UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

OFFICE O 

OFFICE OF CHEMCICAL SAFETY AND 

POLLUTION PREVENTION 

Environmental Fate and Ecological Risk Assessment 

Problem Formulation 

In Support of Registration Review of Propamocarb-HCl 

Propamocarb-HCl (PC code: 119302, CAS No. 25606-41-1) 

Completed By: 

Mohammed Ruhman, PhD, Agronomist 

Justin Housenger, Biologist 

Environmental Risk Branch 5 

Environmental Fate and Effects Division 

September 20, 2011

Carbamate Moiety 

H+

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H3C

CH3

CH3

ClN

H

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1 
Table of Contents

1. Purpose ........................................................................................................................ 4

2. Problem Formulation .................................................................................................. 4

2.1 Nature of Regulatory Action ..................................................................................... 4

2.2 Previous Risk Assessments ....................................................................................... 4

3. Stressor Source and Distribution ................................................................................ 6

3.1 Mechanism of Action ................................................................................................ 6

3.2 Overview of Pesticide Usage .................................................................................... 7

3.3 Environmental Fate and Transport .......................................................................... 12

4. Ecological Effects ..................................................................................................... 20

4.1 Aquatic and Terrestrial Effects ............................................................................... 20

4.2 Incident Database Review ....................................................................................... 26

4.3 Ecosystems Potentially at Risk ............................................................................... 26

4.4 Assessment Endpoints ............................................................................................ 27

4.5 Conceptual Model ................................................................................................... 27

5. Analysis Plan ............................................................................................................ 31

5.1 Stressors of Concern ............................................................................................... 31

5.2 Measures of Exposure ............................................................................................. 31

5.3 Measures of Effect .................................................................................................. 32

5.4 Integration of Exposure and Effects ....................................................................... 34

5.5 Endangered Species Assessments ........................................................................... 34

5.6 Drinking Water Assessment ................................................................................... 34

5.7 Monitoring Data ...................................................................................................... 35

5.8 Clean Water Act ...................................................................................................... 35

5.9 Endocrine Disruptor Screening Program (EDSP) ................................................... 36

5.10 Uncertainty and Preliminary Identification of Data Gaps .................................... 37

Bibliography ..................................................................................................................... 41

2 
List of Tables 

Table 1 Propamocarb-HCl labeled vegetables use patterns and application parameters based on 

the latest revised labels submitted in 2010 (MxR= Maximum single Application Rate (lb a.i/A), 

MxNA= Maximum Number of Applications, MxSRT= Maximum seasonal rate (lb a.i/A), 

MnAI= Minimum Application Intervals in days) ........................................................................... 8

Table 2 Propamocarb-HCl labeled turf and ornamentals use patterns and application parameters 

based on the latest revised labels submitted in 2010 (MSR= Maximum single Application Rate 

(lb a.i/A), MNA= Maximum Number of Applications, MSRT= Maximum seasonal rate (lb a.i/A), 

MAI= Minimum Application Intervals in days).............................................................................. 9

Table 3 Screening Level Estimates of Agricultural Uses of Propamocarb-HCl (119302) sorted 

alphabetically ................................................................................................................................ 11

Table 4 Summary of physicochemical properties of Propamocarb-HCl ...................................... 13

Table 5 Summary of abiotic laboratory determined properties of Propamocarb-HCl .................. 14

Table 6 Summary of acceptable fate and transport properties for propamocarb-HCl .................. 17

Table 7 Terrestrial field dissipation studies data for Propamocarb-HCl ...................................... 18

Table 8 Test Species Evaluated for Assessing Potential Acute and Chronic Ecological Effects of 

Propamocarb-HCl ......................................................................................................................... 20

Table 9 Measures of Ecological Effects and Exposure for Propamocarb-HCl ............................ 33

Table 10. Environmental fate Data Requirements for Propamocarb-HCl ................................... 38

Table 11 Ecological Effects Data Requirements for Propamocarb-HCl ...................................... 39

List of Figures 

Figure 1 Screening Level Estimates of Agricultural Uses of Propamocarb-HCl ......................... 11

Figure 2 Propamocarb-HCl vegetable usage data from 1998 to 2008 (Pounds a.i Applied) ...... 12

Figure 3 A conceptual model for Propamocarb-HCl effects on aquatic organisms ..................... 29

Figure 4 A conceptual model of Propamocarb-HCl effects on terrestrial organisms ................... 30

APENDICIES 

Appendix A: Issues Associated with Current Labels for Propamocarb-HCl 

Appendix B: Fate Data for Propamocarb-HCl

3 
1. Purpose 

The purpose of this problem formulation is to provide the foundation for the ecological risk 

assessment being conducted for the registered uses of Propamocarb-hydrochloride 

(Propamocarb-HCl). As such, it articulates the purpose and objectives of the risk assessment, 

evaluates the nature of the problem, and provides a plan for analyzing the data and characterizing 

ecological risk (EPA, 1998). Additionally, this problem formulation is intended to identify data 

gaps, uncertainties, and potential assumptions needed to address those uncertainties in 

characterizing the ecological risk associated with the registered uses of Propamocarb-HCl. 

Propamocarb-HCl is a member of the carbamate family of fungicides. The chemical was initially 

registered in 1984 for use on turf and ornamental and currently has uses on potatoes, lettuce, 

cucurbits, and fruiting vegetables (such as tomatoes peppers), in addition to the original 

registration on turf, and ornamentals. Propamocarb-HCl is used as a liquid foliar spray prepared 

from the EC formulation. The chemical is used to control late blight (Phytophthora infestans), 

early blight (Altemaria solani), downy mildews, Phytophthora fruit rots, Pythium blight, 

Pythium damping off, root rot, dollar spot, brown patch, leaf spot, gray leaf spot, red thread, and 

Rhizoctonia.

2. Problem Formulation 

2.1 Nature of Regulatory Action 

The Food Quality Protection Act of 1996 mandated the EPA to implement a new program, i.e., 

registration review (http://www.epa.gov/oppsrrd1/registration_review/). All pesticides 

distributed or sold in the United States generally must be registered by EPA. The decision to 

register a pesticide is based on the consideration of scientific data and other factors showing that 

it will not cause unreasonable risks to human health, workers, or the environment when used as 

directed on the product label. The registration review program is intended to ensure that, as the 

ability to assess risk evolves and as policies and practices change, all registered pesticides 

continue to meet the statutory standard of no unreasonable adverse effects to human health and 

the environment. Changes in science, public policy, and pesticide use practices will occur over 

time. Through the new registration review program, the Agency periodically reevaluates 

pesticides to make sure that as change occurs, products in the marketplace can be used safely. 

As part of the implementation of the new Registration Review program pursuant to Section 3(g) 

of the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA), the Agency is beginning its 

evaluation to determine whether Propamocarb-HCl continues to meet the FIFRA standard for 

registration. This problem formulation, for the environmental fate and ecological risk assessment 

chapter in support of the registration review, is intended for the initial docket opening, the public 

phase of the review process. 

2.2 Previous Risk Assessments 

Propamocarb-HCl has been registered since 1984, and has been subject to two main risk 

4 
assessments (Section 3), several Section 18 assessments and a chapter drafted for the reregistration eligibility decision (RED). Previous assessments serve as the basis for this problem 

formulation and a summary of the two primary assessments are included hereunder: 

. 

(1) EFED's chapter for the RED of this chemical (dated August 1995)1

. This chapter covered 

Propamocarb-HCl uses on ornamental lawns and turf, ornamental sod farms (turf), 

ornamental herbaceous plants, and ornamental woody shrubs and vines. At the time of the 

RED, the Agency had adequate data available to assess the acute ecological hazard of 

Propamocarb-HCl but did not have sufficient data to assess chronic toxicity. The Agency 

therefore had required chronic avian reproduction, invertebrate life-cycle, and hydrolysis and 

photo degradation studies. 

In the EFED RED chapter, Propamocarb-HCl usage yielded risk quotients (RQs) that 

exceeded the acute risk levels of concern (LOCs) for birds and mammals with multiple 

applications on turf. Additionally, the use of Propamocarb-HCl on ornamentals resulted in 

RQs exceeding acute risk LOCs for birds and mammals. For aquatic organisms, all uses of 

propamocarb-HCl did not exceed acute or chronic LOCs for freshwater and estuarine/marine 

fish. Acute LOCs were not exceeded for freshwater invertebrates but chronic risk could not 

be characterized due to a lack of a chronic freshwater invertebrate study. The RQ for 

estuarine/marine invertebrates exceeded the acute risk LOC for the use on ornamentals. 

Available aquatic plant toxicity studies show low toxicity from Propamocarb-HCl use and 

there were no LOC exceedances for aquatic plants. An additional aquatic plant study, 

however, was requested to evaluate the toxicity of Propamocarb-HCl to Lemna gibba. 

Tier I Terrestrial plant toxicity studies (Seedling Emergence and Vegetative Vigor) showed 

significant reductions in dry weight (tomato, 24.3%; cabbage, 20.4%; and oat, 22.4%), and 

length (cucumber, 7.1%; and soybean, 9.2% ), however none of these reductions exceeded 

25% and therefore Tier II studies are not required. An acute honey bee contact study was not 

submitted in order to evaluate the risk of Propamocarb-HCl exposure to terrestrial 

invertebrates. This study was required by the RED because the Agency had concerns that the 

high use on field-grown ornamentals would exceed the Levels of Concern (LOC) for 

endangered birds, mammals, estuarine and marine animals. Label changes for PropamocarbHCl use or additional ecological data on seedling emergence, aquatic plant and honeybee 

contact studies have been required through a Data Call-in (DCI). 

A mitigation measure was described in EFED’s “Transmittal of EFED RED for the List C 

Chemical Propamocarb Hydrochloride” (EPA, June, 1995). The label indicated that the 

maximum application rate for turf was 8.19 lbs a.i/A. It did not limit the number of 

applications per year. The registrant indicated that they were willing to limit applications to 

three per year at 8.19 lbs a.i/A or to 6 per year at 4.1 lbs a.i/A. Based on the available 

toxicity data, these rates do not result in exceedances of LOCs for non-target organisms. In 

addition, The RED recommended the following language be placed on Propamocarb-HCl 

product labels to mitigate aquatic exposure:

“Do not apply directly to water, or to areas where surface water is present or to intertidal 

 

1

 http://www.epa.gov/oppsrrd1/REDs/3124red.pdf 

5 
areas below the mean high water mark. Do not contaminate water when cleaning 

equipment or disposing of equipment washwaters or rinsate.” 

(2) EFED chapters covering the proposed new uses of Propamocarb-HCl to the following crops: 

a. Potatoes (EFED; DP# D259522, D265954, D226118, D253789, D221659, and 

D252192, June 2000). This assessment concluded that the restricted use and 

endangered species LOCs were exceeded for birds, but there were no other acute or 

chronic LOC exceedances for terrestrial or aquatic organisms. 

b. Cucurbits, lettuce, peppers, and tomatoes (EFED; DP# D293626, January, 2004). 

This assessment concluded that the chronic LOC for birds was exceeded in the use on 

lettuce, but there were no further acute or chronic LOC exceedances for terrestrial and 

aquatic organisms. 

In both the 2000 and 2004 new use assessments; chronic data for freshwater invertebrates and 

estuarine/marine fish and invertebrates were still not available. Terrestrial plant studies only 

assessed two plants (wheat and cucumber) and, while the study was classified as supplemental, 

the toxicity of Propamocarb-HCl was higher than the maximum rate used for all uses at the time 

of these assessments. 

3. Stressor Source and Distribution 

3.1 Mechanism of Action 

Propamocarb-HCl is a member of the carbamate family of fungicides (FRAC, 2010a; ETN, 

1997). The chemical is a systemic fungicide with protective qualities against several oomycete 

(water molds) species (e.g. Phytophthora spp., Pythium spp., Bremia lactucae [lettuce downy 

mildew], and Pseudoperonospora cubensis [cucurbit downy mildew]). These diseases may 

cause seed, seedling, and root and stem rots, and foliar diseases in many edible crops and 

ornamental plants. The mode of action of Propamocarb-HCl is classified by the Fungicide 

Resistance Action Committee (FRAC, 2010a) as a "Group 28" fungicide, with a low to medium 

risk of resistance. Because resistance to propamocarb-HCl has been identified in greenhouse 

isolates of Pythium spp. (Pest Management Guidelines, 201la; FRAC. 2010b) resistance 

management strategies have been recommended with its use (BEAD Memo, April, 2011). The 

fungicide works by disrupting the formation of fungal cell walls by interfering with the synthesis 

of phospholipids and fatty acids. It affects mycelial cell growth, spore production, and 

germination. Disease control is mainly by protection as Propamocarb-HCl has little curative 

action once an infection has started.2

Propamocarb-HCl is formulated with other fungicide active ingredients including chlorothalonil 

or fluopicolide. The mode of action for chlorothalonil is related to its function as a multi-site 

inhibitor of several enzymes that control metabolic processes and spore germination. 

Specifically, it reduces fungal intracellular glutathione molecules to alternate forms which cannot 

 

2

 http://www.agf.gov.bc.ca/pesticides/infosheets/propamocarb_hcl.pdf 

6 
participate in essential enzymatic reactions. Chlorothalonil is also toxic to fungal cell 

membranes.3 In contrast to both Propamocarb-HCl and chlorothalonil, fluopicolide is novel in its 

anti-oomycete properties from other fungicides in that it affects the release and motility of 

zoospores and the germination of cysts, as well as mycelial growth and sporulation. It has also 

been shown to specifically modify the spatial and cellular distribution of proteins labeled by 

antibodies specific for animal cytoskeleton associated proteins spectrin. Cytoskeletal proteins 

such as actins, tubulins, integrins and spectrins provide structural stability to cells as they form a 

network sustaining the plasma membrane. Fluopicolide may interfere and destabilize this 

network leading to cell disorganization.4

3.2 Overview of Pesticide Usage 

Labeled Uses 

Propamocarb-HCl is formulated as water miscible concentrate (WMC) or suspended concentrate 

(SC) alone or mixed with other fungicide including fluopicolide or chlorothalonil. The chemical 

is applied as a liquid spray or as diluted drench directly into the soil or foliage (one label) and/or 

through label specified irrigation systems. There are eight labels for Propamocarb-HCl, three for 

use on vegetables and five for use on turf and ornamentals. These labels are listed hereunder:

Vegetable labels

(1) Propamocarb-HCl alone: 

a. 55260-10 Label: Promess Fungicide; water miscible concentrate formulation (WMC) with 

66.8% Propamocarb-HCl 

b. 264-678 Label: Previcur Flex; water miscible concentrate (WMC) formulation with 66.5% 

Propamocarb-HCl 

(2) Propamocarb-HCl with fluopicolide 

a. 59639-142 Label: V-10162 Premix; suspended concentrate (SC) formation with 55.4% 

Propamocarb-HCl and 5.54% fluopicolide 

Turf & Ornamentals labels

(1) Propamocarb-HCl alone: 

a. 55260-9 Label: Advan Proplant® Turf and Ornamental; water miscible concentrate 

(WMC) formulation with 66.8% Propamocarb-HCl (2010 Revised Label) 

b. 432-942 Label: Banol; water miscible concentrate (WMC) formulation with 66.5% 

Propamocarb-HCl (2010 Revised Label) 

c. 83070-8 Label: Advan propamocarb HCl; water miscible concentrate (WMC) formulation 

with 66.8% Propamocarb-HCl (2010 Revised Label) 

(2) Propamocarb-HCl with fluopicolide or chlorothalonil 

a. 59639-143 Label: V-10162 VPP Fungicide; suspended concentrate (SC) formulation with 

55.4% Propamocarb-HCl and 5.54% fluopicolide 

b. 432-961 Label: Banol C Fungicide: water dispersible concentrate (WDC) formulation with 

30.5% Propamocarb-HCl and 30.5% chlorothalonil 

 

3

 http://www.agf.gov.bc.ca/pesticides/infosheets/chlorothalonil.pdf 4

 http://www.epa.gov/opprd001/factsheets/fluopicolide-newchemical.pdf 

7 
As stated above, Propamocarb-HCl is formulated with either chlorothalonil (for turf & 

ornamentals use) or fluopicolide (for vegetable use). Chlorothalonil is a member of the 

chloronitrile class of fungicides. It is a board spectrum contact or protectant fungicide with a 

long acting residual activity. It helps to prevent infection by fungi when applied as a protective 

barrier on plant surfaces. In contrast, fluopicolide is a member of the benzamide class of 

fungicides and it is used to control certain diseases on cucurbits, lettuce, and fruiting vegetables. 

A summary of currently labeled agricultural use patterns for Propamocarb-HCI is shown in 

Table 1 for field vegetable crops. Table 1 summarizes the application parameters and 

application methods which includes aerial, ground and chemigation. 

