposed to low levels of dinotefuran for relatively long periods 

of time, but the toxicity of these levels of residues remains an uncertainty.

Field Study: Exposure

Concentrations of dinotefuran residues appear to be higher in flower nectar compared to 

flower pollen. Residues were detected in nectar samples from treated flowers up to 27 

days after application in trial 1 and up to 26 days after application in trials 2 and 3. These 

time points represent the latest time points that residues were collected from flowers in 

treated plots. The fact that residues were still present in these flower nectar samples, 

including one sample that had quantifiable residues of 0.013 ppm (LOQ = 0.004 ppm) 

after 26 days (trial 3), indicates that residues could potentially be found in nectar from 

extra floral nectaries in cotton plants as well as the flowers. These nectaries, which are 
23

not part of the blossom, may continue to produce nectar even after bloom that bees will 

use as a sugar source. Therefore, continual chronic exposure is likely to occur. 

Given detections of dinotefuran in hive nectar (plot 1) at day 34, may suggest that nectar 

was collected by bees from either available flowers or extrafloral nectaries (which are 

present, but may or may not be active, continuously – even when flowers fall off). 

Though dinotefuran detections were not made on the extrafloral nectaries of cotton 

plants, the presence of dinotefuran in flower nectar (e.g., up to day 27 post-application for 

plot 1 samples) lends strong support for dinotefuran concentrations in extrafloral 

nectaries given the common phloem source and dinotefuran‟s systemic properties, which 

would have implications for long-term exposure post-bloom.

Furthermore, trial 2 shows that dinotefuran residues can be detected in stored honey 

inside hives at least 85 days after application, which also suggests the occurrence of longterm chronic exposure inside the hive, which has implications for overwintering success 

as well.

Terrestrial Animals (birds/mammals)

Dinotefuran was tested on various species of birds (Japanese quail, northern bobwhite 

quail, and mallard duck for acute oral and dietary studies; and, bobwhite quail and 

mallard duck for chronic reproduction studies). The parent compound is practically 

nontoxic to Japanese quail (LD50 > 2,000 mg a.i./kg-bw; MRID 45639720) and bobwhite 

quail (LD50 > 2,250 mg a.i./kg-bw; MRID 47353601) on an acute oral basis and to 

mallard duck (LC50 > 5,000 mg a.i./kg-diet; whereby the mean test item intake is 997.9 

mg a.i./kg-diet; MRID 45639722) and Japanese quail (LC50 > 5,000 mg a.i./kg-diet; 

whereby the mean test item intake is 1301 mg a.i./kg-diet; MRID 45639721) on a 

subacute dietary basis. However, sublethal effects (somnolence up to 3 hours after 

administration of the test compound) were observed in the highest test concentration 

(2,000 mg a.i./kg-bw) of the acute oral Japanese quail study leading to a NOAEL 

determination of 1,000 mg a.i./kg-bw. Although there appeared to be no significant 

treatment-related effects on bobwhite quail (MRID 45639724) reproductive parameters, 

chronic testing on mallard duck (NOAEC = 2,150 mg a.i./kg-diet; MRID 45639723) 

showed significant reductions in the percentages of number of hatchlings/eggs laid, eggs 

set, and 14-day old survivors.

Dinotefuran is slightly to practically nontoxic on an acute basis to surrogate wild 

mammal species (laboratory rat) (female LD50 = 2000 mg/kg-bw; MRID 45639823). 

Chronic studies indicated effects on rats and rabbits. A 2-generation reproduction study 

for MTI-446 technical on the rat indicated a reproductive NOAEL of 3,000 mg/kg-diet 

(MRID 45639913) based on decreased uterine weights and microscopic alterations in the 

utrus and estrous cyclicity in Fo and F1 females, slight increases in abnormal sperm 

morphology in Fo and F1 males, and slight decreases in testicular sperm count in Fo males 

and sperm mortality in F1 males. The developmental toxicity NOAEL for MTI-446 

technical on rabbits is ≥ 300 mg/kg-bw/day, while the maternal toxicity NOAEL is 52 

mg/kg-bw/day based on decreased body weight gain, decreased food consumption, and 

gross necropsy findings (pale discoloration of the liver and gray white plaques in the 

stomach). The rabbit study is included here to illustrate that sublethal effects as a result of 
24

chronic exposure to dinotefuran occur in multiple mammalian species; the endpoint is 

utilized in additional calculations at a later section in the risk assessment. The degradates 

MNG and DN were not tested on birds or surrogate mammals.

Table 5. Acute effect (mortality) concentrations (LD50/ LC50) for terrestrial animals (birds/mammals) 

following exposure to Dinotefuran (Technical MTI-446). 

Species %a.i. Study 

Parameters

LD50/LC50; NOAEL/NOAEC MRID Classification 

/Category

Birds

Japanese

quail

Coturnix 

japonica

97.26 14-day, acute 

oral study 

(gavage)

8-wks old

Nominal 

concentrations: 

vehicle control 

(H2O), 200, 

1000, 2000 mg 

a.i./kg-bw

14-day LD50 >2000 mg a.i./kg-bw

14-day NOAEL: 1000 mg a.i./kgbw

Endpoint(s) affected: None.

(Sub)lethal effects: No mortality 

observed. All ♂ & ♀ birds showed 

somnolence up to 3 hours after 

gavage in 2000 mg a.i./kg-bw 

level which was the basis for a 

NOAEL of 1000 mg a.i./kg-bw; 

otherwise, none

45639720 Supplemental

/Practically nontoxic1

Northern 

Bobwhite 

quail

Colinus 

virginianus

94.7±1.04 14-day, acute 

oral study

(gavage)

(limit test)

25-wks old

Nominal 

concentrations: 

0 and 2250 mg 

a.i./kg-bw

14-day LD50 >2250 mg a.i./kg-bw

14-day NOAEL ≥ 2250mg a.i./kgbw

Endpoint(s) affected: None.

(Sub)lethal effects: None.

47353601 Acceptable 

/Practically nontoxic1

Japanese

quail

Coturnix 

japonica

8-day (5-day 

exposure; 3-

day obs), acute 

dietary study

(limit test)

16-days old

Nominal 

concentrations: 

0 and 5000 mg 

a.i./kg-diet

Meanmeasured 

concentrations:

8-day LC50 >5000 mg a.i./kg-diet

8-day NOAEC ≥5000 mg a.i./kgdiet

Endpoint(s) affected: None.

Sublethal effects: None.

45639721 Supplemental 

/Practically nontoxic2
25

0 and 4936 mg 

a.i./kg-diet; 

mean test item 

intake = 1301 

mg a.i./kg-diet

Mallard duck

Anas 

platyrhynchos

99.2 8-day (5-day 

exposure; 3-

day obs), acute 

dietary study

(limit test)

16-days old

Nominal 

concentrations: 

0 and 5000 mg 

a.i./kg-diet

Meanmeasured 

concentrations:

0 and 4732 mg 

a.i./kg-diet; 

mean test item 

intake = 997.9 

mg a.i./kg-diet

8-day LC50 >5000 mg a.i./kg-diet

8-day NOAEC ≥ 5000 mg a.i./kgdiet

Endpoint(s) affected: None.

Sublethal effects: None.

45639722 Acceptable 

/Practically nontoxic2

Mammals

Laboratory 

rat

Rattus 

norvegicus

99.1 14-day acute 

oral toxicity

♂ LD50 = 2,804 mg/kg-bw

♀ LD50 = 2,000 mg/kg-bw

Endpoint(s) affected: Morbidity.

45639823 Acceptable

(Tox. Category III)

1 Acute Oral (avian/mammal): Based on LD50 (mg/kg) <10 very highly toxic; 10-50 highly toxic; 51-500 moderately 

toxic; 501-2000 slightly toxic; >2000 practically nontoxic

2 Acute Dietary (avian): Based on LC50 (mg/kg) <50 very highly toxic; 50-500 highly toxic; 501-1000 moderately toxic; 

1001-5000 slightly toxic; >5000 practically nontoxic

*Values in bold indicate definitive endpoint and/or one which is used in risk quotient calculation.

Table 6. Chronic effect concentrations (NOAEC/LOAEC) for terrestrial animals (birds/mammals) 

following exposure to Dinotefuran (Technical MTI-446). 

Species %a.i. Study Parameters NOAEC/LOAEC MRID Classification 

/Category

Birds

Northern 

bobwhite quail

Colinus 

virginianus

99.3 1-generation (21 wks) 

reproductive study

(dietary)

21-wks old at initiation

Mean-measured 

concentrations:

0, 764, 2150, and 5270 

21-wk NOAEC ≥ 5270 

mg a.i./kg-diet

21-wk LOAEC > 5270 

mg a.i./kg-diet

Endpoint(s) affected: 

None.

45639724 Supplemental
26

mg a.i./kg-diet (Sub)lethal effects:

Two incidental 

mortalities, one each in 

control and 5270 mg 

a.i./kg-diet level. 

Incidental injuries due to 

pen-wear; slight (not 

considered treatment 

related), but statistically 

significant reduction in 

food consumption at 5270 

mg a.i./kg-diet level and 

percentage of viable 3-

week embryos at 764 mg 

a.i./kg-diet level

Mallard duck

Anas 

platyrhynchos

99.3 1-generation (20 wks) 

reproductive study

(dietary)

21-wks old at initiation

Mean-measured 

concentrations:

0, 764, 2150, and 5270 

mg a.i./kg-diet

20-wk NOAEC: 2150 

mg a.i./kg-diet

20-wk LOAEC: 5270 mg 

a.i./kg-diet

Endpoint(s) affected: 

number of hatchlings/eggs 

laid and set, 14-day old 

survivors/eggs set

(Sub)lethal effects: One 

incidental mortality in 

control. Incidental injuries 

due to pen-wear. 

Reproductive effects 

resulted in endpoint 

determination. 

45639723 Acceptable

Mammals

Laboratory 

rat

Rattus 

norvegicus

98.9 2-generation repro. 

study

(dietary)

Dietary concentrations: 

0, 300, 1000, 3000, and 

10000 mg/kg

Pre-mating doses:

Fo males

0, 24.1, 79.9, 241, 

822.1 mg/kg-bw/day

Fo females

0, 26.8, 90.1, 267.9, 

907 mg/kg-bw/day

F1 males

0, 27.2, 90.5, 269, 

934.7 mg/kg-bw/day

F1 females

Repro. NOAEL = 3,000 

mg/kg-diet 

(241-269 mg/kg-bw/day ♂;

267-292.6 mg/kg-bw/day ♀)

Repro. LOAEL = 10,000 

mg/kg-diet

(822.1-934.7 mg/kg-bw/day ♂;

907-1004.8 mg/kg-bw/day ♀)

Endpoint(s) 

affected/Sublethal effects: 

Decreased uterine 

weights, microscopic 

alteration in uterus and 

vagina of Fo ♀; decreased 

numbers of primordial 

follicles in F1 ♀, altered 

estrous cyclicity in Fo ♀; 

slight increases in 

abnormal sperm 

morphology in Fo and F1

45639913 

(definitive test);

45639914 (rangefinding test)

Acceptable
27

0, 29.6, 96.5, 292.6, 

1004.8 mg/kg-bw/day

♂, and slight decreases in 

testicular sperm count in 

Fo ♂ and sperm mortality 

in F1 ♂.

Laboratory rat

Rattus 

norvegicus

92.9 Prenatal development

(gavage)

Dose levels:

0, 100, 300, 1000 

mg/kg-bw/day on 

gestation days 6-15 

(inclusive)

Dev. NOAEL ≥ 1,000 

mg/kg-bw/day

Dev. LOAEL Not 

established

Endpoint(s) affected: 

None. No statistically 

significant effects on 

developmental endpoints. 

Sublethal effects:

Maternal toxicity was 

evident at a dose of 1000 

mg/kg-bw/day. After 

initiation, decreases in 

body wt gain (5.5, 40, and 

56% of controls) and 

decreased food 

consumption (88, 87, and 

90% of controls) at 

gestation days (6-7, 7-8, 

and 9-10).

45654207 

(definitive test)

45639910 (range 

finding test)

Acceptable

Rabbit 92.9 Prenatal development

(gavage)

Dose levels:

0, 52, 125, 300 mg/kgbw/day on gestation 

days 6-18 (inclusive)

Dev. NOAEL ≥ 300 

mg/kg-bw/day

Dev. LOAEL Not 

established

Maternal NOAEL = 52 

mg/kg-bw/day

Maternal LOAEL = 125 

mg/kg-bw/day

Endpoint(s) affected: 

None. No statistically 

significant effects on 

developmental endpoints

Sublethal effects: 

Maternal toxicity was 

evident at doses of 125 

and 300 mg/kg-bw/day. 

Decreased bw gain (80% 

of controls) in ♀ in the 

125 mg/kg-bw/day group 

at gestation days 6-18 and 

transient decrease in food 

consumption (84-90% of 

controls) after initiation 

(gestation days 6-10). 

45654208 

(definitive test)

45639911 (range 

finding test)

45639912 (range 

finding test)

Acceptable
28

Other findings include: 

liver discoloration, 

stomach plaque, transient 

neurological signs

*Values in bold indicate definitive endpoint and/or one which is used in risk quotient calculation.

Aquatic Animals

The data submitted by the registrant show that dinotefuran (technical MTI-446) is 

practically nontoxic on an acute basis to freshwater and estuarine/marine fish (96-hour 

LC50 > 99 mg a.i./L), as well as freshwater invertebrate (D. magna 48-hour LC50 > 968.3 

mg a.i./L; MRID 45639709) and saltwater invertebrate (eastern oyster 96-hr EC50 > 141 

mg a.i./L; MRID 45639711). The degradate of dinotefuran (DN phosphate) is also 

considered practially non-toxic to the freshwater invertebrate (D. magna 48-hour LC50 > 

110.6 mg a.i./L; MRID 45639710); however, on the basis of 10% immobility in the 

highest concentration tested a NOAEC of 10 mg a.i./L was determined. However, on an 

acute basis dinotefuran appears to be highly toxic to the estuarine/marine invertebrates

(mysid shrimp LC50 = 0.79 mg a.i./L; MRID 45639713). Chronic toxicity testing on 

freshwater fish (rainbow trout; MRID 45639719) and invertebrates (D. magna; MRID 

45639718) showed no treatment related effects and NOAECs of > 6.36 mg a.i./L and > 

95.3 mg a.i./L, respectively. Since estuarine/marine chronic toxicity studies were not 

submitted for this compound there is uncertainty regarding chronic risk to

estuarine/marine fish, but a major uncertainty regarding chronic risk to estuarine/marine 

invertebrates. Based on the available data the estuarine/marine invertebrates (mysid, LC50

= 0.79 mg a.i./L) are significantly more sensitive to dinotefuran than freshwater 

invertebrates (daphnia, LC50 >110.6 mg a.i./L) on an acute exposure basis. Given that the 

acute and chronic endpoints for the freshwater invertebrate are non-definitive, estimates 

for the chronic saltwater invertebrates on the basis of an acute-to-chronic ratio would not 

be reliable. Therefore, a chronic mysid study is needed to address this uncertainty.

Table 7. Acute effect concentrations (LC50/EC50) for aquatic animals and plants following exposure to 

Dinotefuran (Technical MTI-446; unless otherwise stated). 

Species %a.i. Study Parameters LD50/LC50/EC50;

NOAEL/NOAEC

MRID Classification 

/Category

Freshwater fish

Rainbow Trout

Oncorhynchus 

mykiss

97.26 96-hour acute toxicity

(limit test)

Static

Nominal 

concentrations: 0, 100 

mg a.i./L

Mean-measured 

concentrations: 0, 

99.5 mg a.i./L

96-hr LC50 > 99.5 mg 

a.i./L

96-hr NOAEC ≥ 99.5 mg 

a.i./L

Endpoints considered: 

mortality, intoxication

Endpoint(s) affected: 

None.

(Sub)lethal effects:

45639714 Acceptable / 

Practically nontoxic1
29

None.

Bluegill sunfish 

Lepomis 

macrochirus

97.26 96-hour acute toxicity

(limit test)

Static

Nominal 

concentrations: 0, 100 

mg a.i./L

Mean-measured 

concentrations: 0, 

99.3 mg a.i./L

96-hr LC50 > 99.3 mg 

a.i./L

96-hr NOAEC ≥ 99.3 mg 

a.i./L

Endpoints considered: 

mortality, intoxication

Endpoint(s) affected: 

None.

(Sub)lethal effects:

None.

45639715 Acceptable / 

Practically nontoxic1

Carp

Cyprinus carpio

97.26 96-hour acute toxicity

(limit test)

Static

Nominal 

concentrations: 0, 100 

mg a.i./L

Mean-measured 

concentrations: 0, 

99.1 mg a.i./L

96-hr LC50 > 99.1 mg 

a.i./L

96-hr NOAEC ≥ 99.1 mg 

a.i./L

Endpoints considered: 

mortality, intoxication

Endpoint(s) affected: 

None.

(Sub)lethal effects:

None.

45639716 Supplemental†

/Practically nontoxic1

Freshwater invertebrate

Waterflea

Daphnia magna

97.26 48-hour acute toxicity

(limit test)

Static

Nominal 

concentrations: 0, 

1000 mg a.i./L

Mean-measured 

concentrations: 0, 

968.3 mg a.i./L

48-hr LC50 > 968.3 mg 

a.i./L

48-hr NOAEC ≥ 968.3 

mg a.i./L

Endpoints considered: 

immobility

Endpoint(s) affected: 

None.

(Sub)lethal effects:

None.

45639709 Acceptable 

/Practically nontoxic1

Waterflea

Daphnia 

magna

Not 

reported 

Metabolite 

(DN 

Phosphate)

48-hour acute toxicity

Static

Nominal 

concentrations: 0, 1, 

10, and 100 mg a.i./L

Mean-measured 

concentrations: <5.04 

(<LOQ, control), and 

110.6 mg a.i./L (for 

48-hr LC50 > 110.6 mg 

a.i./L

48-hr NOAEC: 10 mg 

a.i./L

48-hr LOAEC: 110.6 mg 

a.i./L

Endpoints considered: 

mortality/immobility

45639710 Acceptable / 

Practically nontoxic1
30

the highest treatment 

group)

Endpoint(s) affected: 

After 48 hours, there was 

10% immobility in the 

110.6 mg a.i./L treatment 

group which was the 

basis for a NOAEC of 10 

mg a.i./L. The control 

and other treatment 

groups had 0% 

immobility.

(Sub)lethal effects:

None.

Saltwater fish

Sheepshead 

minnow

Cyprinodon 

variegatus

99.2 96-hour acute toxicity

(limit test)

Flow-through

Nominal 

concentrations: 0, 120 

mg a.i./L

Mean-measured 

concentrations: 0, 109 

mg a.i./L

96-hr LC50 > 109 mg 

a.i./L

96-hr NOAEC ≥ 109 mg 

a.i./L

Endpoints considered: 

mortality, intoxication

Endpoint(s) affected: 

None.

(Sub)lethal effects:

None.

45639717 Supplemental♠

/Practically nontoxic1

Saltwater invertebrate

Eastern oyster

Crassostrea 

virginica

99.6 96-hour acute toxicity

Flow-through

Nominal 

concentrations: 0, 16, 

26, 43, 72, and 120 

mg a.i./L

Mean-measured 

concentrations: 0, 15, 

24, 47, 75 and 141 mg 

a.i./L

96-hr EC50 > 141 mg 

a.i./L

96-hr NOAEC ≥ 141 mg 

a.i./L

Endpoints considered: 

shell deposition 

Endpoint(s) affected: 

None. After 96 hours of 

exposure, mean shell 

growth was 2.2 mm for 

negative control, 2.26, 

2.43, 1.96, 1.71, and 2.22 

for the test 

concentrations, 

respectively.

(Sub)lethal effects:

None.

45639711 Acceptable 

/Practically nontoxic1

Mysid shrimp

Americamysis 

bahia

99.2 96-hour acute toxicity

Flow-through

Nominal 

concentrations: 0, 

96-hr LC50: 0.79 mg 

a.i./L (95% C.I.: 0.49-

1.0 mg a.i./L)

96-hr NOAEC: 0.49 mg 

a.i./L

45639713 Acceptable / 

Highly toxic1
31

0.063, 0.13, 0.25, 

0.50, 1.0 and 2.0 mg 

a.i./L

Mean-measured 

concentrations: 0, 

0.065, 0.13, 0.25, 

0.49, 1.0, and 2.0 mg 

a.i./L

96-hr LOAEC: 1.0 mg 

a.i./L

Endpoints considered: 

Mortality, sublethal 

effects

Endpoint(s) affected: 

Mortality, sublethal 

effects

(Sub)lethal effects: At 96 

hours, mortality was 5% 

in the contol and 5, 5, 0, 

5, 75, and 100% for the 

test concentrations, 

respectively. Erratic 

swimming and loss of 

equilibrium were 

observed in surviving 

mysids from the 1.0 and 

2.0 mg a.i./L treatment 

levels during the test. 

Lethargic mysids were 

observed in the 1.0 mg 

a.i./L treatment level.

1Based on EC50 (mg/L): < 0.1 very highly toxic; 0.1-1 highly toxic; >1-10 moderately toxic; >10-100 slightly toxic; >100 

practically nontoxic

† The common carp is not a recommended species

♠ Mean fish weight of 0.35g, determined from control fish at test termination, was less than the required initial weight range 

of 0.5 to 5g

*Values in bold indicate definitive endpoint and/or one which is used in risk quotient calculation.

Table 8. Chronic effect concentrations (NOAEC/LOAEC) for aquatic animals following exposure to 

Dinotefuran (Technical MTI-446). 

Species %a.i. Study Parameters NOAEC/LOAEC MRID Classification 

/Category

Freshwater fish

Rainbow 

Trout

Oncorhynchus 

mykiss

98.9 Early life stage

(94 days: 34-day 

hatching period; 60-day 

post hatch period)

(limit test)

Flow-through

Nominal 

concentrations: 0 and 

10 mg a.i./L

Mean-measured 

concentrations: 0 and 

10.4 mg a.i./L

94-d NOAEC > 6.36 mg 

a.i./L

94-d LOAEC ≥ 6.36 mg 

a.i./L

Endpoints considered: 

Fertilization / hatching 

success, time to hatch, 

time to swim up, posthatch survival, terminal 

length, wet or dry weights

Endpoint(s) affected: 

None.

45639719 Acceptable1
32

(Sub)lethal effects:

None.

Freshwater invertebrate

Waterflea

Daphnia 

magna 

97.26 21-day chronic toxicity

Static renewal

Nominal 

concentrations: 0, 6.25, 

12.5, 25, 50, and 100 

mg a.i./L

Mean-measured 

concentrations (for 

highest concentration 

only): 95.3 mg a.i./L

21-d LC50/EC50 > 95.3 

mg a.i./L

21-d NOAEC > 95.3 mg 

a.i./L

21-d LOAEC ≥ 95.3 mg 

a.i./L

Endpoints considered: 

Mortality, reproductive 

effects (number of 

offspring per surviving 

adult), terminal length.

Endpoint(s) affected: 

None.

(Sub)lethal effects:

None.

45639718 Acceptable

Saltwater fish – NA

Saltwater invertebrate - NA

1

Study was previously classified invalid on account of low recoveries of test concentrations and highly variable analytical 

results; however, as no endpoints were affected at the lowest, measured dinotefuran concentration (that is, 6.36 mg a.i./L) 

and the limit testing on guildeline 72-4 is allowable, the study was reclassified to acceptable in 2006 (USEPA, DP Barcodes 

D331699 & D316645 add to refs)

Plants

Terrestrial plant testing (Tier I seedling emergence, MRID 45639729, and vegetative 

vigor, MRID 45639730) on ten species indicated no effects as a result of a single 

application of LX1414-01 MTI-446 20% SG (dinotefuran) Lot # 01i-6252 at a rate of 

0.54 lbs a.i./A. For some plants, considered endpoints exhibited reductions relative to the 

controls which were < 25% (see Table 9), which indicates that further testing (i.e., Tier 

II) is not required. The 14-day EC25 and NOAEL for both studies were >0.54 lbs a.i./A 

and ≥ 0.54 lbs a.i./A, respectively.

Acute toxicity testing on aquatic vascular plant (L. gibba; MRID 45639731) showed no 

treatment related effects yielding 7-day EC50 annd NOAEC of > 110 mg a.i./L and ≥ 110 

mg a.i./L, respectively. Non-vascular plant (P. subcapitata) acute toxicity testing on two 

degradates MNG (MRID 45639733) and DN (DN-phosphate; MRID 45639734) also 

showed no treatment related effects and thus 96-hour EC50 and NOAEC values of > 98.7/ 

≥98.7 mg a.i./L and > 100.4 / ≥100.4 mg a.i./L, respectively. However, testing with the 

TGAI (MTI-446) indicated a significant effect on cell density for P. subcapitata at the 

two highest test concentrations yielding a 96-hour NOAEC of 25 mg a.i./L; the EC50 for 

cell density, biomass, and growth rate endpoints, however, is >97.6 mg a.i./L (the highest 

concentration tested).
33

Table 9. Effect concentrations (EC25/NOAEC) for terrestrial plants following exposure to Dinotefuran 

(TEP: MTI – 446 20%SG).

Species %a.i. Study Parameters EC25 / NOAEL MRID Classification 

/Category

Seedling 

emergence

20.39 Tier I, 14-day test; 

utilized overhead track 

sprayer

Single application rate:

600 g a.i./ha (i.e., 

0.5352 lbs a.i./A)

Dicots: bean, cabbage, 

lettuce, radish, 

soybean, tomato

Monocots: corn, onion, 

ryegrass, wheat

14-d EC25 > 0.54 lbs a.i./A

14-d NOAEL ≥ 0.54 lbs 

a.i./A

Endpoints considered: 

Emergence, survival, dry 

weight, plant height.

Endpoint(s) affected: None. 

No single monocot or dicot 

was most sensitive than the 

rest; there were no 

significant effects of 

treatment on any species or 

endpoint; however, 

observed reductions 

(relative to the control) for 

the considered endpoints 

across species were ≤ 14%.

(Sub)lethal effects:

None. By 2 weeks, no 

treatment related signs of 

toxicity were observed.

45639729 Acceptable

Vegetative 

vigor

20.39 Tier I, 14-day test; 

utilized overhead track 

sprayer

Single application rate:

600 g a.i./ha (i.e., 

0.5352 lbs a.i./A)

Dicots: bean, cabbage, 

lettuce, radish, 

soybean, tomato

Monocots: corn, onion, 

ryegrass, wheat

14-d EC25 > 0.54 lbs a.i./A

14-d NOAEL ≥ 0.54 lbs 

a.i./A

Endpoints considered: 

Dry weight, plant height.

Endpoint(s) affected: None. 

No single monocot or dicot 

was most sensitive than the 

rest; however, by 14 days 

soybean dry weight 

exhibited a significant 

reduction (7%) relative to 

the control, which yields a 

NOAEL of <0.54 lbs a.i./A; 

but other reductions include 

lettuce plant ht (8%), onion 

dry wt (4%) and plant ht 

(10%), radish dry wt (3%) 

and plant ht (10%).

(Sub)lethal effects:

None. By 2 weeks, no 

treatment related signs of 

45639730 Acceptable
34

toxicity were observed.

Table 10. Effect concentrations (EC50/NOAEC) for aquatic plants following exposure to Dinotefuran 

(Technical MTI-446, unless otherwise stated). 

Species %a.i. Study Parameters EC50; NOAEC MRID Classification 

/Category

Vascular

Duckweed 

Lemna gibba

99.2 7-day acute toxicity

Static renewal

Nominal 

concentrations: 11, 

20, 35, 62, and 110 

mg a.i./L

Mean-measured 

concentrations: N/A, 

but a mean-measured 

test concentration 

averaged 101% of 

nominal 100 mg 

a.i./L

All endpoints:

7-d EC50 >110 mg a.i./L

7-d NOAEC ≥ 110 mg 

a.i./L

Endpoints considered: 

dry weight, growth rate, 

biomass

Endpoints affected: 

None. 

(Sub)lethal effects: 

Compared to the control, 

frond dry wt decreased by 

21.5, 2.9, 12.9, 2.3, and 

4.3%, biomass decreased 

by 11.2, 3, 17.5, 12.5, and 

8.4%, growth rate 

decreased by 4.8, 2.3, 6.9, 

4.7, and 3.2%.

45639731 Supplemental1

Non-vascular

Green Algae 

Pseudokirchneriella 

subcapitata 

(a.k.a. Selenastrum 

capricornutum)

97.26 96-hour acute 

toxicity

Static 

Nominal 

concentrations: 0, 

6.25, 12.5, 25, 50, 

and 100 mg a.i./L

Mean-measured 

concentrations (for 

highest concentration 

only): 97.6 mg a.i./L

Cell density

96-hr EC50 > 97.6 mg 

a.i./L

96-hr EC05: 21 mg a.i./L 

(95% C.I. 24-190 mg 

a.i./L)

96-hr NOAEC: 25 mg 

a.i./L

Probit slope: 0.535 ± 

0.325

AUG curve (biomass) & 

growth rate

96-hr EC50 >97.6 mg 

a.i./L

NOAEC ≥ 97.6 mg a.i./L

Endpoints considered: 

Cell density, AUG curve 

(biomass), growth rate

Endpoint(s) affected: Cell 

density.

(Sub)lethal effects:

45639732 Acceptable
35

Cell density significantly 

reduced in the two 

highest test 

concentrations, thus the 

determination of NOAEC 

of 25 mg a.i./L. The 96-hr 

%inhibition of growth 

rate was 1.5, 0, 0.5, 1.6, 

and 2.0%; of AUG curve 

was 12, -3.2, -1.1, 5.9, 

and 3.6% for test 

concentrations, 

respectively. Shape of 

cells was unaffected. 

Green Algae 

Pseudokirchneriella 

subcapitata 

(a.k.a. Selenastrum 

capricornutum)

Not 

reported

Metabolite

MNG

96-hour acute 

toxicity (limit test)

Static

Nominal 

concentrations: 0, 

1.0, 10, and 100 mg 

a.i./L

Mean-measured 

concentration (for 

highest concentration 

only): 98.7 mg a.i./L

All endpoints:

96-hr EC50 > 98.7 mg 

a.i./L

96-hr NOAEC ≥ 98.7 mg 

a.i./L

Endpoints considered: 

cell density, growth rate, 

AUG curve (biomass)

Endpoints affected: 

None. 

