UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

OFFICE OF CHEMICAL SAFETY 

AND POLLUTION PREVENTION 

PC Codes 1 1883 1 & 12883 1 

DP Barcodes D376232, D376441 

Date July 29,20 10 

MEMORANDUM 

SUBJECT: EFED Registration Review Problem Formulation for Cyfluthrin and Betacyfluthrin 

FROM: Jose L. Meldndez, Chemist w/ w/1 Amanda Solliday, Biologist 

Environmental Risk Branch V 

Environmental Fate and Effects Division (7507P) 

THROUGH: Mah T. Shamim, Ph.D., Branch Chief 

Environmental Risk Branch V 

Environmental Fate and Effects Division ( 

TO: Yan Donovan, Chemical Review Manager 

Cathryn O'Connell, Team Leader 

Margaret Rice, Branch Chief 

Risk Management and Implementation Branch I1 

Pesticide Re-evaluation Division (7508P) 

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

problem formulation (attached) for the ecological risk, environmental fate, endangered 

species, and drinking water assessment to be conducted as part of the Registration 

Review of the pyrethroid insecticides cyfluthrin and beta-cyfluthrin. Functioning as the 

first stage of the risk assessment process for registration review, this problem formulation 

provides an overview of what is currently known about the environmental fate and 

ecological effects associated with cyfluthrin and beta-cyfluthrin. It also describes the 

preliminary ecological risk hypothesis and analysis plan for evaluating and characterizing 

risk to non-target species in support of the registration of cyfluthrin and beta-cyfluthrin. 

Many of the environmental fate properties of cyfluthrin and beta-cyfluthrin are known. 

Nonetheless, there is uncertainty with respect to the aerobic and anaerobic soil and 

aerobic and anaerobic aquatic metabolism of cyfluthrin and beta-cyfluthrin and their 

TEXT SEARCHABLE DOCUMENT - 2010
overall persistence in the environment. Due to the very low solubility of cyfluthrin and 

beta-cyfluthrin, there is also concern with respect to the results of the batch equilibrium 

study. There is uncertainty concerning the potential for adverse aquatic effects, including 

benthic environments, for acute, chronic and endangered species risk based on fate 

transport involving drift and run-off, and persistence. There is uncertainty concerning the 

potential for adverse terrestrial effects for acute and endangered species risk to birds, 

terrestrial invertebrates and plants based on fate transport, drift, binding to the soil, and 

persistence. In addition, there are ecological data gaps that need to be addressed for 

cyfluthrin and beta-cyfluthrin. For cyfluthrin, this includes acute effects to passerine 

birds, acute effects to freshwater fish and estuarinelmarine organisms, chronic effects to 

benthic organisms, and toxicity to terrestrial and aquatic plants. For beta-cyfluthrin, data 

gaps include chronic effects to aquatic invertebrates and toxicity to terrestrial and aquatic 

plants. The potential for adverse effects to pollinators and other beneficial insects fiom 

use of cyfluthrin and beta-cyfluthrin appears to be high. 
Environmental Pate and Ecological Risk 

Assessment Problem Formulation in 

Support of Registration Review for 

Cyfluthrin and Beta-cyfluthrin 

Unstated stereochemistry, 

consists of eight isomers C1 

July 29,2010 

Environmental Fate and Effects Division 

Office of Pesticide Programs 

US Environmental Protection Agency 
Prepared by: 

Amanda Solliday, Biologist 

Jos6 L. MelCndez, Chemist 

Secondary Review: 

Keith Sappington, Senior Scientist 

Mah T. Shamim, Ph.D., Branch Chief 

Environmental Risk Branch V 
Table of Contents 

1 . Purpose .................................................................................................................................... 6 

2 . Problem Formulation .............................................................................................................. 6 

2.1 Nature of Regulatory Action ................................................................................................ 7 

2.2. Previous Risk Assessments .................................................................................................. 7 

3 . Stressor Source and Distribution .......................................................................................... 13 

3.1 . Mechanism of Action ........................................................................................................ 18 

3.2. Overview of Pesticide Usage ............................................................................................ 19 

3.3. Environmental Fate and Transport .................................................................................... 27 

4 . Receptors ............................................................................................................................... 37 

4.1. Aquatic and Terrestrial Effects ......................................................................................... 37 

4.2. Incident Database Review ................................................................................................. 19 

4.3. Ecosystems Potentially at Risk ......................................................................................... 48 

6 . Conceptual Model .............................................................................................................. 50 

6.1. Risk Hypothesis ............................................................................................................... 50 

6.2. Conceptual Diagram ........................................................................................................ 51 

7 . Analysis Plan ..................................................................................................................... 55 

7.1. Stressors of Concern ......................................................................................................... 56 

7.2. Measures of Exposure ....................................................................................................... 56 

7.3. Measures of Effect ............................................................................................................ 58 

7.4. Integration of Exposure and Effects ................................................................................. 59 

7.5. Deterministic and Probabilistic Assessment Methods ...................................................... 59 

7.6. Endangered Species Assessments ..................................................................................... 60 

7.7. Drinking Water Assessment ............................................................................................. 61 

7.8. Preliminary Identification of Data Gaps ........................................................................... 62 

7.8.1 . Fate ............................................................................................................................. 62 

7.8.2 Effects ......................................................................................................................... 66 

8 . References ................................................................................................................................ 75 . . 9 . Blbhography ..................................................................... Appendix A . SRRD data request justification tables .................................................................. 81 
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 cyfluthrin and beta-cyfluthrin. 

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 the 

risk (USEPA, 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 cyfluthrin and 

beta-cyfluthrin. 

Cyfluthrin is a Type I1 synthetic pyrethroid insecticide that is registered for numerous 

agricultural, non-agricultural and residential uses, such as (but not limited to) alfalfa, 

almond, apple, beans, brassica (head and stem) vegetables, carrots, citrus, corn, cotton, 

cucurbit vegetables, fruiting vegetables, grapes, hops, leafy vegetables, legume 

vegetables, lettuce, peach, peanuts, peas, pome fruits, potato, root and tuber vegetables, 

sorghum, soybeans, stone hits, sugarcane, sunflower, tomato, tree nuts, wheat, airport1 

landing fields, animal kennels1 sleeping quarters, barns, warehouse premises, industrial 

lawns, eating establishments, food processing plant premises, golf course turf, 

greenhouses, domestic dwellings, rights-of-way, ornamental and1 or shade trees, 

ornamental lawns, tobacco and wood protection to buildings. Type I1 pyrethroids are 

characterized by the cyano moiety in their chemical structure (Type I pyrethroids do not 

contain this moiety, see Mechanism of Action for additional distinctions between the two 

types). Cyfluthrin is a mixture of eight possible isomers. 

Beta-cyfluthrin consists of four of the eight possible isomers of cyfluthrin, which are the 

more potent isomers of cyfluthrin. Thus, its application rate is usually lower than that for 

cyfluthrin. The environmental fate and ecological effects properties of cyfluthrin and 

beta-cyfluthrin are expected to be similar to each other. Although beta-cyfluthrin 

registrations are separate from cyfluthrin, the environmental fate and ecological database 

for beta-cyfluthrin has been largely supplemented by available data for cyfluthrin. 

Beta-cyfluthrin is registered also on numerous agricultural, non-agricultural and 

residential uses such as (but not limited to) alfalfa, apple, beans, brassica (head and stem) 

vegetables, broccoli, cabbage, canola, carrot, cashew, citrus, corn, cotton, peas, cucurbit 

vegetables, fruiting vegetables, grass forage1 fodder1 hay, hops, leafy vegetables, legume 

vegetables, lettuce, mustard, pastures, peach, peanuts, pear, pecan, pepper, pome hits, 

potato, plum, rangeland, root and tuber vegetables, sorghum, soybeans, stone fruits, 

sugarcane, sunflower, tomato, tree nuts, wheat, sugarbeets, tobacco, agricultural1 farm 

premises, animal kennels1 sleeping quarters, automobiles, barns, Christmas tree 

plantations, comrnerciall industrial lawns, fencerowsl hedgerows, greenhouse - empty, 

hospitals1 medical institutions premises, domestic dwellings, ornamental and1 or shade 

trees, ornamental lawns and turf, paths1 patios, paved areas, recreation area lawns, 

residential lawns and wood protection treatment to buildings. 

2. Problem Formulation 
2.1. Nature of Regulatory Action 

This report summarizes the Environmental Fate and Effects Division's (EFED) Problem 

Formulation for the Registration Review of cyfluthrin and beta-cyfluthrin. Previous risk 

assessments were completed for the uses of these chemicals, which serve as the basis for 

this assessment. 

The Food Quality Protection Act (FQPA) of 1996 mandated the EPA to implement a new 

program, i. e., registration review (htt~:llwww.epa.gov/oppsrrdl/registration review/). All 

pesticides distributed or sold in the United States generally must be registered by the 

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 product labeling. 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 reevaluate$ 

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 cyfluthrin and beta-cyfluthrin 

continue to meet the FIFRA standard for registration. This problem formulation far 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 and Scientific Advisory Panels 

Previous Assessments 

Recent risk assessments conducted on cyfluthrin and beta-cyfluthrin, indicated risk 

concerns for freshwater and estuarinelmarine organisms. In addition, there were risk 

concerns for organisms living in the benthos. 

In June and July 2007, EFED issued three incremental risk assessments (an assessment 

for uses for which the risk for cyfluthrin are similar to those previously identified) for 

proposed new uses of cyfluthrin (D33 1952+), beta-cyfluthrin (D3323 14+), and cyfluthrin 

and beta-cyfluthrin (D340740+). The first new use risk assessment for cyfluthrin, 

covered its use of the chemical on grasses; the second new use risk assessment for betacyfluthrin covered its uses on grasses, Crop Group #15 (cereal grains except rice) and 

Crop Group #16 (forage, fodder and straw of cereal grains); finally, the third new use risk 

assessment for cyfluthrin and beta-cyfluthrin covered the increased application rate for 

alfalfa (maximum application rate 0.175 lb a.i./Alseason for cyfluthrin and 0.35 lb 

a.i./A/season for beta-cyfluthrin). All three reviews relied upon previously issued 

assessments (e.g. high application rates for sweet corn at a rate of 0.44 lb a.i./A/season, 
and cotton at a rate of 0.5 lb a.i./A/season). These assessments concluded that the 

potential risks associated with newly proposed crops or maximum application rates were 

within the range of risks identified by previously issued risk assessments and overall risks 

should be similar. 

Also in June 2007, the EFED issued an incremental risk assessment for the proposed new 

use of PONCHO BETA (EPA Reg. No. 264-1056), a product containing both, 

chlothianidin and beta-cyfluthrin, for the use for seed treatment on sugar beet seeds 

(D335254). The single application rate for the chemical beta-cyfluthrin is 0.0125 lb 

a.i.lA, and the risks were based on a previously issued assessment for the use of 

cyfluthrin on tobacco, with a similar application rate. It was indicated thatagenerally, 

seed treatments result in less risk to aquatic organisms due to a lower potential for 

exposure since the seed is normally covered and there is little or no pesticide drift. Also, 

application rates per acre are usually lower than normal spray treatments." A seed 

leaching study was required for clothianidin and beta-cyfluthrin. 

Prior to this assessment, in 2006, a risk assessment was issued for the use of cyfluthrin on 

tobacco (D3 163 13). The application rate for tobacco is 0.0044 lb a.i./A, with a single 

application allowed. This is only a small fraction of the application rate on several other 

crops. Regarding risk to terrestrial and aquatic organisms, it was concluded that there 

was a potential for non-target aquatic organisms (freshwater and estuarinel marine, fish 

and invertebrates) to be exposed to cyfluthrin via off target spray drift and1 or runoff into 

surface water. The results indicated that chronic levels of concern (LOCs) were exceeded 

for estuarine1 marine invertebrates with a risk quotient (RQ) of 1.35. For the proposed 

maximum application rate on tobacco, the acute or chronic RQs for benthic invertebrates 

did not exceed the LOCs. Also, there were no acute or chronic risks to birds or mammals 

fkom a single application of cyfluthrin to tobacco. Cyfluthrin is very highly toxic to 

honey bees on an acute contact basis, therefore, risk was assumed. Risks to aquatic and 

terrestrial plants were not assessed because data were not available. Nonetheless, due to 

cyfluthrin's mode of action and lack of incidents pertaining phytotoxicity for the 

chemical or other pyrethroid pesticides, there were no phytotoxicity concerns stated in 

the risk assessment. The environmental fate and ecological effects databases were 

considered mostly complete, but an aerobic aquatic metabolism study was required. In 

addition, it was indicated that acute freshwater and chronic estuarinel marine sediment 

studies were received as follows. The studies are currently in review. 

MRID 46591 507 Cyfluthrin - Toxicity to Midge (Chironomus tentans) During a 

10-Day Sediment Exposure. 

MRID 46591 506 Cyfluthrin - Toxicity to Estuarine Amphipods (Leptocheirus 

plumulosus) During a 28-Day Sediment Exposure. 

Finally, the tobacco risk assessment also provided a fate characterization for cyfluthrin. 

In short, it was indicated that cyfluthrin is moderately persistent in the environment 

(terrestrial field dissipation half-lives 18 to <32 days; aerobic soil metabolism 73.5-94.8 

days; anaerobic soil metabolism of the order of about 30 days), and practically immobile 

(Kds ranged from 11 16 to 1793 mLIg, Kocls ranged from 73,480 to 124,000 mLlgoc). 
mote: According to the currently used mobility classification (FA0 2000), cyfluthrin is 

considered immobile to hardly mobile.] It was also pointed out that the primary routes of 

dissipation for cyfluthrin are hydrolysis in alkaline media (half-life 2.1 days), and 

aqueous and soil photolysis (respective half-lives of 4.5 and 5.6 days). Cyfluthrin is 

resistent to hydrolysis in acidic and neutral media. It binds strongly to soil suggesting 

little potential to leach to subsurfaces and to contaminate ground water. Nonetheless, 

cyfluthrin appeared to have a high potential to reach surface waters by spray drift or in 

runoff events accompanied by erosion, with cyfluthrin bound to particulate and organic 

matter in the water column. It was also indicated that the chemical has the potential for 

deposition in the benthos, accumulating with repeated use. Cyfluthrin was not expected 

to volatilize, based on its moderately low Henry's Law constant, low vapor pressure and 

binding capacity. This chemical bioaccumulates moderately (854X for total residtres, 

whole fish), with relatively rapid depuration (observed DTso for depuration 13 days). 

Degradates observed in the studies included DCVA, FPB-ald and FPB-acid, all of which 

are product of pyrethroid ester cleavage. 

In 2004, the EFED issued a risk assessment for several proposed new uses as follows: 

tree nuts, grapes and peanuts, wheat, leafy vegetables, fruiting vegetables, cucurbits, 

leafy brassica, pome fruit, stone hit. In addition, the registrant seeked to establish IR-4 

tolerances for the use of cyfluthrin on tuberous and corm vegetables (crop Subgroup 1 C), 

turnip greens, dried shelled peas and beans (except soybeans), grass hay, and grass forage 

(D274813-t.). Regarding the risk to terrestrial organisms, it was concluded that there were 

no acute or chronic risks to birds fiom applications of cyfluthrin. However, for small 15- 

35 g mammals, acute LOCs were slightly exceeded for single and multiple application 

scenarios. As in the case for the assessment for use on tobacco, risk was assumed for 

nontarget terrestrial insects; and for semi-aquatic and terrestrial plant, data were not 

required. 

In the 2004 assessment, most acute, chronic, restricted use and endangered species LOCs 

were exceeded for aquatic organisms (freshwater and estuarinelmarine fish and 

invertebrates). Acute RQs based on rainbow trout ranged from 1.5 to 39 while chonic 

RQs ranged from 0.45 to 30. For freshwater invertebrates, the results indicated that acute 

RQs for daphnia ranged from 4 to 107 and for crayfish ranged from 1.7 to 43. Chronic 

RQs for daphnia ranged from 1.3 to 61. For estuarinelmarine fish, acute RQs basCd on 

sheepshead minnow ranged fiom <0.01 to 0.70 while chronic RQs ranged fkom 0.10 to 

12. For estuarinelrnarine invertebrates, the results indicated that acute RQs for mysids 

ranged from 48 to 1214 and for shrimp surrogate crayfish ranged from 1.7 to 43. Chronic 

RQs for mysids ranged from 45 to 2130. In addition, based on the risk of cyfluthrin to 

fish, exposed amphibians were also assumed to be at risk due to a portion of their lifecycle being spent in aquatic environments, particularly the early life stages that are 

primarily aquatic and where respiration is dependent on gills (such as tadpoles) oa where 

later adult stages retain external gill structures (primitive salamanders). It was indicated 

that amphibians often inhabit shallow litoral areas where incoming runoff concentrations 

of cyfluthrin may be the highest. 

In 200 1, the EFED issued an incremental risk assessment for the use of cyfluthrin on 

Southern peas (D271494). Conclusions were based on the previously issued assessment 
of the same or similar use in the year 2000 (see below). 

In 2000, the EFED also conducted an assessment for the use of cyfluthrin on leafy 

vegetables (lettuce, mustard greens, cauliflower and broccoli), soybeans, corn (pop, field, 

and seed), dry peas, pigeon peas, chick peas, and lentils (D256960+). The following was 

stated in the review: "Cyfluthrin poses a risk to freshwater and estuarinelmarine fishes 

and invertebrates based on the highest suggested application rates for all proposed 

commodities based on corn (pop, seed, and field), leafy vegetables, and soybeans. Levels 

of concern (LOCs) for freshwater fishes and freshwater invertebrates and estuarine1 

marine invertebrates were exceeded on an acute and chronic basis. Chronic data for the 

freshwater rainbow trout showed LOC exceedance while chronic data for the fathead 

minnow did not show an exceedance of LOCs when multiple applications of cyfluthrin 

was used. Semi-aquatic and terrestrial plant data is not required due to the results of 

previous phytotoxicity testing with a pyrethroid surrogate (cypermethrin) which showed 

no evidence of phytotoxicity. Based on the registrant submitted studies, cyfluthrin 

appears to be poorly mobile and moderately persistent in the environment. Because of 

cyfluthrin's low mobility, it should not reach ground water in significant quantities, but 

does have the potential for surface water contamination through drift and erosion where it 

will become sorbed mainly on sediment." 

1999 Scientzj?~ Advisory Panel 

A FIFRA Scientific Advisory Panel (SAP) in 1999 examined the sediment toxicity and 

fate of synthetic pyrethroids. In response to a question regarding whether sediment 

toxicity data on one pyrethroid (cypermethrin) could be used to predict sediment toxicity 

to all pyrethroids, the panel generally supported the method of using data from a few 

pyrethroids to extrapolate information on toxicity to other pyrethroids. Also, the new 

CFR Part 158 requirements include sediment toxicity tests and these studies are 

considered particularly important for ecological risk assessment of all synthetic 

pyrethroids, including cyfluthrin and beta-cyfluthrin. 

The SAP commented on the use of Kd or KOC to estimate concentrations of synthetic 

pyrethroids in sediments, recommending that the Agency reconsider Koc as a measure of 

the binding potential of synthetic pyrethroids to sediment and soil because the use of Kd 

alone limits extrapolation to experimental conditions while Koc allows estimates 

partitioning across a wide variety of soillsediment types (USEPA 1999). The Panel 

expressed concern that standard methods used to measure sorption may not be applicable 

to highly hydrophobic compounds due to high solids to water ratio, consideration of the 

character of the organic matter, presence of dissolved organic carbon, use of nonrepresentative soils and sediments as sorbents, and improper methods used to measure 

organic carbon. 

While the biota-sediment accumulation factor is a widely accepted method of assessment 

of bioaccumulation in sediments, the Panel indicated that the bioconcentration data for 

Daphnia and Hyalella should be sufficient to predict bioconcentration of pyrethroids. 

Finally, the Panel indicated that use of a solid phase microextraction (SPME) method to 

determine the dissolved concentration in water could be used to account for sorption of 
pyrethroids to organic carbon and colloids present in the water column in the 

measurement of bioconcentration factors. 

In 2003 and in response to the comments from the SAP on pyrethroids, EFED requested 

the following studies on cyfluthrin and three other synthetic pyrethroids: cypermethrin, 

esfenvalerate and bifenthrin (memorandum dated 12/22/03, Rexrode & Melkndez): 

850.1735: 10-day Sediment (freshwater) 

- Test organism: Hyalella azteca and Chironomus dilutus. 

- Duration: 10 days, endpoint is survival. 

EPA/600/R01/020: Chronic EstuarineJMarine Sediment Testing 

- 28 day test on Leptocheirusplumulosus. 

- Percentage of neonates that suwive as adults. 

- Growth rate. 

- Reproduction (#eggs/ female, etc.). 

- Behavior. 

A chronic 65-day freshwater test was also requested only for cypermethrin. 

EPA/600/R-991064: Chronic Freshwater Sediment Testing 

- 65 day test on Chironomus dilutus. 

- Survival. 

- Growth rate. 

- Reproduction (# eggs/ female, time to oviposition, proportion of females 

ovipositing, % hatch). 

2009 ScientiJic Advisory Panel 

OPP presented a "Proposed Common Mechanism Grouping for the Pyrethrins and 

Synthetic Pyrethroids to a FIFRA SAP in June 2009. OPP proposed two subgroups 

based on Type I or Type I1 effects related to sodium current tails and neurobehaviloral 

impact, with esfenvalerate and fenpropathrin showing symptoms of both types. 

Cyfluthrin and beta-cyfluthrin are Type I1 synthetic pyrethroids, which means th& are 

cyano-substituted in the alpha position. The panel indicated that substances with hixed 

characteristics could be included in both groups (see p. 18 of SAP minutes, USEqA 

2009). This mechanism of action assessment was performed by HEDIOPP and 

presented to the SAP to determine if a cumulative assessment is required for the synthetic 

pyrethroids. However, EFED does not currently conduct cumulative assessments. EFED 

does not currently have the methodology to conduct similar cumulative risk asses6ments 

for all of the (non-human) biological entities for which EFED has responsibility. 

Although EFED agrees that an assessment of cumulative risk would be a desirable goal, 

EFED does not believe the current state of the science can address this issue 

quantitatively. The ecological risk assessment for cyfluthrin and beta-cyfluthrin hll 

consider open literature, modeling and other lines of evidence, as available, to 

qualitatively address the potential for cumulative effects in the risk assessment. 
Information on the 2009 SAP is available in the docket (with non-copyright material 

available at http://www.requlations.aov) under EPA-HQ-OPP-2008-0489. 

Open Literature Information 

There are multiple articles in the open literature that indicate concern over cyfluthrin, 

beta-cyfluthrin and other pyrethroids' toxicity towards benthic and other non-target 

aquatic organisms. Also, the articles illustrate cyfluthrin's prevalence in the 

environment. Please, refer to the Appendix C for further details. 

Aquatic Life Criteria andAquatic Life Benchmarks 

The Clean Water Act requires the Agency to publish water quality criteria that accurately 

reflect the latest scientific knowledge on the kind and extent of all identifiable effects on 

health and welfare which might be expected from the presence of pollutants in any body 

of water, including ground water. While these recommended criteria do not, in 

themselves, impose any requirements, states and authorized tribes can use them to 

develop water quality standards. An Aquatic Life Ambient Water Quality Criteria 

document has not been published for cyfluthrin or beta-cyfluthrin 

(http:llwww.epa. gov/waterscience/criteria/). 

Based on toxicity values revised by the EPA, the OPP publishes aquatic life benchmarks 

for freshwater species, based on the most sensitive species fiom the most recent risk 

assessments. For cyfluthrin and beta-cyfluthrin, no aquatic life benchmarks have been 

published 

(http://www.epa.gov/oppefedl/ecorisk derslaquatic life benchmark.htm#benchmarks). 

Impaired Water Bodies 

Cyfluthrin and beta-cyfluthrin are not individually identified as a cause of impairment for 

any water bodies listed as impaired under section 303(d) of the Clean Water Act, based 

on information provided at 

http://iaspub.epa.gov/tmdl waterslO/attains nation cy.cause detail 303d?p cause grou 

p id=885. However, the pyrethroids as a group have been identified as a cause for 

impairment for three water bodies in Central Valley, California: Del Puerto Creek, 

Ingram Creek Site (from confluence with Hospital Creek to Highway 33 crossing) and 

second Ingrarn Creek Site (fiom confluence with San Joaquin River to confluence with 

Hospital Creek). 

Nonetheless, no Total Maximum Daily Load (TMDL) criteria have been developed for 

cyfluthrin or beta-cyfluthrin, based on information provided at 

http://iaspub.epa.aov/tmdl waters1 Olattains nation.tmd1 pollutant detail?p pollutant m 

oup id=885&p pollutant group name=PESTICIDES. More information on impaired 

water bodies and TMDLs can be found at http://www.e~a.gov/owow/tmdl/. The Agency 

invites submission of water quality data for these pesticides. To the extent possible, data 

should conform to the quality standards in Appendix A of the OPP Standard Operating 

Procedure: Inclusion of Impaired Water Body and Other Water Quality Data in OPP's 

Registration Review Risk Assessment and Management Process (refer to: 

http://www.epa.gov/oppsrrdl/registration reviewlwater quality sop.htm), in order to 
ensure they can be used quantitatively or qualitatively in pesticide risk assessments. 

3. Stressor Source and Distribution 

Cyfluthrin (Tables 3.la) is a synthetic pyrethroid insecticide and acaricide. Its structure 

has three rings, two phenyl rings attached to each other by an oxygen atom, and a 

cyclopropyl ring. It is a Type I1 synthetic pyrethroid (it is cyano-substituted in the alpha 

position). The chemistry of cyfluthrin may be dictated by its ester moiety. It would be 

expected to hydrolyze as the pH increases; this is confirmed from the hydrolysis study, 

where cyfluthrin was stable at pH 5, nearly stable at pH 7 and showed a half-life of 2.1 

days at pH 9. The structure of the molecule has three chiral centers that could result in a 

total of 23 or 8 isomers. Cyfluthrin has 2,2-dichloroethenyl and it is 2,2-dimethyl 

substituted in the cyclopropane ring. 

Beta-cyfluthrin (Tables 3.la) is a mixture of four of the isomers of cyfluthrin. 

Chemically, it is the (R)-alcohol-(1 S)-cis-acid, (R)-alcohol-(1 S)-trans-acid, (S)-alcohol- 

(1R)-cis-acid and (S)-alcohol-(1R)-trans-acid out of eight isomeric esters. 

In general, the physicochemical and environmental fate properties of cyfluthrin and betacyfluthrin are expected to be similar to each other. Information about the identification 

of cyfluthrin and beta-cyfluthrin is provided in Table 3.la. A summary of 

physicochemical properties of cyfluthrin and beta-cyfluthrin is included in Table 3.lb. 
dimethylcyclopropanecarboxylate in 

ratio 1:2 yitJ the enantiomeric pair 

(R)-a-cyano-4-fluoro-3- 

phenoxybenzyl(lS,3R)-3-(2,2- 

dichloroviny1)-2,2- 

dimethylcyclopropanecarboxylate 

and (S)-a-cyano-4-fluoro-3- 

phenoxybenzyl(lR,3S)-3-(2,2- 

dichloroviny1)-2,2- dichloroviny1)-2,2- 

imethylcyclopropanecarboxylate htt~:/lwww.alanwood.net/~estic htta://~~~.alanwood.netiuestic 

(RS)-a-cyano-4-fluoro-3- ides/cvfluthrin.html reaction mixture comprising the ideslbeta-cvfluthrin.html 

henoxybenzyl(1RS)-cis-trans-3- enantiomeric pair (R)-a-cyano-4- 

(2,2-dichloroviny1)-2,2- fluoro-3-phenoxybenzyl (IS)-cis-3- 

imethylcyclopropanecarboxylate (2,2-dichloroviny1)-2,2- dimethylcyclopropanecarboxylate 

and (4-a-cyano-4-fluoro-3- 

phenoxybenzyl(1R)-cis-3-(2,2- 

dichloroviny1)-2,2- 

dimethylcyclopropanecarboxylate in 

ratio 1 :2 yitJ the enantiomeric pair 

(R)-a-cyano-4-fluoro-3- 

phenoxybenzyl (IS)-tmns-3-(2,2- 

dichloroviny1)-2,2- 

dimethylcyclopropanecarboxylate 
Unstated stereochemistry; 

It consists of 8 isomers 

(S)-alcohol (1R)-cis-acid 
Cyfluthrin is a mixture of all possible isomers. 

86560-92-1 (diastereoisomer I) 

86560-93-2 (diastereoisomer 11) 

86560-94-3 (diastereoisomer 111) 

86560-95-4 (diastereoisomer IV) 

Beta-cyfluthrin is comprised mainly of 

FAOIWHO Specifications1 

and Cyfluthrin (157)lBetacyfluthrin (228), Draft 

Review Prepared by 

Australian Quarantine and 

Inspection sewice' 

Diastereoisomer IV: (lR,3S,lS + lS,3R,lR = 1: 1; trans) 

Dia$@e'&bjsqmler iY ' Gym&!4i:%6i @&q-~y~ut$rim 

I 23-27% 4.0% 

I1 17-21% 30.0-40.0 FAOIWHO Specifications 

rtmula Cyfluthrin's data sheet 

64.40 diastereoisomer I; 

Not measurable; weight 1 

basic or acidic characteristics in water Active Substance Cvfluthrin 

and eta-cyfluthrin4 

2.32 x 10" mdL or vvm or 2.32 DD~ at 20°C 

pH 31pH 5: 2.512.2 uUg/L di; I; 2.111.9 uz diast. 11; 3.212.2 

ug/L diast. 111; 4.312.9 ug/L diast. IV* 

*The material used was a defined mixture of four 

diastereoisomeric enantiomer pairs. 

'Not Soluble' 

2.1 x mm~i at 20°C 

020°C 9.6 x Pa diast. I 

1.4 x loFs Pa diast I1 

2.1 x Pa diast. I11 

8.5 x 10" Pa diast. IV 

025°C 2.1 x Pa diast. I 

3.4 x 1 o-~ Padiast I1 

4.7 x lo-' Pa diast. I11 

2.0 x Pa diast. IV 

Laskowski 2002, 

FAOIWHO Specifications 

FAO, 2000 

Laskowski 2002 

FAOIWHO Specifications 

USEPA, 2008 

'http://www.fao.org/a~~~~~/~~~~~estici~ecs/docs/dnew/cflut.df and 

htep:l/www.fao.ordarr/AGPIAGPP/Pestici~vdf (accessed 05/05/10). 

2 htep://www.fao.ordfileadmin/temvlates/amhome/documentsPests~Pesticides/~P~valuationO7/C~flu~ 

hin.pdf (accessed 05/05/10). 

3 hW://toxnet.nlm.nih. god. 4 http://ec.europa.edfood/plant/protectiodevaluatiodexistactive/list1-29 en.pdf and 

hftr>://ec.europa.eu/food/vlant/~rotectiodevaluatiodexistactive/listl-32~en.pdf (accessed 05/05/10). 
Cyfluthrin has a high molecular weight of 434.29 glmol. It also has a small solul$lity 

(only 2.32 ppb) and a high octanoll water partition coefficient (Kow = 9.33~10~). Based 

on its octanoY water partition coefficient, it appears that cyfluthrin has the potential to 

bioaccumulatel bioconcentrate (Kow 3 1000) in fish and other aquatic organisms. I With a 

vapor pressure of 1.5 x loa8 mmHg, it is considered "non-volatile under field conditions." 

Due to its very small solubility (2.32 ppb), its calculated Henry's Law Constant iq 

moderately low (3.7 x 10'~ atm-m3/mol). In addition, its Cwater/Calr is 6612, whicH 

classifies it as "slightly volatile from a water surface" (USEPA 2008). Cyfluthrid could 

have a potential to volatilize slightly from wet surfaces. The potential to volatiliz may 

be greatly attenuated in the environment by its tendency to bind to organic matter I" (e.g., 

soils, sediments, or organic matter and particulate in natural water). For cyfluthrih, the 

log KOA range is 9.79 - 1 1.88 (calculated and EPIWEB v.4.0 estimates), the log is 

5.97 and the rate of transformation is moderate in the environment and appears to be 

moderate in fish (the majority of the residues observed in fish were the parent 

compound), with moderately rapid depuration (observed depuration DT50 of 

approximately 3 days). Therefore, it appears that cyfluthrin may have a low potential to 

biomagnify substantially in terrestrial food chains, based on the presumption made by 

Gobas et al. and Armitage & Gobas, in 2003 and 2007 articles, respectively. 

and beta-cyfluthrin 

SOURCES 

Laskowski, 2002 

Laskowski, 2002 

FAOIWHO Specifications 

Calculated Value 

EPIWEB ".4.0 ~~~i~~~~ 

Calculated 

EPIWEB v.4.0 

USEPA, 2008 

Calcula{ed 

USEPA, ZOO8 

EPIWEB v.4.0 Estimate 

**Gobas et al. ,2003 and 

Armitage & Gcjbas, 2007 

support this prqsumption 

utilized here onl* as a broad 

reference to detbrmine the 

potential for 

biomagnifi 1 ation. 

Table 3.lb. Summary 

PARAMETER 

Henry's Law Constant 

Octano'-Water Partition 

Coeff~cient 

(20 and 2Z°C) 

Kow (log Kow) 

Octanol-Air Partition 

Coefficient 

&A Oog &A) 

K~w (log K~w) 

CwateACair 

OH Radical Reaction 

Half-life 

Biomagnification 

Potential 

Bolded value is considered - 

of physicochemical properties of cyfluthrin 

VALUE@) (units) 

3.7 x atm-m3/mol (estimated from vapor pressure at 

25°C and water solubility at 20°) 

9.33 lo5 (5.97)* 

6.00 diast. I; 5.94 diast. 11; 6.04 diast. 111; 5.91 diast. IV* 

6.18 diast. 11; 6.18 diast IV at 22°C 

*The material used was a defined mixture of four 

diastereoisomeric enantiomer pairs. 

Kow - K,=-- KowRT = 6.17 x lo9 (9.79) 

KAW Henry's Law Constant 

Calculated using kw = 9.33 x lo5 and HLC = 3.7 x 1w6 

atm-m3/mol; the temperature was assumed to be 25°C. 

EPIWEB est.: 1.47 x 101° - 7.52 x 10" (10.164-11.876) 

KAW = Cair/Cwater = HLCIRT = 1.51 x (-3.82) 

EPIWEB estimate: KAW = 1.18 x 1 o'~ (-5.926) 

'Slightly volatile from a water surface' 

- 

Cwatm S x T x R x 760 = 6,612 (unitless) = ( c,, PXGMWX~O~ 1 

'Slightly volatile from a water surface' 

0.856 days 

(Assumptions: 12-hr days; 1.5 x lo6 0H/cm3) 

Presumption: If log KOA > 5, log Kow > 2 and the rate of 

chemical transformation is low, the chemical may 

biomagnify in terrestrial food chains*" 

For cyfluthrin, log KOA> 5, log kw> 2. However, its rate 

of transformation is moderate in the environment and 

appears to be moderately rapid in fish, with moderate to 

rapid depuration indicated. Therefore, it appears that 

cyfluthrin may have a low potential to biomagnz3 in 

terrestrial food chains. 

representative for cyfluthrin. 
Nevertheless, the possibility of biomagnification has not been quantified. Even though 

EFED has not adopted an official reference or guideline to distinguish chemicals that 

biomagnify, Gobas et al. and Armitage & Gobas' presumption was utilized here as a 

general or broad reference to detect the potential for biomagnification in terrestrial food 

chains for these chemicals. 

Even though various degradates were observed in the laboratory studies (e.g. FPB-acid 

and DCVA), it was found that they were the result of the rupture of the ester bond of the 

parent molecule. It is believed that the toxicity of the resulting molecules is substantially 

reduced compared to the parent because they presumably have lost the neurotoxic mode 

of action. Table 3.lc shows the chemical structures of cyfluthrin's major degradation 

products. At this time, they are not considered stressors of concern in this problem 

formulation. As part of the forthcoming risk assessment, available information on the 

toxicity of these degradates will be considered to confirm this assumption. 

3.1. Mechanism of Action 

Table 3.1~. 