Table 1 Propamocarb-HCl labeled vegetables use patterns and application parameters based on 

the latest revised labels submitted in 2010 (MxR= Maximum single Application Rate (lb a.i/A), 

MxNA= Maximum Number of Applications, MxSRT= Maximum seasonal rate (lb a.i/A), 

MnAI= Minimum Application Intervals in days)

Use Pattern MxSR MxN* MxSRT MnAI COMMENTS 

59639-142 Label: V-10162 Premix; SC formation with 55.4% Propamocarb-HCl and 5.54% fluopicolide 

Cucurbits 0.9 4 3.4 10 - Not for use in greenhouses 

- Aerial, ground, and chemigation 

applications allowed only through 

center pivot or solid set irrigation 

systems 

Lettuce 1.1 4 3.4 10 

Fruiting vegetables 0.9 4 3.4 7 

55260-10 Label: Promess Fungicide; WMC formulation with 66.8% Propamocarb-HCl 

Cucurbits 0.9 5 4.5 7 Aerial, ground (banded and broadcast), and 

chemigation applications. In case of 

chemigation, apply only through center 

pivot, motorized-lateral move, traveling gun, 

solid set or portable and drip irrigation 

systems. 

Lettuce 1.5 NR 6.0 5 

Peppers 0.9 NR 4.5 7 

Tomatoes 1.1 NR 5.6 7 

264-678 Label: Previcur Flex; WMC formulation with 66.5% Propamocarb-HCl 

Cucurbits 0.9 5 4.5 7 Aerial, ground (banded and broadcast), and 

chemigation applications. In case of 

chemigation, apply only through center 

pivot, motorized-lateral move, traveling gun, 

solid set or portable and drip irrigation 

systems. 

Lettuce 1.5 4 6.0 5 

Peppers 0.9 5 4.5 7 

Tomatoes 1.1 5 5.6 7 

Potatoes 0.9 5 4.5 7 

* NR= Not Reported

It is important to note that two of the labels for vegetable crops include greenhouse application, 

namely, 55260-10 Promess and 264-678 Previcur Flex. Both labels include one pre-seeding 

application to rock-wool cubes seed bed or one pre-seeding and one seedling applications to soilsoilless seed beds, and drip/drench/foliar applications to plants after transplanting. The list of 

greenhouse vegetables includes cucurbits, leaf lettuce, peppers and tomatoes. With the exception 

of lettuce, labels call for a total of six or seven applications: one (in case of rock-wool cubes 

seedbed) or two (in case of seed beds with and without soil) pre-seeding applications and four 

drip/drench applications to plants after transplanting (all four crops). In case of lettuce, an 

additional two foliar applications may be made to plants after transplanting. Maximums for each 

cropping season were set to be 11.6 lbs. a.i./A with 6,000 plants, 9.4 lbs. a.i./A with 10,000 

plants, and 27.1 lbs. a.i./A with 14,000 plants. However, label instructions needs to be clarified 

8 
as per notes provided in Appendix A.

Propamocarb-HCl is also labeled for use on turf and ornamentals. A summary of these labeled 

uses is included in Table 2. The table summarizes the application parameters and the application 

methods which include ground application for turf, soil drench (or foliar in one label) and 

chemigation for ornamentals. 

Table 2 Propamocarb-HCl labeled turf and ornamentals use patterns and application parameters 

based on the latest revised labels submitted in 2010 (MSR= Maximum single Application Rate 

(lb a.i/A), MNA= Maximum Number of Applications, MSRT= Maximum seasonal rate (lb a.i/A), 

MAI= Minimum Application Intervals in days)

Use Pattern and Labels* MSR MNA MSRT MAI COMMENTS 

55260-9 Label: Proplant® Turf and Ornamental; WMC formulation with 66.8% Propamocarb-HCl (2010 Revised 

Label)

Turf 8.2 NR 24.5 7 

No application through any irrigation 

system. 

Ornamentals: seeding & 

transplanting 45.9 NR 25.5 NR 

Ornamentals: transplanting 

cuttings 81.7 NR 25.5 NR 

Ornamentals: potting 4” pot 127.9 NR 25.5 21 

Ornamentals: Woody ornamentals 63.8 NR 25.5 90 

59639-143 Label: V-10162 VPP Fungicide; SC formulation with 55.4% Propamocarb-HCl and 5.54% fluopicolide 

Turf 2.12 2 4.25 14 

- No chemigation on turf 

- For chemigation to ornamentals, apply 

only through micro-irrigation, drip, 

overhead, or motorized calibrated 

equipment. 

Ornamentals: Foliar 4.25 2 NR 14 

Ornamentals: Drench for flat beds 212.4 2 NR 14 

Ornamentals: Potting 4” 

pot 228.0 2 NR 14 

5” pot 194.6 2 NR 14

6” pot 202.7 2 NR 14

8” pot 190.0 2 NR 14

10” pot 243.2 2 NR 14

12” pot 253.4 2 NR 14

432-942 Label: Banol ; WMC formulation with 66.5% Propamocarb-HCl (2010 Revised Label)

Turf 8.2 4 25 7 

Do not apply through any type of 

irrigation system 

Ornamentals: Seeding & Seedlings 45.9 Single application values (column to the left) are calculated from the 

labels and may be used only in the case of ONE application. 

However, in case of TWO applications, the maximum single 

application per season should be 64.3 lb a.i./A/application giving a 

Maximum of 128.6 lb a.i./A/season with intervals ranging from 7-90 

days. 

Ornamentals: Transplanted cuttings 81.7 

Ornamentals: Potting (4” pots) 128

Ornamentals: Woody ornamentals 63.8

432-961Label: Banol C Fungicide: WDC formulation with 30.5% Propamocarb-HCl and 30.5% chlorothalonil 

Turf 8.5 NR 25.5 7-14 

May be applied via ground equipment or 

hydraulic backpack sprayer 

Ornamentals: Seeding & Seedlings 47.7 1 25.5 N/A 

Ornamentals: Transplanted cuttings 85.1 1 25.5 N/A 

Ornamentals: Potting 133.2 NR 25.5 42 

Ornamentals: Woody ornamentals 66.5 NR 25.5 90 

83070-8 Label: Advan Propamocarb; WMC formulation with 66.8% Propamocarb-HCl (2010 Revised Label)

Turf 8.2 NR 24.5 7 Do not apply through any type of 

Ornamentals: seeding & irrigation system. 

transplanting 45.9 NR 25.5 N/A 

9 
Use Pattern and Labels* MSR MNA MSRT MAI COMMENTS 

Ornamentals: transplanting cuttings 81.7 NR 25.5 N/A 

Ornamentals: potting 4” pot 127.9 NR 25.5 21 

Ornamentals: Woody ornamentals 63.8 NR 25.5 90 

Use Pattern and Labels: hereunder notes on Each Label

55260-9 Label

1

Turf: Only for use on golf courses & sod farms (excluding AZ) 2

Ornamentals: commercially-grown in greenhouses and container-grown in nurseries. 

59639-143 Label

1

Turf: Only for use on commercial turf, golf course turf, residential turf, & sod farms 2

Ornamentals: Not specified if only ornamentals that are commercially-grown in greenhouses and container-grown 

in nurseries. 

432-942 Label 1

Turf: Only for use on golf & sod farms; Not for use on sod farms in AZ 2

Ornamentals: Not to be used for field grown ornamentals but the label did not specify if only ornamentals that are 

commercially-grown in greenhouses and container-grown in nurseries. 

432-961Label

1

Turf: Only for use on golf courses, sod farms, and non-residential lawns, Not for sale or use in CA and not for use 

on sod farms in AZ. Use on home lawns is prohibited: Do not use on home lawns and turf sites associated with 

apartment buildings, daycare centers, playgrounds, playfields, recreational park athletic fields, athletic fields 

allocated on or next to schools (i.e., elementary, middle, and high schools), campgrounds, churches, and theme 

parks. Do not use on sod farms at application rates greater than 13 lb a.i./acre/year. Note for intervals 7-14= 7-day 

for the 6 fl oz application and 14-dayfor the 8 fl oz application 

2

Ornamentals: Not specified if only ornamentals that are commercially-grown in greenhouses and container-grown 

in nurseries. 

83070-8 Label

1

Turf: type of turf is not specified; assume all types of turf, Not for use in CA and not for use on sod farms in AZ. 2

Ornamentals: Not specified if only ornamentals that are commercially-grown in greenhouses and container-grown 

in nurseries. 

3

NR= Not reported; N/A= Not applicable

As shown in Table 2, many issues were identified in labels for this use especially instructions 

related to application to ornamental plants. Label issues are different from one label to the other 

but are currently being discussed with respective registrants and these issues are discussed in 

Appendix A. 

Usage Data 

Propamocarb-HCl was first registered for use on turf and ornaments in 1984. Use on potatoes 

was added on the year 2000 while use on fruiting vegetables, lettuce, potatoes, and cucurbits was 

added in 2004. 

Reported Usage data were obtained for the two major use patterns as follows: 

(1) Usage on vegetables: usage data were obtained from the Screening Level Usage Analysis 

(SLUA, date November 23, 2010) (Table 3 and Figure 1). This estimated usage is derived 

from a variety of published and proprietary sources that are available to the Agency. The 

data, reported on an aggregate and site (crop) basis, reflect annual fluctuations in use patterns 

as well as the variability in using data from various information sources including USDANASS (United States Department of Agriculture's National Agricultural Statistics Service, 

10 
2001 to 2008 data), Private Pesticide Market Research (2001 to 2008 data), and the 

California DPR (Department of Pesticide Regulation, 2000 to 2008 data) 

Table 3 Screening Level Estimates of Agricultural Uses of Propamocarb-HCl (119302) sorted 

alphabetically 

Crop Total Lbs. of a.i Used 

Percent Crop Treated 

Average Maximum 

Cantaloupes 1,000 <1 <2.5 

Cucumbers 70,000 30 45 

Lettuce 200,000 25 35 

Peppers 6,000 5 15 

Potatoes 9,000 <1 <2.5 

Pumpkins 6,000 10 15 

Squash 8,000 10 15 

Tomatoes 1,000 <1 <2.5 

Watermelons 3,000 <2.5 5 

Figure 1 Screening Level Estimates of Agricultural Uses of Propamocarb-HCl 

As per BEAD report (BEAD 2011), which was based on private market survey data from 2006-

2008, the annual vegetable usage (excluding eggplant because data are not available) for 

Propamocarb-HCl averaged approximately 240,000 pounds for treating 220,000 acres (GtK 

Kynetec, 2006-2008). Based on the same source, Propamocarb-HCl is typically applied at a rate 

11 
of 0.7-1.4 pounds a.i/A as it varies from one vegetable crop to the other. The same data suggest 

that the top crops, in terms of total pounds of active ingredient applied were lettuce (52%), 

cucumbers (37%), squash (3%), peppers (3%), and pumpkins (3%). These crops ranked similarly 

in terms of the total area treated except cucumbers ranked higher (46%) than lettuce (40%). The 

states with the most usage in terms of pounds a.i applied were California (53%), Michigan 

(24%), Georgia (7%), Florida (5%), Texas (2%), and Indiana (2%); Other States (7%). These 

listed States were also the highest in terms of the total area treated.

A very broad overview of the historical usage data of Propamocarb-HCl can be summarized as 

follows: 

• Prior to 2005, agricultural usage was limited to potatoes and tomatoes; 

• From 1998-2008, the use on potatoes and tomatoes has decreased with no use reported on 

tomatoes since 2001. 

• Overall, usage has increased substantially in recent years due to the 2004 registration of lettuce, 

cucurbits, and fruiting vegetables (Figure 2)

Figure 2 Propamocarb-HCl vegetable usage data from 1998 to 2008 (Pounds a.i Applied) 

0

350,000

1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008

Other 

Tomatoes

Potatoes

Cucumbers

Lettuce

Source: GfK Kynetec, 1998-2008 

Other includes: squash, pepper, pumpkins, watermelons, and cantaloupes. 

(2) Usage on turf and ornamentals: According to pesticide usage surveys for turf and 

ornamentals, usage on golf courses has been declining since the peak of approximately 

85,000 pounds in 2002 to just under 10,000 pounds in 2006 (Kline and Company; 1999-

2006). Usage by lawn care operators and in nursery/greenhouse sites was only reported in 

2006, accounting for approximately 4,000 pounds each (Kline and Company; 1999-2006).

3.3 Environmental Fate and Transport 

Two sets of studies were submitted for the physiochemical properties, laboratory fate in 

abiotic/biotic systems, laboratory mobility, and field dissipation. The 1st set was conducted 

12 
between 1976 and 1988 while the 2nd set of studies was conducted between 1995 and 2002. Data 

from the two sets are in general agreement on the physiochemical and abiotic fate of 

Propamocarb-HCl. Based on these data, a summary of the physicochemical properties of the 

chemical is included in Table 4. 

Table 4 Summary of physicochemical properties of Propamocarb-HCl

Parameter Value (Units) Source

CAS Chemical Name Propyl N-[3-(dimethylamino)propyl]carbamate hydrochloride (1:1) 

Registrant data 

IUPAC Chemical Name Propyl 3-(dimethylamino)propylcarbamate hydrochloride 

Chemical Formula 

Propamocarb HCl: C9H21ClN2O2 

(Note that Propamocarb chemical formula is: C9H20N2O2)

PC Code 119302 EPA

Chemical Structure Smiles Code: ClN(C)(C)(H)CCCNC(=O)OCCC

CAS Reg. No. 

Propamocarb HCl (salt) 25606-41-1 

(Note that Propamocarb CAS No is 24579-73-5)

Registrant data 

Molecular Weight 224.73 g/mole 

Solubility (20oC) >700 g/L 

Vapor Pressure (VP @ 

25oC) 6.0x 10-7 torr 

MRID 433684-

09 

Dissociation Constant pka= 9 (Very weak acid) 

MRID 412781-

06 

Henry’s Law Constant 2.5 x 10-13 atm-m3

-mol-1 Calculated @ 25 o

C

Octanol-Water Partition 

Coefficient (25 oC) 

(log KOW; and KOW) 

-0.39; 0.4 

and 

-1.36; 0.044 @ pH 7 

412781-07 and 

443049-04 

H3C 

CH3 CH3

H+

ClCarbamate Moiety 

Data in Table 4 indicate that Propamocarb-HCl has a molecular weight of 224.7 g/mol with a 

high water solubility of over 700,000 ppm and an octanol/water partition coefficient (Kow) of 

0.4 to 0.04 suggesting high availability for leaching (due to high solubility) and very low 

potential for bioaccumulation in aquatic organisms such as fish (due to low Kow). A fish 

Accumulation (BCF) study confirmed the prediction based on KOW. Determined concentration in 

13 
tissue to exposure concentration in water were1.5X for edible, 3X for non-edible. Depuration 

was rapid with approximately 100 % depurating within 7 days (MRID 412781-14). It is noted 

that an additional fish accumulation study was submitted and was found to be un-acceptable 

(MRID 458943-23). 

A summary of abiotic laboratory studies for Propamocarb-HCl is included in Table 5. The 

summary table contains data obtained from the two sets of studies identified above. 

Table 5 Summary of abiotic laboratory determined properties of Propamocarb-HCl

Property Value (Source; Study 

Classification1) MRID Classification 

Hydrolysis (halflife= t1⁄2, days) 

1st & 2nd data sets

Stable @ pH 5, 7 and 9 000712-97 Supplemental 

Direct Aqueous 

Photolysis (t1⁄2, 

days) 

1st & 2nd data sets

Stable The chemical does 

not absorb photo energy in 

the visible region (λ ≥290 

nm) 

000712-96 Acceptable 

Soil Photolysis (t1⁄2, 

days) 

1st data set

Considered Stable because 

degradation in dark controls 

was greater than irradiated 

samples which gives a halflife of 210 days in a 31-day 

experiment

2nd data set

35.4 with three un-identified 

minor degradates (3, 4, and 

9%) and 21% unidentified 

bound residue 

045893-18 

418346-08 

Supplemental 

Acceptable 

Based on abiotic laboratory data, Propamocarb-HCl is stable to hydrolysis and photolysis in 

water and on soil as registrant submitted data do not show that the chemical absorb photo energy 

in the visible region. The observed t1⁄2= 35 days in one of the soil photolysis studies (MRID 

418346-08) can be partly explained by effect of the bound residue in reducing the calculated 

half-life of the chemical (Table 5; It appears that the extraction of the parent was not complete). 

Laboratory biotic fate and mobility data for Propamocarb-HCl were reviewed by close 

examination of studies and/or the data evaluation reports (DERs). Data obtained from the 1st and 

2nd sets of submitted studies is included and compared for aerobic/anaerobic soil and aquatic 

systems. Detailed comparisons are included in Table B-1 (Appendix B) for biotic fate studies 

and in Table B-2 (Appendix B) for mobility studies. The purpose of these two tables is: 

• To identify differences in the submitted two sets of data and possible cause(s) for such 

differences; 

• To determine the need for additional data; and 

14 
• To identify possible changes in the data that may be used to represent fate and transport of 

the chemical in soil and aquatic systems; the most important compartments of the 

environment where highest exposure is expected. 