(Sub)lethal effects: 

Compared to the control, 

96-hr %inhibition for cell 

density was 34, -8, and 

23%, for growth rate was 

20, -1.7, and 8.3%, for 

biomass was 30, -9.8, and 

14%

45639733 Supplemental2

Green Algae 

Pseudokirchneriella 

subcapitata 

(a.k.a. Selenastrum 

capricornutum)

Not 

reported

Metabolite 

DN (DNPhosphate)

96-hour acute 

toxicity (limit test)

Static

Nominal 

concentrations: 0, 

1.0, 10, and 100 mg 

a.i./L

Mean-measured 

concentration (for 

highest concentration 

only): 100.4 mg 

a.i./L

All endpoints:

96-hr EC50 > 100.4 mg 

a.i./L

96-hr NOAEC ≥ 100.4 

mg a.i./L

Endpoints considered: 

cell density, growth rate, 

AUG curve (biomass)

Endpoints affected: 

None. 

(Sub)lethal effects: 

Compared to the control, 

96-hr %inhibition for cell 

density was 31, -6, and 

1%, for growth rate was 

7, 0, and 2%, for biomass 

was 15, 2, and 4%

45639734 Supplemental2

Freshwater Diatom NA NA NA NA NA
36

Navicula pelliculosa

Marine Diatom 

Selenastrum costatum

NA NA NA NA NA

Freshwater Alga 

Anabaena flosaquae

NA NA NA NA NA

1 The study is scientifically sound, but does not satisfy guideline requirements for a tier II acute toxicity study with aquatic 

vascular plants because there were an insufficient number of plants per replicate, test concentrations were not analytically 

determined, and replicate data were only provided for frond number.

2 As there is no requirement for testing with a degradate, the study is classified as supplmenetal.

*Values in bold indicate definitive endpoint and/or one which is used in risk quotient calculation.

3. Data Uncertainties and Data Gaps

Fate Studies

835.4100 Aerobic Soil Metabolism (MRID#s 45640111 and #45640112). These two 

studies were found to be supplemental. One of the studies (#45640111) was conducted as 

a preliminary study and many details of the study methods were not reported. In 

addition, the study was terminated after only 90 days. The other study (#45640112) did 

not satisfy the guideline requirement for an aerobic soil biotransformation because the 

extraction methods failed to extract a significant fraction of the identifiable 

[14C]residues, including dinotefuran, from the soil. None of these supplemental studies 

provided any data on the degradation rate of the major transformation products of 

dinotefuran. The combined studies provide sufficient data to determine the rate of 

degradation of dinotefuran, but neither study provides information about the fate of the 

major transformation products of dinotefuran. This study (MRID#45640112) can be 

upgraded if the registrant addresses the characterization of the major degradates at 

various sampling intervals. Otherwise, a new study is required to fully address the data 

requirement.

835.4100 & 835.4300 Anaerobic Aquatic/Soil Metabolism (MRID# 45891616). This 

anaerobic aquatic metabolism study, conducted along with the anaerobic soil metabolism 

study, was found to be supplemental. In this study the test substance was added to 

anaerobic flooded soil rather than being added to soil left under aerobic condition for at 

least 30 days or to its half-life prior to being placed under anaerobic conditions. The 

study does not meet the requirements for an anaerobic aquatic metabolism study because 

the study was terminated after 120 days, which was not sufficient to establish the pattern 

of formation and decline of the major degradate. No additional data are required at this 

time. However, to assess any future aquatic uses for this chemical a new study may be 

needed.

835.4300 Aerobic Aquatic Metabolism (MRID# 45640117). This study provides 

supplemental information about a system that was partially aerobic (water) and partially 

anaerobic (sediment). No additional data are required at this time. However, to assess 

any future aquatic uses for this chemical a new study may be needed.
37

Ecotox Studies

OPPTS 850.1350 Mysid Chronic Toxicity Test

Since estuarine/marine chronic toxicity studies were not submitted for this compound 

there is an uncertainty regarding chronic risk to estuarine/marine fish and invertebrates.

However, given that dinotefuran technical is highly toxic to mysid shrimp (i.e., <1 mg 

a.i./L) on an acute basis (MRID 45639713) and the hydrolysis half-life (MRID 

45640101) of dinotefuran indicates that the parent is stable in water at pH 4-7 and is ~48 

days at pH 9, a mysid chronic toxicity study is required under 40 CFR §158.

Non-Guideline Magnitude of Residues Study: Field Residue Analysis of Edible Parts of 

Trees/Plants (Whole flowers, Leaves, Fruit, Seeds, Pollen, and Nectar [from flowers and, 

if present, extrafloral nectaries])

Submission of a magnitude of residues study that quantifies potential exposure levels 

after tree injection and other application types would be of high value to this risk 

assessment. Risks may be further quantified and refined if a magnitude of residues study 

in treated trees and plants is submitted that evaluates concentrations of dinotefuran in 

edible parts of treated trees and plants, including leaves, fruit, seeds as well as blooming, 

pollen-shedding, and nectar producing parts (i.e., flowers and, if present, extrafloral 

nectaries) of plants. The reason for asking for multiple test species and plant part residues 

stems from open literature data available for imidacloprid, another systemic 

neonicotinoid. The studies reveal that imidacloprid will move into the plant parts at 

different concentrations based on the type of plant (i.e., corn pollen will have different 

concentrations of imidacloprid compared to sunflower pollen) and the part of the plant 

(i.e., pollen will have different concentrations of imidacloprid compared to nectar). In 

addition, given that there is no information on rate of degradation of dinotefuran inside 

the plant, concentrations of degradates of dinotefuran in these plant parts would also be 

of high value to this risk assessment. Therefore, the EFED concludes that information on 

dinotefuran/degradate concentrations, in various plant parts for different crops is essential 

to understanding the potential exposure levels of dinotefuran and degradates to terrestrial 

non-target invertebrates, mammals, and birds over time. A study protocol should be 

submitted for Agency review prior to study initiation. 

OPPTS 850.3040 Field Testing for Pollinators

A new honey bee field study that provides relevant and reliable toxicity information on 

the performance of the colonies after exposure to dinotefuran is recommended. A study 

protocol should be submitted for Agency review prior to study initiation. 

Dinotefuran is highly toxic to bees on an acute oral and contact basis and when applied as 

a foliar spray at a rate of 0.13 lbs a.i./A it will remain toxic to bees on foliage for more 

than 24 hours after application (MRID 45639728). Because of this, EFED recommends 

that dinotefuran not be applied to blooming, pollen-shedding or nectar-producing parts of 

plants; but the test crop should be one on which bees will actively forage for both nectar 

and pollen (e.g., cotton, melon, alfalfa). EFED expects the study design will include 

maximum dinotefuran application rates, at minimum intervals, and maximum number of 

applications. EFED does not know how much dinotefuran can be expected to be 
38

translocated to the nectar and pollen when applied as a foliar, soil, or tree injection 

application to plants before nectar or pollen production. Though the currently reviewed 

field study had detected residues in pollen and nectar of flowers after foliar application, 

the study design was such that toxicity endpoints could not be reliably determined. If 

dinotefuran is being translocated to the nectar and pollen, there is uncertainty as to 

whether there is any adverse effect to foragers or to the hive over time. 

IV. Exposure Estimates

Exposure estimates for the proposed use patterns for Christmas trees, trees in plantations 

including conifers & deciduous trees, reforestation nurseries, forests & wooded areas 

(National, private, & State) are outlined below. Refer to Table 2 for a summary of label 

information. All use/application types/rates except for the tree trunk injection application 

have been addressed in previous risk assessments for other crop sites. The risk 

conclusions for those use patterns can be found in the cited assessments (see below and 

Appendix A). The primary focus of this assessment, therefore, will be on the tree 

injection use pattern.

a. Foliar, Airblast & Broadcast spray application, soil application (i.e., soil 

media drench, chemigation), basal trunk spray application

These particular application types (ground/aerial spray, soil incorporation) and/or 

maximum application rates (0.54 lbs a.i./A) are found in the 2004 risk assessments (DP 

Barcodes: D285633, D304957) with use on ornamental plants, which are listed in the 

current label in conjunction with the proposed forestry uses. However, it is important to 

note that at the time the assessment (D285633, June 30, 2004) was completed, there was 

uncertainty regarding application timing and dosage of residential ornamental uses. As a 

result the assessment focused on outdoor agricultural uses (i.e. leafy vegetables and turf). 

For leafy vegetables, granular soil incorporation, a one-time application of 0.54 lbs a.i./A 

was allowed (note that: leafy vegetables are not listed in the current label for soil 

injection); for foliar sprays up to two applications were allowed with a total maximum of 

0.268 lbs a.i./A/yr, which is consistent with the current label but not applicable for the 

application rates proposed for forestry uses. However, turfgrass applications may be more 

applicable as the single spray application rate was also a seasonal maximum of 0.54 lbs 

a.i./A. The second assessment (D304957, August 9, 2004), among other uses, included 

ornamental plant beds at 0.52 lbs a.i./A; the first assessment was cited for additional 

information. Neither of the two previous assessments addresses basal trunk sprays, but 

for the purpose of this assessment basal trunk sprays are assumed to lead to 

approximately equivalent levels of exposure to other spray applications, given the 

seasonal application maxima are equivalent. Exposure of surface waters to dinotefuran is 

possible through surface water runoff, soil erosion, and off-target spray drift. Due to the 

low adsorption potential of dinotefuran (Koc <45), the exposure to surface and ground 

water is expected to be high.
39

b. Tree Trunk Injection

The amount of chemical injected depends on the size of the treated tree. A 1⁄4-

3

/8” drill bit 

is used to drill two holes into the trunk for each inch of trunk diameter. Holes 3/8- 1⁄2” 

deep are drilled into healthy xylem at a 45odownward angle and spaced evenly at 4-8” 

above the ground. The maximum proposed label rate for trunk injection is 2.0 g/inch of 

trunk diameter at breast height (dbh ~ 4.5 ft above ground), which is equivalent to 400 

mg a.i./inch of dbh (i.e., 2.0g x 0.2 a.i. x 1000 mg/g). The amount of formulation that 

may be applied to various size trees as specified on the proposed label is summarized in 

Table 11.
40

Table 11. Summary of Maximum Application Rates for Various Tree Sizes

Tree Diameter 

(DBH, Inches)

g of product/ treea

(mg a.i./tree applied)b

No. of Injection Sites

(average)

Low High

4 – 6 8

(1600)

12 

(2400)

8-12

(10)

7 – 9 14

(2800)

18

(3600)

14-18

(16)

10 – 12 20

(4000)

24

(4800)

20-24

(22)

13 – 15 26

(5200)

30

(6000)

26-30

(28)

16 – 18 32

(6400)

36

(7200)

32-36

(34)

19 – 21 38

(7600)

42

(8400)

38-42

(40)

22 – 24 44

(8800)

48

(9600)

44-48

(46)

25 – 27 50

(10,000)

54

(10,800)

50-54

(52)

28 – 30 56

(11,200)

60

(12,000)

56-60

(58)

31 – 33 62

(12,400)

66

(13,200)

62-66

(64)

34 – 36 68

(13,600)

72

(14,400)

68-72

(70)

37 – 39 74

(14,800)

78

(15,600)

74-78

(76)

40 – 42 80

(16,000)

84

(16,800)

80-84

(82)

43 – 45 86

(17,200)

90

(18,000)

86-90

(88)

46 – 48 92

(18,400)

96

(19,200)

92-96

(94)

49 – 51 98

(19,600)

102

(20,400)

98-102

(100)

52 – 54 104

(20,800)

108

(21,600)

104-108

(106)

55 – 57 110

(22,000)

114

(22,800)

110-114

(112)

58 – 60 116

(23,200)

120

(24,000)

116-120

(118)

61 – 63 122

(24,400)

126

(25,200)

122-126

(124)

64 – 66 128

(25,600)

132

(26,400)

128-132

(130)

67 – 69 134

(26,800)

138

(27,600)

134-138

(136)

70 – 72 140

(28,000)

144

(28,800)

140-144

(142)

 

a Calculated as dbh * 2 g/inch of dbh

 bCalculated as dbh * 400 mg a.i./inch of dbh
41

i. Conceptual diagram

For the proposed tree injection use, the potential routes of exposure to terrestrial 

organisms is expected to be primarily through consumption of various parts of the tree 

after dinotefuran has been translocated throughout the tree after injection. It is assumed 

that the pesticide may enter foliage, fruit, seeds, and pollen, which can in turn be used as 

food items by other organisms. In addition, secondary exposure may occur for animals 

that consume invertebrates that have been exposed to the chemical. There are no data on 

the rate of translocation or decay of dinotefuran in trees nor has the presence of 

transformation products in trees been evaluated. Degradates of toxicological concern 

have been identified (MNG and DN); however, they have been shown to form via aerobic 

soil metabolism and terrestrial field dissipation (MNG) and anaerobic soil metabolism 

and aerobic aquatic metabolism (DN) –the other four are mostly photolysates- and it is 

unknown whether any of the six may form within a treated tree. MNG contains the nitro 

guanidine structure and therefore is considered to possess similar toxicity as the parent. 

DN is also structurally similar to the parent and therefore considered to share similar 

toxicity as the parent. None of the degradates of dinotefuran are expected to have any 

higher toxicity than the parent (HED Memo of 01/20/04. L. Cheng, D293759). Therefore, 

the focus of this assessment is on the parent with the assumption that it does not degrade 

rapidly in treated trees. However, this assumption may be re-evaluated if a residue study 

in trees is submitted. 

Given the specificity of the tree injection use pattern, the predominant transport 

mechanism consists of translocation/uptake to foliage, fruit, seeds, and pollen in treated 

trees. The transport mechanism (i.e., source) is depicted in the conceptual model below 

(Figure 2) along with the receptors of concern and the potential attribute changes in the 

receptors due to exposures of dinotefuran. The conceptual model also depicts the 

potential for dinotefuran residues in leaves, fruits, and seeds to enter adjacent water 

bodies. 
42

Figure 2. Conceptual Model for Dinotefuran Application via Tree Injection

Stressor

Source

Receptors

Attribute

Change

Dinotefuran applied to use site (tree injection)

Direct 

application

Individual organisms

Reduced survival

Reduced growth

Reduced reproduction

Terrestrial food items (fruit, 

seeds, foliage, and pollen)

Mammals

Exposure

Media

Direct Contact/ 

Ingestion

Ingestion

Ingestion

Ingestion

Translocation/uptake

Terrestrial Birds 

insects

Aquatic 

Animals

Shedding 

leaves
43

ii. Analysis Plan: Measures of Exposure

There is no currently approved model for estimating potential exposure to organisms 

from tree injection methods. Evaluating exposure for this use pattern requires 

information on concentrations of the pesticide in animal food items after the chemical is 

translocated throughout the tree from the application site. This information is not 

available for dinotefuran. Therefore, exposure estimates used in this assessment are 

screening level estimates. Additional data, if available in the future, may allow for a 

refinement of the screening level estimates. The method used to estimate exposure is 

discussed in a couple of recently completed assessments (USEPA, 2010a; USEPA 2010b)

in EFED; the screen is based on the following assumptions: 

(1) Total mass of chemical applied (Terrestrial and Aquatic Assessments)

a. Terrestrial Assessment: The total mass of chemical applied to the tree 

was compared to toxicity values of terrestrial animals; EEC = total mass 

of chemical applied

b. Aquatic Assessment-1: The total mass of chemical applied to a given 

number of trees per acre assumed to enter a 20,000,000 L water body 

directly; EEC = total mass of chemical applied to trees on one acre/ 

20,000,000 L

c. Aquatic Assessment-2: The total mass of chemical applied to the tree was 

assumed to be available for runoff to a nearby water body. The maximum 

application rate was assumed to be 0.54 lbs a.i./A/year. EECs were 

estimated using GENEEC2 (surface water) assuming that 100% of the 

chemical reached the soil.

(2) Tree trunk concentration (Terrestrial Assessment, cont.)

a. Concentrations in the tree trunk were estimated by assuming that the 

chemical was evenly distributed within the tree trunk. Estimates of tree 

mass were based on information published by the University of Arkansas 

Cooperative Extension Service; EEC = total mass of chemical applied / 

mass of stem or trunk of tree. These dietary based EECs were converted 

to a dose-basis by assuming that 20g birds consume 114% and 15g 

herbivorous mammals consume 95% of their body weight daily. These 

assumptions are based on feeding rates provided in the Wildlife Exposure 

Factors Handbook (USEPA 1993) and are consistent with T-REX.

(3) Concentration of chemical in leaves (Terrestrial Assessment, cont.)

a. Leaf concentration was estimated by assuming that 100% of the chemical 

was translocated to the leaves only. Leaf mass was estimated using 

allometric equations developed for blue oak trees presented by the USDA 

Forest Service (Karlik and McKay 2002). EEC = total mass of chemical 

applied / leaf mass on tree. These dietary based EECs were converted to 

a dose-basis by assuming that 20g birds consume 114% and 15g 

herbivorous mammals consume 95% of their body weight daily. These 

assumptions are based on feeding rates provided in the Wildlife Exposure 

Factors Handbook (USEPA 1993) and are consistent with T-REX.
44

Exposure analysis

Given the tree injection use pattern, a major route of exposure to terrestrial organisms is 

expected to occur through uptake and translocation of the chemical to foliage, fruit, 

pollen, and seeds which can be used as food items. However, organisms could also be 

exposed to dinotefuran if it spills from the injection site or as a result of the chemical 

entering the terrestrial or aquatic environment via fallen leaves or other tree parts. 

Biodegradation data suggest that dinotefuran does not biodegrade fast in soils, when it 

does it is expected to degrade to MNG and DN, which are also persistent and expected to 

be of proximate toxicity to the parent.

In order to quantitatively assess exposure, data pertaining to the amount and rate of 

translocation and decay of dinotefuran in trees following application are needed. This 

type of data would facilitate estimation of potential residues in foliage/fruit/pollen which 

can be used as food items for terrestrial organisms. Currently, there are no data on the 

rate of translocation or decay of dinotefuran in trees after injection. Therefore, 

quantitative estimates of exposure are difficult. As a conservative screening approach, 

three exposure approaches were used to estimate exposures that were based on (1) total 

mass of dinotefuran applied to various sizes of trees (terrestrial and aquatic EECs), (2) 

estimated concentration in leaves assuming 100% of the chemical translocates to the 

leaves (terrestrial EECs), and (3) estimated whole tree concentrations (terrestrial EECs).

In order to refine these exposure estimates, data that evaluate uptake, translocation, and 

degradation of dinotefuran in situ are needed. 

1. Estimates based on total mass of dinotefuran applied 

(Terrestrial and Aquatic EECs)

a. Terrestrial EECs

A range of the total mass of dinotefuran that may be applied to trees is summarized in 

Table 12. According to the label the diameter at breast height is measured in inches. A 

1⁄4-

3

/8” drill bit is used to drill two holes into the trunk for each inch of trunk diameter. 

Holes 3/8- 1⁄2” deep are drilled into healthy xylem at a 45odownward angle and spaced 

evenly at 4-8” above the ground. The maximum proposed label rate for trunk injection is 

2.0 g/inch of trunk diameter at breast height (dbh ~ 4.5 ft above ground), which is 

equivalent to 400 mg a.i./inch of dbh (i.e., 2.0g x 0.2 a.i. x 1000 mg/g). Given the two 

injection holes per inch of trunk diameter, a maximum of 1 gram of dinotefuran is 

injected per injection hole. This is equivalent to 0.00044 lbs a.i./injection hole (0.00088 

lbs a.i./inch of dbh). These values were compared with terrestrial animal toxicity values 

to determine if there is a potential for LOC exceedances. 
45

Table 12. Exposure Screen for Dinotefuran for Tree Injection

Tree Size 

diameter at breast 

height (dbh), in

Amount of formulation injected (from proposed label)

in lbs a.i./treecin mg a.i./treed

Small, 4a– 6 in. 0.00352 – 0.00528 1,600 – 2,400

Medium, 12-24 inb0.01056 – 0.02112 4,800 – 9,600

Large, 70 – 72 in. 0.0616 – 0.06336 28,000 – 28,800

a The label indicates that trees less than two inches in diameter should not be injected with 20% 

Dinotefuran. In addition, all trees should not be injected more than once per year.

b Landis representative indicated that the majority of trunk injections will be with trees in this range. 

c Calculated as dbh * 0.00088 lbs a.i./inch of dbh

d Calculated as dbh * 400 mg a.i./inch of dbh

b. Aquatic EECs

i. Direct contamination with tree parts

There is also potential for aquatic systems to be exposed to dinotefuran either directly 

from contaminated tree parts (e.g., leaves, sticks, flowers, pollen) entering the water or 

from tree parts falling onto land and subsequent runoff into aquatic systems. As a screen, 

the total amount of chemical applied to a tree was added to a 20,000,000 liter pond. The 

resulting water concentration would result in a conservative screen, but could be used to 

preclude risks to taxonomic groups if no LOCs are exceeded. The resulting pesticide 

concentrations range from 0.08 g a.i./L to 1.44 g a.i./L (1,600 mg a.i. to 28,800 mg 

a.i./ 20,000,000 L / 0.001 mg * g

-1

= 0.08 g a.i./L to 1.44 g a.i./L) depending on the 

amount of pesticide applied to the tree. 

Table 13. Exposure Screen for Dinotefuran for Tree Injection

Tree Size 

diameter at breast 

height (dbh), in

Concentrations expected in a 20,000,000 L pond

in g a.i./L

Small, 4a– 6 in. 0.08 – 0.12

Medium, 12-24 inb0.24 – 0.48

Large, 70 – 72 in. 1.4 – 1.44

a The label indicates that trees less than two inches in diameter should not be injected with 20% 

Dinotefuran. In addition, all trees should not be injected more than once per year.

b Landis representative indicated that the majority of trunk injections will be with trees in this range. 

ii. Direct application to soil

In addition, aquatic exposures could occur from the chemical entering soil environments 

and subsequently entering aquatic environments. This could occur if the chemical is 

translocated primarily to the leaves, and the leaves fall to the soil and decompose. As an 

initial screen, it was assumed that the total mass of the chemical applied to a tree via 

injection was applied directly to soil. Assuming 1 tree per acre is treated, the applied 

mass was used as an application rate (in lbs a.i./Acre), and GENEEC2 was used to 
46

estimate potential aquatic concentrations in surface water. The application rate resulting 

from 1600 mg a.i. (small tree) to 28,800 mg a.i. (large tree) would be 0.004 lbs a.i./Acre 

to 0.063 lbs a.i./Acre (= 1,600 mg a.i. to 28,800 mg a.i./tree / 453,592 mg/lb x 1 

tree/Acre). The upper end of the range could represent application to one large tree or 

numerous smaller trees per acre. On the other hand the application rate was also 

calculated with the assumption of multiple trees per acre: 10, 100, 1000, and 10,000 trees 

per acre (Table 14). Realistically, the number of trees planted depends on and is limited 

by the desired or observed spacing of trees in the field, tree size or age, and canopy cover. 

For example, for a spacing of trees of 5 x 5 feet the number of trees per acre is 1,742 trees 

estimated by the University of Georgia, School of Forestry (Coder, 1996). The larger the 

density of trees in Table 14 the more applicable the values become to seedlings. 

Table 14. Exposure Screen for Dinotefuran for Tree Injection

Tree Size 

diameter at breast 

height (dbh), in

Assumed application rate to soil in lbs a.i./A

1 tree/ A 10 trees/ A 100 trees/ A 1,000 trees/A 10,000 trees/A

Small, 4a– 6 in. 0.004 - 0.005 0.035 – 0.053 0.353 - 0.529 3.53 – 5.29 35.3 – 52.9

Medium, 12-24 inb0.011- 0.021 0.106 – 0.212 1.06 – 2.12 10.6 – 21.2 106 – 212

Large, 70 – 72 in. 0.062-0.063 0.617 – 0.635 6.17 – 6.35 61.7 – 63.5 617 - 635

a The label indicates that trees less than two inches in diameter should not be injected with 20% Dinotefuran. In addition, all

trees should not be injected more than once per year.

b Landis representative indicated that the majority of trunk injections will be with trees in this range.

c Calculated as mg a.i./tree / 453,592 mg/lb x # of trees/Acre

Example for Context 1 Hemlock-Hardwood forests

According to the USDA Forest Service Risk Assessment (MRID 47814402), [softwood, 

gymnosperm, conifer: cone-bearing] hemlock (Tsuga spp.) will be treated for a nonnative fluid-feeding predatory (on the tree) insect, the hemlock woolly adelgid (Adelges 

tsugae) and [hardwood, angiosperm; flower bearing] ash trees (Fraxinus spp.) for the 

non-native predatory (on the tree) emerald ash borer4(Agrilus planipennis). Silviculture 

guides for hemlock-hardwood type stands (including white pine-hemlock, eastern 

hemlock or Tsuga canadensis, and hemlock-hardwood or hemlock-yellow birch) in 

Wisconsin (DNR, 1990) and the hardwood stands of north-central America (Tubbs 1977) 

indicate that the number of trees per acre varies by stand composition, age, and size-class 

and basal area distribution (Figures 3 and 4, extracted from the DNR 1990 and Tubbs 

1977, respectively). 

 

4 Current label EPA-Reg. No. 86203-11 has excluded emerald ash borer as a pest for which dinotefuran 

could be used in tree injection
47

Figure 3. Hemlock-hardwood stands where B‟ accounts for forest types containing 20-

49% hemlock (softwood) but predominantly hardwood and B accounts for forest types 

having 50-100% hemlock. Stands are more dense (i.e., higher trees/acre) where the ratio 

of hemlock to hardwoods is greater; in other words, hemlocks need less space to grow 

than hardwoods do in comparable or greater numbers as hardwoods. The younger the 

stands (i.e. average dbh) the more dense the forest (i.e., higher trees/acre) and the greater 

the ratio of hemlock to hardwoods for comparable average size class. Therefore, the 

range of trees per acre captured by this diagram can be approximately 40-500 trees/A 

given stand structure, age and size class differences. (DNR 1990; Tubbs 1977)
48

Figure 4. Northern hardwood stand density (by size class) that is desirable for 

continuous growth: 320 trees of varying sizes per acre (Tubbs 1977)

GENEEC – Surface Water

Using the values from Table 14 as application rates and inputting the chemical properties 

for dinotefuran listed in Table 15 results in peak EECs that range from 0.19 g/L to 

34,357 g/L (see Table 16). Raw outputs from the modeling exercise are in Appendix 

D. These EECs are intended as screening level values that can be used to preclude 
49

potential risks to taxonomic groups if toxicity data indicate that effects are not likely to 

occur at these levels. If LOCs are exceeded based on these EECs, then additional 

refinements are needed to better characterize potential risks. 

Table 15. GENEEC2 input parameter values for tree injection

PARAMETER (units) VALUE(S) SOURCE COMMENT

Maximum Application Rate (lb 

a.i./A)

0.54 -- Assumed maximum. Not specified on label.

Number of Applications per 

Year

1 -- Represents most-conservative scenario in which the 

maximum rate is applied once per year.

Organic Carbon Partition 

Coefficient (Koc; mL/g)

31.4 MRID 45640114 Represents the mean of the following values: 42, 45, 42, 6, 

22 mL/g for the parent compound. There is more than 

three-fold variation among values.

Aerobic Soil Metabolism Halflife (days)68 MRID 45640111, 

45640112/46751101, 

46711201

Represents the upper 90th percentile of the following seven 

values: 87.7, 38, 17, 78, 89, 20, 15.9 days. 

Solubility limit (ppm) 39,830 MRID# 45640112 Upper Limit on concentration value

Aerobic aquatic metabolic half 

life (days)

82.73

MRID # 45640117 (s) Upper 90th percentile of study using two radiolabeled 

materials: 79.3 days (total river system); 76 days (total 

pond system)

Photolysis half life (days) 1.8

MRID# 45640105 (s)

Single Available Value

Other GENEEC Assumptions -- -- Pesticide is wetted in; Granular application method; 0 inch 

incorporation depth

1. Parameters are selected as per Guidance for Selecting Input Parameters in Modeling the Environmental Fate and Transport of 

Pesticides; Version II, February 28, 2002.

Given the linear relationship of the peak EEC and maximum application rate in 

GENEEC, taking the ratio of the peak EEC (28.75 g a.i./A) and the assumed maximum 

application rate (0.54 lbs a.i./A) and multiplying by the application rates for given tree 

size and spacing from Table 14 yields expected EECs in surface water for the given tree 

size and spacing classes (Table 16).

Table 16. GENEEC Outputs for Tree Injection

Tree Size 

diameter at breast 

height (dbh), in

Peak EECs in g a.i./L

1 tree/ A 10 trees/ A 100 trees/ A 1,000 trees/A 10,000 trees/A

Small, 4 – 6 in. 0.19-0.28 1.9-2.8 19-28 188-282 1,878-2,817

Medium, 12-24 in 0.56-1.13 5.6-11 56-113 563-1,127 5,634-11,268

Large, 70 – 72 in. 3.29-3.38 33-34 329-338 3,287-3,380 32,865-33,804

With the given conservative assumption that what is intended for tree injection is directly 

applied to soil, these modeling results indicate that dinotefuran may runoff into surface

water. Further, field and laboratory data indicate that when dinotefuran residues reach 

surface water, they may persist particularly in deep water (as it is stable to aerobic and 

anaerobic soil metabolism and hydrolysis; but not to aqueous photolysis) and potentially 

accumulate as a result of continual applications. However, as indicated previously, once 
50

in rivers, ponds, or other bodies of water, the fate of dinotefuran is somewhat uncertain. 

Aqueous photolysis should be important in clear and shallow bodies of water; but in deep 

ponds or rivers or flowing bodies of water, it is more likely to dissipate via dissolution, 

and subsequently via metabolism.

2. Estimates Based on Tree Trunk Concentrations

(Terrestrial EECs)

The tree injection formula of dinotefuran is designed to be distributed throughout the tree, 

but the fate of the chemical within a tree after injection is uncertain. Therefore, potential 

exposures to terrestrial organisms that feed on treated trees were estimated using 

estimated tree trunk concentrations and leaf concentrations. These estimates were used to 

design a screening-level analysis of risk and to determine the value of a magnitude of 

residues study that measures potential exposures to organisms that may feed on treated 

trees. 

