UNITED STATES ENVIRONMENTAL PROTECTIONAGENCY 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. Functioningas the first stage ofthe risk assessmentprocess for registrationreview, this problem formulation provides an overview of what is currently known about the environmental fate and ecological effects associated with cyfluthrinand beta-cyfluthrin. It also describes the preliminary ecological risk hypothesis and analysis plan for evaluating and characterizing risk to non-target species in support ofthe 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-cyfluthrinand theiroverall 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 speciesrisk 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 estuarinelmarineorganisms, chronic effects to benthic organisms, and toxicity to terrestrial and aquatic plants. For beta-cyfluthrin, data gaps include chronic effects to aquatic invertebratesand 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

Unstatedstereochemistry, consists of eight isomers C1



# July 29,2010 

# Environmental Fate and Effects Division Office of Pesticide Programs 

# US Environmental Protection AgencyPrepared by: Amanda Solliday, Biologist Jos6 

### L. MelCndez, Chemist Secondary Review: Keith Sappington, Senior Scientist Mah 

### T. Shamim, Ph.D., Branch Chief
Environmental 

### Risk BranchVTable of Contents 1



### . Purpose



### .................................................................................................................................... 6



### .............................................................................................................. 2



### . Problem Formulation 6 2.1 Nature of Regulatory Action



### ................................................................................................ 7 2.2. PreviousRisk Assessments



### .................................................................................................. 7



### .......................................................................................... 3

. Stressor Source and Distribution 13



### ........................................................................................................ 3.1



### . Mechanism of Action 18



### ............................................................................................ 3.2. Overview of PesticideUsage 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. Integrationof Exposure and Effects



### ................................................................................. 59 7.5. Deterministicand ProbabilisticAssessment 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 requestjustification tables



### .................................................................. 811. Purpose
The purpose ofthis problem formulation is to provide the foundation for the ecological risk assessmentbeing 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 assumptionsneeded to address those uncertaintiesin characterizing the ecological risk associated with the registered uses of cyfluthrin and beta-cyfluthrin. Cyfluthrin is a Type 

### I1 syntheticpyrethroid insecticidethat is registered for numerous agricultural, non-agriculturaland residentialuses, such as (but not limited to) alfalfa, almond, apple, beans, brassica (head and stem) vegetables, carrots, citrus, corn, cotton, cucurbitvegetables, 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 and1or shade trees, ornamental lawns, tobacco and wood protection to buildings. Type 

### I1 pyrethroids are characterizedby the cyano moiety in their chemical structure (Type 

### I pyrethroids do not contain this moiety, see Mechanism of Action for additional distinctionsbetween 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 effectsproperties 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 residentialuses 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 forage1fodder1hay, 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, fencerowslhedgerows, greenhouse -empty, hospitals1 medical institutionspremises, domestic dwellings, ornamental and1or shade trees, ornamental lawns and turf, paths1patios, paved areas, recreation area lawns, residential lawns and wood protection treatmentto 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 RegistrationReview of cyfluthrin and beta-cyfluthrin. Previous risk assessmentswere completed for the uses of these chemicals, which serve as the basis for this assessment. The Food Quality ProtectionAct (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 causeunreasonable risks to human health, workers, or the environment when used as directed on product labeling. The registration reviewprogram is intended to ensure that, as the abilityto 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 periodicallyreevaluate$ pesticidesto make sure that as change occurs, products in the marketplace can be used safely. As part of the implementationofthe new RegistrationReview 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 formulationfar the environmental fate and ecological risk assessment chapter in support ofthe registration review is intended for the initial docket opening the public phase of the reviewprocess. 2.2. Previous Risk Assessments and ScientificAdvisory Panels
Previous Assessments Recent risk assessments conducted on cyfluthrin and beta-cyfluthrin, indicated risk concerns for freshwater and estuarinelmarineorganisms. 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 similarto those previously identified)for proposed new uses of cyfluthrin (D33 1952+),beta-cyfluthrin (D332314+),and cyfluthrin and beta-cyfluthrin (D340740+). The first new use risk assessment for cyfluthrin, covered its use of the chemical on grasses; the secondnew use risk assessment for betacyfluthrincovered 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 applicationrate 0.175 lb a.i./Alseasonfor cyfluthrinand 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 assessmentsconcluded 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 containingboth, chlothianidinand 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 spraytreatments." A seed leaching study was required for clothianidinand beta-cyfluthrin. Prior to this assessment, in 2006, a risk assessment was issued for the use of cyfluthrin on tobacco (D3 163 13). The applicationrate 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 estuarinelmarine, fish and invertebrates) to be exposed to cyfluthrin via off target spray drift and1or runoff into surface water. The results indicated that chronic levels of concern (LOCs) were exceeded for estuarine1 marine invertebrateswith a risk quotient (RQ) of 1.35. For the proposed maximum applicationrate on tobacco, the acute or chronicRQs 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. Cyfluthrinis very highly toxic to honey bees on an acute contactbasis, 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 incidentspertaining phytotoxicity for the chemical or other pyrethroidpesticides, there were no phytotoxicity concerns stated in the risk assessment. The environmental fate and ecological effects databaseswere considered mostly complete, but an aerobic aquatic metabolism study was required. In addition,it was indicated that acute freshwater and chronic estuarinelmarine sediment studies were received as follows. The studies are currently in review. MRID 46591507 Cyfluthrin
-Toxicity to Midge (Chironomustentans) During a 10-Day Sediment Exposure.
MRID 46591 506 Cyfluthrin
-Toxicityto EstuarineAmphipods (Leptocheirus plumulosus) During a 28-Day SedimentExposure. 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 18to <32 days; aerobic soil metabolism 73.5-94.8 days; anaerobic soil metabolism of the order of about 30 days), and practically immobile (Kdsranged from 11 16 to 1793mLIg, Koclsranged from 73,480 to 124,000mLlgoc).mote: According to the currentlyused 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 alkalinemedia (half-life 2.1 days), and aqueous and soil photolysis (respectivehalf-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, cyfluthrinappeared to have a high potential to reach surfacewaters by spray drift or in runoff events accompanied by erosion, with cyfluthrinbound to particulate and organic matter in the water column. It was also indicated that the chemical has the potential for depositionin 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 DTsofor depuration 13days). Degradates observed in the studies included DCVA, FPB-ald and FPB-acid, all of which are product ofpyrethroid ester cleavage. In 2004, the EFED issued a risk assessment for severalproposed 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 establishIR-4 tolerances for the use of cyfluthrinon tuberous and corm vegetables (crop Subgroup 1 C), turnip greens, dried shelledpeas 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 exceededfor 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, restricteduse 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 freshwaterinvertebrates, the results indicated that acute RQs for daphniaranged from 4 to 107 and for crayfishranged from 1.7 to 43. Chronic RQs for daphniaranged from 1.3to 61. For estuarinelmarine fish, acute RQs basCd on sheepshead minnow ranged fiom <0.01 to 0.70 while chronicRQs 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 crayfishranged 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 amphibianswere also assumed to be at risk due to a portion of theirlifecycle being spent in aquatic environments, particularly the early life stages that are primarily aquatic and where respirationis 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 cyfluthrinmay be the highest.
In 200 1,the EFED issued an incremental risk assessment for the use of cyfluthrin on Southernpeas (D271494). Conclusionswere based on the previously issued assessmentofthe same or similaruse in the year 2000 (see below). In 2000, the EFED also conducted an assessment for the use of cyfluthrinon 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 estuarinelmarinefishes and invertebratesbased 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 invertebratesand estuarine1 marine invertebrateswere exceeded on an acute and chronicbasis. Chronic data for the freshwater rainbow trout showed LOC exceedancewhile chronic data for the fathead minnow did not show an exceedanceof LOCs when multiple applicationsof cyfluthrin was used. Semi-aquaticand 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 surfacewater contaminationthrough drift and erosion where it will become sorbed mainly on sediment." 