Comparing data in Tables B-1 and B-2 (Appendix B), the following can be stated: 

• There are differences in the extraction systems used for soils and sediments: the 1st set of 

studies used methanol base extraction while the 2nd set of studies used acetonitrile base 

extraction. As a result, the unidentified bound residues observed in aerobic soil systems were 

significantly different. Maximums of unidentified bound residues were reached within 13 to 

30 days to levels ranging from 20 to 38% in the 1st set and were reached within 30 to 120 

days to levels ranging from 29 to 49% in the 2nd set. More importantly, with time, bound 

residues showed a relatively important decline, from maximums, in the 1st set (a decline to 

11-15%) while it showed relative persistence in the 2nd set (no decline in one soil and a 

decline to 31 to 44%). In contrast, data on bound residues, in the only anaerobic soil system 

(from the 1st set), formed at a relatively low concentration as it reached a maximum of only 

8% of the applied in 14 days and showed no apparent decline up to the end of the one year 

study. Furthermore, in the only anaerobic aquatic system (from the 2nd set), bound residue 

formed and reached a maximum of 20% of the applied at 110 days and showed a sharp 

decline to 6% at the end of this 370 days study (Figure B-1, Appendix B). Bound residues 

were characterized only by fractionation/quantification of radioactivity from the bound 

residues that is present in fulvic and humic acids and the humin fractions in soils/sediments. 

Examination of the degradation profile for Propamocarb-HCl in all of the systems, suggests 

that the formation of the bound residues are directly related to parent biodegradation in both 

level and timing. In each soil or aquatic system, the bound residues increase with the increase 

in the rate of parent degradation and reach its maximums as parent mineralizes completely to 

CO2. 

• Both sets of studies tracked only the parent and CO2, the major mineralization product of the 

chemical. Observed degradation products were quantified as % of applied radioactivity but 

were only identified in one study. In this study, formed degradation products were compared 

to the standards of possible degradates shown in Figure B-2, Appendix B. None of the 

observed degradates were found to be any of these investigated standards.

It is noted however; that interpretation of data, in terms of expected environmental exposure, 

may not be affected by non-identification of degradates because all degradates formed at low 

concentration and most declined with time. However, the non-identification of the significant 

bound residue, if proved to be toxic, is important. The residue, that partitions and bound to 

sediment and soil particle, is of concern especially if it is un-extracted parent and/or a toxic 

unidentified degradate(s). Available data appear not to support the first possibility due to the 

apparent efficiency of parent extraction and due to the fact that formation of the bound residue 

increases in parallel to the decrease in parent by degradation. However, the second possibility of 

the bound residue being a toxic degradates(s) need to be further investigated. 

• For chemical identification, the 1st set of studies relied on 1 or 2 dimensional thin layer 

chromatography (1-2 D TLC) without using another confirmatory method. In contrast, the 

15 
2nd set of studies did use HPLC for this purpose. It is however, important to note that both 

sets were able to only identify parent compound. Measurement of radioactivity by LSC was 

the procedure used for quantification in the two sets of submitted studies. 

• There are apparent difference between the two sets of aerobic soil studies in the observed 

quantities of evolved CO2 and calculated half-lives. In the 1st set, evolved CO2 ranged from 

80 to 87% and half-lives from 10 to 27 days (90th percentile t1⁄2= 27 days). Half-lives in the 

aerobic soils from this 1st set appear to be directly related to mineralization of the chemical 

and in some cases degradation of the bound residue. In contrast, evolved CO2 from soils in 

the 2nd set ranged from 31 to 49% and half-lives from 14 to 70 days (90th percentile t1⁄2= 45 

days). Half-lives determined in this 2nd set are longer and appear to be directly related to 

mineralization of the chemical to CO2 (which was comparably less) in addition to the fact 

that the significant unidentified bound residue was considered as a fraction of no concern (i.e. 

a chemical sink). The differences in calculated half-lives, between the two sets of data, may 

be related to differences in characteristics of the soils. However close examination of texture, 

pH, O.C%, clay%, and CEC reveals no direct relation to calculated half-lives. No other soil 

information was provided such as soil taxonomy, including soil series in order to obtain more 

information about the soils used in the studies. In the absence of additional soil data, 

differences may be related to differences in biological viability of the soils (this was not 

monitored or confirmed by data in all studies) and/or other soil characteristics that were not 

measured such as clay mineralogy. 

• For the anaerobic soil system, only one study was submitted, as part of the 1st set, and the 

degradation profile in this soil suggests that Propamocarb-HCl is highly persistent 

(extrapolated t1⁄2= 459 days). Mineralization of the chemical appears to be relatively low 

(Maximum evolved CO2= 8%). In addition, the formation of bound residue was relatively 

low (Maximum= 8%). 

• For the anaerobic aquatic systems, only one study was submitted, as part of the 2nd set, and 

the degradation profile in this system suggests that Propamocarb-HCl is relatively persistent 

(t1⁄2= 92 days). Mineralization of the chemical appears to be relatively high (Maximum 

evolved CO2= 68%) while formation of bound residue was relatively low (Maximum= 20%) 

and show a sharp decline to only 6% after 365 days presumably by mineralization to CO2 

(Figure B-1, Appendix B). In this anaerobic aquatic study, the applied radioactivity (parent 

application) partitioned within two weeks from the water to the sediment (Figure B-3, 

Appendix B). By TLC/HPLC, most of this radioactivity was the parent compound indicating 

that applied parent is the one involved in the observed partitioning. Following this 

portioning, parent appears to mineralize directly into CO2 with only a small part becomes as 

bound residue. The high extent of parent mineralization in this anaerobic aquatic system is 

not expected when compared to the anaerobic soil system. Examination of data on the 

aerobicity in this anaerobic aquatic study suggests that the system was sub-oxic and not 

completely anaerobic (Figure B-4, Appendix B). Therefore data obtained from this study 

may not reflect the expected behavior of Propamocarb-HCl in an anaerobic aquatic system in 

the natural environment. 

16 
In conclusion, laboratory biotic fate studies suggest that Propamocarb-HCl is relatively nonpersistent in some soils and exhibits higher persistence in others. Propamocarb-HCl degradation 

in the soil system can be mainly related to microbialy mediated mineralization to CO2. 

Propamocarb-HCl is expected to be highly persistent in anaerobic soil systems while its 

persistence in aerobic and anaerobic aquatic systems is uncertain due to lack of an aerobic 

aquatic metabolism study and the existence of only sub-oxic conditions in the submitted 

anaerobic aquatic study. 

Mobility data suggest that Propamocarb-HCl is highly mobile in some soils while it is 

moderately mobile in others (Table B-2, Appendix B). Adsorption-Desorption data were 

obtained for seven soils varied in texture, pH, organic carbon% (O.C%), clay%, and cation 

exchange capacity (CEC). Organic carbon based adsorption coefficient (Koc) ranged from 41 to 

359 mL/g in five of the soils and ranged from 802 to 1,317 mL/g in the other two. No apparent 

relationship was observed with the soil system OC% and as a result different mobility 

interpretation was obtained depending on whether the interpretation is based on Koc or Kd 

coefficients. Therefore, Kd is the preferred parameter for describing partitioning for this 

chemical. Values for Kd ranged from 0.67 to 1.29 mL/g in three soils, 5.2 to 6.72 mL/g in 

another three, and was 13.83 mL/g for the last one. In addition, a positive relationship appears to 

exist between Kd and both soil clay content and its CEC in only five of the soils. All of the 

examined soils were acidic (pH range from 5.2 to 6.5), therefore the positive relationship might 

be partly related to the fact that Propamocarb-HCl is an organic week acid (pKa =9.1). In acidic 

conditions this week acid acts as a base capable of accepting H+ ions and be positively charged. 

Presence of the positive charge causes more adsorption of the chemical into the negatively 

charged clays. This may have caused the observed increase in adsorption and related Kd values. 

In conclusion, Propamocarb-HCl is expected to show high mobility in highly permeable soils if 

rainfall or irrigation leads to leaching before it is affected by microbial activity that causes its 

degradation into CO2 and immobile bound residues. In most other soils, the chemical is expected 

to be of moderate mobility. When leaching to lower anaerobic soil horizons soon after 

application occurs, propamocarb-HCl is expected to persist in these anaerobic horizons and 

eventually reach ground water where it also expected to persist. Ground water contamination 

with propamocarb-HCl is therefore expected in case of high rainfall after application in 

vulnerable sandy soils affected by high ground water table. 

Table 6 contains a summary of the fate and transport properties of propamocarb-HCl 

 

Table 6 Summary of acceptable fate and transport properties for propamocarb-HCl 

Parameter 

Value for parent (Estimated Value for 

Total Parent + Bound Residue)1 Source 

Soil adsorption 

coefficient Kd and 

Koc (mL/g) 

Adsorption Kd = 0.671, 0.849, 5.2, 

1.29, 6.27, 13.83, and 4.65 

Adsorption Koc = 140, 41, 359, 57, 180, 

1,317, and 802

MRID: 412781-30 

and 

MRID: 458943-21

17 
Value for parent (Estimated Value for 

Parameter Total Parent + Bound Residue)1 Source 

Aerobic metabolism 

half-life in soil (days) 

Loamy sand soil: 14 (22); Loamy 

sand soil: 27 (48); 

Loamy sand soil: 10 (58); Sandy 

Loam soil: 23 (60); 

Silt loam soil 16 (59); Clay loamy 

sand soil: 15 (58); and 

Sandy Loam soil: 70 (140) 

90th percentile value= 36 (83) 

MRIDs: 412781-25/26/27 

And 

MRID: 458943-19

Anaerobic 

metabolism half-life 

in soil (days) 

Loamy sand soil 459 

(No need for recalculation of half-life 

because the maximum bound residue 

reached only 8% of the applied 

radioactivity) MRID: 412781-29 

Aerobic Aquatic halflife (days) No data 

Anaerobic Aquatic 

half-life (days) 

92 

(No need for recalculation of half-life 

because bound residue showed a 

significant decline to nearly 6% of the 

applied radioactivity) MRID: 445385-04 1

 This value is a rough estimate only, half lives may increase or decrease based on the chosen procedure for calculating 

half-lives

In the field, three terrestrial field dissipation studies were conducted the first one was from the 1st

set) and was conducted on turf plots in CA and NY (MRID 424212-02). The second and third 

studies were from the 2nd set and were conducted on bare soil plots in IL and NC (MRID 

440016-01) and on turf plots in CA and GA (MRID 458943-22). Propamocarb-HCl formulations 

were applied three to four times at a single application rates ranging from 4.6 to 9.2 kg/ha. The 

application rates used in turf plots corresponds to the current turf application rate of 9.5 x 4 kg/ha 

however, the rate used on bare soil plots is much higher than the current vegetables single rate of 

1.0 to 1.7 kg/ha and seasonal rate of 3.8 to 6.7 kg/ha. Terrestrial field dissipation data obtained 

from these sites are summarized in Table7. 

Table 7 Terrestrial field dissipation studies data for Propamocarb-HCl

Study (MRID) Crop 

Location (Study 

Duration; Days) Study Results 

Study 1 

(1st set) 

(424212-02)1 Turf 

NY 

(21+127=148)

Dissipation Half-life (top 8 cm): 10 days; noting that no data were 

submitted for dissipation of the chemical in various turf layers (Grass, 

thatch, and soil) 

Leaching: parent detected up to the maximum depth monitored (90 cm) 

@ day 2 with a maximum of nearly 10% Therefore, the extent of parent 

leaching may have been below 91 cm

CA 

(21+111=132)

Dissipation Half-life (top 8 cm): 15 days 

Leaching: parent was not detected below 46 cm at any day after last 

application

Study 2 

(2nd set) 

(440016-01)2

Bare 

plots 

IL 

(21+548=569)

Dissipation Half-life (top 15 cm): Biphasic with 7 days half-life for the 

fast phase and 165 days for the slow phase 

Leaching: Parent was not detected below 30 cm at any after last 

application

NC Dissipation Half-life (top 15 cm): Biphasic with 23 days half-life for the 

18 
Location (Study 

Study (MRID) Crop Duration; Days) Study Results 

(21+546= 567) fast phase and 187 days for the slow phase 

Leaching: Parent was not detected below 30 cm at any day after last 

application

Study 3 

(2nd set) 

458943-22 

Bare 

plots 

CA 

(21+123=144) 

Dissipation Half-life (top 15 cm): 22 days 

Leaching: Parent was not detected below 30 cm at any day after last 

application

GA 

(21+123=144) 

Dissipation Half-life (top 15 cm): 18 days, observed bi-phasic with <5 

day half-life for the 1st degradation phase 

Leaching: Parent was not detected below 30 cm at any day after last 

application

Turf 

CA 

(21+123=144) 

Grass: Dissipation DT50= 18 days; Thatch: Dissipation DT50= 23 

days; 

Soil: Dissipation DT50= 18 days) 

Leaching: Parent was not detected below 45 cm at any day after last 

application

GA 

(21+123=144) 

Grass: Dissipation DT50= 18 days; Thatch: Dissipation DT50= 18 

days; 

Soil: Dissipation DT50= 13 days 

Leaching: Parent was not detected below 15 cm at any day after last 

application 

Data in Table 7 suggest that Propamocarb-HCl dissipate in four field soils with half-lives 

ranging from 7 to 23 days in bare ground plots. Similar range of half-lives were also observed in 

four turf plots (Range= 10 to 23 days). Half-lives for Propamocarb-HCl were also in the same 

range on the turf grass (18 days), associated thatch layer (18-23 days), and the soil layer below 

(13-18 days). In some soils the degradation profile was biphasic and stated half-lives above 

represent the fast phase (22 to 42 days) which was followed by a slow degradation phase in 

which the chemical degraded with half-lives ranging from 165 to 187 days. Leaching was 

observed to occur within the top 30 cm in bare ground soils and within 15-46 cm in three of the 

turf plots. Leaching of residues to 90 cm and possibly even deeper at levels above the detection 

limit was confirmed at only one site: NY turf site (Maximum sampling depth 90 cm). 

Finally, three environmental chemistry methods (ECM) were submitted for determination of 

Propamocarb-HCl residues in water, surface water, and soil (MRIDs 458943-15, 458943-16, 

and 458943-17, respectively. Each of these methods included an independent laboratory 

validation (ILV). For water, the method was found to be valid for quantitative analysis of 

propamocarb wit an LOD= 0.02 μg/L and LOQ= 0.05 μg/L. For surface water, the method was 

found to be valid for quantitative analysis of propamocarb wit an LOD= 0.1 μg/L and LOQ= 0.5 

μg/L. For soil, the method was found to be valid for quantitative analysis of Propamocarb-HCl 

with an LOD= 0.004 mg/Kg and LOQ= 0.02 mg/Kg.

19 
4. Ecological Effects 

4.1 Aquatic and Terrestrial Effects 

As described in the Agency’s Overview Document (U.S EPA, 2004), the most sensitive endpoint 

for each taxonomic group will be used to calculate risk quotients (RQs). Assessment endpoints 

include direct toxic effects on the survival, reproduction, and growth of terrestrial and aquatic 

life as well as indirect effects such as reduction in prey base and/or modification of habitat. 

Acute and chronic toxicity data from studies submitted by pesticide registrants along with the 

available open literature are used to evaluate the potential direct effects of Propamocarb-HCl to 

the aquatic and terrestrial receptors identified in this section. This includes toxicity data on the 

technical grade active ingredient, degradates, and when available, formulated products. The 

open literature studies are identified through EPA’s ECOTOX database 

(http://cfpub.epa.gov/ecotox/), which employs a literature search engine for locating chemical 

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

data can also provide insight into the direct and indirect effects of Propamocarb-HCl on biotic 

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

and functional characteristics of the affected communities. 

Other sources of information included the use of acute probit dose response relationship to 

establish the probability of an individual effect and reviews of the Ecological Incident 

Information System (EIIS), the American Bird Conservancy’s Avian Incident Monitoring 

System (AIMS) and EFED’s Aggregated Incident database are conducted to further refine the 

characterization of potential ecological effects with exposure to Propamocarb-HCl. A summary 

of the available eco-toxicity information (below Table 8) and the incident information (Section 

4.2) for Propamocarb-HCl are provided below. 

Table 8 provides a summary of the taxonomic groups and the surrogate species tested to help 

understand potential acute and chronic ecological effects of Propamocarb-HCl. In addition, the 

table provides a preliminary overview of the potential acute toxicity of Propamocarb-HCl by 

providing the acute toxicity classifications. The endpoints listed in Table 8 represent the most 

sensitive endpoints for a given taxa as multiple studies were received in some cases to fulfill the 

same data requirement. 