Tree trunk concentration estimates assume that the chemical is evenly distributed 

throughout the tree trunk. Submission of a magnitude of residues study would reduce 

uncertainty in these estimates. Pesticide mass applied to trees was obtained from the 

proposed label. Tree weight estimates were obtained from the Cooperative Extension 

Service of the University of Arkansas, and they represent estimates for standing 

hardwood trees. The estimate was based on the merchantable portion of the tree (stem or 

trunk of the tree). The estimate does not include tops, foliage, or limbs and, therefore, 

provides a conservative measure of whole-tree concentration. However, the estimates 

were comparable to the values calculated for above ground biomass for similar size trees 

(esp. 12 in dbh or 30 cm dbh size class) reported by Tritton and Hornbeck (1982, USDA 

Forest Service). Therefore, the estimate was not further refined for this assessment. 
51

The largest tree included in the U. of Arkansas publication was a 36 inch dbh tree. 

Therefore, estimates were only made for this assessment for trees that range from 12 to 

36 dbh (inches). Tree trunk concentrations were compared with toxicity values to 

characterize potential risks to terrestrial organisms by converting the concentrations in 

the trunk to a dose value. Tree trunk pesticide concentration was converted to dose by 

assuming that 20g birds consume 114% and 15g herbivorous mammals consume 95% of 

their body weight daily using the following equation:

Body weight adjusted EEC for residues in tree trunk mg/kg bw

= X mg/kg tree x 1.14 or 0.95 kg tree/kg-bw

Table 17. Range of Tree Trunk Concentration Estimates of Dinotefuran 

DBH (inches) Tree Wt (kg)

Mass of pesticide 

injected in tree (mg

a.i./tree)

a

Pesticide concentration mg a.i./kg

Dietary 

based

mg a.i./kgtree

Dose based mg 

a.i./kg-bw

birds mammals

12 680 4,800 7.06 8.05 6.71

24 3,221 9,600 2.98 3.40 2.83

36 7,448 14,400 1.93 2.20 1.83

a Calculated as dbh * 400 mg a.i./inch of dbh

3. Estimates Based on Leaf Concentrations 

(Terrestrial EECs)

Dinotefuran concentration was also estimated in leaves of treated trees. Estimated leaf 

concentrations resulting from tree injection assume that 100% of the chemical was 

translocated to the leaves and that the chemical was evenly distributed across the leaf 

mass. Submission of a magnitude of residues study would reduce uncertainty in these 

assumptions. 

Pesticide mass applied to trees was obtained from the proposed label (Table 11). 

Estimated leaf mass was based on an allometric equation for oak trees published by the 

USDA Forest Service that relates tree size to estimated leaf mass (Karlik and McKay 

2002): 

Leaf mass (g) = 1.78x2– 12.4x – 108.5 

x = tree circumference at breast height (cm), where

dbh (cm) = tree circumference at breast height (cm)/ 
52

Resulting estimates of leaf concentrations are summarized in Table 18. The resulting 

leaf concentration estimates were compared to toxicity values from terrestrial organisms 

to characterize potential risks by converting the concentrations in leaves to a dose value. 

Pesticide concentration on leaves was converted to dose by assuming that 20g birds 

consume 114% and 15g herbivorous mammals consume 95% of their body weight daily

using the following equation:

Body weight adjusted EEC for residues on leaves mg/kg bw

= X mg/kg leaf x 1.14 or 0.95 kg leaf/kg-bw

Table 18. Range of Estimated Concentrations of Dinotefuran in Leaves 

DBH 

(in.) Leaf mass (kg)

Pesticide mass (mg 

a.i./tree)a

Pesticide concentration mg a.i./kg

Dietary based

mg a.i./kg-leaf

Dose based

mg a.i./kg-bw

birds mammals

4 1.3 1,600 1,224 1,395 1,162

12 15 4,800 320 365 304

24 63 9,600 153 174 145

36 143 14,400 101 115 96

72 580 28,800 50 57 47

a Calculated as dbh * 400 mg a.i./inch of dbh

V. Risk Characterization

Potential risks to terrestrial organisms are described below. The lack of quantifiable 

exposure levels precludes derivation of refined RQs. Submission of a study that 

measures the fate, uptake and translocation (magnitude of residue study) of dinotefuran in 

edible parts of trees (e.g., leaves, fruit, seeds, pollen, nectar) to estimate exposure to 

honey bees, pollinators, and other terrestrial animals is of high value to this assessment. 

Because such a study is currently not available, the risk estimates included in this 

assessment are screening level estimates of risk. In addition, a marine/estuarine chronic 

study and an additional bee field study are needed to allow for refinements of potential 

risks. 
53

a. Foliar, Airblast & Broadcast spray application, soil application (i.e., soil 

media drench, chemigation), basal trunk spray application

These particular application types (ground/aerial spray, soil incorporation) and/or 

maximum application rates (0.54 lbs a.i./A) are found in the 2004 risk assessments (DP 

Barcodes: D285633, D304957) with use on ornamental plants, which are listed in the 

current label in conjunction with the proposed forestry uses. That assessment of June 30, 

2004 (D285633) concluded that the proposed uses of dinotefuran (i.e., leafy vegetables, 

turf, which were also a surrogate for ornamental uses) should not result in acute or 

chronic effects to non-listed or listed terrestrial (e.g., birds and mammals) and aquatic 

species (e.g., fish and aquatic invertebrates). However, a precautionary note was raised 

with regard to the possibility of honey bee concerns and future dinotefuran uses. It was a 

generic precaution at the time reflecting the family of neonicotinoid compounds and their 

potential for risk to honey bees and other beneficial insects. Since the completion of that 

assessment, an interim LOC (0.05) for listed terrestrial invertebrates has been established. 

A risk concern for listed terrestrial invertebrates implies risk to other listed as well as 

non-listed species that rely on them.

Similarly, the assessment of August 9, 2004 (D304957) concluded that the Agency was 

concerned about the protection of pollinators from chemicals in the nonicotinoid class 

(which includes acetamiprid, thiacloprid, dinotefuran, clothianidin, thiamethozam, and 

imidacloprid). The neonicotinoid chemicals are systemic and EFED is concerned about 

the possibility of long term exposure to bees from residues that remain in pollen and 

nectar of flowering crops. In addition, dinotefuran is persistent in the field (average field 

dissipation half-life ~ 46.83 days); higher application rates would cause longer residual 

toxicity time. Again, it was recommended that dinotefuran should not be applied to 

blooming, pollen-shedding or nectar-producing parts of plants. 

b. Tree injection

There is no standard methodology currently used by EFED to evaluate potential 

ecological risks from tree injection of insecticides. However, this screening level risk 

assessment identified potential risks to terrestrial birds (assuming the non-definitive 

endpoint is definitive on account of sublethal effects observed in the study), mammals 

and terrestrial invertebrates that forage on treated trees. Potential risks to birds, 

mammals, and terrestrial invertebrates also presumably exceed levels of concern, and 

potential risks to saltwater invertebrates could not be precluded. 

The proposed application method is tree injection at a rate of approximately 1.0-2.0 g of 

product per inch of trunk diameter at breast height (approximately 1,600 mg to 28,800 

mg a.i./tree, for trees ranging in size from 4 to 72 inches at dbh). The amount of chemical 

applied depends on the size of the tree and no maximum application limit (aside from 

injecting once per year) for this use type is supplied by the label. After dinotefuran (a 

systemic neonicotinoid) is injected into a tree, it is translocated throughout the tree by the 

xylem.
54

Risk estimates were derived that were based on (1) the total mass of dinotefuran applied 

to a tree, (2) estimated concentration of dinotefuran in the tree trunk assuming that the 

pesticide is evenly distributed throughout the tree trunk, and (3) estimated concentrations 

of dinotefuran in leaves assuming 100% translocation of the applied pesticide to the 

leaves. The total mass assumption and translocation to leaves resulted in risk concern for 

birds and mammals, but not the assumption of tree trunk concentrations. All three screens 

result in risk concern for terrestrial invertebrates.

In addition, if dinotefuran is translocated primarily to leaves, then the chemical could 

enter the soil and be available for runoff into aquatic environments when the leaves fall to 

the ground. The amount of chemical that could enter the soil and water is related to the 

number and type of trees that are treated in a given area and the amount of chemical in 

the leaves. Freshwater and saltwater invertebrates and non-vascular plants are likely not 

at risk of effects from direct contamination with tree parts. Freshwater invertebrates and 

non-vascular plants are likely not at risk of effects from exposure in surface and/or 

ground water. However, potential risks to saltwater invertebrates could not be precluded. 

i. Potential Risk to Terrestrial Organisms

Birds and Mammals

There are no definitive acute avian endpoints. However, the acute oral study on Japanese 

quail (MRID 45639720; mean weights: ♂181g; ♀ 204g; average of which, 193g, is used 

in T-REX v. 1.4.1 to derive the adjusted LD50) yielded a NOAEL of 1000 mg a.i./kg-bw 

on account of sublethal effects at the highest test concentration, but an LD50 of >2000 mg 

a.i./kg-bw. Given the assumption that this endpoint is definitive, the adjusted LD50 = 

1,423 mg/kg-bw for a 20g bird, which corresponds to consumption of approximately 28.5 

mg (= 1,423 mg/kg-bw * 0.02 kg) for a 20 g bird. There is a definite endpoint for 

mammals, given by an acute oral study on the rat (MRID 45639823) for the female LD50 

= 2,000 mg/kg-bw. The adjusted LD50 = 4,396 mg/kg-bw for a 15 g mammal, which 

corresponds to consumption of approximately 65.9 mg (= 4396 mg/kg-bw * 0.015kg) for 

a 15 g mammal. Therefore, consumption of 2.85 mg a.i. (for birds) to 6.59 mg a.i. (for 

mammals) or more would result in exceedance of the endangered terrestrial animal 

species level of concern (LOC) of 0.1. Consumption of 14.3 mg a.i. (for birds) to 32.9 

mg a.i. (for mammals) or more would result in exceedance of the acute terrestrial animal 

LOC of 0.5.

Similarly, given the assumption that the acute avian endpoint is definitive, the adjusted 

LD50 = 1423 mg/kg-bw for a 20g bird and the acute mammalian endpoint is the adjusted 

LD50 = 4396 mg/kg-bw for a 15 g mammal, exposure to doses of 142 mg a.i./kg-bw (for 

birds) and 440 mg a.i./kg-bw (for mammals) or more from tree parts would result in 

exceedance of the endangered terrestrial animal species LOC of 0.1. Exposure of 712 mg 

a.i./kg-bw (for birds) and 2,198 mg a.i./kg-bw (for mammals) or more from tree parts 

would result in exceedance of the acute terrestrial animal LOC of 0.5. Body weight 

adjusted EECs for residues in the whole tree do not lead to an LOC exceedance of either 

type for the tree size classes assessed (12-36 in dbh) in either birds or mammals. 

However, body weight adjusted EECs for residues in leaves do lead to endangered 
55

species LOC exceedances in birds for trees approximately between 4 to 36 inch dbh and 

in mammals for trees approximately between 4 to12 inch dbh; leaf residues could 

potentially lead to acute LOC exceedances for birds and mammals in small trees (~4-12 

in dbh). 

The exceedances predicted from single tree exposures are complicated by several factors 

including feeding/foraging behavior of the given organism, visitation of multiple 

contaminated tree parts, and availability of the pesticide residues in edible portions of the 

tree. Although it is not reasonable to expect that a single organism will consume an entire 

tree exposed to dinotefuran, it is possible that repeat visitation of contaminated tree parts 

may lead to chronic effects – for example, the 20-week NOAEC for mallard duck is 

2,150 mg a.i./kg-diet (MRID 45639723); the reproduction NOAEL for the lab rat is 3,000 

mg/kg diet (or 241 mg/kg-bw-day for the lowest value in males; MRID 45639913) which 

adjusts to 530 mg/kg-bw for a 15g mammal; and, the maternal NOAEL for the rabbit is 

52 mg/kg-bw/day (MRID 45654208), which adjusts to 114 mg/kg-bw for a 15g mammal.

Terrestrial Invertebrates

The lowest honey bee acute oral LD50 (0.0076 g a.i./bee; MRID 45639727) based on the 

dinotefuran formulation (MTI-446 20% WG) is reported in the table below, but all acute 

oral (range of 0.0076-0.032 g a.i./bee) and contact (range of 0.024- 0.061 g a.i./bee) 

LD50‟s indicate high sensitivity to dinotefuran, both as technical and formulation. 

According to the USEPA classification system, these values indicate that dinotefuran is 

highly toxic to honey bees. In addition, the interim listed species LOC for terrestrial 

invertebrates is 0.05. To lead to LOC exceedances (given the toxicity value is 0.0594 g

a.i./g of bee, whereby the LD50 is 0.0076 g a.i./bee and one bee weighs approximately 

0.128g), the EEC would have to equal or exceed 0.003 g a.i./g of bee (or ppm).

Three non-guideline studies testing terrestrial invertebrate (non-Apis spp.) mortality and 

reproductive success parameters indicated significant toxic effects as a result of spray 

exposure of dinotefuran formulation (MTI-446 20% SG) to parasitoid wasps (Aphidius 

rhopalosiphi, hymenoptera, MRID 45640121), predaceous bugs (Orius laevigatus, 

hemiptera, MRID 45640122), and predaceous mites (Typhlodromus pyri, acari, the only 

non-insect – i.e., arachnid, tested, MRID 45640120). Effects on mortality (13-day LC50 = 

6.89 x 10-5lbs a.i./A, 21-d LC50 = 1.19 x 10-5lbs a.i./A, and 14-d LC50 = 0.027 lbs a.i./A) 

were observed for the wasp, bug, and mite, respectively. Significant reproductive effects, 

parasitism success in wasps and fecundity (#of eggs produced/female/day) in mites, were 

also observed. These studies suggest that terrestrial invertebrates may be affected at 

application rates that are much lower than the maximum seasonal application rate (0.54 

lbs a.i./A) for the proposed use patterns (spray and soil applications). For example, the 

ratio of application rate to LC50 ranges from 20 – 45,378, which implies that contact with 

the pesticide at current application rates will lead to mortality. 

For tree injection uses, assuming 1 tree is treated per acre, the amount of formulation 

injected would be 2,400 mg a.i. (small tree, 6 in dbh) to 9,600 mg a.i. (medium-sized tree, 

24 in dbh). Assuming that an acre of hemlock-hardwood stands contains 40-500 trees 

(see Figure 3), the application rate would range from 0.85 lbs a.i./Acre (= 9,600 mg 
56

a.i./tree ÷ 453,592 mg/lb x 40 tree/Acre) to 2.65 lbs a.i./Acre (= 2,400 mg a.i./tree ÷

453,592 mg/lb x 500 tree/Acre). Although the exposure route is different (for the studies 

above, exposure is via contact to residues from a spray application; and for tree injection, 

the exposure is the ingestion of plant parts in which dinotefuran has been translocated), 

this calculation indicates that the potential tree injection rates per acre are considerably 

higher than the LC50 values in the terrestrial invertebrate studies (i.e., the ratio of 

application rate to LC50 ranges from 12,287-38,397 for the wasp, 71,140- 222,315 for the 

bug, and 31-98 for the mite). This implies a potential for acute risk to terrestrial 

invertebrates from the tree injection application. These studies have implications for long 

term effects also. In particular, the chronic endpoint available from a 21-day predaceous 

bug study indicated a non-definitive endpoint (NOAEC <1.36 mg a.i./ha = 1.21x 10-6lbs 

a.i./A), which implies that it is not known, at this time, how much lower the application 

would need to be to elicit no response in terrestrial invertebrates.

According to a study (MRID 45639728) assessing effects of dinotefuran (formulation 

MTI-446 20% WG) residues (on alfalfa) on the RT25 (residual time to cause 25% 

mortality) in honey bees, it was determined that dinotefuran applied as a foliar spray at a 

rate of 0.13 lbs a.i./A will remain toxic to bees on foliage for more than 24 hours after 

application (i.e., exposure to 8-hour aged residue leads to RT25 of 4.8 hours; whereas 

exposure to 24-hour aged residue leads to RT25 of 24 hours5). 

Though the bee field study (MRID 48120501) provides highly uncertain information on 

the toxicity of dinotefuran 70 SG (70% a.i.) to bee colonies, it does, however, provide

information regarding the translocation of residues from sprayed cotton plants to bee hive 

colony beeswax, pollen, nectar, and honey. The residue results suggest long-term chronic 

exposure post-bloom (i.e., flower nectar concentrations were up to 0.115 ppm 

approximately 5 days after application and 0.013 ppm approximately 26 days after 

application, which implies presence of dinotefuran in and potential exposure via nectar 

from extrafloral nectaries post-bloom) as well as inside the hive (e.g., dinotefuran 

residues detected, < LOQ: 0.008 ppm in beeswax <LOQ: 0.003 ppm in honey, at least 85 

days after application). As a result, persistent concentrations inside the hive could 

potentially affect overwintering success of the colonies. 

The latter two studies not only have implications for spray applications, but suggest that 

bees could be affected if dinotefuran residues translocate from the tree injection site to 

blooming, pollen-shedding, or nectar producing parts of plants. Submission of a study 

that measures the fate, uptake and translocation (magnitude of residue study) of 

dinotefuran in trees after injection to allow for an estimation of exposure to terrestrial 

invertebrates (and other terrestrial organisms) is of high value to this assessment.

As shown in Table 19, screening level EECs exceeded levels that may result in potential 

risk to terrestrial organisms. 

 

5

 48-hour aged residue leads to RT25 of 90 hours; bees were the least sensitive to treatment when exposed 

to 48 hour aged residue. Bee mortality on 48 hour aged residues did not differ from bees exposed to control 

leaves after 48 hours. 
57

Table 19. Risk Summary for Terrestrial Animals

Screening EEC Toxicity Value Risk Summary

Assumption EEC Birds (20g)c Mammals (15g)dInverts.e

Total 

Mass

4-6 in dbh 1,600-2,400 

mg a.i.

>28.5 

mg a.i.

65.9 

mg a.i.

0.0076 g 

a.i./beeb

Sufficient mass is 

available to 

potentially affect 

birds, mammals, and 

terrestrial 

invertebrates. 

12-24 in dbh 4,800 -9,600 

mg a.i.

70-72 dbh 28,000-28,800 

mg a.i.

Tree 

trunk

conc.

12 -36 in 

dbh

Birds: 2 – 8 mg 

a.i./kg-bwa

Mammals: 2 –

7 mg a.i./kgbwa

Adj. LD50 

>1,423 mg 

a.i./kg-bw

Adj. LD50 4,396 mg 

a.i./kg-bw

0.0076 g 

a.i./bee

Estimated 

concentrations of 

dinotefuran are 

sufficient to result in 

potential risks to 

terrestrial 

invertebrates.

Leaf 

Conc.

4 -72 in dbh Birds: 57 –

1,395 mg 

a.i./kg-bwa

Mammal: 47 –

1,162 mg 

a.i./kg-bwa

Adj. LD50 

>1,423 mg 

a.i./kg-bw

Adj. LD50 4,396 mg 

a.i./kg-bw

0.0076 g 

a.i./bee

Estimated 

concentrations of 

dinotefuran are 

sufficient to result in 

potential risks to 

birds, mammals, and 

invertebrates.

a Pesticide concentrations in whole tree and on leaves were converted to dose by assuming that birds and mammals consume, 

respectively, 114% and 95% of their body weight daily. Estimated pesticide concentration was 1.93-7.06 mg a.i./kg-whole 

tree (for trees ranging in size 12-36 in dbh) and 50-1,224 mg/kg-leaf (for trees ranging in size 4-72 in dbh). 

b This is equivalent to 7.6x10-6 mg a.i./bee

c Japanese quail (Coturnix japonica) MRID 45639720; LD50 of >2000 mg a.i./kg-bw with sublethal effects

d Laboratory rat (Rattus norvegicus) MRID 45639823; the female LD50 = 2,000 mg/kg-bw based on morbidity

e Honey bee (Apis mellifera) MRID 45639727; acute oral study

Terrestrial Plants

The tier I, seedling emergence (MRID 45639729) and vegetative vigor (MRID 

45639730), studies indicated that no endpoints (for 10 plant species tested) were affected 

up to or beyond 25% relative to the controls and that the plants did not show treatment 

related signs of toxicity at the single application rate of 0.54 lbs a.i./A. This application 

rate is a maximum for all proposed non-tree injection uses and the assumed maximum for 

the tree injection use. Risk to terrestrial plants is, therefore, not expected as a result of 

dinotefuran applications at the maximum applications designated on the current label. 

Conclusions

The total mass of dinotefuran applied to treated trees ranges from 1,600 mg a.i. to 28,800 

mg a.i.. Therefore, there is sufficient mass applied to trees to potentially affect birds, 

mammals, and terrestrial invertebrates. For example, the fraction of the mass of 

dinotefuran applied to a tree consumed by a 20-gram bird would need to be < 0.002 

(0.2%) of the total mass applied for a small tree and <0.0001 (0.01%) of the total mass 

applied for a large tree to result in no LOC exceedances for birds. Similarly, the fraction 

of the mass of dinotefuran applied to a tree consumed by a 15-gram mammal would need 
58

to be < 0.004 (0.4%) of the total mass applied for a small tree and <0.0002 (0.02%) of the 

total mass applied for a large tree to result in no LOC exceedances for birds. 

Consideration of dilution within the tree did not reduce potential risks to levels that are 

below concern levels. Estimated leaf concentrations were sufficient to result in risk 

concerns for organisms that may eat leaves of treated trees. This evaluation assumed that 

100% of the injected chemical was translocated to the leaves. However, even 

translocation of a relatively small fraction of dinotefuran to the leaves could result in 

potential effects to terrestrial organisms (particularly, the invertebrates). Estimates of 

whole-tree pesticide concentrations assuming that the chemical is evenly distributed 

throughout the above ground biomass were also above levels that may be of concern to 

non-target terrestrial invertebrates. Therefore, the available data suggest that potential 

risks as a result of tree injection to non-target terrestrial organisms are of concern. 

Submission of a magnitude of residues study that quantifies potential exposure levels 

after tree injection would be of high value to this risk assessment. Risks may be further 

quantified and refined if a magnitude of residues study in treated trees is submitted that 

evaluates concentrations of dinotefuran in edible parts of treated trees, including leaves,

fruit, seeds as well as blooming, pollen-shedding, and nectar producing parts of plants.

The above analysis only considered potential acute effects. However, there is also 

potential for repeated or prolonged exposures to terrestrial animals because dinotefuran is 

not expected to rapidly dissipate from trees after it is injected and translocated. 

Therefore, there is also potential risk to reproduction and/or growth endpoints from the 

proposed tree injection use. 

ii. Potential Risk to Aquatic Organisms

There is also potential for aquatic systems to be exposed to dinotefuran either directly 

from contaminated tree parts (e.g., leaves, sticks, flowers, pollen) entering the water or 

from tree parts falling onto land and subsequent runoff into aquatic systems. As a screen, 

the total amount of chemical applied to a tree was added to a 20,000,000 liter pond. In 

addition, aquatic exposures could occur from the chemical entering soil environments and 

subsequently entering aquatic environments. The resulting water concentration would 

result in a conservative screen, but could be used to preclude risks to taxonomic groups if 

no LOCs are exceeded. EECs and toxicity values are summarized in Table 20. 

The most sensitive aquatic organisms were chosen for the aquatic risk characterization. 

Given the comparison of endpoints and EECs (Table 20) calculated as a result of direct 

contamination with tree parts in a 20,000,000 L pond (i.e., the application is to a single 

tree of a given size that is diluted in the pond), it is not likely that aquatic organisms 

(freshwater/saltwater invertebrates and non-vascular plants) will be at risk. In addition, 

on an acute basis, the freshwater fish (trout, MRID 45639714; bluegill, MRID 45639715; 

carp, MRID 45639716) and saltwater fish (sheepshead minnow, MRID 45639717) 

showed no effects as a result of exposure to dinotefuran (technical MTI-446) at the limit 

concentrations tested. Similarly, on an acute basis freshwater invertebrate (waterflea, 

MRID 45639709) and saltwater invertebrate (eastern oyster, MRID 45639711) showed 
59

no effects as a result of exposure to dinotefuran (technical MTI-446). On a chronic basis, 

the freshwater fish (trout, MRID 45639719) and freshwater invertebrate (wateflea, MRID 

45639718) showed no effects as a result of exposure to dinotefuran (technical MTI-446). 

However, the freshwater invertebrate, waterflea, study (MRID 45639710) indicated 

effects on mobility as a result of exposure to 110.6 mg a.i./L DN-phosphate, a metabolite 

of dinotefuran, which led to a definitive NOAEC of 10 mg a.i./L; similarly, the nonvascular plant, green algae, study (MRID 45639732) indicated effects on cell density as a 

result of exposure to 50 and 100 mg a.i./L dinotefuran (technical MTI-446), which led to 

a definitive NOAEC of 25 mg a.i./L. Assuming the metabolite and parent compound are 

present in equivalent concentrations a comparison of the NOAECs to the EECs indicates 

that concentrations to cause sublethal effects could be achieved through exposure in 

surface water if an application rate equivalent to that used for 10,000 trees/A (of 12-72 in 

dbh) were to leach into the soil. 

The most sensitive aquatic organism is the saltwater invertebrate, mysid shrimp. The 

study (MRID 45639713) indicated an LC50 of 0.79 mg a.i./L and a classification of 

dinotefuran (technical MTI-446) being highly toxic to the saltwater invertebrate. 

Exposure to 39.5 g a.i./L or more would result in exceedance of the endangered aquatic 

animal species level of concern (LOC) of 0.05. This could be achieved through exposure 

in surface water if an application rate equivalent to that used for 100-10,000 trees/A (of 

4-72 in dbh) were to leach into the soil. On the other hand, exposure to 395 g a.i./L or

more would result in exceedance of the acute aquatic animal species level of concern 

(LOC) of 0.5. This could be achieved through exposure in surface water if an application 

rate equivalent to that used for 1,000- 10,000 trees/A (of 4-72 in dbh) were to leach into 

the soil. This analysis indicates that potential risks to marine invertebrates cannot be 

precluded on an acute basis. Submission of a marine/estuarine chronic study and a

magnitude of residues study previously described would be of high value to this 

assessment and may allow for further refinement of the EECs included in Table 20. 
60

Table 20. Risk Summary for Aquatic Animals

Screening EEC Toxicity Value ( g a.i./L) Risk Summary

Assumption EEC1FW 

Invert2

SW 

Invert3

Non-vasc. 

Plant4

Direct 

Deposition/ 

Contamination 

with tree parts

4-6 in dbh 0.08 – 0.12

g a.i./L

LC50

>1.1 x 105

NOAEC: 

10,000

LC50

790

NOAEC:

490

EC50

>9.8 x104

NOAEC:

25,000

Risk to freshwater and 

saltwater invertebrates as 

well as non-vascular 

plants is assumed to be 

low from direct 

contamination with tree 

parts.

12-24 in dbh 0.24 – 0.48

g a.i./L

70-72 in dbh

1.4 – 1.44

g a.i./L

Runoff from 

Soil

(surface water)

GENEEC2

4-6 in dbh 0.19 – 2,817

g a.i./L

Risk to freshwater 

invertebrates and nonvascular plants is assumed 

to be low based solely on 

the available toxicity data 

and estimated exposures 

from surface water. 

However, potential risks 

to saltwater invertebrates 

could not be precluded. 

12-24 in dbh 0.56-11,268

g a.i./L

70-72 in dbh 3.29-33,804

g a.i./L

1 EECs from the runoff from soil (in surface water) include tree spacings of 1 tree/A to 10,000 trees/A

2 Waterflea (Daphnia magna) MRID 45639710; the study was conducted with DN-phosphate, a metabolite of dinotefuran

3 Mysid shrimp (Americamysis bahia) MRID 45639713

4 Green algae (Pseudokirchneriella subcapitata) MRID 45639732

VI. Summary

This analysis suggests that translocation of dinotefuran from the site of injection to edible 

portions of a tree may result in effects to birds, mammals, and terrestrial invertebrates. 

Potential risks to saltwater invertebrates could not be precluded given the sensitivity of 

the mysid shrimp to relatively low concentrations of dinotefuran. Additional data, 

including a magnitude of residues study in treated plants, a marine/estuarine chronic 

study, and an additional bee field study are needed to allow for refinements of potential 

risks. 
61

Uncertainties

There is currently no standard methodology for evaluating potential ecological risks from 

application of pesticides via tree injection. This assessment was based on conservative 

estimates of exposure, and a primary uncertainty in this assessment is that the screening 

level exposure estimates cannot be refined based on the currently available data. In 

addition, as there is no limit indicated on the label on the maximum number of trees 

injected per acre, conservative estimates up to 10,000 trees per acre were used to 

calculate exposure. This is an uncertainty as we do not know the maximum number of 

trees injected per acre of any given crop type. Screening level exposure values were used 

in this assessment that identified potential risks to non-target terrestrial and aquatic 

animals. However, these screening-level values were likely conservative, and submission 

of a magnitude of residues study that evaluates pesticide concentrations in various parts 

of the tree that may serve as food for birds, mammals, and invertebrates is necessary to 

allow for refinements of potential risks. This type of study requires submission of a 

formal protocol by the registrant. 

The fate of the pesticide within the tree is also largely unknown. It was assumed that 

dinotefuran may leach from leaves or other parts of a tree after they have fallen to the 

ground. However, the fate of the chemical within the tree remains unknown. Also, 

degradates of toxicological concern were observed to form via aqueous photolysis. It is 

not known if degradates of concern form within a treated tree, and if they do form, to 

what extent non-target organisms may be exposed. 

Estimates of exposure included estimations of pesticide concentrations in leaves and in 

the tree trunk. Estimated pesticide concentrations in leaves were determined by assuming 

that 100% of the chemical is translocated to leaves. Leaf mass was estimated using the 

following allometric equation developed for blue oak trees presented by the USDA Forest 

Service (Karlik and McKay 2002):

Leaf mass (g) = 1.78x2– 12.4x – 108.5 

x = tree circumference at breast height (cm)

The regression was developed based on a study of 14 blue oak trees harvested in the 

Sierra Nevada foothills with an r2 value of 0.98. The extent to which the equation 

estimates leaf mass for other types of trees or for blue oak trees in other locations has not 

been evaluated for this assessment. 