### 1999 Scientzj?~ Advisory Panel A FIFRA ScientificAdvisory Panel (SAP) in 1999 examined the sediment toxicity and fate of synthetic pyrethroids. In response to a questionregarding 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 158requirements 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 

### Kdor 

### KOCto 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 conditionswhile 

### Koc allows estimates partitioning across a wide variety of soillsedimenttypes (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, considerationofthe characterofthe 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 ofbioaccumulation 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 ofpyrethroids to organic carbon and colloidspresent 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, esfenvalerateand bifenthrin (memorandum dated 12/22/03,Rexrode & Melkndez):
850.1735: 10-day Sediment (freshwater)


### - Test organism: Hyalella azteca and Chironomus dilutus. 

## - Duration: 10days, endpoint is survival. EPA/600/R01/020: Chronic EstuarineJMarine Sediment Testing


### - 28 day test on Leptocheirusplumulosus.


### - Percentage ofneonates 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: ChronicFreshwater Sediment Testing


### - 65 day test on Chironomus dilutus. 

## - Survival.


### - Growth rate.


### - Reproduction (# eggs/ female, time to oviposition, proportion of females ovipositing, % hatch). 2009 ScientiJicAdvisory 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 effectsrelated to sodium current tails and neurobehaviloral impact, with esfenvalerateand fenpropathrinshowing symptoms ofboth types. Cyfluthrin and beta-cyfluthrin are Type I1 syntheticpyrethroids, 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 ofthe (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-cyfluthrinhll 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 availablein the docket (with non-copyrightmaterial 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. AquaticLife Criteria andAquaticLife Benchmarks The Clean Water Act requires the Agency to publish water quality criteria that accurately reflect the latest scientificknowledge on the kind and extent of all identifiable effects on health and welfare which might be expected from the presence ofpollutants in any body ofwater, 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 Cyfluthrinand beta-cyfluthrin are not individually identified as a cause of impairment for any water bodies listed as impairedunder section 303(d) of the Clean Water Act, based on informationprovided 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 confluencewith 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 informationprovided at http://iaspub.epa.aov/tmdl waters1Olattains 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 submissionof water quality data for these pesticides. To the extent possible, data should conform to the quality standardsin Appendix A ofthe OPPStandard Operating Procedure: Inclusion of Impaired Water Body and Other Water Quality Data in OPP's Registration Review RiskAssessment andManagementProcess (refer to: http://www.epa.gov/oppsrrdl/registration reviewlwater quality sop.htm), in order toensure they can be used quantitativelyor qualitativelyin 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 cyclopropylring. 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 cyfluthrinwas 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 23or 

### 8 isomers. Cyfluthrin has 2,2-dichloroethenyl and it is 2,2-dimethyl substitutedin the cyclopropane ring. Beta-cyfluthrin (Tables 3.la) is a mixture of four of the isomers of cyfluthrin. Chemically, it is the (R)-alcohol-(1S)-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 environmentalfate properties of cyfluthrin and betacyfluthrin are expected to be similar to each other. Information about the identification of cyfluthrin and beta-cyfluthrinis provided in Table 3.la. A summary of physicochemical properties of cyfluthrin and beta-cyfluthrinis included in Table3.lb.dimethylcyclopropanecarboxylate in ratio 1:2yitJ the enantiomericpair (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- enantiomericpair (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 1:2yitJ the enantiomericpair (R)-a-cyano-4-fluoro-3- phenoxybenzyl(IS)-tmns-3-(2,2- dichloroviny1)-2,2- dimethylcyclopropanecarboxylateUnstated stereochemistry; It consists of 8 isomers