Common 

Name 

DCVA 

FPB-ald 

FPB-acid 

Both, cyfluthrin and beta-cyfluthrin are neural toxic insecticides acting through direct 

contact and ingestion. The insecticidal effect of pyrethroids is characterized by a rapid 

"knock down," or paralysis, of insects. All pyrethroids act as axonic poisons, affecting 

both the peripheral and central nervous systems, and share similar modes of action. The 

primary biological effects of cyfluthrin, beta-cyfluthrin and other pyrethroids on insects 

and vertebrates reflect an inhibition of the correct firing of neurotransmitter deliver 

signals from one cell to another via nerve membrane inhibition of the voltage-gated ca2+ 

Major Transformation Products 

Chemical Name 

3-(2,2-dichloroviny1)-2,2- 

dimethyl-cyclopropanecarboxylic 

acid 

4-fluoro-3 -phenoxybenzaldehyde 

or 

3 -phenoxy-4-fluorobenzaldehyde 

4-fluoro-3-phenoxybenzoic acid 

or 

3-phenoxy-4-fluorobenzoic acid 

of Cyfluthrin and Beta-cyfluthrin 

Structure 

clqAH H3C CH3 aF')'J+ \ o / /'O 

~~nOH 
(calcium ion) channels coupled with a stimulatory effect on the voltage-gated Na+ 

(sodium ion) channels. The pyrethroids (including cyfluthrin and beta-cyfluthrin) share 

similar modes of action, and are considered axonic poisons that affect both the peripheral 

and central nervous system. 

It is now well established that severe neurological symptoms of poisoning with 

pyrethroids in mammals and insects are the result of modification of the Na+ channels 

activity (cellular pores through which ~a+ ions are permitted to enter the axon to cause 

excitation) (Matsumura, 1985). Advanced electrophysiological experiments using 

voltage clamp and patch clamp, together with ligand-binding and ionic flux experiments, 

have unveiled unique actions of pyrethroids of keeping the Na+ charnel in the open state 

for an extremely long period, sometimes as long as several seconds. This modification of 

Na+ channel properties leads to hyperactivity of the nervous system. This action leads to 

spontaneous depolarizations, augmented neurotransmitter secretion rate and 

neuromuscular block, which ultimately results in paralysis of the insect. 

Pyrethroids have also been shown to suppress GABA and glutamate receptor-channel 

complexes and voltage-activated ca2' channels, but the toxicological significance of 

these actions is uncertain. Relative to physiological responses, researchers have 

designated two types of pyrethroids, Type I (e.g., bifenthrin, resmethrin, permethrin) and 

Type I1 (e.g., cypermethrin, deltamethrin, fenvalerate, cyfluthrin and beta-cyfluthrin). 

Type I pyrethroids action is mainly associated with compounds that cause nerve 

excitation symptoms typified by the appearance of repetitive firing of axons in the 

peripheral nervous system and a negatively correlated temperature reversible knogkdown 

property (Clark & Matsumura, 1987). In insects, the type I1 pyrethroids predominantly 

cause ataxia and uncoordinated movement. 

3.2. Overview of Pesticide Usage 

Cyfluthrin and beta-cyfluthrin have numerous uses. A summary of agricultural use 

patterns for cyfluthrin and beta-cyfluthrin, based on a set of labels for cyfluthrin and all 

labels for beta-cyfluthrin, are shown Tables 3.2a and 3.2b. 

Table 33a. Summary use information for cvfluthrin based on BAYTHROIDB 2 ~mulsibable 

Pyrethroid Insecticide (Reg. No. 264-745), RENOUNCE@ 20WP Insecticide (Reg. No. 26k784) and 

LEVERAGE@ 2.7 Suspension Emulsion Insecticide (Reg. No. 264-770) labels. For use oh corn, labels 

with Reg. Nos. 264-811,264-812,264-813 and 264-839 were also evaluated. I 

USE 

Corn (field corn, popcorn, seed corn, 

teosmte) - foliar applications 

or Corn - soil avolications at vlant 

or Corn - soil applications at plant - 

granular formulation 

Sweet Corn (FoliarApplications)/_(Soil 

Application - one application allowed) 

Cotton 

Peanut 

INTERVAL 

BETWEEN 

APPS. (days) 

7 

2 

3 

10 

SINGLE 

APP. RATE 

(lbs. a.i./A) 

0.044 

0.044 

0.0073 

0.044 

0.05 

0.044 

I 

APPL~c. 

METH~D 

G, A, ULV, 

Soil 

Applicanions 

G, A, ULV 

G, A, ULV 

G, A, ULV 

NUMBER 

OF APPS. 

4 

1 

10 

10 

3 

PHI (days) 

Grain and 

fodder - 

2 1 ; green 

forage - 0 

0 

0 

14 

SEASONAL 

APP. RATE 

(lbs. a.i./A) 

0.175 

0.44 

0.5 

0.131 
Table 3.2a. Summary use information for cvfluthrin based on BAYTHROID0 2 Emulsifiable 

Pyrethroid Insecticide (Reg. No. 264-745), RENOUNCE0 20WP Insecticide (Reg. No. 264-784) and 

LEVERAGE@ 2.7 Suspension Emulsion Insecticide (Reg. No. 264-770) labels. For use on corn, labels 

with Reg. Nos. 264-811,264-812,264-813 

USE 

Sorghum 

Soybean 

Sugarcane 

Sunflower 

Tobacco 

Wheat 

Brassica (Cole) Leafy Vegetables: 

broccoli, broccoli raab (rapini), Chinese (gal 

lon) broccoli, Brussels sprouts, cabbage, 

Chinese (bok choy) cabbage, Chinese (napa) 

cabbage, Chinese mustard (gai choi) 

cabbage, cauliflower, cavalo broccoli, 

collards, kale, kohlrabi, mizuna, mustard 

greens, mustard spinach, rape greens, and 

turnlp greens 

Cucurbits: balsam apple, balsam pear, 

bitter melon, chayote, Chinese cucumber, 

Chinese waxgourd, citron melon, cucumber, 

gherkin, edible gourd (includes various), 

muskmelon (mcludes cantaloupe, honeydew 

melon and others), pumpkin, summer 

squash (includes zucchini and others), 

watermelon, Winter squash (includes 

calabaza, and others) 

Fruiting Vegetables: eggplant, 

groundcherry, pepino, pepper (includes bell 

pepper, chilipepper, cooking pepper, 

pimento, sweet pepper), tomatillo, tomato 

Leafy Vegetables: amaranth, arugula, 

cardoon, celery, Chinese celery, celtuce, 

chervil, Chrysanthemum, corn salad, cress, 

dandelion, dock, endive, Florence fennel, 

lettuce (head and leaf), New Zealand 

spinach, orach, parsley, purslane, radicchio, 

rhubarb, spinach, Swiss chard, vlne spinach 

Dried Shelled Legume Vegetables: 

adzuki beans, blackeyed pea, broad bean, 

catJan, chickpea, cowpea, crowder pea, field 

bean, field pea, guar, kidney bean, lablab 

bean, lentil, dry lima bean, lupin (various), 

moth bean, mung bean, navy bean, pigeon 

pea, pmto bean, rice bean, tepary bean, urd 

bean 

Southern Pea 

Potato and Other Tuberous and Corm 

Vegetables: arracacha, arrowroot, 

artichoke, edible canna, cassava, chayote 

root, chufa, dasheen, gmger, leren, potato, 

sweet potato, tamer, true yam, turmeric, 

yam bean 

SINGLE 

APP. RATE 

Obs. a.i./A) 

0.044 

0.044 

0.044 

0.044 

0.0044 

0.038 

0.05 

0.044 

0.044 

0.05 

0.05 

0.033 

0.044 

and 264-839 

NUMBER 

OF APPS. 

3 

4 

6 

3 

1 

2 

4 

4 

6 

4 

2 

5 

6 

were also 

SEASONAL 

APP. RATE 

(Ibs. a.i./A) 

0.131 

0.175 

0.263 

0.131 

0.0044 

0.076 

0.2 

0.175 

0.263 

0.2 

0.1 

0.165 

0.263 

evaluated. 

INTERVAL 

BETWEEN 

APPS. (days) 

10 

7 

7 

7 

NIA 

3 

7 

7 

7 

7 

14 

5 

5 

APPLIC. 

METHOD 

G, A, ULV 

G, A, ULV 

G, A, ULV 

G, A 

G 

G, A, ULV 

G, A 

G, A 

G, A 

G, A 

G, A 

G, A 

G, A 

PHI (days) 

14 

45 

15 

30 

Apply UP to 

7 days 

following 

transplantmg 

30 

0 

0 

0 for 

tomato and 

7 for other 

crops 

0 

7 

3 

0 
Table 3.2a. Summary use information for cvfluthrin based on BAYTHROIDG9 2 Emulsifiable 

Pyrethroid Insecticide (Reg. No. 264-745), RENOUNCE@ 20WP Insecticide (Reg. No. 264-784) and 

LEVERAGE@ 2.7 Suspension Emulsion Insecticide (Reg. No. 264-770) labels. For use on, corn, labels 

with Reg. Nos. 264-811,264-812,264-813 

USE 

Root Vegetables (except sugarbeet): 

gardenbeet, edible burdock, carrot, celeriac, 

turnip-rooted chervil, chicory, ginseng, 

horseradish, turnip-rooted parsley, parsnip, 

radish, Oriental radish, rutabaga, salsify 

(various), skirret, turnip 

Citrus** calamondm, citrus citron, citrus 

hybrids (includes chlronja, tangelo), 

grapefnrit, kumquat, lemon, lime, mandarin 

(tangerine), orange, pummelo, satsuma 

mandarin, white sapote and other cnltivars 

and/or hybrids of these 

**California and Arizona, only. 

Grape: table grape, raisin, wine and 

muscadme grape 

(Product LEVERAGE@ 2.7) 

Hop 

Pome Fruit: apple, crabapple, loquat, 

mayhaw, pear, Oriental pear, quince 

Stone Fruit: apricot, cherry, nectanne, 

peach, plum, plumcot, prune (fresh and 

dried) 

Tree Nut Crops: almond, beechnut, Brazil 

nut, butternut, cashew, chestnut, chinquapin, 

filbert, hickory nut, macadamia nut, pecan, 

pistachio, walnut (black and English) 

Alfalfa, alfalfa grown for seed 

Grass (pasture, rangeland, grass for seed, 

grass for hay, grass in mixed-stands with 

alfalfa) 

labels. 

USE 

Corn (field corn, popcorn, seed corn); 

Corn (soil applications) 

Sweet Corn (FoliarApp1ications)l 

(Soil Application - at plant) 

Cotton 

Peanut 

Sorghum 

SINGLE 

APP. RATE 

(Ibs. a.i./A) 

0.044 

0.1 

0.05 

0.07 

0.05 

0.044 

0.044 

0.044 

. 0.044, 

0.088 per 

cutting 

0.044 per 

aPP. 

SINGLE 

APP. RATE 

(Ibs. a.i./A) 

0.022 

0.0221 

0.022 

0.025 

0.022 

0.022 

and 264-839 

NUMBER 

OF APPS. 

5 

1 

4 

1 

5 

1 

2 

1 

8 

4 

NUMBER 

OF APPS. 

4 

10 

10 

3 

3 

were also 

SEASONAL 

APP. RATE 

(Ibs. a.i./A) 

0.22 

0.1 

0.2 

0.07 

0.25 

0.044 

0.088 

0.044 

0.35 

0.176 

SEASONAL 

APP. RATE 

(Ibs. a.i./A) 

0.088 

0.44 

0.25 

0.066 

0.066 

evaluated. 

INTERVAL 

BETWEEN 

APPS. (days) 

7 

N/A 

14 

N/A 

14 

NIA 

14 

NIA 

5 

5 

INTERVAL 

BETWEEN 

APPS. (days) 

7 

2 

3 

10 

10 

APPLIC. 

METH~D 

G, A 

G, A 

G, A 

G, A 

G, A 

G, A I 

G, A 

I 

G, A, U~LV 

I 

G, A, U~V 

I 

PHI (days) 

0 

0 

3 

7 

7 

7 

14 

7 

Pregrazing 

interval: 

0-7 

G, A, UGV, 

Soil 

Applicatibns I 

G, A, LJLV 

G, A, ULV 

G, A, ULV 

G, A, ULV 

Grain and 

fodder - 

21; green 

forage - 0 

0 

0 

14 

14 
Table 3.2b. Summary use information for beta-cvfluthrin, based on BAYTHROIDB XL (Reg. No. 

264-840), LEVERAGE@ 360 

labels. 

USE 

Soybean 

Sugarcane 

Sunflower 

Tobacco 

Brassica (Cole) Leafy Vegetables: 

broccoli, broccoli raab (rapini), Chinese (gal 

lon) broccoli, Brussels sprouts, cabbage, 

Chinese (bok choy) cabbage, Chinese (napa) 

cabbage, Chinese mustard (ga choi) 

cabbage, cauliflower, cavalo broccoli, 

collards, kale, kohlrabi, mlzuna, mustard 

greens, mustard spinach, rape greens, and 

turnip greens 

Cucurbits: balsam apple, balsam pear, 

bitter melon, chayote, Chinese cucumber, 

Chinese waxgourd, citron melon, cucumber, 

gherkin, edible gourd (includes vmous), 

muskmelon (indudes cantaloupe, honeydew 

melon and others), pumpkin, summer 

squash (includes zucchini and others), 

watermelon, Winter squash (includes 

butternut squash, calabaza, and others) 

Fruiting Vegetables: eggplant, 

groundcherry, pepino, pepper (includes 

bellpepper, chilipepper, cookmg pepper, 

pimento, sweet pepper), tomatillo, tomato 

Leafy Vegetables: amaranth, arugula, 

cardoon, celery, Chinese celery, celtuce, 

chervil, Chrysanthemum, corn salad, cress, 

dandelion, dock, endive, Florence fennel, 

lettuce (head and leaf), New Zealand 

spmach, orach, parsley, purslane, radicchio, 

rhubarb, spinach, Swiss chard, vine spinach 

Dried Shelled Legume Vegetables: 

adzuki beans, blackeyed pea, broad bean, 

catjan, chickpea, cowpea, crowder pea, field 

bean, field pea, guar, kidney bean, lablab 

bean, lentil, dry lima bean, lupin (vanous), 

moth bean, mung bean, navy bean, pigeon 

pea, plnto bean, rice bean, tepary bean, urd 

bean 

Southern Pea 

Potato and Other Tuberous and Corm 

Vegetables: arracacha, arrowroot, 

artichoke, edible canna, cassava, chayote 

root, chufa, dasheen, ginger, leren, potato, 

sweet potato, tanier, true yam, turmeric, 

yam bean 

Root Vegetables (except sugarbeet): 

garden beet, edlble burdock, carrot, celeriac, 

turnip-rooted chervil, chicory, ginseng, 

horseradish, turnip-rooted parsley, parsnip, 

radish, Oriental radish, rutabaga, salsi6 

(vanous), skirret, turnip 

Insecticide 

SINGLE 

APP. RATE 

(Ibs. ai./A) 

0.022 

0.022 

0.022 

0.0022 

0.025 

0.022 

0.022 

0.025 

0.025 

0.017 

0.022 

0.022 

(Reg. No. 

NUMBER 

OF GPPS. 

4 

6 

3 

1 

4 

4 

6 

4 

2 

5 

6 

5 

264-1104) and 

SEASONAL 

APP. RATE 

(lbs. a.i./A) 

0.088 

0.132 

0.066 

0.0022 

0.1 

0.088 

0.132 

0.1 

0.05 

0.083 

0.132 

0.11 

PONCHO BETA 

INTERVAL 

BETWEEN 

APPS. (days) 

7 

7 

7 

NIA 

7 

7 

7 

7 

14 

5 

5 

7 

(Reg. No. 

APPLIC. 

METHOD 

G, A, ULV 

G, A, ULV 

G, A 

G 

G, A 

G, A 

G, A 

G, A 

G, A 

G, A 

G, A 

G, A 

264-1056) 

PHI (days) 

45 

15 

30 

Apply 7 

days 

following 

transplantmg 

0 

0 

0 

0 

7 

3 

0 

0 
As mentioned previously at the top of Tables 3.2a and 3.2b, there are several end 'use 

agricultural products containing cyfluthrin and beta-cufluthrin like BAYTHROID@ XL 

(Reg. No. 264-840), BAYTHROID@ 2 Emulsifiable Pyrethroid Insecticide (Reg. No. 264-745), 

RENOUNCE@ 20WP Insecticide (Reg. No. 264-784) and PONCHO BETA (Reg. No. 264-1056). 

Table 3.2b. Summary use information for beta-cvfluthrin, based on BAYTHROIDO XL (Reg. No. 

264-840), LEVERAGE@ 360 Insecticide (Reg. No. 264-1104) and PONCHO BETA (Reg. No. 264-1056) 

In general, for a given crop, the application rate for beta-cyfluthrin is around half lthat for 

cyfluthrin. For agricultural products, application methods include aerial or grounfl spray 

(foliar) and ULV. In addition, soil applications are possible, particularly for corn! The 

labels for cyfluthrin and beta-cyfluthrin require a buffer zone of 10 ft around certain 

bodies of water, such as lakes, reservoirs, rivers, permanent streams, marshes or natural 

ponds, estuaries and commercial fish farm ponds, so as to allow growth of a maintained 

vegetative filter strip. The agricultural products should not be applied by ground 

equipment within a distance of 25 ft, or by aerial equipment within a distance of 150 ft, 

or by ULV within a distance of 450 ft from freshwater or estuarine1 marine bodie$ of 

water (e.g. lakes, reservoirs, rivers, permanent streams, marshes or natural ponds, 

estuaries and commercial fish farm ponds). 

For corn, granular formulations are available that may be applied as a band, T-band or in 

furrow applications, soil incorporated (it appears that the minimum incorporation depth is 

PHI (days) 

0 

3 

7 

7 

7 

14 

7 

0 

N/A 

APPLI~. 

METHOD 

G, A 

G, A 

G, A 

G, A 

G, A 

G, A 

G, A, LJLV 

G, A, ULV 

Seed1 

Treatment 

INTERVAL 

BETWEEN 

APPS. (days) 

NIA 

14 

14 

NIA 

14 

NIA 

5 

5 

NIA 

SEASONAL 

APP. RATE 

(Ibs. a.i./A) 

0.05 

0.1 

0.05 

0.125 

0.022 

0.044 

0.022 

0.175 

0.089 

-0.0125 

NUMBER 

OF APPS. 

1 

4 

1 

5 

1 

2 

1 

8 

4 

1 

labels. 

USE 

Citrus** calamondin, citrus citron, citrus 

hybrlds (includes chlronja, tangelo), 

grapefruit, kumquat, lemon, lime, mandarin 

(tangerine), orange, pummelo, satsuma 

mandarin, white sapote and other cultivars 

and/or hybrids of these 

**California and Arizona, only. 

Grape: table grape, raisin, wine and 

muscadine grape/ 

For the product LEVERAGE@ 360 

HOP 

Pome Fruit: apple, crabapple, loquat, 

mayhaw, pear, Oriental pear, quince 

Stone Fruit: apricot, cherry, nectarine, 

peach, plum, plumcot, prune (fiesh and 

dried) 

Tree Nut Crops: almond, beechnut, Brazil 

nut, butternut, cashew, chestnut, chinquapin, 

filbert, hickory nut, macadamia nut, pecan, 

pistachio, walnut (black and English) 

Alfalfa 

Grass (pasture, rangeland, grass for seed, 

grass for hay, grass in mixed-stands with 

alfalfa) 

Sugar beet, seed .treatment 

SINGLE 

APP. RATE 

(Ibs. a.i./A) 

0.05 

0.025 

0.05 

0.025 

0.022 

0.022 

0.022 

0.022 

0.044 per 

cutting 

0.0221 app. 

0.0221 

cutting 

-0.0125 
1 inch). The buffer zone is 60 ft from adjacent bodies of water. The granular 

formulations also contain 0-12-(1,l -Dimethylethyl)-5-pyrimidinyll-0-ethyl 0-(1- 

methylethyl) phosphorothioate, an organophosphate insecticide, commonly named 

phostebupirim. Cyfluthrin and beta-cyfluthrin may be co-formulated with imidacloprid, 

in the products LEVERAGE@ 2.7 Suspension Emulsifiable Insecticide and 

LEVERAGE@ 360 Insecticide. For beta-cyfluthrin, the product PONCHO@ BETA is 

coforrnulated with chlothianidin, for the use on sugar beet seeds. 

The Label Use Information System (LUIS report) & UsageILabel Use Reports for 

cyfluthrin (provided by BEAD) was based on a partial listing of labels, due to the large 

number of labels available for review; use data is not based on an exhaustive review of 

the entire population of labels. Section 3 labels or major producers' labels, along with all 

State and Local Needs (SLNs) labels, are included in the LUIS report. These data 

represent the major uses of this chemical. For beta-cyfluthrin, all labels were included in 

the LUIS report. 

The usage of cyfluthrin, from the Screening Level Usage Analysis (SLUA),is provided in 

Table 3.3. The table is arranged in alphabetical order of crops. According to the table, 

the major agricultural uses for cyfluthrin, crops for which 5000 or more pounds active 

ingredient are applied, are alfalfa, corn, cotton, soybeans, potatoes, oranges and sweet 

corn. For cotton and corn, for which the pounds applied are 60,000 and 30,000, 

respectively, the average percent crop treated is 5, and maximum percent crop treated are 

moderately low (10-15%). The crop for which the percent crop treated is the highest is 

potatoes, for which these percentages may reach moderately high values (25 and 35%, for 

the average and maximum, respectively). 

Table 3.3. Screening-Level Estimates of Agricultural Uses of Cyfluthrin (SLUA, 

dated 09/28/09). 

Crop 

Alfalfa 

Apples 

Artichokes 

Beans, Green 

Broccoli 

Cabbage 

Cantaloupes 

Carrots 

Cauliflower 

Celery 

Cherries 

Corn 

Cotton 

Cucumbers 

lbs a.i. 

10,000 

<500 

<500 

-400 

<500 

<500 

-400 

<SO0 

<SO0 

<500 

<500 

30,000 

60,000 

<SO0 

Percent Crop 

Avg. 

<2.5 

<2.5 

<1 

<2.5 

<2.5 

5 

<2.5 

10 

5 

<2.5 

<2.5 

5 

5 

< 1 

Treated 

Max. 

5 

5 

<2.5 

5 

<2.5 

15 

<2.5 

25 

10 

<2.5 

<2.5 

10 

15 

<2.5 
There is no similar SLUA for beta-cyfluthrin. According to the LUIS report, no usage 

Table 3.3. Screening-Level Estimates of Agricultural Uses of Cyfluthrin (SLUA, 

dated 09/28/09). 

Crop 

Dry Beans/Peas 

Grapefruit 

Grapes 

Hazelnuts (Filberts) 

Lemons 

Lettuce 

Onions + 

Oranges 

Peaches 

Peanuts 

Pears 

Pecans 

Peppers 

Pistachios 

Potatoes 

Pumpkins 

Rice 

Sod (NPUD '02) + 

Sorghum 

Soybeans 

Spinach 

Squash 

Sugarcane 

Sunflowers 

Sweet Corn 

Tobacco 

Tomatoes 

Watermelons 

Wheat 

All numbers are rounded. '<500t 

than 2.5 percent of crop is treated. 

to be listed on active end use product registrations or as Section 18 emergency exemptions when the report 

was run. The sources of the SLUA include the USDA-NASS, Private Pesticide Market Research, the 

National Pesticide Use Database (NPUD 2002) of the CropLife America Foundation and California 

Department of Pesticide Regulation (CDPR) data. The information reflects amalgamated data developed 

by the Agency and are in a releasable format. 

lbs a.i. 

<500 

<500 

<500 

-300 

<500 

1,000 

GOO 

5,000 

<500 

1,000 

GOO 

<500 

1,000 

GOO 

10,000 

<500 

<500 

<500 

2,000 

7,000 

<5~00 

<500 

1,000 

1,000 

6,000 

400 

2,000 

<500 

2,000 

indicates less than 500 

'<I' indicates less than 1 

Percent Crop 

Avg. 

< 1 

<2.5 

< 1 

20 

5 

5 

<1 

5 

<I 

5 

<2.5 

<1 

15 

5 

25 

<2.5 

< 1 

5 

< 1 

< 1 

5 

5 

<2.5 

<2.5 

10 

<1 

5 

< 1 

< 1 

pounds of active ingredient. 

percent of crop is treated. 

Treated 

Max. 

<2.5 

5 

<2.5 

25 

15 

10 

<2.5 

15 

<2.5 

lQ 

<2.5 

<2.5 

25 

15 

3 5 

<2.5 

<2.5 

N/C 

<2.5 

<2.5 

5 

10 

5 

5 

25 

<2.5 

10 

4.5 

4.5 

'<2.5' indicates less 

'+' Crops r~ot known 
data was found for this chemical (as of January 2010). 

The U.S. Geological Survey (USGS) pesticide agricultural use maps (Fig. 3.1) show 

regional scale patterns in use intensity within the United States. The USGS pesticide 

maps are based on State level estimates of pesticide use rates for individual crops, which 

have been compiled by the National Center for Food and Agricultural Policy (NCFAP) 

for 1999 through 2004, and on the 2002 Census of Agriculture for county crop acreage 

crop. According to the map, the major agricultural use for cyfluthrin is cotton with 

46.96% of the use, followed by corn, alfalfa hay and potatoes with 6.72-19.41% of the 

use. Other crops with >1% of the use included sweet corn, citrus hits, tomatoes, 

sorghum and lettuce. One crop, with reported percent of the use 4% is sunflower seed. 

As expected, there is a general agreement between the SLUA and the USGS map. The 

map shows a generalized use of cyfluthrin for agricultural purposes throughout the 

country, with highest uses in the cornbelt and the cotton belt. It also shows potential uses 

in estuarine1 marine regions of the US. Multiple agricultural uses are approved for 

cyfluthrin, other than the ones in the map, as indicated above in the Table 3.2a. 

At the present time, there is no similar agricultural map for beta-cyfluthrin. 
CYFLUTHRIN - insecticide 

2002 estimated annual aglrioultural use 

A"z3 

(pounds per st 

Q 

noastimated use 

C] 0.Wl to 0.003 

0.004 t~ 0.01 

0.01 1 to 0.025 

0.026 to 0.057 

1 >=0.058 

p annual use of 

ve ingredient 

quare mile of agricuttural 

alfalfa hay 

citrus f Iit 

sorghum 

sunfiwver seed 

nd in own&) rrlrrtlt 

pYy..yo Y,.r-J natiil use 

68061 46.96 

281 25 19.41 

19613 1853 

9794 6.72 

6862 4.74 

4343 3.00 

3399 2.3s 

21 27 1 A7 

1553 1.07 

395 027 

Total *-.^all 1 

CrODS MIA= m&r 

Fig. 3.1. Estimated Use of Cyfluthrin in 2002 

In addition to the classical agricultural use sites, cyfluthrin and beta-cyfluthrin have 

multiple other uses. Cyfluthrin and beta-cyfluthrin may be used in multiple urb 

environments. Many of these uses are classified as outdoor residential such as 

"P 

ornamental lawns and turf, recreation area lawns, ornamental andl or shade trees, 

Note of Caution: The pestlcide use maps available (hM, ) show the 

average annual pestlcide use Intensity expressed as average welght (in pounds) of a pestlcide applled to each square mlle of agric ltural land In 

a county The area of each map m based on state-level estimates of pesticide use rates for md~vidual crops that were compiled bjthe CropLife 

Foundation, Crop Protection Research Inshtute dunng based on information collected dunng 1999 through 2004 and on 2 2 Census of 

Agriculture county crop acreage The maps do not represent a specific year, but rather show typical use patterns over the five ye period 1999 

through 2004 Use Intensity rates are expressed as the pounds applied per square mile of mapped agncultural land in a coun The area of 

mapped agncultural land for each county was obtamed fram an enhanced version of the 1992 USGS National Land Cover Data NLCD) The 

key llmitatlons of the data used to produce these maps Include the following (1) state use coefficients represent an average fort f e enhre state 

and consequently do not reflect the local variability of pestic~de management prachces found withln states and counties, (2) 'pesticide use 

estimates are not for a specific year, but represent typical use patterns for the five year period, (3) state pesticide use coefficients Lay not have 

ornamental herbaceous plants, ornamental woody shrubs and vines, paths1 patios, paved 

areas (private roads1 sidewalks), pet living1 sleeping quarters, and residential laws. 

Tables 3.4a and 3.4b provide a summary of the terrestrial nonagricultural use sit$s for 

cyfluthrin and beta-cyfluthrin, respectively. Application methods vary. Many of these 

uses could involve substantive exposure to wildlife, specifically, aquatic organisms, and 

been available for all states where a pesticide may have been applied to agricultural land, and therefore, are not d~splayed on the 

county crop acreage is based on the 2002 Census of Agriculture and may not represent all crop acreage because of Census 

and (5) agncultural land area used to calculate the pesticide use mtensity and dlsplay the data was denved fiom 30-meter 

senslng data that may over esbmate or underestimate the actual agncultural land area The maps are not Intended for makuig 

estimates of pesticide use, such as estimates at the county level Please refer to Method for Estimating Pesticide Use for a detailed 

how the pestlcide use data were developed 

maps, (4) the 

nondi~closure rules, 

satellite remote 

local-scale 

discussion of 

I 
they will be assessed accordingly (e.g., commercial/ industrial lawns, residential lawn, 

golf course turf, ornamental lawns and turf, recreation areas and residential lawns). (Note 

that there are fewer non-food uses for beta-cyfluthrin than for cyfluthrin.) Another use 

that will be evaluated is wood protection treatment (outdoors). 
In addition, there are several other indoor non-food or indoor residential use sites for both 

cyfluthrin and beta-cyfluthrin, like for example, commercial/institutional/industrial 

premiseslequipment (indoor), dairieslcheese processing plant premises (nonfood contact), 

eating establishments, food processing plant premises (nonfood contact), food stores1 

markets1 supermarkets premises, hospitals1 medical institutions premises and household/ 

domestic dwellings. Cyfluthrin and beta-cyfluthrin also have greenhouse uses. 

Table 3.4b. Uses Classified as Non-Food or Outdoor for Beta-cyfluthrin 

For the indoor uses, the Division has conducted environmental risk assessments for a few 

chemicals for Re-registration Eligibility Decisions. In an open literature study (weston 

and Lydy 201 O), several synthetic pyrethroids were observed in effluents after secondary 

treatment from POTWs in the Sacramento-San Joaquin Delta. In the study, bifenthrin 

was the most frequently detected pyrethroid. Cyfluthrin was found in 6% of the 

municipal wastewater treatment plant effluents (POTWs) tested in the Sacramento-San 

Joaquin Delta (1 8 samples), at a maximum concentration of 1.7 ngIL, and it exceeded the 

Hyalella azteca ECso of 1.9 ngL in 0% of the samples. This study indicates therd is a 

potential for synthetic pyrethroids to reach surface waters via exposure from 

contaminated drains, and even after treatment in plants (for further information about this 

study, see Section 3.4). The EFED will evaluate the potential for exposure to aqQatic 

organisms from the various indoor uses of cyfluthrin and beta-cyfluthrin (see also further 

information below). 

Toxicity data on environmental mixtures of cyfluthrin or beta-cyfluthrin with othtr 

pesticides may be presented, if available, as part of the ecological risk assessment. It is 

expected that the toxic effect of cyfluthrin or beta-cyfluthrin, in combination with other 

pesticides used in the environment, is likely to be a function of many factors incl4ding 

but not necessarily limited to: (1) the exposed species, (2) the co-contaminants inthe 

mixture, (3) the ratio of cyfluthrin or beta-cyfluthrin and co-contaminant concentkations, 

(4) differences in the pattern and duration of exposure among contaminants, and (5) the 

differential effects of other physical1 chemical characteristics of the receiving waters (e.g. 

organic matter present in sediment and suspended water). Quantitatively predicting the 

NS = Not Specified; AN =As Needed, cc = crop cycle. Data obtained from LUIS Report. 

Max. App. 

Rate per 

Year 

NS 

NS 

NS 

NS 

NS 

NS 

NS 

NS 

NS 

NS 

NS 

0.0022 1b/ cc 

NS 

Max. No. 

AppsJ Year 

NS 

NS 

NS 

NS 

61 1 yr 

NS 

NS 

NS 

NS 

61 1 yr 

6/ 1 yr, NS 

11 cc 

NS 

Use 

householdidomestic dwellings outdoor premises 

ornamental andlor shade trees 

ornamental ground cover 

ornamental herbaceous plants 

ornamental lawns and turf 

ornamental woody shrubs and vines 

paved areas (private roadslsidewalks) 

recreation area lawns 

residential lawns 

wood protection treatment to buildingslproducts outdoor 

Min. App. 

IntJ days 

NS, 7 

NS, 7, 14,30, 

AN 

NS, 7 

NS, 7, 14, AN 

NS, AN 

NS, 7, 14 

NS, 7, 14 

NS, 7 

NS 

AN 

7, NS, AN 

NS 

7, NS 

Max. App. Rate/ 

units 

0 0042 lb 1K sq ft 

0.0015 lb 1K sq ft 

0.0015 lb 1K sq ft 

0.0015 lb 1K sq ft 

0.0022 lb 1K sq ft 

0 0015 lb 1K sq ft 

0 0015 Ib 1K sq ft 

0 0044 Ib 1K sq ft 

Not specified, RTU 

formulation 

0.0022 lb 1K sq ft 

0.0022 lb 1K sq ft 

0.0022 lblA 

NS, various 

formulations 
combined effects of all these variables on mixture toxicity to any given taxa with 

confidence is beyond the capabilities of the available data and methodologies. However, 

a qualitative discussion of implications of the available pesticide mixture effects data 

regarding the confidence of risk assessment conclusions will be addressed as part of the 

uncertainty analysis. 

Piperonyl butoxide (PBO) and MGK-264 are commonly used in formulations with 

pyrethroids. PBO acts as a potentiator in both mammals and insects because the 

pyrethroid is not metabolized and excreted as quickly in its presence (Barile 2004; 

Hodgson & Smart 200 1). Exposure to pyrethroids along with PBO increases the toxicity 

of the pyrethroids (Amweg & Weston 2007; Weston & Lydy 2010). MGK-264, another 

potentiatorlsynergist used with pyrethroids, has similar effects as those observed for 

piperonyl butoxide (Hodgson & Smart 2001). 

A total of 4 current product registrations exist for cyfluthrin formulations with PBO: 

Cyfluthrin, PBO and Pyrethrins: # 279-3404, #499-462, #9444-183, #9444-226 

Beta-cyfluthrin is not co-formulated with PBO or MGK in any currently active 

registrations. 

The Agency routinely assesses potential exposure to formulations by examining acute 

exposure due to spray drift or direct applications to water and comparing the estimated 

exposure to available acute toxicity data on the formulation. The spray drift associated 

with the cyfluthrin uses containing synergists will be minimal, as all cyfluthrin products 

with PBO or MGK are registered for residential or structural uses only. Therefore, a 

quantitative assessment of the potential aquatic exposure to the formulation containing 

MGK synergists will not be conducted. Piperonyl butoxide andlor MGK-264 from other 

pyrethroid applications (e.g. the application of an adulticide containing PBO), could 

interact with cyfluthrin and beta-cyfluthrin in the environment. Available literature data 

also suggest the potential for synergism in the environment (Amweg et al. 2006, Weston 

et al. 2006, Amweg & Weston 2007, and Brander et al. 2009). Therefore, potential 

interactions will be discussed qualitatively in the risk assessment. EPA is currently 

evaluating options on how to gather data on pyrethroid end use products co-formulated 

with a synergist. 

It is important to recognize that the active ingredient and the synergist have differing fate 

properties and therefore would be expected to occur in the environment at different times 

and at different concentrations than present in the end use product. Consequently, it is 

necessary to have toxicology data which allows the assessment of the level of synergy as 

the ratio of the pesticide and synergist vary in the environment. Datasets which allow the 

calculation of the 'pesticide-synergist interaction' are often not available. EFED 

recognizes the limitations inherent in this approach and is looking into the acquisition of 

data that would allow the evaluation of the effect of both synergist and active ingredient 

when present in the ecosystem. Evaluating the potential toxic effects of the synergist 

include evaluating ecological effects data generated using end-use products and the active 

ingredient in the presence of synergists, in addition to data for the active ingredient alone. 
At this time, EFED typically has data for individual active ingredients, as well as for the 

synergists alone, but few data are available from which to draw conclusions regarding the 

potential effect of the combination. As stated above, the Agency is evaluating its options 

for obtaining data appropriate for this type of evaluation. 

3.3. Environmental Fate and Transport 

The majority of the environmental fate studies for these chemicals were conducted with 

cyfluthrin, which comprises all eight isomers. The environmental fate properties of 

cyfluthrin and beta-cyfluthrin are expected to be similar to each other. [~hen~l-l~~lradiolabeled compound was utilized in most instances. 

A summary of environmental fatel transport properties for cyfluthrin and beta-cyfluthrin 

is included in Table 3.5. 
Table 3.5. Summary 

beta-cyfiwthrin. 