Estimates of pesticide concentration in the tree trunk assumed that the chemical was 

evenly distributed within the tree and required an estimate of tree mass. Estimates of tree 

mass were based on information published by the University of Arkansas Cooperative 

Extension Service and included only the merchantable portion of the tree (stem or trunk 

of the tree). The estimate did not include tops, foliage, or limbs and it, therefore, 

provides a conservative measure of whole-tree concentration. However, the estimates 

were comparable to the values calculated for above ground biomass for similar size trees 

(esp. 12 in dbh or 30 cm dbh size class) reported by Tritton and Hornbeck (1982, USDA 
62

Forest Service). Therefore, the estimate was not further refined for this assessment. 

However, use of a tree trunk concentration may not be conservative because the estimate 

assumes that the pesticide is evenly distributed throughout the tree trunk, which could 

lead to an underestimation of exposure and risk if the chemical concentrates in an edible 

portion of the tree. It is also possible that when a tree is not growing rapidly that the 

pesticide within it may not be diluted via the generated biomass.

Aquatic exposure estimates assumed either that 100% of the chemical entered the soil 

and was available for runoff or that 100% of the chemical entered a water body directly. 

These are conservative estimates of exposure to aquatic organisms. Submission of a 

magnitude or residues study previously discussed may allow for refinement of potential 

aquatic exposures. Also, leaves and some other tree parts that enter the water could 

ultimately end up in the sediment. Exposure estimates for sediment organisms were not 

included in this assessment.

REFERENCES

Coder, K.D. 1996. Number of Trees per Acre by Spacing. December 1996. Warnell 

School of Forestry. Available at: 

http://warnell.forestry.uga.edu/service/library/for96-054/index.html (accessed 

March 7, 2011).

DNR, 1990. Silviculture Handbook. Wisconsin Department of Natural Resources. 

2431.5, Ch. 39; Dec. 5, 1990 

http://dnr.wi.gov/forestry/publications/Handbooks/24315/24315.pdf

Durkin. P.R. 2009. Administrative Materials: Dinotefuran Human Health and Ecological 

Risk Assessment. Vol 5. USDA Forest Service, Southern Region. Contract No. 

AG-3187-C-06-0010. Submitted by Mitsui Chemicals, Inc. c/o Landis 

International, Inc. April 24, 2009. MRID 47814402.

Hummel, Robert L. Evaluation of Toxicity of Residues of MTI-446 on Alfalfa to Honey 

Bees (Apis mellifera). Unpublished study submitted by Landis International, Inc. 

P.O. Box 5126 3185 Madison Highway Valdosta, GA, and sponsored by Mitsui 

Chemicals, Inc., Chiyoda-ku, Tokio. February 17, 2001. DP Barcode 283465.

MRID 45639728. 

Karlik, J.F. and A.H. McKay. 2002. Leaf area index, leaf mass density, and allometri 

relationships derived from harvest of blue oaks in California oak Savanna. USDA 

Forest Service Gen. Tech. Rep. PSW-GTR-184.2002. 

http://www.fs.fed.us/psw/publications/documents/psw_gtr184/061_Karlik.pdf

Suchail, S., D. Guez, and L.P. Belzunces. 2001. Discrepancy between acute and chronic 

toxicity induced by imidaloprid and its metabolites in Apis mellifera. 

Environmental Toxicology and Chemistry. 20 (11): 2482 – 2486.
63

Tubbs, C.H. 1977., Manager‟s handbook for northern hardwoods in the north central 

states. USDA –Forest Service, North Central For. Exp. Sta.: St. Paul, MN. 

General Technical Report NC-39 http://nrs.fs.fed.us/pubs/gtr/gtr_nc039.pdf

Tritton L.M. and J. W. Hornbeck. 1982. Biomass Equations for Major Tree Species of 

the Northeast. USDA - Forest Service, Northeastern Forest Experiment 

Station.General Technical Report NE-69. 

http://www.fs.fed.us/ne/newtown_square/publications/technical_reports/pdfs/scan

ned/gtr69.pdf

University of Arkansas Division of Agriculture (David W. Patterson). Undated. 

Landowner‟s guide to determining weight of standing hardwood trees. University 

of Arkansas Division of Agriculture, Cooperative Extension Service. FSA 5021-

PD-5-08N. http://www.uaex.edu/Other_Areas/publications/PDF/FSA-5021.pdf

USEPA 1993. Wildlife Exposure Factors Handbook. Volume I of II. EPA/600/R93/187a. Office of Research and Development, Washington, DC 20460.

US EPA. 2004. Revised Section 3 Environmental Risk Assessment for the Registration of 

Dinotefuran on Leafy Vegetable, Turfgrasses, Ornamentals and Residential Use. 

OPP/EFED, Washington, DC. June 30, 2004. (DP Barcode D285633).

US EPA. 2004. FIFRA Section 3, Environmental Risk Assessment for the New Use 

Registration of Dinotefuran on Cotton, Potato, Head and stem Brassica, Fruiting 

Vegetables, Cucurbits, Grapes, Ornamental Plants and Flower Beds, Lawn, 

Shrubs and Additional Residential Uses. OPP/EFED, Washington, DC. August 9, 

2004. (DP Barcode: D304957).

USEPA 2006. Environmental Fate and Effects Division‟s (EFED‟s) Response to 

Dinotefuran Ecological Concerns Dealing with Upgrading a Chronic Freshwater 

Fish Study, the Acceptability of an Acute Study Using Japanese Quail as the Test 

Species, and the Registrants‟ Request for a Meeting to Discuss a Honey Bee Field 

Study. OPP/EFED, Washington, DC. Agency. October 20, 2006. (DP Barcodes 

D331699 & D316645). 

US EPA. 2006. FIFRA Section 3, Environmental Risk Assessment for Increasing the Use 

Rates for the Registration of Dinotefuran on Head and Stem Brassica, Cucurbits, 

Fruiting Vegetables, Grapes, Leafy Vegetables, and Potatoes. OPP/EFED, 

Washington, DC. October 16, 2006. (DP Barcode: D324854)

USEPA. 2006. Section 18 Request for Use of Dinotefuran in Texas on Leafy Brassica to 

Control Whitefly. OPP/EFED, Washington, DC. October 31, 2006. (DP Barcode 

332829).
64

USEPA. 2008. Section 18 Request for Use of Dinotefuran in Texas on Rice to Control 

Rice Stink Bug. OPP/EFED, Washington, DC. October 28, 2008. (DP Barcode 

D355010)

USEPA. 2009. Guidance for Selecting Input Parameters in Modeling the Environmental 

Fate and Transport of Pesticides, Version 2.1. OPP/EFED, Washington, DC.

Available at 

http://www.epa.gov/oppefed1/models/water/input_parameter_guidance.htm

(Accessed November 12, 2010).

USEPA, 2010a. Ecological Risk Assessment for the Proposed Section 24C New Use of 

Triisopropanolamine Salt of Aminopyralid for Control of Herbaceous Broadleaf 

Weeds and Woody Plants in Forests, Non-cropland, Grazed areas, and Industrial 

Non-crop Areas in Arkansas. OPP/EFED, Washington, DC. December 7, 2010.

(DP Barcode 383620). 

USEPA. 2010b. Section 3 Product Registration For Expansion of Tree Species for 

Emammectin Boenzoate Tree Injection Use to Control Arthropod Pests.

OPP/EFED, Washington, DC. October 5, 2010. (DP Barcode 381025). 
65

Appendix A. Current and Proposed Application Rates and Use Patterns

Table A1. Current and Proposed Application Rates for Dinotefuran (data obtained from current and 

proposed labels for DINOTEFURAN 20SG (EPA Reg. No. 33657-17), STARKLE 70SG (EPA Reg. No. 33657-

38), DINOTEFURAN 70SG (EPA Reg. No. 59639-135) and DINOTEFURAN 20% (EPA Reg. No. 33657-16; 

and the new label with altered EPA Reg. No. 86203-11). The new use appears shaded.

Crop

Maximum 

application 

rate per 

application (lb 

a.i./A)

Maximum 

seasonal 

application 

rate (lb 

a.i./A)

Foliar or Soil application 

allowed?

Ground or 

Aerial allowed 

for foliar 

applications?

Year Assessed 

DP Barcode

Forests: Christmas 

trees*, trees in 

plantations (conifers, 

deciduous trees), 

reforestation 

nurseries*, forests 

and wooded areas 

(national, private, and 

state)

Ornamental trees 

(new for tree injection 

only)

*Not included in tree 

injection use

Foliar

0.2 (≤1 apps. @ 

max app. , but if 

necessary, make 

a second 

application after 

14-21 days)

Or

Soil

Varies with use 

type (soil 

drench, 

chemigation)

Or

Basal trunk 

spray

12-24 oz/gallon 

for all but 

Christmas trees: 

1.5-6.0 

oz/gallon

Or

Trunk injection

2.0 g/inch of 

trunk diameter 

at breast height 

(dbh) (0.00044 

lb a.i./injection 

hole)

0.54*

*Assumed for 

tree injection 

use, but is 

specified as 

such for all 

other uses

F or Broadcast spray

Or

Tree injection

Maximum rate is 2 g 

EUP/inch at dbh; 2 

injection holes proposed 

for each inch of trunk 

diameter, which leads to a 

maximum of 1 g EUP per 

injection hole which is 

equivalent to 0.00044 lb 

a.i./injection hole. Under 

ideal conditions, an 

applicator can make 600 

trunk injections/day. 

Range of dbh is 12-24” but 

a rare maximum dbh is 

expected to be 60” Trees 

less than 2 inches dbh 

should not be injected

G Present RA

Ornamental plants in 

greenhouses, nurseries, 

interior plantscapes, 

lath and shadehouses 

and outdoor landscapes 

(commercial, 

industrial, recreational 

and residential) or 

Ornamental 

containerized or in 

ground plants 

(including Shrubs, 

Bedding Plants, 

Flowering Plants, 

Foliage Plants, Ground 

Foliar

0.2 (≤1 apps. @ 

max app., but if 

necessary, make 

a second 

application after 

14-21 days)

Or

Soil

Varies with use 

type

Or

Basal trunk 

0.54 F w. airblast (for trees and 

vines) or Broadcast spray, S

Do not make more than one 

soil application per crop 

cycle or three months, 

whichever is shorter.

G 2004,

D285633; 

2004, 

D304957
66

Table A1. Current and Proposed Application Rates for Dinotefuran (data obtained from current and 

proposed labels for DINOTEFURAN 20SG (EPA Reg. No. 33657-17), STARKLE 70SG (EPA Reg. No. 33657-

38), DINOTEFURAN 70SG (EPA Reg. No. 59639-135) and DINOTEFURAN 20% (EPA Reg. No. 33657-16; 

and the new label with altered EPA Reg. No. 86203-11). The new use appears shaded.

Crop

Maximum 

application 

rate per 

application (lb 

a.i./A)

Maximum 

seasonal 

application 

rate (lb 

a.i./A)

Foliar or Soil application 

allowed?

Ground or 

Aerial allowed 

for foliar 

applications?

Year Assessed 

DP Barcode

Covers, Evergreens, 

Ornamental Plants and 

Trees, Non-Bearing 

Fruit Trees, NonBearing Nut Trees and 

Non-Bearing Vines)

spray

12-24 oz/ gallon

Leafy Brassica 

Greens: Broccoli 

Raab, Chinese 

Cabbage (Bok Choy), 

Collards, Kale, 

Mizuna, Mustard 

Greens, Mustard 

Spinach, Rape 

Greens, Turnip 

Greens

0.134 @ 7 days 

interval1

0.268 F

No more than 3 

applications per season are 

allowed.

G, A 2006, 

D332829; 

2009 (IR-4 

Petition),

D358860

Cotton 0.134 @ 7 days 

interval (≤2 

apps. @ max 

app.)

0.268 F G, A 2004, 

D304957

Head and Stem 

Brassica: Broccoli, 

Brussels sprouts, 

Cabbage, Cauliflower, 

Cavalo Broccolo, 

Chinese broccoli, 

Chinese cabbage, 

Chinese mustard 

cabbage, Kohlrabi

Foliar: 0.179 @ 

7 days interval

(≤2 apps. @ 

max app.)

Or

Soil: 0.33 @7 

days interval 

(≤2 apps. @ 

max app.)

0.33 Foliar

Or 

0.536 Soil

F, S

Do not combine foliar app. 

with soil applications, or 

vice versa.

G, A 2004, 

D304957

Cucurbits: Balsam pear 

(bitter melon), 

Calabaza, Chayote 

(fruit), Chinese okra, 

Chinese waxgourd, 

Citron melon, 

Cucumber, Gherkin, 

Gourds, Edible melons 

including hybrids 

(including cantaloupe, 

casaba, Chinese 

preserving melon, 

Crenshaw, honeydew 

melons, honey balls, 

mango melon, 

muskmelon, Persian 

melon, winter melon), 

Pumpkin, Squash 

(including summer, 

winter acorn, 

spaghetti), Watermelon 

Foliar: 0.179 @ 

7 days interval

(≤2 apps. @ 

max app.)

Or

Soil: 0.33 @ 7 

days interval 

(≤2 apps. @ 

max app.)

0.33 Foliar

Or 

0.536 Soil

F, S

Do not combine foliar app. 

with soil applications, or 

vice versa.

G, A 2004, 

D304957
67

Table A1. Current and Proposed Application Rates for Dinotefuran (data obtained from current and 

proposed labels for DINOTEFURAN 20SG (EPA Reg. No. 33657-17), STARKLE 70SG (EPA Reg. No. 33657-

38), DINOTEFURAN 70SG (EPA Reg. No. 59639-135) and DINOTEFURAN 20% (EPA Reg. No. 33657-16; 

and the new label with altered EPA Reg. No. 86203-11). The new use appears shaded.

Crop

Maximum 

application 

rate per 

application (lb 

a.i./A)

Maximum 

seasonal 

application 

rate (lb 

a.i./A)

Foliar or Soil application 

allowed?

Ground or 

Aerial allowed 

for foliar 

applications?

Year Assessed 

DP Barcode

including hybrids

Fruiting Vegetables: 

Eggplant, Ground 

Cherry, Pepinos, 

Pepper (including bell 

peppers, chili peppers, 

cooking peppers, 

pimentos and sweet 

peppers), Tomatillo, 

Tomato (do not apply 

to varieties of tomatoes 

which are less than 2 

inches in size, such as 

cherry and grape 

tomatoes)

Foliar: 0.179 @ 

7 days interval

(≤2 apps. @ 

max app.)

Or 

Soil: 0.33 @7 

days interval 

(≤2 apps. @ 

max app.)

0.268 Foliar

Or 

0.536 Soil

F, S

Do not combine foliar app. 

with soil applications, or 

vice versa.

G, A 2004, 

D304957

Grapes Foliar: 0.132 @ 

14 days interval

(≤2 apps. @ 

max app.)

Or

Soil: 0.33 (≤1 

apps. @ max 

app.)

0.264 Foliar

Or

0.33 

Ground

0.528 

overall per 

season2

F, S

Make only one soil 

application.

G w. airblast, A 2004, 

D304957

Leafy Vegetables 

(Except Brassica 

Vegetables): includes: 

Amaranth, Arugula, 

Cardoon, Celery, 

Chinese Celery, 

Celtuce, chervil, 

Edible-leaved & 

Garland 

Chrysanthemum, Corn 

Salad, Garden & 

Upland Cress, 

Dandelion, Dock, 

Endive, Florence 

Fennel, Head & Leaf 

Lettuce, Orach, 

Parsley, Garden & 

Winter Purslane, 

Radichio, Rhubarb, 

Spinach, New Zealand 

& Vine Spinach, Swiss 

Chard

Foliar: 0.134 @ 

7 days interval

(≤2 apps. @ 

max app.)

Or 

Soil: 0.33 @7 

days interval 

(≤2 apps. @ 

max app.)

0.268 Foliar

Or 

0.536 Soil

F, S

Do not combine foliar app. 

with soil applications, or 

vice versa.

G, A 2004,

D285633;

2006,

D324854

Potato Foliar: 0.176 @ 

14 days interval

(≤2 apps. @ 

max app.)

0.198 Foliar

(given 

modeled 

max single 

app. rate of 

F, S

Do not combine foliar app. 

with soil applications, or 

vice versa.

G w. airblast, A 2004, 

D304957; 

2006, 

D324854
68

Table A1. Current and Proposed Application Rates for Dinotefuran (data obtained from current and 

proposed labels for DINOTEFURAN 20SG (EPA Reg. No. 33657-17), STARKLE 70SG (EPA Reg. No. 33657-

38), DINOTEFURAN 70SG (EPA Reg. No. 59639-135) and DINOTEFURAN 20% (EPA Reg. No. 33657-16; 

and the new label with altered EPA Reg. No. 86203-11). The new use appears shaded.

Crop

Maximum 

application 

rate per 

application (lb 

a.i./A)

Maximum 

seasonal 

application 

rate (lb 

a.i./A)

Foliar or Soil application 

allowed?

Ground or 

Aerial allowed 

for foliar 

applications?

Year Assessed 

DP Barcode

Or 

Soil: 0.33 (≤1 

apps. @ max 

app.)

0.099 lbs 

a.i./A)

Or 

0.33 Soil

Turfgrass (commercial, 

residential, 

recreational)

Foliar

0.54

0.54 F G 2004,

D285633

Leafy Brassica 

Greens: Broccoli 

Raab, Chinese 

Cabbage (Bok Choy), 

Collards, Kale, 

Mizuna, Mustard 

Greens, Mustard 

Spinach, Rape 

Greens, Turnip 

Greens

Foliar

0.134 @ 7 days 

interval1

Or

Soil

0.179 @ 7 days 

interval

0.268

Or

0.536

F

No more than 3 

applications per season are 

allowed.

G, A 2006 (Section 

18)3,D332829

Rice 0.131 0.262 N/A A 2008 (Section 

18)4, D355010

1A typographical error was noted in the label for Dinotefuran 20SG, which shows a maximum individual application 

rate of 0.141 lb a.i./A for leafy brassica greens.

2

For risk assessment purposes, EFED had assumed 2 foliar applications are made at the maximum application rate 

(0.132 lbs a.i./A) and 1 soil treatment at 0.264 lbs a.i./A. The label states that the maximum seasonal combined foliar 

and soil seasonal application rate cannot exceed 0.528 lbs a.i./A.

3

 Label name: VENOM 20SG INSECTICIDE (20% a.i. as soluble granule); Section 18: Emergency Exemption request from 

Texas Department of Agriculture

4 Label name: TENCHU 20 SG INSECTICIDE (20% a.i. as soluble granule); Section 18: Emergency Exemption request from 

Texas Department of Agriculture
69

Appendix B. Nomenclature and structures of dinotefuran and its transformation products

Table B2-1. Nomenclature

Applicant's Code IUPAC Chemical CAS Name CAS No.

Dinotefuran/MTI-446 (RS)-1-methyl-2-nitro-3-(tetrahydro-3-furylmethyl) 

guanidine

N-methyl-N‟-nitro-N”-[(tertrahydro-3-furanyl) methyl] 

guanidine.

165252-70-0

(PC Code 

044312)

DN-Phosphate 1-Methyl-3-(tetrahydro-3-furylmethyl) guanidinium 

dihydrogen phosphate

NA NA

MNG 1-Methyl-2-nitroguanidine N-methyl-N‟-nitro-guanidine 4245-76-5

UF 1-methyl-3-(tetrahydro-3-furylmethyl)urea NA NA

DN-2-OH + DN-3-OH Bis[1-(3-hydroxytetrahydro-3-furylmethyl)-3-

methylguanidinium] terephthalate

NA NA

Mg-HCl 1-methylguanidinium chloride NA NA

BCDN succinate 3-(methylamino)-9-oxa-2-aza-4-

azoniabicyclo[4.3.0]non-3-ene hydrogen succinate

NA NA

Table B2-2. Nomenclature and structures of dinotefuran and its transformation products

(extracted from Section 18 of October 28, 2008 DP Barcode D355010)

Dinotefuran [MTI-446] – Parent Compound

IUPAC Name: (EZ)-(RS)-1-Methyl-2-nitro-3-(tetrahydro-3-furylmethyl)guanidine.

CAS Name: N-Methyl-N′-nitro-N′′-[(tetrahydro-3-furanyl)methyl]guanidine.

CAS Number: 165252-70-0.

SMILES String: CNC(=NN(=O)=O)NCC1COCC1 (ISIS v2.3/Universal SMILES).

No EPI Suite, v3.12 SMILES String found as of 9/29/06.

O

C

H2

N

H

C

N

N

H

NO2

CH3

1-Methyl-2-nitroguanidine [N-Methyl-N’-nitro-guanidine; MNG]

IUPAC Name: 1-Methyl-2-nitroguanidine.

CAS Name: N-methyl-N‟-nitro-guanidine.

CAS Number: 4245-76-5.

SMILES String: NC(=NN(=O)=O)NC (ISIS v2.3/Universal SMILES).

N(=O)(=O)NC(=N)NC EPI Suite, v3.12 SMILES String found as of 07/02/08.

N

H

H2N

N

CH3

NO2

4245-76-5
70

Nitroguanidine [NG]

IUPAC Name: Nitroguanidine.

CAS Name: Not reported.

CAS Number: Not reported.

H2N NH2

N

NO2

1-Methyl-3-(tetrahydro-3-furylmethyl)urea [UF]

IUPAC Name: 1-Methyl-3-(tetrahydro-3-furylmethyl)urea.

CAS Name: Not reported.

CAS Number: Not reported.

O N

H

O

N

H

CH3

1-Methyl-3-(tetrahydro-3-furylmethyl)guanidinium dihydrogen phosphate [DN phosphate] (a salt of DN)

IUPAC Name: Not reported.

CAS Name: Not reported.

CAS Number: Not reported.

O N

H

NH

N

H

CH3

H3PO4

3-(Methylamino)-9-oxa-2-aza-4-azoniabicyclo[4.3.0]non-3-ene hydrogen succinate [BCDN Succinate]

IUPAC Name: 3-(Methylamino)-9-oxa-2-aza-4-azoniabicyclo[4.3.0]non-3-ene hydrogen succinate.

CAS Name: Not reported.

CAS Number: Not reported.

HN N

O

HN

CH3

COOH

COOH
71

1-Methylguanidinium chloride [MG Hydrogen chloride]

IUPAC Name: 1-Methylguanidinium chloride.

CAS Name: Not reported.

CAS Number: Not reported.

NH

N

H

H2N

CH3

ClH

Guanidine [G]

IUPAC Name: Guanidine.

CAS Name: Not reported.

CAS Number: Not reported.

NH

NH2 NH2

N-Methylurea [MU]

IUPAC Name: N-Methylurea.

CAS Name: Not reported.

CAS Number: Not reported.

O

H

NH N 2

Bis[1-(3-hydroxytetrahydro-3-furylmethyl)-3-methylguanidinium] terephthalate [DN-3-OH]

IUPAC Name: Bis[1-(3-hydroxytetrahydro-3-furylmethyl)-3-methylguanidinium] terephthalate.

CAS Name: Not reported.

CAS Number: Not reported.

O

H

N

NH

HN

OH

COOH

COOH

2
72

Appendix C. Additional Information on the Honey Bee Field Study

Classification and Conclusions

The submitted field study of foraging honey bees (Apis mellifera) after exposure to 

dinotefuran 70 SG (70% a.i.) applied to cotton fields in Georgia, USA (MRID 48120501) 

was deemed supplemental (for qualitative use only and not upgradable). It is very 

important to note that on account of a poor study design, inadequate raw data reporting6, 

and multiple additional considerations (see below and Appendix C), the toxicity 

determinations cannot be used for risk assessment purposes. However, information 

regarding residue detections may be informative assuming freezer stability (MRID 

48120502) was conducted at -20 oC (as reported in the field study), or at an alternative, 

representative temperature. Therefore, solely on the basis of the residue data, the field 

study may still be utilized to address long-term exposure (but not toxicity) of honey bees 

to dinotefuran.

Although bees were exposed to dinotefuran, the dinotefuran residue levels detected in 

treatment plot samples of nectar, honey, beeswax, and pollen, did not, for the most part, 

differ greatly from those detected in the control samples, which is indicative of cross 

contamination in the control plot blossoms and hives (of all three trials in pollen and/or 

nectar samples) and likely foraging of treatment groups on control plots and of control 

groups on treated plots. For example, only trial 1 samples of nectar in flowers for days 7 

and 17 indicated a clear distinction between no residue detected in controls and detected 

levels (0.012-0.021 ppm) in both treatment plots; and, in trial 3 day 26 flower nectar 

samples where no residues were detected in the control, but were detected in the two 

treatments as 0.013 ppm and <LOQ (0.004 ppm). As a result of the cross-contamination, 

this study is inconclusive in terms of the toxicity of dinotefuran applications on cotton to 

honey bee hives. In addition, the lack of quantitative data rather than simply 

presence/absence on overwintering parameters such as egg abundance, larval abundance, 

pupal abundance renders the study inconclusive in terms of assessing overwintering 

success. The data suggest that all colonies (control and treatment) for all three trials were 

healthy (w/ >4 frames of adults) by approximately 200 days after exposure (i.e., Spring 

colony assessment performed in February for all three trials), with presence of queen, 

larvae, and eggs. However, the numbers on these hive attributes are not included. Instead, 

the quantitative data for this time step indicates that all colonies had adults present in all 

10 frames of each colony; this was the case for all three trials. Also, an estimate of the 

number of capped brood was only provided for trial 1, but the difference between control 

and treatment groups did not appear to be significant. In addition, presence of queens 

may not be an indicator of overwintering success as new queens were added to hives 

when queen loss occurred during the study. While re-queening hives is a common 

management practice, it is not particularly desirable for field studies as it prevents a test 

from quantifying the colony's ability to supersede naturally. 

The data on toxic effects in this study cannot be used for risk assessment purposes on 

account of poor study design. Similarly, residue values below the LOQ (i.e., a <LOQ 

 

6

Statistical verification of the adult bee mortality was not possible as the raw data counts were not 

provided by the study author.
73

value that was calculated by integration for samples where residue values were 

<0.010mg/kg) cannot be used quantitatively in the risk assessment; therefore, the residue 

analysis is of limited value other than characterizing qualitatively the presence/absence of 

dinotefuran residues over time. In addition, there are two major metabolites, MNG and 

DN, for which no residue data are provided in this study. The presence/absence data for 

residues, particularly in nectar, are important, however, because they suggest that 

residues could potentially be present in extra floral nectaries once flowers have been 

shed, and dinotefuran (or, total) residues will be present in stored food inside hives for 

long periods of time (i.e., at least 85 days after application). Therefore, honeybee adults 

and brood will likely be exposed to low levels of dinotefuran for relatively long periods 

of time, but the toxicity of these levels of residues remains an uncertainty.

Hive placement

Three separate trials were performed (over two years: July-Aug. 2008; July-Sept. 2009; 

August 2009). For each trial, twelve honey bee hives were prepared and maintained on 

new hive components. Two treated plots were approximately five acres each; one plot 

received two foliar applications of 40.5 g a.i./A, and the other plot received two foliar 

applications of 60.75 g a.i./A. A third plot in the same field was maintained as the nontreated control area. Four hives were randomly assigned to each of three treatments, and 

placed into the center of the appropriate plot seven days following the final foliar 

application (non-treated hives were placed at the far edge of the non-treated cotton area).

Dinotefuran (initial application) was applied to cotton plants approximately two weeks 

prior to peak flowering period. The second application was applied one week prior to 

peak flowering. At the initiation of approximate peak flowering, i.e., 1 week after the 

second treatment, four test hives were moved to the approximate center of each treated 

plot. An area of approximately 9 by 9 meters was cleared by mowing. The clearing was 

made accessible by mowing a 3-meter wide path from the edge of the field. A shade 

structure was erected in each treated plot to provide hives relief from direct sunlight. 

All hives within a trial location were positioned in the assigned field for a minimum of 27 

days (i.e., 4-week exposure period). After removal from the assigned field, all hives were 

maintained at a common location for the remainder of the study. A final evaluation of all 

hives was performed in February following initial exposure of the hives to the test area.

Study design concerns

While no statistically significant adverse effects were observed by the study author, this 

absence of effects could not be verified. The study author did not submit raw data for 

critical endpoints of concern. Furthermore, the study design does not allow for statistical 

comparisons. In each of the three trials, large fields were divided into 3 plots which were 

used as treatment units. Only one plot (ranging in size from 4.7 – 8 acres) per treatment 

level within one field (ranging in size from 18-30 acres) per year precludes any 

meaningful statistical comparison within and across trials. Comparison of plots within a 

trial is not possible on account of having no replicates for a given plot within a given 

trial, which implies that this is an un-replicated longitudinal study. Also, each year 
74

represents a unique trial given different environmental conditions and field/hive 

management regimes. Therefore, comparison across trials is also not possible.

The data show that residues were sometimes detected in nectar and pollen from control 

plots (e.g. 0.011 ppm in flower nectar at 15 days post-application in trial 3 and detectable 

in flower pollen at 27 days post-application in trial 1). These detections suggest that the 

plots were so close in each field trial that the control plots likely were exposed to drift 

from the spray applications in treated plots. The control contamination in flower samples 

could also be from previous applications of dinotefuran where the residues are still in the 

soil and available for uptake. Alternatively, it may be possible that control bees foraging 

on treated plots transferred pollen to control plots and/or hives. Control hive samples of 

pollen in every trial (detected at every time point) and nectar in every trial were 

contaminated with dinotefuran, even in the absence of detectable residues in the sampled 

flowers from control plots. Given detections of dinotefuran in hive nectar (plot 1) at day 

34, may suggest that nectar was collected by bees from either available flowers or 

extrafloral nectaries (which are present, but may or may not be active, continuously –

even when flowers fall off). Though dinotefuran detections were not made on the 

extrafloral nectaries of cotton plants, the presence of dinotefuran in flower nectar (e.g., up 

to day 27 post-application for plot 1 samples) lends strong support for dinotefuran 

concentrations in extrafloral nectaries given the common phloem source and 

dinotefuran‟s systemic properties, which would have implications for long-term exposure 

post-bloom. 

Many of the results for parts of the plants and hive that were sampled were below the 

level of quantitation; therefore, although detected the magnitude of the residues is 

unavailable. In addition, a non-guideline freezer storage stability study (MRID 

48120502) did not provide details on the freezer storage conditions (temperature, etc.) 

and was subsequently classified as „unacceptable, but upgradable.‟ This study would 

validate whether freezing the samples in -20oC (as reported in this field study MRID 

48120501) had an effect on the stability of the samples. Nonetheless, with the 

information at hand these residue results indicate that the plots were too close together 

and allowed control bees to forage in treated plots and vice versa. Given the crosscontamination, this study is inadequate to fully assess toxicity to field pollinators.