(S)-alcohol (1R)-cis-acidCyfluthrin is a mixture of all possible isomers. 86560-92-1 (diastereoisomer I) 86560-93-2 (diastereoisomer11) 86560-94-3 (diastereoisomer111) 86560-95-4 (diastereoisomer IV) Beta-cyfluthrin is comprisedmainly of FAOIWHO Specifications1 and Cyfluthrin (157)lBetacyfluthrin (228), Draft Review Prepared by Australian Quarantine and Inspection sewice'

DiastereoisomerIV: (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 characteristicsin 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/Ldi; I; 2.111.9uz diast. 11; 3.212.2 ug/L diast. 111; 4.312.9 ug/L diast. IV* *The materialused 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 1.4x 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). 3hW://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 octanollwater partition coefficient (Kow = 9.33~10~). Based on its octanoY water partition coefficient, it appears that cyfluthrin has the potential to bioaccumulatelbioconcentrate (Kow

### 3 1000) in fish and other aquatic organisms.I With a vapor pressure of 1.5x 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 classifiesit as "slightly volatile from a water surface" (USEPA 2008). Cyfluthrid could have a potential to volatilize slightlyfrom wet surfaces. The potential to volatiliz may be greatly attenuatedin the environmentby its tendency to bind to organicmatter

# I" (e.g., soils, sediments, or organic matter and particulatein natural water). For cyfluthrih,the log 

### KOArange is 9.79 - 11.88 (calculated and EPIWEB v.4.0 estimates), the log is 5.97 and the rate of transformationis moderate in the environment and appears tobe moderate in fish (the majority of the residues observed in fish were the parent compound), with moderately rapid depuration (observed depurationDT50 of approximately3 days). Therefore, it appears that cyfluthrinmay have a lowpotential 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

**Gobaset al. ,2003and Armitage & Gcjbas, 2007 support this prqsumption utilized here onl* as a broad referenceto detbrmine the potential for biomagnifi ation. 

# 1 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 diastereoisomericenantiomer pairs. Kow - K,=-- KowRT =6.17 x lo9(9.79) KAW Henry'sLaw Constant Calculated using kw = 9.33 x lo5and HLC = 3.7 x 1w6 atm-m3/mol;the temperaturewas assumed to be 25°C. EPIWEB est.: 1.47x 101° -7.52 x 10" (10.164-11.876) KAW = Cair/Cwater =HLCIRT = 1.51x (-3.82) EPIWEB estimate: KAW = 1.18x 1 

### o'~ (-5.926) 'Slightly volatile from a water surface'
Cwatm S xT x R x760 = 6,612 (unitless) - =

# ( 

# 1 c,, PXGMWX~O~

'Slightly volatile from a water surface' 0.856 days (Assumptions: 12-hr days; 1.5 x lo60H/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 appearsto be moderately rapid in fish, with moderate to

rapid depuration indicated. Therefore, it appears that cyfluthrin may have a lowpotential 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' presumptionwas utilized here as a general or broad reference to detect the potential for biomagnification in terrestrial food chains for these chemicals.
Even though various degradateswere 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 neurotoxicmode 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 informationon the toxicity of these degradateswill be considered to confirm this assumption.

3.1. Mechanism ofAction Table3.1~.

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 ofpyrethroids is characterized by a rapid "knock down," or paralysis, of insects. All pyrethroids act as axonicpoisons, affecting both the peripheral and central nervous systems, and share similarmodes 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 ofthe 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-phenoxybenzoicacid
or 3-phenoxy-4-fluorobenzoic acid of Cyfluthrin and Beta-cyfluthrin
Structure 

# clqAH
H3C CH3 

# aF')'J+

\ o 

## / /'O 

# ~~nfo

OH(calciumion) channels coupled with a stimulatory effect on the voltage-gated Na+ (sodium ion) channels. The pyrethroids (including cyfluthrinand beta-cyfluthrin) share similar modes of action, and are considered axonicpoisons that affect both the peripheral and central nervous system.
It is now well established that severeneurological symptoms of poisoning with pyrethroids in mammals and insects are the result of modificationof the Na+channels activity (cellular pores through which ~a+ ions are permitted to enter the axon to cause excitation) (Matsumura, 1985). Advanced electrophysiological experimentsusing voltage clamp and patch clamp, together with ligand-binding and ionic flux experiments, have unveiled unique actions of pyrethroids ofkeeping the Na+charnel in the open state for an extremely long period, sometimes as long as several seconds. This modificationof 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 ofthe insect. Pyrethroids have also been shown to suppress GABA and glutamatereceptor-channel complexes and voltage-activated ca2' channels, but the toxicological significanceof these actions is uncertain. Relative to physiological responses, researchershave designated two types ofpyrethroids, Type I (e.g.,bifenthrin, resmethrin, permethrin) and Type I1 (e.g., cypermethrin, deltamethrin, fenvalerate, cyfluthrinand 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 reversibleknogkdown 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 agriculturaluse 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. 264-811,264-812,264-813and 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 OFAPPS. 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 0.131Table 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, broccoliraab (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, Chinesewaxgourd, citron melon, cucumber, gherkin, edible gourd (includes various), muskmelon (mcludescantaloupe, honeydew melon and others),pumpkin, summer squash (includes zucchini and others), watermelon, Winter squash (includes calabaza, and others) Fruiting Vegetables: eggplant, groundcherry, pepino, pepper (includesbell 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: adzukibeans, 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 0Table 3.2a. Summary use information for cvfluthrinbased onBAYTHROIDG9 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, Orientalradish, rutabaga, salsify (various), skirret,turnip Citrus** calamondm,citrus citron, citrus hybrids (includeschlronja, tangelo), grapefnrit,kumquat, lemon, lime, mandarin (tangerine), orange,pummelo, satsuma mandarin, white sapote and other cnltivars and/or hybrids of these **Californiaand Arizona, only. Grape:table grape, raisin, wine and muscadme grape (ProductLEVERAGE@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, macadamianut, 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 14Table 3.2b. Summary use information for beta-cvfluthrin,based on BAYTHROIDBXL (Reg.No. 264-840), LEVERAGE@ 360 labels.