PARAMETER 

Hydrolysis Half-life 

bH 5,7,9, (25 OC)] 

Aqueous Photolysis Half-life 

(PH 5) 

Soil Photolysis Half-life 

Aerobic Soil Metabolism Halflife 

Anaerobic Soil Metabolism 

Half-life 

Aerobic Aquatic Metabolism 

Half-life 

Anaerobic Aquatic Metabolism 

Half-life 

Soil Partition Coefficient (Kd) 

Organic Carbon Partition 

Coefficient (Koc) 

For Cvfluthrin 

Soil Partition Coefficient O(d) 

Organic Carbon Partition 

Coefficient (Koc) 

For trans-DCVA 

Terrestrial Field Dissipation 

Half-life 

transport properties 

SOURCE 

MRD 00131493, 

00137539,45022101 

MRID 00149595, 

45022102 

MRID 00137543, 

00157043 

MRID 00131494 

MRID 00131494 

MRID, 46824101 

NA 

MRD 00131495, 

00137544,45022103 

MRID 43424901 

MRID. AN 259211, 

44822901,42794801 

of the environmental fate and 

VALUE(S) (units) 

Stable at pH 5, nearly stable at pH 7, 

tllz = 2 1 days at pH 9; major degradation 

product FPB-ald 

t112 = 4.5 days linear, 

tllz = 0 7 days nonlinear, 

degradation products: 

FPB-acid and FPB-ald 

tllz = 5 6 days; 

degradahon product FPB-ald 

L tl12 = 73 5 days 

SL tl12 = 94.8 days 

major degradate. FPB-acid 

tl12 -30 days, 

degradate FPB-acid declined 

tllz = 32 9 and 42 0 days for two German 

systems Degradates DCVA, FPB-acid and 

FPB-aid 

No Study Avalable 

Adsorption: 

Soil -c 

German LS 1116 124000 

US LS 1244 180300 

US CL 1321 118000 

German SiL 1793 73500 

Desorptiou: 

So11 Kd- --..AE 

GermanLS 1448 161000 

US LS 974 141000 

US CL 1307 117000 

German SiL 1705 69900 

Koc in rnLlgoc and & in mL/g 

Immobile to hardly mobile 

There is a linear relationship between the soil 

organic carbon content and the Kd values (? = 

0 92). 

Adsorption: 

Soil KE Kmc 

Sand ND ND 

Silty Clay 0 46 18 

Sandy Loam 0 16 19 

SandvLoam 0 54 48 

Desorption: 

Soil KF- KFS 

Sand ND ND 

Silty Clay 0 91 36 

Sandy Loam 0.36 44 

Sandy Loam 0 72 64 

ND = Not determined 

NC: tvz (in surface sod) = 18.1 days, was only 

detected in top 6 in soil layer 

- CA (Fresno) cotton site: t1,z reported to be 4 3 

days (using 0-7 day data, or 23 8 days if 0-14 

day data are used), cyfluthrin was not detected 

after day 29 post-treatment, residues remained 

in top 6 in soil layer, except for two individual 

samples. FPB-acld and DCVA were detected 

in this study 

AZ. FL, KS. GA. OR. MS, Canada: 

DTSO < 32 days 

of cyfluthrin and 

COMMENT 

Supplemental data shows that the 

half-life was 9 days in natural 

waters from the Rhine river Major 

product was FPB-acid Water's pH 

was 7 7-8 3 

Value obtained uslng natural 

sunlight 

Dark control corrected, using 

natural sunlight - 

Study lasted 60 days. 

(20 4 & 22 0 days for two Dutch 

systems, but the quality of these 

half-lives was considered very low ) 

Study is required. 

In supplemental studies, TLC data 

for cyfluthrin on six different soils 

were submitted Uslng the Helling 

and Turner mobility classification 

system, cyfluthrin was classified as 

immobile in the six test soils To 

help EFED develop a Kd input for 

modeling, the registrant later 

submitted a supplemental study to 

the Agency which contained a 

single Kd value for one soil of 810 

mL1g 

Prov~des information to partially 

fulfill the data requirement. 

Study 42794801 was screened only 

and a full review will be provided at 

a later time. 
Cyfluthrin and beta-cyfluthrin are Type I1 synthetic pyrethroids (they are cyano 

substituted in the alpha position. Cyfluthrin and beta-cyfluthrin have a 2,2- 

dichloroethenyl, and they are 2,2-dimethyl substituted in the cyclopropane ring. The 

database for cyfluthrin has been used as a surrogate fate database for beta-cyfluthrin 

since they are structurally related. Even though they are Type I1 pyrethroids that 

characteristically show more stability to photolysis, submitted laboratory data suggest 

that the primary routes of dissipation are aqueous and soil photolysis (4.5 and 5.6 days, 

respectively) and hydrolysis in alkaline media (2.1 days). Cyfluthrin and beta-cyfluthrin 

are moderately persistent in the environment and immobile (aerobic soil metabolism 