Table 8 Test Species Evaluated for Assessing Potential Acute and Chronic Ecological Effects of 

Propamocarb-HCl

Taxonomic Group Surrogate Species 

Acute Toxicity (LC50, 

EC50, LD50, EC25) 

-- 

Chronic Toxicity 

(NOAEC, LOAEC, 

NOAEL, LOAEL) 

MRID Acute Toxicity 

Classification 

Birds1 Mallard duck (Anas 

platyrhynchos) LC50 = >4160 ppm 

42567903 Slightly toxic 

20 
Taxonomic Group 

Acute Toxicity (LC50, 

EC50, LD50, EC25) 

Surrogate Species -- Acute Toxicity MRID Chronic Toxicity Classification 

(NOAEC, LOAEC, 

NOAEL, LOAEL) 

-- 

LOAEL = 990 ppm (adult 

female body weight) 

NOAEL = 250 ppm 

-- 

46145213 

-- 

Northern bobwhite quail 

(Colinus virginianus) 

LD50 = >2000 mg a.i/kg 

bw 

LC50 = >4160 ppm 

-- 

LOAEL = 4992 ppm 

a.i,(hatchling weight) 

 NOAEL = 500 ppm a.i 

46145210 

42567902 

-- 

46145212 

Practically nontoxic 

Slightly toxic 

-- 

Mammals Laboratory rat (Rattus 

norvegicus) 

LD50 = >2000 mg/kg bw 

-- 

NOAEL = 1250 ppm 

LOAEL = 8000 ppm 

(decreased body weight) 

443049-07 

-- 

44730103, 

44730102 

Practically nontoxic 

-- 

Insects Honey bee (Apis 

mellifera) 

LD50 (contact) = > 100 

ug/a.i/bee 44324501 Practically nontoxic 

Freshwater Fish2

Rainbow trout 

(Oncorhynchus mykiss) 

96-hour LC50 = >99 mg 

a.i/L 42083103 Slightly toxic 

Bluegill sunfish 

(Lepomis macrochirus) 

96-hour LC50 = >92 mg 

a.i/L 42083102 Slightly toxic 

Fathead minnow 

(Pimephales promelas) 

NOAEC = > 6.3, 

LOAEC = 13 (reduced dry 

weight) mg a.i/L 

42083105 -- 

Freshwater 

invertebrates 

Water Flea (Daphnia 

magna) 

48-hour EC50 = >103.4 mg 

a.i/L 

45894303 Practically nontoxic 

Estuarine/marine 

fish 

Sheepshead minnow 

(Cyprinodon variegatus) 

96-hour LC50 = >96.8 mg 

a.i/L 

-- 

No Data submitted 

41834603 

No data 

Slightly toxic 

-- 

Estuarine/marine 

invertebrates 

Mysid shrimp 

(Americamyis bahia) 

96-hour LC50 = 50.5 mg 

a.i/L 

-- 

No Data submitted 

45894306 

-- 

No data 

submitted 

Slightly toxic 

-- 

Eastern oyster 

(Crassotrea virginica) 

96-hour EC50 = 39.2 mg 

a.i/L 42083104 Slightly toxic 

Terrestrial plants Multiple species 

Seedling Emergence: 

Monocot and dicot EC25

for all endpoints = >8.0 

lbs a.i/A 

Vegetative Vigor4

: 

Monocot and dicot EC25

for all endpoints = >8.0 

lbs a.i/A 

45894310 

45894311 

-- 

Aquatic plants Vascular Plant: Tier I EC50 (biomass) = 45894313 -- 

21 
Taxonomic Group 

Acute Toxicity (LC50, 

EC50, LD50, EC25) 

Surrogate Species -- Acute Toxicity MRID Chronic Toxicity Classification 

(NOAEC, LOAEC, 

NOAEL, LOAEL) 

Duckweed (Lemna 

gibba) 

476.1 mg a.i/L 

-- 

NOAEC (biomass) = 

269.1 mg a.i/L 

Green Algae 

(Selenastrum 

capricoruntum) 

Tier I: EC50 (cell density) 

= > 14 mg a.i/L 

-- 

NOAEC (cell density) = 

71 mg a.i/L 

44187802 

-- 

-- 

1

Birds represent surrogates for terrestrial-phase amphibians and reptiles 

2

Freshwater fish represent surrogates for aquatic-phase amphibians 

Terrestrial Species 

Propamocarb-HCl is classified as practically non-toxic to birds on an acute oral basis and slightly 

toxic to birds on an acute dietary basis. Although not an eco-toxicological requirement, a 

mammalian acute oral study with the rat showed that Propamocarb-HCl is practically non-toxic 

on an acute oral basis. An acute contact toxicity study to the honey bee showed that 

propamocarb-HCl is practically non-toxic to terrestrial insects. 

Non-definitive endpoints were observed in the avian acute oral study with bobwhite quail 

(MRID 46145210) and both acute dietary studies with the bobwhite quail and mallard duck 

(MRIDs 42567902 and 42567903, respectively). These endpoints are listed as greater than 

values (e.g. >2,000 mg/kg-bw) because the highest dose tested did not result in at least 50% 

mortality. A definitive RQ value cannot be calculated from these non-definitive endpoints, risk 

cannot be estimated using RQs for these taxa. In looking at previous assessments for 

propamocarb-HCl, the maximum EEC listed in risk assessments (EEC on short grass from 

application to lettuce was 1184 ppm) was below the highest dose tested in both acute oral 

(highest dose tested was 2,000 ppm) and acute dietary (highest dose tested was 4,160 ppm) 

studies. However, in the acute oral toxicity study with the northern bobwhite quail, there were 

mortalities observed in 2 birds at the highest dose tested (2,000 mg/kg bw) within 7 hours of 

administration. Furthermore, treatment related clinical signs of toxicity were observed in birds at 

and above the 500 ppm dose level that included fluid feces, quick breathing, drooping of the 

upper or lower eyelid, hunched posture, abnormal posture of the head, uncoordinated 

movements, tremors, spasms, and slow breathing. This study was originally classified as 

supplemental due to the fact that the study was not conducted with technical grade active 

ingredient (TGAI), as the purity for Propamocarb-HCl in this study was 69.1%. Of note is that 

two mortalities and several treatment-related sublethal effects occurred at the highest dose of this 

formulated product. Additionally, the high percentage of inert ingredients associated with the 

active ingredient may be affecting the bioavailability of the test substance to the test organism. It 

is therefore recommended that a new acute oral toxicity study on the bobwhite quail with 

22 
technical grade propamocarb-HCl be submitted in order to achieve a definitive LD50 while 

investigating the toxicity of TGAI Propamocarb-HCl. An acute oral toxicity study on a 

passerine species is also being requested in order to evaluate Propamocarb-HCl’s toxic effects on 

passerines.

In two dietary toxicity studies (one with mallard duck and one with northern bobwhite quail), 

Propamocarb-HCl was shown to have an LC50 of >4,160 ppm for both studies (the highest doses 

tested for the studies). Both studies were found to be supplemental as they were not conducted 

with TGAI propamocarb-HCl. In the study with the mallard, there was a statistically significant 

reduction in body weight gain and feed consumption was observed at the highest treatment 

concentration. While this concentration is 5 times higher than the highest EEC reported in 

previous risk assessments, it is unclear if non-target species would be affected given that a 

definitive endpoint was not achieved, yet sublethal effects were still noted. Furthermore, this 

study was conducted with a formulated product, and therefore a dietary study on the mallard with 

TGAI may show increased toxicity and the establishment of a definitive LC50. The high 

percentage of inert ingredients associated with the active ingredient may be affecting the 

bioavailability of the test substance to the test organism. A new dietary study with TGAI 

Propamocarb-HCl on the mallard is therefore recommended. 

In the dietary study with the bobwhite quail, the treatment concentrations were 163, 325, 650, 

1,300, 2,600, and 5,200 ppm a.i for nominal concentrations. There were two birds (one from the 

650 ppm dose level and one from the 1,300 ppm dose level) that died during the study. It was 

reported that the bird from the 1,300 ppm group appeared to show signs of pecking by the other 

birds. There were no reductions in bodyweight increase or feed consumption in any of the 

treatment groups during the test. In the initial review of the study, the study reviewer stated that 

the mortality that occurred from the bird in the 1,300 ppm group (that showed signs of being 

pecked) was not treatment related. The initial study reviewer did not address the other mortality 

in the 650 ppm group. The high percentage of inert ingredients associated with the active 

ingredient may be affecting the bioavailability of the test substance to the test organism. As a 

non-definitive endpoint was reached that precludes the ability to estimate risk and two 

mortalities occurred, a new dietary study with TGAI Propamocarb-HCl on the bobwhite quail is 

being recommended. 

In two chronic reproduction studies with the northern bobwhite quail and mallard duck (MRIDs 

46145212 and 46145213, respectively) Propamocarb-HCl yielded a NOAEC of 500 and 250 

ppm, respectively. The bobwhite quail study showed no treatment related mortalities and there 

was a treatment related statistically significant decrease in hatchling weight in the highest dose 

level tested. This study was found to be supplemental due to the use of a formulated product and 

not TGAI Propamocarb-HCl. In the mallard study, there was no treatment related to the 

observed mortalities. At the highest dose level (3800 ppm), treatment related sublethal effects 

included decreases in eggs laid per pen, eggs set per pen, viable embryos per pen, live embryos 

per pen, number of hatchlings per pen, hatchlings per eggs set, hatchling survival per pen, and 

hatchling survival per eggs. Again, this study was found to be supplemental due to the use of a 

formulated product and not TGAI Propamocarb-HCl. 

23 
In an acute oral study with the laboratory rat (MRID 443049-07), Propamocarb-HCl was shown 

to be practically non-toxic to mammals with a LD50 of >2,000 mg/kg bw (the highest dose 

tested). There were no sublethal effects observed during the course of the study. 

In a mammalian two-generation reproduction study with the laboratory rat (MRIDs 44730103, 

44730102), there were statistically significant reductions in mean body weights of the F1

generation at the highest treatment level (8,000 ppm). Mean food consumption values were also 

significantly reduced at the highest dose level. The NOAEL was therefore determined to be 

1250 pm. There were no effects at any treatment level other than the highest. The dietary 

exposure levels for this study were: 0 (control), 250, 1,250, and 8,000 ppm. 

Aquatic Species 

Propamocarb-HCl is classified as slightly toxic to freshwater fish and practically non-toxic to 

freshwater invertebrates on an acute basis. In acute toxicity tests with rainbow trout and bluegill 

sunfish (MRIDs 42083103 and 42083102, respectively) non-definitive endpoints were reached 

(LC50/EC50 values of >99 mg a.i/L, >92 mg a.i/L, respectively, mean measured concentrations). 

In the both studies, there were no mortalities observed, nor were any sublethal effects reported. 

Previous risk assessments have reported that maximum EECs in surface water (from application 

to lettuce) reached 162 μg a.i/L which is several orders of magnitude less than the highest 

concentration tested in both studies (100 mg a.i/L nominal concentration). As there is no 

incident data indicating a risk to freshwater fish. Therefore, the presumed risk to freshwater fish 

is considered low and additional toxicity data are not recommended. 

In an acute toxicity study with Daphnia magna (MRID 45894303), there were no mortalities or 

sublethal effects observed and, the EC50 (>103.4 mg a.i/L) was several orders of magnitude 

below to maximum EEC determined in previous assessments (162 μg a.i/L). There are no 

incident data indicating a risk to freshwater invertebrates from Propamocarb-HCl The presumed 

risk to this taxa is low. 

In a freshwater fish early life stage test with the fathead minnow (MRID 42083105), there were 

no treatment related effects on percent hatching success at all treatment levels. The treatment 

levels for this test were defined as 3.5, 6.3, 13, 25, and 51 mg a.i/L. Fish wet weight and length 

at concentrations 25 and 51 mg a.i/L were significantly different from the control. Fish dry 

weight at 13, 25, and 51 mg a.i/L were significantly reduced when compared to the control. 

This study was classified as supplemental due to the fact that a formulated product was used 

instead of TGAI Propamocarb-HCl. 

A chronic freshwater invertebrate toxicity study with Daphnia magna was previously submitted, 

but found to be invalid for several reasons. Insufficient analytical sampling was conducted to 

provide accurate mean-measured concentrations and to verify the stability of Propamocarb-HCl 

in the test media for up to 72 hours between renewal periods. Furthermore, the study does not 

fulfill guideline requirements because it was not conducted with technical-grade active 

ingredient, and terminal length measurements were not obtained. The registrant submitted 

another chronic toxicity study in Daphnia (MRID 45727801), which is currently undergoing 

Agency review. This study remains a data requirement for Propamocarb-HCl until EPA has 

reviewed and approved a chronic toxicity study for Daphnia. 

24 
Propamocarb-HCl is shown to be practically non-toxic to estuarine/marine fish and slightly toxic 

to estuarine/marine invertebrates on an acute exposure basis. In an acute toxicity test with the 

sheepshead minnow (MRID 41834603), Propamocarb-HCl exposure resulted in no mortalities 

or sublethal effects at the lone treatment level (100 mg a.i/L nominal concentration, 96.8 mg 

a.i/L mean measured concentration). Even though the study failed to reach a definitive LC50, as 

the highest EEC reported in previous assessment (162 μg a.i/L for application on lettuce) is 

several orders of magnitude below the highest treatment level tested for this study (96.8 mg a.i/L 

mean measured) and there is no incident data indicating Propamocarb-HCl poses a threat to 

estuarine/marine fish, the presumed risk for this taxa despite the absence of a definitive endpoint 

is low. There were no sublethal effects in the acute toxicity test with the mysid shrimp. The 

acute toxicity study with the eastern oyster (shell deposition) showed a slightly more sensitive 

endpoint than that of the mysid study (LC50 = 39.2 mg a.i/L for oysters and LC50 = 50.5 mg a.i/L 

for mysids. Both studies were determined to be supplemental due to a formulated product being 

used instead of TGAI Propamocarb-HCl. 

An early life stage toxicity test with the sheepshead minnow and a chronic life stage invertebrate 

toxicity test with the mysid shrimp are conditionally required provided that several triggers of 

toxicity and exposure are met. For Propamocarb-HCl, the only triggers that are expected to be 

met is the persistence in water (half-life greater than 4 days) and the likelihood to enter the 

estuarine/marine environment as Propamocarb-HCl has a very high solubility and a propensity to 

leach off soil. Based on the fact that the chemical is stable to hydrolysis, it is expected that the 

half-life will be longer than 4 days in the recommended aerobic aquatic metabolism study. 

Therefore, sheepshead minnow early life stage toxicity test and a chronic life stage invertebrate 

toxicity test with the mysid shrimp are requested. If a new aerobic aquatic metabolism study 

shows the half life to be less than 4 days, these two studies may be waived. 

Available environmental fate studies show degradation of Propamocarb-HCl, in the soil system, 

can be mainly related to microbially mediated mineralization to CO2. There is a fraction of 

propamocarb that is unidentified bound residue where the toxicity is not known. When the Tier 

1 aquatic model GENEEC is run with the highest application rate (64 lbs a.i/A) from previous 

assessments under the assumption that degradates are as toxic as the parent, the resulting EEC is 

3.22 ppm. When taking the most sensitive aquatic organism in toxicity tests (Eastern oyster) 

EC50 of 39.2 mg a.i/L, the resulting RQ is 0.08. This value is below the acute high risk to nonlisted species LOC, and risk that may be mitigated through restricted use LOC, but above the 

endangered species LOC. The uncertainty that goes along with the toxicity of the bound residue 

is an issue that will need to be revisited pending future uses of Propamocarb-HCl. In the absence 

of sediment toxicity studies, the assumption is made that the bound residue is as toxic as the 

parent compound which lengthens half lives and increases aquatic EECs. 

Terrestrial and Aquatic Plants 

Tier I Seedling Emergence (MRID 45894310) and Vegetative Vigor (MRID 45894311) studies 

were previously submitted and classified as acceptable. Propamocarb-HCl exposure did not 

result in a 25% reduction of endpoints in either study and therefore Tier II studies are not 

required. It was determined however that because a NOAEC could not be established in all 

species for both the seedling emergence and vegetative vigor studies (and therefore an inability 

25 
to estimate an EC05 values in lieu of a NOAEC), the utility of the study will be impacted when 

characterizing risk to endangered species. Despite this, the data requirements for Terrestrial 

Plant studies for Propamocarb-HCl are fulfilled. 

An aquatic plant study with freshwater green algae (Selenastrum capricornutum) (MRID 

45894312) was submitted and classified as supplemental. The study was deemed to be 

scientifically sound but because it was only conducted for 72 hours and not 96 hours, current 

policy is to only consider those studies as screening studies only. Furthermore the test solutions

were not measured during the study at every test level. Despite these deficiencies, this study is 

suitable for use in risk assessment in that scientifically sound endpoint can be derived. 

An aquatic plant study (MRID 45894313) with a freshwater vascular plant (Lemna minor) was 

submitted and classified as acceptable. 