USE Soybean Sugarcane Sunflower Tobacco

Brassica (Cole) Leafy Vegetables: broccoli, broccoliraab (rapini), Chinese (gal lon) broccoli, Brussels sprouts, cabbage, Chinese (bok choy) cabbage, Chinese (napa) cabbage, Chinesemustard (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 (includesvmous), 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: adzukibeans, 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, edlbleburdock, carrot, celeriac, turnip-rooted chervil, chicory, ginseng, horseradish, turnip-rootedparsley, 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 PONCHOBETA

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

0As 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 EmulsifiablePyrethroid Insecticide (Reg.No. 264-745), RENOUNCE@20WP Insecticide (Reg.No. 264-784) and PONCHOBETA (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 PONCHOBETA (Reg. No. 264-1056)

In general, for a given crop, the applicationrate for beta-cyfluthrin is around halflthat for cyfluthrin. For agriculturalproducts, applicationmethods include aerial or grounflspray (foliar) and ULV. In addition, soil applications are possible,particularly for corn! The labels for cyfluthrin and beta-cyfluthrinrequire 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 agriculturalproducts should not be applied by ground equipment within a distance of 25 ft, or by aerial equipment within a distance of 150ft, or by ULV within a distance of 450 ft from freshwater or estuarine1marine bodie$of water (e.g. lakes, reservoirs, rivers,permanent streams, marshes or natural ponds, estuaries and commercial fish farm ponds).
For corn, granular formulationsare 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 (includeschlronja,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 muscadinegrape/ For the productLEVERAGE@360 HOP Pome Fruit: apple, crabapple, loquat, mayhaw, pear, Orientalpear, quince Stone Fruit: apricot, cherry, nectarine, peach, plum, plumcot, prune (fiesh and dried) TreeNut Crops: almond, beechnut, Brazil nut, butternut, cashew, chestnut, chinquapin, filbert, hickory nut, macadamianut, pecan, pistachio, walnut (black and English) Alfalfa

Grass (pasture,rangeland, grass for seed, grass for hay, grass in mixed-stands with alfalfa) Sugarbeet, 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 0.044per

cutting 0.0221app.

0.0221 cutting -0.01251 inch). The buffer zone is 60 ft from adjacentbodies ofwater. The granular formulations also contain 0-12-(1,l

### -Dimethylethyl)-5-pyrimidinyll-0-ethyl 0-(1- methylethyl) phosphorothioate,an organophosphate insecticide, commonly named phostebupirim. Cyfluthrinand beta-cyfluthrinmay be co-formulated with imidacloprid, in the products LEVERAGE@2.7 Suspension Emulsifiable Insecticideand LEVERAGE@ 360 Insecticide. For beta-cyfluthrin, the product PONCHO@

### BETA is coforrnulatedwith chlothianidin, for the use on sugarbeet 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 exhaustivereview 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),isprovided in 

### Table 3.3. The table is arranged in alphabetical order of crops. According to the table, the major agriculturaluses 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 averagepercent 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 percentagesmay 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 <2.5There 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 35 <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 

### '+' Cropsr~ot knowndata was found for this chemical (as of January 2010).
The U.S. Geological Survey (USGS) pesticide agriculturaluse maps (Fig. 3.1) show regional scale patterns in use intensitywithin 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 1999through 2004, and on the 2002 Census ofAgriculture for county crop acreage crop. According to the map, the major agriculturaluse 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 agreementbetween the SLUA and the USGS map. The map shows a generalized use of cyfluthrin for agriculturalpurposes throughout the country, with highest uses in the cornbelt and the cottonbelt. It also shows potential uses in estuarine1marine regions of the US. Multiple agriculturaluses 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 agriculturalmap for beta-cyfluthrin.CYFLUTHRIN

## - insecticide 2002 estimatedannual aglrioultural use



## A"z3 (pounds perst Q noastimateduse 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 useof ve ingredient quare mileof agricuttural

alfalfa hay
citrusfIit sorghum sunfiwverseed nd inown&) rrlrrtlt pYy..yo Y,.r-J natiiluse

68061 46.96 28125 19.41 19613 1853 9794 6.72 6862 4.74 4343 3.00 3399 2.3s 2127 1 A7 1553 1.07 395 027 Total *-.^all 1 CrODS MIA= m&r