73.5-94.8 days, aerobic aquatic metabolism 32.9-42 days). The terrestrial field 

dissipation data confirm the pattern observed in the laboratory studies with half-lives and 

~~~0's in the range of 18-32 days, which would indicate that the chemical follows mix 

routes of dissipation in the field. The Koc7s ranged fi-om -73,000-1 80,000 mL/gac, 

indicating low mobility. Like other pyrethroids, cyfluthrin and beta-cyfluthrin bihd 

strongly to soils suggesting a low potential to leach to subsurfaces and to contaminate 

groundwater. The moderate persistence of the chemical, the high soil affinity and very 

low solubility indicate that the chemicals have a high potential to reach surface waters in 

moff events accompanied by erosion occurring during periods of weeks to months after 

application. Residues could also reach surface waters via spray drift. Once the chemicals 

reach surface waters, there is potential impact to water quality, which appears to be 

mostly due to parent compound. The fate of cyfluthrin in anaerobic environments is 

uncertain. Cyfluthrin and beta-cyfluthrin are likely to partition with sediments in bodies 

of water. Since cyfluthrin may be applied repeatedly, the material may build up in 

sediments and affect benthic communities. Cyfluthrin and beta-cyfluthrin are moderately 

bioaccumulative with moderately rapid rates of depuration (estimated half-depuration 

time 13 days). Major metabolites observed in laboratory studies include cis- and transDCVA, FPB-acid and FPB-ald (Table 3.1~). These compounds result fiom the 

hydrolysis of the ester bond of the parent compounds. 

Table 3.5. Summary of the environmental fate and transport properties of cyfluthrin and 

beta-cyfluthrin. 

Transport 

The potential impact to water quality fiom the use of cyfluthrin appears to be mostly due 

to the parent compound. Laboratory studies show that cyfluthrin is moderately persistent 

under most environmental conditions making the compound available for runoff. 

Although the potential for mobility appears low, the likely means of cyfluthrin movement 

fi-om a crop site to an adjacent body of water would be runoff accompanied by erosion, as 

well as spray drift. Laboratory studies predict that once the chemical reaches surface 

waters, it may persist for moderate periods of time (relatively stable at pH 7). Even 

though cyfluthrin undergoes photolysis in water, its lypophilicity and affinity with 

particulate should make it unavailable to photolysis in a short period. In addition, 

COMMENT 

- 

SOURCE 

MRID. 00143143 

PARAMETER 

Bioaccumulation in Fish 

(BCF) 

VALUE(S) (units) 

Maximum BCF=854X for whole fish, with 

moderate depuration. The only major residue 

was the parent. The depuration time appears 

to be 4 days. 
photolysis will be limited only to clear shallow waters or the upper layers of the water 

column. Cyfluthrin does not seem to be a significant threat to ground water quality under 

most conditions. While laboratory conditions show that cyfluthrin is moderately 

persistent, the very low mobility observed in the laboratory reduces substantially the 

concern that there would be a potential of the compound to reach ground water. Some 

supplemental studies indicate that the potential degradates cis- and trans-DCVA could 

leach to ground waters. Conclusions with respect to the mobility of these degradates are 

limited by the available data. 

Degradation and Metabolism 

The hydrolysis of cyfluthrin was pH dependent. It was fast in alkaline media (stable, 

essentially stable and 2.1 days at pH's 5, 7 and 9 respectively). In a supplemental study 

conducted on filtered Rhine River water (pH 7.7-8.3), in the dark, cyfluthrin hydrolyzed/ 

degraded with a half-life of 9 days. An important route of dissipation for this chemical 

may be aqueous photolysis with a non-linear half-life of 0.7 days/ linear 4.5 days in an 

aqueous solution under natural sunlight. The major degradates were FPB-acid (4-fluoro3-phenoxybenzoic acid) and FPB-ald (4-fluoro-3-phenoxybenzaldehyde). Soil 

photodegradation may also be an important route of dissipation for cyfluthrin and betacyfluthrin. In soil, photodegradation followed a half-life of 5.6 days (dark control 

corrected). The only phenyl-labeled degradate was FPB-ald (up to 8% of the applied). It 

is assumed that the degradate DCVA 13-(2,2-dichloroviny1)-2,2-dimethylcyclopropanecarboxylic acid] is formed in the hydrolysis and the aqueous photolysis 

studies. DCVA is stable to hydrolysis at pH's 4,7 and 9 (European Commission, 

Appendix 2). 

The aerobic soil metabolism appears to play a lesser role in the dissipation of cyfluthrin 

with half-lives in a loam soil and a sandy loam soil, of 73.5 and 94.8 days, respectively. 

There was some formation of carbon dioxide and the only fluoro-phenyl degradate 

detected at appreciable amounts was FPB-acid (7% of the applied). In an anaerobic soil 

metabolism study, using aged loam, flooded and purged with nitrogen and based on two 

points, a half-life of around 30 days was obtained. Two degradates detected at the end of 

the initial aerobic incubation, FPB-acid and cyfluthrin-amide (minor degradate), declined 

during the anaerobic phase. The degradate DCVA was identified in a 100-day aerobic 

soil metabolism study at >lo% of the applied, as indicated by the European Commission 

(Appendix 2). In aerobic soil metabolism studies at 25OC at 40% MWHC, the DT50 

range for DCVA was 12-62 days (mean 24 days, median 16 days, 2 soils, 4 isomers). It 

is indicated that DTSOFPJ~~~~~ < DT50DCVA. 

In aerobic aquatic metabolism studies, conducted on beta-cyfluthrin, based on first order 

linear regression analysis, the half-lives of cyfluthrin in the total systems were 32.9 and 

42.0 days for two German systems, and 20.4 and 22.0 days for two Dutch systems. The 

quality of the results of the Dutch systems is regarded as low, and those half-lives should 

not be used for modeling. Three degradates were identified in the aerobic aquatic 

systems. In the German systems, DCVA was a maximum of 47.63% at 28 days. In the 

Dutch systems, FPB acid was a maximum of 44.5% at 11 days, and FPB-ald) was a 

maximum of 15.7% at 1 day. No anaerobic aquatic metabolism studies are available at 
this time. 

Sorption and Mobility 

Cyfluthrin is hydrophobic and was hardly mobile to immobile in four soils (Kd range 

11 16 to 1793 mL1g; Koc range 73,000 to 180,000 mL/goc; measurements made at single 

concentrations, FA0 mobility classification, FA0 2000). The chemical will bind 

strongly to the soil surfaces. There was a linear relationship between the soil organic 

carbon content and cyfluthrin Kd values (r2 = 0.92). The soils included German loamy 

sand and silty loam, and US loamy sand and clay loam. At least, some of the degradates 

formed from the cleavage of the carboxylate ester are expected to be more mobile than 

the parent. Supplemental data available to the Agency, indicates that the degradate 

DCVA is mobile to moderately mobile in neutral to alkaline soils (Koc range 14 to 356 

mL/goc, FA0 mobility classification). 

Even though cyfluthrin may be applied aerially, by ground or ULV, and drift is possible, 

the chemical appears to be relatively non-volatile (vapor pressure 1.5 x 10" mmHg, 

Henry's Law Constant 3.7 x 1 o-~ atm-m3/mol). Furthermore, cyfluthrin readily binds to 

soils or partitions with suspended matter and sediment. Thus, volatilization would be 

greatly reduced. 

Field Dissipation 

Cyfluthrin, applied on Fairmont, NC sandy soil (sand 90.8%, depth 0-6 inches, 0133% 

OM), cropped with cotton, at a rate of 0.55 lb a.i./A, dissipated from the field with a halflife of 18 days (r2 = 0.94, n = 8), or with a DTso of <32 days. Residues were detected 

only in the top 6" soil layer. No residues were detected below the top 6" of soil diepth 

(sandy loam, 0.33% OM). There were two single detects of C12CA (10.012 uglg)~ and 

eight, mostly single detects of FPBA (50.016 uglg). All values were close to the 

analytical detection limits. Cyfluthrin dissipated fiom a cotton site in Fresno, California 

with a registrant-reported half-life of 4.3 days (using 0-7 day data; or 23.8 days if 0-14 

day data are used, but the data point for 14 days was higher than for 7 days). Cyfluthrin 

was not detected after day 29 post-treatment. The DTS0 was ca. 3 days. Residues 

remained in top 6 in soil layer, except for two individual samples. FPBA and DCYA 

were detected in this study. This study was screened only, but a full review will be 

conducted at a later time. 

In other terrestrial field dissipation studies, in AZ, FL, KS, GAY OR, MS and Canada 

different soils, with different organic matter content showed that cyfluthrin (in thd form 

of Baythroid 24% EC), sprayed at 1 kg a.i./ha dissipated with DTSO's of <32 days, In 

these studies, soil sampling intervals, spaced by 30-32 days were inadequate and 

prevented accurate half-life calculations. Besides the parent, residues of DCVA and 

FPB-acid were detected in some studies. Cyfluthrin was detected in the 6-12" cores at 

levels less than 0.13 mg/Kg in five out of the seven studies. 

Bioaccumulation 

Based on the octanoll water partition coefficient, cyfluthrin shows a high potential to 

bioaccumulate (I(Ow = 9.33 x lo5). The bioconcentration factor in whole rainbow trout 
was moderate (854x, whole fish). Residues were depurated at moderately rapid rates in 

untreated water (apparent depuration half-life of approximately 53 days). Accumulated 

residues were found mostly in non-edible tissues, and the only residue detected at high 

levels was the parent compound. 

Transformation Products 

The fate and transport characterization is also summarized for the various degradation 

products formed by each process for the studies reviewed in Table 3.6. 

Major degradates identified in laboratory studies are FPB-acid, FPB-ald and DCVA 

result from the rupture of the ester linkage of the synthetic pyrethroid. FPB-acid was 

identified in the aqueous photolysis, aerobic soil metabolism, and anaerobic soil 

metabolism studies at 10-37% of the applied at 10-30 days after treatment. FPB-ald was 

observed at significant amounts in photolysisl photodegradation studies at 18% of the 

applied of the applied (5-7 days posttreatment) and in hydrolysis studies (up to 89% of 

the applied at pH 9, but only 11% at pH 7). DCVA was identified in supplemental 

aerobic soil metabolism studies (>lo% of the applied). The degradate DCVA was also 

identified in field studies at up to 0.16 mg/Kg. 

Table 3.6. Summary of degradate formation from degradation of cyfluthrin. 

There is uncertainty with respect to the available data on the cyclopropane side of the 

ester linkage and cold analyses were not performed on the possible degradates resulting 

from the rupture of this linkage. There is evidence of the formation of DCVA, but there 

is no further information on the possible degradation pathways. There are limited data 

about the mobility and persistence of FPB-ald, FPB-acid and DCVA. While it appears 

that DCVA is much more mobile than the parent compound and has the potential to reach 

ground waters in vulnerable sites, there are limited data about its mobility. DCVA has 

been detected in laboratory studies at >lo% of the applied. 

STUDY TYPE 

Hydrolysis 

Aqueous Photolysis 

Soil Photolysis 

Aerobic Soil Metabolism 

Anaerobic Soil Metabolism 

Aerobic Aquatic Metabolism 

Terrestrial Field Dissipation 

Uncertainties 

The environmental fate database for parent cyfluthrin and beta-cyfluthrin was previously 

considered adequate to perform a screening level assessment of the chemical. However, 

the following uncertainties were noted. There is uncertainty related to the anaerobic soil 

metabolism study. The half-life was very roughly estimated, based on two data points. 

SOURCE 

MRID 00131493, 

00137539,45022101 

MRID: 00149595, 

45022101,45022102 

MRID: 00137543, 

00157043 

MRID 00131494 

MRID. 00131494 

MRID: 46824101 

MRID AN 25921 1, 

42794801,44822901 

DEGRADATE and MAXIMUM CONCENTRATION 

F-PB-acid (% app) 

- 

37% at day 14 

- 

10% at 10 days 

10% at 30 days of 

aerobic mcubation 

(time of flooding) 

44 5% at 11 days 

10.07 mgKg in the 0- 

6" cores 

I?-PB-ald (% app) 

11% at 35 days at pH 

7,89% at 21 days at 

pH 9 

18% at day 7 

18% at days 5-6 

- 

- 

15 7% at 1 day - 

DCVA (% app) 

- 

- 

- 

>lo% in 100-day 

studies - 

47.63% at 28 days 

0 16 mg/Kg at 30 days 
Also, the fate of cyfluthrin in anaerobic aquatic environments is uncertain. 

Studies using radiolabeling on the cyclopropane side of the ester linkage were not 

conducted and cold analyses were not performed. Consequently, there were no analyses 

for potential cyclopropane containing degradates that may have originated from the 

cleavage of the carboxylate ester linkage, such as DCVA. At this time, most of the data 

available are on the fluorophenyl ring only. 

EFED has limited data about the environmental fate (mobility and persistence) of 

degradates of cyfluthrin, FPB-ald, FPB-acid, cyfluthrin amide, and cis/ trans-DCVA. 

The limited data available indicate that DCVA is mobile to moderately mobile and has 

the potential to reach ground waters in vulnerable sites. However, this potential would be 

limited by the amounts of DCVA produced in the soils because cyfluthrin degrades 

slowly. It appears that DCVA is not highly toxic to mammals (communication with 

Carol Christensen, Health Effects Division, 07/01/2004). As part of the risk assessment, 

the EFED will conduct an ECOTOX search for information about the possible toxicity of 

the degradates of cyfluthrin as it will be further indicated below. 

The mobility (batch equilibrium) data available for cyfluthrin was obtained at a single 

concentration. EFED has available Kd and Koc values, but no Freundlich KF and KFoC 

values (no isotherms available). 

4. Receptors 

4.1. Aquatic and Terrestrial Effects 

The receptor is the biological entity that is exposed to the stressor (EPA, 1998). Due to 

the outdoor uses of cyfluthrin and beta-cyfluthrin, the types of receptors that may be 

exposed include both aquatic and terrestrial receptors, such as birds, reptiles, mammals, 

amphibians, freshwater and estuarinelmarine fish, non-target terrestrial & aquatic 

invertebrates and terrestrial & aquatic plants. This list may not be comprehensive. Spray 

drift and runoff exposures are expected for both ground and aerial applications of 

cyfluthrin. Consistent with the process described in the Overview Document (USEPA, 

2004), this risk assessment uses a surrogate species approach in its evaluation of 

cyfluthrin. Toxicological data generated from surrogate test species, which are intended 

to be representative of broad taxonomic groups, are used to extrapolate to potential 

effects on a variety of species (receptors) included under these taxonomic groupiqgs. 

Tables 4.1 and 4.2 provide a summary of the taxonomic groups and the surrogate; species 

tested to help understand potential acute ecological effects of pesticides to these nontarget taxonomic groups. In addition, the tables provide a preliminary overview of the 

potential acute toxicity of cyfluthrin and beta-cyfluthrin, by providing the acute tqxicity 

classifications. 

Terrestrial Species 
A summary of sensitive terrestrial toxicity data from registrant-submitted studies is 

provided in Table 4.1. Based on the available acute data, cyfluthrin is classified as 

practically nontoxic to birds, moderately toxic to mammals, and highly toxic to terrestrial 

invertebrates. Avian reproductive studies indicate reproductive effects at 250 mgkg diet 

(NOAEC<250 mglkg diet). A mammalian reproduction study with cyfluthrin showed 

adverse effects on pup body weight at 150 ppm (NOAEL=50 ppm). All endpoints are 

provided in terms of the active ingredient (ai) unless otherwise specified. 

Mammals 

Mammalian toxicity data suggest that this compound is moderately toxic to small 

mammals on an acute basis (rat LD50 400 mglkg bw and mouse LDso = 291 mglkg bw) 

(Accession #072008 and 004334). Reproductive effects were based on decreased pup 

bodyweight observed at a LOAEC of 150 ppm (NOAEC = 50 ppm) (Accession 

#072009). For mammalian toxicity in the final risk assessment, EFED will coordinate 

with HED to determine the most sensitive endpoints for acute and chronic studies. In an 

acute oral study conducted to examine beta-cyfluthrin effects on rats, the LD50=960 

mglkg bw (males) and LDS0=1 150 mgkg bw (females) (MRID 44251 101). Based on the 

submitted data, beta-cyfluthrin appears to have lower toxicity to mammals than 

cyfluthrin. 
Birds 

The available toxicity data suggests that cyfluthrin appears to be practically non-toxic on 

an acute basis to avian species based on a bobwhite quail (Colinus virginianus) single 

dose LDsO of >5000 mg/kg bw (0013 1498, acceptable) and an 8-day dietary LCs0 of 

>5000 mglkg diet for the bobwhite quail and mallard duck (Anas platyrynchos) 

(001 3 1500 and 001 3501, both acceptable). 

Reproductive tests with mallard ducks indicated effects at 250 mglkg diet (NOAEC <250 

mg/kg diet). In one test conducted with mallards, a high percentage of eggs cracked were 

observed at 250 mg/kg diet, the lowest level tested (MRID 00145331, supplemental). 

This effect was not seen at the higher treatment levels, however. Other adverse effects 

shown at the 1000 and 4000 mglkg diet levels include a reduction in the number of eggs 

laid, eggs set, fertilized eggs, 3-week viable embryos, hatchlings and 14-day survivors. 

Due to low control reproductive performance, including low embryo viability, hatchling 

number and 14-day survivorship, the results of this study are classified as supplemental. 

In another one-generation reproductive study conducted on mallard ducks, cyfluthrin 

statistically showed no adverse effects to reproduction at the highest concentration tested 

when compared to control birds (NOAEC = 250 mg/kg diet) (MRID 001 58782, 

supplemental). In this study, no statistical differences in reproductive parameters 

between the controls and treatments were determined at any concentration tested (10, 50 

and 250 mg/kg diet). Response variables examined include eggs laid, eggs cracked, eggs 

set, viable embryos, 3-week embryos, hatchlings and 14-day survivors per hen. 

Pathological results showed an increase in egg yolk peritonitis and regressing ovary at 

levels as low as 10 mglkg diet (lowest level tested). In this study, control bird 

reproduction appeared to be impaired, as indicated by a low number of eggs laid, embryo 

viability and hatching rate compared to guideline criteria. 

Two studies were submitted for bobwhite quail, yielding less sensitive reproductive 

endpoints than the mallard studies. The NOAEC = 900 and 1000 mg/kg diet, for MRIDs 

00152829 (acceptable) and 00145330 (supplemental), respectively. Effects observed 

include low body weight gain in males and low 14-day survivorship at 4000 mg/lQg diet 

level. 

Terrestrial Invertebrates 

Cyfluthrin is highly toxic to nontarget terrestrial invertebrates. A 48-hour acute contact 

study on honeybees (Apis mellifra) with cyfluthrin technical produced an LDso = 0.037 

pglbee (MRID 00153638, acceptable). A 10-day honey bee residual toxicity study with 

cyfluthrin 2 EC (Baythroid) indicated that the formulated product is also highly toxic to 

nontarget terrestrial invertebrates, with and ECso of 0.045 pglbee (MRID 00162586). 

Terrestrial Plants 

No terrestrial plant data have been submitted to the Agency for cyfluthrin. 
Table 4.1. 

and beta-cyfluthrin. 

Species 

(common 

name) 

Rattus 

nowegicus 

(Laboratory 

Rat) 

Mus musculus 

(Laboratory 

mouse) 

Rattus 

nowegicus 

(Laboratory 

Rat) 

Colinus 

virginianus 

(Bobwhite 

quail) 

Anas 

plutyqwzchos 

duck) 

and 

Colinus 

virginianus 

(Bobwhite 

quail) 

Anus 

plutyrynchos 

(Mallard duck) 

Apis mellifera 

(Honey bee) 

Original 

this time 

additional data evaluation. 

Data need additional review. Original reviews classified the study as acceptable, completed in 1984 by W. 

Summary of most 

Taxa 

Represented 

Mammals 

~irds, terrestrialphase 

amphibians, and 

reptiles 

Terrestrial 

invertebrates 

review classified the 

because a cursory 

sensitive endpoints 

Endpoint 

LD50 

LDso 

NOAEL 

LOAEL 

LDso 

LC50 

NOAEC 

LOAEC 

LD50 

study as 

review indicates 

from submitted 

Concentration 

Cyfluthrin: 400 

mgkg bw 

Beta-cvfluthrin: 960 

mgkg bw (male) 

1150 mgkg bw 

(female) 

29 1 mglkg bw (male) 

609 mgkg bw 

(female) 

50 PPm 

150 ppm 

>5000 mglkg bw 

>5000 mgkg diet 

<250 mglkg diet 

250 mgkg diet 

0.037 &bee 

acceptable, completed in 

that the study is acceptable, 

terrestrial 

Test 

Substance 

(% a.i.) 

tech 

tech 

tech 

87 

87 

94% 

93% 

1983 by W. 

but may 

toxicity studies for 

classificationnd 

Accession 

#072008 

Acceptable 

44251 101 

Acceptable 

Accession 

#004334 

Acceptable 

Accession 

#072009 

Acceptable 

0013 1498l 

00131500~ 

001315012 

0014533 l3 

Supplemental 

00153638 

Acceptable 

Faatz. Study not 

be required pending 

cytluthrin 

Acute 

Toxicity Classification 

Moderately 

toxic 

NA 

Practically 

non-toxic 

Practically 

non-toxic 

NA 

Highly toxic 

required at 
Faatz. Study not required at this time because a cursory review indicates that the study is acceptable, but 

may be required pending additional data evaluation. 

This endpoint is based on the most sensitive registrant-submitted study available. However, in this study, 

the endpoint is non-definitive. Another study conducted on mallard ducks with lower treatment 

concentrations (1 0-250 mgkg diet) showed no reproductive effects at any treatment levels. 

NA=not applicable 

Aquatic Species 

A summary-of sensitive aquatic toxicity data from registrant-submitted studies is 

provided in Table 4.2. Numerous aquatic studies have been submitted to the Agency, 

some of which were conducted with beta-cyfluthrin. Appendix B includes a table 

detailing all aquatic toxicity data submitted to the Agency. Cyfluthrin and betacyfluthrin are classified as very highly toxic to aquatic organisms based on data for 

aquatic vertebrates and invertebrates. Chronic effects were also seen in all aquatic taxa at 

levels ranging from 0.00040 - 0.63 pg a.i./L. 

Freshwater 

Cyfluthrin technical is highly toxic to freshwater fish, with a 96-hour LCso = 0.68 pg 

a.i./L (MRID 00 13 1502). Beta-cyfluthrin technical is also highly toxic to freshwater fish, 

with a 96-hour LCso = 0.068 pg a.i./L in the most sensitive acute test conducted om 

rainbow trout (Oncorhynchus mykiss) (MRID 45375002). In an acute test with cyMuthrin 

EC (2%), the 96-hour LCsO = 0.295 pg a.i./L for rainbow trout (MRID 41558002, 

supplemental). A freshwater fish early-life stage study for cyfluthrin technical reslulted in 

an NOAEC of 0.010 yg a.i./L and LOAEC of 0.018 pg a.i./L for rainbow trout b sed on 

reduced growth and behavioral effects (MRID 001 55898, supplemental). In a fis 1 full life 

cycle test with cyfluthrin, fathead minnow (Pimephalespromelas) showed reducqd 

survival and hatching success at 0.25 pg a.i./L, with a NOAEL = 0.14 pg a.i./L (MRID 

4 145040 1, acceptable). I I 

Daphnia magna is used as the test species for freshwater invertebrates for both adute and 

chronic effects. Acute toxicity values for daphnids suggest that cyfluthrin technic@l is 

very highly toxic to freshwater invertebrates, with a 48-hour ECso of 0.141 pg a.i//~ 

(MRID 001 3 1504). An acute 48-hour study examining beta-cyfluthrin technical dffects to 

daphnids produced an ECsO = 0.29 pg a.i./L (MRID 45426701). A 48-hour study 1 

conducted with the formulated product (Tempo, 25% a.i.) showed higher toxicity to 

daphnids, with an ECS0 of 0.025 (MRID 41558003). Chronic toxicity to invertebr I3 tes is 

represented through Daphnia magna life cycle studies. In a daphnid chronic life-qycle 

test with cyfluthrin, the NOAEC = 0.00174 pg/L and the LOAEC = 0.0157 pg/L based 

on adverse effects to growth, survival and # of young (MRID 00151442, accepta$e). In 

this study, cyfluthrin showed significant degradation, due to hydrolysis at the hig pH (8 

to 8.5). Based on results from thin layer chromatography analysis, it was determ' ed that 

approximately 37% of the total carbon-labelled residues were the parent compou ! d. 

Therefore, the mean-measured concentrations were adjusted to reflect the percendage of 

cyfluthrin in the final endpoint calculations (endpoints based on mean-measured I4c 

concentrations alone were NOAEC=0.020 pg/L and LOAEC=0.041 pg/L). 

For freshwater benthic organisms, a 10-day toxicity study with midges (Chironomus 
tentans) has been submitted (MRID 46591507, in review). Based on preliminary results 

from this study, cyfluthrin is very highly toxic to freshwater benthic organisms and the 

LC50=0.44 yg a.i./L based on mean-measured pore water concentrations and LC50=290 

pg a.i./kg sediment based on bulk sediment concentrations. 

EstuarinelMarine 

Estuarinelmarine fish are represented by the sheepshead minnow (Cyprinodon 

variegatus). Acute toxicity studies indicates that cyfluthrin is very highly toxic to 

estuarinelmarine fish, with an = 4.05 pg a.i./L for the technical material (MRID 

00146485, acceptable). The most sensitive sheepshead minnow early life stage study 

submitted by the registrant resulted in a 39-day NOAEC = 0.025 yg a.i./L and a LOAEC 

= 0.084 pg a.i./L, based on reduced juvenile survival. Another early life stage study has 

been submitted, yielding less sensitive endpoints based on treatment-related mortality 

(NOAEC=0.27 yg a.i.1L and LOAEC = 0.63 yg a.i./L) (MRID 00158784, this study is 

currently unreviewed). 

Estuarinelrnarine aquatic invertebrates are represented by the mysid shrimp (Mysidopsis 

bahia) and eastern oyster (Crassostrea virginica) with toxicity studies indicating 

cyfluthrin is very highly toxic to both. Cyfluthrin technical produced an LC50= 0.0024 

pg a.i./L in an acute toxicity study with mysid shrimp (MRID 40069501). In an acute 

study with mysid shrimp, the 96-hour LCso = 0.0022 yg a.i./L for beta-cyfluthrin 

technical (MRID 45426709, acceptable). In a study with the eastern oyster, the 96-hour 

EC50 was 2.69 pg a.i.1L for cyfluthrin technical (MRID 00158783, acceptable). A 

chronic study with estuarinelmarine invertebrates has also been submitted for cyfluthrin 

technical. In a 28-day life cycle study with mysid shrimp, the NOAEC = 0.00017 pg 

a.i./L and LOAEC = 0.00040 pg a.i./L based on adverse effects to growth and survival 

(MRID 001 58785, supplemental). This study was deemed supplemental due to 

fluctuations in the test concentrations throughout the study. 

Aquatic Plants 

A 96-hour toxicity test with the green algal species Scenedesmus subspicatus was 

submitted for cyfluthrin, but the test was determined to be invalid due to low test 

substance solubility and absence of analytically-determined concentrations (MRID 

41450402). Another study with green algae (Pseudokirchneriella subcapitata, formerly 

known as Selenastrum capricornutum) has been submitted for cyfluthrin (MRID 

43984901). The reported ECso > 181 yg a.i.1L and NOAEC = 181 yg a.i./L in this study, 

based on Day 0 soluble measured concentrations. No studies have been submitted for 

aquatic vascular plants. 

Toxicity of Degradates 

Four aquatic toxicity studies have been submitted for degradates of cyfluthrin, FPB ALD 

and DCVA. Both degradates appear to be less toxic than the parent compound based on 

acute toxicity studies with freshwater fish and invertebrates. Studies with rainbow trout 

resulted in a 96-hour = 792 yg a.i./L for FPB ALD and LC50>14.7 mg a.i./L for 

DCVA (MRIDs 00158554 and 00158557). Acute 48-hour studies with Daphnia magna 

resulted in an ECsO=l .3 mg a.i./L for FPB ALD and EC5~=25 mg a.i./L for DCVA 
(MRIDs 00158555 and 00158556). Therefore, the parent compound is expected to be the 

primary stressor of concern. 

for 

Acute 

Toxicity 

Classification 

Very highly 

toxic 

NA 

Very highly 

toxic 

NA 

I 

Very highly 

toxic 

Very highly 

toxic 

NA 

toxicity studies 

MRID 

study 

classification 

00 13 1502 

Acceptable 

45375002 

Supplemental 

00155898 

Supplemental 

00158783 

Acceptable 

41558003 

Acceptable 

45426701 

Supplemental 

00151442 

Acceptable 

46591507 

In review 

Oo 1464s5 

Acceptable 

00158781 

Supplemental 

submitted aquatic 

Mean 

concentration 

(pg a.i./L) 

Cyfluthrin: 

0.68 

BA 

Cyfluthrin: 

0.068 

0.010 

0.018 

2.69 

Cvfluthrin: 

0.025 

Betacyfluthrin: 

0.29 

0.0074 

0.0157 

0.44 (pore 

water) 

290 pg a.i.kg 

sediment 

(bulk 

sediment) 

4.05 

0.025 

0.084 

from 

Duration 

(hours) 

96 

58 (days) 

96 

48 

21 

(days) 

10 (days) 

96 

39 (days) 

sensitive endpoints 

Endpoint 

LC50 

NOAEC 

LOAEC 

EGO 

EC50 

NOAEC 

LO~C 

LC50 

LC50 

NOmC 

LOAEC 

Table 4.2. Summary 

cyfluthrin and 

Species 

(common name) 

Oncorhynchus 

mykiss 

(Rainbow trout) 

Crassostrea 

virginica 

(Eastern oyster) 

Daphnia magna 

(Water Flea) 

Chironomus tentans 

(Midge) 

Cyprinodon 

variegatus 

(Sheepshead 

minnow) 

of most 

beta-cyfluthrin 

Taxa 

Represented 

Freshwater 

fish and 

aquatic-phase 

amphibians 

Freshwater 

Invertebrates 

Freshwater 

Benthic 

Invertebrates 

Estuarine1 

Marine Fish 
ECOTOX 

Available open literature will be used to evaluate the potential direct effects of cyfluthrin 

and beta-cyfluthrin to the terrestrial receptors identified in this section. This includes 

toxicity data on the technical grade active ingredient, and when available, formulated 

products. 

Mysidopsis bahia 

(M~sid shrimp) 

Leptocheirus 

plurnulosus 

(Amphipod) 

Green algae 

(Pseudokirchneriella 

subcapita) 

At this time, a full and complete ECOTOX search has not been performed, but will be 

conducted prior to issuance of any Data Call-in. The open literature studies will be 

identified through EPA's ECOTOX database (htt~://cfpub.epa.qov/ecotox/), which 

employs a literature search engine for locating chemical toxicity data for aquatic life, 

terrestrial plants, and wildlife. The evaluation of data can also provide insight into the 

direct and indirect effects of cyfluthrin and beta-cyfluthrin 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. 

Open literature toxicity data for other 'target' insect species (not including bees, 

butterflies, beetles, and non-insect invertebrates including soil arthropods and worms), 

which include efficacy studies, are not currently considered in deriving the most sensitive 

IZstuarineI 

Marine 

Invertebrates 

Estuarine1 

Marine 

Benthic 

Invertebrates 

Aquatic 

plants 

Lcso 

NOAEC 

LOAEC 

LC50 

(survival) 

(growth) EGO 

ECso 

96 

28 (days) 

28 (days) 

96 

Cyfluthrin: 

0.0024 

cvfluthrin: 

0.0022 

0.00017 

0.00040 

35 

36 

>181 

40069501 

Acceptable 

45426709 

Acceptable 

00158785 

Supplemental 

46591506 

In review 

4398490 

Acceptable 

Very highly 

toxic 

NA 

Very highly 

toxic 

~ractically 

nontoxic 
endpoint for terrestrial insects. Efficacy studies do not typically provide endpoint values 

that are useful for risk assessment (e.g., NOAEC, EC50, etc.), but rather are intended to 

identify a dose that maximizes a particular effect (e.g., ECloo). Therefore, efficacy data 

and non-efficacy toxicological target insect data will not be included in the ECOTOX 

open literature search. 

4.2. Incident Database Review 

A preliminary review on May 20,2010 of the Ecological Incident Information System 

(EIIS, version 2. 1)' which is maintained by the Agency's Office of Pesticide Programs 

indicates reported ecological incidents associated with the use of cyfluthrin and betacyfluthrin. A search for incidents involving cyfluthrin and beta-cyfluthrin was also 

conducted in the American Bird Conservancy's Avian Incident Monitoring System 

(AIMS). These incidents are summarized in Table 4.3. This total excludes incidents 

classified as 'unlikely' and only includes those incidents with certainty categories of 

'highly probable', and 'probable' and 'possible' (for EIIS) and 'certain', 'highly likely', 

'likely', 'probable', and 'possible' (for AIMS). In the EIIS and AIMS databases, the 

"unlikely" category is used when a chemical is not likely to be responsible for the 

incident. For example, an 'unlikely' classification might be applied in situations where a 

given chemical is practically nontoxic to the category of organism killed and/ or there is 

evidence that another pesticide or stressor likely caused the incident. Incidents classified 

as 'unlikely' for cyfluthrin and beta-cyfluthrin will not be included in this Problem 

Formulation or the ecological risk assessment conducted for Registration Review. 

A total of eight reported ecological incidents associated with the use of cyfluthrin have 

been reported to the Agency. No incidents associated with beta-cyfluthrin were faund in 

the EIIS database. This is likely due to the fact that enantioselective methods are iequired 

for differentiating cyfluthrin and beta-cyfluthrin. Therefore, cyfluthrin incidents clannot 

be ruled out as possible beta-cyfluthrin incidents. 

Five incidents were reported for aquatic animals and three are reported for terrestl'ial 

plants. All incidents were reported between 1993 and 2005. Four of the incidents were 

associated with registered uses of cyfluthrin, two were associated with uses where it was 

undetermined if the use was a registered use, and two incidents were associated with 

misuse. The certainty that the incidents were associated with cyfluthrin exposure was 

considered highly probable for two incidents, probable for four incidents and posdible for 

two incidents. See Table 4.3 for summary of the incidents. 

The AIMS database contains no incidents involving cyfluthrin and beta-cyfluthrih. 

Table 4.3. Wildlife Incidents Associated with Cyfluthrin 1 

Residue 

Legality 

Use of Use 

Certaijty 

Magnitude Year category1 

Incident 

Number 

Location 

(County, 

State) 

Taxa 

Involved 
Table 4.3. 

Incident 

Number 

1004564- 

001 1 

1003621- 

Ool 

I00335 1- 

02 1 

I0 13927- 

00 1 

1009427- 

006 

I0 16940- 

010 

1001728- 

00 1 

1013550- 

002 

'~ncidents 

Wildlife 

Taxa 

Involved 

Koi fish 

(Cyprinus 

carpio) 

Bluegill 

(Lepomis 

macrochirus) 

Crayfish 

(Decapoda) 

and snail 

(Gastropods) 

Flathead 

catfish 

(Pylodictis 

oilvaris), 

grass carp 

(Ctenopharyn 

godon idella) 

and 

largemouth 

bass 

(Micropterus 

salmoides) 

Crayfish 

(Decapoda) 

Corn (Zea 

mays) 

Unknown 

ornamentals 

Potatoes 

classified as 

Incidents 

Magnitude 

5 

unknown 

hundreds 

400 

Unknown 

30 acres 

Unknown 

65 acres 

'unlikely' are 

Associated 

Year 

1996 

1996 

1994 

2003 

1999 

2005 

1993 

200 1 

excluded; 

with Cyfluthrin 

Location 

(County, 

State) 

CA 

Not 

reported 

Placer, 

CA 

Imperial, 

CA 

Madison, 

LA 

Imperial, 

CA 

WA 

Kent, DE 

RU = Registered 

Use 

Building 

Spray 

Not 

reported 

Not 

reported 

Agriculma1 

Aerial to 

cotton 

Aerial 

Commercial lawn 

Aerial 

Use; M = 

Legality 

of Use 

RU 

M 

UN 

UN 

RU 

RU 

RU 

Misuse; UN = 

Certainty 

category1 

Probable 

Probable 

Probable 

Probable 

Possible 

Highly 

probable 

Probable 

Possible 

Unknown 

Residue 

No 

No 

No 

220-390 

PP~ in 

gill 

tissue, 

0.33 

PP~ in 

water 

No 

0.15-7.2 

ppm in 

plant 

tissue 

Yes, 

levels 

not 

reported 

No 
Aquatic Incidents Involving CyJluthrin 

Incident # 1004564-001 - A fishkill in two ornamental ponds occurred due to cyfluthrin 

use in California in 1996. Cyfluthrin (TEMPO) dust was sprayed on the side of a 

building to control wasps. Around five days after application, approximately five koi 

fish (Cyprinus carpio) began to die in ponds 20-30 feet away. Water samples taken 20 

days after application contained 2 ppb cyfluthrin. No analyses were conducted on the 

fish tissues. This incident is listed as "highly probable" for a registered use of 

cyfluthrin. 

Incident # I00362 1-00 1 - After a heavy rainfall, cyfluthrin (Aztac 2.1 %) washed into a 

stream where hundreds of bluegill (Lepomis macrochirus) were subsequently killed. 

The incident occurred in 1996. No water or tissue samples were taken. This incident is 

listed as "probable" for an intentional misuse of cyfluthrin. 

Incident # I0033 5 1-02 1 - Cyfluthrin was the probable cause of the death of hundreds 

of crayfish (Decapoda) and snails (Gastropoda) in California in 1994. No other data 

were reported. This incident is listed as "probable" for cyfluthrin. It is unknown if the 

incident was due to a registered use or misuse. 

Incident # 1013927-001 - Cyfluthrin was the probable cause of a fish kill in California 

in 2003, reported the California Department of Fish & Game. Cyfluthrin and 

chlorpyrifos were aerially applied to an agricultural field adjacent to the site of the kill. 

Approximately 400 fish died, including 320 flathead catfish (Pylodictis oilvaris), 60 

grass carp (Ctenopharyngodon idella) and 20 largemouth bass (Micropterus 

salmoides). Two water samples were analyzed, and chlorpyrifos was found in bpth 

water samples (0.08 and 11.7 ppb) and cyfluthrin was found in one sample (0.33 ppb). 

Analyses of fish gills ranged from 220-390 ppb cyfluthrin and 660-2100 ppb 

chlorpyrifos. The report states that "there was probably some dilution of the water 

between the time of application of the pesticides and the time of sampling". Thib 

incident is listed as "probable" for cyfluthrin. It is unknown if the incident was due to a 

registered use or misuse. 

Incident # 1003351-021 - Cyfluthrin (Baythroid) was the possible cause of death to an 

unknown number of crayfish (Decapoda) in Lousiana in 1999. Both cyfluthrin ad 

profenofos were aerially applied to cotton fields 100 yards from 200 acres of pdnds. 

The Lousiana Department of Agriculture took water samples 8 hours after the 

application and found neither chemical (LOD= 1.4 ppb for cyfluthrin and LODS.1.48 

ppb for profenofos). Bayer Cropscience, the registrant, said the incident may be due to 

low dissolved oxygen levels. This incident is listed as "possible" for a registered use of 

cyfluthrin. 

Terrestrial Plant Incidents Involving CyJluthrin 
Incident # I0 16940-0 10 - A crop duster experienced mechanical problems and 

discharged cyfluthrin (Baythroid) and dimethoate (Prokil) onto a corn field (Zea mays). 

A few days later the corn field showed burn symptoms in 30 acres of the crop. Around 

7,500 pounds of the crop were sampled for residues, and the two chemicals were found 

in 2,500 pounds (the grower voluntarily disposed of this portion). The analysis showed 

0.15 to 7.2 ppm of cyfluthrin and 0.96 to 1 19.2 ppm of dimethoate. This incident is 

listed as "highly probable" for a misuse of cyfluthrin. 

Incident # I001 728-001 - In Washington state, a commercial applicator sprayed 

cyfluthrin in a yard, which resulted in drift to a neighbor's garden. Damage to unknown 

species of ornamentals ensued. The type and magnitude of the damage was not 

reported. Soil samples from the neighbor's garden tested positive for cyfluthrin (levels 

not reported). This incident is listed as "probable" for a registered use of cyfluthrin. 

Incident # I01 3550-002 - A Delaware potato grower aerially applied cyfluthrin 

(Baythroid), chlorothalonil (Bravo Ultrex) and spinosad (Spin Tor 2SC) to 65 acres of 

his crop, and damage to the plants occurred within 2 days. The Department of 

Agriculture investigated and determined there was glyphosate contamination in the 

containers. This incident is listed as "possible" for a registered use of cyfluthrin. 

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 nontarget incidents, are 

generally reported aggregately and are not included in EIIS. In addition, there have been 

reductions in state monitoring efforts due to lack of resources. 

In the risk assessment, these incidents will be further evaluated to determine if they 

represent current patterns of use for cyfluthrin and1 or beta-cyfluthrin. Examples of 

additional considerations are mitigation (e.g., reduced application rates), product 

cancellations, and changes in use patterns that have occurred since the date of the 

reported incidents. 

As it has been indicated earlier, cyfluthrin is among the constituents monitored by the 

National Water Quality Assessment Data Warehouse, (NAWQA) maintained by the U.S. 

Geological Survey; furthermore, multiple articles from the literature document the 

presence of synthetic pyrethroids like cyfluthrin and/ or beta-cyfluthrin in both urban and 

agricultural water and sediments (refer to Section 3.4). 

4.3. Ecosystems Potentially at Risk 

Cyfluthrin and beta-cyfluthrin may be applied on a variety of food crops, including (but 

not limited to) alfalfa, tree nuts, pome fruits, brassica (head and stem) vegetables, fi-uiting 
vegetables, leafy vegetables, legume vegetables and root and tuber vegetables. In 

addition, they may be used in numerous non-food sites (e.g. ornamental and/ or shade 

trees and ornamental lawns). Thus, the ecosystems at risk may be extensive in scope, and 

as a result it may not be possible to identify specific ecosystems during the development 

of a baseline risk assessment. In general terms, terrestrial ecosystems potentially at risk 

due to the use of cyfluthrin and beta-cyfluthrin, 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. 

Due to the potential persistence of cyfluthrin and beta-cyfluthrin, they are expected to 

drift andlor runoff due to application to food crops, resulting in possible exposure to 

aquatic ecosystems. Aquatic ecosystems potentially at risk due to the use of cyfluthrin 

and beta-cyfluthrin include water bodies adjacent to, or down stream from, the treiated 

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, such as estuaries. 

5. Assessment Endpoints 

Assessment endpoints are defined as "explicit expressions of the actual environmental 

value that is to be protected." Defining an assessment endpoint involves two steps: 1) 

identifying the valued attributes of the environment that are considered to be at ri$k; and 

2) operationally defining the assessment endpoint in terms of an ecological entity (i. e., a 

community of fish and aquatic invertebrates) and its attributes (i.e., survival and 

reproduction). Therefore, selection of the assessment endpoints is based on valued 

entities (i. e., ecological receptors), the ecosystems potentially at risk, the migratidn 

pathways of pesticides, and the routes by which ecological receptors are exposed to 

pesticide-related contamination. The selection of clearly defined assessment endpoints is 

important because they provide direction and boundaries in the risk assessment far 

addressing risk management issues of concern. Changes to assessment endpoints are 

typically estimated from the available toxicity studies, which are used as the meadures of 

effects to characterize potential ecological risks associated with exposure to pesti~ides, 

such as cyfluthrin and beta-cyfluthrin. 

To estimate exposure concentrations, the ecological risk assessment considers 

applications at the maximum application rate to fields that have vulnerable soils. The 

most sensitive toxicity endpoints are used from surrogate test species to estimate 