4.2 Incident Database Review 

A preliminary review of the Ecological Incident Information System (EIIS, Version, 2.1) which 

is maintained by the Agency’s Office of Pesticide Programs indicated one reported ecological 

incident. The incident occurred in Montana in July of 2002 on sugar beets with the primary 

symptom of stunting being reported. This incident number is I013246-040 with the product 

PREVICUR® FLEX that was applied to a 500-acre crop and reportedly damaged 200 acres. The 

probable cause was determined to be adjuvant. Sugar beets is not included as a crop suitable for 

treatment with PREVICUR FLEX® but the sugar beet might have been included under an 

umbrella of tank mixtures, according to the report submitted by Bayer Crop Sciences. A search 

of the Avian Monitoring Information System (AIMS), which is maintained by the American Bird 

Conservancy and the EFED Aggregated Incident Database, yielded no reported ecological 

incident associated with the use of Propamocarb-HCl. 

Incident reports for non-target organisms typically provide information only on mortality events 

and plant damage incidents. Except for phytotoxic effects in terrestrial plants, sublethal effects 

for organisms such as reduced growth or impaired reproduction are rarely reported. 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 effect due to a lack of resources. 

4.3 Ecosystems Potentially at Risk 

The ecosystems at risk are often extensive in scope, and as a result it may not be possible to 

identify specific ecosystems during the development of a baseline risk assessment. However, in 

general terms, terrestrial ecosystems potentially at risk could include the treated field and areas 

immediately adjacent to the treated field that may receive drift or runoff. Areas adjacent to the 

treated field could include cultivated fields, fencerows and hedgerows, meadows, fallow fields or 

grasslands, woodlands, riparian habitats and other uncultivated areas. 

26 
Aquatic ecosystems potentially at risk include water bodies adjacent to or down-stream from, the 

treated field and might include impounded bodies such as ponds, lakes and reservoirs, or flowing 

waterways such as streams or rivers. For uses in coastal areas, aquatic habitat also includes 

marine ecosystems, including estuaries. 

4.4 Assessment Endpoints 

Assessment endpoints represent the actual environmental value that is to be protected, defined by 

an ecological entity (species, community, or other entity) and its attribute or characteristics 

(EPA, 1998). For Propamocarb-HCl, the ecological entities may include the following: birds, 

mammals, freshwater fish and invertebrates, estuarine/marine fish and invertebrates, terrestrial 

plants, insects, and aquatic plants and algae. The attributes for each of these entities may include 

growth, reproduction, and survival. 

4.5 Conceptual Model 

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

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

environment from a source to an ecological receptor. For an ecological pathway to be complete, 

it must have a source, a release mechanism, an environmental transport medium, a point of 

exposure for ecological receptors, and a feasible route of exposure. 

The conceptual model for Propamocarb-HCl provides a written description and visual 

representation of the predicted relationships between propamocarb-HCl, potential routes of 

exposure, and the predicted effects for the assessment endpoint. According to EPA’s ecological 

risk assessment guidelines (U.S EPA, 1998) a conceptual model consist of two major 

components: a risk hypothesis and a conceptual diagram. 

Risk Hypothesis 

A risk hypothesis describes the predicted relationship among the stressor, exposure, and 

assessment endpoint response along with the rationale for their selection. For propamocarb-HCl, 

the following ecological risk hypothesis is being employed for this national-level risk 

assessment: 

Propamocarb-HCl, when used in accordance with registered labels, will likely lead to 

off-site movement of the compound via runoff, spray drift, and eroded soil leading to 

exposure of non-target plants and animals. Based on information on environmental fate, 

mode of action, direct toxicity, and potential indirect effect, EFED assumes that 

registered uses of Propamocarb-HCl have the potential to cause reduced survival, 

growth, and reproduction to non-target terrestrial plants and/or aquatic animals and 

plants. Based on available data and previous risk assessments for propamocarb-HCl, 

acute risk to terrestrial organisms is presumed to be low. 

Conceptual Diagram 

27 
The conceptual site model is a generic graphic depiction of the risk hypothesis, and assumes that 

Propamocarb-HCl, having outdoor uses only, is capable of affecting aquatic and terrestrial 

animals provided that environmental concentrations are sufficiently elevated as a result of 

proposed label uses. Based on an examination the physicochemical properties of PropamocarbHCl, the fate and disposition in the environment, and mode of application, a conceptual model 

was developed that represents the possible relationships between the stressors, ecological 

receptors, and assessment endpoints. Through a preliminary iterative process of examining 

available data, the conceptual model (i.e., the representation of the risk hypothesis) may be 

refined to reflect the likely exposure pathways and the organisms that are the most relevant and 

applicable to this assessment. It includes the potential pesticide or stressor (Propamocarb-HCl), 

the sources and/or transport pathways, exposure media, exposure points, biological receptor 

types, and attributes changes. The conceptual model depicted in Figures 2 and 3. This model 

represents labeled uses for propamocarb-HCl including both urban outdoor uses of. 

28 
Figure 3 A conceptual model for Propamocarb-HCl effects on aquatic organisms 

Stressor 

Source

Receptors 

Attribute 

Change 

Propamocarb HCl applied to use site 

Spray drift 

Fish/aquatic-phase 

amphibians 

Invertebrates 

Vertebrates 

**Piscivorous 

mammals and birds 

Individual organisms 

Reduced survival 

Reduced growth 

Reduced reproduction 

Food chain 

Reduction in algae 

Reduction in prey 

Habitat integrity 

Reduction in primary productivity

Reduced cover 

Community change 

Surface water/ 

Sediment 

Runoff 

Aquatic Animals 

Invertebrates 

Vertebrates 

Exposure 

Media 

Uptake/gills 

or integument 

Ingestion Ingestion

Soil Ground water 

Uptake/gills 

or integument 

Aquatic Plants 

Non-vascular 

Vascular 

Uptake/cell, 

roots, leaves Riparian plant

terrestrial 

exposure 

pathways see 

Figure 2 

**Route of exposure includes only ingestion of fish and aquatic invertebrates 

29 
Figure 4 A conceptual model of Propamocarb-HCl effects on terrestrial organisms 

Stressor 

Source

Receptors 

Attribute 

Change 

Propamocarb HCl applied to use site 

Direct 

Application Spray drift 

Birds / Terrestrialphase amphibians 

/ reptiles / 

mammals 

Terrestrial 

Insects 

Individual organisms 

Reduced survival 

Reduced growth 

Reduced reproduction 

Food chain 

Reduction in prey 

Habitat integrity 

Reduction in primary productivity

Reduced cover 

Community change 

Terrestrial/riparian plants 

grasses/forbs, fruit, seeds 

(trees, shrubs) 

Runoff 

Mammals

Exposure 

Media 

Soil 

Ingestion 

Ingestion

Ingestion

Ingestion

Dermal uptake/Ingestion 

Root uptake 

Terrestrial food 

web 

Ingestion 

In order for a chemical to pose an ecological risk, it must reach ecological receptors in 

biologically significant concentrations. Exposure pathway is the means by which a pesticide 

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

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

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

addition, the potential mechanisms of degradation/ transformation (i.e. which degradation/ 

transformation products may form in the environment, in which media, and how much) must be 

understood, especially if for the chemical, its metabolites/transformation products are of greater 

toxicological concern than the parent compound. The assessment of ecological exposure 

pathways, therefore, includes an examination of the source and potential migration pathways for 

constituents, and the determination of potential exposure routes. 

In the case of Propamocarb-HCl, mammals are exposed to the chemical but available data have 

shown that the chemical is not toxic, even beyond levels that are the result of registered uses. 

EFED presumes the likelihood of risk to be low based on available data from mammalian studies 

as well as previous risk assessments for Propamocarb-HCl where it was determined that risk to 

mammals was below levels of concern. In the case of birds, despite available data indicating 

Propamocarb-HCL is slightly to practically non-toxic to birds (depending on the exposure and 

30 
test species), these studies were conducted with formulated product and so while previous risk 

assessments have concluded low risk to avian species, there is still some uncertainty in this 

statement until new studies with TGAI are conducted. 

5. Analysis Plan 

In order to address the risk hypothesis, the potential for adverse effect on the environment is 

estimated. The use, environmental fate, and ecological effects of Propamocarb-HCl are 

characterized and integrated to assess the risks. This is accomplished using a risk quotient (ratio 

of exposure concentration to effect concentration) approach. Although risk is often defined as 

the likelihood and magnitude of adverse ecological effects, the risk-quotient based approach does 

not provide a quantitative estimate of likelihood and/or magnitude of an adverse effect. 

However, as outlined in the Overview Document (U.S EPA, 2004), the likelihood of effects to 

individual organisms from particular uses of propamocarb-HCl is estimated using the probit-dose 

response slope and either the level of concern (discussed below) or actual calculated risk quotient 

value. 

This analysis plan will be revisited and may be revised depending on the information submitted 

by the public in response to the opening of the Registration Review docket for PropamocarbHCl. 

5.1 Stressors of Concern 

The stressor of concern for this assessment is the total toxic residue of parent compound 

propamocarb-HCl and bound residue with the assumption that the bound residue is of equal 

toxicity to the parent the bound residue is considered as part of the stressor because it forms in 

significant amounts in the aerobic soil. 

5.2 Measures of Exposure 

Exposure modeling is an important step in estimating risks of Propamocarb-HCl. All exposure 

modeling in aquatic and terrestrial environments will be based on maximum application rates, 

minimum application intervals and maximum number of applications for a given use. Measures 

of exposure are based on aquatic and terrestrial models that predict estimated environmental 

concentrations (EECs) of Propamocarb-HCl. The models that will be used to predict aquatic 

EECs are the Pesticide Root Zone Model coupled with the Exposure Analysis Model System 

(PRZM/EXAMS). The model used to predict terrestrial EECs on food items is T-REX. The 

model to derive EECs relevant to terrestrial and wetland plants is TerrPlant. These models are 

parameterized using relevant reviewed registrant-submitted environmental fate data. 

Exposure estimates for terrestrial animals assumed to be in the target area or in an area exposed 

to spray drift are derived using the T-REX model (version 1.3.1, 12/07/2006). This model 

incorporates the Kenega nomograph, as modified by Fletcher et al. (1994), which is based on a 

large set of actual field residue data. The upper limit values from the nomograph represented the 

95th percentile of residue values from actual field measurements (Hoerger and Kenega, 1972). 

The Fletcher et al. (1994) modifications to the Kenega nomograph are based on measured field 

31 
residues from 249 published research papers, including information on 118 species of plants, 121 

pesticides, and 17 chemical classes. EECs for terrestrial plants inhabiting dry and wetland areas 

are derived using TerrPlant (version 1.2.2, 12/26/2006). This model uses estimates of pesticides 

in runoff and in spray drift to calculate EECs. EECs are based upon solubility, application rate 

and minimum incorporation depth. 

5.3 Measures of Effect 

Ecological effect data are used as measures of direct and indirect effects to biological receptors. 

Data were obtained from registrant-submitted studies or from literature studies identified by 

ECOTOX. The ECOTOXicology database (ECOTOX) was searched on May 1, 2008 in order to 

provide more ecological effects data to bridge existing data gaps. ECOTOX is a source for 

locating single chemical toxicity data and potentially chemical mixture toxicity data for aquatic 

life, terrestrial plants, and wildlife. ECOTOX was created and is maintained by the USEPA, 

Office of Research and Development, and the National Health and Environmental Effects 

Research Laboratory's Mid-Continent Ecology Division (ECOTOX, 2006). 

Information on the potential effects of Propamocarb-HCl on non-target animals is also collected 

from the Ecological Incident Information System (EIIS; USEPA 2007c). The EIIS is a database 

containing adverse effect (typically mortality) reports on non-target organisms where such 

effects have been associated with the use of pesticides. Where available, sublethal effects 

observed in both registrant-submitted and open literature studies will be evaluated qualitatively. 

Such effects have included behavioral changes (e.g., lethargy, changes in coloration and effects 

olfaction). Quantitative assessments of risks, though, are limited to those endpoints that can be 

directly linked to the Agency’s assessment endpoints of impaired survival, growth and 

reproduction. 

The assessment of risk for direct effects to non-target organisms makes the assumption that 

toxicity of Propamocarb-HCl to birds is similar to terrestrial-phase amphibians and reptiles. The 

same assumption is made for fish and aquatic-phase amphibians. 

The acute measures of effect used for animals in this screening-level assessment are the LD50, 

LC50 and EC50 (Table 9). LD stands for "Lethal Dose", and LD50 is the amount of a material, 

given all at once, that is estimated to cause the death of 50% of the test organisms. LC stands for 

“Lethal Concentration” and LC50 is the concentration of a chemical that is estimated to kill 50% 

of the test organisms. EC stands for “Effective Concentration” and the EC50 is the concentration 

of a chemical that is estimated to produce a specific effect in 50% of the test organisms. 

Endpoints for chronic measures of exposure for listed and non-listed animals are the 

NOAEL/NOAEC and NOEC. NOAEL stands for “No Observed-Adverse-Effect-Level” and 

refers to the highest tested dose of a substance that has been reported to have no harmful 

(adverse) effects on test organisms. The NOAEC (i.e., “No-Observed-Adverse-EffectConcentration”) is the highest test concentration at which none of the observed effects were 

statistically different from the control. The NOEC is the No-Observed-Effects-Concentration. 

For non-listed plants, only acute exposures are assessed (i.e., EC25 for terrestrial plants and EC50

for aquatic plants); for listed plants, either the NOAEC or EC05 is used. 

32 
Table 9 Measures of Ecological Effects and Exposure for Propamocarb-HCl

Assessment Endpoint 

Surrogate Species and 

Measures of Ecological 

Effect1 

Measures of Exposure 

Birds2 

Survival 

Bobwhite acute oral LD50

Bobwhite and mallard 

subacute dietary LC50

Maximum residues on food 

items (foliar) 

Reproduction and 

growth 

Bobwhite and mallard chronic 

reproduction NOAEC and 

LOAEC 

Mammals 

Survival Laboratory rat acute oral LD50

Reproduction and 

growth 

Laboratory rat oral 

reproduction chronic NOAEC 

and LOAEC 

Freshwater fish3 

Survival Rainbow trout and bluegill 

sunfish acute LC50

Peak EEC4 

Reproduction and 

growth 

Fathead minnow 

chronic (early life-stage) 

NOAEC and LOAEC 

60-day average EEC4 

Freshwater 

invertebrates 

Survival 

Water flea (and other 

freshwater invertebrates) 

acute EC50

Peak EEC4 

Reproduction and 

growth 

Water flea chronic (life cycle) 

LOAEC (no study usable for 

quantitative risk assessment) 

21-day average EEC4 

Estuarine/marine fish 

Survival Sheepshead minnow acute 

LC50

Peak EEC4 

Reproduction and 

growth 

Sheepshead minnow chronic - 

early life-stage – (no study 

submitted 

60-day average EEC4 

Estuarine/marine 

invertebrates 

Survival Eastern oyster acute EC50 and 

mysid acute LC50

Peak EEC4 

Reproduction and 

growth No study submitted 21-day average EEC4 

Terrestrial plants5 Survival and growth 

Monocot and dicot seedling 

emergence and vegetative 

vigor EC25, EC05, and 

NOAEC values 

Estimates of runoff and spray 

drift to non-target areas 

Insects Survival (not 

quantitatively assessed) Honeybee acute contact LD50 Maximum application rate 

Aquatic plants and 

algae Survival and growth 

Algal and vascular plant (i.e., 

duckweed) EC50 and NOAEC 

values for growth rate and 

biomass measurements 

Peak EEC 

1 If species listed in this table represent most commonly encountered species from registrant-submitted studies, risk assessment 

guidance indicates most sensitive species tested within taxonomic group are to be used for baseline risk assessments. 

2 Birds represent surrogates for amphibians (terrestrial phase) and reptiles. 3 Freshwater fish may be surrogates for amphibians (aquatic phase). 4 One in 10-year return frequency. 

5 Four species of two families of monocots - one is corn, six species of at least four dicot families, of which one is soybeans. 

LD50 = Lethal dose to 50% of the test population; NOAEC = No observed adverse effect concentration; LOAEC = Lowest 

33 
observed adverse effect concentration; LC50 = Lethal concentration to 50% of the test population; EC50/EC25 = Effect 

concentration to 50%/25% of the test population.

5.4 Integration of Exposure and Effects 

Risk characterization is the integration of exposure and ecological effects characterization to 

determine the potential ecological risk from the use of pesticides and the likelihood of direct and 

indirect effects to non-target organisms in aquatic and terrestrial habitats. The exposure and 

toxicity effects data are integrated in order to evaluate the risks of adverse ecological effects on 

non-target species. For the assessment of risks, the risk quotient (RQ) method is used to 

compare exposure and measured toxicity values. EECs are divided by acute and chronic toxicity 

values. The resulting RQs are then compared to the Agency’s Levels of Concerns (LOCs) (U.S 

EPA, 2004). These criteria will be used to indicate when Propamocarb-HCl’s uses, as directed o 

the label, have the potential to cause adverse direct or indirect effects to non-target organisms. In 

addition, incident data from the EIIS will be considered as part of the risk characterization. 