Fig. 3.1. Estimated Use of Cyfluthrin in 2002

In additionto the classical agriculturaluse sites, cyfluthrin and beta-cyfluthrinhave multiple other uses. Cyfluthrin and beta-cyfluthrinmay be used in multiple urb environments. Many ofthese 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 applledto 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 specificyear, 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 1992USGS National Land Cover Data NLCD) The key llmitatlonsof 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 specificyear, but represent typical use patterns for the five year period, (3) statepesticide use coefficients Lay not have

ornamental herbaceous plants, ornamental woody shrubs and vines, paths1patios,paved areas (private roads1 sidewalks),pet living1 sleeping quarters, and residential laws. Tables3.4a and 3.4b provide a summary ofthe terrestrial nonagriculturaluse sit$sfor cyfluthrin and beta-cyfluthrin, respectively. Applicationmethods vary. Many ofthese uses could involve substantive exposureto wildlife, specifically, aquatic organisms, and been availablefor all states where a pesticide may have been applied to agricultural land, and therefore, are not d~splayed on the county crop acreageis based on the 2002 Census ofAgriculture 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 ofpesticideuse, such as estimatesat the county level Pleaserefer 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

Ithey will be assessed accordingly (e.g.,commercial/industrial lawns, residential lawn, golf course turf, ornamentallawns and turf, recreation areas and residential lawns). (Note that there are fewer non-food uses for beta-cyfluthrinthan for cyfluthrin.) Another use that will be evaluated is wood protection treatment (outdoors).In addition, there are several other indoor non-food or indoor residentialuse sites for both cyfluthrin and beta-cyfluthrin, like for example, commercial/institutional/industrial premiseslequipment (indoor), dairieslcheeseprocessingplant premises (nonfood contact), eating establishments, food processing plant premises (nonfood contact), food stores1 markets1 supermarkets premises, hospitals1medical institutionspremises and household/ domestic dwellings. Cyfluthrin and beta-cyfluthrin also have greenhouse uses. 

### Table 3.4b. Uses Classified as Non-Food or Outdoor forBeta-cyfluthrin

For the indoor uses, the Division has conducted environmentalrisk assessmentsfor a few chemicalsfor Re-registration Eligibility Decisions. In an open literature study (weston and Lydy 201O), several synthetic pyrethroidswere observed in effluents after secondary treatment from POTWs in the Sacramento-San Joaquin Delta. In the study, bifenthrin was the most frequentlydetected pyrethroid. Cyfluthrin was found in 6% ofthe municipal wastewater treatmentplant effluents (POTWs) tested in the Sacramento-San Joaquin Delta (1

### 8 samples), at a maximum concentration of 1.7ngIL, and it exceeded the Hyalella azteca ECsoof 1.9ngL in 0% ofthe samples. This study indicatestherd 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 organismsfrom the various indoor uses of cyfluthrinand beta-cyfluthrin (see also further informationbelow). Toxicity data on environmental mixtures of cyfluthrin or beta-cyfluthrin with othtr pesticides may be presented, if available, as part ofthe ecological risk assessment. It is expected that the toxic effect of cyfluthrin or beta-cyfluthrin, in combinationwith other pesticidesused 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 otherphysical1 chemical characteristics of the receiving waters (e.g. organicmatter present in sediment and suspended water). Quantitatively predicting the NS =Not Specified;AN =AsNeeded, cc =crop cycle. Data obtained fromLUIS 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 1yr

NS NS NS
NS 61 1yr 6/ 1yr, NS 11cc NS Use householdidomesticdwellings outdoorpremises
ornamental andlor shade trees ornamental ground cover ornamental herbaceous plants ornamentallawns and turf ornamental woody shrubs and vines
paved areas (privateroadslsidewalks) recreation area lawns residential lawns

wood protection treatmentto 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 formulationscombined 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 availablepesticide mixture effects data regarding the confidence of risk assessment conclusionswill 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 potentiatorlsynergistused with pyrethroids, has similar effects as those observed for piperonyl butoxide (Hodgson & Smart 2001).
A total of 4 currentproduct 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 exposureto formulationsby 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 cyfluthrinuses containing synergistswill 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. Piperonylbutoxide andlor MGK-264 from other pyrethroid applications (e.g. the applicationof an adulticide containing PBO), could interact with cyfluthrin and beta-cyfluthrinin 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 interactionswill be discussed qualitativelyin 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 expectedto 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 synergistvary 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 availablefrom which to draw conclusions regarding the potential effect ofthe 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 chemicalswere conducted with cyfluthrin, which comprises all eight isomers. The environmental fate properties of cyfluthrinand beta-cyfluthrin are expected to be similar to each other. [~hen~l-l~~lradiolabeled compound was utilized in most instances. A summary of environmentalfatel transport properties for cyfluthrin and beta-cyfluthrin is included in 

### Table 3.5.Table 

### 3.5. Summary beta-cyfiwthrin.

PARAMETER Hydrolysis Half-life bH5,7,9, (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 CarbonPartition Coefficient (Koc) For trans-DCVA

Terrestrial Field Dissipation Half-life transport properties

SOURCE MRD00131493, 00137539,45022101

MRID 00149595, 45022102

MRID 00137543, 00157043 MRID 00131494

MRID 00131494 MRID, 46824101

NA
MRD00131495, 00137544,45022103

MRID 43424901

MRID.AN 259211, 44822901,42794801 ofthe environmentalfate 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; degradahonproduct 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 DegradatesDCVA, FPB-acid and FPB-aid No StudyAvalable 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 SandyLoam 0.36 44 SandyLoam 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 obtaineduslng 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 consideredvery 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, cyfluthrinwas classified as