treatment-related direct effects on acute mortality and chronic reproductive, growth and 

survival assessment endpoints. Toxicity tests are intended to determine effects of 

pesticide exposure on birds, mammals, fish, terrestrial and aquatic invertebrates, and 

plants. These tests include short-term acute, sub-acute, and reproduction studies $nd are 

typically arranged in a hierarchical or tiered system that progresses from basic laboratory 

tests to applied field studies. The toxicity studies are used to evaluate the potential of a 

pesticide to cause adverse effects, to determine whether further testing is required, and to 

determine the need for precautionary label statements to minimize the potential adverse 

effects to non-target animals and plants. 
An open literature search will be conducted to determine any relevant endpoints. The 

search will focus on survival, growth and reproductive effects for aquatic and terrestrial 

effects of cyfluthrin and/ or beta-cyfluthrin. More sensitive endpoints from acceptable 

open literature studies will be included in this risk assessment. 

6. 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. 

A conceptual model provides a written description and visual representation of the 

predicted relationships between cyfluthrin or beta-cyfluthrin, potential routes of 

exposure, and the predicted effects for the assessment endpoint. A conceptual model 

consists of two major components: risk hypothesis and a conceptual diagram (USEPA, 

1998). 

6.1. Risk Hypothesis 

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

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

mathematical models, or probability models (USEPA 1998). For this assessment, the risk 

is stressor-initiated, where the stressor is the release of cyfluthrin and beta-cyfluthrin into 

the environment. The following risk hypotheses are presumed for this screening-level 

assessment: 

Cyfluthrin and beta-cyfluthrin, when used in accordance with registered labels, 

will likely lead to off-site movement of the compound via run08 spray drift, and 

eroded soil leading to exposure of nontarget plants and animals. Based on 

information on the environmental fate, mode of action, direct toxicity and 

potential indirect effects, EFED assumes that registered uses of cyfluthrin and 

beta-cyfluthrin have the potential to cause reduced survival, growth, and 

reproduction to non-target terrestrial and/ or aquatic animals andplants. 

Cyfluthrin and beta-cyfluthrin, when used indoors, in accordance with current 

labels, may result in off-site movement of the compound via wash-off into surface 

waters via drains and treatment plants, leading to exposure of nontarget aquatic 

animals andplants. This potential exposure pathway may result in adverse 

effects upon the survival, growth, and/or reproduction of non-target aquatic 

animals andplants. 

The conceptual model is a generic graphic depiction of the risk hypothesis. It includes 
the potential pesticide or stressor (cyfluthrin, beta-cyfluthrin and possible metabolites), 

the source of the pesticide and/or transport pathways, exposure media, exposure point, 

biological receptor types, and attribute changes. 

6.2. Conceptual Diagram 

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

assumes that the insecticides cyfluthrin and beta-cyfluthrin, which are Type I1 synthetic 

pyrethroids, having multiple outdoor agricultural and non-agricultural uses, are 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 of 

the physicochemical properties of cyfluthrin and beta-cyfluthrin, 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 the 

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 most relevant and 

applicable to this assessment (see Figures 6.la and 6.lb, below). They include the 

potential pesticide or stressor (cyfluthrin and/ or beta-cyfluthrin, but the presence of 

toxicologically important metabolites cannot be ruled out), the sources and/ or transport 

pathways, exposure media and exposure points, biological receptor types and attribute 

changes. 

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

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

pesticide moves in the environment fi-om a source to an ecological receptor. For w 

ecological exposure pathway to be complete, it must have a source, a release mecpanism, 

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 degradation1 transformation products may form in the 

environment, in which media, and how much) must be understood, especially if fbr the 

chemical, its metabolites1 transformation products are of greater toxicological coricern 

than the parent compound. The assessment of ecological exposure pathways, thetefore, 

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

and the determination of potential exposure routes. 

Under the possible uses of cyfluthrin and beta-cyfluthrin, the sources and mechanisms of 

release of the compound are from ground or aerial spray or ULV applications. Note that 

this conceptual model also considers agricultural applications as well as certain nbnagricultural applications. Surface runoff from the areas of application is assumed to 

depend on factors such as topography, irrigation, and rainfall events. Direct depqsition 

may result in contamination of food items that may be consumed by terrestrial organisms. 

Spray drift results in contaminated adjacent areas, including bodies of water. ~otice that 

leaching to groundwater is not considered an important source because cyfluthrin and 

beta-cyfluthrin are relatively immobile. Due to cyfluthrin and beta-cyfluthrin's dotential 

for volatilization, atmospheric transport cannot be ruled out. Despite the fact that 
cyfluthrin and beta-cyfluthrin show a moderate Henry's Law Constant, that would 

suggest some potential for volatilization, and it is moderately persistent in various 

environmental media, the hydroxyl radical reaction half-life for the chemical is 0.86 days 

(EPI Suite v.4.0 estimate). The short (atmospheric) half-life suggests that the potential 

for atmospheric transport for cyfluthrin and beta-cyfluthrin is relatively low and that this 

source of the chemical is of low importance, compared to spray drift, runoff and/ or direct 

contact after application. 

For aquatic receptors, the major point of exposure is through direct contact with the water 

column, sediment, and pore water (gill1 integument) contaminated with spray drift (from 

spray application) andlor runoff from treated areas. Indirect effects to aquatic organisms 

(fish, amphibians and aquatic invertebrates) can also occur through impact to various 

food chains. It was established earlier in this document that cyfluthrin and betacyfluthrin have the potential to bioaccumulatel bioconcentrate. The representative 

aquatic receptors are certain freshwater and estuarine1 marine fish, invertebrates, and, in 

certain cases, aquatic plants. The major point of exposure for terrestrial animals is 

consumption of food contaminated with residues such as grass, foliage, and small insects. 

For plants, the point of exposure is direct contact or root uptake. The representative 

terrestrial receptors are mammals, birds and terrestrial plants. The attribute changes used 

to assess risk to terrestrial receptors depend on the type of test (e.g., reduced survival, 

growth, or reproduction for animals and seedling emergence and vegetative vigor for 

plants). It should be noted, that these species do not cover all the possible species in the 

animal and plant kingdoms; certain taxa are considered as surrogates for other taxa. For 

example, fish are considered surrogates for aquatic phase amphibians. Other attribute 

changes are related to the food chain and habitat integrity. Changes in the food chain 

include, for example, reduction in prey and modifications in primary constituent elements 

(PCEs). PCEs are physical and biological features essential to the conservation of the 

listed species. Changes in habitat integrity include, for example, reduction in primary 

productivity. 

This conceptual model also shows some details about biomagnification for a chemical 

(see piscivorous birds and mammals in Fig. 6.la). Cyfluthrin and beta-cyfluthrin have a 

very high Kow and according to its physicochemical and fate properties, there would be a 

potential for bioaccumulation/bioconcentration in aquatic organisms; however, the 

potential for biomagnification in terrestrial organisms, though at the screen level appears 

low, is uncertain and has not been quantified. 

Cyfluthrin and beta-cyfluthrin show a very low solubility, a very high Kow and also high 

Kocs. These properties suggest that the chemical partitions with the sediments, and with 

organic matter, suspended in the water bodies. Cyfluthrin and beta-cyfluthrin are likely 

to concentrate and persist in the sediments, especially after repeated exposures 

(applications). Such sediments could serve as repositories of the chemical for extended 

periods of time and could potentially be toxic to sediment dwelling organisms, affecting 

the food chain. These issues will also be assessed in the risk assessment for cyfluthrin 

and beta-cyfluthrin. 
................................. . . x.. ......... Source el Spray drift Leaching to : i Atmoipheric i : ...................... Groundwater :.....................# transport i 

Stressor 

- - 

Cyfluthrin or befa-cyfluthrin applied to agricultural 

or non-agricultural use site 

Figure 6.la. Conceptual model depicting stressors, exposure pathways, and 

potential effects to aquatic organisms from the use of cyfluthrin or beta-cyfldthrin 

on agricultural and certain non-agricultural sites 

Dotted lines indicate exposure pathways that have a low likelihood of contributing to ecological risk. 

PCE=primary constituent element 

I I 

+ + .......................................... Exposure Surface water/ ......................... Media Sediment + Wet/dry deposition +..........- ; 

1 ' 

Uptakelgills 

Aquatic Plants 

Non-vascular 

Vascular 

Riparian plants 

terrestrial 

exposure 

pathways; see 

Figure 6.1 b 

Aquatic animals 

Invertebrates 

Vertebrates 

**Piscivorous mammals 

and birds + v v 

Habitat integrity 

Reduction in algae and Reduction in primary 

productivity 

Reduced cover 

Modification of PCEs Community changei 

Modification of PC& related to 

habitat 

**Route of exposure includes only ingestion of fish and aquatic inverts. 
4 I 

Source Direct application 5 1 .................... Irrigation Leaching to 

Exposure Media water +---...+Groundwaterh-: ................... : . & Receptors ermal uptakellngestion 

Terrestrial plants 

Terrestrial grasses/ forbs, fruit, seeds ............................ ~etldry deposition 4.i 

invertebrates 

, 

(trees, shrubs) 

I I -Ingestion 

v Terrestrial 

Ingestion vertebrates 

vertebrates 7 

Habitat integrity 

Reduction in primary productivity 

Reduced cover 

y and food Community change 

~odification ofPCEs related 

related to prey availability to habitat 

Stressor 

Figure 6.lb. Conceptual model depicting stressors, exposure pathways, and 

potential effects to terrestrial organisms from the use of cyfluthrin or betacyfluthrin on agricultural and certain non-agricultural sites 

Dotted lines indicate exposure pathways that have a low likelihood of contributing to ecological risk. 

PCE=prirnary constituent element 

Cyfluthrin or beta-cyfluthrin applied to agricultural 

or non-agricultural use site 

Indoor uses can result in discharges of cyfluthrin and beta-cyfluthrin into sewer systems 

and subsequently into publicly owned treatment works (POTWs), and to aquatic 

ecosystems. These discharges of cyfluthrin and beta-cyfluthrin will be included in the 

assessment as a possible route of exposure to the environment. Exposure estimates could 

be used to evaluate potential effects to ecological entities. The conceptual model for 

potential risks of cyfluthrin or beta-cyfluthrin to aquatic organisms due to various indoor 

uses of the chemical that could potentially end up in a "drain" is depicted in Fig. 6.2. 

The stressor is the chemical of concern, cyfluthrin and beta-cyfluthrin. It is noted that the 

transport pathway is wastewater flow, the exposure media is the treatment facility, but the 

exposure point or route, receptor and attribute changes for aquatic organisms are similar 

to the conceptual model for agricultural and urban applications (as depicted in Fig. 6.la). 

I 
Sourcel 

Transport 

Pathways 

Stressor 

Sourcel 

Exposure 

Media 

Cyfluthrin and Beta-cyfluthrin Applications 

that Could Potentially End Up "Down-the-drain" 

Exposure 

Route 

I 

Receptors 

Attribute 

Changes 

G Wastewater flow 

I 

I 

Uptake/ Gill/ 

Integument Adsorption Uptake 

Treatment Facility 

Discharges into Surface 

Waters 

Invertebrates, 1 

Vertebrates I 

I 

I 

Plant Population 

Reduced 

population 

Vertebrates and 

Invertebrates 

Reduced survival 

or reproduction 1 

Figure 6.2. Conceptual model for potential risks of cyfluthrin and beta-cyflu hrin to 

aquatic organisms for various indoor uses of the chemical that could potenti Ily end 

up in the "drain." 

4 ~ 

7. Analysis Plan 

In order to address the risk hypothesis, the potential for adverse effects on the 

environment is estimated. Usage, environmental fate and transport, and ecological 

effects of cyfluthrin and beta-cyfluthrin are characterized and integrated to assess the 

risks. This is accomplished using a risk quotient (ratio of exposure concentration to 

effects concentration) approach. Although risk is often defined as the likelihood bd 

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

provide a quantitative estimate of likelihood and or magnitude of an adverse effe~ct. 

However, as outlined in the Overview Document (USEPA 2004), the likelihood qf effects 

to individual organisms from particular uses of a chemical is estimated using the firobit 

dose-response slope and either the level of concern (discussed below) or the actual 

calculated risk quotient value. 

This analysis plan will be revisited and may be revised depending on the data available in 
the open literature and the information submitted by the public or the registrant in 

response to the opening of the Registration Review docket. 

7.1. Stressors of Concern 

The focus of this assessment is on the parent materials, cyfluthrin and beta-cyfluthrin. 

However, the Agency will review available studies to identify degradate(s) of potential 

toxicological concern (e.g., DCVA, FPB-acid and FPB-ald). 

Toxicity data for environmental mixtures of cyfluthrin and beta-cyfluthrin with other 

pesticides (those mixtures occurring in the environment following application), if 

available, may be presented as part of the ecological risk assessment. Cyfluthrin and 

beta-cyfluthrin may be applied in tank mixtures with other products approved for use on 

registered crops. It is expected that the toxic effect of cyfluthrin and beta-cyfluthrin, in 

combination with other pesticides used in the environment, is likely to be a function of 

many factors including, but not necessarily limited to (1) the exposed species, (2) the cocontaminants in the mixture, (3) the ratio of cyfluthrin and/ or beta-cyfluthrin and cocontaminant concentrations, (4) differences in the pattern and duration of exposure 

among contaminants, and (5) the differential effects of other physicall chemical 

characteristics of the receiving waters (e.g. organic matter present in sediment and 

suspended water). Quantitatively predicting the combined effects of all these variables 

on mixture toxicity to any given taxa with confidence is beyond the capabilities of the 

available data and methodologies. However, a qualitative discussion of implications of 

the available pesticide mixture effects data on the confidence of risk assessment 

conclusions will be addressed as part of the uncertainty analysis. 

7.2. Measures of Exposure 

In order to estimate risks of cyfluthrin and beta-cyfluthrin exposures in aquatic and 

terrestrial environments, all exposure modeling and resulting risk conclusions will be 

made based on maximum application rates for the current use patterns. Measures of 

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

concentrations of cyfluthrin and beta-cyfluthrin using maximum labeled application rates 

and methods, as well as any mitigation measures specifically indicated on the label. The 

models used to predict aquatic EECs are the Pesticide Root Zone Model coupled with the 

Exposure Analysis Model System (PRZMIEXAMS). Also, to estimate exposure related 

to releases of cyfluthrin and beta-cyfluthrin from domestic wastewater treatment plants, 

the Exposure and Fate Assessment Screening Tool's (EFAST2) down-the-drain module 

will be used. The model used to predict terrestrial exposure to birds and mammals is TREX. The model used to derive EECs relevant to terrestrial and wetland plants is 

TerrPlant. The potential for bioaccumulation for the chemical is assessed using the 

KABAM model, as well the results fi-om bioconcentration in fish studies (e.g. the 

bioconcentration factors). KABAM is used to estimate potential bioaccumulation of 

hydrophobic organic pesticides in freshwater aquatic ecosystems and risks to mammals 

and birds consuming aquatic organisms which have bioaccumulated these pesticides. All 

of these models are parameterized using relevant reviewed registrant-submitted 
environmental fate and transport data. 

PRZM (v.3.12.2, May 2005) and EXAMS (v.2.98.4.6, April 2005) are screening 

simulation models coupled with the input shell PE5.pl (August, 2007) to generate daily 

exposures and 1-in-1 0 year EECs of cyfluthrin and beta-cyfluthrin, that may occur from 

spray drift and runoff to surface water bodies adjacent to application sites. PRZM 

simulates pesticide application, movement and transformation on an agricultural field and 

the resultant pesticide loadings to a receiving water body via runoff, erosion and spray 

drift. The EXAMS model simulates the fate of the pesticide and resulting concentrations 

in the water body. The standard scenario used for ecological pesticide assessments 

assumes application to a 10-hectare agricultural field that drains into an adjacent 1- 

hectare water body that is 2 meters deep (20,000 cubic meters volume) with no outlet. 

PRZMI EXAMS is used to estimate screening-level exposure of aquatic organisms to 

cyfluthrin and/ or beta-cyfluthrin and/ or their transformation products, should they be of 

concern. The measure of exposure for aquatic species is the 1 -in-1 0 year return peak or 

rolling mean concentration. The 1 -in- 10 year peak is used for estimating acute exposures 

of direct effects to aquatic organisms. The 1 -in-l O-year 60-day mean is used for assessing 

chronic exposure to fish and aquatic-phase amphibians. The 1 -in- 1 0-year 2 1 -day mean is 

used for assessing aquatic invertebrate chronic exposure. 

Given the aquatic toxicity of cyfluthrin and beta-cyfluthrin and their likelihood to occur 

in sediment, the Agency will also consider the potential exposures resulting from benthic1 

sediment concentrations (EECs). Pore water concentrations are commonly used to 

predict toxicity of non-ionic substances in sediments and characterize exposure to 

organisms that spend time in or near sediments (Di Toro et al. 1991; US EPA 2002). 

PRZMI EXAMS estimates 1 -in-10-year peak and 21 -day mean EECs for pore water. 

To estimate exposure related to releases of cyfluthrin and beta-cyfluthrin from domestic 

wastewater treatment plants, the Agency will rely on the Office of Pollution Prevention 

and Toxics (OPPT) model, Exposure and Fate Assessment Screening Tool (EFAST, 

version 2.0, or EFAST2,2007). From this model, the Agency will use the "Down-theDrain" module, which is designed for releases to domestic wastewater treatment. It is 

suitable for all the sources of cyfluthrin and beta-cyfluthrin that could potentially be 

exposed through a "down-the-drain" scenario. The model provides screening level 

estimate concentrations of chemicals in surface water that may result fiom household 

uses and the disposal of consumer products into wastewater using a few simple input 

parameters (production volume and fiaction of the chemical removed during wastewater 

treatment) (please, refer to Section 7.9.1 for data being required for this analysis; a 

POTW treatability study is being required for these chemicals). 

Exposure estimates for terrestrial animals assumed to be in the target area are derived 

using the T-REX model (version 1.3.1, 12/07/2006). For pesticides such as cyfluthrin 

and beta-cyfluthrin, which can be applied as a dust, this includes the amount of pksticide 

per square foot, used in LDsa per square foot risk assessment calculations. 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 
(assumed to be 0% for granulars) to calculate EECs. EECs are based upon solubility, 

application rate and minimum incorporation depth. 

As indicated in Table 3.1 and its associated text in Section 3, cyfluthrin and betacyfluthrin appear to have a potential to bioaccumulate in aquatic organisms, based on its 

high Kow (9.33 x lo5) and persistence in water and sediments. Due to its metabolism and 

relatively rapid depuration, it appears that cyfluthrin and beta-cyfluthrin have a low 

likelihood to biomagnify in aquatic and terrestrial organisms (i. e., a form of 

bioaccumulation where concentrations increase from prey to predators due to dietary 

exposure). However, this potential has not been quantified. The potential for 

bioaccumulation and biomagnification of cyfluthrin and beta-cyfluthrin in aquatic food 

webs will be examined in the risk assessment. Because cyfluthrin and beta-cyfluthrin 

have a fairly high Kow (9.33 x lo5) and the chemical may be persistent in water and 

sediments, there is a potential for bioaccumulation. The maximum bioconcentration 

factor was 854x for whole fish and depuration rate is moderate (half depuration time of 3 

days, MRID 00 143 143). Bioaccumulation will be assessed using the results from 

bioaccumulation in fish studies, as well as the (Kow (based) Aquatic BioAccumulation 

Model (KABAM, v. 1 .O, 2009), adjusting for biotransformation rates. KABAM is used to 

estimate potential bioaccumulation of hydrophobic organic pesticides in freshwater 

aquatic ecosystems and risks to mammals and birds consuming aquatic organisms which 

have bioaccumulated these pesticides. Currently, EFED does not have the modeling 

capabilities to quantitatively evaluate bioaccumulation and biomagnification in terrestrial 

food webs5. Therefore, EFED will address these exposure routes qualitatively. 

7.3. Measures of Effect 

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

receptors. Data are typically obtained from registrant-submitted studies or from literature 

studies identified by ECOTOX. The ECOTOX database provides more ecological effects 

data in an attempt to bridge existing data gaps. ECOTOX is a source for locating single 

chemical toxicity data and potential 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. 

The acute measures of effect used for animals in this assessment are the LDsO, LCs0 and 

ECsO. LD stands for "Lethal Dose", and LDsO 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 LCso is the concentration of a chemical that is estimated to 

kill 50% of the test organisms. EC stands for "Effective Concentration" and the ECso is 

5 USEPA. 2009a. SAP Minutes No. 2009-01. A Set of Scientific Issues Being Considered by the 

Environmental Protection Agency Regarding: Selected Issues Associated with the Risk Assessment Process 

for Pesticides with Persistent, Bioaccumulative and Toxic Characteristics October 28 - 3 1,2008. FIFRA 

Scientific Advisory Panel Meeting, Held at the Environmental Protection Agency Conference Center, 

Arlington, Virginia (http://epa.~ov/osc~mont/sap/meetin~~/2008/o~tober/min~te~.pdf, 
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 ObservedAdverse-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., "NoObserved-Adverse-Effect-Concentration") is the highest test concentration at which none 

of the observed effects were statistically different from the control. The NOEC is the NoObserved-Effects-Concentration. For non-listed plants, only acute exposures are 

assessed (i.e., ECZ5 for terrestrial plants and ECso for aquatic plants); for listed plants 

either the NOAEC or ECo5 is used. 

Information on the potential effects of cyfluthrin and beta-cyfluthrin on non-target 

animals is also collected from the Ecological Incident Information System (EIIS). 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. 

Information on incidents involving avian species is also provided through the Avian 

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

Conservancy. 

Where available, sub-lethal effects observed in both registrant-submitted and open 

literature studies will be evaluated qualitatively. Such effects may include behavioral 

changes (e.g., lethargy and changes in coloration). 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 the toxicity of cyfluthrin and beta-cyfluthrin to birds is similar to terrestrial-phase 

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

amphibians. 

7.4. 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 compar$d to the 

Agency's Levels of Concern (LOCs) (USEPA 2004). These criteria will be used to 

indicate when cyfluthrin and beta-cyfluthrin's uses, as directed on 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. 

7.5. Deterministic and Probabilistic Assessment Methods 
The quantitative assessment of risk will primarily depend on the deterministic pointestimate based approach described in the risk assessment. An effort may also be made to 

further qualitatively describe risk using probabilistic tools that the Agency has developed. 

These tools have been reviewed by FIFRA Scientific Advisory Panels 

(http:llwww.epa.govlscipolylsaplindex.htm) and have been deemed as appropriate means 

of refining assessments where deterministic approaches have identified risks. 

7.6. Endangered Species Assessments 

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

the Agency will evaluate risks to Federally-listed threatened andlor endangered (listed) 

species from registered uses of cyfluthrin and beta-cyfluthrin. This assessment will be 

conducted in accordance with the Overview Document (USEPA 2004), provisions of the 

ESA, and the Services' Endangered Species Consultation Handbook (USFWSNMFS, 

1998). No previous endangered species assessment has been conducted for cyfluthrin or 

beta-cyfluthrin. 

The assessment of effects associated with the registration of cyfluthrin and betacyfluthrin 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 cyfluthrin and 

beta-cyfluthrin 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 sub-lethal 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. 

Currently, EFED does not assess risk to non-target insects. Results of acceptable studies 

are used for recommending appropriate label precautions. Based on the results of a 

single study in honey bees (LD50 of 0.037 pg a.i./bee, MRID 00153638), cyfluthrin is 

classified as highly toxic on an acute contact basis. This study suggests that the acute 

toxicity to non-target beneficial endangered insects may also be of concern should 

exposure occur. 

Toxicity data are not available for terrestrial plants, and risks associated with cyfluthrin 

and beta-cyfluthrin exposure to terrestrial plants cannot be assessed. In the past, it had 
been indicated that a review of cyfluthrin and beta-cyfluthrin's mode of action (neural 

toxin) suggested that direct toxicity to plants would not be an issue of concern. However, 

incidents involving terrestrial plants have been reported to the Agency. These data are 

requested, according to the Part 158 data requirements. 

7.7. Drinking Water Assessment 

A drinking water assessment will be conducted to support future human health risk 

assessments of cyfluthrin and beta-cyfluthrin should it be required and based on the 

newly submitted environmental fate results. The drinking water assessment will 

incorporate model estimates of cyfluthrin and/ or beta-cyfluthrin in surface and ground 

waters. Concentrations in surface waters will be estimated using FQPA Index Reservoir 

Screening Tool (FIRST, v. 1.1.1, 1211 8/07) (or subsequently using PRZMI EXAMS, with 

the Index Reservoir - for description see above - if refinements are required). Ground 

water estimates of concentrations will be obtained using the Screening Concentration In 

GRound Water (SCI-GROW) model (v.2.3, July 2003). The drinking water assessment 

will also include a summary of available surface and ground water monitoring data. 

7.8. Endocrine Disruptor Screening Program 

As required under FFDCA section 408(p), EPA has developed the Endocrine Disruptor 

Screening Program (EDSP) to determine whether certain substances (including pesticide 

active and other ingredients) may have an effect in humans or wildlife similar to an effect 

produced by a "naturally occurring estrogen, or other such endocrine effects as the 

Administrator may designate." The EDSP employs a two-tiered approach to making the 

statutorily required determinations. Tier 1 consists of a battery of 11 screening assays to 

identify the potential of a chemical substance to interact with the estrogen, androgen, and 

or thyroid (E, A, or T) hormonal systems. Chemicals that go through Tier 1 screening and 

are found to have the potential to interact with E, A, or T hormonal systems will proceed 

to the next stage of the EDSP where EPA will determine which, if any, of the Tier 2 tests 

are necessary based on the available data. Tier 2 testing is designed to identify any 

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

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

Between October 2009 and February 201 0, EPA issued test ordersldata call-ins for the 

first group of 67 chemicals, which contains 58 pesticide active ingredients and 9 inert 

ingredients. This list of chemicals was selected based on the potential for human 

exposure through pathways such as food and water, residential activity, and certain postapplication agricultural scenarios. This list should not be construed as a list of known or 

likely endocrine disruptors. I 

Cyfluthrin is among the group of 58 pesticide active ingredients on the initial list to be 

screened under the EDSP. The Agency will review the EDSP Tier 1 data and any "other 

scientifically relevant information" submitted in response to test orders. Based on this 

review the Agency will determine the need for additional testing. For further information 

on the status of the EDSP, the policies and procedures, the list of 67 chemicals, the test 
guidelines and the Tier 1 screening battery, please refer to the following website: 

http://www.epa.aov/endo/ . 

7.9. Preliminary Identification of Data Gaps 

7.9.1. Fate 

After evaluation of the available data for cyfluthrin and beta-cyfluthrin, the following 

data gaps for registration review have been identified. 

835.4100 Aerobic Soil Metabolism - The Agency has aerobic soil metabolism studies 

performed in two soils for fluorophenyl-labeled cyfluthrin; no data are available with 

cyclopropyl-labeled cyfluthrin. A study performed in two soils should be submitted for 

cyfluthrin (at least, one of which should be conducted with cyclopropyl-labeledcyfluthrin). In addition, a study should be performed in four soils for beta-cyfluthrin. 

The data requirement is being required for beta-cyfluthrin as per current draft guidance 

provided in the EFED Interim Policy for Stereoisomeric Pesticides (1 0/26/00),~ that 

indicates that " . . .an aerobic soil metabolism study (GLN 1 62- 1/83 5.3 3 00) is required as 

part of the minimal data set for enantiomeric enriched mixtures." (Note that the current 

guideline number for the aerobic soil metabolism studies is 835.4100.) At this time, 

these data are not available to the Agency. Furthermore, there is evidence in the 

literature that the degradation of cyfluthrin and beta-cyfluthrin may be enantioselective 

(Qin et al. 2006, Li et al. 2008). Aerobic soil metabolism studies with one soil type are 

generally sufficient for the evaluation of transformation pathways. Rates of 

transformation should be determined in at least three additional soils (from Fate, 

Transport and Transformation Test Guidelines - OCSPP (formerly OPPTS) Guideline 

83 5.4 100 & 83 5.4200). For all metabolism studies, domestic soils are preferred. 

835.4200 Anaerobic Soil Metabolism - The available supplemental anaerobic soil 

metabolism study, conducted on cyfluthrin, was performed with only one soil and for a 

period of roughly one month of anaerobic incubation. A new study is required. 

Anaerobic studies with one soil type are generally sufficient for the evaluation of 

transformation pathways. Rates of transformation should be determined in at least three 

additional soils (from Fate, Transport and Transformation Test Guidelines - OCSPP 

(formerly OPPTS) Guideline 835.4100 & 835.4200). For all metabolism studies, 

domestic soils are preferred. 

835.4300 Aerobic Aquatic Metabolism - Two soil/ sediment systems are available that 

were conducted with cyclopropyl-labeled cyfluthrin. The studies available that were 

conducted with fluorophenyl-labeled cyfluthrin provide only a minimum supplemental 

inf~rmation.~ A study should be conducted utilizing fluorophenyl-labeled beta-cyfluthrin 

6 Available at url http:llwww.epa.gov/oplsefed1/ecorisk~ders/stereoisomer~~olicv.htm . 7 The following problems were observed in the studies: the amount of parent material at the first sampling 

interval was too low, studies were conducted at above the solubility limit, and the study was not performed 

in accordance with FIFRA GLP standards. When conducting the new study, the registrant should avoid 

these problems. 
on one sediment system of marine origin. According to the OCSPP (formerly OPPTS) 

Fate, Transport and Transformation Test Guidelines (835.4300 & 835.4400). . ."At least 

two sediments and their associated waters are used for both the aerobic and the anaerobic 

studies respectively.. .However, there may be cases where more than two aquatic 

sediments should be used, for example, for a chemical that may be present in freshwater 

andlor marine environments. Sediments should be representative of intended use sites." 

Since both cyfluthrin and beta-cyfluthrin have the potential for use near estuarine1 marine 

areas, the required sediment system should be from estuarinel marine environment. For 

the metabolism studies, domestic sediments are preferred. 

835.4400 Anaerobic Aquatic Metabolism -No study has been submitted. The study is 

required, and it should be conducted on beta-cyfluthrin. Three sediment systems are 

required, one of which should be of marine origin (see guideline requirement above). For 

the metabolism studies, domestic sediments are preferred. 

835.1230 Mobility Adsorption1 Desorption - The available study was performed at a 

single concentration and no Freundlich correlations or isotherms are available. A new 

study is required. According to OCSPP (formerly OPPTS) Fate, Transport and 

Transformation Test Guideline (83 5.1230), the main portion of the adsorption/ desorption 

study is for the "Determination of Freundlich adsorption isotherms to determine the 

influence of concentration on the extent of adsorption on soils." The available study 

indicated that cyfluthrin is relatively immobile in the various soils tested (Koc > 73,500). 

Environmental Chemistry Methods (ECMs), and Independent Laboratory 

Validations (ILVs), for Soil, Water and Sediment. ECMs associated with the 

Terrestrial Field Dissipation study (Field dissipation 5 158.1300; OPPTS guidelines 

835.6100, 835.6200, and 835.6300), along with successful confirmatory method trials 

(validation) by an independent laboratory (i. e. ILVs), are required. If there is risk 

concern for a given taxon, ECMs should be available for the environmental media in 

which organisms of the taxon reside. These ECMs should have limits of quantizdtion for 

the residues of concern that are lower than the relevant toxicological levels of concern. 

Previous reviews on cyfluthrin and beta-cyfluthrin indicate that there is high condern for 

acute and chronic toxicity to aquatic animals. Certain scenarios may have triggered acute 

and chronic levels of concern for freshwater and1 or estuarinel marine aquatic 

invertebrates and1 or for fish and/ or organisms living in the benthos. Therefore, ECMs 

for water and sediment are required in addition to the ECM for soil. The ECMs should 

include parent and those residues found in the laboratory studies that exceeded 10% of 

the applied. Based on the available data at this time, the following appear to be the 

residues of concern for each media, but this could change, based upon the results of new 

environmental fate studies: 

Soil, Water and Sediment - cyfluthrin, beta-cyfluthrin, FPB-acid, FPB-ald and DCVA 

The registrant is encouraged to submit state-of-the-art environmental chemistry rttethods; 

further, multi-residue methods (MRMs) for soil, water and sediment are preferred, if 

applicable. The registrant submitted one method (MRID 4 15 1 1301, published in the 

Agency's ECM website),' that could quantify cyfluthrin in water and sediment. In 

Available at url: h~://www.e~a.p;ov/ombeadl/methods/ecmindex.htm 
addition, there is one ECM and ILV that quantifies cyfluthrin and other pyrethroids in 

sediments (MRID 47053001 and 47053002). The Agency will verify the suitability of 

these methods and the appropriateness of their levels of quantization. At this time, no 

methods have been identified for the analysis of beta-cyfluthrin. A full description of the 

method validation procedures performed by an independent laboratory should also be 

submitted. It should include the following information (Corbin et al. 2006): (a) Recovery 

level(s) of the test compound(s) fi-om the soil, water and sediment (substrates) at various 

relevant fortification level(s) using the residue analytical methodology; (b) a validated 

method sensitivity level; (c) results of the study and statistical test applied, including a 

stepwise presentation of the procedure for calculating percent recovery from the raw data; 

(d) all the data/ information necessary to independently verify the results; (e) summary of 

the results; and, (0 discussion and conclusions of the results. 

Other data needs: 

Leachability from Treated Wood - A study is required. It should be conducted 

according to the American Wood Preservers Association Standard Method of 

Determining the Leachability of Wood Preservatives (El 1-06). It is strongly preferred 

that the registrant provided a protocol to be evaluated by the Agency prior to conducting 

the study. 

POTW Effluent Monitoring - Request any existing or ongoing POTW effluent 

monitoring data for the pyrethroids be submitted to the Agency. 

POTW Treatability Study - The Agency is anticipating requiring a bench scale study of 

waste water treatment, to assess the percentage removed in the biosolids by the treatment, 

the amount that would degrade during treatment, and the amount that would remain in the 

waste water. These data would be used to inform removal percentages by waste water 

treatment, which is an input to the Exposure and Fate Assessment Screening Tool's (EFAST) down-the-drain module. The Office of Pesticide Programs will continue to 

confer with the Office of Water with the goal of refining our down-the-drain assessment 

for registration review. 

Table 7.1 lists the status of the environmental fate data requirements for cyfluthrin and 

beta-cyfluthrin. 

Table 7.1. Summary of Environmental Fate Data Requirements for Cyfluthrin and Beta-cyfluthrin 

I I I I 

Degradation Studies-Lab: 

Study Identification 

835.2120 Hydrolysis 12 Yes 00131493,00137539, No 

45022101 

$158.1300 ENVIRONMENTAL FATE 

Use 

pattern1 

Does EPA Have 

Data To Satisfy 

 hi^ Requirement? Bibliographic Citation 

Must Additional 

Data Be Submitted 

Under FIFRA 

3(~)(2)(B)? 
835.2240 Photodegradation in 

Water 

Table 7.1. Summary of Environmental Fate Data Requirements for Cyfluthrin and Beta-cyfluthrin 

Yes 

835.24 10 Photodegradation on 

Soil 

Must Additional 

Data Be Submitted 

Under FIFRA 

3(~)(2)(B)? 

Yes 

Bibliographic Citation 

835.2370 Photodegradation in 

Air 

Does EPA Have 

Data To Satisfy 

Study Identification This Requirement? 

Not Available 

Use 

Pattern1 

Metabolism Studies-Lab: 

835.4100 Aerobic Soil Yes 

Yes 

No 

No 

835.4200 Anaerobic Soil 

835.4300 Aerobic Aquatic 

835.4400 Anaerobic Aquatic Not Available 

Mobility Studies: 

835.1230 Leaching - 

Adsorption1 Desorption 

Yes 

835.1410 Volatility (Lab) Not Available 

835.8100 Volatility (Field) Not Available 

Dissi~ation Studies-Field: 

83 5.6 100 Terrestrial Field 

Dissipation 

Yes 

83 5.6200 Aquatic Field 

Dissipation 

Not Applicable 

835.6300 Forestry Dissipation Not Applicable 

Ground Water Monitoring Studies: 

835.7100 Ground Water 

Monitoring 

Reserved 

5158.1 100 SPRAY DRIFT 

201-1 Droplet Size Spectrum Yes 

202-1 Drift Field Evaluation Yes 

Other Studies: 
Environmental Chemistry 12 Yes 41511301,47053001, yesg 

Methods (ECMs) and 47053002 

Independent Laboratory 

Validations (ILVs) 

Table 7.1. Summary of Environmental Fate Data Requirements for Cyfluthrin and Beta-cyfluthrin 

Leachability £tom Treated 1.2 

.Wood 

No Not Available yes1' 

Study Identification 

POTW Effluent Monitoring 1.2 No Not Available yes1' 

and POTW Treatability Study 

1. Use Patterns: 1 =Terrestrial/Food; 2=Terrestrial/Feed. 

2. A study performed in two soils should be submitted for cyfluthrin. In addition, a study should be performed on four soils 

for beta-cyfluthrin. The data requirement is being required for beta-cyfluthrin as per current draft guidance provided in the 

EFED Interim Policy for Stereoisomeric Pesticides. 

3. Data are required for cyfluthrin on four soils utilizing fluorophenyl- and cyclopropyl-labeled cyfluthrin, as per current 

guidance. 

4. A study should be conducted utilizing fluorophenyl-labeled beta-cyfluthrin on one sediment system of estuarine1 marine 

origin. 

5. A study is required for beta-cyfluthrin. 

6. The available study was conducted at only one concentration and a Freundlich isotherm could not be drawn. A new 

study is required. 

7. One of the studies is currently in review. 

8. Data requirement covered by submission of the Spray Drift Task Force. 

9. The data requirement remains unfulfilled for cyfluthrin, pending evaluation of three available studies. No data have been 

identified for beta-cyfluthrin. 

10. It is strongly preferred that the registrant provided a protocol to be evaluated by the Agency prior to conducting the 

study. 

11. Request any existing or ongoing POTW effluent monitoring data. Further, the Agency is anticipating requiring a bench 

scale study of waste water treatment, to assess the percentage removed in the biosolids by the treatment, the amount that 

would degrade during treatment, and the amount that would remain in the waste water. 

Does EPA Wave 

Data To Satisfy 

 hi^ Requirement? 

Use 

pattern1 

7.9.2 Effects 

For registration review, the following studies are being requested to fulfill any data gaps: 