 5.5 Endangered Species Assessments 

Consistent with the Agency’s responsibility under the Endangered Species Act (ESA), the 

Agency will evaluate risks to Federally-listed threatened and/or endangered (listed) species from 

registered uses of Propamocarb-HCl. This assessment will be conducted in accordance with the 

Overview Document (USEPA 2004), provisions of the ESA, and the Services’ Endangered 

Species Consultation Handbook (USFWS/NMFS, 1998). 

The assessment of effects associated with the registration of Propamocarb-HCl is based on an 

action area. The action area is considered to be the area directly or indirectly affected by the 

federal action, as indicated by the exceedance of Agency Levels of Concern (LOCs) used to 

evaluate direct or indirect effects. The Agency’s approach to defining the action area under the 

provisions of the Overview Document (USEPA 2004) considers the results of the risk 

assessment process to establish boundaries for that action area with the understanding that 

exposures below the Agency’s defined LOCs constitute a no-effect threshold. For the purposes 

of this assessment, attention will be focused on the footprint of the action (i.e., the area where 

Propamocarb-HCl application occurs), plus all areas where offsite transport may result in 

potential exposure that exceeds the Agency’s LOCs. Specific measures of ecological effect that 

define the action area for listed species include any direct and indirect effects and/ or potential 

modification of its critical habitat, including reduction in survival, growth, and reproduction as 

well as the full suite of sub-lethal effects available in the effects literature. Therefore, the action 

area extends to a point where environmental exposures are below any measured lethal or sublethal effect threshold for any biological entity at the whole organism, organ, tissue, and/or 

cellular level of organization. In situations where it is not possible to determine the threshold for 

an observed effect, the action area is not spatially limited and is assumed to be the entire United 

States. 

5.6 Drinking Water Assessment 

34 
A

a

estimates of Propamocarb-HCl in surface

Propamocarb-HCl in surface waters will 

 drinking water assessment will be conducted to support future human health dietary risk 

ssessments of Propamocarb-HCl. The drinking water assessment will incorporate model 

 water and ground water. Concentrations of 

be estimated using PRZM/EXAMS (see description 

 be 

 concentrations found in ground water used as drinking water. The output of SCIn 

sediment were found at the present time. 

f 

ided at: 

nation_cy.cause_detail_303d?p_cause_group_id=88

above). 

EFED’s Tier I aquatic model SCI-GROW (Screening Concentration in Ground Water) will

used to arrive at the Estimated Drinking Water Concentration (EDWC) of propamocarb-HCl 

residues in ground water. SCI-GROW is a regression model used as a screening tool to estimate 

pesticide

GROW represents the concentrations that might be expected in shallow unconfined aquifers 

under sandy soils, which represents the ground water most vulnerable to pesticide contaminatio

and likely to serve as a drinking water source. 

The drinking water assessment will also include any available surface and ground water 

monitoring data with consideration of changes in use patterns that may have occurred. States are 

encouraged to submit monitoring data for review. 

5.7 Monitoring Data 

The USGS NAWQA5

 databases were searched, and no monitoring data on the concentration of 

Propamocarb-HCl in surface water, groundwater, or 

5.8 Clean Water Act 

Based on the EPA list of impaired water bodies, Propamocarb-HCl is not identified as a cause o

impairment for any water bodies listed as impaired under section 303(d) of the Clean Water Act, 

based on information prov

http://iaspub.epa.gov/tmdl_waters10/attains_

5. 

Also, no Total Maximum Daily Loads (TMDL) has been developed for Propamocarb-HCl, based 

on information provided at: 

http://iaspub.epa.gov/tmdl_waters10/attains_nation.tmdl_pollutant_detail?p_pollutant_group_id

=885&p_pollutant_group_name=PESTICIDES. 

More information on impaired water bodies and TMDLs can be found at: 

http://www.epa.gov/owow/tmdl/. 

The Agency invites submission of water quality data for this pesticide. To the extent possible, 

ndard Operating 

ta in OPP’s 

t and Management Process. This procedure can be found at: 

data should conform to the quality standards in Appendix A of the OPP Sta

Procedure: Inclusion of Impaired Water Body and Other Water Quality Da

Registration Review Risk Assessmen

http://www.epa.gov/oppfead1/cb/ppdc/2006/november06/session1-sop.pdf

 

5 http://infotrek.er.usgs.gov/nawqa_queries/swmaster/index.jsp (visited June, 24, 2011) 

35 
Data should conform to the referenced quality standards in order to ensure they can be used 

quantitatively or qualitatively in pesticide risk assessments. 

5.9 Endocrine Disruptor Screening Program (EDSP) 

As required by FIFRA and FFDCA, EPA reviews numerous studies to assess potential adverse 

s include acute, sub-chronic and 

toxicity, developmental, 

productive, and general or systemic toxicity. These studies include endpoints which may be 

nd 

 Administrator 

may designate.” The EDSP employs a two-tiered approach to making the statutorily required 

 a 

l 

A 

and 

ropamocarbCl is not among the group of 58 pesticide active ingredients on the initial list to be screened 

 with 

of 

outcomes from exposure to chemicals. Collectively, these studie

chronic toxicity, including assessments of carcinogenicity, neuro

re

susceptible to endocrine influence, including effects on endocrine target organ histopathology, 

organ weights, estrous cyclicity, sexual maturation, fertility, pregnancy rates, reproductive loss, 

and sex ratios in offspring. For ecological hazard assessments, EPA evaluates acute tests a

chronic studies that assess growth, developmental and reproductive effects in different 

taxonomic groups. As part of its re-registration decision, EPA reviewed these data and selected

the most sensitive endpoints for relevant risk assessment scenarios from the existing hazard 

database. However, as required by FFDCA section 408(p), Propamocarb-HCl is subject to the

endocrine screening part of the Endocrine Disruptor Screening Program (EDSP). 

EPA has developed the EDSP to determine whether certain substances (including pesticide 

active and other ingredients) may have an effect in humans or wildlife similar to an effect 

produced by a “naturally occurring estrogen, or other such endocrine effects as the

determinations. Tier 1 consists of a battery of 11 screening assays to identify the potential of

chemical substance to interact with the estrogen, androgen, or thyroid (E, A, or T) hormona

systems. Chemicals that go through Tier 1 screening and are found to have the potential to 

interact with E, A, or T hormonal systems will proceed to the next stage of the EDSP where EP

will determine which, if any, of the Tier 2 tests are necessary based on the available data. Tier 2

testing is designed to identify any adverse endocrine-related effects caused by the substance, 

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

Under FFDCA section 408(p), the Agency must screen all pesticide chemicals. Between 

October 2009 and February 2010, EPA issued test orders/data call-ins for the first group of 67 

chemicals, which contains 58 pesticide active ingredients and 9 inert ingredients. P

H

under the EDSP. On November 17, 2010, a notice from the Federal Register was released

the planned second list of chemicals to have the Tier I Screening Level performed and includes

134 chemicals. Propamocarb-HCl is not among this list of chemicals. Accordingly, as part of 

registration review, EPA will issue future EDSP orders/data call-ins, requiring the submission 

EDSP screening assays for Propamocarb-HCl. For further information on the status of the 

EDSP, the policies and procedures, the list of 67 chemicals, future lists, the test guidelines and 

the Tier 1 screening battery, please visit our website: http://www.epa.gov/endo/. 

36 
5.10 Uncertainty and Preliminary Identification of Data Gaps 

Environmental Fate & Transport 

Review of submitted studies reveals that bound residues had formed in significant quantities in 

certain aerobic soils and its identity and toxicity is unknown. In deciding on the stressor, all 

residues are to be considered when it is of toxicological concern. The observed significant bound 

residue in some of the soils was only quantified by radioactivity but was not identified. 

Therefore, uncertainty exists, on determining the stressor of concern, until the bound residue 

toxicity is established. For modeling currently reported half-lives can only be used on the 

assumption that the stressor is parent alone and the significant bound residue is of no 

toxicological concern. In case the bound residue was found to be of toxicological concern, halflives are to be recalculated for the stressor which will be parent plus bound residue. 

Also, uncertainty exists in the expected fate of the chemical in aerobic aquatic systems as no 

studies were submitted. Furthermore, uncertainty also exists in the expected behavior of the 

chemical in anaerobic aquatic systems because the only submitted study included one pond 

system in which the anaerobic conditions were not maintained. Lastly, submitted mobility data 

points out to high probability for leaching in some soils and uncertainty exists on the type(s) of 

soils in which such leaching may occur. Additional adsorption/desorption data are necessary 

along with higher levels of soil characterization (such as mineralogy) in order to understand the 

reason for the observed differences in the mobility data. This will help in identifying the type of 

soils were leaching to ground water may occur. This might also explain differences in the 

observed leaching profiles in previously submitted field dissipation studies. Table 10 below lists 

the status of environmental fate data requirements for Propamocarb-HCl. 

The list of studies that were submitted is included previously in Tables 4, 5, 6, and 7 located in 

Section 3.3 (Environmental Fate and Transport) and in Appendix B. Based on examination of 

the available data and its quality in addition to identified uncertainties, EFED recommends the 

following: 

- Submittal of a new aerobic aquatic study (Guideline number 835.4300) for two system from 

areas, in the USA, where the chemical is expected to be used; 

- Submittal of a new anaerobic aquatic study (Guideline number 835.4400) for one system 

from an area, in the USA, where the chemical is expected to be used with special attention to 

monitoring and maintaining the anaerobic condition of the system as per guideline. 

- Submittal of one adsorption/desorption study (Guideline number 835.1230) for two soil 

from areas, in the USA, where the chemical is expected to be used. In choosing the two 

soils, the purpose of this recommendation is to be considered; that is to “understand the 

reason for the observed differences in the mobility data” and to identify the type of soil 

37 
Table 10. Environmental fate Data Requirements for Propamocarb-HCl

Guideline 

Number 

Data Requirement Additional Data Needed 

for Risk Assessment? MRID #’s Study Classification 

835.2120 Hydrolysis NO 000712-97 S 

835.2240 Photo-degradation in water NO 000712-96 A 

835.2410 Photo-degradation on soil NO 

045893-18 

418346-08 

S 

A 

835.4100 Aerobic soil metabolism NO 

412781-25

412781-26 

412781-27 

458943-19 

A 

A 

A 

S

835.4200 Anaerobic soil metabolism NO 412781-29 A 

835.4300 Aerobic Aquatic Metabolism 

Yes: Submittal of new 

study None submitted N/A 

835.4400 Anaerobic Aquatic Metabolism 

Yes: Submittal of new 

study 445385-04 (A) A 

835.1230 

835.1240 

Leaching and adsorption/ 

desorption 

Yes: Submittal of new 

study* 

412781-30 

458943-21 

412781-32 

000714-72 

458943-20 

412781-31

S 

S (Upgradable) 

A 

S 

S 

U 

835.6100 Terrestrial Field Dissipation NO 

424212-02 

440016-01 

458943-22 

S 

A 

S 

Fish Bio-concentration NO 

412781-14 

458943-23 

A 

U 

Special 

Environmental Chemistry Methods 

and Independent Laboratory 

Validations NO 

458943-15 

458943-16 

458943-17 

A 

A 

A 

A= Acceptable; S= Supplemental; U=Unacceptable 

* New study is needed in order to understand the reason for the observed differences in previously 

submitted mobility data and identify the soils were leaching to ground water may occur

Ecological Effects 

The majority of the studies (both terrestrial and aquatic) submitted for Propamocarb-HCl were 

conducted using a formulated product rather than TGAI Propamocarb-HCl. While all but one of 

these studies was scientifically sound, there is uncertainty in that a higher percent active 

ingredient formulation may cause increased toxicity than what was seen in previously submitted 

studies. Specifically the studies that fail to achieve an LD/LC/EC50 are highly uncertain as these 

studies were conducted using a product with a percent active ingredient in the range of 60 – 70% 

38 
a.i. While the majority of these studies observed no mortalities or sublethal effects, uncertainty 

still exists in all taxa that the formulated product was used when TGAI should have been. 

The list of studies that were submitted is included previously in Tables 7 located in a previous 

section (Section 4.1). Based on examination of the available data and its quality, EFED 

recommends the following: 

- Submittal of a new acute oral toxicity study on the bobwhite quail with TGAI (OCSPP 

850.2100) 

- Submittal of two new acute dietary studies (one with the northern bobwhite quail and one 

with the mallard duck) conducted with TGAI (OCSPP 850.2200) 

- Submittal of an avian acute oral toxicity study with a passerine species conducted with 

TGAI 

- Submittal of a chronic freshwater invertebrate life cycle toxicity study with the water flea 

(Daphnia magna) as the previously submitted study was classified as INVALID and this 

study remains a requirement (OCSPP 850.1300) 

- Submittal of an early life stage toxicity test for sheepshead minnow and a chronic life stage 

invertebrate toxicity test with the mysid shrimp. If a new aerobic aquatic metabolism study 

shows the half life to be less than 4 days, these two studies may be waived. 

Table 11 lists the status of the ecological effects data requirements for Propamocarb-HCl. 

Table 11 Ecological Effects Data Requirements for Propamocarb-HCl

Guideline Data Requirement Test Species MRID 

Preliminary 

Study 

Classification 

More Data 

Needed for 

Risk 

Assessment? 

71-1 

(850.2100) Avian Oral LD50 

Mallard duck 

Bobwhite quail 

Passerine species 

No study 

submitted 

46145210 

No study 

submitted 

N/R 

Supplemental 

N/R 

No 

Yes1

Yes1

71-2 

(850.2200) Avian Dietary LC50 

Mallard duck 

Bobwhite quail 

45894212 

46145211 

Supplemental 

Supplemental 

Yes2

Yes2

71-4 

(850.2300) Avian Reproduction 

Mallard duck 

Bobwhite quail 

46145213 

46145212 

Supplemental 

Supplemental 

No 

72-1 

(850.1075) Freshwater Fish LC50

Rainbow trout 

Bluegill sunfish 

45894302 

45894301 

Supplemental 

Supplemental 

No 

72-2 

(850.1010) 

Freshwater 

Invertebrate Acute 

LC50

Water flea 45894303 Supplemental No 

72-3(a) Estuarine/Marine Sheepshead 45894304 Supplemental No 

39 
Guideline Data Requirement Test Species MRID 

More Data Preliminary Needed for Study Risk Classification Assessment? 

(850.1075) Fish LC50 minnow 

72-3(b) 

(850.1025 or 

850.1055) 

Estuarine/Marine 

Mollusk Shell 

Deposition EC50 

Eastern oyster 45894305 Supplemental No 

72-3(c) 

(850.1035 or 

850.1045) 

Estuarine/Marine 

Invertebrate EC50

Mysid shrimp 45894306 Supplemental No 

72-4(a) 

(850.1400) 

Freshwater Fish Early 

Life Stage Fathead minnow 45894307 Supplemental No 

72-4(b) 

(850.1300) 

Freshwater 

Invertebrate Life 

Cycle 

Water flea 45894308 

45727801 

Invalid 

In-review 

Yes3 

In-review5 

72-4(c) 

850.1350 

Estuarine/marine 

Invertebrate Life 

Cycle 

Mysid Shrimp No study 

submitted N/A Yes4

72-4(d) 

(850.1400) 

Estuarine/Marine 

Fish Early Life Stage 

Sheepshead 

minnow 

No study 

submitted N/A Yes4

123-1(a) 

(850.4100) 

Seedling Emergence 

(Tier I) Multiple species 45894310 Acceptable No 

123-1(b) 

(850.4150) 

Vegetative Vigor 

(Tier I) Multiple species 45894311 Acceptable No 

122-2(a) 

(850.4400) 

Aquatic vascular 

plants (Tiers I and II) 

Duckweed 45894313 Acceptable No

Freshwater algae 45894312 Supplemental No 

141-1 

(850.3020) 

Honey bee acute 

contact toxicity Honey bee 44324501 Acceptable No 

 1Data are required for one passerine species and either one waterfowl or one upland game bird species. At this time, 

only an acute oral test for a game bird species has been submitted and this study, conducted with formulated 

product, may be showing less toxicity than a study conducted with TGAI propamocarb-HCl would. 

2

Data required based on the current study being conducted with formulated Propamocarb-HCl and the study 

showing sublethal effects. 

3

 Data required based on previous submission of an invalid study. 

4

This data may be waived if the results of a new aerobic aquatic metabolism study indicate that the half life is less 

than 4 days. 

5

This study is currently in review and the status of this study being a data requirement may change pending the 

review. 

40 
Bibliography

(1) General References

U.S. Environmental Protection Agency. 1998. Guidelines for Ecological Risk Assessment. 

Risk Assessment Forum, Office of Research and Development, Washington, D.C. 

EPA/630/R-95/002F. April 1998. 

U.S. Environmental Protection Agency. 2000. Risk Characterization Handbook. Science 

Policy Council, U.S. Environmental Protection Agency, Washington, D.C. 20460. EPA 

100-B-00-002. December 2000. 