immobile in the six test soils To help EFED develop a Kd input for

modeling, the registrant later submitted a supplementalstudy 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 screenedonly and a full review will be provided at a later time.Cyfluthrin and beta-cyfluthrin are Type I1 syntheticpyrethroids (they are cyano substitutedin the alphaposition. Cyfluthrin and beta-cyfluthrinhave a 2,2- dichloroethenyl,and they are 2,2-dimethyl substitutedin the cyclopropane ring. The database for cyfluthrin has been used as a surrogatefate database for beta-cyfluthrin sincethey 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 alkalinemedia (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 studieswith half-lives and ~~~0's in the range of 18-32days, which would indicate that the chemical follows mix routes of dissipationin the field. The Koc7s ranged fi-om-73,000-1 80,000 mL/gac, indicating low mobility. Like other pyrethroids, cyfluthrinand beta-cyfluthrinbihd strongly to soils suggestinga low potential to leach to subsurfaces and to contaminate groundwater. The moderatepersistence of the chemical, the high soil affinity and very low solubility indicate that the chemicals have a high potential to reach surface waters in moffevents 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 surfacewaters, 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 cyfluthrinmay be applied repeatedly, the material may build up in sediments and affect benthic communities. Cyfluthrin and beta-cyfluthrinare moderately bioaccumulative with moderately rapid rates of depuration (estimated half-depuration time 13days). Major metabolites observed in laboratory studiesinclude 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 ofthe environmentalfate and transport properties of cyfluthrin and beta-cyfluthrin.

Transport The potential impact to water quality fiom the use of cyfluthrin appearsto be mostly due to the parent compound. Laboratory studies show that cyfluthrin is moderately persistent under most environmental conditionsmaking the compound available for runoff. Although the potential for mobility appears low, the likely means of cyfluthrinmovement fi-oma crop site to an adjacentbody of water would be runoff accompanied by erosion, as well as spray drift. Laboratory studiespredict 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 lypophilicityand affinitywith particulate should make it unavailable to photolysis in a shortperiod. In addition, COMMENT

- SOURCE MRID. 00143143 PARAMETER Bioaccumulationin Fish (BCF) VALUE(S) (units) MaximumBCF=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 significantthreat to ground water qualityunder 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 ofthese degradates are limited by the available data. 

### Degradation andMetabolism The hydrolysis of cyfluthrinwas pH dependent. It was fast in alkalinemedia (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, cyfluthrinhydrolyzed/ degraded with a half-life of 9 days. An importantroute 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 solutionunder natural sunlight. The major degradateswere FPB-acid (4-fluoro3-phenoxybenzoic acid) and FPB-ald (4-fluoro-3-phenoxybenzaldehyde). Soil photodegradationmay also be an important route of dissipationfor 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 degradateDCVA 

### 13-(2,2-dichloroviny1)-2,2-dimethylcyclopropanecarboxylic acid] is formed in the hydrolysis and the aqueousphotolysis 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 formationof carbon dioxide and the only fluoro-phenyl degradate detected at appreciable amounts was FPB-acid (7% ofthe 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 degradateDCVA 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 12-62days (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 cyfluthrinin 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 ofthe results ofthe Dutch systems is regarded as low, and those half-lives should not be used for modeling. Three degradateswere 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 atthis time. Sorption and Mobility Cyfluthrin is hydrophobic and was hardly mobile to immobilein four soils (Kdrange 1116to 1793mL1g; Koc range 73,000 to 180,000mL/goc; measurements made at single concentrations,FA0 mobility classification, FA0 2000). The chemical will bind stronglyto the soil surfaces. There was a linear relationshipbetween the soil organic carbon content and cyfluthrinKdvalues (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 carboxylateester 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 14to 356 mL/goc, FA0mobility classification). Even though cyfluthrinmay be applied aerially,by ground or ULV, and drift is possible, the chemical appears to be relatively non-volatile (vapor pressure 1.5x 10" mmHg, Henry's Law Constant 3.7 x 1 

## o-~ atm-m3/mol). Furthermore, cyfluthrinreadily binds to soils or partitions with suspended matter and sediment. Thus, volatilizationwould be greatly reduced. FieldDissipation 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 18days (r2=0.94, n = 8), or with a DTsoof <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 studywas 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 organicmatter content showedthat cyfluthrin (in thd form of Baythroid 24% EC), sprayed at 1kg 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. Cyfluthrinwas 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 octanollwater partition coefficient, cyfluthrin shows a high potential to bioaccumulate (I(Ow = 9.33 x lo5). The bioconcentration factor in whole rainbow troutwas moderate (854x, whole fish). Residues were depurated at moderately rapid rates in untreated water (apparent depuration half-life of approximately53 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 characterizationis also summarized for the various degradation products formed by each process for the studiesreviewed 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 syntheticpyrethroid. FPB-acid was identifiedin 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 photolysislphotodegradation 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 degradateDCVA 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 degradatesresulting from the rupture of this linkage. There is evidence of the formationof DCVA, but there is no further information on the possible degradationpathways. 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% ofthe 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 uncertaintieswere 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

-

-

157% at 1 day

- DCVA (% app)

-

-

- >lo% in 100-day studies

-

47.63% at 28 days 0 16mg/Kg at 30 daysAlso, the fate of cyfluthrinin anaerobic aquatic environments is uncertain. Studiesusing 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 ofthe 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 (mobilityand persistence) of degradates of cyfluthrin,FPB-ald, FPB-acid, cyfluthrinamide, and cis/ trans-DCVA. The limited data available indicate that DCVA is mobile to moderately mobile and has the potentialto 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 cyfluthrinwas obtained at a single concentration. EFED has available

### Kdand 

### Koc values, but no Freundlich 

### KFand 

### 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 terrestrialreceptors, such as birds, reptiles, mammals, amphibians, freshwaterand estuarinelmarine fish, non-target terrestrial & aquatic invertebratesand 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 describedin 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 ofbroad 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 ofthe 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 ofthe potential acute toxicity of cyfluthrinand beta-cyfluthrin,by providing the acute tqxicity classifications.