Bibliographic Citation 

Cyfluthrin is part of the Endocrine Disruptor Screening Program; certain data has been 

required for the chemical under the program (DCI issued on 11/19/09; 90-day response 

by 0212711 0; order due date 1 111 911 1). 

Must Additional 

Data Be Submitted 

Under FIFRA 

3(c)(2HB)? 

Study Title: Endocrine Disruptor Screening Program 

As required under FFDCA section 408(p), EPA has developed the Endocrine Disruptor 

Screening Program (EDSP) to determine whether certain substances (including pesticide 

active and other ingredients) may have an effect in humans or wildlife similar to an effect 

produced by a "naturally occurring estrogen, or other such endocrine effects as the 

Administrator may designate." The EDSP employs a two-tiered approach to making the 

statutorily required determinations. Tier 1 consists of a battery of 11 screening assays to 
identify the potential of a chemical substance to interact with the estrogen, androgen, and 

or thyroid (E, A, or T) hormonal systems. Chemicals that go through Tier 1 screening and 

are found to have the potential to interact with E, A, or T hormonal systems will proceed 

to the next stage of the EDSP where EPA will determine which, if any, of the Tier 2 tests 

are necessary based on the available data. Tier 2 testing is designed to identify any 

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

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

Between October 2009 and February 201 0, EPA issued test ordersldata call-ins for the 

first group of 67 chemicals, which contains 58 pesticide active ingredients and 9 inert 

ingredients. This list of chemicals was selected based on the potential for human 

exposure through pathways such as food and water, residential activity, and certain postapplication agricultural scenarios. This list should not be construed as a list of known or 

likely endocrine disruptors. 

Cyfluthrin is among the group of 58 pesticide active ingredients on the initial list to be 

screened under the EDSP. The Agency will review the EDSP Tier 1 data and any "other 

scientifically relevant information" submitted in response to test orders. Based on this 

review the Agency will determine the need for additional testing. For further infarmation 

on the status of the EDSP, the policies and procedures, the list of 67 chemicals, the test 

guidelines and the Tier 1 screening battery, please refer to the following website: 

http:llwww.epa.govlendol . 

Guideline Number: 850.2100 

Study Title: Passerine Acute Avian Oral 

An acute avian oral study was received for bobwhite quail. The Agency updated its data 

requirements in 40 CFR Part 158 (October 26,2007) to include an acute oral toxicity 

study for both a passerine species and either a waterfowl or an upland game species. 

Prior to starting toxicity testing, a protocol will need to be provided for review. Many 

passerine species utilize agricultural fields, forests, residential areas and surrounding 

areas, and, therefore, have the potential to be exposed to pesticides used in agricultural, 

forest, and residential settings. It is likely that, for most pesticide use patterns, passerines 

are more likely to be exposed to pesticides than upland game species and waterfowl. 

Passerines are smaller in size and generally have faster metabolisms than the waterfowl 

and upland game bird species traditionally used in avian toxicity tests which could impact 

their sensitivity to chemicals. 

Guideline Number: 850.2300 

Study Title: Avian Reproduction Study (Mallard duck only) 

No acceptable data on reproductive toxicity to the most sensitive bird species has been 

submitted (mallard duck). The most sensitive study resulted in a nondefinitive NOAEC 

(<250 ppm) and both submitted studies had issues with control performance. A chronic 

risk assessment for birds is needed based on cyfluthrin's use patterns and potential impact 

on birds. The avian reproduction toxicity study is justified for cyfluthrin because 1) the 

avian reproduction studies for both waterfowl and upland game bird species are standard 

data requirements for all outdoor terrestrial use patterns, 2) evidence of chronic toxicity 
to mammals indicates possible chronic toxicity in birds, and 3) cyfluthrin use pattern 

indicates that chronic exposure is likely. 

Guideline Number: 850.1025 

Study Title: Oyster Acute Toxicity (saltwater, cyfluthrin TEP only) 

Guideline Number: 850.1035 

Study Title: Mysid Acute Toxicity (saltwater, cyfluthrin TEP only) 

Cyfluthrin and beta-cyfluthrin have the potential to enter estuarinelmarine water bodies 

based on current usage patterns that include coastal areas (see Fig. 3.1). Cyfluthrin 

technical is very highly toxic to estuarinelrnarine fish and invertebrates on an acute basis, 

but no information is available for cyfluthrin TEP effects on estuarinelrnarine species. 

Testing on Typical end-use products (TEP) 

According to the Part 158 data requirements, testing on the typical end-use product may 

be required for aquatic toxicity tests when any of the following conditions exist: 

1. The end-use product will be introduced directly into the aquatic environment. 

2. The maximum expected environmental concentration or estimated 

environmental concentration in the aquatic environment is greater than or equal to 

one-half the LCj0 or ECjo of the TGAI. 

3. An ingredient in the end-use formulation other than the active ingredient is 

expected to enhance the toxicity of the active ingredient or cause toxicity to 

aquatic organisms. 

Previous assessments on cyfluthrin indicate that the expected environmental 

concentrations in aquatic environments are well above acute 50% mortality levels for all 

estuarinelmarine invertebrate species tested. Based on preliminary calculations (see 

Appendix D), the peak aquatic EEC is 1.62 pg ai1L using the PRZMIEXAMS MS cotton 

scenario. In estuarinelmarine tests conducted with cyfluthrin technical, the lowest 96- 

hour LCso was 4.05 pg/L for sheepshead minnow, 0.0022 pg1L for mysid shrimp and 

2.69 pg1L for the eastern oyster. Therefore, cyfluthrin fulfills the second requirement 

(above) for TEP studies with all tested estuarinelrnarine invertebrate species, but not 

estuarinelmarine fish. 

A Typical End-Use Product is defined in the Pesticide Assessment Guidelines 

Subdivision J Hazard Evaluation: Nontargetplants on Part 120-2(1) on Page 18 as "a 

pesticide product that is representative of a major formulation category (e.g., emulsifiable 

concentrate, granular product, wettable powder) and pesticide group (e.g., herbicide, 

fungicide, insecticide etc.) and contains the active ingredient of the applicant's product." 

(Holst and Ellwanger, 1982) 

Page 5 of the Pesticide Assessment Guidelines Subdivision JHazard Evaluation: 

Nontargetplants, provides additional information on what TEP data should be tested for 

toxicity testing in the following excerpt. 

"The Agency seeks to avoid imposing a burden of duplicative testing on 
applicants for registration. Therefore, where 40 CFR Part 158 specifies that the 

test substance should be a representative end-use product, testing may be 

performed using the formulation in question (end-use product being registered) or 

similar, yet representative, end-use product. It is not necessary to repeat the test 

using other similar products." (Holst and Ellwanger, 1982). 

When TEP data are requested, data should be submitted for the different formulations, 

e.g., wettable powder, emulsifiable concentrate, granular, along with a rationale as to why 

the TEP is representative of other similar end-use products. Acute aquatic toxicity studies 

conducted with the Typical End-Use Product (TEP) may be used to assess effects as a 

result of exposure to spray drift only and reflect potential effects fkom a brief exposure to 

the formulation. Therefore, appropriate TEPs should be selected from formulations that 

are registered for agricultural uses, not residential. 

Guideline Numbers: Non-guideline 

Study Title: Aquatic Invertebrate Acute Toxicity (Hyalella azteca) 

Available information in the Agency ECOTOX database indicates that the freshwater 

amphipod, Hyalella azteca, is substantially more sensitive to pyrethroids than Daphnia 

magna, the commonly tested freshwater invertebrate. Information on the acute to~icity 

of cyfluthrin to Hyalella azteca was not identified in this problem formulation. 

Therefore, in order to ensure that risk to sensitive aquatic invertebrates are appropriately 

quantified, additional acute toxicity testing of Hyalella azteca is needed (water coLumn 

exposure, not sediment-spiked). 

Guideline Number: Non-guideline 

Study Title: Whole sediment: chronic invertebrates freshwater and marine 

No chronic sediment toxicity tests for freshwater or marine invertebrates have been 

submitted to satisfy the Agency's updated data requirements for outdoor uses in 40 CFR 

Part 158 (October 26,2007). For cyfluthrin, available information indicates that benthic 

organisms may be exposed via run-off or spray drift applications used in agricultural, 

forest, and residential settings. Based on preliminary calculations (see Appendix' D), the 

peak sediment porewater EECs predicted for cyfluthrin (0.048 yg a.i./L) exceeds 0.1 of 

the most sensitive acute LC/ECSO (0.0022 yg/L for mysid shrimp), which satisfie~ one of 

the criteria for requiring chronic whole sediment toxicity testing under 40 CFR Part 158. 

Further, the expected half-life of cyfluthrin in sediment (73.5-94.8 for aerobic soil 

metabolism and 32.9-42 days for aerobic aquatic metabolism) is substantially gre@ter than 

40 CFR Part 158 criterion of 10 days. The third set of trigger criteria for requiring 

chronic testing (Kd > 50, or log Kow >3 or Koc > 1000) is also met for cyfluthrin (e.g., Kd 

values are 974-1793, log Kow is 6, and Koc values are 69900-180300). In additidn, 

chronic effects were also seen in all aquatic taxa tested at levels ranging from 0.00040 - 

0.63 yg a.i./L. Finally, the potential for persistent exposure from cyfluthrin in sediment 

is also indicated by open literature studies on pyrethroids (Weston et al. 2005, Mweg et 

al. 2006 and Ding et al. 2009). 

For sediment studies involving pyrethroids, chronic whole sediment tests on Hyalella 

azteca, Chironomus tentans, and Leptocheirus plumulosus are requested. Although both 

are freshwater species, Hyalella and Chironomus differ substantially in their ecological 
niche (i. e., epibenthic v. infaunal species), physiology, and there is some evidence 

suggesting Hyalella is among the more sensitive invertebrates to some pyrethroids based 

on water column tests (Anderson el al. 2006, Maund et al. 2002). Cyfluthrin has the 

potential to enter estuarinelmarine water bodies based on current usuage patterns that 

include coastal areas. Therefore, testing is required for Leptocheirusplumulosus, an 

estuarinelmarine sediment-dwelling invertebrate species. The previously-submitted 28- 

day sediment test for cyfluthrin with Leptocheirusplumulosus (MRID 4659 1506) does 

not include reproductive endpoints, and does not fulfill this data requirement for 

estuarinelmarine benthic invertebrates. 

Guideline Numbers: 850.4100 and 850.4150 

Study Title: Vegetative vigor and Seedling emergence, Tier I/ Tier I1 

No acceptable toxicity data are currently available to assess the risk of cyfluthrin to nontarget terrestrial plants. Since cyfluthrin has residential outdoor uses, vegetative vigor and 

seedling emergence studies are required. Additionally, three incidents have been reported 

to the Agency where cyfluthrin was identified as the possible - highly probable cause of 

phytotoxic damage. Phytotoxicity data are needed to evaluate the level of pesticide 

exposure to non-target terrestrial and aquatic plants and to assess the impact of pesticides 

on endangered and threatened plants. 

Guideline Number: 850.4400 

Study Title: Aquatic Vascular Plant Growth-Lemna spp. Tiers 1/11 

No studies for cyfluthrin have been submitted for vascular aquatic plants. The Agency 

has finalized its update to the data requirements in 40 CFR Part 158, which were 

promulgated on October 26,2007. In these updated data requirements, vascular plant 

testing is required for pesticides with outdoor uses, such as cyfluthrin. 

In addition to the above mentioned data requirements for cyfluthrin, the following; 

are required for beta-cvfluthrin as per the EFED Interim Policv for Stereoisomeric 

~esticides,~ which savs the following: 

"OPP requires the following minimal data set using species and conditions 

(including testing laboratories) that are identical to those for the data submitted 

for the previous racemic mixture. If the toxicity values are substantially similar 

for the racemic and enantiomeric enriched mixture and do not result in 

sign lJicantly greater potential risk, then no additional ecotoxicity data are 

needed. a however, the toxicity data for the racemic and enantiomeric enriched 

mixture differ significantly and suggests that the enriched mixture poses a 

signzj?cantly greater risk, then additional ecotoxicity data may be required on a 

case-by-case basis. " 

The data required in the interim policy is as follows: 

Avian 

Available at http://~ww.epa.gov/o~pefedI/ecorisk~ders/stereoisomer~lic~.htm . 

70 
Guideline 850.2100 - Acute Avian Oral -Inspection of the available results for 

cyfluthrin shows that the acute endpoint (LDS0) was >5000 mgtkg bw for both 

mallard duck and bobwhite quail (practically non-toxic). 

o Since cyfluthrin shows low toxicity towards bobwhite quail and mallard 

species, EFED is not requiring the data for beta-cyfluthrin at this time. 

Guideline 850.2300 - Avian Reproduction - required if birds are more sensitive 

than mammals. 

o Preliminary inspection of available data for cyfluthrin indicates that birds 

are less sensitive to the chemical compared to mammals. Studies 

examining beta-cyfluthrin reproductive effects to mammals have been 

submitted. Therefore, at this time, no additional data are required for betacyfluthrin. 

Aquatic 

Guideline 850.1075 or 850.1010 - Acute Freshwater Fish Toxicity or Acute 

Freshwater Invertebrate Toxicity - Several tests with beta-cyfluthrin tedhnical 

were submitted for freshwater fish, freshwater invertebrates and estuarinefmarine 

invertebrates. Two studies with mysids were determined to be acceptable. All 

other aquatic studies with beta-cyfluthrin were deemed supplemental. 

o The most sensitive species based on registrant-submitted data is 

Mysidopsis bahia. At this time, no additional data are required for betacyfluthrin effects on mysids. 

Guideline 850.1400 or 850.13001 850.1350 - Fish Early Life Stage or 

Invertebrate Life Cycle - test most sensitive species from previous studies with 

cyfluthrin. 

o Required for beta-cyfluthrin. Preliminary inspection of the results ' 

indicates that the most sensitive species is Mysidopsis bahia. 

Nontarget Plant 

Guideline 850.4100 or 850.4150 - Seedling Emergence or Vegetative Vigor 

Test most sensitive monocotyledon and dicotyledon based on results of c$fluthrin 

terrestrial plant toxicity tests. No data is available for cyfluthrin. 

o Required for beta-cyfluthrin. 

Guideline 850.4400 - Aquatic Plant Growth, Lemna gibba 

No data is available for cyfluthrin. 

o Required for beta-cyfluthrin. 

Guideline 850.5400 - Aquatic Plant Growth, algae -The available acceptable 

study conducted on cyfluthrin shows that the EC50 was non-definitive (>I81 pg 

a.i./L). 

o Since the highest level tested is much greater than the preliminary peak 

aquatic estimated exposure concentration (EEC) (1.62 pg a.i./L baked on 

the PRZMI EXAMS MS cotton scenario), no additional nonvascular 

aquatic plant data are required at this time for beta-cyfluthrin. 
Table 7.2 lists the status of the ecological effects data requirements for cyfluthrin and 

beta-cyfluthrin. All additional data requests are for cyfluthrin only, with the exception of 

invertebrate life cycle, seedling emergence, vegetative vigor and vascular aquatic plant 

growth studies required for beta-cyfluthrin (see footnote section of table for each of these 

data requests). 

Table 7.2. Ecological Effects Data Requirements for Cyfluthrin and Beta-cyfluthrin 

Does EPA Have Must 

Data To Satisfy Additional 

This Data Be 

Requirement? Submitted 

Use (Yes, No, or Bibliographic Under FIFRA 

Data Requirement pattern1 Partially) Citation (MIRTD) 3(~)(2)(B)? 

5158.490 WILDLIFE AND AQUATIC ORGANISMS 

71-l(a) Acute Avian Oral, 

QuaiVDucMPasserine 

Partially Yes, passerine 

study 

 NO^ 

 NO^ 

7 1 -2(a) Acute Avian Diet, Quail Yes 

7 1 -2(b) Acute Avian Diet, Duck Yes 

7 1-3 Wild Mammal Toxicity 

7 1 -4(a) Avian Reproduction Quail 

71-4(b) Avian Reproduction Duck 

Yes 

No 

7 1 -5(a) Simulated Terrestrial Field Study 

7 1-5(b) Actual Terrestrial Field Study 

72-l(a) Acute Fish Toxicity Bluegill Yes 

72-l(b) Acute Fish Toxicity Bluegill Yes 

(TEP) 

72-l(c) Acute Fish Toxicity Rainbow 

Trout 

Yes 

72-l(d) Acute Fish Toxicity Rainbow 

Trout (TEP) 

Yes 

72-2(a) Acute Aquatic Invertebrate Yes 

72-2(b) Acute Aquatic Invertebrate (TEP) 

72-3(a) Acute EstIMar Toxicity Fish 

72-3(b) Acute EstMar Toxicity Mollusk 

72-3(c) Acute Est/Mar Toxicity Shrimp 

Yes 

Yes 

Yes 

Yes 

72-3(d) Acute Est/Mar Toxicity Fish 

(TEP) 
Table 7.2. Ecological Effects Data Requirements for Cyfluthrin and Beta-cyfluthrin 

Does EPA Have Must 

Data To Satisfy Additional 

This Data Be 

Requirement? Submitted 

Use (Yes, No, or Bibliographic Under FIFRA 

Data Requirement pattern1 Partially) Citation (MRID) 3(~)(2)(B)? 

72-3(e) Acute EsttMar Toxicity Mollusk 192 No 

(TEP) 

72-30 Acute Est/Mar Toxicity Shrimp 1,2 No 

(TEP) 

72-4(a) Early Life Stage Fish 1, 2 Yes 41450401 No 

72-4(b) Life Cycle Aquatic Invertebrate 172 Yes 00132761,00162969 yes6 

72-5 Life Cycle Fish 1,2 Yes 00151442 No 

72-6 Aquatic Organism Accumulation 1,2 

72-7(1) Simulated Aquatic Field Study 1,2 

72-7(b) Actual Aquatic Field Study 1,2 

No 

No 

No 

Whole sediment: acute freshwater Yes 

invertebrates 

Whole sediment: acute marine invertebrates 1,2 Yes 

Whole sediment: chronic invertebrates 1,2 No 

freshwater & marine 

Non-guideline Aquatic Invertebrate Acute 

Toxicity (HyaZeZZa) 1,2 Yes 

3158.540 PLANT PROTECTION 

122-l(a) Seed Germ, Seedling Emergence 14 

122-l(b) Vegetative Vigor 

122-2 Aquatic Plant Growth 

124-1 Terrestrial Field Study 

124-2 Aquatic Field Study 

9158.490 NONTARGET INSECT TESTING 

14 1-1 Honey Bee Acute Contact 1,2 

141-2 Honey Bee Residue on Foliage 1,2 

14 1-5 Field Test for Pollinators 1,2 

$158.630 AQUATIC ORGANISMS TESTING 

850.1730 Bioaccumulation in Fish 1,2 

Yes 

No 

No 

Yes 
Table 7.2. Ecological Effects nata Requirements for Cyfluthrin and Beta-cyfluthrin 

Does EPA Have Must 

Data To Satisfy Additional 

Thfs Data Be 

Requirement? Submitted 

Use (Yes, No, or Bibliographic Under FIFRA 

Data Requirement pattern1 Partially) Citation (MRDD) 3@)(2)(B)? ' Use Patterns: (l=Terrestrial/Food; 2=Terrestrial/Feed). 

Original review classified the study as acceptable, completed in 1983 by W. Faatz. Study not required at this time as the 

study is acceptable based on a cursory review, but may be required pending additional evaluation of the data. 3 A bluegill toxicity test with an end-use product has been submitted for cyfluthrin, but the study was classified as 

supplemental. However, TEP data has been submitted for the most acutely sensitive fish species, rainbow trout so the data 

requirement is waived. 

Both submitted chronic studies for mallard duck are classified as supplemental. Therefore, a new study is requested. 

4 Based on preliminary calculations (see Appendix D), the peak aquatic EEC is 1.62 pg a.i./L using the PRZMI EXAMS 

MS cotton scenario. In estuarinelmarine tests conducted with cyfluthrin technical, the lowest 96-hour LC50 was 4.05 pg/L 

for sheepshead minnow, 0.0022 pg/L for mysid shrimp and 2.69 pg/L for the eastern oyster. Therefore, cyfluthrin fulfills 

the requirements for requesting TEP studies with all tested estuarinelrnarine invertebrate species, but not estuarinelmarine 

fish (According to Part 158, for TEP data requests, the maximum expected environmental concentration or estimated 

environmental concentration in the aquatic environment is greater than or equal to one-half the LC50 or EC~O of the TGAI). 

Data are required for beta-cyfluthrin. 

Data in review. According to current Part 158 guidelines, only chronic sediment studies would be requested for cyfluthrin. 7 Data required for chironomids, Hyalella azteca and Leptocheivusplurnulosus. 

Studies are required for cyfluthrin and beta-cyfluthrin. For beta-cyfluthrin, the most sensitive monocotyledon and 

dicotyledon should be tested from tests with cyfluthrin. 

9 Aquatic toxicity tests are required for aquatic vascular plant species. A test has been submitted for green algae 

(acceptable), but the EC50 was non-definitive (>I8 1 yg a.i./L). Because the highest level tested is much greater than the 

preliminary peak aquatic estimated exposure concentration (EEC) (1.62 pg ai/L based on the PRZMIEXAMS MS cotton 

scenario), no additional nonvascular aquatic plant data is requested at this time. A study should be conducted on betacyfluthrin (vascular aquatic plant study only). 
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Environmental Fate Cyfluthrin 

161 -1 Hydrolysis 

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3125-EX-188; submitted by Mobay Chemical Corp., Kansas City, MO; 

CDL:072003-B) 

137539 Sandie, F.; Thornton, J. (1983) Hydrolysis of Baythroid in Sterile, Aquebus 

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3125-351; submitted by Mobay Chemical Corp., Kansas City, MO; 

CDL:072361 -B) I 

137543 Puhl, R.; Hurley, J.; Dime, R. (1983) Photodecomposition of Bayth- roid-14C in 

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1984 under 3125-351; submitted by Mobay Chemical Corp., Kansas C ty, MO; 

CDL:072362-B) 

t 

MRlD Citation Reference 

149596 Mobay Chemical Corp. (I 984) Baythroid: Addition No. 1, January 6, 19184, 

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157043 Chopade, H. (1 986) Photodecomposition of [Carbon 141 Baythroid on Soil: 

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162-1 Aerobic soil metabolism 

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162-4 

MRlD 

163-1 

MRlD 

Aerobic aquatic metab. 

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163-3 Volatility - field 

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149596 Mobay Chemical Corp. (1984) Baythroid: Addition No. 1, January 6, 1984, 

Brochure No. 1239 to Brochure Entitled: Baythroid: The Effects on the 

Environment (Dated September 16, 1983):[Attached: 1. Studies on 

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164-1 Terrestrial field dissipation 

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42794801 Grace, T.; Cain, K. (1990) Dissipation of Cyfluthrin in California Soils: Lab 

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4482290 1 Lam, C.; Dehart, B.; Barney, W. (1995) Terrestrial Field Dissipation of Gyfluthrin 

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247 p. 

42752901 Lin, J. (1993) Field Measurement of Cyfluthrin Fate and Runoff from a Cotton 

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ACC 2591 1 1 Ash, C.R. 1983 Residues in Arizona soil 

ACC 2591 11 McMullen, P.W. 1983 Residues in Ontario Soil 

ACC 2591 11 Warren, J.W. 1983 Residues in Oregon soil 

Acc 2591 1 1 Meriweather, B.K. 1983 Residues in Mississppi soil 

ACC 2591 11 Robertson, R.E., 1983 Residues in Kansas soil 

ACC 2591 1 1 Rogers, W.D. 1983 Residues in Georgia soil 

ACC 2591 11 Fleming, M.O. 1983 Residues in Florida soil 

ACC 2591 11 Price, D.A. 1983 Residues in Florida soil 
165-2 Field rotational crop 

MRlD Citation Reference 

40942701 Leslie, W. (1988) Baythroid--Residues in Field Rotational Cereal Crops: Project 

ID; BD850086R01: Mobay Project ID: Objective No. 8500. Unpublished study 

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41 190202 Leslie, W. (1 989) Baythroid--Residues in Field Rotational Cereal Crops-- 

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165-4 Bioaccumulation in fish 

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143143 Carlisle, J.; Roney, D. (1984) Bioconcentration of Cyfluthrin (Baythroid) by 

Bluegill Sunfish: Study Number 83-766-01. Unpub- lished study prepared by 

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Brochure No. 1239 to Brochure Entitled: Baythroid: The Effects on the 

Environment (Dated September 16, 1983):[Attached: 1. Studies on 

Environmental Fate in Soil; 2. Accumulation Study in Bluegill Sunfish]. 

Unpublished study. 171 p. 

202-1 Drift field evaluation 

MRlD Citation Reference 

143144 Olson, T. (1984) Evaluation of Spray Drift Following Aerial ULV Applications of 

Baythroid 2. Unpublished study prepared by Mobay Chemical Corp. in 

cooperation with Chemonics Industries. 147 p. 

Not Available McDaniel, S.G. 

850.71 00 Data reporting for environmental chemistry 

methods 

MRlD Citation Reference 

47053001 Robinson, N. (2007) Residue Analytical Method for the Determination of 

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study prepared by Syngenta Jealotts Hill International. 185 p. 

47053002 Reed, R. (2006) Laboratory Validation: Validation of the Residue Analytical 

Method: Residue Analytical Method for the Determination of Residues of 

Bifenthrin, Cypermethrin, Cyfluthrin, Deltamethrin, Esfenvaierate, 

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Environmental Fate Beta-Cyfluthrin 

162-4 Aerobic aquatic metabolism 

MRlD Citation Reference 

468241 01 Dyer, D.; Sabbagh, G. (2006) Cyfluthrin - Aerobic Aquatic Metabolism 

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Non Guideline Selections 

47647801 Hanzas, J.; Stone, C.; Toth, B.; et al. (2008) Bifenthrin and Beta-Cyfluthrin: 

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Ecological Effects Cyfluthrin 

I Avian Single Dose Oral Toxicity 

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131498 Carlisle, J.; Carsel, M.; Lamb, D. (1983) Acute Oral LD50 of Tech- nical 

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received Oct 12, 1983 under 3125-EX-188; submitted by Mobay Chemical 

Corp., Kansas City, MO; CDL: 072004-B) 

143142 Thyssen, J. (1980) Acute Oral Toxicity to Quails: FCR 1272: Study No. 

12721048. Unpublished Mobay study no. 82347 prepared by Bayer lnskitute of 

Toxicology. 6 p. 

42005407 Toll, P. (1991) Aztec 2.1 percent Granular: An Acute Oral LD50 with ~bbwhite 

Quail (Colinus virginianus): Lab Project No: M4711701: 101219. Unpublished 

study prepared by Mobay Corp. 33 p. 

42005408 Toll, P. (1 990) Aztec 2.1 (percent) Granular: An Acute Oral LD50 with house 

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71 -2 Avian Dietary Toxicity 
MRlD Citation Reference 

131497 Mobay Chemical Corp. (1983) Synopsis of Environmental Toxicology of FCR 

1272 (Cyfluthrin): (Summary). (Unpublished study re- ceived Oct 12, 1983 

under 3125-EX-1 88; CDL:072004-A) 

131 500 Carlisle, J.; Toll, P.; Lamb, D.; et al. (1983) Acute Dietary LC50 of Cyfluthrin 

Technical to Mallard Ducks: Study No. 83-1 75-02; 85937. (Unpublished study 

received Oct 12, 1983 under 3125-EX- 188; submitted by Mobay Chemical 

Corp.., Kansas City, MO; CDL: 072004-D) 

131 501 Carlisle, J.; Carsel, M.; Lamb, D.; et al. (1983) Acute Dietary LC50 of Cyfluthrin 

Technical to Bobwhite Quail: Study No. 83- 175-05; 85943. (Unpublished study 

received Oct 12, 1983 under 3125-EX-188; submitted by Mobay Chemical 

Corp., Kansas City, MO; CDL:072004-E) 

71 -4 Avian Reproduction 

MRlD Citation Reference 

145330 Carlisle, J. (1984) Effect of Cyfluthrin (Baythroid Technical) on Bobwhite Quail 

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145331 Carlisle, J. (1984) Effect of Cyfluthrin (Technical Baythroid) on Mallard Duck 

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152829 Carlisle, J. (1985) Effects of Cyfluthrin (Baythroid Technical) on Bobwhite Quail 

Eggshells: Study No. 85-675-04: Mobay Report No. 90275. Unpublished study 

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158782 Beavers, J. (1986) Baythroid Technical: A One-generation Reproduc- tion Study 

with the Mallard (Anas platyrhynchos): Final Report: Project No.: 149-1 17. 

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118 p. 

71 -5 Simulated or Actual Field Testing 

MRlD Citation Reference 

4200541 5 Fischer, D. (1991) Simulated Field Study of Acute Hazard to House Sparrows 

and Juvenile Northern Bobwhite Posed by Applications of Aztec 2.1% 

Granular Insecticide to Cornfields: Lab Project Num- ber: M4752302: 101313. 

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42752601 Idema, P.; Kolaszar, T.; Perritt, J.; et al. (1993) Aztec 2.1% Granular 

Insecticide: An Evaluation of its Effects Upon Avian Species in and around 

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Phostebuprim/Cyfluthrin 

72-1 Acute Toxicity to Freshwater Fish 
Citation Reference 

145332 

ACC 72004 

45375001 

Beta-Cyfluthrin 

PC Code 

1 18831 

45375002 

Beta-Cyfluthrin 

PC Code 

11 8831 

45375003 

Beta-Cyfluthrin 

PC Code 

I 18831 

45426703 

Beta-Cyfluthrin 

PC Code 

118831 

41 558002 

Mobay Chemical Corp. (1983) Synopsis of Environmental Toxicology of FCR 

1272 (Cyfluthrin): (Summary). (Unpublished study re- ceived Oct 12, 1983 

under 31 25-EX-1 88; CDL:072004-A) 

Carlisle, J.; Carsel, M.; Lamb, D. (1983) Acute Toxicity of Cyflu- thrin Technical 

to Rainbow Trout: Study No. 83-066-02; 85701. (Unpublished study received 

Oct 12, 1983 under 3125-EX-188; submitted by Mobay Chemical Corp., 

Kansas City, MO; CDL: 072004-F) 

Carlisle, J.; Roney, D.; Lamb, D. (1983) Acute Toxicity of Cyflu- thrin Technical 

to Bluegill Sunfish: Study No. 83-066-05; 85809. (Unpublished study received 

Oct 12, 1983 under 31 25-EX-188; submitted by Mobay Chemical Corp., 

Kansas City, MO; CDL: 072004-G) 

Carlisle, J. (1984) Acute Toxicity of Cyfluthrin to Rainbow Trout: Study No. 84- 

066-05. Unpublished study prepared by Mobay Chem- ical Corp. 10 p. 

Carlisle, J. (1 984) Acute Toxicity of Fluorphenoxybenzaldehyde to Rhinbow 

Trout: 86696: Study No. 84-066-07. Unpublished study prepared by Mobay 

Chemical Corp. I I p. 

Carlisle, J. (1984) Acute Toxicity of Dichlorvinylcarboxylic Acid to Rainbow 

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Bowman, J. (1989) Acute Flow-through Toxicity of Tempo 2 EC to Blue gill 

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Bowman, J.; Leak, T. (1991) Acute Flow-through Toxicity of (Carbon 14) Aztec 

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Bowers, L. (1 994) Acute Toxicity of (carbon 14)-FCR 4545 to the Rainbow 

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Surprenant, D. (1 991) Acute Toxicity of FCR 4545 Technical to Rainbdw Trout 

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Surprenant, D. (1991) Acute Toxicity of FCR 4545 Technical to Bluegill 

(Lepomis macrochirus) Under Flow-Through Conditions: Lab Project Number: 

103232: 274.0387.6121 .105: 89-5-2985. Unpublished study prepared by 

Springborn Labs., Inc. 57 p. 

Grau, R.; Kollbach, R.; Kohler, J. (1988) The Acute Toxicity of FCR 4545 

(Techn.) to Rainbow Trout (Salmo gairdneri) in a Flow-Through Test: Lab 

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Bowman, J. (1989) Acute Flow-through Toxicity of ?carbon 141-Tempo 2 EC 

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45426707 Gagliano, G. (1994) Acute Toxicity of (Carbon 14)-Cyfluthrin to the Bluegill 

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45426706 Bowers, L. (1994) Acute Toxicity of (Carbon 14)-FCR 4545 to the Bluegill 

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45426705 Bowers, L. (1994) Acute Toxicity of (Carbon 14)-Cyfluthrin to the Rainbow 

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45426708 Gagliano, G.; Bowers, L. (1994) Acute Toxicity of (Carbon 14)-Cyfluthrin to the 

Befa-Cyfluthrin Rainbow trout (Oncorhynchus mykiss) Under Flow-Through Conditions: Lab 

Project Number: BD812201: 106778. Unpublished study prepared by Miles 

Incorporated. 33 p. 

72-2 Acute Toxicity to Freshwater Invertebrates 

MRlD Citation Reference 

131497 Mobay Chemical Corp. (1983) Synopsis of Environmental Toxicology of FCR 

1272 (Cyfluthrin): (Summary). (Unpublished study re- ceived Oct 12, 1983 

under 31 25-EX-1 88; CDL:072004-A) 

131504 Carlisle, J.; Carsel, M.; Lamb, D. (1983) Acute Toxicity of Techni- cal Cyfluthrin 

(Baythroid) to Daphnia magna: Study No. 83-067- 05; 85944. (Unpublished 

study received Oct 12, 1983 under 3125-EX-1 88; submitted by Mobay 

Chemical Corp., Kansas City, MO; CDL:072004-H) 

158555 Forbis, A,; Burgess, D. (1984) Acute Toxicity of FPB ALD to Daphnia magna: 

Report 31761. Unpublished study prepared by Analytical Bio-Chemistry Labs, 

lnc..35 p. 

158556 Forbis, A.; Burgess, D. (1984) Acute Toxicity of DCVA to Daphnia magna: 

Report 31762. Unpublished study prepared by Analytical Bio-Chemistry Labs, 

Inc. 35 p. 

41494001 Suprenant, D. (1 990) Acute Toxicity of (Carbon 14)-Baythroid to Crayfish 

(Procambus clarkii) under Flow-through Conditions: Lab Project I.D. 87-7- 

2434: Mobay Report No. 100108. Unpublished study prepared by Mobay 

Corp., Agricultural Chemicals Div. 58 p. 

41 558003 Burgess, D. (1989) Acute Flow-through Toxicity of ?carbon 141-Tempo 

(Cyfluthrin) to Daphnia magna: Lab Project Number: 37593: 99848. 

Unpublished study prepared by Analytical Bio-Chemistry Labora- tories, Inc. 

30 p. 

42005429 Blakemore, G.; Hicks, S.; Burgess, D. (1991) Acute Toxicity of ?carbon 141 

Aztec to Daphnia magna under Flow-through Conditions :Lab Project Number: 

38625: 10121 8. Unpublished study prepared by Analytical Bio-Chemistry 

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42705801 Burgess, D. (1990) Acute Flow-through Toxicity of (carbon 14)-Cyfluthrin to 

Daphnia magna: Lab Project Number: 37684: 100321. Unpublished study 

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45426701 Forbis, A. (1988) Acute Toxicity of FCR 4545-1 Technical to Daphnia Magna 

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11 8831 ' Unpublished study prepared by ABC Laboratories, Inc. 30 p. 

45426702 Heimbach, F. (1988) Acute Toxicity of FCR 4545 (Techn.) to Water Fleas: Lab 

Beta-Cyfluthrin Project Number: 98561. Unpublished study prepared by Bayer AG. 13 p. 

45375003 Surprenant, D. (1991) Acute Toxicity of FCR 4545 Technical to Bluegill 

Beta-cyfluthrin (Lepomis macrochirus) Under Flow-Through Conditions: Lab Project Number: 

PC Code 103232: 274.0387.6121 .I 05: 89-5-2985. Unpublished study prepared by 

1 18831 Springborn Labs., Inc. 57 p. 

42605801 

Wrong MRlD May be same study as 41 558003 

72-3 Acute Toxicity to EstuarineIMarine Organisms 

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1461 18 Barrows, B. (1 984) Shell Deposition in Eastern Oyster (Crassostrea virginica) 

Exposed to Cyfluthrin Technical in a Static Test System: Project No. 84E060CV. Unpublished study prepared by Biospherics, Inc. 10 p. 

146485 Barrows, B. (1 984) The Static Acute Toxicity of Cyfluthrin Technical to the 

Sheepshead Minnow, Cyprinodon varieqatus: Project No. 84E-060SHM: 

Report No. 88914. Unpublished study prepared by Biospherics Incorpdrated. 

14 p. 

149598 Ward, G. (1985) Toxicity Test Report: Acute Toxicity of Cyfluthrin to thd 

Saltwater Mysid, Mysidopsis bahia: ESE No. 85-31 7-0200- 21 30: Mobay 

Report No. 90274. Unpublished study prepared by Environmental Sciehce and 

Engineering, Inc. 19 p. 

158783 Carr, R. (1 986) The Oyster Shell Deposition Test To Assess the Acute Effects 

of Baythroid on the Eastern Oyster, (Crassostrea virginica): Final Repqrt: 

Project No. N 07780100. Unpublished Mobay Report No. 91889 prepated by 

Battelle New England Marine Research Laboratory. 95 p. 

40069501 Surprenant, D. (1987) Acute Toxicity of Baythroid to Mysid Shrimp (Myisidopsis 

bahia) under Flow-through Conditions: Bionomics Report #BW-87-1-2277: 

Bionomics Study #274.1286.6115.515. Un- published Mobay report 94220 

prepared by Springborn Bionomics, Inc. 218 p. 

4481 5301 Cunningham, F. (1996) MAT 7484: Acute Effect on New Shell Growth pf the 

Eastern Oyster (Crassostrea virginica): Lab Project Number: J960400gD: 

107660: 107370. Unpublished study prepared by Toxikon Environmenqal 

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4481 5302 Cunningham, F. (1996) MAT 7484: Acute Toxicity to Mysid Shrimp 

(Mysidopsis bahia) Under Flow-Through Conditions: Lab Project Number: 

J9604005C: 107524: 107527. Unpublished study prepared by Toxikon 

Environmental Sciences. 74 p. 

4481 5303 Cunningham, F. (1996) MAT 7484: Acute Toxicity to the Sheepshead Minnow 
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59608008: 107666: 107527. Unpublished study prepared by Toxikon 

Environmental Sciences. 73 p. 

46591 506 Putt, A. (2005) Cyfluthrin - Toxicity to Estuarine Amphipods (Leptocheirus 

plumulosus) During a 28-Day Sediment Exposure. Project Number: 

13656161 16. Unpublished study prepared by Springborn Smithers 

Laboratories. 85 p. 

45426704 Machado, M. (1994) Acute Toxicity of FCR 4545 to Mysid Shrimp (Mysidopsis 

Befa-cyfluthrin bahia) Under Flow-Through Conditions: Lab Project Number: 

= PC Code 13507.1 293.61 05.51 5: 106588. Unpublished study prepared by Springborn 

11 8831 Laboratories Incorporated. 72 p. 

45426709 Machado, M. (1 994) Acute Toxicity of FCR 4545 to the Mysid Shrimp 

(Mysidopsis bahia) Under Flow-Through Conditions: Lab Project Number: = PC 106797: 13507.0894.61 08.51 5. Unpublished study prepared by Springborn 11 8831 Laboratories Incorporated. 72 p. 

72-4 Fish Early Life StageIAquatic Invertebrate Life Cycle 

Study 

MRlD Citation Reference 

145333 Carlisle, J. (1984) Toxicity of Cyfluthrin (Baythroid) to Rainbow Trout Early Life 

Stages: Study No. 83-666-05. Unpublished study prepared by Mobay 

Chemical Corp. 13 p. 

151 442 Forbis, A.; Burgess, D.; Franklin, L.; et al. (1984) Chronic Toxi- city of [Carbon 

141-Cyfluthrin to Daphnia magna under Flow- through Test Conditions: Final 

Report #31763. Unpublished Mobay Report No. 88690 and Toxicology Report 

No. 557 prepared by Ana- lytical Bio-Chemistry Laboratories, Inc. 255 p. 

155898 Carlisle, J. (1 985) Toxicity of Cyfluthrin (Baythroid) Technical to Early Life 

Stages of Rainbow Trout: Study No. 85-666-01. Unpub- lished study prepared 

by Mobay Chemical Corp. 20 p. 

158781 Ward, G. (1986) Effects of Cyfluthrin on Survival, Growth, and Development of 

Sheepshead Minnow (Cyprinodon variegatus): ESE No. 85-317-0830-2130. 

Unpublished Mobay Report No. 91887 prepared by Environmental Science 

and Engineering, Inc. 29 p. 

158784 Carr, R. (1986) Chronic Toxicity of Baythroid to the Sheepshead Minnow, 

Cyprinodon variegatus: Final Report: Project No. N 0778-0100. Unpublished 

Mobay Report No. 91890 prepared by Battelle New England Marine Research 

Lab. 115 p. 

158785 Hoberg, J.; Breteler, R. (1986) Chronic Toxicity of Baythroid to Opossum 

Shrimp (Mysidopsis bahia): Report #BW-86-3-1964; Study #274-0286-6106- 

530. Unpublished Mobay Report No. 91891 prepared by Springborn 

Bionomics, Inc. 59 p. 

164499 Brussell, G. (1 986) Letter sent to G. LaRocca dated Oct 29, 1986: Baythroid 2 

on cotton: [Including Page 9 of Mobay report no. 91890 and supporting raw 

data for Mobay report no. 91 890, 91 887 and 91 8911. Prepared by Mobay 

Chemical Corp. 2307 p. 
40047301 Breteler, R. (1987) Chronic Toxicity of Baythroid to Opossum Shrimp 

(Mysidopsis bahia): Report #BW-86-3-1964: Study #274-0286-6106- 530. 

Unpublished Mobay report #91891 prepared by Springborn Bionomics, Inc. 

148 p. 

41450401 Rhodes, J.; McAllister, W.; Leak, T.; et al. (1990) Full Life-cycle Toxicity of 

?Carbon 141-Cyfluthrin (Baythroid) to the Fathead Minnow (Pimephales 

promelas) under Flow-through Conditions: Final Report #33821: Mobay Report 

No. 100097. Unpublished study prepared by Analytical Bio-Chemistry 

Laboratories, Inc. 905 p. 

40359001 Breteler, R. (1986) Chronic Toxicity of Baythroid to Opussum Shrimp 

(Mysidopsis bahia): Supplemental Submission to Mrid No. 158785: 

Addendum to Mobay Report No. 91891: Study No.: 274-0286-6106- 530 

Unpublished study prepared by Springborn Bionomics, Inc. 12 p. 

40359002 Carlisle, J. (1985) Toxicity of Cyfluthrin (Baythroid) Technical to Early Life 

Stages of Rainbow Trout: Supplemental Submission to Mrid No. 15G898: 

Addendum to Mobay Report No. 90801: Study No.: 85-66601. Unpublished 

study prepared by Mobay Corp. 22 p. 

72-5 Fish Full Lifecycle Study 

41450401 Rhodes, J.; McAllister, W.; Leak, T.; et al. (1990) Full Life-cycle Toxicity of 

?Carbon 141-Cyfluthrin (Baythroid) to the Fathead Minnow (Pimephales 

promelas) under Flow-through Conditions: Final Report #33821: Mobay Report 

No. 100097. Unpublished study prepared by Analytical Bio-Chemistry 

Laboratories, Inc. 905 p. 

72-7 Simulated or Actual Field Testing 

MRlD Citation Reference 

41 51 1301 Kennedy, J.; Johnson, P.; Montandon, R. (1990) Assessment of the Potential 

Ecological/Biological Effects of BAYTHROID (Cyfluthrin) utilizing Artificial Pond 

Systems: Lab Project Number: 1001 47. Unpublished study prepared bi/ 

University of North Texas. 1600 p. 

42005434 Graney, R.; Giddings, J. (1991) Aztec: Aquatic Microcosm Test for 

Environmental Fate and Ecological Effects: Lab Project Number: M48812401: 

101293. Unpublished study prepared by ABC Labs, Inc. in coop. with Mobay 

Corp. and Springborn Labs. 321 p. Mixture 2 ais 

42734801 Graney, R.; Gagliano, G. (1 993) Response to EPA Review of: Assesdment of 

the Potential Ecological 1 Biological Effects of BAYTHROID (Cyfluthrin) 

Utilizing Artificial Pond Systems: Supplemental Report: Lab Project Nutnber: 

100147-1. Unpublished study prepared by University of North Texas. 6/32 p. I 

123-2 Aquatic plant growth 

MRlD Citation Reference 

41450402 or Heimbach, F. (1984) Growth Inhibition of Green Algae (Scenedesmus 

158558 subspicatus) caused by FCR 1272 (Technical): Report No. 99836. 

Unpublished study prepared by Bayer AG, Institute for Environmental Biology. 
43984901 Dobbs, M. (1996) Toxicity of Cyfluthrin to the Green Alga, Selenastrum 

capricornutum: Lab Project Number: 107333: BD883501. Unpublished study 

prepared by Bayer Corp. 36 p. 

158558 Heimbach, F. (1 984) Growth Inhibition of Green Algae (Scenedesmus 

subspicatus) by FCR 1272 (Technical): Report HBFlA102: Study No. A1 

04/84. Unpublished study prepared by Bayer AG. 15 p. 

141-1 Honey bee acute contact 

MRlD Citation Reference 

153638 Atkins, E. (1 984) Letter sent to C. Engle dated Nov 21, 1984: Honey bee adult 

worker (BATDT) laboratory LDl50 toxicity study with cyfluthrin, Bathroid] (sic). 

Prepared by Univ. of California, Riverside, Dept. of Entomology. 32 p. 

47775501 Chauzat, M.; Carpentier, P.; Martel, A.; et al. (2009) Influence of Pesticide 

Residues on Honey Bee (Hymenoptera: Apidae) Colony Health in France. 

Environmental Entomology 38(3): 514-523. 

47796306 Marletto, F.; Patetta, A.; Manino, A. (2003) Laboratory Assessment of 

Pesticide Toxicity to Bumblebees. Bulletin of lnsectology 56(1): 155-158. 

162586 Schmidt, H. (1985) [Bee Toxicity of Baythroid Sprayed on Alfalfa]: Report No. 

VAZ 16/85. Unpublished study prepared by Bayer AG. 18 p. 