U.S. Environmental Protection Agency. 2004. Overview of the Ecological Risk Assessment 

Process in the Office of Pesticide Programs, U.S. Environmental Protection Agency. 

Endangered and Threatened Species Effects Determinations. Office of Prevention, 

Pesticides and Toxic Substances, Office of Pesticide Programs, Washington, D.C. 

January 23, 2004. 

U.S. Environmental Protection Agency. 2005. Generic Format and Guidance for the Level I 

Screening Ecological Risk Assessments Conducted in the Environmental Fate and Effects 

Division. Office of Pesticide Programs, Washington, D.C. January 24, 2005. 

U. S. Environmental Protection Agency. 2007. Ecological Incident Information System. 

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

U. S. Environmental Protection Agency. 1995. Re-registration eligibility decision: 

propamocarb hydrochloride, case 3124. 

ETN (Extension Toxicology Network). 1997. Propamocarb. Pesticide Information Profile. 

Cornell University. (http://pmep.cce.cornell.edu/profiles/extoxnet/metirampropoxur/propamocarb-ext.html) 

FRAC (Fungicide Resistance Action Committee). 2010a. FRAC Code List©: Fungicides 

sorted by mode of action (including FRAC Code numbering). 

http://www.frac.info/frac/publication/anhang/FRAC_Code_List_2010.pdf)

FRAC (Fungicide Resistance Action Committee). 2010b. List of plant pathogenic organisms 

resistant to disease control agents. Revised January 2010. 

http://www.frac.info/frac/publication/anhang/List_of_resistant_plant_pathogens_Jan%202010.pd

f) 

Kline and Co. (2000-2007). Professional Turf and Ornamental Markets for Pesticides and 

Fertilizers. 

EPA Proprietary Data. GfK Kynetec. 1998-2008. 

41 
EFED, 2000. Section 3 for propamocarb hydrochloride to control late blight (Phytophthora 

infestans) on potatoes (DP Barcode 0259522). 

BEAD, 2011. Chemical Profile for Registration Review: Propamocarb-HCl (119302), April 

2011 

(2) Environmental Fate and Transport References

MRID 00071297

Riemann, J.; Repenthin, W. (1976) Determination of Rates of Hydrolysis of Propamocarb Base 

at pH 5, 7 and 9: Report No. APC 26/76. (Translation; unpublished study received Feb 24, 1981 

under 2139-121; prepared by Schering, AG, West Germany, submitted by Nor-Am Agricultural 

Products, Inc., Naperville, Ill.; CDL: 244469-D). (Same but clear readable copy was submitted 

under MRID 2402168-04). 

MRID 00071296 

Klehr, M. (1980) Photolysis Experiments with Propamocarb-HCl (SN 66 752) in Heat Sterilized 

Aqueous Solutions. (Unpublished study received Feb 24, 1981 under 2139-121; prepared by 

Schering, AG, West Germany, submitted by Nor-Am Agricultural Products, Inc., Naperville, Ill.; 

CDL:244469-C) 

MRID 45894318 

Yeomans, P. (2001) (Carbon 14)-Propamocarb Hydrochloride: Photodegradation on a Soil 

Surface: Final Report: Lab Project Number: 1669/8: 1669/8-D2149. Unpublished study prepared 

by Covance Laboratories Ltd. 62 p. 

MRID 41834608 

Tschampel, M. (1990) W78 Propamocarb: The Photodegradation of Propamocarb Hydrochloride 

on soil surfaces (Schering Code ZK 66 752) on Soil Surfaces. Laboratory Project ID: APC 

87/90. Study No. 90/030. Unpublished Study Performed by Schering AG, Berlin, Federal 

Republic of Germany and Submitted by Nor-Am Chemical Company, Wilmington, DE. 

MRID 41278125 

Bruhl, R.; Celorio, J.; Wi. (1978) Degradation of SN 66 752 in a Loamy Sand: Report No. PA 

66 752.71/6. (Unpublished study received Feb 24, 1981 under 2139-121; prepared by Schering 

AG, West Germany, submitted by Nor-Am Agricultural Products, Inc., Naperville, Ill.; 

CDL:244472-F). 

MRID 41278126 

Bruhl, R.; Wi. (1979) Degradation of Propamocarb Hydrochloride in a Californian Loamy Sand: 

Report No. R + S 29/79--PA 66 752.71/6. (Unpublished study received Feb 24, 1981 under 

2139-121; prepared by Schering AG, West Germany, submitted by Nor-Am Agricultural 

Products, Inc., Naperville, Ill.; CDL: 244472-E). 

MRID 41278127 

42 
Bruhl, R. and J. Celorio (1980a) W15 Propamocarb: Degradation of Propamocarb Hydrochloride 

in a Loamy Sand. Laboratory Project ID: R+S71/80 PA66752 71/6. Unpublished Study 

Performed by Schering AG, Berlin, Federal Republic of Germany, and Submitted by Nor-AM 

Chemical Company, Wilmington, DE. 

MRID 45894319 

Schnoder, F. (2002) (Carbon 14)Propamocarb Hydrochloride: Aerobic Route and Rate of Soil 

Degradation: Final Report: Lab Project Number: 1760-1669-007: 1669-007. Unpublished study 

prepared by Covance Laboratories GmbH. 110 p. 

MRID 41278129 

Bruhl, R. (1979) W20 Propamocarb HCL: Degradation of SN 66 752 in a Loamy Sand under 

Anaerobic Conditions: Lab Project Number: PA/66/752/71/6. Unpublished study prepared by 

Schering AG. 11 p. 

MRID 44538504 

Judge, D.N. (1998) W144-1 Propamocarb: The Degradation of [1-14C]Propamocarb under 

Laboratory Anaerobic Aquatic Conditions. Laboratory Project ID: AV97E517. Unpublished 

Study Performed by AgrEvo USA Company, Pikesville, NC and Submitted by AgrEvo USA 

Company, Wilmington, DE. 

MRID 00071465 

Bruhl, R.; Celorio, J.; Wi. (1980) Anaerobic Degradation of Propamocarb Hydrochloride in 

River Sediment: R + S 60/80--PA 66 752.71/6. (Unpublished study received Feb 24, 1981 under 

2139-121; prepared by Schering AG, West Germany, submitted by Nor-Am Agricultural 

Products, Inc., Naperville, Ill.; CDL: 244472-H) 

MRID 41278130 

Bruhl, R. (1988) W59 Propamocarb Hydrochloride: Adsorption to and Desorption from Soil: 

Lab Project Number: UPSR/19/88. Unpublished study prepared by Schering AG. 41 p. 

MRID 45894321 

Willems, H. (1998) Adsorption/Desorption of Propamocarb Hydrochloride on Soil: Lab Project 

Number: 220769. Unpublished study prepared by NOTOX B.V. 41 p. 

MRID 41278132

Bruhl, R.; Wi. (1978) Mobility of Propamocarb Hydrochloride in Four Soils: PA 66 752.71/6. 

(Unpublished study received Feb 24, 1981 under 2139-121; prepared by Schering AG, West 

Germany, submitted by Nor-Am Agricultural Products, Inc., Naperville, Ill.; CDL:244473-D). 

MRID 00071472 

Bruhl, R.; Celorio, J.; Wi. (1979) Mobility of SN 66 752 in Two Soils after Aging: R + S 28/79-

-PA 66 752.71/6. (Unpublished study received Feb 24, 1981 under 2139-121; prepared by 

Schering AG, West Germany, submitted by Nor-Am Agricultural Products, Inc., Naperville, Ill.; 

CDL:244473-E). 

43 
MRID 45894320 

Willems, H. (1998) Aged Leaching of Propamocarb Hydrochloride: Lab Project Number: 

220758. Unpublished study prepared by NOTOX B.V. 38 p. 

MRID 41278131 

Feyerabend, M. (1988) W69 Propamocarb: The Mobility of N-(3-dimethylamino-?1-14C|-

Propyl)-Propamocarb-Hydrochloride in Four Soils Determined by Soil TLC: Lab Project 

Number: UPSR/88/88. Unpublished study prepared by Schering AG. 30 p. 

MRID 42421202 

Wred-Rucker, A. (1992) W115 Propamocarb Hc1: Dissipation of Propamocarb X HC1 in Soil 

Following Application of Banol – USA 1990. Report No. UPSR 57/91. Study No. PF-R 89093. 

Unpublished Study Performed by Schering AG, Berlin, Germany and Submitted by Nor-Am 

Chemical Company, Goldsboro, NC.

MRID 44001601 

Cole, M. (1995) Dissipation of Propamocarb.HCl in Soil Following Application of Banol to Bare 

Plot, USA, 1993: Lab Project Number: AV-93R-01: A54951: W132. Unpublished study 

prepared by AgrEvo USA Co. 161 p. 

MRID 45894322 

Willard, T. (2002) Terrestrial Field Soil Dissipation of Propamocarb Hydrochloride in Turf: 

Final Study Report: Lab Project Number: AA010716: 01-0027: ENC-1/02. Unpublished study 

prepared by American Agricultural Services, Inc. 406 p. 

MRID 45894316 

Melkebeke, T. (2000) Validation of an Analytical Method for the Determination of Propamocarb 

Residues in Surface Water: Lab Project Number: 289676. Unpublished study prepared by 

NOTOX.27 p. 

MRID 45894317

Melkebeke, T. (1997)Validation of an Analytical Method for Residues of Propamocarb in 

Soil:Lab Project Number: 174904. Unpublished study prepared by NOTOX.19p.

MRID 45894315 

R. de Vries (1997)Validation of an Analytical Method for Residues of Propamocarb in 

Water:Lab Project Number: 173598. Unpublished study prepared by NOTOX.19p.

MRID 41278114 

Gray, C.; Knowles, C. (1980) W34 Propamocarb HCL: Uptake of propamocarb hydrochloride by 

bluegills and channel catfish. Chemosphere (9):329-333. 

MRID 45894323 

Mazzonetto, F. (2001) Bioconcentration of Proplant to Zebrafish (Danio rerio): Final Report: 

Lab Project Number: RF-0998.210.022.01. Unpublished study prepared by BIOAGRI 

Laboratories Ltda. 92 p. 

44 
(3) Ecological Effects References

71-1 Avian Single Dose Oral Toxicity

MRID 46145210. Teunissen, M.S. 2002. Acute Oral Toxicity Study in Northern Bobwhite with 

Proplant (Propamocarb HC1722 g/L). Unpublished study performed by NOTOX B.V., DD'sHertogenbosch, The Netherlands. Laboratory ID No. 327004. Study sponsored by Chimac - 

Agriphar s.a., (Ougree, Belgium. Study initiated October 18, 2001 and completed January 15, 

2002. 

71-2 Avian Dietary Toxicity

MRID 45894212. Miller, V. 2002. Proplant - Dietary Toxicity Test with the Mallard Duck 

(Anas platyrhynchos). Unpublished study performed by Springborn Smithers Laboratories, 

Snow Camp, NC and Wareharn, MA. Laboratory Project ID No. 13763.4102. Study sponsored 

by Chimac - Agriphar, Ougree, Belgium. Study initiated October 30, 2001 and completed March 

22, 2002. 

MRID 46145211. Teunissen, M.S. 2001. 5-Day Dietary Toxicity Study in Bobwhite Quail with 

Proplant (Propamocarb HCI 722 g/L). Unpublished study performed by NOTOX B.V., DD'sHertogenbosch, The Netherlands. Laboratory ID No. 329783. Study sponsored by Chimac - 

Agriphar s.a., Ougree, Belgium. Study initiated July 1, 2001 and completed November 20, 2001. 

71-4 Avian Reproduction

MRID 46145212. Teunissen, M.S. 2002. Reproduction Study in Bobwhite Quail with 

PROPLANT (Propamocarb HCI 722 g/L) (By Dietary Admixture). Unpublished study 

performed by NOTOX B.V., DD's-Hertogenbosch, The Netherlands. Laboratory ID No. 295526. 

Study sponsored by Chimac – Agriphar s.a , Ougree, Belgium. Study initiated September 3. 

2001 and completed April 18, 2002. 

MRID 46145213. Miller, V. 2002. Proplant - Reproductive Toxicity Test with Mallard Duck 

(Anas platyrhynchos). Unpublished study performed by Springborn Smithers Laboratories, 

Snow Camp, NC and Wareham, MA. Laboratory Project ID No. 13763.4100. Study sponsored 

by Chimac - Agriphar, Ougree, Belgium. Study initiated April 11, 2001 and completed June 27, 

2002. 

72-1 Acute Toxicity to Freshwater Fish

MRID 45894301. Migchielsen, H.J. 2001. 96-Hour Acute Toxicity Study in Bluegill Sunfish 

with Proplant (Propamocarb HC1722 g/L) (Static). Unpublished study performed by NOTOX 

B.V., Hertogenbosch, The Netherlands. Laboratory Project Identification No. 329748. Study 

submitted by CHIIVIAC-AGRIPHAR S.A., Ougree, Belgium. Study initiated July 4, 2001 and 

completed December 19, 2001. 

45 
MRID 45894302. Bodgers, M. 1996. 96-Hour Acute Limit Study in Rainbow Trout with 

Proplant (Semi-static). Unpublished study performed by NOTOX B.V., Hertogenbosch, The 

Netherlands. Laboratory Project Identification No. 161303. Study submitted by ChimacAgriphar s.a., Ougree, Belgium. Study initiated June 26, 1996 and completed August 28, 1996. 

72-2 Acute Toxicity to Freshwater Invertebrates

MRID 45894303. Bodgers, M. 1996. Acute Limit Study in Daphnia magna with Proplant. 

Unpublished study performed by NOTOX B.V., Hertogenbosch, The Netherlands. Laboratory 

Project Identification No. 16 13 14. Study submitted by Chimac-Agriphar s.a., Ougree, Belgium. 

Study initiated June 26, 1996 and completed August 28, 1996. 

72-3 Acute Toxicity to Estuarine/Marine Organisms

MRID 45894304. Putt, A. 2001. Proplant (Propamocarb HC1722 g/L SL) - Acute Toxicity to 

Sheepshead Minnow (Cyprinodon variegatus) Under Static Conditions. Unpublished study 

performed by Springborn Laboratories. Inc.,Wareham, MA. Laboratory Study No. 13763.6104. 

Study submitted by Chimac-Agriphar, Ougree, Belgium. Study initiated May 14, 2001 and 

completed August 15, 2001. 

MRID 45894305. Dionne, E. Proplant (Propamocarb HC1722 g/L SL,) - Acute Toxicity to 

Eastern Oysters (Crassostrea virginica) Under Flow- Through Conditions. Study Completion 

Date: August 16, 2001. Laboratory: Springborn Laboratories, Inc. 790 Main Street Wareharn, 

MA 02571-1075. Sponsored by: CHIMAC-AGRIPHAR Rue de Renory 26 B-4102 Ougree, 

Belgium. Laboratory Report ID: 13763.6102 

MRID 45894306. Putt, A.E. Proplant (Propamocarb HC1722 g/L SL) - Acute Toxicity to 

Mysids (Americamysis bahia) Under Static Conditions. Study Completion Date: August 28, 

2001. Laboratory: Springborn Laboratories, Inc. 790 Main Street Wareham, MA 0257 1 – 1075. 

Sponsored by: CHIMAC-AGRIPHAR, Rue de Renory 26 B-4 102 Ougree, Belgium. Laboratory 

Report ID: 13763.6 10 1. 

72-4 Fish Early Life Stage/Aquatic Invertebrate Life Cycle Study

MRID 45894307. Gries, T. 2002. Proplant: Early-Life Stage Toxicity Test with the Fathead 

Minnow (Pimephales promelas) under Flow-Through Conditions. Unpublished study performed 

by Springborn Laboratories (Europe) AG, Seestrasse 21, Postfach CH-9326 Horn, Switzerland. 

Laboratory Study No. 1038.004.122. Study sponsored/submitted by Chimac-Agriphar S.A., Rue 

de Renory, 26 8-4102 Ougree, Belgium. Study initiated October 24, 2001 and completed 

February 26, 2002. 

122-2 Aquatic plant growth

MRID 45894312. Bogers, M. 1996. Fresh Water Algal Growth Inhibition Test with Proplant. 

Unpublished study performed by NOTOX B.V., Hertogenbosch, The Netherlands. Laboratory 

Project Identification No. 165364. Study submitted by CHIMAC-AGRIPHAR S.A. Ougree, 

Belgium. Study initiated December 13, 1995 and completed September 4, 1996. 

46 
MRID 45894313. Bogers, M. 2001. A 7-Day Aquatic Plant Toxicity Test with using Lemna 

minor with Proplant (Propamocarb HC1722 g/L) Unpublished study performed by NOTOX 

B.V., Hertogenbosch, The Netherlands. Laboratory Project Identification No. 329254. Study 

submitted by CHIMAC-AGRIPHAR S.A. Ougree, Belgium. Study initiated June 18, 2001 and 

completed November 13, 2001. 