Terrestrial SpeciesA 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 indicatereproductive 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=50ppm). 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 LD50400mglkg 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 endpointsfor 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 150mgkgbw (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 cyfluthrinappears to be practically non-toxic on an acute basis to avian speciesbased on a bobwhite quail (Colinusvirginianus) single dose LDsO of >5000 mg/kg bw (0013 1498, acceptable) and an 8-day dietary LCs0of >5000 mglkg diet for the bobwhite quail and mallard duck (Anasplatyrynchos) (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 reproductiveperformance, includinglow embryo viability, hatchling number and 14-day survivorship, the results ofthis study are classified as supplemental. In another one-generationreproductive 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 00158782, supplemental). In this study,no statistical differences in reproductive parameters between the controls and treatmentswere determined at any concentrationtested (10, 50 and 250 mg/kg diet). Responsevariables examined include eggs laid, eggs cracked, eggs set, viable embryos, 3-week embryos,hatchlings and 14-day survivorsper hen. Pathological results showed an increasein egg yolk peritonitis and regressing ovary at levels as low as 10mglkg diet (lowest level tested). In this study, control bird reproduction appeared to be impaired, as indicatedby a low number of eggs laid, embryo viability and hatching rate compared to guideline criteria.
Two studieswere submitted for bobwhite quail, yielding less sensitivereproductive endpoints than the mallard studies. The NOAEC = 900 and 1000mg/kg diet, for MRIDs 00152829 (acceptable) and 00145330 (supplemental),respectively. Effects observed include low body weight gain in males and low 14-daysurvivorship at 4000 mg/lQg diet level.
TerrestrialInvertebrates Cyfluthrin is highly toxic to nontarget terrestrial invertebrates. A 48-hour acute contact study on honeybees (Apis mellifra) with cyfluthrintechnical produced an LDso= 0.037 pglbee (MRID 00153638, acceptable).A 10-day honey bee residual toxicity study with cyfluthrin2 EC (Baythroid)indicated that the formulated product is also highly toxic to nontarget terrestrial invertebrates, with and ECsoof 0.045 pglbee (MRID 00162586).
Terrestrial Plants No terrestrialplant 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

(Honeybee) Original this time additional data evaluation.

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

Beta-cvfluthrin: 960

mgkgbw (male)

1150mgkgbw (female) 29 1mglkg 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%
1983by W. but may toxicity studies for

classification nd

Accession #072008 Acceptable

44251 101 Acceptable
Accession #004334 Acceptable
Accession #072009 Acceptable

0013 1498l

00131500~ 001315012

0014533l3 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 atFaatz. Study not required at this time because a cursoryreview indicates that the study is acceptable,but may be requiredpending additional data evaluation.

This endpointis based on the most sensitiveregistrant-submitted study available. However, in this study, the endpoint is non-definitive.Another study conducted on mallard ducks with lower treatment concentrations (10-250 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 studieshave been submittedto 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 technicalreslulted 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 00155898, 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 1450401, acceptable). I I Daphnia magna is used as the test species for freshwater invertebratesfor both adute and chronic effects. Acute toxicity values for daphnids suggest that cyfluthrintechnic@l is very highly toxic to freshwater invertebrates,with a 48-hour ECsoof 0.141 pg a.i//~ (MRID 0013 1504).An acute 48-hour study examining beta-cyfluthrin technical dffectsto daphnidsproduced 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 significantdegradation, 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% ofthe total carbon-labelled residues were the parent compou

# !
d. Therefore, the mean-measured concentrations were adjusted to reflect the percendage of cyfluthrinin the final endpoint calculations (endpointsbased 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 (Chironomustentans) has been submitted (MRID 46591507, in review). Based on preliminary results from this study, cyfluthrin is very highly toxic to freshwaterbenthic 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 submittedby the registrantresulted in a 39-day NOAEC = 0.025 yg a.i./L and a LOAEC

= 0.084 pg a.i./L,based on reducedjuvenile survival.Another early life stage study has been submitted, yielding less sensitive endpointsbased on treatment-relatedmortality (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 representedby the mysid shrimp (Mysidopsis bahia) and eastern oyster (Crassostrea virginica) with toxicity studies indicating cyfluthrin is very highly toxic to both. Cyfluthrin technicalproduced 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 EC50was 2.69 pg a.i.1L for cyfluthrintechnical (MRID 00158783, acceptable). A chronic study with estuarinelmarine invertebrateshas 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./Lbased on adverse effects to growth and survival (MRID 00158785, 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 Scenedesmussubspicatus was submitted for cyfluthrin, but the test was determined to be invalid due to low test substance solubilityand absence of analytically-determined concentrations (MRID 41450402).Another study with green algae (Pseudokirchneriella subcapitata, formerly known as Selenastrumcapricornutum) 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 solublemeasured concentrations.No studieshave been submitted for aquatic vascular plants. Toxicity of Degradates Four aquatic toxicity studieshave been submitted for degradatesof 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. Studieswith 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 Daphniamagna resulted in an ECsO=l .3mg 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 131502 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 Table4.2. 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 FishECOTOX Available open literature will be used to evaluate the potential direct effects of cyfluthrin and beta-cyfluthrinto 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 completeECOTOX 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 speciesthat are sensitiveto the chemical and from changes in structure and functional characteristicsof 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 nontoxicendpoint for terrestrial insects. Efficacy studies do not typically provide endpointvalues 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 indicatesreported ecological incidents associated with the use of cyfluthrin and betacyfluthrin. A search for incidents involving cyfluthrin and beta-cyfluthrinwas also conducted in the AmericanBird 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 incidentswith certainty categoriesof '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' classificationmight be applied in situationswhere a given chemical is practically nontoxic to the category of organismkilled and/ or there is evidence that another pesticide or stressor likely caused the incident. Incidents classified as 'unlikely' for cyfluthrin and beta-cyfluthrinwill not be included in this Problem Formulation or the ecological risk assessment conducted for RegistrationReview. A total of eight reported ecological incidents associated with the use of cyfluthrinhave been reported to the Agency. No incidents associated with beta-cyfluthrinwere 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 incidentswere reported between 1993 and 2005. Four of the incidents were associated with registereduses of cyfluthrin, two were associated with uses where it was undetermined if the use was a registered use, and two incidentswere associated with misuse. The certainty that the incidentswere 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. WildlifeIncidents Associated with Cyfluthrin 1