141-2 Honey bee residue on foliage 

MRlD Citation Reference 

158786 Bayer AG (1 986) Letter sent to Mobay Chemical Corp. dated March 10, 1986: 

Honey bee residue testing1Baythroid: [Foliar residues in Alfalfa]: Mobay Report 

No. 91915. 39 p. 

47800530 Chauzat, M.; Carpentier, P.; Martel, A.; et al. (2009) Influence of Pesticide 

Residues on Honey Bee (Hymenoptera: Apidae) Colony Health in France. 

Environ. Entomol. 38(3):514-523. 

47796308 Gels, J.; Held, D.; Potter, D. (2002) Hazards of Insecticides of the Bumble 

Bees Bombus impatiens (Hymenoptera: Apidae) Foraging on Flowering White 

Clover in Turf. J. Econ. Entomol. 95(4): 722-728. 

850.1790 Chironomid Sediment Toxicity Test 

MRlD Citation Reference 

46871 501 Giddings, J. (2006) Overview of Sediment Toxicity Studies with Synthetic 

Pyrethroids. Project Number: 06723, 06273. Unpublished study prepared by 

Compliance Services International. 62 p. 

46591 507 Putt, A. (2005) Cyfluthrin - Toxicity to Midge (Chironomus tentans) During a 

10-Day Sediment Exposure. Project Number: 13656161 15. Unpublished study 
prepared by Springborn Smithers Laboratories. 89 p. 

Non Guideline Selections 

157786 Machemer, L.; Eben, A.; Thyssen, J. (1983) Toxicity of Pyrethroids in 

Warmblooded Animals with Special Reference to Cyfluthrin. Unpublished paper 

presented at the International Conference on Environmental Hazards af 

Agrochemicals in Developing Countries; Vol. 1; Nov 8-12,1983, AleMandria, 

Egypt. 20 p. 

42005416 Fischer, D. ; Toll, P (1991) Measurement of Whole Blood and Brain Aztec = Cholinesterase Activity in House Sparrows Given a Sub-lethal Dose of Aztec 29086 + 2.1 % Granular Insecticide: Lab Project Number: M4761401: 101 31 2. 128831 

mixture Unpublished study prepared by Mobay Corp. 21 p. 

4200541 8 Fischer, D.; Best, L. (1 991) Oral Exposure of Birds to Silica Gran- ules Applied 

at-Planting to Cornfields: Lab Project Number: GE761402: 101315. Unpublished 

study prepared by Mobay Corp. 32 p. 

4200541 9 Best, L.; Gionfriddo, J. (1990) Literature Review of Grit Use by Birds: Lab Project 

Number: 99846. Unpublished study prepared by lowa State Univ., Dept. of 

Animal Ecology and Agrobirds. 69 p. 

42005420 Best, L.; Gionfriddo, J. (1990) Characterization of Natural Grit Use in House 

Sparrows: Lab Project Number: 99847. Unpublished study prepared by lowa 

State Univ., Dept. of Animal Ecology and Agrobirds. 29 p. 

42005421 Best, L.; Gionfriddo, J. (1990) Characterization of Grit Use by 22 Species of 

Birds Using Cornfields During the Breeding Season: Lab Project Number: 

100129. Unpublished study prepared by lowa State University, Dept. of Animal 

Ecology and Mobay Corp. 31 p. 

42005422 Best, L.; Gionfriddo. J. (1991) Integrity of Five Granular Insecti- cide Carriers in 

the Gizzards and Intestines of House Sparrows: Lab Project Number: 10001 30. 

Unpublished study prepared by lowa State Univ., Dept. of Ecology and 

Agrobirds. 29 p. 

42385001 Morris, R. (1991) Pyrethroid lnsecticide Effects on Bluegill Sunfish (Lepomis 

Macrochirus) and the lmpacts of Bluegill Predation on Invertebrates in 

Microcosms: Lab Project Number: 101 953. Unpublished study prepared by 

Mobay Corp. 11 1 p. 

42725601 Johnson, P. (1992) lmpacts of the Pyrethroid lnsecticide Cyfluthrin on Aqluatic 

Invertebrate Populations in Outdoor Experimental Tanks: Lab Project Number: 

105036. Unpublished study prepared by University of North Texas. 5 p. 

45245501 Soderlund, D.; Clark, J.; Mullin, L. et al. (2000) Pyrethroid Insecticides: Is1 there a 

Common Mechanism of Mammalian Toxicity?: Lab Project Number: PWG FQPA 

2000-01. Unpublished study prepared by Pyrethroid Working Group. 144 p. 

47506603 Hall, L.; Killen, W.; Anderson, R.; et. al. (2008) An Assessment of Benthic 

Communities with Concurrent Physical Habitat, Pyrethroid, and Metals Ahalysis 

in an Urban and Residential Stream in California in 2006 and 2007-Pyrethroid: 

Assessment. Project Number: T001523108. Unpublished study prepared by Wye 

Research and Education Center and Northern Illinois University. 229 p. 
Appendix A. PRD data request justification tables 

The following proposed Data Call-in tables include rationales for requiring the data 

requested in this problem formulation, explanations of the utility of the data, and 

explanations for how the data might impact risk assessment, following the format 

provided by PRD. 

-- 

According to 40 CFR Part 1 5 8, Subpaxt N (Environmental Fate) tj 1 5 8.1 300 

(Environmental fate data requirements table), these data are required for all terrestrial use 

patterns. 

The Agency has aerobic soil metabolism studies performed in two soils, with flurophenyl 

labeled cyfluthrin; no data are available with cyclopropyl-labeled cyfluthrin. A study 

performed in two soils should be submitted for cyfluthrin (at least one of which should be 

conducted with cyclopropyl-labeled cyfluthrin, for the identification of possible 

cyclopropyl labeled metabolites, such as DCVA). In addition, a study should be 

performed in four soils for beta-cyfluthrin. The data requirement is being required for 

beta-cyfluthrin too as per current draft guidance provided in the EFED Interim Policy for 

Stereoisomeric Pesticides, that indicates that ". . .an aerobic soil metabolism study (GLN 

162-11835.3300) is required as part of the minimal data set for enantiomeric enriched 

mixtures." (Current guideline 835.4100) Furthermore, there is evidence in the literature 

that the degradation of cyfluthrin and beta-cyfluthrin may be enantioselective (Qin et al. 

2006, Li et al. 2008). Aerobic soil metabolism studies with one soil type are generally 

sufficient for the evaluation of transformation pathways. Rates of transformation should 

be determined in at least three additional soils (fiom Fate, Transport and Transformation 

Test Guidelines - OCSPP Guideline 835.4100 & 835.4200). 

The available supplemental anaerobic soil metabolism study, conducted on cyfluthrin, 

was performed with only one soil, for a period of only one month of anaerobic 

incubation, and sampling was insufficient to determine a suitable half-life. A new study 

is required. Anaerobic studies with one soil type are generally sufficient for the 

evaluation of transformation pathways, but for cyfluthrin, cyclopropyl and phenyl-labeled 

studies are needed. Rates of transformation should be determined in at least three 

additional soils (from Fate, Transport and Transformation Test Guidelines - OCSPP 

Guideline 835.4100 & 835.4200). 

Practical-Utility of SheData -- 

How will the data be used? 

Cyfluthrin and beta-cyfluthrin are synthetic pyrethroids with high toxicity towards 

aquatic organisms, including those living in the benthos. Knowledge of their persistence 

in terrestrial and aquatic environments is important. The results of this study will be used 
in the environmental fate assessment, and later on, in the ecological risk characterization. 

In addition, the data will be used to derive the rate of reaction input parameter to be used 

in the aquatic models GENEEC2, PRZW EXAMS, FIRST and SCI-GROW. The results 

from these models are used to determine exposure concentrations, for ecological risk 

estimation, and to determine surface drinking water concentrations, for drinking water 

exposure assessments. 

How could the data impact the Agency's future decision-making? 

Without these data, the Agency would have to make certain conservative assumptions 

(e.g. calculate the upperbound value derived from only two soils, for the aerobic soil 

metabolism input value). These conservative assumptions could lead to higher predicted 

concentrations (EECs or EDWCs), according to the models, and consequently, higher 

risk quotients or drinking water exposures. Also, there would be a higher degree of 

uncertainty in the environmental fate assessment. Knowledge of these dissipation 

pathways in detail is essential to perform a better and accurate environmental fate 

assessment and risk assessment. 

The lack of these data will limit the flexibility the Agency and registrants have in coming 

into compliance with the Endangered Species Act and could result in use restrictions for 

cyfluthrin and beta-cyfluthrin that may be unnecessary. 
(Environmental fate data requirements table), these data are required for all terrestrial use 

patterns. 

Two aerobic aquatic metabolism studies (soil1 sediment systems) are available that were 

conducted with cyclopropyl-labeled beta-cyfluthrin. The studies available that were 

conducted with fluorophenyl-labeled beta-cyfluthrin were considered of low quality 

because major deficiencies were detected. A study should be conducted utilizing 

fluorophenyl-labeled beta-cyfluthrin on one sediment system of marine origin. 

According to the OCSPP Fate, Transport and Transformation Test Guidelines (835.4300 

& 835.4400). .."At least two sediments and their associated waters are used for both the 

aerobic and the anaerobic studies respectively.. .However, there may be cases where 

more than two aquatic sediments should be used, for example, for a chemical that may be 

present in Ereshwater and/or marine environments. Sediments should be representative of 

intended use sites." Since both cyfluthrin and beta-cyfluthrin have the potential for use 

near estuarine1 marine areas, the required sediment system should be from estuarine1 

marine environment. 

There is no anaerobic aquatic metabolism study available for review. It should be 

conducted on beta-cyfluthrin. Three sediment systems are required, one of which should 

be of marine orinin (see above). - 0 - -- I 

bcticai Utility of the Data 

How will the data be used? 

Cyfluthrin and beta-cyfluthrin are synthetic pyrethroids with high toxicity towards 

aquatic organisms, including those living in the benthos. Knowledge of their persistence 

in soil and aquatic environments is important. The results of this study will be used in the 

environmental fate assessment, and later on, in the ecological risk characterization. 

In addition, the data will be used to derive the rate of reaction input parameter to be used 

in the aquatic models GENEEC2, PRZW EXAMS and FIRST. The results from these 

models are used for ecological risk estimation and in drinking water exposure 

assessments. 

How could the data impact the Agency's future decision-making? 

Without these data, the Agency would have to make certain conservative assumptions 

(e.g. use the upperboud value derived from only two supplemental values for the aerobic 

aquatic metabolism or two times the aerobic aquatic metabolism half-life input for the 

anaerobic aquatic metabolism). These conservative assumptions could lead to higher 

predicted concentrations (EECs), according to the models, and consequently, higher risk 
quotients. Also, there would be a higher degree of uncertainty in the environmental fate 

assessment. At this time, the anaerobic aquatic metabolism of cyfluthrin and betacyfluthrin is uncertain. Knowledge of these dissipation pathways in detail is essential to 

perform a better and accurate environmental fate assessment and risk assessment. 

The lack of these data will limit the flexibility the Agency and registrants have in coming 

into compliance with the Endangered Species Act and could result in use restrictions for 

cyfluthrin and beta-cyfluthrin that may be unnecessary. 
nvironmen 

The available study was performed at a single concentration and no Freundlich 

correlations or isotherms are available. According to OCSPP Fate, Transport and 

Transformation Test Guideline (83 5.1230), the purpose of the main part of the study in 

Batch Equilibrium studies is the "Determination of Freundlich adsorption isotherms to 

determine the influence of concentration on the extent of adsorption on soils." The 

important. The results of this study will be used in the environmental fate assessment, 

and later on, in the ecological risk characterization. 

In addition, the data will be used to derive the mobility input parameter to be used in the 

aquatic models GENEEC2, PRZMI EXAMS, FIRST and SCI-GROW. The results from 

these models are used for ecological risk estimation and in drinking water exposure 

How could the data impact the Agency's future decision-making? 

Without these data, the Agency would have to make certain uncertain assumptions (e.g. 

use the adsorption constants derived at the highest concentration for the mobility input 

parameter in the aquatic models). These uncertain assumptions could lead to higher or 

lower predicted concentrations (EECs), according to the models, and consequently, 

higher or lower risk quotients. The Koc input parameter has a major effect in the 

determination of the EECs for benthic organisms. Also, there would be a higher degree 

of uncertainty in the environmental fate assessment. Knowledge of the mobility of this 

chemical in detail is essential to perform a better and accurate environmental fate and risk 

The lack of these data will limit the flexibility the Agency and registrants have in coming 
Guideline Number: Non-guideline 

Study Title: Wood Leachability 

: . Rationale fop Requiring $lie Ihb 'I $ 

A study is required. It should be conducted according to the American Wood Preservers 

~ssociation standard Method of Determining the ~eichabilit~ of Wood Preservatives 

(El 1-06). It is strongly suggested that the registrant provide a protocol to be evaluated by 

Cyfluthrin and beta-cyfluthrin are synthetic pyrethroids with high toxicity towards 

aquatic organisms, including those living in the benthos. They are used for wood 

protection treatment to buildings/products indoor and outdoor and wood protection 

treatment to forest products (unseasoned). The results of this study will be used in the 

ecological risk characterization, and in particular, for aquatic assessments. At the present 

time, the EFED believes that cyfluthrin and beta-cyfluthrin bind strongly to the w~od 

material, but there are uncertainties as to the degree to which this occurs. Knowledge of 

the leachability from treated wood for these chemicals is important. 

In addition, the data will be used to derive the application rate to be used in the aquatic 

models GENEEC2 and PRZW EXAMS. The results from these models are used for 

exposure assessment and ecological risk estimation. 

How could the data impact the Agency's future decision-making? 

Without these data, the Agency would have to make certain uncertain assumptions (e.g. 

assume that 100% of the cyfluthrin and/ or the beta-cyfluthrin leaches instantaneously 

from the wood, to estimate the application rate in GENEEC and PRZW EXAMS). 

These uncertain assumptions could lead to higher predicted concentrations (EECs), 

according to the models, and consequently, higher risk quotients. The application rate 

input parameter has a major effect in the determination of the aquatic EECs. Also, there 

would be a higher degree of uncertainty in the overall transport assessment for ecological 

effects. Knowledge of the leachability fi-om treated wood of this chemical in detail is 

essential to perform a better and accurate environmental fate/ transport and risk 

assessment. 

The lack of these data will limit the flexibility the Agency and registrants have in coming 

into compliance with the Endangered Species Act and could result in use restrictions for 

this chemical that may be unnecessary. 
along with successful confirmatory method trials (validation) by an independent 

laboratory (i.e. ILVs). The registrant submitted two methods and one independent 

laboratory validation (MRID 4151 1301,47053001 and 47053002), that could quantify 

cyfluthrin in water and sediment. The Agency will verify the suitability of these methods 

and the appropriateness of their levels of quantization. At this time, no methods have 

been identified for the analysis of beta-cyfluthrin. In addition to the method for soil, at 

this time, methods are required for water and sediment. The results of previous 

assessments indicate that there is risk for fieshwater and estuarine1 marine fish, 

invertebrates and benthic organisms. Therefore, ECMs for water and sediment are 

required in addition to the ECM for soil. The ECMs should include parent and those 

residues found in the laboratory studies that exceed 10% of the applied. Acceptable 

ECMs for the residues of concern (parent and its transformation products, DCVA, FPBacid and FPB-ald) should have levels of quantization that are adequate to address risk 

concerns or that are at levels below the toxicological endpoints for the relevant aquatic 

organisms. The registrant is encouraged to submit state-of-the-art environmental 

chemistry methods; further, multi-residue methods (MRMs) for soil, water and sediment 

are preferred. 

How will the data be used? 

The data will be used to verify the suitability of the methods. Subsequently the methods 

could be used by states or other enforcement agencies, departments or entities, to monitor 

concentrations of the residues of concern. Validated analytical methods in environmental 

media (a.k a., ECMs) are useful for conducting and evaluating submitted environmental 

fate and toxicity field and monitoring studies and for addressing potential risks to the 

environment posed by the use andlor accidental release of pesticides. 

How could the data impact the Agency's future decision-making? 

If monitoring of the chemical is required or performed, the Agency could be able to 

determine if the chemical is present in the environment at concentrations that are 

threatening to wildlife (or to humans, in the case of drinking waters), according to the 

levels of concern (LOCs). If that is the case, measures to prevent these concentrations to 

occur could be taken. The data could also be used by enforcement entities like the states 

or government agencies or departments. Without these data, the potential for the 

determination of residues of cyfluthrin, beta-cyfluthrin and transformation products 

(DCVA, FPB-acid and FPB-ald) in soil, water and sediment is restricted. The lack of 

these data will limit the flexibility the Agency and registrants have in coming into 

compliance with the Endangered Species Act, and could result in use restrictions for 

cyfluthrin and beta-cyfluthrin which may otherwise be avoided, or which are 

unnecessarily severe. 
-. 

monitoring data for the pyre&roids be submitted to the Agency. 

POTW Treatability Study - In addition, the Agency is anticipating requiring a bench 

scale study of waste water treatment, to assess the percentage removed in the biosolids by 

the treatment, the amount that would degrade during treatment, and the amount that 

would remain in the waste water. 

Pracfieal Utility of the Ma 

How will the data be used? 

These data would be used to inform removal percentages by waste water treatment, 

which is an input to the Exposure and Fate Assessment Screening Tool's (E-FAST) 

down-the-drain module. 

How could the data impact the Agency's future decision-making? 

Without these data, the Agency will have to make assumptions regarding the level of 

removal of cyfluthrin and beta-cyfluthrin (e.g., results of modeling from the EPIWEB 

v.4.0 may be used). These assumptions are likely to be crude and conservative. The lack 

of these data will limit the flexibility the Agency and registrants have in coming into 

compliance with the Endangered Species Act, and could result in use restrictions for 

cyfluthrin and beta-cyfluthrin which may otherwise be avoided, or which are 

unnecessarilv severe. 
An acute avian oral study was received for bobwhite quail. The Agency updated its data 

requirements in 40 CFR Part 158 (October 26,2007) to include an acute oral toxicity 

study for both a passerine species and either a waterfowl or an upland game species. 

Prior to starting toxicity testing, a protocol will need to be provided for review. Many 

passerine species utilize agricultural fields, forests, residential areas and surrounding 

areas, and, therefore, have the potential to be exposed to pesticides used in agricultural, 

forest, and residential settings. It is likely that, for most pesticide use patterns, passerines 

are more likely to be exposed to pesticides than upland game species and waterfowl. 

Passerines are smaller in size and generally have faster metabolisms than the waterfowl 

and upland game bird species traditionally used in avian toxicity tests which could impact 

their sensitivity to chemicals. 

Praoticai Btility of the Da@ 

How will the data be used? 

Data from passerine toxicity studies will be used to estimate potential risks to birds 

associated with uses of cyfluthrin. The data will reduce uncertainties associated with the 

current risk assessment for passerine species and will improve our understanding of the 

potential effects of cyfluthrin. 

How could the data impact the Agency's future decision-making? 

Because birds significantly contribute to overall environmental quality, a solid 

understanding of the potential risks to birds, including passerine species, is essential for 

sound environmental management. Without acceptable data for cyfluthrin, the Agency 

cannot determine the level of exposure that result in effects to passerine species. If the 

data indicates that registered usage may pose a risk of adverse effects to non-target birds 

above the Agency Level of Concern, the Agency may explore decision options to 

mitigate this risk. The lack of these data will limit the flexibility the Agency and 

registrants have in coming into compliance with the Endangered Species Act, and could 

result in use restrictions for cyfluthrin which may otherwise be avoided, or which are 

unnecessarily severe. 
No acceptable data on reproductive toxicity to the most sensitive bird species has been 

submitted (mallard duck). A chronic risk assessment for birds is needed based on 

cyfluthrin's use patterns and potential impact on birds. The avian reproduction toxicity 

study is justified for cyfluthrin because 1) the avian reproduction studies for both 

waterfowl and upland game bird species are standard data requirements for all outdoor 

terrestrial use patterns, 2) evidence of chronic toxicity to mammals indicates possible 

chronic toxicity in birds, and 3) cyfluthrin use pattern indicates that chronic exposure is 

likelv. i 

Prac&al Utility @f t&e Da'ta . 

How will the data be used? 

The avian reproduction studies are needed for future regulatory decisions and for an 

endangered species assessment in particular. The data would allow the Agency to 

quantify the potential for chronic risk, as measured by effects on reproduction and 

hatchling survival, from the use of cyfluthrin. Results of this study would be used to 

calculate risks to avian reproduction from dietary exposure to cyfluthrin at labeled use 

rates and to identify what, if any, label language is needed to mitigate identified risks. 

How could the data impact the Agency's future decision-making? 

If future endangered species risk assessments are performed without these data, the 

Agency would have to assume that cyfluthrin "may affect" birds directly (and endangered 

species from other taxa indirectly), and use of cyfluthrin might need to be restricted in 

areas where endangered species could be exposed. The lack of these data will limit the 

flexibility the Agency and registrants have in coming into compliance with the 

Endangered Species Act and could result in use restrictions for cyfluthrin which are 

unnecessarily severe. 
c&ent usage that include coastal areas (see Fig. 3.1). Cyfluthrin technical is very highly 

toxic to estuarinelmarine fish and invertebrates on an acute basis, but no information is available 

for cyfluthrin TEP effects on estuarinelmarine species. 

According to the Part 15 8 data requirements, testing on the typical end-use product may be 

required for aquatic toxicity tests when any of the following conditions exist: 

1. The end-use product will be introduced directly into the aquatic environment. 

2. The maximum expected environmental concentration or estimated environmental 

concentration in the aquatic environment is greater than or equal to one-half the LCs0 or 

EC5() of the TGAI. 

3. An ingredient in the end-use formulation other than the active ingredient is expected to 

enhance the toxicity of the active ingredient or cause toxicity to aquatic organisms. 

Previous assessments on cyfluthrin indicate that the expected environmental concentrations in 

aquatic environments are well above acute 50% mortality levels for all species tested. For 

example, the maximum peak aquatic EEC was 2.67 pg ai/L based on the PRZMIEXAMS MS 

cotton scenario in the cyfluthrin new use 2004 assessment for a variety of crops, including tree 

nuts, grapes and leafy vegetables (DP 274813,290926,290922,2913 13,291923,294835 and 

294488). In estuarinelmarine tests conducted with cyfluthrin technical, the lowest 96-hour 

was 4.05 pg/L for sheepshead minnow, 0.0022 pglL for mysid shrimp and 2.69 pg/L for the 

eastern oyster. Therefore, cyfluthrin fulfills the second requirement (above) for TEP studies with 

all tested estuarinelrnarine species. 

Practical Utility of the Data 

How will the data be used? 

These data are needed for a registration review decision and for an endangered species 

assessment, which will be conducted as part of that decision. The data would allow the Agency 

to determine acute and chronic risk to estuarine/marine organisms from exposure to cyfluthrin. 

The effects data would be used to determine the likelihood that exposure to cyfluthrin can 

potentially impact aquatic communities, either by direct effects or by indirect effects on other 

organisms by reducing their food sources. 

/ How could the data impact the Agency's future decision-making? 
If future endangered species risk assessments are performed without these data, the Agency 

would have to assume that cyfluthrin "may affect" endangered invertebrates directly (and 

endangered species fiom other taxa indirectly), and use of cyfluthrin might need to be restricted 

in areas where endangered species could be exposed. The lack of these data will limit the 

flexibility the Agency and registrants have in coming into compliance with the Endangered 

Species Act and could result in use restrictions for cyfluthrin which are unnecessarily severe. 
Rationale for Requiring the Data 

Required for beta-cyfluthrin as per the EFED Interim Policy for Stereoisomeric Pesticides. 

According to the interim policy, certain studies are required for stereoisomeric pesticides to 

identify the possibility that the chemical may be more, equally or less toxic than the previously 

assessed chemical (in this case, cyfluthrin). 

Practical Utility of the Data 

How will the data be used? 

The aquatic invertebrate chronic toxicity study would allow the Agency to analyze chronic toxic 

effects to one of the most sensitive species of freshwater and marine aquatic invertebrates. The 

effects data would be used to determine the likelihood that chronic risks can potentially impact 

aquatic communities, either by direct effects on invertebrates or by indirect effects by reducing 

the food source for their predators (e.g., fish). By refining the assessment, the Agency would be 

able to determine whether the mitigation imposed as part of the registration review process was 

appropriate due to toxicity concerns with beta-cyfluthrin. 

How could the data impact the Agency's future decision-making? 

If future risk assessments are performed without these data, the Agency would have to account 

for the potential increased sensitivity of water flea and mysid to beta-cyfluthrin, as compared to 

cyfluthrin, using other means which may include using an extrapolation factor based on 

sensitivity differences with cyfluthrin. Since this extrapolation factor would involve uncertainty, 

it is likely that a conservative factor would be applied. This may impinge on the Agency's 

flexibility in coming into compliance with the Endangered Species Act and could result in use 

restrictions for beta-cyfluthrin which are unnecessarily severe. 
Rationale for Requiring the Data 

Available information in the Agency ECOTOX database indicates that the freshwater amphipod, 

Hyalella azteca, is substantially more sensitive to pyrethroids than Daphnia magna, the 

commonly tested freshwater invertebrate. Information on the acute toxicity of cyfluthrin to H. 

azteca was not identified in this problem formulation. Therefore, in order to ensure that risk to 

sensitive aquatic invertebrates are appropriately quantified, additional acute toxicity testing of H. 

azteca is needed (water column exposure, not sediment-spiked). 

Practical Utility of the Data 

How will the data be used? 

The freshwater acute toxicity study with Hyalella would allow the Agency to analyze acutely 

toxic effects to one of the most sensitive species of freshwater aquatic invertebrates. The effects 

data would be used to determine the likelihood that acute risks can potentially impact aquatic 

communities, either by direct effects on invertebrates or by indirect effects by reducing the food 

source for their predators (e.g., fish). By refining the assessment, the Agency would be able to 

determine whether the mitigation imposed as part of the registration review process was 

appropriate due to toxicity concerns with cyfluthrin. 

How could the data impact the Agency's future decision-making? 

If future risk assessments are performed without these data, the Agency would have to account 

for the potential increased sensitivity of Hyalella to cyfluthrin using other means which may 

include using an extrapolation factor based on sensitivity differences with other pyrethroids. 

Since this extrapolation factor would involve uncertainty, it is likely that a conservative factor 

would be applied. This may impinge on the Agency's flexibility in coming into compliance with 

the Endangered Species Act and could result in use restrictions for cyfluthrin which are 

unnecessarilv severe. 
No chronic sediment toxicity tests for freshwater or marine invertebrates have been 

submitted to satisfl the Agency's updated data requirements for outdoor uses in 40 CFR 

Part 158 (October 26,2007). For cyfluthrin, available information indicates that benthic 

organisms may be exposed via run-off or spray drift applications used in agricultural, 

forest, and residential settings. Specifically, 

o Based on preliminary calcutions, the peak sediment porewater EECs predicted for 

cyfluthrin (0.048 pg ai/L) exceeds 0.1 of the most sensitive acute LC/ECSo 

(0.0022 pg ai1L for mysid shrimp), which satisfies one of the criteria for requiring 

chronic whole sediment toxicity testing under 40 CFR Part 158. 

o The expected half-life of cyfluthrin in sediment (73.5-94.8 for aerobic soil 

metabolism and 32.9-42 days for aerobic aquatic metabolism) is substantially 

greater than 40 CFR Part 158 criterion of 10 days. 

o The third set of trigger criteria for requiring chronic testing (Kd > 50, or log Kow 

>3 or Koc > 1000) is also met for cyfluthrin (e.g., Kd values are 974-1793, log 

Kow is 6, and Koc values are 69900-180300). 

o Chronic effects were also seen in all aquatic taxa tested at levels ranging from 

0.00040 - 0.63 pg a.i./L. 

o There is a potential for persistent exposure from cyfluthrin in sediment is also 

indicated by open literature studies on pyrethroids (Weston et al. 2005, Amweg et 

al. 2006 and Ding et al. 2009). 

For sediment studies involving pyrethroids, chronic tests on Hyalella azteca, Chironomus 

tentans, and Leptocheirusplumulosus are requested. Although both are freshwater 

species, Hyalella and Chironomus differ substantially in their ecological niche (i.e., 

epibenthic vs. infaunal species), physiology, and potential sensitivities to pyrethroid 

exposure (e.g., Anderson et al. 2006; Maund et al., 2002). Cyfluthrin has the potential to 

enter estuarinelmarine water bodies based on current usuage patterns that include coastal 

areas. Therefore, testing is required for Leptocheirusplurnulosus, an estuarinelmarine 

I sediment-dwelling invertebrate species. I 

How will the data be used? 

Data from sediment toxicity studies will be used to estimate potential risks to benthic 

organisms associated with uses of cyfluthrin. The data will reduce uncertainties 

associated with the current risk assessment for benthic species and will improve our 

understanding of the potential effects of cyfluthrin. 

How could the data impact the Agency's future decision-making? 

Although there was uncertainty in estimating the effect of cyfluthrin on benthic 

organisms in previous assessments, there was a potential risk associated with adverse 

effects identified for other aquatic organisms. Acceptable data for benthic organisms will 

reduce the uncertainty from the previous assessment If the data indicates that registered 
cyfluthrin usage may pose a risk of adverse effects to non-target benthic organisms above 

the Agency Level of Concern, the Agency may explore decision options to mitigate this 

risk. The lack of these data will limit the flexibility the Agency and registrants have in 

coming into compliance with the Endangered Species Act, and could result in use 

restrictions for cyfluthrin which may otherwise be avoided, or which are unnecessarily 

severe. 
No acceptable toxicity data are currently available to assess the risk of cyfluthrin to nontarget terrestrial plants. Since cyfluthrin has residential outdoor uses, vegetative vigor and 

seedling emergence studies are required. Additionally, three incidents have been reported 

to the Agency where cyfluthrin was identified as the possible - highly probable cause of 

phytotoxic damage. Phytotoxicity data are needed to evaluate the level of pesticide 

exposure to non-target terrestrial and aquatic plants and to assess the impact of pesticides 

on endangered and threatened plants. In addition to the studies required for cyfluthrin, 

tests conducted on beta-cyfluthrin are required for the most sensitive monocotyledon and 

dicotyledon as per requirements of the EFED Interim Policy for Stereoisomeric Pesticides. 

Practical USility of the Data 

How will the data be used? 

Data from terrestrial plant toxicity studies will be used to estimate potential risks to plants 

associated with uses of cyfluthrin and beta-cyfluthrin. The data will reduce uncertainties 

associated with the current risk assessment for terrestrial plants and will improve our 

understanding of the potential effects of cyfluthrin on plants. 

How could the data impact the Agency's future decision-making? 

Because plants form the basis of most habitats and significantly contribute to overall 

environmental quality, a solid understanding of the potential risks to terrestrial plants is 

essential for sound environmental management. Without acceptable plant growth data for 

cyfluthrin and beta-cyfluthrin, the Agency cannot determine the levels of cyfluthrin that 

result in effects to terrestrial plants. If the data indicates that registered usage may pose a 

risk of adverse effects to non-target terrestrial plants plants above the Agency Level of 

Concern, the Agency may explore decision options to mitigate this risk. The lack of these 

data will limit the flexibility the Agency and registrants have in coming into compliance 

with the Endangered Species Act, and could result in use restrictions for cyfluthrin which 

may otherwise be avoided, or which are unnecessarily severe. 
No studies for cyfluthrin have been submitted for vascular aquatic plants. The Agency 

has finalized its update to the data requirements in 40 CFR Part 158, which were 

promulgated on October 26,2007. In these updated data requirements, vascular' plant 

testing is required for pesticides with outdoor uses, such as cyfluthrin. In addition to the 

study on cyfluthrin, a study is required for beta-cyfluthrin, as per the EFED Interim 

Policy for Stereisomeric Pesticides. 

Practical Utility of the Data 

How will the data be used? 

Data fiom aquatic plant toxicity studies will be used to estimate potential risks ta plants 

associated with uses of cyfluthrin and beta-cyfluthrin. The data will reduce 

uncertainties associated with the current risk assessment for aquatic plants and will 

improve our understanding of the potential effects on vascular aquatic plants. 

How could the data change the Agency's decision, or impact the Agency's future 

decision-making? 

Because plants form the basis of most habitats and significantly contribute to overall 

environmental quality, a solid understanding of the potential risks to aquatic plats is 

essential for sound environmental management. Without plant growth data for 

cyfluthrin, the Agency cannot determine the levels of cyfluthrin that result in effects to 

vascular aquatic plants. If the data indicates that registered usage may pose a risk of 

adverse effects to non-target aquatic vascular plants above the Agency Level of 

Concern, the Agency may explore decision options to mitigate this risk. 

If future endangered species risk assessments are performed without these data, the 

Agency would have to assume that cyfluthrin and beta-cyfluthrin "may affect" 

endangered plants and use might need to be restricted in areas where endangered, species 

could be exposed. The lack of these data will limit the flexibility the Agency and 

registrants have in coming into compliance with the Endangered Species Act an4 could 

result in use restrictions for cyfluthrin that may be unnecessarily severe. 
Appendix B. Summary of registrant-submitted aquatic toxicity studies 

for cyfluthrin and beta-cyfluthrin 

% a.i. 

87% 

87% 

2% 

2% 

98% 

99.4% 

99.4% 

98.1 % 

97.6% 

98% 

97.6% 

97.6% 

Species 

(common name) 

Oncorhynchus 

mykiss 

(Rainbow trout) 

Lepomis 

Macrochirus 

(Bluegill sunfish) 

Lepomis 

Macrochirus 

(Bluegill sunfish) 

Oncorhynchus 

mykiss 

(Rainbow trout) 

Oncorhynchus 

mykiss 

(Rainbow trout) 

Oncorhynchus 

mykiss 

(Rainbow trout) 

Lepomis 

Macrochirus 

(Bluegill sunfish) 

Oncorhynchus 

mykiss 

(Rainbow trout) 

Oncorhynchus 

mykiss 

(Rainbow trout) 

Lepomis 

Macrochirus 

(Bluegill sunfish) 

Lepomis 

Macrochirus 

(Bluegill sunfish) 

Oncorhynchus 

mykiss 

(Rainbow trout) 

Endpoint 

LC50 

Lcso 

LC50 

LC50 

LC50 

LC~O 

LC50 

Lcso 

LC50 

LC50 

LC50 

Test 

Substance 

Cyfluthrin 

(TEMPO 

2EC) 

cyfluthrin 

(TEMPO 

2EC) 

Betacyfluthrin, 

FCR-4545 

Betacyfluthrin, 

FCR-4545 

Betacyfluthrin, 

FCR-4545 

B~~~- 

cfluthrin, 

FCR-4545 

Cyfluthrin 

Betacyfluthrin, 

FCR-4545 

Cyfluthrin 

Cyfluthrin 

Mean 

concentration 

(pg a.i./L) 

0.68 

1.50 

0.647 

0.295 

0.111 

0.068 

0.28 

0.085 

0.302 

0.566 

0.998 

0.209 

Duration 

(hours) 

96 

96 

96 

96 

96 

96 

96 

96 

96 

96 

96 

96 

MRID and 

study 

classification 

00131502 

Acceptable 

0013 1503 

Acceptable 

41558001 

Supplemental 

41558002 

Acceptable 

45375001 

Supplemental 

45375002 

Supplemental 

45375003 

Supplemental 

45426703 

Supplemental 

45426705 

Acceptable 

45426706 

Supplemental 

45426707 

Acceptable 

45426708 

Supplemental 
MRID and 

study 

classification 

00155898 

Supplemental 

41450401 

Acceptable 

00131504 

Acceptable 

45426701 

Supplemental 

42'105801 

Unreviewed 

41558003 

Acceptable 

00151442 

Acceptable 

46591 507 

In review 

00146485 

Acceptable 

Mean 

concentration 

(pg a.i./L) 

0.010 

0.018 

0.14 

0.25 

0.141 

0.29 

0.16 

0.025 

0.0074 

0.0157 

0.44 (pore 

water) 

290 yg a.i./kg 

sediment 

(bulk sediment) 

4.05 

Duration 

(hours) 

58 (days) 

60 (days) 

48 

48 

48 

48 

21 (days) 

lo (days) 

96 

Endpoint 

LOAEC 

NOAEC 

LOAEC 

LC50 

EC5o 

LC50 

EC5o 

LOAEC 

LC~O 

Lcso 

% a.i. 

96% 

99% 

Tech 

Tech 

98.6% 

2% 

94.7% 

99% 

87% 

Species 

(common name) 

Oncorhynchus 

mykiss 

(Rainbow trout) 

Pimephales 

promelas 

(Fathead 

Minnow) 

Daphnia magna 

(Water Flea) 

Daphnia magna 

(Water Flea) 

Daphnia magna 

(Water Flea) 

Daphnia magna 

(Water Flea) 

Daphnia magna 

(Water Flea) 

Chironomus 

tentans 

(Midge) 

Cyprinodon 

variegatus 

(Sheepshead 

minnow) 

Test 

Substance 

Cyfluthrin 

Betacyfluthrin, 

FCR-4545 

Cyfluthrin 

Cyfluthrin 

(TEMPO 

2EC) 

Cyfluthrin 
Species 

(common name) 

Cyprinodon 

variegatus 

(Sheepshead 

minnow) 

Cyprinodon 

variegatus 

(Sheepshead 

minnow) 

Mysidopsis bahia 

(Mysid shrimp) 

Mysidopsis bahia 

(Mysid shrimp) 

Mysidopsis bahia 

Mysid shrimp) 

Mysidopsis bahia 

(M~sid shrimp) 

Crassostrea 

virginica 

(Eastern oyster) 

Leptocheirus 

plumulosus 

(Amphipod) 

Mysidopsis bahia 

(Mysid shrimp) 

Test 

Substance 

Betacyfluthrin, 

FCR-4545 

Betacyfluthrin, 

FCR-4545 

Endpoint 

NOAEC 

LOAEC 

NOAEC 

LOAEC 

LC50 

Lcso 

Lcso 

LC50 

EC5o 

LC50 

(survival) 

EC50 

(growth) 

NOAEC 

LOAEC 

% a.i. 

90.5% 

90.5% 

90.5% 

92% 

>98% 

>98% 

93% 

99% 

97% 

Duration 

(hours) 

39 (days) 

28 (days) 

96 

96 

96 

96 

96 

28 (days) 

28 (days) 

Mean 

concentration 

(pg a.i./L) 

0.025 

0.084 

0.27 

0.63 

0.0064 

0.0024 

0.0023 

0.0022 

2.69 

35 

36 

0.00017 

0.00040 

MRID and 

study 

classification 

00158781 

Supplemental 

00 158784 

Not reviewed 

00149598 

Acceptable 

40069501 

Acceptable 

45426704 

Acceptable 

45426709 

Acceptable 

00158783 

Acceptable 

46591 506 

In review 

00158785 

Supplemental 
Appendix C. Open Literature Information 

The following is a cursory search of the available literature on cyfluthrin, beta-cyfluthrin 

and synthetic pyrethroids in general, mostly about their prevalence1 occurrence, and 

about their toxicity to aquatic invertebrates and sediment dwelling organisms (which also 

pertains to Section 4.1). It is not intended to be exhaustive. In the relatively recent past 

there has been an increased awareness of the prevalence and toxicity of cyfluthrin, and 

other synthetic pyrethroids, in sediment environments of urban and agricultural sites, 

particularly in California. 

In a 3-year field test studying honey bee (Apis rnellifera) colony health, Chauzat et al. 

(2009) found no residues of cyfluthrin at levels of 0.7 pghee (MRID 47775501) (Note 

that the acute contact LDsO for honeybees is 0.037 pghee according to registrantsubmitted studies). Although no statistical significant relationships were found between 

colony mortality and the presence of pesticides overall, the authors state that "more work 

is needed to determine the role these residues play in affecting colony health". In mother 

study, Dai et al. (201 0) examined the sublethal effects of two pyrethroids, deltamethrin 

and bifenthrin, on bee colony health. The authors concluded that both chemicals 

adversely impacted bees by reducing bee fecundity and decreasing the rate of bee 

development into adulthood. 

Ureda (2004) determined the LCSOs for deltamethrin, lambda-cyhalothrin and cyfluthrin, 

using the test species Hyalella azteca. Also, sediment samples from two locations in 

Central Valley, California were tested. They found that there was a linear relationship 

between the LCso and the total organic carbon for cyfluthrin, but not for lambdacyhalothrin or for deltamethrin. They found that for cyfluthrin, the LCSOs ranged from 

0.34 to 1.07 pg/goc. The LOEC for cyfluthrin were 0.17-0.77 pg/goc. In addition, 