Other causes of concern in the study design are listed below:

The study authors only state the limit of quantitation (LOQ), but they do 

not state the limit of detection. Furthermore, the study employs 

LC/MS/MS with a limit of quantitation at 0.01 ppm, which is not sensitive 

enough to quantitatively assess exposure through contaminated food 

sources. Given the toxicity of dinotefuran on an acute oral basis (48-hour 

LD50 = 0.0076 g a.i./bee, MRID 45639727), concentrations comparable 

(i.e., 0.06 ppm, where 0.0076 g a.i./bee * [1 bee/0.128g] = 0.06 g a.i./g 

of bee) to the LOQ (0.01 ppm) may be toxicologically relevant. 

Bees may have used alternative forage sites since cotton is not a good 

pollen (protein) source, though it is a very good nectar (carbohydrate) 
75

source. In addition, all hives within a trial location were positioned in the 

assigned field for a minimum of 27 days (i.e., 4-week exposure period). It 

is possible that bloom was in successive decline over the exposure period 

such that suitable forage for the bees was also reduced.

Colonies are potentially fairly young as new foundation and new boxes 

were used. It appears that frame foundations were constructed close to 

study initiation in the Spring, so it is unclear how long the bees had to 

equilibrate (the study authors indicate that hives were provided with new 

foundation stock several weeks before test initiation). Typically, 6-8 

weeks are required for package bees to equilibrate in their colonies to lay 

down brood; otherwise, the bees may exert more energy building up the 

colony rather than laying down stores for the test duration.

The colonies were treated for disease/pests; however, these treatments 

apparently were on an as needed basis and were not uniform across study 

colonies. 

The treatment units were treated with a variety of compounds including 

aldicarb (Temik), which is highly toxic to honeybees; however, residue 

analyses beyond those for dinotefuran were not provided. A full spectrum 

residue analysis (on pollen and nectar) would have been preferred to 

account for additional contaminants and metabolites/degradates of 

dinotefuran.

Study authors intentionally destroyed queen cells to prevent swarming. 

Typically, additional frames are added to allow colonies to expand and 

thus prevent swarming. The presence of queen cells may be an indicator of 

colony (queen) performance as bees will not typically attempt to supersede 

the queen if she is functioning normally and conditions are not crowded in 

the colony. The fact that several hives swarmed suggests that the colonies 

were not sufficiently monitored and accommodated.

New queens were added to hives when queen loss occurred during the 

study. While re-queening hives is a common management practice, it is 

not particularly desirable for field studies as it prevents a test from 

quantifying the colony's ability to supersede naturally.

Reliance on a flat sheet of fabric (5 x 6 ft) placed on the ground in front of 

the hive to monitor adult bee mortality may result in counts that are

negatively biased as dead bees may be removed by scavengers. Dead 

zone dead bee traps (boxes fitted with screens) would have been a better 

method to employ since they prevent bees and scavengers from removing 

dead bees from these observation areas.

Removing all of the bees from the hive periodically through the study (i.e., 

right after placement to and before removal from the test site, at 42-50 

days, and 65-78 days) by shaking the frames into a large funnel to get an 

estimate of adult bee mass is likely a major stress factor. 

Trial 1 may have been compromised by the 7.6 inches of rain which fell 

during an August tropical storm event. Since the compound is systemic, 

presumably a significant portion of the amount applied roughly one month 

earlier had been taken up into the plant; however, bees would not have 
76

foraged on the treated plants for about two days.

Pretreatment analysis of hive vigor for trial 2 indicated that there was a 

difference in the estimated number of capped brood between the control 

hives and the 300 g ai/ha treatment group. This pretreatment difference 

may affect any future comparisons hive vigor through the study period.

The management practices in the “incubation period” were not described. 

This period immediately followed the exposure period after which the 

hives were evaluated for overwintering success. These management 

practices should be characterized to evaluate the environmental conditions 

to which the hives were exposed.

Field Study: Exposure

Concentrations of dinotefuran residues appear to be higher in flower nectar compared to 

flower pollen. Residues were detected in nectar samples from treated flowers up to 27 

days after application in trial 1 and up to 26 days after application in trials 2 and 3. These 

time points represent the latest time points that residues were collected from flowers in 

treated plots. The fact that residues were still present in these flower nectar samples, 

including one sample that had quantifiable residues of 0.013 ppm (LOQ = 0.004 ppm) 

after 26 days (trial 3), indicates that residues could potentially be found in nectar from 

extra floral nectaries in cotton plants as well as the flowers. These nectaries, which are 

not part of the blossom, may continue to produce nectar even after bloom that bees will 

use as a sugar source. Therefore, continual chronic exposure is likely to occur. 

Given detections of dinotefuran in hive nectar (plot 1) at day 34, may suggest that nectar 

was collected by bees from either available flowers or extrafloral nectaries (which are 

present, but may or may not be active, continuously – even when flowers fall off). 

Though dinotefuran detections were not made on the extrafloral nectaries of cotton 

plants, the presence of dinotefuran in flower nectar (e.g., up to day 27 post-application for 

plot 1 samples) lends strong support for dinotefuran concentrations in extrafloral 

nectaries given the common phloem source and dinotefuran‟s systemic properties, which 

would have implications for long-term exposure post-bloom.

Furthermore, trial 2 shows that dinotefuran residues can be detected in stored honey 

inside hives at least 85 days after application, which also suggests the occurrence of longterm chronic exposure inside the hive, which has implications for overwintering success 

as well.
77

Appendix D. Raw GENEEC Input/Output

RUN No. 1 FOR Dinotefuran ON Forestry * INPUT VALUES * 

 --------------------------------------------------------------------

 RATE (#/AC) No.APPS & SOIL SOLUBIL APPL TYPE NO-SPRAY INCORP

 ONE(MULT) INTERVAL Koc (PPM ) (%DRIFT) (FT) (IN)

 --------------------------------------------------------------------

 .540( .540) 1 1 31.4 39830.0 GRANUL( .0) .0 .0

 FIELD AND STANDARD POND HALFLIFE VALUES (DAYS) 

 --------------------------------------------------------------------

 METABOLIC DAYS UNTIL HYDROLYSIS PHOTOLYSIS METABOLIC COMBINED

 (FIELD) RAIN/RUNOFF (POND) (POND-EFF) (POND) (POND) 

 --------------------------------------------------------------------

 68.00 0 N/A 1.80- 223.20 82.73 60.36

 GENERIC EECs (IN MICROGRAMS/LITER (PPB)) Version 2.0 Aug 1, 2001

 --------------------------------------------------------------------

 PEAK MAX 4 DAY MAX 21 DAY MAX 60 DAY MAX 90 DAY

 GEEC AVG GEEC AVG GEEC AVG GEEC AVG GEEC

 --------------------------------------------------------------------

 28.75 28.48 26.98 23.92 21.89
78

Appendix E. LOCATES Output

Species numbers include endangered and threatened bird, mammal, amphibian, reptile, fish (freshwater, 

freshwater/saltwater), crustacean, bivalve, gastropod, arachnid, insect, and plant species

Table E1. Number of Endangered Species Potentially Exposed to Dinotefuran with the Proposed Use

Mammals Amphibians Birds Reptiles Arachnids Insects Conf/Cyc Dicot Ferns Lichen Monocots

Counties 1305 138 1295 372 15 240 8 892 43 22 512

Species 69 17 62 30 12 55 3 569 15 2 58

States 48 11 47 34 5 30 3 46 9 5 45

Table E2. Number of Endangered Species Potentially 

Exposed to Dinotefuran with the Proposed Uses

Bivalve Crustacean Fish Gastropod

Counties 552 74 797 56

Species 70 20 112 72

States 30 13 40 18

Taxon Count by State for Selected Crops

No species exclusions.

Minimum of 1 Acre

Terrestrial, Freshwater, Brackish, Saltwater, Subterraneous, Vernal pool, Coastal, Floodplain, Seas. 

wetland, Perm. wetland

almonds, chestnuts, hazelnuts (filberts), macadamia nuts, nuts-all, orchards, other fruits, 

nuts and tree crops, other nuts, pecans-all,

pecans-improved, pecans-native and seedling, pistachios, walnuts-english, christmas 

trees, short rotation woody crops, woodland-all

AL, AK, AS, AZ, AR, CA, CO, CT, DE, DC, FM, FL, GA, GU, HI, ID, IL, IN, IA, KS, KY, LA, 

ME, MH, MD, MA, MI, MN, MS, MO, MT, NE,

NV, NH, NJ, NM, NY, NC, ND, MP, an, OA, OP, OH, OK, OR, PW, PA, PR, RI, SC, SD, TN, 

TX, UM, UT, VT, VI, VA, WA, WV, WI, WY

Amphibian, Arachnid, Bird, Bivalve, Conf/cycds, Coral, Crustacean, Dicot, Ferns, Fish, 

Gastropod, Insect, Lichen, Mammal, Monocot, Reptile

1166 species with crop co-occurrence:

Frog, California Red-legged (Rana aurora draytonii) Amphibian Terrestrial, Freshwater Frog, Chiricahua 

Leopard (Rana chiricahuensis) Amphibian Terrestrial, Freshwater

Frog, Dusky Gopher (Mississippi DPS) (Rana capito sevosa) Amphibian Terrestrial, Freshwater Frog, Mountain 
79

Yellow-legged (Rana muscosa) Amphibian Terrestrial, Freshwater

Salamander, Barton Springs (Eurycea sosorum) Amphibian Terrestrial, Freshwater Salamander, 

California Tiger (Ambystoma californiense) Amphibian Terrestrial, Vernal pool

Salamander, Cheat Mountain (Plethodon nettingi) Amphibian Terrestrial, Freshwater Salamander, 

Desert Slender (Batrachoseps aridus) Amphibian Terrestrial, Freshwater

Salamander, Frosted Flatwoods (Ambystoma cingulatum) Amphibian Terrestrial, Freshwater, Salamander, 

Red Hills (Phaeognathus hubrichti) Amphibian Terrestrial, Freshwater

Vernal pool

Salamander, San Marcos (Eurycea nana) Amphibian Terrestrial, Freshwater Salamander, 

Santa Cruz Long-toed (Ambystoma macrodactylum Amphibian Terrestrial, Freshwater, 

croceum) 

Salamander, Shenandoah (Plethodon shenandoah) Amphibian Terrestrial, Freshwater Salamander, 

Sonora Tiger (Ambystoma tigrinum stebbinsi) Amphibian Terrestrial, Freshwater, 

Salamander, Texas Blind (Typhlomolge rathbuni) Amphibian Freshwater, Toad, Arroyo 

Southwestern (Bufo californicus (=microscaphus)) Amphibian Terrestrial, Freshwater

Subterraneous

Toad, Houston (Bufo houstonensis) Amphibian Terrestrial, Freshwater Harvestman, 

Bee Creek Cave (Texella reddelli) Arachnid Terrestrial, 

Harvestman, Bone Cave (Texella reyesi) Arachnid Terrestrial, Harvestman, 

Cokendolpher Cave (Texella cokendolpheri) Arachnid Terrestrial, 

Subterraneous 

Meshweaver, Braken Bat Cave (Cicurina venii) Arachnid Terrestrial, Meshweaver, 

Government Canyon Bat Cave (Cicurina vespera) Arachnid Terrestrial, 

Subterraneous 

Meshweaver, Madla's Cave (Cicurina madla) Arachnid Terrestrial, Meshweaver, 

Robber Baron Cave (Cicurina baronia) Arachnid Terrestrial, 

Subterraneous 

Pseudoscorpion, Tooth Cave (Tartarocreagris texana) Arachnid Terrestrial, Spider, 

Government Canyon Bat Cave (Neoleptoneta microps) Arachnid Terrestrial, 

Subterraneous 

Spider, Kauai Cave Wolf (Adelocosa anops) Arachnid Terrestrial, Spider, Sprucefir Moss (Microhexura montivaga) Arachnid Terrestrial

Subterraneous

Spider, Tooth Cave (Leptoneta myopica) Arachnid Terrestrial, 'Akepa, Hawaii 

(Loxops coccineus coccineus) Bird Terrestrial

Subterraneous

'Akepa, Maui (Loxops coccineus ochraceus) Bird Terrestrial 'Akia Loa, 

Kauai (Hemignathus procerus) (Hemignathus Bird Terrestrial

procerus)

'Akia Pola'au (Hemignathus munroi) (Hemignathus munroi) Bird Terrestrial Albatross, 

Short-tailed (Phoebastria (=Diomedea) albatrus) Bird Terrestrial, Saltwater Bobwhite, 

Masked (Colinus virginianus ridgwayi) Bird Terrestrial Caracara, 

Audubon's Crested (Polyborus plancus audubonii) Bird Terrestrial

Condor, California (Gymnogyps californianus) Bird Terrestrial Coot, Hawaiian 

(=Alae keo keo) (Fulica americana alai) Bird Terrestrial

Crane, Mississippi Sandhill (Grus canadensis pulla) Bird Terrestrial, Freshwater Crane, 

Whooping (Grus americana) Bird Terrestrial, Freshwater

Creeper, Hawaii (Oreomystis mana) Bird Terrestrial Creeper, Oahu 

(Alauwahio) (Paroreomyza maculata) Bird Terrestrial

Crow, Hawaiian ('Alala) (Corvus hawaiiensis) Bird Terrestrial Curlew, Eskimo 

(Numenius borealis) Bird Terrestrial

Duck, Hawaiian (Koloa) (Anas wyvilliana) Bird Terrestrial, Freshwater Eagle, Bald 

(Haliaeetus leucocephalus) Bird Terrestrial

Elepaio, Oahu (Chasiempis sandwichensis ibidis) Bird Terrestrial Falcon, 

Northern Aplomado (Falco femoralis septentrionalis) Bird Terrestrial

Flycatcher, Southwestern Willow (Empidonax traillii extimus) Bird Terrestrial Gnatcatcher, 

Coastal California (Polioptila californica californica) Bird Terrestrial
80

Goose, Hawaiian (Nene) (Branta (=Nesochen) sandvicensis) Bird Terrestrial, Freshwater Hawk, 

Hawaiian (Io) (Buteo solitarius) Bird Terrestrial

Honeycreeper, Crested ('Akohekohe) (Palmeria dolei) Bird Terrestrial Kite, Everglades 

Snail (Rostrhamus sociabilis plumbeus) Bird Terrestrial

Moorhen, Hawaiian Common (Gallinula chloropus sandvicensis) Bird Terrestrial Murrelet, 

Marbled (Brachyramphus marmoratus) Bird Terrestrial, Freshwater, 

'O'o, Kauai (='A'a) (Moho braccatus) Bird Terrestrial 'O'u 

(Honeycreeper) (Psittirostra psittacea) Bird Terrestrial

Owl, Mexican Spotted (Strix occidentalis lucida) Bird Terrestrial Owl, Northern 

Spotted (Strix occidentalis caurina) Bird Terrestrial

Palila (Loxioides bailleui) Bird Terrestrial Parrotbill, Maui 

(Pseudonestor xanthophrys) Bird Terrestrial

Petrel, Hawaiian Dark-rumped (Pterodroma phaeopygia Bird Terrestrial Plover, Piping 

(Charadrius melodus) Bird Terrestrial

sandwichensis)

Plover, Western Snowy (Charadrius alexandrinus nivosus) Bird Terrestrial Po'ouli 

(Melamprosops phaeosoma) Bird Terrestrial

Prairie-chicken, Attwater's Greater (Tympanuchus cupido Bird Terrestrial Rail, California 

Clapper (Rallus longirostris obsoletus) Bird Terrestrial

attwateri)

Rail, Light-footed Clapper (Rallus longirostris levipes) Bird Terrestrial Rail, Yuma 

Clapper (Rallus longirostris yumanensis) Bird Terrestrial

Scrub-Jay, Florida (Aphelocoma coerulescens) Bird Terrestrial Shearwater, 

Newell's Townsend's (Puffinus auricularis newelli) Bird Terrestrial, Saltwater

Shrike, San Clemente Loggerhead (Lanius ludovicianus mearnsi) Bird Terrestrial Sparrow, Cape 

Sable Seaside (Ammodramus maritimus mirabilis) Bird Terrestrial

Sparrow, Florida Grasshopper (Ammodramus savannarum Bird Terrestrial Sparrow, San 

Clemente Sage (Amphispiza belli clementeae) Bird Terrestrial

floridanus)

Stilt, Hawaiian (=Ae'o) (Himantopus mexicanus knudseni) Bird Terrestrial Stork, Wood 

(Mycteria americana) Bird Terrestrial

Swiftlet, Mariana Gray (=Vanikoro) (Aerodramus vanikorensis Bird Terrestrial Tern, California 

Least (Sterna antillarum browni) Bird Terrestrial

bartschi)

Tern, Interior (population) Least (Sterna antillarum) Bird Terrestrial Tern, Roseate 

(Sterna dougallii dougallii) Bird Terrestrial

Thrush, Large Kauai (Myadestes myadestinus) Bird Terrestrial Thrush, Small 

Kauai (Puaiohi) (Myadestes palmeri) Bird Terrestrial

Vireo, Black-capped (Vireo atricapilla) Bird Terrestrial Vireo, Least 

Bell's (Vireo bellii pusillus) Bird Terrestrial

Warbler (=Wood), Golden-cheeked (Dendroica chrysoparia) Bird Terrestrial Warbler 

(=Wood), Kirtland's (Dendroica kirtlandii) Bird Terrestrial

Warbler, Bachman's (Vermivora bachmanii) Bird Terrestrial Woodpecker, 

Ivory-billed (Campephilus principalis) Bird Terrestrial

Woodpecker, Red-cockaded (Picoides borealis) Bird Terrestrial Bankclimber, 

Purple (Elliptoideus sloatianus) Bivalve Freshwater

Combshell, Southern (=Penitent mussel) (Epioblasma penita) Bivalve Freshwater Combshell, 

Upland (Epioblasma metastriata) Bivalve Freshwater

Elktoe, Appalachian (Alasmidonta raveneliana) Bivalve Freshwater Fanshell 

(Cyprogenia stegaria) Bivalve Freshwater

Fatmucket, Arkansas (Lampsilis powelli) Bivalve Freshwater Kidneyshell, 

Triangular (Ptychobranchus greenii) Bivalve Freshwater

Mucket, Orange-nacre (Lampsilis perovalis) Bivalve Freshwater Mucket, Pink 

(Pearlymussel) (Lampsilis abrupta) Bivalve Freshwater

Mussel, Acornshell Southern (Epioblasma othcaloogensis) Bivalve Freshwater Mussel, 

Alabama Moccasinshell (Medionidus acutissimus) Bivalve Freshwater

Mussel, Black (=Curtus' Mussel) Clubshell (Pleurobema curtum) Bivalve Freshwater Mussel, 

Clubshell (Pleurobema clava) Bivalve Freshwater
81

Mussel, Coosa Moccasinshell (Medionidus parvulus) Bivalve Freshwater Mussel, 

Cumberland Combshell (Epioblasma brevidens) Bivalve Freshwater

Mussel, Cumberland Elktoe (Alasmidonta atropurpurea) Bivalve Freshwater Mussel, 

Cumberland Pigtoe (Pleurobema gibberum) Bivalve Freshwater

Mussel, Dark Pigtoe (Pleurobema furvum) Bivalve Freshwater Mussel, Dwarf 

Wedge (Alasmidonta heterodon) Bivalve Freshwater

Mussel, Fat Threeridge (Amblema neislerii) Bivalve Freshwater Mussel, Finelined Pocketbook (Lampsilis altilis) Bivalve Freshwater

Mussel, Fine-rayed Pigtoe (Fusconaia cuneolus) Bivalve Freshwater Mussel, Flat 

Pigtoe (=Marshall's Mussel) (Pleurobema marshalli) Bivalve Freshwater

Mussel, Gulf Moccasinshell (Medionidus penicillatus) Bivalve Freshwater Mussel, Heavy 

Pigtoe (=Judge Tait's Mussel) (Pleurobema Bivalve Freshwater

taitianum)

Mussel, Heelsplitter Carolina (Lasmigona decorata) Bivalve Freshwater Mussel, 

Heelsplitter Inflated (Potamilus inflatus) Bivalve Freshwater

Mussel, Ochlockonee Moccasinshell (Medionidus simpsonianus) Bivalve Freshwater Mussel, Oval 

Pigtoe (Pleurobema pyriforme) Bivalve Freshwater

Mussel, Ovate Clubshell (Pleurobema perovatum) Bivalve Freshwater Mussel, Oyster 

(Epioblasma capsaeformis) Bivalve Freshwater

Mussel, Ring Pink (=Golf Stick Pearly) (Obovaria retusa) Bivalve Freshwater Mussel, Rough 

Pigtoe (Pleurobema plenum) Bivalve Freshwater

Mussel, Scaleshell (Leptodea leptodon) Bivalve Freshwater Mussel, Shiny 

Pigtoe (Fusconaia cor) Bivalve Freshwater

Mussel, Shiny-rayed Pocketbook (Lampsilis subangulata) Bivalve Freshwater Mussel, 

Southern Clubshell (Pleurobema decisum) Bivalve Freshwater

Mussel, Southern Pigtoe (Pleurobema georgianum) Bivalve Freshwater Mussel, 

Speckled Pocketbook (Lampsilis streckeri) Bivalve Freshwater

Mussel, Winged Mapleleaf (Quadrula fragosa) Bivalve Freshwater Pearlshell, 

Louisiana (Margaritifera hembeli) Bivalve Freshwater

Pearlymussel, Alabama Lamp (Lampsilis virescens) Bivalve Freshwater Pearlymussel, 

Appalachian Monkeyface (Quadrula sparsa) Bivalve Freshwater

Pearlymussel, Birdwing (Conradilla caelata) Bivalve Freshwater Pearlymussel, 

Cracking (Hemistena lata) Bivalve Freshwater

Pearlymussel, Cumberland Bean (Villosa trabalis) Bivalve Freshwater Pearlymussel, 

Cumberland Monkeyface (Quadrula intermedia) Bivalve Freshwater

Pearlymussel, Curtis' (Epioblasma florentina curtisii) Bivalve Freshwater Pearlymussel, 

Dromedary (Dromus dromas) Bivalve Freshwater

Pearlymussel, Fat Pocketbook (Potamilus capax) Bivalve Freshwater Pearlymussel, 

Green-blossom (Epioblasma torulosa Bivalve Freshwater

gubernaculum)

Pearlymussel, Higgins' Eye (Lampsilis higginsii) Bivalve Freshwater Pearlymussel, 

Little-wing (Pegias fabula) Bivalve Freshwater

Pearlymussel, Orange-footed (Plethobasus cooperianus) Bivalve Freshwater Pearlymussel, 

Pale Lilliput (Toxolasma cylindrellus) Bivalve Freshwater

Pearlymussel, Purple Cat's Paw (Epioblasma obliquata obliquata) Bivalve Freshwater Pearlymussel, 

Tubercled-blossom (Epioblasma torulosa torulosa) Bivalve Freshwater

Pearlymussel, Turgid-blossom (Epioblasma turgidula) Bivalve Freshwater Pearlymussel, 

White Cat's Paw (Epioblasma obliquata perobliqua) Bivalve Freshwater

Pearlymussel, White Wartyback (Plethobasus cicatricosus) Bivalve Freshwater Pearlymussel, 

Yellow-blossom (Epioblasma florentina florentina) Bivalve Freshwater

Purple Bean (Villosa perpurpurea) Bivalve Freshwater Rabbitsfoot, 

Rough (Quadrula cylindrica strigillata) Bivalve Freshwater Riffleshell, 

Northern (Epioblasma torulosa rangiana) Bivalve Freshwater Riffleshell, Tan 

(Epioblasma florentina walkeri (=E. walkeri)) Bivalve Freshwater

Rock-pocketbook, Ouachita (=Wheeler's pm) (Arkansia Bivalve Freshwater Slabshell, 

Chipola (Elliptio chipolaensis) Bivalve Freshwater

Spinymussel, James River (Pleurobema collina) Bivalve Freshwater Spinymussel, 

Tar River (Elliptio steinstansana) Bivalve Freshwater

Stirrupshell (Quadrula stapes) Bivalve Freshwater Cypress, Gowen 
82

(Cupressus goveniana ssp. goveniana) Conf/cycds Terrestrial

Cypress, Santa Cruz (Cupressus abramsiana) Conf/cycds Terrestrial Torreya, Florida 

(Torreya taxifolia) Conf/cycds Terrestrial

Amphipod, Illinois Cave (Gammarus acherondytes) Crustacean Freshwater, Amphipod, 

Kauai Cave (Spelaeorchestia koloana) Crustacean Freshwater,

Subterraneous Subterraneous

Amphipod, Noel's (Gammarus desperatus) Crustacean Freshwater Amphipod, 

Peck's Cave (Stygobromus (=Stygonectes) pecki) Crustacean Freshwater, Subterraneous

Crayfish, Cave (Cambarus aculabrum) (Cambarus aculabrum) Crustacean Freshwater Crayfish, 

Nashville (Orconectes shoupi) Crustacean Freshwater

Crayfish, Shasta (Pacifastacus fortis) Crustacean Freshwater Fairy Shrimp, 

Conservancy Fairy (Branchinecta conservatio) Crustacean Vernal pool

Fairy Shrimp, Longhorn (Branchinecta longiantenna) Crustacean Vernal pool Fairy Shrimp, 

Riverside (Streptocephalus woottoni) Crustacean Vernal pool

Fairy Shrimp, San Diego (Branchinecta sandiegonensis) Crustacean Vernal pool Fairy Shrimp, 

Vernal Pool (Branchinecta lynchi) Crustacean Vernal pool

Isopod, Lee County Cave (Lirceus usdagalun) Crustacean Freshwater Isopod, 

Madison Cave (Antrolana lira) Crustacean Freshwater

Isopod, Socorro (Thermosphaeroma thermophilus) Crustacean Freshwater Shrimp, 

Alabama Cave (Palaemonias alabamae) Crustacean Freshwater

Shrimp, California Freshwater (Syncaris pacifica) Crustacean Freshwater Shrimp, 

Kentucky Cave (Palaemonias ganteri) Crustacean Freshwater

Shrimp, Squirrel Chimney Cave (Palaemonetes cummingi) Crustacean Freshwater, Tadpole 

Shrimp, Vernal Pool (Lepidurus packardi) Crustacean Vernal pool

Subterraneous

Abutilon sandwicense (ncn) (Abutilon sandwicense) Dicot Terrestrial Achyranthes 

mutica (ncn) (Achyranthes mutica) Dicot Terrestrial

Achyranthes splendens var. rotundata (ncn) (Achyranthes Dicot Terrestrial Adobe 

Sunburst, San Joaquin (Pseudobahia peirsonii) Dicot Terrestrial

splendens var. rotundata)

A'e (Zanthoxylum dipetalum var. tomentosum) (Zanthoxylum Dicot Terrestrial A'e 

(Zanthoxylum hawaiiense) (Zanthoxylum hawaiiense) Dicot Terrestrial

dipetalum var. tomentosum)

'Aiea (Nothocestrum breviflorum) (Nothocestrum breviflorum) Dicot Terrestrial 'Aiea 

(Nothocestrum peltatum) (Nothocestrum peltatum) Dicot Terrestrial

'Akoko (Chamaesyce celastroides var. kaenana) (Chamaesyce Dicot Terrestrial 'Akoko 

(Chamaesyce deppeana) (Chamaesyce deppeana) Dicot Terrestrial

celastroides var. kaenana)

'Akoko (Chamaesyce herbstii) (Chamaesyce herbstii) Dicot Terrestrial 'Akoko 

(Chamaesyce kuwaleana) (Chamaesyce kuwaleana) Dicot Terrestrial

'Akoko (Chamaesyce rockii) (Chamaesyce rockii) Dicot Terrestrial 'Akoko 

(Chamaesyce skottsbergii var. skottsbe (Chamaesyce Dicot Terrestrial

skottsbergii var. 

kalaeloana)

'Akoko (Euphorbia haeleeleana) (Euphorbia haeleeleana) Dicot Terrestrial Alani (Melicope 

adscendens) (Melicope adscendens) Dicot Terrestrial

Alani (Melicope balloui) (Melicope balloui) Dicot Terrestrial Alani (Melicope 

haupuensis) (Melicope haupuensis) Dicot Terrestrial

Alani (Melicope knudsenii) (Melicope knudsenii) Dicot Terrestrial Alani (Melicope 

lydgatei) (Melicope lydgatei) Dicot Terrestrial

Alani (Melicope mucronulata) (Melicope mucronulata) Dicot Terrestrial Alani (Melicope 

ovalis) (Melicope ovalis) Dicot Terrestrial

Alani (Melicope pallida) (Melicope pallida) Dicot Terrestrial Alani (Melicope 

quadrangularis) (Melicope quadrangularis) Dicot Terrestrial

Alani (Melicope saint-johnii) (Melicope saint-johnii) Dicot Terrestrial Alani (Melicope 

zahlbruckneri) (Melicope zahlbruckneri) Dicot Terrestrial

Allocarya, Calistoga (Plagiobothrys strictus) Dicot Vernal pool Alsinidendron 

obovatum (ncn) (Alsinidendron obovatum) Dicot Terrestrial
83

Alsinidendron trinerve (ncn) (Alsinidendron trinerve) Dicot Terrestrial Alsinidendron 

viscosum (ncn) (Alsinidendron viscosum) Dicot Terrestrial

Amaranth, Seabeach (Amaranthus pumilus) Dicot Coastal Ambrosia, San 

Diego (Ambrosia pumila) Dicot Terrestrial

Ambrosia, South Texas (Ambrosia cheiranthifolia) Dicot Terrestrial Amphianthus, 

Little (Amphianthus pusillus) Dicot Freshwater

'Anaunau (Lepidium arbuscula) (Lepidium arbuscula) Dicot Terrestrial 'Anunu (Sicyos 

alba) (Sicyos alba) Dicot Terrestrial

Aster, Decurrent False (Boltonia decurrens) Dicot Terrestrial, Freshwater Aster, Florida 

Golden (Chrysopsis floridana) Dicot Terrestrial

Aster, Ruth's Golden (Pityopsis ruthii) Dicot Terrestrial Aupaka 

(Isodendrion hosakae) (Isodendrion hosakae) Dicot Terrestrial

Aupaka (Isodendrion laurifolium) (Isodendrion laurifolium) Dicot Terrestrial Aupaka 