MRID 44187802. Christ, M. T., and Ruff, D. F. Propamocarb hydrochloride: 68.2% w/w (738 

g/L) Toxicity to Duckweed (Lemna gibba, G3) in a Static Renewal System. Study Completion 

Date: December 2, 1996. Laboratory: AgrEvo USA Company, AgrEvo Research 

Center, Environmental Biology Department, 703 NOR-AM Road, PO Box 538, Pikeville, NC 

27863. Sponsored by AgrEvo USA Company, 2711 Centerville Rd.,Wilmington, DE 19808 

522AV. 

123-1 Seed germination/seedling emergence and vegetative vigor

MRID 45894310. Ir. W.H.C. Geuijen. Terrestrial Plant Toxicity Test, Tier 1: Seedling 

Emergence, With Proplant (Propamocarb HCL 722 G/L). Study Completion Date: February 1, 

2002. Laboratory: NOTOX B .V., Hambakenwetering 7, 5231 DD's-Hertogenbosch, The 

Netherlands. Sponsored by: CHIMAC-AGRPHAR S .A. Rue de Renory, 26 B-4102 Ougree, 

Belgium. Laboratory Report ID: 327048. 

MRID 45894311. Ir. W.H.C. Geuijen. Terrestrial Plant Toxicity Test, Tier 1: Vegetative Vigor, 

with Proplant (Propamocarb HCI 722 GIL). Study Completion Date: December 20, 2001. 

Laboratory: NOTOX B .V. Hambakenwetering 7, 5231 DD's-Hertogenbosch, The Netherlands. 

Sponsored by: CHIMAC-AGRIPHAR S .A. Rue de Renory, 26 B -4 102 OUGREE, Belgium 

Laboratory Report ID: 327059. 

MRID 44187801. Christ, Mark T. and Ruff, David F. Tier II: Investigating into the Phytotoxic 

Effects on Seedling Emergence/Growth of Terrestrial Plants. Study Completion Date: December 

19, 1996. Laboratory: AgroEvo Research Center Pikeville, North Carolina. Sponsored by 

AgrEvo USA Company Wilmington, DE. Laboratory Report ID: 511AV 

141-1 Honey bee acute contact

MRID 44324501. Nengel, Sabine. Assessment of Side Effects of Proplant to the Honey Bee, 

Apis mellifera L. in the Laboratory Following the EPPO Guideline No. 170. Study Completion 

Date: 01/09/97. Laboratory: GAB Biotechnologie BmgH & I FU. Sponsored by GAB 

Biotechnologie BmgH & IFU. Laboratory Report ID: 96047/01-BLEU. 

47 
48 

Appendix A: Issues Associated with Current Labels for Propamocarb-HCl

(1) Vegetable labels

Issues associated with labels for this use can be categorized into the following: 

a. Field Vegetables Labels 

• Registrants need to confirm and correct discrepancies in data presented on this use in Table 1

of the problem formulation document and provide missing data.

b. Greenhouse application, namely, 55260-10 Promess and 264-678 Previcur Flex 

• Registrants need to confirm data presented and correct discrepancies in data presented on this 

use in the problem formulation document 

• Maximums for each cropping season were set to be 11.6 lbs. a.i./A with 6,000 plants, 9.4 lbs. 

a.i./A with 10,000 plants, and 27.1 lbs. a.i./A with 14,000 plants. However, label instructions 

needs to be clarified by stating the intervals between all applications, specifying which 

treatment applies to which crops (or state that all treatments may apply to all crops), and by 

clarifying the rate in case of the two applications for soil or soilless seed beds. Based on the 

label instructions EFED calculated the first application to be 65.33 lb a.i./A and the second 

application to be 32.67 lbs a.i./A and both are higher than the maximum permitted seasonal 

rate of 27.1 lbs. a.i./A. Therefore label instruction need to be modified. 

(2) Turf and Ornamentals Labels 

• Registrants need to confirm and correct discrepancies in data presented on this use in Table 2

of the problem formulation document and provide missing data.

• Registrants need to address other issues associated with labels for this use which include one 

or more of the following: 

• Specifying which application rates apply to ornamentals in greenhouses and which ones 

apply to ornamentals in nurseries; 

• Correcting errors in calculating amount of a.i from formulation; 

• Specifying if the nurseries are limited to container-grown; 

• Including the yearly rate/acre that takes in consideration the number of containers that 

can be placed on an acre; 

• Specifying the turf categories; 

• Modifying the label so that single rate for ornamental does not exceeds the yearly rate; 

• Including the number of applications; and 

• Including the application intervals in case of more than one application. 
Appendix B: Fate Data for Propamocarb-HCl

Table B-1 1st and 2nd sets for propamocarb-HCl biotic fate studies compared (Abbreviations are in bold or bold 

included below the Table) 

Location (ID)

MRID (Classification)

Soil/sediment properties

Extraction Procedure

Identification/ Confirmation & Quantification Procedures

Degradation Data 

Identified Residues Un-identified Res

Texture pH O.C Clay CEC 

Parent Halflife (Study Length) CO2 Degradation Products 

Aerobic Soil Systems (Data from 1st set): Radiolabel position aminopropyl-1 14C; Used an exaggerated rate of 200 ppm and incubated @ 25 0C Germany (Soil 1) 

412781-25 

(A) LS 6.6 2.4 5 11 

MeOH

+ SHX

TLC (Soil 3)

and

TLC/1 & 2 D 

TLC 

(soils 1&2) 

& LSC 

(All Soils) 

DT50= 14 d

(360 d) 87 

3 minor degradates 

(Apparent Decline) 

USA, CA (Soil 2) 

412781-26 

(A) LS 5.2 1.1 4 5 

MeOH

+ SHX

DT50= 27 d

(14-30 d) 

(360 d) 87 

3 minor degradates 

(No apparent Decline) 

Germany (Soil 3) 

412781-27 

(A) LS 6.6 2.3 7 NR MeOH

DT50= 10 d

(7-13 d) 

(46 d) 80 

6 minor degradates 

(No apparent Decline) 

Aerobic Soil Systems (Data from 2nd set): Radiolabel position aminopropyl-2 14C; Used an exaggerated rate of 250 ppm in all soils with one of the soils rincubated @ 20 0C with one soil repeated @ 10 0C UK (Soil 4) 458943-19 (S; because 

soils were not 

classified/ 

compared to 

expected use 

sites of the 

chemical) 

SL 7.1 2.5 11 15 ACNTRL 

TLC/HPLC 

& LSC 

t 1⁄2 = 23 d

(365 d) 49 

7 minor degradates 

6 Declined/1 No Decline 

Same soil 4 above with the low 

application rate ACNTRL 

t 1⁄2 = 14 d

(120 d) 36 

2 minor degradates 

1 Declined/1 No Decline 

Same soil 4 above with the same rate 

@ 10 0C ACNTRL 

t 1⁄2 = 47 d

(120 d) 32 

3 minor degradates 

1 Declined/3 No Decline 

UK (Soil 5) SiL 6.7 4.5 20 18 ACNTRL 

t 1⁄2 = 16 d

(120 d) 48 

2 minor degradates 

1 Declined/1 No Decline 

UK (Soil 6) CL 8.0 2.7 34 22 ACNTRL 

t 1⁄2 = 15 d

(120 d) 48 

2 minor degradates 

1 Declined/1 No Decline 

UK (Soil 7) SL 5.5 1.3 12 11 ACNTRL 

t 1⁄2 = 70 d

(120 d) 31 

2 minor degradates 

2 No Decline 

Anaerobic Soil Systems* (Data from 1st set): Radiolabel position aminopropyl-1 14C; Used an exaggerated rate of 200 ppm and incubated @ 25 0C Germany (Soil 1) 

412781-29 

(A) Same soil 1 used in the aerobic soil 

MeOH

+ Others TLC & LSC 

t 1⁄2 = 459 d 

(180 d) 8 

3 minor degradates 

2 Declined/1 No Decline 

Aerobic Aquatic Systems: No data were submitted in either the 1st or the 2nd setAnaerobic Aquatic Systems** (Data from 2nd set): Radiolabel position aminopropyl-2 14C; Used rate of 7.7 ppm and incubated @ 25 0C USA, NC 445385-04 Water 6.8 NR NA NA ACNTRL TLC/HPLC t 1⁄2 = 92 d 68 9 minor degradates 

49 
Location 

(ID)

MRID (Classification)

Soil/sediment properties

Extraction Procedure

Identification/ Degradation Data 

Confirmation & 

Identified Residues Un-identified Res

Quantification 

Texture pH O.C Clay Procedures

Parent Halflife (Study 

CEC Length) CO2 Degradation Products 

(Pond) (A) CL 

Sediment 

(25% of 

sand 

removed 

by 

sieving) 5.5 4.0 29 12 

+SHX 

(SHX 

extracted 

up to 9% 

more 

parent)

“selected 

samples” 

& LSC 

Total 

System

(370 d) 

8 Declined/1 No Decline 

MRID= MRID number; Texture: Textural class: LS= Loamy sand, CL= Clay loam, SiL= Silt loam, SCL= Sandy clay loam; O.C= % of organic carbon%Cation exchange capacity (meq/100 g); NR= Not reported; NA= Not applicable; d= Time in days; CO2= Maximum evolved CO2 occurring mostly at end o

radioactivity); Study Previous Classification: A= Acceptable, S= supplemental; MeOH= Aqueous methanol based extraction; ACNTRL= Aqueous acet

extraction; SHX= Shoxhlet extraction; MeOH + Others= 3 times methanol + 1 time acetone + 1 time toluene + 1 time 5 N NaCl; TLC= Thin layer chrom

dimensional; 2D= 2 dimensional); HPLC= high performance liquid chromatography; LSC= LSC= Liquid scintillation, a method for determination radioa

estimated time degradation of 50% degradation; t 1⁄2 = calculated half-life by linear and/or non-linear methods

* No data was submitted in the 2nd set; ** No data from the 1st set because the anaerobic aquatic study submitted under Accession Number 000714-65 was 

50 
Table B-2 The 1st and 2nd sets for propamocarb-HCl mobility data compared (Abbreviations are in bold or bold i

included below the Table) 

Soil Properties

Location (ID) 

MRID 

(Classification) Study Type Texture pH O.C Clay CEC Aging Notes 

German: Soil 1 

412781-30 

(S) 

Ad-Des 

(1st Data Set) 

S 6.0 0.5 5 4 

Unaged

Aminopropyl-1 14C labeled pro

used and was the only chemical analysis. It was reported that pardata). Quantification by LSC 

German: Soil 2 LS 6.0 2.1 4 8 UK Soil: 3 SL 5.2 1.5 13 13 Germany: Soil 4 

458943-21 

(S, Upgradable) 

Ad-Des 

(2nd Data Set) 

LS 6.1 2.3 7 9 

Unaged Aminopropyl-2 14C labeled pro

used and found to be stable throu(TLC analysis). Quantification b

UK: Soil 5 SCL 6.5 3.5 32 34 US: Soil 6 SL 5.7 1.1 16 11 US: Soil 7 LS 5.9 0.6 6 6 Germany: Soil 8 

412781-32 

(A)* 

Un-aged Column 

Leaching 

(1st Data Set) 

S 6.6 0.5 4 2 

Unaged 

Aminopropyl-1 14C labeled pro

used and was the only chemical analysis. Quantification by LSC6-days at a rate of 8-10 mL/hr

Germany: Soil 9 LS 5.7 1.9 7 8 US: Soil 10 LS 5.2 1.1 4 5 Germany: Soil 11 

000714-72 

(S) 

Aged Column 

Leaching 

(1st Data Set) 

SL 5.9 1.1 6 5 

30 d 

Aminopropyl-1 14C labeled pro

used and was the only chemical analysis. It is assumed that reporon radioactivity remaining in the Quantification by LSC. Soil extr

Germany: Soil 12 LS 6.1 2.5 2 13 Columns eluted for 45 days at a Germany: Soil 13 

458943-20 

(S) 

Aged Column 

Leaching 

(2nd Data Set) 

SL 7.3 2.0 6 10 12 d Aminopropyl-2 14C labeled pro

used with a residue, after aging a

from soil 13 and 33% CO2 from 

consists of mostly parent 35% an35% in soil 13. In soil 14, the resmostly parent 46% and bound reanalysis). Quantification by LSCMOH & NaCl. Columns eluted fradioactivity related to parent ranbound residues ranged from to . radioactivity related to parent ran

US: Soil 14 SL 6.6 1.2 10 9 23 d and bound residues ranged from 

Mobility Results

Adsorption-Desorption Results (Ad-Des) from the 1st Data Set at a rate of 0.04 ppm (MRID 412781-30)

German: Soil 1 Adsorption Kd (mL/g) = 0.671 & Adsorption Koc (mL/g)= 140 (calculated from Kd and O.C%)German: Soil 2 Adsorption Kd (mL/g) = 0.849 & Adsorption Koc (mL/g)= 41 (calculated from Kd and O.C%) UK: Soil 3 Adsorption Kd (mL/g) = 5.2 & Adsorption Koc (mL/g)= 359 (calculated from Kd and O.C%) 

51 
Adsorption-Desorption Results (Ad-Des) from the 2nd Data Set at a rate of 0.19 to 22.165 ppm (MRID 458943-21)

Germany: Soil 4 Adsorption Kd (mL/g) = 1.29 & Adsorption Koc (mL/g)= 57 (calculated from Kd and O.C%) UK: Soil 5 Adsorption Kd (mL/g) = 6.27 & Adsorption Koc (mL/g)= 180 (calculated from Kd and O.C%) US: Soil 6 Adsorption Kd (mL/g) = 13.83 & Adsorption Koc (mL/g)= 1,317 (calculated from Kd and O.C%) UK: Soil 7 Adsorption Kd (mL/g) = 4.65 & Adsorption Koc (mL/g)= 802 (calculated from Kd and O.C%) 

Un-aged Column Leaching Results from the 1st Data Set at a rate of 21 ppm (MRID 412781-32)

Germany: Soil 8 52 to 61% of parent found in the leachate suggesting the chemical is Very mobile in this soil Germany: Soil 9 Only <1% of parent found in the leachate and ≈87% in the upper 20 cm of the 30 cm column suggesting the chemical is relatively IUS: Soil 10 Only <1% of parent found in the leachate and ≈77% in the upper 20 cm of the 30 cm column suggesting the chemical is relatively I

Aged Column Leaching Results from the 1st Data Set 2nd Data Set at a rate of 420 ppm (MRID 000714-72)

US: Soil 11 38 to 48% of parent found in the leachate suggesting the chemical is Very mobile in this soil Germany: Soil 12 Only 2% of parent found in the leachate suggesting the chemical is relatively Immobile

Aged Column Leaching Results from the 2nd Data Set at a rate of 15.4 (MRID 458943-20)

Germany: Soil 13 Only 1% of parent found in the leachate; ranged from 28-44% in the upper 6 cm of the 30 cm column suggesting the chemical is reUS: Soil 14 Only 1% of parent found in the leachate; ranged from 37-45% in the upper 6 cm of the 30 cm column suggesting the chemical is reMRID= MRID number noting that numbers starting with zeros are Accession numbers; Texture: Textural class: S= Sand, LS= Loamy sand, SL= Sandy l

clay loam; O.C= % of organic carbon%, Clay= % of clay, CEC= Cation exchange capacity (meq/100 g); d= Time in days; CO2= evolved CO2 (% of appl

Study Previous Classification: A= Acceptable, S= supplemental; TLC= Thin layer chromatography; LSC= Liquid scintillation, a method for determinat* One un-aged leaching study (MRID 412781-31) was classified as Unacceptable 

52 
0.0%

10.0%20.0%30.0%40.0%50.0%60.0%70.0%80.0%90.0%

100.0%

0 50 100 150 200 250 300 

ParentBound residueCO2Un‐identified Degradates

% of Applied Radioactivity

Time (days) 

Figure B-1 Degradation profile for propamocarb-HCl in a pond water/sediment system from NC 

53 
AE B132674 

Name: 3-hydroxypropyl[3-(dimethylamino) 

propyl]carbamate 

AE B155306 

Name: Propyl [3-(dimethylamino)propyl] carba

hydrochloride N-oxide 

 AE B1532679 

Name: 3-[(3-dimethylamino)propyl]-4-hydroxy-4methyl-2-

oxazolidine 

AE B132677 

Name: Propyl [3-(dimethylamino)propyl] carba

Figure B-2 Standard possible degradation products for Propamocarb-HCl 

54 
0

20406080

100120

0 100 200 300

WaterSedimentCO2

% of Applied Radioactivity

Time (days) 

Figure B-3 Distribution of radioactivity between water, sediment and evolved CO2 in a pond  water/sediment system from NC 

55 
5.0

12.9

0 50 100 150 200 250 300 350 

pe+ph waterpe+pHSedime

56 

Figure B-4 Aerobicity of the pond water/sediment system from NC as indicated by pe+pH

Sub-Oxic Conditions

Oxic Conditions (Aerobic) Anaerobic Conditionsditions
57