Amweg, et al., 2005 determined the toxicity of six pyrethroids in three Central Valley, 

CA sediments towards Hyalella azteca. They found that of all the synthetic pyrethroids 

tested, bifenthrin exhibited the highest toxicity, while for cyfluthrin the average sediment 

10-day median LC50 was roughly an order of magnitude higher (or less toxic) than for 

bifenthrin. The actual value was 1.08 pglgoc, which is of the same order of magnitude 

reported in the Ureda 2004 study. 

Two major factors that affect the toxicity of the pyrethroids include the presence of a 

synergist, such as piperonyl butoxide (PBO) and the temperature. Amweg et al. 2006a 

documented the effect of PBO on the pyrethroid permethrin's toxicity towards Hyalella 

azteca in sediment samples. It was found that PBO could increase the toxicity of 

permethrin in sediment up to seven-fold. Also, Amweg and Weston 2007, documented 

the effects of the presence of PBO in sediments containing the synthetic pyrethroid 

bifenthrin and other representative chemicals, which included cadmium (a metal), 

chlorpyrifos (an organophosphate), DDT (an organochlorine), and flowanthene (a 

polycyclic aromatic hydrocarbon). The presence of PBO was considered as a Toxicity 

Identification Evaluation (TIE) tool. The 10-day Hyalella azteca LCso was 0.26 pg/goc, 

compared to 0.12 pg/goc in the presence of PBO in the overlying water, at 25 pglL 

(increased toxicity by a factor of 2.2). For the other chemicals, the factor was around or 
less than 1 with no statistical difference in toxicity for all but chlorpyrifos. Eight field 

collected sediments, containing a variety of synthetic pyrethroids, or synthetic 

pyrethroids and chlorpyrifos (except for one sediment that contained only chlorpyrifos), 

that were previously tested and found to be toxic to Hyalella azteca, were examined with 

and without the presence of PBO. All the sediments exhibited higher toxicity in the 

presence of PBO except for the sediment that contained only chlorpyrifos. 

The effect of temperature was documented by Weston et al., 2009a. In an effort to 

identify factors affecting the toxicity identification evaluation (TIE) of the synthetic 

pyrethroids (TIE refers to "manipulating a sample in a manner that alters the toxicity of 

some toxicants but not others"), they performed sediment toxicity tests at various 

temperatures (13, 18,23 and 28°C). 10-day LCSO's to Hyalella azteca were determined 

for four pyrethroids, (permethrin, bifenthrin, esfenvalerate and cyhalothrin), also for 

chlorpyrifos, cadmium and DDT (which were representative of other classes of 

chemicals). For the four pyrethroids, the toxicity approximately doubled when the 

temperature was decreased from 23 to 1 S°C, and approximately tripled when the 

temperature was further decreased to 13°C. The results at 28°C were mixed, but for some 

of the control samples, survival was low, which could indicate that the test species was 

not tolerant of the change to high temperature. For DDT, there was a similar response 

profile with temperature, but not as pronounced as for the synthetic pyrethroids. For 

chlorpyrifos and cadmium, the responses with temperature were either nearly 

independent of temperature or opposite to the one for the pyrethroids (increasing toxicity 

with increasing temperature), respectively. Various field samples with known amounts 

of pyrethroids (some of which contained cyfluthrin), also showed similar responses to 

those of the tested pyrethroids (as indicated above), with a few exceptions. The authors 

discussed the possible repercussions of the temperature dependence of the synthetic 

pyrethroids during the winter season, when the temperatures of the waters and sediments 

are lower. 

Yang et al. 2007 observed the effect of dissolved organic matter (DOM) on the 

bioavailability of the pyrethroids cyfluthrin and permethrin, and their toxicity towards 

Daphnia magna and Ceriodaphnia dubia. A total of 15 surface water samples fi-om 

southern California were utilized. The dissolved organic content (DOC) ranged from 3.3- 

20.2% and the pH ranged from 6.67-7.76. Various indicators were also characterized in 

the waters like an indicator of the level of aromaticity, the carboxyl group capacity and 

the phenol group capacity. They also obtained bioconcentration factors (BCFs) for D. 

magna. Using polydimethylsiloxane (PDMS) activated fiber, a measure of the freely 

dissolved pesticide concentration was obtained (the PDMS fibers were placed in 

scintillation vials and measured via LSC). Based on their low absortivity at 254 nm, it 

was suggested that the water samples had low DOM aromaticity. The E4lE6 (a ratio of 

absorbance at two specified wavelengths) of <5 suggested humic acid dominated 

composition and lesser fulvic acids. Finally, the molar content of carboxylic acid and 

phenolic acid, normalized for DOC varied widely. The DOM did not affect the fieely 

available perrnethrin, but for cyfluthrin, the freely available cyfluthrin was less than for 

the control samples in all instances. The KD~~ were less for cyfluthrin than for 

permethrin by about twice, suggesting affinity of cyfluthrin towards the DOM. 
KDOC = (Cw - Cfiee) 1 (DOC X Cfiee) 

The cyfluthrin D. rnagna body residues were lower than in the control in 14 of the 15 

samples (for 9 samples, the difference was significant). There was a significant 

correlation between the cyfluthrin body residue and Cfi,,, but not for permethrin. In 96- 

hour static exposure tests with C. dubia neonates, the cyfluthrin LCsos were greater than 

the controls in every case (for 7 samples, the difference was significant). These findings 

suggest high affinity of cyfluthrin with organic carbon and organic matter, and lower 

bioavailability in natural waters than in control waters. 

In a recent study (Stout 11, et al. 2009), conducted by the US Department of Housing and 

Urban Development, in collaboration with the Agency, several chemicals were surveyed 

on floors of occupied homes. The survey included several synthetic pyrethroids like 

cyfluthrin. The most frequently detected pesticide was permethrin (89% of the samples). 

Cyfluthrin was detected with a frequency of 17% (n = 480 samples; mean not reported 

for chemicals with detection frequency below 30%; maximum value = 129 ng/cm2), 

illustrating that this chemical is commonly applied, detected and present in homes. 

Cyfluthrin is among the constituents monitored by the National Water Quality 

Assessment (NAWQA), maintained by the U.S. Geological Survey. Two kinds of 

parameters (types of samples) are reported. One is "Cyfluthrin water - filtered - 

recoverable micrograms per liter," with a reported percent of &mples with this 

parameter of 9.7 (report units of pg/L). The other is "Cyfluthrin solids- recoverabledry weight- micrograms per kilogram," with a reported percent if samples with this 

parameter of 0.1 (report units of pg/Kg). 

Multiple articles from the literature document the presence of synthetic pyrethroids, 

including cyfluthrin, in both urban and agricultural sediments. Weston et al. 2005, 

studied the presence of synthetic pyrethroids in Roseville, CA, selected as a typical 

suburban development. Sediments from creeks that drain subdivisions of single-fmily 

homes were found to be toxic to Hyalella azteca. The sediments were tested for deveral 

pesticides, including 7 pyrethroids. Bifenthrin was present in all the sediment samples. 

It was considered to be the primary cause of the toxicity towards the organism, with 

additional contributions of the pyrethroids cyfluthrin and cypermethrin. The maximum 

concentration of cyfluthrin was found to be 169 ng/g dry weight, for a tributary ok 

Kaseberg Creek, in sampling site 1 1. It was detected in 12 out of 24 sediment samples. 

The authors indicate that the presence of synthetic pyrethroids was not likely to be due to 

agricultural uses. In Placer County, the use of synthetic pyrethroids for agricultuaal 

purposes was reported to amount to around 1%. 

Amweg et al. 2006b also studied synthetic pyrethroids in urban areas of Californin and 

Tennessee. Bifenthrin was found to be the major contributor to the toxicity of sediments 

sampled in California to Hyalella azteca, due to its high reported concentrations and 

toxicity. Cypermethrin, cyfluthrin, deltamethrin and lambda-cyhalothrin may have 

contributed to the toxicity in some of the sites. The concentrations of cypermethrin and 

cyfluthrin were typically higher than for other synthetic pyrethroids (usually 2-30 nglg), 

but the bifenthrin and permethrin concentrations were the highest. On the other hand, in 

Tennessee only a few samples contained synthetic pyrethroids and none of the samples 
were toxic to Hyalella azteca. The differences between the two sites were attributed to 

different climate, types of residential development and pesticide use practices. 

Holmes et al. 2008 presented the occurrence and toxicity of the synthetic pyrethroids 

throughout the state of California's urban creek sediment samples. First, 90 samples 

were screened for toxicity to Hyalella azteca, of which around one third caused 

significant toxicity to the organism, Later, 30 sample locations were selected for the final 

study. Of the 30 samples, 25 were toxic to Hyalella azteca at 23OC and all 30 samples 

were toxic at 15OC (the synthetic pyrethroids often show higher toxicity at lower 

temperatures, as indicated above). Seven of eight pyrethroids were detected in the 

sediment samples. Fenpropathrin was not detected in any of the samples, and 

deltamethrin and esfenvalerate were detected infrequently; but bifenthrin was present in 

all the 30 samples (2.19 to 21 9 nglg dry weight). Permethrin was the second most 

detected pyrethroid and cyfluthrin was detected in 16 samples, with a highest 

concentration of 127 nglg dry weight. The results suggested an important role of the 

synthetic pyrethroids in California's urban creeks sediment toxicity. Bifenthrin 

accounted for around two thirds of the toxicity on an average basis, with cyfluthrin and 

cypermethrin also playing an important role in the pyrethroid toxicity statewide. 

Trimble et al. 2009 screened a previously referenced database of 24 pesticides and 94 

urban sediment samples, with minimal agricultural or industrial contribution, collected 

from creeks and streams throughout central and northern California. The seven synthetic 

pyrethroids tested and chlorpyrifos were the pesticides most commonly occurring in 

toxicologically significant mixtures. Bifenthrin, permethrin and DDT were observed in 

greater than 90% of the samples. After normalizing the chemical concentrations for 

organic carbon "to provide better estimates of the biologically available chemical 

fractions," all the seven pyrethroids monitored had levels exceeding the established level 

of interest, LO1 (defined as 0.005 toxic units, 0.005 TU) for at least one sample. 

Cyfluthrin was detected in around 70% of the samples (Fig. 1 of the report). Bifenthrin, 

cypermethrin and cyfluthrin exceeded 0.5 TU (100x the initially established LOI) in 

greater than 30% of the samples. It was stated that.. . "The three pesticides with the 

highest average TU values were bifenthrin (2.4 TU), cypermethrin (1.2 TU), and 

cyfluthrin (0.5 TU)." These are just a few examples that illustrate the high use of 

synthetic pyrethroids in urban settings and potential ecological ramifications. 

Budd et al. 2007 sampled sediments in mixed land (urban and agricultural) in the San 

Diego Creek in Newport Bay Watershed in southern California. Bifenthrin and 

fenpropathrin were among the most frequently detected synthetic pyrethroids, with 

bifenthrin found in 95-100% of the samples. Cyfluthrin was observed less frequently, at 

a highest concentration of 2.48 uglkg. The highest concentrations were associated with 

commercial nurseries. The authors found in this case that the concentration of synthetic 

pyrethroids was generally lower in residential or commercial areas as opposed to 

agricultural sites. Also, the frequency of detections of pyrethroids was higher during the 

wet season (e.g., cyfluthrin 33% vs. 5%), but the total concentration was not statistically 

different between the wet and dry seasons. 
Weston et al. 2004 studied the presence of 26 pesticides, including five pyrethroids, in 70 

sediment samples taken from the agriculture dominated Central Valley in California. 

Ten-day sediment tests were conducted for Hyalella azteca and Chironomus dilutus 

(formerly known as Chironomus tentans), for some of the samples. Synthetic pyrethroids 

were found in 75% of the sediment samples; also they were found, based on a toxicity 

unit basis, to be sufficiently high to cause toxicity in 40% of the samples toxic to C. 

dilutus and around 70% of the samples toxic to H. azteca. The most commonly found 

pyrethroids were permethrin > esfenvalerate > bifenthrin > lambda-cyhalothrin. Even 

though this study did not include cyfluthrin or beta-cyfluthrin, the presence of several 

synthetic pyrethroids illustrated the possibility of high levels of several synthetic 

pyrethroids in agricultural zones. 

In a study, Gan et al. 2005 monitored the spatial distribution and enrichment (enrichment 

ratio, ER, or ratio of the concentration of a substance in eroded sediment to that of the 

source matrix) of the synthetic pyrethroids permethrin and bifenthrin, along a 260 meters 

runoff path. A sedimentation pond was used as the source point for the study (permethrin 

and bifenthrin had been used extensively at the site, for ant control, in a nursery 

environment). It was observed that, in general, the sediment concentration of permethrin 

and bifenthrin increased with distance (downstream from the source). Using the source 

as the reference value, ERs were calculated for these chemicals. The ERs reached 25.7- 

32.2 for bifenthrin at 145 m and beyond, and they were lower for permethrin. Also, the 

persistence of the test substances was assessed, both, in aerobic and anaerobic 

environments. Despite the fact that this study was not conducted with cyfluthrin or betacyfluthrin, this study illustrated the possibility of enrichment through a runoff path for the 

synthetic pyrethroids. 

I Woudneh & Oros 2006 presented a multi-chemical analytical method that includeid 

among others cyfluthrin and piperonyl butoxide (PBO). Analysis of the San Francisco 

Bay tributary sediment samples (six samples from five sites) revealed that cyfluthtin was 

detected in one of the sediments, at 17.6 ng/g and was less than the detection limit in the 

other samples. PBO was detected in all the samples at 0.010-0.215 nglg. 

Weston et al. 2009b, found that bifenthrin was the most frequently detected pyretl-iroid 

from runoff waters from Roseville and Elk Grove urban sites. Cyfluthrin, cypemethrin 

and permethrin were also detected frequently. During the dry season, cyfluthrin was 

detected with a frequency of 50%, while during the wet season, it was found with a 

frequency of detection of 100% (maximum concentration 26.6 ng/L). It was noted that 

stormwater runoff (which occurs mostly around the winter) was responsible for more 

transport than irrigation runoff (which occurs mostly around the summer), towards 

surface waters. It was suggested that mitigation of the effects of the synthetic pyqethroids 

would need to target both sources of moff. It was reported that the use of bifenthrin (for 

retail and for professional use) was higher approximately in the months around thie 

summer. 

Most of the studies related to the synthetic pyrethroids were conducted in California, but 

other studies document the presence of synthetic pyrethroids elsewhere. 
Hintzen et al. 2009 monitored for 12 insecticides and degradation products, including 

synthetic pyrethroids and fipronyl in Texas stream sediments from urban sites in 2006, as 

a model to evaluate their potential impact in Southern US. Bifenthrin was the pyrethroid 

found with the highest frequency. Cyfluthrin's frequency of detection was 9.8% (mean = 

0.27 pg/goc; maximum = 0.40 pg/goc; compared to 10-day LC5() to Hyalella azteca of 1.1 

pg/goc). Lamda-cyhalothrin and permethrin were also frequently detected; the detections 

of lamda-cyhalothrin occurred frequently at concentrations of concern, but the 

concentrations of permethrin were below the LCs0 for H. azteca. Bifenthrin was the 

greater contributor to the TUs, followed by lambda-cyhalothrin. The TUs generally 

correlated well with the toxicity of the samples, although some discrepancies between the 

TUs and toxicity were noted (even after normalization for organic carbon). There were 

no seasonal variations of the TUs. 

Ding et al. 20 10 conducted monitoring for 29 pesticides, including pyrethroids like 

bifenthrin, fenpropathrin and cyfluthrin, from both urban and agricultural sites in central 

and southern counties in the state of Illinois in 2008. Most of the urban samples were 

from constructed storm drains, while the agricultural samples were from small waterways 

between farmlands in areas where mostly corn and soybeans were grown and the major 

pesticides used were tefluthrin and atrazine. Furthermore, sediment toxicity tests towards 

Hyalella azteca were performed. In the urban samples, the synthetic pyrethroids were 

detected in 95% of the samples. Bifenthrin was detected in 80% of the samples, while 

permethrin, lambda-cyhalothrin and fenpropathrin were also frequently detected; 

cyfluthrin was not detected. In the agricultural samples, bifenthrin, permethrin, 

cypermethrin and tefluthrin were detected (frequency of detection 47%), while cyfluthrin, 

fenpropathrin and lambda-cyhalothrin were not detected. Ten of 17 urban sediment 

samples tested were significantly more toxic to H azteca than the controls. Only one of 

the agricultural sediment samples was significantly more toxic than the controls. The 

major source of TUs were the pyrethroids (in particular, bifenthrin). It was indicated that 

the detections of fenpropathrin in the urban samples was unexpected because it is a 

pesticide primarily used in agriculture. 

LeBlanc & Perkins, 2009, documented the presence of synthetic pyrethroids in Maine 

sediments. Of five synthetic pyrethroids monitored, only bifenthrin was detected, at 

levels of 1.26 - 16.68 ng/g (means). The other synthetic pyrethroids monitored were 

lambda-cyhalothrin, permethrin, cyfluthrin and cypermethrin. Four sediments were 

monitored: Mill Creek Lower Intertidal, Mill Creek Upper Intertidal, Back Cove and 

Payson Park. 

In an article, Weston & Lydy 20 10 studied the possible sources of pyrethroids in 

California's Sacramento - San Joaquin River Delta, including three types of samples: (a). 

urban runoff, (b). municipal wastewater treatment plants (or Publicly Owned Treatment 

Works, POTWs), and (c). agricultural discharges, in a study that focused on water 

samples (as opposed to most of the studies above that are related to sediments). Samples 

were taken during the wet and dry seasons. First, urban runoff samples were taken from 

concrete sumps, from which pumps lift waters to adjacent rivers over levees. Second, 
POTW effluents with secondary (and in one case, tertiary) treatment were sampled just 

prior to discharge to surface waters. And finally, third, agricultural discharges were 

collected at pump stations, where the runoff is lifted over the levees. Samples were 

tested for 8 pyrethroids and chlorpyrifos (LOQ around 1 ng/L for most samples). Tests to 

Hyalella azteca were also performed on the water samples. Cyfluthrin was found in 55,6 

and 0% of the samples of urban runoff, POTWs and agricultural drains, respectively. 

Also, 55,O and 0% of the samples, respectively, exceeded the EC50 = 1.9 ng/L for H. 

azteca. The maximum measured cyfluthrin concentration was 17.8 ng/L. Through TIE, 

it was found that the toxicity of most samples was increased in the presence of PBO. A 

similar effect was observed when the temperature of the samples was decreased. In the 

presence of the enzyme E3, which is capable to degrade the pyrethroids, the effect was a 

decreased toxicity of the samples towards H. azteca. In the presence of bovine serum 

albumin (BSA), no effect on the toxicity of the samples towards H. azteca, was observed. 

The pyrethroid presence in POTWs was unexpected because the effluents had low 

suspended material and for the possible partitioning with biosolids within the plants. The 

authors indicated that possible sources of pyrethroids are sewer disposal of household 

insecticides, lice control shampoos, pet products and permethrin treated clothing. 

Weston 2007 said that, "Contrary to popular perception, non-agricultural use of 

pyrethroids far exceeds agricultural use, at least in California, one of the few areas where 

data are available. A similar situation is likely elsewhere where there is substantial urban 

development. Whereas agricultural use of pyrethroids in California is about 300,000 

lblyr, non-agricultural commercial use (mostly applications done by professional pest 

control firms) is currently about 700,000 lblyr. Retail sales to homeowners are not 

included in this non-agricultural figure, but are probably about another 100,000 lblyr. 

Some of the major urban uses of pyrethroids include cyperrnethrin and permethrin for 

termite control, permethrin to maintain landscaping, and bifenthrin and cyfluthrin for a 

variety of pests around homes." 

Various studies provide additional environmental fate characterization of cyfluthrin and 

beta-cyfluthrin. It appears that cyfluthrin degrades slowly under normal conditions of 

aerobicity and organic matter, but degrades faster under anaerobic environments or in 

soils with higher organic matter. The moisture level does not appear to have a significant 

effect on the rate of degradation (Smith, et.al., 1995). The degradation of cyfluthf-in 

appeared to be faster in soils with higher pH's (Shehata, et.al., 1987), which would be 

expected based upon the results of the available hydrolysis study. In a study performed 

by Fernhdez-Alvarez et al. 2007, the photolytic behavior of cyfluthrin and various other 

synthetic pyrethroids was studied under artificial and natural light. The detection was 

performed using solid phase micro-extraction (SPME). After 20 minutes of exposure to 

UV light, cyfluthrin was almost completely degraded, with 8 photoproducts tentatively 

identified. However, under natural light for 2 days, there was no decrease in the 

analytical signal of cyfluthrin, indicating that the half-life is much larger than 2 days. 

Additional studies, using SPME were said to be conducted in the future. 

Gupta and Gajbhibe conducted two studies on the fate of beta-cyfluthrin. In a 2002 

study, they determined the persistence and effect of moisture in alluvial soil from India. 
The half-lives ranged fiom 7.8 to 4 1.8 days. With an increased application rate, the 

dissipation rate decreased when the soil was at field capacity or flooded, but the effect 

was the opposite (but not pronounced) in air-dried soil. The persistence was greater in 

air-dried soils and lower in flooded soils. In a soil column study, beta-cyfluthrin was 

considered to be "highly immobile" in alluvial soil with greater than 99% of the residues 

in the upper 0-5 cm depth. The soil was classified as a sandy loam and it was an 

inceptisol with a pH of 7.7. In 2005, the same researchers studied the fate of betacyfluthrin in water, and the effect of pH, temperature and presence of sediments 

(approximately 20 mL water plus 1 g of air-dried soil-sediment). They used a 

formulation containing 2.5% a.i. named Bulldock 025 SC. At application rates of 0.01 to 

0.1 pg/rn~'O the half-lives in water (pH not specified) were 8.4 - 10.5 days. At pHs 4.0, 

7.0 and 9.2, and 0.1 pg/mL, the half-lives of formulated beta-cyfluthrin were 125.4,23.9 

and 13.4 days, respectively in studies conducted for a period of 30 days. At 5,25 and 

40°C, the half-lives were 15.1-16.4, 8.5-10.5 and 5.8-4.7 days respectively. In the 

presence of sediment, the dissipation of beta-cyfluthrin formulation from the water 

followed a biphasic pattern, with initial half-lives in the water of 0.75-0.8 1 days (initial 0- 

5 day period), while the dissipation from the soil-sediment was reported to be slower 

(initial 3.0-4.3 days and 13.5-13.9 during the 10-30 day period). 

Qin et al. 2006 observed enantioselectivity in the degradation of cyfluthrin and other 

selected pyrethroids. No substantive difference was observed in sterile soils, indicating 

preferential biological transformation. One soil (pH 6.7), and one sediment (pH 7.9) 

from California were used for incubation in this study. The incubations were performed 

with viable and sterile soils1 sediments. The incubations were performed with cisbifenthrin, cis-permethrin and cypermethrin (however, they did not use cyfluthrin of 

beta-cyfluthrin in this part of the study). Also, duplicate sediments were collected from 

diverse areas of Orange County, CA and analyzed. Analysis of the field samples 

indicated that for cyfluthrin for the diastereomeric pairs that follow, the stereoisomer 

fraction (SF) were as indicated. 

1 R-trans-aR i- 1 S-trans-as, consistently c0.25, and 

1R-trans-aS + 1 S-trans-aR, consistently B0.25. 

They indicated that, "Of the cis enantiomers, the SF remained around 0.125 for some 

samples but clearly increased or decreased in the other samples.. .When enantioselective 

degradation was observed, the direction of enantioselectivity also appeared to depend on 

the sampling location and environmental conditions." 

Li et al. 2008 demonstrated that for beta-cyfluthrin, the trans-diastereomer degraded 

faster in a loam Tianjin alkaline soil from North China (pH of 8.2). The half-lives for the 

cis-isomers were 17.16-28.41 days, and for the trans-isomers, they were 8.74-12.67 days. 

A similar enantioselective behavior was observed for beta-cypermethrin, but betacyfluthrin degradation was generally faster. 

Moore et al. 2007 examined the use of constructed wetlands in Leflore County, MS to 

mitigate exposure and ecological impacts in runoff fiom agricultural fields. The 

synthetic pyrethroids cyfluthrin and lambda-cyhalothrin were used as model 

10 It was noted that these concentrations exceed the solubility limit for beta-cyfluthrin of near 2 ppb. 

122 
contaminants. Testing with Hyalella azteca was performed to determine the efficiency of 

the system. There was spatial and temporal variation of the two pyrethroids' 

concentrations in water, sediment and leaf litter in all three wetland constructed cells. By 

61 days, there were little or no pyrethroids in water or leaf-litter. The concentration of 

the pyrethroids decreased with distance fiom the application point, but there was no 

decrease in the H. azteca toxicity in water during the 61-day observation period even 

though the pyrethroids' concentrations decreased significantly. The authors concluded 

that the pyrethroids can move, affecting non-target aquatic organisms for weeks to 

months after entering a constructed wetland. 

In 2009, Moore et al. also used cyfluthrin and lambda-cyhalothrin in constructed 

wetlands (comprised of a sediment retention basin, and two treatment cells) in a study 

lasting 55 days. A high percentage of the measured cyfluthrin was associated with 

vegetation while for lambda-cyhalothrin, it was associated with the sediment. It was 

determined that wetlands lengths of 210-217 m were required to mitigate inflow of both 

chemicals from a 14 ha contributing field. 
Appendix D. Test Run for Cyfluthrin Representing the Cotton Use 

Modeling Results 

Table 1. Estimated Environmental Concentrations (EECs) for Cyfluthrin 

MS cottona 

Water column 

Pore water 

Table 2. Previously Generateda EECs for Cyfluthrin 

MS cottonb 

Water column 

Sediment 

Table 3. Input Parameters 

Parameter (units) 

Output File Name 

Chemical Name 

Crop Names 

Application Rate 

Day of Application (daymonth) 

Number of Applications 

Allowed 

Interval between 

Applications (days) 

Koc (mugoc) 

Aerobic Soil Metabolism 

(days) 

Method of Application 

Buffer Zone (ft.) 

Application Efficiency 

(fraction) 

Spray Drift (fraction) 

Solubility in Water (ppm) 

Aerobic Aquatic 

Metabolism (days) 

a' A chosen representative scenario for agricultural applications of cyfluthrin. 

Peak (ppb) 

1.62 

0.0476 

"' At the time there was no aerobic aquatic metabolism study for cyfluthrin and the v. 2 (instead of 2.1) of the input 

parameter guidance was used. Also, the date of application was different. b. A chosen representative scenario for 

agricultural applications of cyfluthrin. 

Peak (ppb) 

2.67 

85.7 

Utilized in Test Run 

Value(s) 

CYFLUTHRIN 

Cyfluthrin 

MS cotton 

0.056 Kg a.i./ha 

01-07 

10 

3 

kc = 123,950 

- (t90,n-1s) 

t,,,, = t,,, + - & 

trnPu = 11 6.9 days 

Aerial 

150 

0.95 

0.039 

2.32 x 

- (t90,n-1s) 

tlnput = t112 + p & 

t,,,, = 51.5 days 

21-day (ppb) 

0.219 

0.0442 

60-day (ppb) 

0.133 

0.0379 

21-day (ppb) 

0.366 

Not Available 

in PRZMIEXAMS 

Sources 

--- 

Label 

Label 

Label 

Label and metadata file 

Label 

Label 

MRID: 43424901 

MRID: 00131494 

Label 

Label 

Value for aerial 

applications 

AgDRIFT, Tier 11, default 

values 

Laskowsky 2002 

MRID: 00131494 

60-day (ppb) 

0.240 

Not Available 

for cyfluthrinl 

Comments 

--- 

e.g , label BAYTHROIDm 2 

Emulsifiable Pyrethroid 

Insecticide (Reg. No 264-745) 

Vulnerable scenario, located in 

Yazoo, MS. 

0.05 lb a.i./A --- 

Maxlmum allowed by the label. 

Min~murn allowed by the label. 

Mean of 4 values available 

(124000,180300, 118000,73500) 

The Koc model was utilized as per 

the 1999 SAP recommendation. 

Represents the 90" percentile of 

the upper confidence bound on the 

mean of two half-life values 

[values: 73 5,94.8 days, mean = 

84 15 days; std. dev = 15.06 days, 

t90,n.1 = 3.078 for n=2] 

--- 

--- 

--- 

Appropriate for a buffer zone of 

150 ft 

--- 

Represents the 90" percentile of 

the upper confidence bound on the 

mean of two half-life values 

[values: 32.9, 42.0 days, mean = 

37 45 days; std dev = 6.435 days, 

tg~,~., = 3 078 for n=2] The value 

available is for beta-cyfluthrin 
Output Files 

Table 3. Input Parameters Utilized in Test Run in PRZMIEXAMS for cyfluthrinl 

stored as CYFLUTHRIN.out 

Chemical: Cyfluthrin 

PRZM environment: MScottonSTD.txt modified Tueday, 29 May 2007 at 13:57:52 

EXAMS environment: pond298.e~~ modified Tueday, 26 August 2008 at 06:14:07 

Metfile: w03940.dvf modified Tueday, 26 August 2008 at 06:14:14 

Water segment concentrations (ppb) 

Year 

1961 

1962 

1963 

1964 

1965 

1966 

1967 

1968 

1969 

1970 

1971 

1972 

1973 

1974 

1975 

1976 

1977 

Parameter (units) 

Anaerobic Aquatic 

Metabolism (days) 

Hydrolysis at pH 7 

Aqueous Photolysis (days) 

Molecular Weight (glmole) 

Vapor Pressure (torr) 

Peak 

0.6178 

0.6591 

0.911 

0.9171 

1.632 

1.524 

0.9011 

0.6025 

1.259 

0.9071 

0.9291 

0.2607 

0.5963 

0.5758 

2.713 

0.9399 

0.9897 

Sources 

MRID 00131494 

MRID: 00131493, 

00137539,45022101 

MRD 00149595, 

45022102 

TOXNETI HSDB 

Laskowsky 2002 

Value@) 

60 

0 

4.5 

434.29 

1.5 x 10'~ 

21 Day 60 Day 90 Day Yearly 

0.162 0.102 0.08218 0.0343 

0.07601 0.05536 0.05195 0.03778 

0.1155 0.063690.04963 0.03501 

0.1429 0,09722 0.09244 0.0557 

0.22 0.1224 0 .I003 0.05414 

0.1858 0.111 0.0928 0.0549 

0.1062 0.06934 0.06358 0.04478 

0.07806 0.0558 0.04871 0.04057 

0.1171 0.07503 0.06445 0.04211 

0.1268 0.09624 0.08772 0.05173 

0.1755 0.1144 0.09702 0.05525 

0.073170.04625 0.0406 0.03489 

0.06612 0.0571 0.04712 0.03802 

0.1194 0.08554 0.07335 0.04889 

0.3188 0.1766 0.1442 0.06754 

0.1508 0.09414 0.08522 0.05163 

0.1175 0.08002 0.07362 0.05088 

Comments 

2x the anaerobic soil metabolism 

input value of -30 days since 

there are no anaerobic aquatic 

studies 

Relatively stable at pH 7 

Linear half-life 

--- 

--- 

Henry's Law Constant 

(atm-m3/mol) 

Environment 

Field Size 

Runoff 

PRZM Scenario 

Metfile 

CAM (Chemical 

Application Method) 

Incorporation Depth (cm) 

IPSCND, Condition for 

disposition of pesticide 

remaining on foliage after 

harvest 

FEXTRC, Foliar extraction 

PLDKRT, Decay rate on 

foliage 

PLVKRT, Volatilization 

rate from foliage 

WTKF, Uptake factor 

Write benthic pore water 

concentrations? 

'~ata were selected according to EFED Guidance on Input Parameters v.2.1, dated October 22,2009. 

pond298.exv 

EPA Pond 

None 

MScottonSTD.txt 

w03940.dvf 

2 

0 

1 

0.5 

0 

0 

0 

Yes 

Laskowsky 2002 

--- 

--- 

--- 

--- 

Meteorological file located 

in Jackson, MS. 

Foliar applied, linear 

application 

Label. 

Surface applied 

Default value 

--- 

--- 

--- 

--- 

Default for pond scenario, as 

opposed to index reseryoir. 

--- 

--- 

As suggested by the shell (PE5). 

--- 

Appropr~ate for foliar kpplications 

--- 

--- 

--- 

--- 

--- 

--- 
Sorted results 

Prob. Peak 96 hr 

0.032258064516129 

0.0645161290322581 

0.0967741935483871 

0.129032258064516 

0.161290322580645 

0.193548387096774 

0.225806451612903 

0.258064516129032 

0.290322580645161 

0.32258064516129 

0.354838709677419 

0.387096774193548 

0.419354838709677 

0.451612903225806 

0.483870967741936 

0.516129032258065 

0.548387096774194 

0.580645161290323 

0.612903225806452 

0.645161290322581 

0.67741935483871 

0.709677419354839 

0.741935483870968 

0.774193548387097 

0.806451612903226 

0.838709677419355 

0.870967741935484 

0.903225806451613 

0.935483870967742 

0.967741935483871 

21 Day 

2.713 

2.131 

1.632 

1.524 

1.34 

1.259 

1.225 

1.099 

1.067 

0.9897 

0.9399 

0.9291 

0.9171 

0.911 

0.9071 

0.9011 

0.8641 

0.8348 

0.8161 

0.7366 

0.6678 

0.6591 

0.6178 

0.6025 

0.5963 

0.5758 

0.5517 

0.5457 

0.2746 

0.2607 

60 Day 

0.8339 

0.7632 

0.6539 

0.4941 

0.4613 

0.4465 

0.4438 

0.4225 

0.3897 

0.3769 

0.3433 

0.3348 

0.3094 

0.3038 

0.3007 

0.2927 

0.2868 

0.2788 

0.2717 

0.2619 

0.253 

0.2332 

0.2281 

0.2256 

0.2084 

0.1876 

0.178 

0.1733 

0.1082 

0.1029 

90 Day Yearly 

0.3188 0.1766 0.1442 0.0712 

0.224 0.1606 0.1375 0.06754 

0.22 0.1337 0.1095 0.05912 

0.2091 0.1224 0.1003 0.0557 

0.195 0.1144 0.09702 0.05545 

0.1858 0.111 0.095570.05525 

0.1755 0.1105 0.0928 0.0549 

0.162 0.102 0.09244 0.05414 

0.1508 0.09722 0.08772 0.05404 

0.1449 0.09657 0.08522 0.05173 

0.1429 0.09624 0.082310.05163 

0.1268 0.09414 0.08218 0.05088 

0.1194 0.08554 0.07362 0.04889 

0.1175 0.080020.073350.04639 

0.1171 0.07503 0.0664 0.04518 

0.1155 0.07086 0.06445 0.04478 

0.114 0.06972 0.063760.04412 

0.1062 0.06934 0.06358 0,04412 

0.1054 0.0681 0.061310.04367 

0.1023 0.06797 0.06028 0.04211 

0.0939 0.06535 0.05894 0.04152 

0.08954 0.06369 0.05797 0.04083 

0.08854 0.05905 0.05214 0.04057 

0.08578 0.058960.05195 0.03802 

0.08565 0.0571 0.04963 0,03778 

0.07806 0.0558 0,04898 0.03776 

0.076010.05536 0.048710.03503 

0.073170.055280.04712 0.03501 

0.06612 0.04832 0.04594 0.03489 

0.06339 0.04625 0.0406 0.0343 

0.1 1.6212 0.63792 0.218910.13257 0.10858 0.058778 

Average of yearly averages: 0.0472183333333333 

Inputs generated by pe5.pl - Novemeber 2006 

Data used for this run: 

Output File: CYFLUTHRIN 

Metf ile : w03940.dvf 

PRZM scenario: MScottonSTD.txt 

EXAMS environment file: pond2 9 8 . exv 

Chemical Name: Cyfluthrin 

Description Variable Name Value Units Comments 

Molecular weight mwt 434.29 g/mol 

Henry's Law Const. henry 3.7e-6 atm-mA3/mol 

Vapor Pressure vapr 1.5e-8 torr 

Solubility sol 2.32e-3mg/L 

~d ~d mg/L 

Koc Koc 123950mg/L 

Photolysis half-life kdp 4.5 days Half-life 

Aerobic Aquatic Metabolism kbacw 51.5 days Halfife 

Anaerobic Aquatic Metabolism kbacs 60 days Halfife 

Aerobic Soil Metabolism asm 116.9 days Halfife 

Hydrolysis: pH 7 0 days Half -life 

Method: CAM 2 integer See PRZM manual 
Incorporation Depth: DEPI 

Application Rate: TAPP 

Application Efficiency: 

SprayDrift DRFT 0.039 

Application Date Date 

Interval 1 interval 

app. rate 1 apprate 0.056 

Interval 2 interval 

app. rate 2 apprate 0.056 

Interval 3 interval 

app. rate 3 apprate 0.056 

Interval 4 interval 

app. rate 4 apprate 0.056 

Interval 5 interval 

app. rate 5 apprate 0.056 

Interval 6 interval 

app. rate 6 apprate 0.056 

Interval 7 interval 

app. rate 7 apprate 0.056 

Interval 8 interval 

app. rate 8 apprate 0.056 

Interval 9 interval 

app. rate 9 apprate 0.056 

Record 17: FILTRA 

IPSCND 1 

UPTKF 

Record 18: PLVKRT 

PLDKRT 

FEXTRC 0.5 

Flag for Index Res. Run 

Flag for runoff calc. RUNOFF 

0 cm 

0.056 kg/ha 

APPEFF 0.95 fraction 

fraction of application rate applied to pond 

01-07 dd/mm or dd/mmm or dd-mm or dd-mmm 

3 days Set to 0 or delete line for single app. 

%/ha 

3 days Set to 0 or delete line for single app. 

kg/ha 

3 days Set to 0 or delete line for single app. 

kg/ha 

3 days Set to 0 or delete line for single app. 

kg/ha 

3 days Set to 0 or delete line for single app. 

kg/ha 

3 days Set to 0 or delete line for single app. 

kg/ha 

3 days Set to 0 or delete line for single app. 

kg/ha 

3 days Set to 0 or delete line for single app. 

kg/ha 

3 days Set to 0 or delete line for single ape. 

kg/ha 

IR EPA Pond 

none none, monthly or total(average of entire run] 

stored as CYFLUTHRINben.out 

Chemical: Cyfluthrin 

PRZM environment: MScottonSTD.txt modified Tueday, 29 May 2007 at 13:57:52 

EXAMS environment: pond298.e~~ modified Tueday, 26 August 2008 at 06:14:07 

Metfile: w03940.dvf modified Tueday, 26 August 2008 at 06:14:14 

Benthic segment concentrations (ppb) 

Year 

1961 

1962 

1963 

1964 

1965 

1966 

1967 

1968 

1969 

1970 

1971 

1972 

1973 

1974 

1975 

1976 

1977 

1978 

1979 

1980 

1981 

1982 

1983 

1984 

1985 

1986 

1987 

1988 

Peak 96 hr 21 Day 60 Day 90 Day Yearly 

0.02832 0.02808 0.027010.025510.0234 0.01068 

0.02547 0.02532 0.02486 0.02336 0.02192 0.01519 

0.01997 0.019860.01957 0.01728 0.01656 0.01296 

0.03422 0.03396 0.032460.02953 0.02897 0.02055 

0.04702 0.0467 0.043510.03803 0.03485 0.02125 

0.042310.04202 0.03923 0.033710.03075 0.02171 

0.02597 0.025810.02514 0.02282 0.02185 0.01734 

0.025610.025560.02514 0.02428 0.0233 0.01637 

0.02866 0.02845 0.0262 0.021910.01978 0.01568 

0.03352 0.03334 0.03227 0.03062 0.02962 0.01984 

0.03635 0.03606 0.0345 0.030610.02967 0.02113 

0.02342 0.02327 0.022810.02125 0.020010.01347 

0.02372 0.02365 0.02156 0.02087 0.01984 0.01441 

0.02815 0.02798 0.02708 0.02636 0.02508 0.01878 

0.06133 0.06089 0.05683 0.04914 0.04446 0.02577 

0.03603 0.03578 0.033910.03084 0.0291 0.02021 

0.02684 0.02663 0.02549 0.02428 0.02319 0.01951 

0.0246 0.0244 0.02382 0.022370.0215 0.01576 

0.051090.050710.04708 0.04272 0.04085 0.02729 

0.0263 0.026110.02545 0.02399 0.02275 0.01437 

0.02452 0.02442 0.02343 0.02178 0.020510.01534 

0.04762 0.04716 0.04426 0.0366 0.03338 0.02212 

0.02793 0.02788 0.027560.02305 0.02068 0.01711 

0.03618 0.03592 0.03307 0.02787 0.02693 0.02169 

0.04408 0.04378 0.0404 0.0344 0.03183 0.02087 

0.02392 0.02383 0.02344 0.02223 0.020610.01662 

0.02255 0.02242 0.02202 0.02125 0.02038 0.01492 

0.02533 0.02522 0.02476 0.02377 0.023010.01637 
Sorted results 

Prob. Peak 96 hr 21 Day 60 Day 90 Day Yearly 

0.032258064516129 0.06133 0.06089 0.05683 0.04914 0.04446 0.02729 

0.0645161290322581 0.051090.050710.04708 0.04272 0.04085 0.02577 

0.0967741935483871 0.04762 0.04716 0.04426 0.03803 0.03485 0.02212 

0.129032258064516 0.04702 0.0467 0.04351 0.0366 0.03338 0.02171 

0.161290322580645 0.04408 0.04378 0.0404 0.0344 0.03183 0.02169 

0.193548387096774 0.042310.04202 0.03923 0.033710.03075 0.02125 

0.225806451612903 0.03635 0.03606 0.0345 0.03084 0.02967 0.02113 

0.258064516129032 0.03618 0.03592 0.033910.03062 0.02962 0.02087 

0.290322580645161 0.03603 0.03578 0.033070.030610.0291 0.02055 

0.32258064516129 0.03422 0.03396 0.03246 0.02953 0.02897 0.02021 

0.354838709677419 0.03352 0.03334 0.03227 0.02787 0.02693 0.01984 

0.387096774193548 0.028660.02845 0.02756 0.02639 0.02508 0.01951 

0.419354838709677 0.02832 0.02808 0.02723 0.026360.0249 0.01878 

0.451612903225806 0.02815 0.02798 0.02708 0.02588 0.0241 0.01798 

0.483870967741936 0.02793 0.02788 0.027010.025510.0234 0.01734 

0.516129032258065 0.02777 0.02769 0.02686 0.02428 0.0233 0.01726 

0.548387096774194 0.02732 0.02723 0.0262 0.02428 0.02319 0.01711 

0.580645161290323 0.02684 0.02663 0.02549 0.02399 0.023010.01662 

0.612903225806452 0.0263 0.026110.02545 0.02377 0.02275 0.01637 

0.645161290322581 0.02597 0.025810.02514 0.02336 0.02192 0.01637 

0.67741935483871 0.025610.02556 0.02514 0.02305 0.02185 0.01576 

0.709677419354839 0.02547 0.02532 0.02486 0.02282 0.0215 0.01568 

0.741935483870968 0.02533 0.02522 0.02476 0.02237 0.02068 0.01534 

0.774193548387097 0.0246 0.02442 0.02382 0.02223 0.020610.01519 

0.806451612903226 0.02452 0.0244 0.02344 0.02191 0.020510.01492 

0.838709677419355 0.02392 0.02383 0.02343 0.02178 0.02038 0.01441 

0.870967741935484 0.02372 0.02365 0.022810.02125 0.020010.01437 

0.903225806451613 0.02342 0.02327 0.02202 0.02125 0.01984 0.01347 

0.935483870967742 0.02255 0.02242 0.02156 0.020870.01978 0.01296 

0.967741935483871 0.01997 0.01986 0.01957 0.01728 0.01656 0.01068 

0.1 0.04756 0.047114 0.044185 0.037887 0.034703 0.022079 

Average of yearly averages: 0.018085 

Inputs generated by pe5.pl - Novemeber 2006 

Data used for this run: 

Output File: CYFLUTHRIN 

Metfile: w03940 .dvf 

PRZM scenario: MScottonSTD.txt 

EXAMS environment file: pond2 9 8 . exv 

Chemical Name: Cyfluthrin 

Description Variable Name Value Units Comments 

Molecular weight mwt 434.29 g/mol 

Henry's Law Const. henry 3.7e-6 atm-mA3/mol 

Vapor Pressure vapr 1.5e-8 torr 

Solubility sol 2.32e-3 mg/L 

Kd Kd mg/ L 

Koc Koc 123950 mg/L 

Photolysis half-life kdp 4.5 days Half-life 

Aerobic Aquatic Metabolism kbacw 51.5 days Halfife 

Anaerobic Aquatic Metabolism kbacs 60 days Halfife 

Aerobic Soil Metabolism asm 116.9 days Halfife 

Hydrolysis: pH 7 0 days Half-life 

Method:CAM 2 integersee PRZM manual 

Incorporation Depth: DEPI 0 cm 

Application Rate: TAPP 0.056 kg/ha 

Application Efficiency: APPEFF 0.95 fraction 

Spray Drift DRFT 0.039 fraction of application rate applied to pond 

Application Date Date 01-07 dd/mm or dd/mmm or dd-mm or dd-mmm 

Interval 1 interval 3 days Set to 0 or delete line for single app. 

app. rate 1 apprate 0.056 kg/ha 

Interval 2 interval 3 days Set to 0 or delete line for single app. 

app. rate 2 apprate0.056 kg/ha 

Interval 3 interval 3 days Set to 0 or delete line for single app. 

app. rate 3 apprate 0.056 kg/ha 
Interval 4 interval 

app. rate 4 apprate 0.056 

Interval 5 interval 

app.rate5 apprate0.056 

Interval 6 interval 

app. rate 6 apprate 0.056 

Interval 7 interval 

app. rate 7 apprate 0.056 

Interval 8 interval 

app. rate 8 apprate 0.056 

Interval 9 interval 

app. rate 9 apprate 0.056 

Record 17: FILTRA 

IPSCND 1 

UPTKF 

Record 18 : PLVKRT 

PLDKRT 

FEXTRC 0.5 

Flag for Index Res. Run 

Flag for runoff calc. RUNOFF 

IR 

none 

days Set to 0 or delete line for single app. 

days Set to 0 or delete line for single app. 

days Set to 0 or delete line for single app. 

days Set to 0 or delete line for single app. 

days Set to 0 or delete line for single app. 

days Set to 0 or delete line for single app. 

EPA Pond 

none, monthly or total(average of entire run)