(Isodendrion longifolium) (Isodendrion longifolium) Dicot Terrestrial

Avens, Spreading (Geum radiatum) Dicot Terrestrial 'Awiwi 

(Centaurium sebaeoides) (Centaurium sebaeoides) Dicot Terrestrial

'Awiwi (Hedyotis cookiana) (Hedyotis cookiana) Dicot Terrestrial Ayenia, Texas 

(Ayenia limitaris) Dicot Terrestrial

Baccharis, Encinitas (Baccharis vanessae) Dicot Terrestrial Barbara 

Buttons, Mohr's (Marshallia mohrii) Dicot Terrestrial

Barberry, Island (Berberis pinnata ssp. insularis) Dicot Terrestrial Barberry, 

Nevin's (Berberis nevinii) Dicot Terrestrial

Bearclaw poppy, Dwarf (Arctomecon humilis) Dicot Terrestrial Beardtongue, 

Penland (Penstemon penlandii) Dicot Terrestrial

Bedstraw, El Dorado (Galium californicum ssp. sierrae) Dicot Terrestrial Bedstraw, 

Island (Galium buxifolium) Dicot Terrestrial

Bellflower, Brooksville (Campanula robinsiae) Dicot Terrestrial Birch, Virginia 

Round-leaf (Betula uber) Dicot Floodplain

Bird's-beak, Palmate-bracted (Cordylanthus palmatus) Dicot Terrestrial Bird's-beak, 

Pennell's (Cordylanthus tenuis ssp. capillaris) Dicot Terrestrial

Bird's-beak, salt marsh (Cordylanthus maritimus ssp. maritimus) Dicot Saltwater Bird's-beak, 

Soft (Cordylanthus mollis ssp. mollis) Dicot Brackish, Saltwater

Birds-in-a-nest, White (Macbridea alba) Dicot Terrestrial Bittercress, 

Small-anthered (Cardamine micranthera) Dicot Terrestrial

Bladderpod, Dudley Bluffs (Lesquerella congesta) Dicot Terrestrial Bladderpod, 

Kodachrome (Lesquerella tumulosa) Dicot Terrestrial

Bladderpod, Lyrate (Lesquerella lyrata) Dicot Terrestrial Bladderpod, 

Missouri (Lesquerella filiformis) Dicot Terrestrial

Bladderpod, San Bernardino Mountains (Lesquerella kingii ssp. Dicot Terrestrial Bladderpod, 

Spring Creek (Lesquerella perforata) Dicot Floodplain

bernardina)

Bladderpod, White (Lesquerella pallida) Dicot Terrestrial Bladderpod, 

Zapata (Lesquerella thamnophila) Dicot Terrestrial

Blazing Star, Ash Meadows (Mentzelia leucophylla) Dicot Terrestrial Blazing Star, 

Heller's (Liatris helleri) Dicot Terrestrial

Blazing Star, Scrub (Liatris ohlingerae) Dicot Terrestrial Bluecurls, 

Hidden Lake (Trichostema austromontanum ssp. Dicot Terrestrial

compactum)

Blue-star, Kearney's (Amsonia kearneyana) Dicot Terrestrial Bluet, Roan 

Mountain (Hedyotis purpurea var. montana) Dicot Terrestrial

Bonamia menziesii (ncn) (Bonamia menziesii) Dicot Terrestrial Bonamia, 

Florida (Bonamia grandiflora) Dicot Terrestrial

Boxwood, Vahl's (Buxus vahlii) Dicot Terrestrial Broom, San 

Clemente Island (Lotus dendroideus ssp. traskiae) Dicot Terrestrial

Buckwheat, Cushenbury (Eriogonum ovalifolium var. vineum) Dicot Terrestrial Buckwheat, 

Ione (incl. Irish Hill) (Eriogonum apricum (incl. var. Dicot Terrestrial

prostratum))

Buckwheat, Scrub (Eriogonum longifolium var. gnaphalifolium) Dicot Terrestrial Buckwheat, 

Southern Mountain Wild (Eriogonum kennedyi var. Dicot Terrestrial
84

austromontanu

m)

Buckwheat, Steamboat (Eriogonum ovalifolium var. williamsiae) Dicot Terrestrial Bush-mallow, 

San Clemente Island (Malacothamnus clementinus) Dicot Terrestrial Bush-mallow, 

Santa Cruz Island (Malacothamnus fasciculatus var. Dicot Terrestrial Buttercup, 

Autumn (Ranunculus aestivalis (=acriformis)) Dicot Terrestrial

nesioticus)

Butterfly Plant, Colorado (Gaura neomexicana var. coloradensis) Dicot Terrestrial Butterweed, 

Layne's (Senecio layneae) Dicot Terrestrial

Butterwort, Godfrey's (Pinguicula ionantha) Dicot Terrestrial, Freshwater Button-celery, 

San Diego (Eryngium aristulatum var. parishii) Dicot Terrestrial

Cactus, Arizona Hedgehog (Echinocereus triglochidiatus var. Dicot Terrestrial Cactus, 

Bakersfield (Opuntia treleasei) Dicot Terrestrial

arizonicus)

Cactus, Black Lace (Echinocereus reichenbachii var. albertii) Dicot Terrestrial Cactus, Brady 

Pincushion (Pediocactus bradyi) Dicot Terrestrial

Cactus, Bunched Cory (Coryphantha ramillosa) Dicot Terrestrial Cactus, Chisos 

Mountain Hedgehog (Echinocereus chisoensis var. Dicot Terrestrial

chisoensis)

Cactus, Cochise Pincushion (Coryphantha robbinsorum) Dicot Terrestrial Cactus, 

Knowlton (Pediocactus knowltonii) Dicot Terrestrial

Cactus, Kuenzler Hedgehog (Echinocereus fendleri var. kuenzleri) Dicot Terrestrial Cactus, Lee 

Pincushion (Coryphantha sneedii var. leei) Dicot Terrestrial

Cactus, Lloyd's Mariposa (Echinomastus mariposensis) Dicot Terrestrial Cactus, Mesa 

Verde (Sclerocactus mesae-verdae) Dicot Terrestrial

Cactus, Nellie Cory (Coryphantha minima) Dicot Terrestrial Cactus, Nichol's 

Turk's Head (Echinocactus horizonthalonius var. Dicot Terrestrial

nicholii)

Cactus, Peebles Navajo (Pediocactus peeblesianus peeblesianus) Dicot Terrestrial Cactus, Pima 

Pineapple (Coryphantha scheeri var. robustispina) Dicot Terrestrial

Cactus, San Rafael (Pediocactus despainii) Dicot Terrestrial Cactus, Siler 

Pincushion (Pediocactus (=Echinocactus,=Utahia) Dicot Terrestrial

sileri)

Cactus, Sneed Pincushion (Coryphantha sneedii var. sneedii) Dicot Terrestrial Cactus, Star 

(Astrophytum asterias) Dicot Terrestrial

Cactus, Tobusch Fishhook (Ancistrocactus tobuschii) Dicot Terrestrial Cactus, Uinta 

Basin hookless (Sclerocactus wetlandicus) Dicot Terrestrial

Cactus, Winkler (Pediocactus winkleri) Dicot Terrestrial Cactus, Wright 

Fishhook (Sclerocactus wrightiae) Dicot Terrestrial

Campion, Fringed (Silene polypetala) Dicot Terrestrial Catchfly, 

Spalding's (Silene spaldingii) Dicot Terrestrial

Catesbaea Melanocarpa (ncn) (Catesbaea melanocarpa) Dicot Terrestrial Cat's-eye, 

Terlingua Creek (Cryptantha crassipes) Dicot Terrestrial

Ceanothus, Coyote (Ceanothus ferrisae) Dicot Terrestrial Ceanothus, Pine 

Hill (Ceanothus roderickii) Dicot Terrestrial

Ceanothus, Vail Lake (Ceanothus ophiochilus) Dicot Terrestrial Centaury, 

Spring-loving (Centaurium namophilum) Dicot Terrestrial

Chaffseed, American (Schwalbea americana) Dicot Terrestrial Chamaesyce 

Halemanui (ncn) (Chamaesyce halemanui) Dicot Terrestrial

Checker-mallow, Keck's (Sidalcea keckii) Dicot Terrestrial Checkermallow, Kenwood Marsh (Sidalcea oregana ssp. valida) Dicot Terrestrial

Checker-mallow, Nelson's (Sidalcea nelsoniana) Dicot Terrestrial Checkermallow, Pedate (Sidalcea pedata) Dicot Terrestrial

Checker-mallow, Wenatchee Mountains (Sidalcea oregana var. Dicot Terrestrial Clarkia, Pismo 

(Clarkia speciosa ssp. immaculata) Dicot Terrestrial

calva)

Clarkia, Presidio (Clarkia franciscana) Dicot Terrestrial Clarkia, 

Springville (Clarkia springvillensis) Dicot Terrestrial

Clarkia, Vine Hill (Clarkia imbricata) Dicot Terrestrial Cliffrose, 
85

Arizona (Purshia (=cowania) subintegra) Dicot Terrestrial

Clover, Fleshy Owl's (Castilleja campestris ssp. succulenta) Dicot Vernal pool Clover, Leafy 

Prairie (Dalea foliosa) Dicot Terrestrial

Clover, Monterey (Trifolium trichocalyx) Dicot Terrestrial Clover, Prairie 

Bush (Lespedeza leptostachya) Dicot Terrestrial

Clover, Running Buffalo (Trifolium stoloniferum) Dicot Terrestrial Clover, Showy 

Indian (Trifolium amoenum) Dicot Terrestrial

Coneflower, Smooth (Echinacea laevigata) Dicot Terrestrial Coneflower, 

Tennessee Purple (Echinacea tennesseensis) Dicot Terrestrial

Coyote-thistle, Loch Lomond (Eryngium constancei) Dicot Terrestrial Crownbeard, 

Big-leaved (Verbesina dissita) Dicot Terrestrial

Crownscale, San Jacinto Valley (Atriplex coronata var. notatior) Dicot Terrestrial Cyanea 

undulata (ncn) (Cyanea undulata) Dicot Terrestrial

Cycladenia, Jones (Cycladenia jonesii (=humilis)) Dicot Terrestrial Daisy, Lakeside 

(Hymenoxys herbacea) Dicot Freshwater

Daisy, Maguire (Erigeron maguirei) Dicot Freshwater Daisy, Parish's 

(Erigeron parishii) Dicot Freshwater

Daisy, Willamette (Erigeron decumbens var. decumbens) Dicot Terrestrial Dawn-flower, 

Texas Prairie (=Texas Bitterweed) (Hymenoxys Dicot Terrestrial

texana)

Delissea rhytodisperma (ncn) (Delissea rhytidosperma) Dicot Terrestrial Dogweed, Ashy 

(Thymophylla tephroleuca) Dicot Terrestrial

Dropwort, Canby's (Oxypolis canbyi) Dicot Terrestrial, Freshwater Dubautia 

latifolia (ncn) (Dubautia latifolia) Dicot Terrestrial

Dubautia pauciflorula (ncn) (Dubautia pauciflorula) Dicot Terrestrial Dudleya, 

Conejo (Dudleya abramsii ssp. parva) Dicot Terrestrial

Dudleya, Marcescent (Dudleya cymosa ssp. marcescens) Dicot Terrestrial Dudleya, Santa 

Clara Valley (Dudleya setchellii) Dicot Terrestrial

Dudleya, Santa Cruz Island (Dudleya nesiotica) Dicot Terrestrial Dudleya, Santa 

Monica Mountains (Dudleya cymosa ssp. Dicot Terrestrial

ovatifolia)

Dudleya, Verity's (Dudleya verityi) Dicot Terrestrial Dwarf-flax, 

Marin (Hesperolinon congestum) Dicot Terrestrial

Evening-primrose, Antioch Dunes (Oenothera deltoides ssp. Dicot Terrestrial Eveningprimrose, San Benito (Camissonia benitensis) Dicot Terrestrial

howellii)

Fiddleneck, Large-flowered (Amsinckia grandiflora) Dicot Terrestrial Flannelbush, 

Mexican (Fremontodendron mexicanum) Dicot Terrestrial

Flannelbush, Pine Hill (Fremontodendron californicum ssp. Dicot Terrestrial Fleabane, Zuni 

(Erigeron rhizomatus) Dicot Terrestrial

decumbens)

Four-o'clock, Macfarlane's (Mirabilis macfarlanei) Dicot Terrestrial Frankenia, 

Johnston's (Frankenia johnstonii) Dicot Terrestrial

Fringe Tree, Pygmy (Chionanthus pygmaeus) Dicot Terrestrial Fringepod, 

Santa Cruz Island (Thysanocarpus conchuliferus) Dicot Terrestrial

Fruit, Earth (=geocarpon) (Geocarpon minimum) Dicot Terrestrial Geranium, 

Hawaiian Red-flowered (Geranium arboreum) Dicot Terrestrial

Gerardia, Sandplain (Agalinis acuta) Dicot Terrestrial Gilia, 

Hoffmann's Slender-flowered (Gilia tenuiflora ssp. Dicot Terrestrial

hoffmannii)

Gilia, Monterey (Gilia tenuiflora ssp. arenaria) Dicot Terrestrial Golden 

Sunburst, Hartweg's (Pseudobahia bahiifolia) Dicot Terrestrial

Goldenrod, Blue Ridge (Solidago spithamaea) Dicot Terrestrial Goldenrod, 

Houghton's (Solidago houghtonii) Dicot Terrestrial

Goldenrod, Short's (Solidago shortii) Dicot Terrestrial Goldenrod, 

White-haired (Solidago albopilosa) Dicot Terrestrial

Goldfields, Burke's (Lasthenia burkei) Dicot Terrestrial Goldfields, 
86

Contra Costa (Lasthenia conjugens) Dicot Terrestrial

Gooseberry, Miccosukee (Ribes echinellum) Dicot Terrestrial Gouania 

hillebrandii (ncn) (Gouania hillebrandii) Dicot Terrestrial

Gouania meyenii (ncn) (Gouania meyenii) Dicot Terrestrial Gouania 

vitifolia (ncn) (Gouania vitifolia) Dicot Terrestrial

Gourd, Okeechobee (Cucurbita okeechobeensis ssp. Dicot Terrestrial Grass, Hairy 

Orcutt (Orcuttia pilosa) Dicot Vernal pool

okeechobeensis)

Grass, Sacramento Orcutt (Orcuttia viscida) Dicot Vernal pool Grass, Slender 

Orcutt (Orcuttia tenuis) Dicot Vernal pool

Ground-plum, Guthrie's (Astragalus bibullatus) Dicot Terrestrial Groundsel, San 

Francisco Peaks (Senecio franciscanus) Dicot Terrestrial

Gumplant, Ash Meadows (Grindelia fraxino-pratensis) Dicot Terrestrial Haha (Cyanea 

acuminata) (Cyanea acuminata) Dicot Terrestrial

Haha (Cyanea asarifolia) (Cyanea asarifolia) Dicot Terrestrial

Haha (Cyanea copelandii ssp. copelandii) (Cyanea copelandii ssp. Dicot Terrestrial Haha (Cyanea copelandii ssp. 

haleakalaensis) (Cyanea copelandii Dicot Terrestrial

copelandii) ssp. 

haleakalaensis)

Haha (Cyanea Crispa) (=Rollandia crispa) (Cyanea (=Rollandia) Dicot Terrestrial Haha (Cyanea 

glabra) (Cyanea glabra) Dicot Terrestrial

crispa)

Haha (Cyanea grimesiana ssp. grimesiana) (Cyanea grimesiana Dicot Terrestrial Haha (Cyanea 

grimesiana ssp. obatae) (Cyanea grimesiana ssp. Dicot Terrestrial

ssp. grimesiana) obatae)

Haha (Cyanea hamatiflora ssp. carlsonii) (Cyanea hamatiflora Dicot Terrestrial Haha (Cyanea 

hamatiflora ssp. hamatiflora) (Cyanea hamatiflora Dicot Terrestrial

ssp. Carlsonii) ssp. 

hamatiflora)

Haha (Cyanea humboldtiana) (Cyanea humboldtiana) Dicot Terrestrial Haha (Cyanea 

koolauensis) (Cyanea koolauensis) Dicot Terrestrial

Haha (Cyanea lobata) (Cyanea lobata) Dicot Terrestrial Haha (Cyanea 

longiflora) (Cyanea longiflora) Dicot Terrestrial

Haha (Cyanea mceldowneyi) (Cyanea mceldowneyi) Dicot Terrestrial Haha (Cyanea 

pinnatifida) (Cyanea pinnatifida) Dicot Terrestrial

Haha (Cyanea platyphylla) (Cyanea platyphylla) Dicot Terrestrial Haha (Cyanea 

recta) (Cyanea recta) Dicot Terrestrial

Haha (Cyanea remyi) (Cyanea remyi) Dicot Terrestrial Haha (Cyanea 

shipmanii) (Cyanea shipmannii) Dicot Terrestrial

Haha (Cyanea stictophylla) (Cyanea stictophylla) Dicot Terrestrial Haha (Cyanea 

St-Johnii) (=Rollandia St-Johnii) (Cyanea st- Dicot Terrestrial

johnii)

Haha (Cyanea superba) (Cyanea superba) Dicot Terrestrial Haha (Cyanea 

truncata) (Cyanea truncata) Dicot Terrestrial

Ha'Iwale (Cyrtandra crenata) (Cyrtandra crenata) Dicot Terrestrial Ha'Iwale 

(Cyrtandra dentata) (Cyrtandra dentata) Dicot Terrestrial

Ha'Iwale (Cyrtandra giffardii) (Cyrtandra giffardii) Dicot Terrestrial Ha'Iwale 

(Cyrtandra munroi) (Cyrtandra munroi) Dicot Terrestrial

Ha'Iwale (Cyrtandra polyantha) (Cyrtandra polyantha) Dicot Terrestrial Ha'Iwale 

(Cyrtandra subumbellata) (Cyrtandra subumbellata) Dicot Terrestrial

Ha'Iwale (Cyrtandra tintinnabula) (Cyrtandra tintinnabula) Dicot Terrestrial Ha'Iwale 

(Cyrtandra viridiflora) (Cyrtandra viridiflora) Dicot Terrestrial

Haplostachys Haplostachya (ncn) (Haplostachys haplostachya) Dicot Terrestrial Harebells, Avon 

Park (Crotalaria avonensis) Dicot Terrestrial

Harperella (Ptilimnium nodosum) Dicot Freshwater Hau Kauhiwi 

(Hibiscadelphus woodi) (Hibiscadelphus woodii) Dicot Terrestrial

Hau Kuahiwi (Hibiscadelphus distans) (Hibiscadelphus distans) Dicot Terrestrial Hau Kuahiwi 

(Hibiscadelphus giffardianus) (Hibiscadelphus Dicot Terrestrial

giffardianus)
87

Hau Kuahiwi (Hibiscadelphus hualalaiensis) (Hibiscadelphus Dicot Terrestrial Heartleaf, 

Dwarf-flowered (Hexastylis naniflora) Dicot Terrestrial

hualalaiensis)

Heather, Mountain Golden (Hudsonia montana) Dicot Terrestrial Heau 

(Exocarpos luteolus) (Exocarpos luteolus) Dicot Terrestrial

Hedyotis degeneri (ncn) (Hedyotis degeneri) Dicot Terrestrial Hedyotis 

parvula (ncn) (Hedyotis parvula) Dicot Terrestrial

Hedyotis St.-Johnii (ncn) (Hedyotis st.-johnii) Dicot Terrestrial Hesperomannia 

arborescens (ncn) (Hesperomannia arborescens) Dicot Terrestrial

Hesperomannia arbuscula (ncn) (Hesperomannia arbuscula) Dicot Terrestrial Hesperomannia 

lydgatei (ncn) (Hesperomannia lydgatei) Dicot Terrestrial

Hibiscus, Clay's (Hibiscus clayi) Dicot Terrestrial Holei (Ochrosia 

kilaueaensis) (Ochrosia kilaueaensis) Dicot Terrestrial

Howellia, Water (Howellia aquatilis) Dicot Freshwater Hypericum, 

Highlands Scrub (Hypericum cumulicola) Dicot Terrestrial

Iliau (Wilkesia hobdyi) (Wilkesia hobdyi) Dicot Terrestrial Ipomopsis, Holy 

Ghost (Ipomopsis sancti-spiritus) Dicot Terrestrial

Ivesia, Ash Meadows (Ivesia kingii var. eremica) Dicot Terrestrial Jacquemontia, 

Beach (Jacquemontia reclinata) Dicot Terrestrial, Coastal

Jewelflower, California (Caulanthus californicus) Dicot Terrestrial Jewelflower, 

Metcalf Canyon (Streptanthus albidus ssp. albidus) Dicot Terrestrial

Jewelflower, Tiburon (Streptanthus niger) Dicot Terrestrial Joint-vetch, 

Sensitive (Aeschynomene virginica) Dicot Terrestrial, Brackish

Kamakahala (Labordia cyrtandrae) (Labordia cyrtandrae) Dicot Terrestrial Kamakahala 

(Labordia lydgatei) (Labordia lydgatei) Dicot Terrestrial

Kamakahala (Labordia tinifolia var. wahiawaen) (Labordia Dicot Terrestrial Kauila 

(Colubrina oppositifolia) (Colubrina oppositifolia) Dicot Terrestrial

tinifolia var. wahiawaensis)

Kaulu (Pteralyxia kauaiensis) (Pteralyxia kauaiensis) Dicot Terrestrial Kio'Ele 

(Hedyotis coriacea) (Hedyotis coriacea) Dicot Terrestrial

Kiponapona (Phyllostegia racemosa) (Phyllostegia racemosa) Dicot Terrestrial Koki'o (Kokia 

drynarioides) (Kokia drynarioides) Dicot Terrestrial

Koki'o (Kokia kauaiensis) (Kokia kauaiensis) Dicot Terrestrial Koki'o Ke'oke'o 

(Hibiscus waimeae ssp. hannerae) (Hibiscus Dicot Terrestrial

waimeae ssp. 

hannerae)

Kolea (Myrsine juddii) (Myrsine juddii) Dicot Terrestrial Kolea (Myrsine 

linearifolia) (Myrsine linearifolia) Dicot Terrestrial

Ko'oko'olau (Bidens micrantha ssp. kalealaha) (Bidens micrantha Dicot Terrestrial Ko'oloa'ula 

(Abutilon menziesii) (Abutilon menziesii) Dicot Terrestrial

ssp. kalealaha)

Kuawawaenohu (Alsinidendron lychnoides) (Alsinidendron Dicot Terrestrial Kulu'I 

(Nototrichium humile) (Nototrichium humile) Dicot Terrestrial

lychnoides)

Larkspur, Baker's (Delphinium bakeri) Dicot Terrestrial Larkspur, San 

Clemente Island (Delphinium variegatum ssp. Dicot Terrestrial

kinkiense)

Larkspur, Yellow (Delphinium luteum) Dicot Terrestrial Laukahi 

Kuahiwi (Plantago hawaiensis) (Plantago hawaiensis) Dicot Terrestrial

Laukahi Kuahiwi (Plantago princeps) (Plantago princeps) Dicot Terrestrial Laulihilihi 

(Schiedea stellarioides) (Schiedea stellarioides) Dicot Terrestrial

Layia, Beach (Layia carnosa) Dicot Terrestrial, Coastal Lead-plant, 

Crenulate (Amorpha crenulata) Dicot Terrestrial

Leather-flower, Alabama (Clematis socialis) Dicot Terrestrial Leather-flower, 

Morefield's (Clematis morefieldii) Dicot Terrestrial

Lessingia, San Francisco (Lessingia germanorum (=L.g. var. Dicot Terrestrial Liliwai (Acaena 

exigua) (Acaena exigua) Dicot Terrestrial

germanorum))

Liveforever, Laguna Beach (Dudleya stolonifera) Dicot Terrestrial Liveforever, 
88

Santa Barbara Island (Dudleya traskiae) Dicot Terrestrial

Lobelia monostachya (ncn) (Lobelia monostachya) Dicot Terrestrial Lobelia 

niihauensis (ncn) (Lobelia niihauensis) Dicot Terrestrial

Lobelia oahuensis (ncn) (Lobelia oahuensis) Dicot Terrestrial Locoweed, 

Fassett's (Oxytropis campestris var. chartacea) Dicot Terrestrial

Lomatium, Bradshaw's (Lomatium bradshawii) Dicot Terrestrial, Freshwater Lomatium, 

Cook's (Lomatium cookii) Dicot Vernal pool

Loosestrife, Rough-leaved (Lysimachia asperulaefolia) Dicot Terrestrial Lousewort, 

Furbish (Pedicularis furbishiae) Dicot Terrestrial

Lupine, Clover (Lupinus tidestromii) Dicot Coastal Lupine, 

Kincaid's (Lupinus sulphureus (=oreganus) ssp. kincaidii Dicot Terrestrial

(=var. 

kincaidii))

Lupine, Nipomo Mesa (Lupinus nipomensis) Dicot Coastal Lupine, Scrub 

(Lupinus aridorum) Dicot Terrestrial

Lysimachia filifolia (ncn) (Lysimachia filifolia) Dicot Terrestrial Lysimachia 

lydgatei (ncn) (Lysimachia lydgatei) Dicot Terrestrial

Mahoe (Alectryon macrococcus) (Alectryon macrococcus) Dicot Terrestrial Makou 

(Peucedanum sandwicense) (Peucedanum sandwicense) Dicot Terrestrial

Malacothrix, Island (Malacothrix squalida) Dicot Terrestrial Malacothrix, 

Santa Cruz Island (Malacothrix indecora) Dicot Terrestrial

Mallow, Kern (Eremalche kernensis) Dicot Terrestrial Mallow, Peter's 

Mountain (Iliamna corei) Dicot Terrestrial

Manioc, Walker's (Manihot walkerae) Dicot Terrestrial Manzanita, Del 

Mar (Arctostaphylos glandulosa ssp. crassifolia) Dicot Terrestrial

Manzanita, Ione (Arctostaphylos myrtifolia) Dicot Terrestrial Manzanita, 

Morro (Arctostaphylos morroensis) Dicot Terrestrial

Manzanita, Pallid (Arctostaphylos pallida) Dicot Terrestrial Manzanita, 

Santa Rosa Island (Arctostaphylos confertiflora) Dicot Terrestrial

Ma'oli'oli (Schiedea apokremnos) (Schiedea apokremnos) Dicot Terrestrial Ma'oli'oli 

(Schiedea kealiae) (Schiedea kealiae) Dicot Terrestrial

Mapele (Cyrtandra cyaneoides) (Cyrtandra cyaneoides) Dicot Terrestrial Meadowfoam, 

Butte County (Limnanthes floccosa ssp. Dicot Vernal pool

californica)

Meadowfoam, Large-flowered Woolly (Limnanthes floccosa ssp. Dicot Vernal pool Meadowfoam, 

Sebastopol (Limnanthes vinculans) Dicot Terrestrial, Freshwater

Grandiflora)

Meadowrue, Cooley's (Thalictrum cooleyi) Dicot Terrestrial Mehamehame 

(Flueggea neowawraea) (Flueggea neowawraea) Dicot Terrestrial

Milkpea, Small's (Galactia smallii) Dicot Terrestrial Milk-vetch, 

Applegate's (Astragalus applegatei) Dicot Terrestrial

Milk-vetch, Ash Meadows (Astragalus phoenix) Dicot Terrestrial Milk-vetch, 

Braunton's (Astragalus brauntonii) Dicot Terrestrial

Milk-vetch, Clara Hunt's (Astragalus clarianus) Dicot Terrestrial Milk-vetch, 

Coachella Valley (Astragalus lentiginosus var. Dicot Terrestrial

coachellae)

Milk-vetch, Coastal Dunes (Astragalus tener var. titi) Dicot Terrestrial Milk-vetch, 

Cushenbury (Astragalus albens) Dicot Terrestrial

Milk-vetch, Deseret (Astragalus desereticus) Dicot Terrestrial Milk-vetch, 

Heliotrope (Astragalus montii) Dicot Terrestrial

Milk-vetch, Holmgren (Astragalus holmgreniorum) Dicot Terrestrial Milk-vetch, 

Jesup's (Astragalus robbinsii var. jesupi) Dicot Terrestrial

Milk-vetch, Mancos (Astragalus humillimus) Dicot Terrestrial Milk-vetch, 

Osterhout (Astragalus osterhoutii) Dicot Terrestrial

Milk-vetch, Pierson's (Astragalus magdalenae var. peirsonii) Dicot Terrestrial Milk-vetch, 

Sentry (Astragalus cremnophylax var. Dicot Terrestrial

Milk-vetch, Triple-ribbed (Astragalus tricarinatus) Dicot Terrestrial Milk-vetch, 

Ventura Marsh (Astragalus pycnostachyus var. Dicot Terrestrial, Freshwater
89

lanosissimus)

Milkweed, Mead's (Asclepias meadii) Dicot Terrestrial Milkweed, 

Welsh's (Asclepias welshii) Dicot Terrestrial

Mint, Garrett's (Dicerandra christmanii) Dicot Terrestrial Mint, Lakela's 

(Dicerandra immaculata) Dicot Terrestrial

Mint, Longspurred (Dicerandra cornutissima) Dicot Terrestrial Mint, Otay 

Mesa (Pogogyne nudiuscula) Dicot Terrestrial

Mint, San Diego Mesa (Pogogyne abramsii) Dicot Terrestrial Mint, Scrub 

(Dicerandra frutescens) Dicot Terrestrial

Monardella, Willowy (Monardella linoides ssp. viminea) Dicot Terrestrial Monkey-flower, 

Michigan (Mimulus glabratus var. michiganensis) Dicot Terrestrial, Freshwater

Monkshood, Northern Wild (Aconitum noveboracense) Dicot Terrestrial Morning-glory, 

Stebbins (Calystegia stebbinsii) Dicot Terrestrial

Mountainbalm, Indian Knob (Eriodictyon altissimum) Dicot Terrestrial Mountainmahogany, Catalina Island (Cercocarpus traskiae) Dicot Terrestrial

Munroidendron racemosum (ncn) (Munroidendron racemosum) Dicot Terrestrial Mustard, 

Carter's (Warea carteri) Dicot Terrestrial

Mustard, Penland Alpine Fen (Eutrema penlandii) Dicot Terrestrial, Freshwater Mustard, 

Slender-petaled (Thelypodium stenopetalum) Dicot Terrestrial

Na'ena'e (Dubautia herbstobatae) (Dubautia herbstobatae) Dicot Terrestrial Na'ena'e 

(Dubautia plantaginea ssp. humilis) (Dubautia Dicot Terrestrial

plantaginea ssp. 

humilis)

Nani Wai'ale'ale (Viola kauaensis var. wahiawaensis) (Viola Dicot Terrestrial Nanu (Gardenia 

mannii) (Gardenia mannii) Dicot Terrestrial

kauaiensis var. wahiawaensis)

Na'u (Gardenia brighamii) (Gardenia brighamii) Dicot Terrestrial Naupaka, Dwarf 

(Scaevola coriacea) (Scaevola coriacea) Dicot Terrestrial

Navarretia, Few-flowered (Navarretia leucocephala ssp. Dicot Terrestrial, Vernal pool Navarretia, 

Many-flowered (Navarretia leucocephala ssp. Dicot Terrestrial, Vernal pool

Pauciflora) plieantha)

Navarretia, Spreading (Navarretia fossalis) Dicot Vernal pool Nehe 

(Lipochaeta lobata var. leptophylla) (Lipochaeta lobata Dicot Terrestrial

var. leptophylla)

Neraudia angulata (ncn) (Neraudia angulata) Dicot Terrestrial Neraudia ovata 

(ncn) (Neraudia ovata) Dicot Terrestrial

Neraudia sericea (ncn) (Neraudia sericea) Dicot Terrestrial Nioi (Eugenia 

koolauensis) (Eugenia koolauensis) Dicot Terrestrial

Niterwort, Amargosa (Nitrophila mohavensis) Dicot Terrestrial Nohoanu 

(Geranium multiflorum) (Geranium multiflorum) Dicot Terrestrial

Oak, Hinckley (Quercus hinckleyi) Dicot Terrestrial 'Oha (Delissea 

rivularis) (Delissea rivularis) Dicot Terrestrial

'Oha (Delissea subcordata) (Delissea subcordata) Dicot Terrestrial 'Oha (Delissea 

undulata) (Delissea undulata) Dicot Terrestrial

'Oha (Lobelia gaudichaudii koolauensis) (Lobelia gaudichaudii ssp. Dicot Terrestrial 

koolauensis) drepanomorpha)

'Oha Wai (Clermontia lindseyana) (Clermontia lindseyana) Dicot Terrestrial 'Oha Wai 

(Clermontia oblongifolia ssp. mauiensis) (Clermontia Dicot Terrestrial

oblongifolia ssp. 

mauiensis)

'Oha Wai (Clermontia peleana) (Clermontia peleana) Dicot Terrestrial 'Oha Wai 

(Clermontia pyrularia) (Clermontia pyrularia) Dicot Terrestrial

'Oha Wai (Clermontia samuelii) (Clermontia samuelii) Dicot Terrestrial 'Ohai (Sesbania 

tomentosa) (Sesbania tomentosa) Dicot Terrestrial

'Ohe'ohe (Tetraplasandra gymnocarpa) (Tetraplasandra Dicot Terrestrial 'Olulu 

(Brighamia insignis) (Brighamia insignis) Dicot Terrestrial

gymnocarpa)
90

Opuhe (Urera kaalae) (Urera kaalae) Dicot Terrestrial Oxytheca, 

Cushenbury (Oxytheca parishii var. goodmaniana) Dicot Terrestrial

Paintbrush, Ash-grey Indian (Castilleja cinerea) Dicot Terrestrial Paintbrush, 

Golden (Castilleja levisecta) Dicot Terrestrial

Paintbrush, San Clemente Island Indian (Castilleja grisea) Dicot Terrestrial Paintbrush, 

Soft-leaved (Castilleja mollis) Dicot Terrestrial

Paintbrush, Tiburon (Castilleja affinis ssp. neglecta) Dicot Terrestrial Pamakani 

(Viola chamissoniana ssp. chamissoniana) (Viola Dicot Terrestrial

chamissoniana 

ssp. chamissoniana)

Pawpaw, Beautiful (Deeringothamnus pulchellus) Dicot Terrestrial Pawpaw, Fourpetal (Asimina tetramera) Dicot Terrestrial

Pawpaw, Rugel's (Deeringothamnus rugelii) Dicot Terrestrial Penny-cress, 

Kneeland Prairie (Thlaspi californicum) Dicot Terrestrial

Pennyroyal, Todsen's (Hedeoma todsenii) Dicot Terrestrial Penstemon, 

Blowout (Penstemon haydenii) Dicot Terrestrial

Pentachaeta, Lyon's (Pentachaeta lyonii) Dicot Terrestrial Pentachaeta, 

White-rayed (Pentachaeta bellidiflora) Dicot Terrestrial

Peppergrass, Slick Spot (Lepidium papilliferum) Dicot Terrestrial, Floodplain Phacelia, Clay 

(Phacelia argillacea) Dicot Terrestrial

Phacelia, Island (Phacelia insularis ssp. insularis) Dicot Terrestrial Phacelia, North 

Park (Phacelia formosula) Dicot Terrestrial

Phlox, Texas Trailing (Phlox nivalis ssp. texensis) Dicot Terrestrial Phlox, Yreka 

(Phlox hirsuta) Dicot Terrestrial

Phyllostegia hirsuta (ncn) (Phyllostegia hirsuta) Dicot Terrestrial Phyllostegia 

kaalaensis (ncn) (Phyllostegia kaalaensis) Dicot Terrestrial

Phyllostegia knudsenii (ncn) (Phyllostegia knudsenii) Dicot Terrestrial Phyllostegia 

mannii (ncn) (Phyllostegia mannii) Dicot Terrestrial

Phyllostegia mollis (ncn) (Phyllostegia mollis) Dicot Terrestrial Phyllostegia 

parviflora (ncn) (Phyllostegia parviflora) Dicot Terrestrial

Phyllostegia velutina (ncn) (Phyllostegia velutina) Dicot Terrestrial Phyllostegia 

waimeae (ncn) (Phyllostegia waimeae) Dicot Terrestrial

Phyllostegia warshaueri (ncn) (Phyllostegia warshaueri) Dicot Terrestrial Phyllostegia 

wawrana (ncn) (Phyllostegia wawrana) Dicot Terrestrial

Pilo (Hedyotis mannii) (Hedyotis mannii) Dicot Terrestrial Pinkroot, 

Gentian (Spigelia gentianoides) Dicot Terrestrial

Pitaya, Davis' Green (Echinocereus viridiflorus var. davisii) Dicot Terrestrial Pitcher-plant, 

Alabama Canebrake (Sarracenia rubra alabamensis) Dicot Terrestrial, Freshwater

Pitcher-plant, Green (Sarracenia oreophila) Dicot Terrestrial, Freshwater Pitcher-plant, 

Mountain Sweet (Sarracenia rubra ssp. jonesii) Dicot Terrestrial, Freshwater

Plum, Scrub (Prunus geniculata) Dicot Terrestrial Po'e (Portulaca 

sclerocarpa) (Portulaca sclerocarpa) Dicot Terrestrial

Polygala, Lewton's (Polygala lewtonii) Dicot Terrestrial Polygala, Tiny 

(Polygala smallii) Dicot Terrestrial

Polygonum, Scott's Valley (Polygonum hickmanii) Dicot Terrestrial Pondberry 

(Lindera melissifolia) Dicot Terrestrial

Poolfish, Pahrump (= Pahrump Killifish) (Empetrichthys latos) Dicot Freshwater Popcornflower, 

Rough (Plagiobothrys hirtus) Dicot Vernal pool

Popolo 'Aiakeakua (Solanum sandwicense) (Solanum Dicot Terrestrial Popolo Ku Mai 

(Solanum incompletum) (Solanum incompletum) Dicot Terrestrial

sandwicense)

Poppy, Sacramento Prickly (Argemone pleiacantha ssp. Dicot Terrestrial Poppy-mallow, 

Texas (Callirhoe scabriuscula) Dicot Terrestrial

pinnatisecta)

Potato-bean, Price's (Apios priceana) Dicot Terrestrial Potentilla, 

Hickman's (Potentilla hickmanii) Dicot Terrestrial

Prickly-apple, Fragrant (Cereus eriophorus var. fragrans) Dicot Terrestrial Primrose, 

Maguire (Primula maguirei) Dicot Terrestrial
91

Pua'ala (Brighamia rockii) (Brighamia rockii) Dicot Terrestrial Pussypaws, 

Mariposa (Calyptridium pulchellum) Dicot Terrestrial

Rattleweed, Hairy (Baptisia arachnifera) Dicot Terrestrial Reed-mustard, 

Barneby (Schoenocrambe barnebyi) Dicot Terrestrial

Reed-mustard, Shrubby (Schoenocrambe suffrutescens) Dicot Terrestrial Remya 

kauaiensis (ncn) (Remya kauaiensis) Dicot Terrestrial

Remya montgomeryi (ncn) (Remya montgomeryi) Dicot Terrestrial Remya, Maui 

(Remya mauiensis) Dicot Terrestrial

Rhododendron, Chapman (Rhododendron chapmanii) Dicot Terrestrial Ridge-cress 

(=Pepper-cress), Barneby (Lepidium barnebyanum) Dicot Terrestrial

Rock-cress, Braun's (Arabis perstellata E. L. Braun var. ampla Dicot Terrestrial Rock-cress, 

Hoffmann's (Arabis hoffmannii) Dicot Terrestrial

Rollins)

Rock-cress, McDonald's (Arabis mcdonaldiana) Dicot Terrestrial Rock-cress, 

Santa Cruz Island (Sibara filifolia) Dicot Terrestrial

Rock-cress, Shale Barren (Arabis serotina) Dicot Terrestrial Rock-cress, 

Small (Arabis perstellata E. L. Braun var. perstellata Dicot Terrestrial

Fernald)

Rosemary, Apalachicola (Conradina glabra) Dicot Terrestrial Rosemary, 

Cumberland (Conradina verticillata) Dicot Terrestrial

Rosemary, Etonia (Conradina etonia) Dicot Terrestrial Rosemary, 

Short-leaved (Conradina brevifolia) Dicot Terrestrial

Roseroot, Leedy's (Sedum integrifolium ssp. leedyi) Dicot Terrestrial Rush-pea, 

Slender (Hoffmannseggia tenella) Dicot Terrestrial

Rush-rose, Island (Helianthemum greenei) Dicot Terrestrial Sandalwood, 

Lanai (='Iliahi) (Santalum freycinetianum var. Dicot Terrestrial

lanaiense)

Sandlace (Polygonella myriophylla) Dicot Terrestrial Sand-verbena, 

Large-fruited (Abronia macrocarpa) Dicot Terrestrial

Sandwort, Bear Valley (Arenaria ursina) Dicot Terrestrial Sandwort, 

Cumberland (Arenaria cumberlandensis) Dicot Terrestrial

Sandwort, Marsh (Arenaria paludicola) Dicot Terrestrial, Freshwater Sanicula 

mariversa (ncn) (Sanicula mariversa) Dicot Terrestrial

Sanicula purpurea (ncn) (Sanicula purpurea) Dicot Terrestrial Schiedea 

haleakalensis (ncn) (Schiedea haleakalensis) Dicot Terrestrial

Schiedea helleri (ncn) (Schiedea helleri) Dicot Terrestrial Schiedea 

hookeri (ncn) (Schiedea hookeri) Dicot Terrestrial

Schiedea kaalae (ncn) (Schiedea kaalae) Dicot Terrestrial Schiedea 

kauaiensis (ncn) (Schiedea kauaiensis) Dicot Terrestrial

Schiedea membranacea (ncn) (Schiedea membranacea) Dicot Terrestrial Schiedea 

nuttallii (ncn) (Schiedea nuttallii) Dicot Terrestrial

Schiedea spergulina var. leiopoda (ncn) (Schiedea spergulina var. Dicot Terrestrial Schiedea 

spergulina var. spergulina (ncn) (Schiedea spergulina var. Dicot Terrestrial

leiopoda) spergulina)

Schiedea, Diamond Head (Schiedea adamantis) (Schiedea 

adamantis)

Silene hawaiiensis (ncn) (Silene hawaiiensis) Dicot Terrestrial Silene 

lanceolata (ncn) (Silene lanceolata) Dicot Terrestrial

Silene perlmanii (ncn) (Silene perlmanii) Dicot Terrestrial Silversword, 

Haleakala ('Ahinahina) (Argyroxiphium sandwicense Dicot Terrestrial

ssp. 

macrocephalum)

Silversword, Ka'u (Argyroxiphium kauense) (Argyroxiphium Dicot Terrestrial Silversword, 

Mauna Kea ('Ahinahina) (Argyroxiphium Dicot Terrestrial

kauense) sandwicense 

ssp. sandwicense)

Skullcap, Florida (Scutellaria floridana) Dicot Terrestrial Skullcap, Largeflowered (Scutellaria montana) Dicot Terrestrial
92

Snakeroot (Eryngium cuneifolium) Dicot Terrestrial Sneezeweed, 

Virginia (Helenium virginicum) Dicot Vernal pool

Snowbells, Texas (Styrax texanus) Dicot Terrestrial Spermolepis 

hawaiiensis (ncn) (Spermolepis hawaiiensis) Dicot Terrestrial

Spineflower, Ben Lomond (Chorizanthe pungens var. Dicot Terrestrial Spineflower, 

Howell's (Chorizanthe howellii) Dicot Terrestrial

hartwegiana)

Spineflower, Monterey (Chorizanthe pungens var. pungens) Dicot Terrestrial Spineflower, 

Orcutt's (Chorizanthe orcuttiana) Dicot Terrestrial

Spineflower, Robust (Chorizanthe robusta va r. robusta) Dicot Terrestrial Spineflower, 

Scotts Valley (Chorizanthe robusta var. hartwegii) Dicot Terrestrial

Spineflower, Slender-horned (Dodecahema leptoceras) Dicot Terrestrial Spineflower, 

Sonoma (Chorizanthe valida) Dicot Terrestrial

Spiraea, Virginia (Spiraea virginiana) Dicot Terrestrial Spurge, Deltoid 

(Chamaesyce deltoidea ssp. deltoidea) Dicot Terrestrial

Spurge, Garber's (Chamaesyce garberi) Dicot Terrestrial Spurge, 

Hoover's (Chamaesyce hooveri) Dicot Vernal pool

Spurge, Telephus (Euphorbia telephioides) Dicot Terrestrial Stenogyne 

angustifolia (ncn) (Stenogyne angustifolia var. Dicot Terrestrial

angustifolia)

Stenogyne campanulata (ncn) (Stenogyne campanulata) Dicot Terrestrial Stenogyne 

kanehoana (ncn) (Stenogyne kanehoana) Dicot Terrestrial

Stickseed, Showy (Hackelia venusta) Dicot Terrestrial Stickyseed, 

Baker's (Blennosperma bakeri) Dicot Vernal pool

Stonecrop, Lake County (Parvisedum leiocarpum) Dicot Vernal pool Sumac, 

Michaux's (Rhus michauxii) Dicot Terrestrial

Sunflower, Pecos (Helianthus paradoxus) Dicot Terrestrial, Perm. Sunflower, San 

Mateo Woolly (Eriophyllum latilobum) Dicot Terrestrial

wetland

Sunflower, Schweinitz's (Helianthus schweinitzii) Dicot Terrestrial Sunray, Ash 

Meadows (Enceliopsis nudicaulis var. corrugata) Dicot Terrestrial

Taraxacum, California (Taraxacum californicum) Dicot Terrestrial Tarplant, 

Gaviota (Deinandra increscens ssp. villosa) Dicot Terrestrial

Tarplant, Otay (Deinandra (=Hemizonia) conjugens) Dicot Terrestrial Tarplant, Santa 

Cruz (Holocarpha macradenia) Dicot Terrestrial

Tetramolopium arenarium (ncn) (Tetramolopium arenarium) Dicot Terrestrial Tetramolopium 

capillare (ncn) (Tetramolopium capillare) Dicot Terrestrial

Tetramolopium filiforme (ncn) (Tetramolopium filiforme) Dicot Terrestrial Tetramolopium 

lepidotum ssp. lepidotum (ncn) (Tetramolopium Dicot Terrestrial

lepidotum ssp. 

lepidotum)

Tetramolopium remyi (ncn) (Tetramolopium remyi) Dicot Terrestrial Thelypody, 

Howell's Spectacular (Thelypodium howellii Dicot Terrestrial

spectabilis)

Thistle, Chorro creek Bog (Cirsium fontinale var. obispoense) Dicot Terrestrial, Freshwater Thistle, 

Fountain (Cirsium fontinale var. fontinale) Dicot Terrestrial

Thistle, La Graciosa (Cirsium loncholepis) Dicot Freshwater, Brackish, Thistle, 

Pitcher's (Cirsium pitcheri) Dicot Terrestrial

Coastal

Thistle, Sacramento Mountains (Cirsium vinaceum) Dicot Terrestrial Thistle, Suisun 

(Cirsium hydrophilum var. hydrophilum) Dicot Terrestrial, Brackish

Thornmint, San Diego (Acanthomintha ilicifolia) Dicot Terrestrial Thornmint, San 

Mateo (Acanthomintha obovata ssp. duttonii) Dicot Terrestrial

Townsendia, Last Chance (Townsendia aprica) Dicot Terrestrial Trematolobelia 

singularis (ncn) (Trematolobelia singularis) Dicot Terrestrial

Tuctoria, Green's (Tuctoria greenei) Dicot Vernal pool Twinpod, 

Dudley Bluffs (Physaria obcordata) Dicot Terrestrial

Uhiuhi (Caesalpinia kavaiensis) (Caesalpinia kavaiense) Dicot Terrestrial Umbel, 
93

Huachuca Water (Lilaeopsis schaffneriana var. recurva) Dicot Terrestrial, Freshwater

Vervain, California (Verbena californica) Dicot Terrestrial Vetch, 

Hawaiian (Vicia menziesii) (Vicia menziesii) Dicot Terrestrial

Vigna o-wahuensis (ncn) (Vigna o-wahuensis) Dicot Terrestrial Viola helenae 

(ncn) (Viola helenae) Dicot Terrestrial

Viola oahuensis (ncn) (Viola oahuensis) Dicot Terrestrial Wahine Noho 

Kula (Isodendrion pyrifolium) (Isodendrion Dicot Terrestrial

pyrifolium)

Wallflower, Ben Lomond (Erysimum teretifolium) Dicot Terrestrial Wallflower, 

Contra Costa (Erysimum capitatum var. angustatum) Dicot Terrestrial

Wallflower, Menzie's (Erysimum menziesii) Dicot Terrestrial Warea, Wideleaf (Warea amplexifolia) Dicot Terrestrial

Watercress, Gambel's (Rorippa gambellii) Dicot Terrestrial, Freshwater, Water-willow, 

Cooley's (Justicia cooleyi) Dicot Terrestrial

Brackish

Whitlow-wort, Papery (Paronychia chartacea) Dicot Terrestrial Wildbuckwheat, Clay-loving (Eriogonum pelinophilum) Dicot Terrestrial

Wild-buckwheat, Gypsum (Eriogonum gypsophilum) Dicot Terrestrial Wings, Pigeon 

(Clitoria fragrans) Dicot Terrestrial

Wireweed (Polygonella basiramia) Dicot Terrestrial Woodland-star, 

San Clemente Island (Lithophragma maximum) Dicot Terrestrial

Woolly-star, Santa Ana River (Eriastrum densifolium ssp. Dicot Terrestrial Woolly-threads, 

San Joaquin (Monolopia (=Lembertia) congdonii) Dicot Terrestrial

sanctorum)

Xylosma crenatum (ncn) (Xylosma crenatum) Dicot Terrestrial Yellowhead, 

Desert (Yermo xanthocephalus) Dicot Terrestrial

Yerba Santa, Lompoc (Eriodictyon capitatum) Dicot Terrestrial Ziziphus, 

Florida (Ziziphus celata) Dicot Terrestrial

Diellia erecta (ncn) (Diellia erecta) Ferns Terrestrial Diellia falcata 

(ncn) (Diellia falcata) Ferns Terrestrial

Diellia pallida (ncn) (Diellia pallida) Ferns Terrestrial Diellia unisora 

(ncn) (Diellia unisora) Ferns Terrestrial

Diplazium molokaiense (ncn) (Diplazium molokaiense) Ferns Terrestrial Fern, Alabama 

Streak-sorus (Thelypteris pilosa var. alabamensis) Ferns Terrestrial

Fern, American hart's-tongue (Asplenium scolopendrium var. Ferns Terrestrial Fern, Pendant 

Kihi (Adenophorus periens) (Adenophorus Ferns Terrestrial

americanum)

'Ihi'Ihi (Marsilea villosa) (Marsilea villosa) Ferns Terrestrial, Vernal pool Pauoa (Ctenitis 

squamigera) (Ctenitis squamigera) Ferns Terrestrial

Pteris lidgatei (ncn) (Pteris lidgatei) Ferns Terrestrial Quillwort, 

Black-spored (Isoetes melanospora) Ferns Vernal pool

Quillwort, Louisiana (Isoetes louisianensis) Ferns Terrestrial, Freshwater Quillwort, Matforming (Isoetes tegetiformans) Ferns Vernal pool

Wawae'Iole (Phlegmariurus (=Huperzia) mannii) (Huperzia Ferns Terrestrial Catfish, Yaqui 

(Ictalurus pricei) Fish Freshwater

mannii)

Cavefish, Alabama (Speoplatyrhinus poulsoni) Fish Freshwater Cavefish, Ozark 

(Amblyopsis rosae) Fish Freshwater

Chub, Bonytail (Gila elegans) Fish Freshwater Chub, 

Chihuahua (Gila nigrescens) Fish Freshwater

Chub, Gila (Gila intermedia) Fish Freshwater Chub, 

Humpback (Gila cypha) Fish Freshwater

Chub, Hutton Tui (Gila bicolor ssp.) Fish Freshwater Chub, Mohave 

Tui (Gila bicolor mohavensis) Fish Freshwater

Chub, Oregon (Oregonichthys crameri) Fish Freshwater Chub, 

Pahranagat Roundtail (Gila robusta jordani) Fish Freshwater Chub, Slender 

(Erimystax cahni) Fish Freshwater Chub, Sonora 

(Gila ditaenia) Fish Freshwater

Chub, Spotfin (Erimonax monachus) Fish Freshwater Chub, Virgin 
94

River (Gila seminuda (=robusta)) Fish Freshwater

Chub, Yaqui (Gila purpurea) Fish Freshwater Cui-ui 

(Chasmistes cujus) Fish Freshwater

Dace, Ash Meadows Speckled (Rhinichthys osculus nevadensis) Fish Freshwater Dace, Blackside 

(Phoxinus cumberlandensis) Fish Freshwater

Dace, Clover Valley Speckled (Rhinichthys osculus oligoporus) Fish Freshwater Dace, Desert 

(Eremichthys acros) Fish Freshwater

Dace, Foskett Speckled (Rhinichthys osculus ssp.) Fish Freshwater Dace, 

Independence Valley Speckled (Rhinichthys osculus Fish Freshwater

lethoporus)

Dace, Moapa (Moapa coriacea) Fish Freshwater Darter, Amber 

(Percina antesella) Fish Freshwater

Darter, Bayou (Etheostoma rubrum) Fish Freshwater Darter, 

Bluemask (=jewel) (Etheostoma sp.) Fish Freshwater

Darter, Boulder (Etheostoma wapiti) Fish Freshwater Darter, 

Cherokee (Etheostoma scotti) Fish Freshwater

Darter, Duskytail (Etheostoma percnurum) Fish Freshwater Darter, Etowah 

(Etheostoma etowahae) Fish Freshwater

Darter, Fountain (Etheostoma fonticola) Fish Freshwater Darter, Goldline 

(Percina aurolineata) Fish Freshwater

Darter, Leopard (Percina pantherina) Fish Freshwater Darter, 

Maryland (Etheostoma sellare) Fish Freshwater

Darter, Niangua (Etheostoma nianguae) Fish Freshwater Darter, 

Okaloosa (Etheostoma okaloosae) Fish Freshwater

Darter, Relict (Etheostoma chienense) Fish Freshwater Darter, 

Slackwater (Etheostoma boschungi) Fish Freshwater

Darter, Snail (Percina tanasi) Fish Freshwater Darter, 

Vermilion (Etheostoma chermocki) Fish Freshwater

Darter, Watercress (Etheostoma nuchale) Fish Freshwater Gambusia, Big 

Bend (Gambusia gaigei) Fish Freshwater

Gambusia, Clear Creek (Gambusia heterochir) Fish Freshwater Gambusia, 

Pecos (Gambusia nobilis) Fish Freshwater

Gambusia, San Marcos (Gambusia georgei) Fish Freshwater Goby, 

Tidewater (Eucyclogobius newberryi) Fish Freshwater

Logperch, Conasauga (Percina jenkinsi) Fish Freshwater Logperch, 

Roanoke (Percina rex) Fish Freshwater

Madtom, Neosho (Noturus placidus) Fish Freshwater Madtom, 

Pygmy (Noturus stanauli) Fish Freshwater

Madtom, Scioto (Noturus trautmani) Fish Freshwater Madtom, 

Smoky (Noturus baileyi) Fish Freshwater

Madtom, Yellowfin (Noturus flavipinnis) Fish Freshwater Minnow, Devils 

River (Dionda diaboli) Fish Freshwater

Minnow, Loach (Tiaroga cobitis) Fish Freshwater Minnow, Rio 

Grande Silvery (Hybognathus amarus) Fish Freshwater

Pupfish, Ash Meadows Amargosa (Cyprinodon nevadensis Fish Freshwater Pupfish, 

Comanche Springs (Cyprinodon elegans) Fish Freshwater

mionectes)

Pupfish, Desert (Cyprinodon macularius) Fish Freshwater Pupfish, Devils 

Hole (Cyprinodon diabolis) Fish Freshwater

Pupfish, Leon Springs (Cyprinodon bovinus) Fish Freshwater Pupfish, Warm 

Springs (Cyprinodon nevadensis pectoralis) Fish Freshwater

Salmon, Atlantic (Salmo salar) Fish Freshwater, Brackish, Salmon, 

Chinook (Oncorhynchus (=Salmo) tshawytscha) Fish Freshwater, Brackish, 

Saltwater 

Salmon, Chum (Oncorhynchus (=Salmo) keta) Fish Freshwater, Brackish, Salmon, Coho 

(Oncorhynchus (=Salmo) kisutch) Fish Freshwater, Brackish, 

Saltwater 

Salmon, Sockeye (Oncorhynchus (=Salmo) nerka) Fish Freshwater, Brackish, Sawfish, 

Smalltooth (Pristis pectinata) Fish Freshwater, Brackish, 
95

Saltwater 

Shiner, Beautiful (Cyprinella formosa) Fish Freshwater Shiner, Blue 

(Cyprinella caerulea) Fish Freshwater

Shiner, Cahaba (Notropis cahabae) Fish Freshwater Shiner, Cape 

Fear (Notropis mekistocholas) Fish Freshwater

Shiner, Palezone (Notropis albizonatus) Fish Freshwater Shiner, Pecos 

Bluntnose (Notropis simus pecosensis) Fish Freshwater

Shiner, Topeka (Notropis topeka (=tristis)) Fish Freshwater Silverside, 

Waccamaw (Menidia extensa) Fish Freshwater

Smelt, Delta (Hypomesus transpacificus) Fish Freshwater, Brackish Spikedace 

(Meda fulgida) Fish Freshwater

Spinedace, Big Spring (Lepidomeda mollispinis pratensis) Fish Freshwater Spinedace, 

Little Colorado (Lepidomeda vittata) Fish Freshwater

Spinedace, White River (Lepidomeda albivallis) Fish Freshwater Springfish, Hiko 

White River (Crenichthys baileyi grandis) Fish Freshwater

Springfish, Railroad Valley (Crenichthys nevadae) Fish Freshwater Springfish, 

White River (Crenichthys baileyi baileyi) Fish Freshwater

Squawfish, Colorado (Ptychocheilus lucius) Fish Freshwater Steelhead 

(Oncorhynchus (=Salmo) mykiss) Fish Freshwater, Brackish, Saltwater

Stickleback, Unarmored Threespine (Gasterosteus aculeatus Fish Freshwater Sturgeon, 

Alabama (Scaphirhynchus suttkusi) Fish Freshwater

williamsoni)

Sturgeon, Gulf (Acipenser oxyrinchus desotoi) Fish Freshwater, Saltwater Sturgeon, North 

American green (Acipenser medirostris) Fish Freshwater, Saltwater

Sturgeon, Pallid (Scaphirhynchus albus) Fish Freshwater Sturgeon, 

Shortnose (Acipenser brevirostrum) Fish Freshwater, Saltwater

Sturgeon, White (Acipenser transmontanus) Fish Freshwater, Saltwater Sucker, June 

(Chasmistes liorus) Fish Freshwater

Sucker, Lost River (Deltistes luxatus) Fish Freshwater Sucker, Modoc 

(Catostomus microps) Fish Freshwater

Sucker, Razorback (Xyrauchen texanus) Fish Freshwater Sucker, Santa 

Ana (Catostomus santaanae) Fish Freshwater

Sucker, Shortnose (Chasmistes brevirostris) Fish Freshwater Sucker, Warner 

(Catostomus warnerensis) Fish Freshwater

Topminnow, Gila (Yaqui) (Poeciliopsis occidentalis) Fish Freshwater Trout, Apache 

(Oncorhynchus apache) Fish Freshwater

Trout, Bull (Salvelinus confluentus) Fish Freshwater Trout, Gila 

(Oncorhynchus gilae) Fish Freshwater

Trout, Greenback Cutthroat (Oncorhynchus clarki stomias) Fish Freshwater Trout, Lahontan 

Cutthroat (Oncorhynchus clarki henshawi) Fish Freshwater

Trout, Little Kern Golden (Oncorhynchus aguabonita whitei) Fish Freshwater Trout, Paiute 

Cutthroat (Oncorhynchus clarki seleniris) Fish Freshwater

Woundfin (Plagopterus argentissimus) Fish Freshwater Abalone, White 

(Haliotis sorenseni) Gastropod Saltwater

Ambersnail, Kanab (Oxyloma haydeni kanabensis) Gastropod Terrestrial, Freshwater Campeloma, 

Slender (Campeloma decampi) Gastropod Freshwater

Cavesnail, Tumbling Creek (Antrobia culveri) Gastropod Freshwater, Elimia, Lacy 

(Elimia crenatella) Gastropod Freshwater

Subterraneous

Limpet, Banbury Springs (Lanx sp.) Gastropod Freshwater Marstonia, 

Royal (=Royal Snail) (Pyrgulopsis ogmorhaphe) Gastropod Terrestrial

Pebblesnail, Flat (Lepyrium showalteri) Gastropod Freshwater Riversnail, 

Anthony's (Athearnia anthonyi) Gastropod Freshwater

Rocksnail, Painted (Leptoxis taeniata) Gastropod Freshwater Rocksnail, 

Plicate (Leptoxis plicata) Gastropod Freshwater

Rocksnail, Round (Leptoxis ampla) Gastropod Freshwater Shagreen, 

Magazine Mountain (Mesodon magazinensis) Gastropod Terrestrial

Snail, Armored (Pyrgulopsis (=Marstonia) pachyta) Gastropod Freshwater Snail, Bliss 
96

Rapids (Taylorconcha serpenticola) Gastropod Freshwater

Snail, Chittenango Ovate Amber (Succinea chittenangoensis) Gastropod Terrestrial, Freshwater Snail, Flatspired Three-toothed (Triodopsis platysayoides) Gastropod Terrestrial

Snail, Iowa Pleistocene (Discus macclintocki) Gastropod Terrestrial Snail, Lioplax 

Cylindrical (Lioplax cyclostomaformis) Gastropod Freshwater

Snail, Morro Shoulderband (Helminthoglypta walkeriana) Gastropod Terrestrial Snail, 

Newcomb's (Erinna newcombi) Gastropod Freshwater

Snail, Noonday (Mesodon clarki nantahala) Gastropod Terrestrial Snail, O'ahu 

Tree (Achatinella abbreviata) (Achatinella Gastropod Terrestrial

abbreviata)

Snail, O'ahu Tree (Achatinella apexfulva) (Achatinella Gastropod Terrestrial Snail, O'ahu 

Tree (Achatinella bellula) (Achatinella bellula) Gastropod Terrestrial

Snail, O'ahu Tree (Achatinella buddii) (Achatinella buddii) Gastropod Terrestrial Snail, O'ahu 

Tree (Achatinella bulimoides) (Achatinella Gastropod Terrestrial

bulimoides)

Snail, O'ahu Tree (Achatinella byronii) (Achatinella byronii) Gastropod Terrestrial Snail, O'ahu 

Tree (Achatinella caesia) (Achatinella caesia) Gastropod Terrestrial

Snail, O'ahu Tree (Achatinella casta) (Achatinella casta) Gastropod Terrestrial Snail, O'ahu 

Tree (Achatinella cestus) (Achatinella cestus) Gastropod Terrestrial

Snail, O'ahu Tree (Achatinella concavospira) (Achatinella Gastropod Terrestrial Snail, O'ahu 

Tree (Achatinella curta) (Achatinella curta) Gastropod Terrestrial

concavospira)

Snail, O'ahu Tree (Achatinella decipiens) (Achatinella decipiens) Gastropod Terrestrial Snail, O'ahu 

Tree (Achatinella decora) (Achatinella decora) Gastropod Terrestrial

Snail, O'ahu Tree (Achatinella dimorpha) (Achatinella dimorpha) Gastropod Terrestrial Snail, O'ahu 

Tree (Achatinella elegans) (Achatinella elegans) Gastropod Terrestrial

Snail, O'ahu Tree (Achatinella fulgens) (Achatinella fulgens) Gastropod Terrestrial Snail, O'ahu 

Tree (Achatinella fuscobasis) (Achatinella Gastropod Terrestrial

fuscobasis)

Snail, O'ahu Tree (Achatinella juddii) (Achatinella juddii) Gastropod Terrestrial Snail, O'ahu 

Tree (Achatinella juncea) (Achatinella juncea) Gastropod Terrestrial

Snail, O'ahu Tree (Achatinella lehuiensis) (Achatinella lehuiensis) Gastropod Terrestrial Snail, O'ahu 

Tree (Achatinella leucorraphe) (Achatinella Gastropod Terrestrial

leucorraphe)

Snail, O'ahu Tree (Achatinella lila) (Achatinella lila) Gastropod Terrestrial Snail, O'ahu 

Tree (Achatinella livida) (Achatinella livida) Gastropod Terrestrial

Snail, O'ahu Tree (Achatinella lorata) (Achatinella lorata) Gastropod Terrestrial Snail, O'ahu 

Tree (Achatinella mustelina) (Achatinella mustelina) Gastropod Terrestrial

Snail, O'ahu Tree (Achatinella papyracea) (Achatinella Gastropod Terrestrial Snail, O'ahu 

Tree (Achatinella phaeozona) (Achatinella Gastropod Terrestrial

phaeozona)

Snail, O'ahu Tree (Achatinella pulcherrima) (Achatinella Gastropod Terrestrial Snail, O'ahu 

Tree (Achatinella pupukanioe) (Achatinella Gastropod Terrestrial

pulcherrima) pupukanioe)

Snail, O'ahu Tree (Achatinella rosea) (Achatinella rosea) Gastropod Terrestrial Snail, O'ahu 

Tree (Achatinella sowerbyana) (Achatinella Gastropod Terrestrial

sowerbyana)

Snail, O'ahu Tree (Achatinella spaldingi) (Achatinella spaldingi) Gastropod Terrestrial Snail, O'ahu 

Tree (Achatinella stewartii) (Achatinella stewartii) Gastropod Terrestrial

Snail, O'ahu Tree (Achatinella swiftii) (Achatinella swiftii) Gastropod Terrestrial Snail, O'ahu 

Tree (Achatinella taeniolata) (Achatinella taeniolata) Gastropod Terrestrial

Snail, O'ahu Tree (Achatinella thaanumi) (Achatinella thaahumi) Gastropod Terrestrial Snail, O'ahu 

Tree (Achatinella turgida) (Achatinella turgida) Gastropod Terrestrial

Snail, O'ahu Tree (Achatinella valida) (Achatinella valida) Gastropod Terrestrial Snail, O'ahu 

Tree (Achatinella viridans) (Achatinella viridans) Gastropod Terrestrial

Snail, O'ahu Tree (Achatinella vittata) (Achatinella vittata) Gastropod Terrestrial Snail, O'ahu 

Tree (Achatinella vulpina) (Achatinella vulpina) Gastropod Terrestrial

Snail, Painted Snake Coiled Forest (Anguispira picta) Gastropod Terrestrial Snail, Pecos 

Assiminea (Assiminea pecos) Gastropod Freshwater
97

Snail, Snake River Physa (Physa natricina) Gastropod Terrestrial Snail, Tulotoma 

(Tulotoma magnifica) Gastropod Terrestrial

Snail, Virginia Fringed Mountain (Polygyriscus virginianus) Gastropod Terrestrial Springsnail, 

Alamosa (Tryonia alamosae) Gastropod Freshwater

Springsnail, Bruneau Hot (Pyrgulopsis bruneauensis) Gastropod Freshwater Springsnail, 

Koster's (Juturnia kosteri) Gastropod Terrestrial

Springsnail, Roswell (Pyrgulopsis roswellensis) Gastropod Freshwater Beetle, 

American Burying (Nicrophorus americanus) Insect Terrestrial

Beetle, Coffin Cave Mold (Batrisodes texanus) Insect Subterraneous Beetle, Comal 

Springs Dryopid (Stygoparnus comalensis) Insect Freshwater, 

Beetle, Comal Springs Riffle (Heterelmis comalensis) Insect Freshwater, Beetle, Delta 

Green Ground (Elaphrus viridis) Insect Terrestrial, Vernal pool

Subterraneous

Beetle, Helotes Mold (Batrisodes venyivi) Insect Subterraneous Beetle, 

Hungerford's Crawling Water (Brychius hungerfordi) Insect Freshwater

Beetle, Kretschmarr Cave Mold (Texamaurops reddelli) Insect Subterraneous Beetle, Mount 

Hermon June (Polyphylla barbata) Insect Terrestrial, 

Beetle, Northeastern Beach Tiger (Cicindela dorsalis dorsalis) Insect Terrestrial Beetle, Ohlone 

Tiger (Cicindela ohlone) Insect Terrestrial

Beetle, Puritan Tiger (Cicindela puritana) Insect Terrestrial, Coastal Beetle, Salt 

Creek Tiger (Cicindela nevadica lincolniana) Insect Terrestrial

Beetle, Tooth Cave Ground (Rhadine persephone) Insect Subterraneous Beetle, Valley 

Elderberry Longhorn (Desmocerus californicus Insect Terrestrial

dimorphus)

Butterfly, Bay Checkerspot (Wright's euphydryas) (Euphydryas Insect Terrestrial Butterfly, 

Behren's Silverspot (Speyeria zerene behrensii) Insect Terrestrial

editha bayensis)

Butterfly, Callippe Silverspot (Speyeria callippe callippe) Insect Terrestrial Butterfly, El 

Segundo Blue (Euphilotes battoides allyni) Insect Terrestrial

Butterfly, Fender's Blue (Icaricia icarioides fenderi) Insect Terrestrial Butterfly, 

Karner Blue (Lycaeides melissa samuelis) Insect Terrestrial

Butterfly, Lange's Metalmark (Apodemia mormo langei) Insect Terrestrial Butterfly, Lotis 

Blue (Lycaeides argyrognomon lotis) Insect Terrestrial

Butterfly, Mission Blue (Icaricia icarioides missionensis) Insect Terrestrial Butterfly, 

Mitchell's Satyr (Neonympha mitchellii mitchellii) Insect Terrestrial, Perm. 

Butterfly, Myrtle's Silverspot (Speyeria zerene myrtleae) Insect Terrestrial Butterfly, 

Oregon Silverspot (Speyeria zerene hippolyta) Insect Terrestrial

Butterfly, Palos Verdes Blue (Glaucopsyche lygdamus Insect Terrestrial Butterfly, Quino 

Checkerspot (Euphydryas editha quino (=E. e. Insect Terrestrial

palosverdesensis) wrighti))

Butterfly, Saint Francis' Satyr (Neonympha mitchellii francisci) Insect Terrestrial Butterfly, San 

Bruno Elfin (Callophrys mossii bayensis) Insect Terrestrial

Butterfly, Smith's Blue (Euphilotes enoptes smithi) Insect Terrestrial Butterfly, 

Uncompahgre Fritillary (Boloria acrocnema) Insect Terrestrial

Dragonfly, Hine's Emerald (Somatochlora hineana) Insect Terrestrial, Freshwater Fly, Delhi 

Sands Flower-loving (Rhaphiomidas terminatus Insect Terrestrial

abdominalis)

Fly, Hawaiian picture-wing (Drosophila heteroneura) Insect Terrestrial Fly, Hawaiian 

picture-wing (Drosophila montgomeryi) Insect Terrestrial

Fly, Hawaiian picture-wing (Drosophila aglaia) Insect Terrestrial Fly, Hawaiian 

picture-wing (Drosophila tarphytrichia) Insect Terrestrial

Fly, Hawaiian picture-wing (Drosophila mulli) Insect Terrestrial Fly, Hawaiian 

picture-wing (Drosophila musaphilia) Insect Terrestrial

Fly, Hawaiian picture-wing (Drosophila neoclavisetae) Insect Terrestrial Fly, Hawaiian 

picture-wing (Drosophila obatai) Insect Terrestrial
98

Fly, Hawaiian picture-wing (Drosophila substenoptera) Insect Terrestrial Fly, Hawaiian 

picture-wing (Drosophila hemipeza) Insect Terrestrial

Fly, Hawaiian picture-wing (Drosophila ochrobasis) Insect Terrestrial Grasshopper, 

Zayante Band-winged (Trimerotropis infantilis) Insect Terrestrial

Moth, Blackburn's Sphinx (Manduca blackburni) Insect Terrestrial Moth, Kern 

Primrose Sphinx (Euproserpinus euterpe) Insect Terrestrial

Naucorid, Ash Meadows (Ambrysus amargosus) Insect Terrestrial Rhadine exilis 

(ncn) (Rhadine exilis) Insect Terrestrial, 

Subterraneous

Skipper, Laguna Mountain (Pyrgus ruralis lagunae) Insect Terrestrial Skipper, 

Pawnee Montane (Hesperia leonardus montana) Insect Terrestrial

Cladonia, Florida Perforate (Cladonia perforata) Lichen Terrestrial Lichen, Rock 

Gnome (Gymnoderma lineare) Lichen Terrestrial

Bat, Gray (Myotis grisescens) Mammal Terrestrial, Bat, Hawaiian 

Hoary (Lasiurus cinereus semotus) Mammal Terrestrial, 

Subterraneous 

Bat, Indiana (Myotis sodalis) Mammal Terrestrial, Bat, Lesser 

(=Sanborn's) Long-nosed (Leptonycteris curasoae Mammal Terrestrial, 

Subterraneous yerbabuenae) 

Bat, Mexican Long-nosed (Leptonycteris nivalis) Mammal Terrestrial, Bat, Ozark Bigeared (Corynorhinus (=Plecotus) townsendii Mammal Terrestrial, 

Subterraneous ingens) 

Bat, Virginia Big-eared (Corynorhinus (=Plecotus) townsendii Mammal Terrestrial, Bear, American 

Black (Ursus americanus) Mammal Terrestrial

virginianus) Subterraneous

Bear, Grizzly (Ursus arctos horribilis) Mammal Terrestrial Bear, Louisiana 

Black (Ursus americanus luteolus) Mammal Terrestrial

Caribou, Woodland (Rangifer tarandus caribou) Mammal Terrestrial Deer, 

Columbian White-tailed (Odocoileus virginianus leucurus) Mammal Terrestrial

Ferret, Black-footed (Mustela nigripes) Mammal Terrestrial Fox, San 

Joaquin Kit (Vulpes macrotis mutica) Mammal Terrestrial

Fox, San Miguel Island (Urocyon littoralis littoralis) Mammal Terrestrial Fox, Santa 

Catalina Island (Urocyon littoralis catalinae) Mammal Terrestrial

Fox, Santa Cruz Island (Urocyon littoralis santacruzae) Mammal Terrestrial Fox, Santa Rosa 

Island (Urocyon littoralis santarosae) Mammal Terrestrial

Jaguar (Panthera onca) Mammal Terrestrial Jaguarundi, 

Gulf Coast (Herpailurus (=Felis) yagouaroundi Mammal Terrestrial

cacomitli)

Kangaroo Rat, Fresno (Dipodomys nitratoides exilis) Mammal Terrestrial Kangaroo Rat, 

Giant (Dipodomys ingens) Mammal Terrestrial

Kangaroo Rat, Morro Bay (Dipodomys heermanni morroensis) Mammal Terrestrial Kangaroo Rat, 

San Bernardino Merriam's (Dipodomys merriami Mammal Terrestrial

parvus)

Kangaroo Rat, Stephens' (Dipodomys stephensi (incl. D. cascus)) Mammal Terrestrial Kangaroo Rat, 

Tipton (Dipodomys nitratoides nitratoides) Mammal Terrestrial

Lynx, Canada (Lynx canadensis) Mammal Terrestrial Manatee, West 

Indian (Trichechus manatus) Mammal Saltwater

Mountain Beaver, Point Arena (Aplodontia rufa nigra) Mammal Terrestrial, Freshwater Mouse, 

Alabama Beach (Peromyscus polionotus ammobates) Mammal Terrestrial, Coastal

Mouse, Anastasia Island Beach (Peromyscus polionotus phasma) Mammal Terrestrial, Coastal Mouse, 

Choctawhatchee Beach (Peromyscus polionotus Mammal Terrestrial, Coastal

allophrys)

Mouse, Pacific Pocket (Perognathus longimembris pacificus) Mammal Terrestrial Mouse, Perdido 

Key Beach (Peromyscus polionotus trissyllepsis) Mammal Coastal

Mouse, Preble's Meadow Jumping (Zapus hudsonius preblei) Mammal Terrestrial Mouse, Salt 

Marsh Harvest (Reithrodontomys raviventris) Mammal Terrestrial

Mouse, Southeastern Beach (Peromyscus polionotus niveiventris) Mammal Terrestrial, Coastal Mouse, St. 

Andrew Beach (Peromyscus polionotus peninsularis) Mammal Terrestrial, Coastal
99

Ocelot (Leopardus (=Felis) pardalis) Mammal Terrestrial Otter, Southern 

Sea (Enhydra lutris nereis) Mammal Saltwater

Panther, Florida (Puma (=Felis) concolor coryi) Mammal Terrestrial Prairie Dog, 

Utah (Cynomys parvidens) Mammal Terrestrial, 

Pronghorn, Sonoran (Antilocapra americana sonoriensis) Mammal Terrestrial Puma 

(=Cougar), Eastern (Puma (=Felis) concolor (all subsp. Mammal Terrestrial

except coryi))

Rabbit, Pygmy (Brachylagus idahoensis) Mammal Terrestrial Rabbit, Riparian 

Brush (Sylvilagus bachmani riparius) Mammal Terrestrial

Seal, Guadalupe Fur (Arctocephalus townsendi) Mammal Saltwater, Coastal Seal, Hawaiian 

Monk (Monachus schauinslandi) Mammal Saltwater, Coastal

Seal, spotted (Phoca largha) Mammal Saltwater Sea-lion, Steller 

(Eumetopias jubatus) Mammal Saltwater, Coastal

Sheep, Peninsular Bighorn (Ovis canadensis nelsoni) Mammal Terrestrial Sheep, Sierra 

Nevada Bighorn (Ovis canadensis sierrae) Mammal Terrestrial

Shrew, Buena Vista Lake Ornate (Sorex ornatus relictus) Mammal Terrestrial Squirrel, 

Carolina Northern Flying (Glaucomys sabrinus coloratus) Mammal Terrestrial

Squirrel, Delmarva Peninsula Fox (Sciurus niger cinereus) Mammal Terrestrial Squirrel, Mount 

Graham Red (Tamiasciurus hudsonicus Mammal Terrestrial

grahamensis)

Squirrel, Northern Idaho Ground (Spermophilus brunneus Mammal Terrestrial Vole, Florida 

Salt Marsh (Microtus pennsylvanicus Mammal Terrestrial, Brackish

brunneus) dukecampbelli)

Vole, Hualapai Mexican (Microtus mexicanus hualpaiensis) Mammal Terrestrial Whale, Blue 

(Balaenoptera musculus) Mammal Saltwater

Whale, Bowhead (Balaena mysticetus) Mammal Saltwater Whale, Finback 

(Balaenoptera physalus) Mammal Saltwater

Whale, Humpback (Megaptera novaeangliae) Mammal Saltwater Whale, North 

Atlantic right (Eubalaena glacialis (incl. australis)) Mammal Saltwater

Whale, North Pacific right (Eubalaena japonica) Mammal Saltwater Whale, Sei 

(Balaenoptera borealis) Mammal Saltwater

Whale, Sperm (Physeter catodon (=macrocephalus)) Mammal Saltwater Wolf, Red 

(Canis rufus) Mammal Terrestrial

Woodrat, Riparian (Neotoma fuscipes riparia) Mammal Terrestrial Alopecurus, 

Sonoma (Alopecurus aequalis var. sonomensis) Monocot Terrestrial

Amole, Cammatta Canyon (Chlorogalum purpureum var. Monocot Terrestrial Amole, Purple 

(Chlorogalum purpureum var. purpureum) Monocot Terrestrial

reductum)

Arrowhead, Bunched (Sagittaria fasciculata) Monocot Freshwater Beaked-rush, 

Knieskern's (Rhynchospora knieskernii) Monocot Terrestrial

Beargrass, Britton's (Nolina brittoniana) Monocot Terrestrial Beauty, 

Harper's (Harperocallis flava) Monocot Terrestrial, Freshwater

Bluegrass, Hawaiian (Poa sandvicensis) Monocot Terrestrial Bluegrass, 

Mann's (Poa mannii) (Poa mannii) Monocot Terrestrial

Bluegrass, Napa (Poa napensis) Monocot Terrestrial, Freshwater Bluegrass, San 

Bernardino (Poa atropurpurea) Monocot Terrestrial

Brodiaea, Chinese Camp (Brodiaea pallida) Monocot Terrestrial Brodiaea, 

Thread-leaved (Brodiaea filifolia) Monocot Terrestrial

Bulrush, Northeastern (=Barbed Bristle) (Scirpus ancistrochaetus) Monocot Terrestrial, Freshwater Fritillary, 

Gentner's (Fritillaria gentneri) Monocot Terrestrial

Grass, California Orcutt (Orcuttia californica) Monocot Terrestrial, Vernal pool Grass, Colusa 

(Neostapfia colusana) Monocot Vernal pool

Grass, Fosberg's Love (Eragrostis fosbergii) Monocot Terrestrial Grass, San 

Joaquin Valley Orcutt (Orcuttia inaequalis) Monocot Vernal pool

Grass, Solano (Tuctoria mucronata) Monocot Terrestrial, Vernal pool Grass, 

Tennessee Yellow-eyed (Xyris tennesseensis) Monocot Terrestrial

Hala Pepe (Pleomele hawaiiensis) (Pleomele hawaiiensis) Monocot Terrestrial Hilo Ischaemum 
100

(Ischaemum byrone) (Ischaemum byrone) Monocot Terrestrial

Iris, Dwarf Lake (Iris lacustris) Monocot Terrestrial Irisette, White 

(Sisyrinchium dichotomum) Monocot Terrestrial

Kamanomano (Cenchrus agrimonioides) (Cenchrus agrimonioides)Monocot Terrestrial Ladies'-tresses, 

Canelo Hills (Spiranthes delitescens) Monocot Terrestrial

Ladies'-tresses, Navasota (Spiranthes parksii) Monocot Terrestrial Ladies'-tresses, 

Ute (Spiranthes diluvialis) Monocot Terrestrial

Lau'ehu (Panicum niihauense) (Panicum niihauense) Monocot Terrestrial Lily, Minnesota 

Trout (Erythronium propullans) Monocot Terrestrial

Lily, Pitkin Marsh (Lilium pardalinum ssp. pitkinense) Monocot Freshwater Lily, Tiburon 

Mariposa (Calochortus tiburonensis) Monocot Terrestrial

Lily, Western (Lilium occidentale) Monocot Terrestrial Lo`ulu 

(Pritchardia affinis) (Pritchardia affinis) Monocot Terrestrial

Lo`ulu (Pritchardia kaalae) (Pritchardia kaalae) Monocot Terrestrial Lo`ulu 

(Pritchardia napaliensis) (Pritchardia napaliensis) Monocot Terrestrial

Lo`ulu (Pritchardia schattaueri) (Pritchardia schattaueri) Monocot Terrestrial Lo`ulu 

(Pritchardia viscosa) (Pritchardia viscosa) Monocot Terrestrial

Onion, Munz's (Allium munzii) Monocot Terrestrial Orchid, Eastern 

Prairie Fringed (Platanthera leucophaea) Monocot Terrestrial

Orchid, Western Prairie Fringed (Platanthera praeclara) Monocot Terrestrial Panicgrass, 

Carter's (Panicum fauriei var.carteri) (Panicum fauriei Monocot Terrestrial

var. carteri)

Pink, Swamp (Helonias bullata) Monocot Terrestrial, Freshwater Piperia, Yadon's 

(Piperia yadonii) Monocot Terrestrial

Platanthera holochila (ncn) (Platanthera holochila) Monocot Terrestrial Poa 

siphonoglossa (ncn) (Poa siphonoglossa) Monocot Terrestrial

Pogonia, Small Whorled (Isotria medeoloides) Monocot Terrestrial Pondweed, 

Little Aguja Creek (Potamogeton clystocarpus) Monocot Freshwater

Pu'uka'a (Cyperus trachysanthos) (Cyperus trachysanthos) Monocot Terrestrial Seagrass, 

Johnson's (Halophila johnsonii) Monocot Saltwater, Coastal

Sedge, Golden (Carex lutea) Monocot Terrestrial Sedge, Navajo 

(Carex specuicola) Monocot Terrestrial

Sedge, White (Carex albida) Monocot Terrestrial, Freshwater Trillium, 

Persistent (Trillium persistens) Monocot Terrestrial

Trillium, Relict (Trillium reliquum) Monocot Terrestrial Water-plantain, 

Kral's (Sagittaria secundifolia) Monocot Freshwater

Wild-rice, Texas (Zizania texana) Monocot Freshwater Alligator, 

American (Alligator mississippiensis) Reptile Terrestrial, Freshwater, 

Crocodile, American (Crocodylus acutus) Reptile Terrestrial, Freshwater Lizard, Bluntnosed Leopard (Gambelia silus) Reptile Terrestrial

Lizard, Coachella Valley Fringe-toed (Uma inornata) Reptile Terrestrial Lizard, Island 

Night (Xantusia riversiana) Reptile Terrestrial

Lizard, St. Croix Ground (Ameiva polops) Reptile Terrestrial Rattlesnake, 

New Mexican Ridge-nosed (Crotalus willardi Reptile Terrestrial

obscurus)

Sea turtle, green (Chelonia mydas) Reptile Saltwater Sea turtle, 

hawksbill (Eretmochelys imbricata) Reptile Saltwater, Coastal

Sea turtle, Kemp's ridley (Lepidochelys kempii) Reptile Saltwater, Coastal Sea turtle, 

leatherback (Dermochelys coriacea) Reptile Saltwater, Coastal

Sea turtle, loggerhead (Caretta caretta) Reptile Saltwater, Coastal Sea turtle, olive 

ridley (Lepidochelys olivacea) Reptile Saltwater

Skink, Blue-tailed Mole (Eumeces egregius lividus) Reptile Terrestrial Skink, Sand 

(Neoseps reynoldsi) Reptile Terrestrial

Snake, Atlantic Salt Marsh (Nerodia clarkii taeniata) Reptile Terrestrial, Brackish, Snake, Concho 

Water (Nerodia paucimaculata) Reptile Terrestrial, Freshwater

Saltwater

Snake, Eastern Indigo (Drymarchon corais couperi) Reptile Terrestrial Snake, Giant 
101

Garter (Thamnophis gigas) Reptile Terrestrial, Freshwater

Snake, Lake Erie Water (Nerodia sipedon insularum) Reptile Terrestrial, Freshwater Snake, Northern 

Copperbelly Water (Nerodia erythrogaster Reptile Terrestrial, Freshwater

neglecta)

Snake, San Francisco Garter (Thamnophis sirtalis tetrataenia) Reptile Terrestrial, Freshwater Tortoise, Desert 

(Gopherus agassizii) Reptile Terrestrial

Tortoise, Gopher (Gopherus polyphemus) Reptile Terrestrial Turtle, Alabama 

Red-bellied (Pseudemys alabamensis) Reptile Terrestrial, Freshwater

Turtle, Bog (Clemmys muhlenbergii) Reptile Terrestrial, Freshwater Turtle, Flattened 

Musk (Sternotherus depressus) Reptile Terrestrial, Freshwater

Turtle, Ringed Map (Graptemys oculifera) Reptile Terrestrial, Freshwater Turtle, Yellowblotched Map (Graptemys flavimaculata) Reptile Terrestrial, Freshwater

Whipsnake (=Striped Racer), Alameda (Masticophis lateralis Reptile Terrestrial

euryxanthus)

No species were selected for exclusion.

Dispersed species included in report.

Marine Species

Fish (Actinopterygii)

Common name Scientific name Family Order

Salmon, Atlantic Salmo salar Salmonidae Salmoniformes

Salmon, Chinook Oncorhynchus (=Salmo) tshawytschaSalmonidae Salmoniformes

Salmon, Chum Oncorhynchus (=Salmo) keta Salmonidae Salmoniformes

Salmon, Coho Oncorhynchus (=Salmo) kisutch Salmonidae Salmoniformes

Salmon, Sockeye Oncorhynchus (=Salmo) nerka Salmonidae Salmoniformes

Sawfish, Smalltooth Pristis pectinata Pristidae Pristiformes

Steelhead Oncorhynchus (=Salmo) mykiss Salmonidae Salmoniformes

Sturgeon, Gulf Acipenser oxyrinchus desotoi Acipenseridae Acipenseriformes

Sturgeon, North American green Acipenser medirostris Acipenseridae Acipenseriformes

Sturgeon, Shortnose Acipenser brevirostrum Acipenseridae Acipenseriformes

Sturgeon, White Acipenser transmontanus Acipenseridae Acipenseriformes

Gastropod (Gastropoda)

Common name Scientific name Family Order

Abalone, White Haliotis sorenseni Haliotidae Vetigastropoda

Mammal (Mammalia)

Common name Scientific name Family Order

Bear, polar Ursus maritimus Ursidae Carnivora

Manatee, West Indian Trichechus manatus Trichechidae Sirenia

Otter, Northern Sea Enhydra lutris kenyoni Mustelidae Carnivora

Otter, Southern Sea Enhydra lutris nereis Mustelidae Carnivora

Seal, Guadalupe Fur Arctocephalus townsendi Phocidae Carnivora

Seal, Hawaiian Monk Monachus schauinslandi Phocidae Carnivora

Seal, spotted Phoca largha Phocidae Carnivora

Sea-lion, Steller Eumetopias jubatus Otariidae Carnivora

Whale, Blue Balaenoptera musculus Balaenopteridae Cetacea

Whale, Bowhead Balaena mysticetus Balaenidae Cetacea

Whale, Finback Balaenoptera physalus Balaenopteridae Cetacea

Mammal (Mammalia)

Common name Scientific name Family Order
102

Whale, Humpback Megaptera novaeangliae Balaenopteridae Cetacea

Whale, North Atlantic right Eubalaena glacialis (incl. australis) Balaenidae Cetacea

Whale, North Pacific right Eubalaena japonica Balaenidae Cetacea

Whale, Sei Balaenoptera borealis Balaenopteridae Cetacea

Whale, Sperm Physeter catodon (=macrocephalus) Physeteridae Cetacea

Monocot (Liliopsida)

Common name Scientific name Family Order

Seagrass, Johnson's Halophila johnsonii Hydrocharitacea Alismatales

Reptile (Reptilia)

Common name Scientific name Family Order

Sea turtle, green Chelonia mydas Cheloniidae Testudines

Sea turtle, hawksbill Eretmochelys imbricata Cheloniidae Testudines

Sea turtle, Kemp's ridley Lepidochelys kempii Cheloniidae Testudines

Sea turtle, leatherback Dermochelys coriacea Dermochelyidae Testudines

Sea turtle, loggerhead Caretta caretta Cheloniidae Testudines

Sea turtle, olive ridley Lepidochelys olivacea Cheloniidae Testudines

Snake, Atlantic Salt Marsh Nerodia clarkii taeniata Colubridae Squamata