Residue Legality

ofUse Use Certaijty category1 Year Magnitude Incident Number Location (County,

State) Taxa InvolvedTable 

### 4.3.
Incident Number

1004564-

001 1

1003621-

Ool

I003351- 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

NoAquatic 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 applicationcontained 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 # I003621-00 1 -After a heavy rainfall, cyfluthrin (Aztac 2.1%) washed into a stream where hundreds ofbluegill (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 # I00335 1-021 -Cyfluthrinwas 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 CaliforniaDepartment of Fish & Game. Cyfluthrin and chlorpyrifos were aerially applied to an agriculturalfield adjacent to the site ofthe kill. Approximately 400 fish died, including 320 flathead catfish (Pylodictis oilvaris), 60 grass carp (Ctenopharyngodonidella) and 20 largemouthbass (Micropterus salmoides). Two water sampleswere analyzed, and chlorpyrifos was found in bpth water samples (0.08 and 11.7ppb) and cyfluthrinwas found in one sample (0.33 ppb). Analyses of fish gillsranged 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 Lousianain 1999.Both cyfluthrin ad profenofos were aerially applied to cotton fields 100yards from 200 acres ofpdnds. The LousianaDepartment ofAgriculture took water samples 8 hours after the application and found neither chemical (LOD= 1.4 ppb for cyfluthrinand LODS.1.48 ppb for profenofos). Bayer Cropscience, the registrant, said the incidentmay be due to low dissolved oxygen levels. This incident is listed as "possible" for a registered use of cyfluthrin.

TerrestrialPlantIncidents Involving CyJluthrinIncident # I0 16940-010 -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 ofthe crop were sampled for residues, and the two chemicalswere 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 119.2ppm 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 ofthe 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 organismstypically provide information only on mortality events and plant damage incidents. Except for phytotoxic effects in terrestrialplants, sublethal effects for organisms such as reduced growth or impaired reproduction are rarely reported. EPA's changes in the registrantreporting requirements for incidents in 1998 may account for a reduced number of reported incidents. Registrants are now only required to submit detailed informationon '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 ofresources. In the risk assessment, these incidentswill be further evaluated to determine if they represent current patterns of use for cyfluthrin and1or beta-cyfluthrin. Examples of additional considerationsare 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, cyfluthrinis among the constituentsmonitored 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 agriculturalwater and sediments (refer to Section 3.4).
4.3. Ecosystems Potentially at Risk Cyfluthrinand beta-cyfluthrinmay be applied on a variety of food crops, including (but not limited to) alfalfa, tree nuts, pome fruits, brassica (head and stem) vegetables, fi-uitingvegetables, leafy vegetables, legume vegetables and root and tuber vegetables. In addition, they may be used in numerous non-food sites (e.g. ornamentaland/ or shade trees and ornamental lawns). Thus, the ecosystems at risk may be extensivein scope, and as a result it may not be possible to identify specific ecosystemsduring 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 includesmarine 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 involvestwo steps: 

### 1) identifying the valued attributes ofthe 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 assessmentendpoints is based on valued entities (i.e., ecological receptors), the ecosystemspotentially at risk, the migratidn pathways ofpesticides, and the routes by which ecologicalreceptors are exposedto 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 cyfluthrinand beta-cyfluthrin.
To estimate exposure concentrations, the ecologicalrisk assessment considers applications at the maximum applicationrate 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 determinewhether further testing is required, and to determine the need for precautionary label statements to minimize the potential adverse effectsto 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 exposurepathway is the means by which a pesticide moves in the environmentfrom 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 feasibleroute of exposure. A conceptual model provides a written description and visual representation of the predicted relationshipsbetween 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 stressoris the release of cyfluthrin and beta-cyfluthrin into the environment. The followingrisk hypotheses are presumed for this screening-level assessment: Cyfluthrin andbeta-cyfluthrin, when used in accordance with registered labels, will likely lead to off-site movement of the compoundvia run08 spray drift, and eroded soil leading to exposure of nontargetplants andanimals. 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 thepotential to cause reduced survival, growth, and reproduction to non-target terrestrial and/or aquatic animals andplants. Cyfluthrin andbeta-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 andtreatmentplants, leading to exposure of nontarget aquatic animals andplants. Thispotential exposurepathway 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 includesthe potential pesticide or stressor (cyfluthrin, beta-cyfluthrinand possible metabolites), the source of the pesticide and/or transportpathways, exposure media, exposure point, biological receptor types, and attribute changes.
6.2. ConceptualDiagram The conceptual site model is a generic graphic depiction ofthe 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 animalsprovided that environmental concentrations are sufficientlyelevated as a result ofproposed label uses. Based on an examinationof the physicochemical properties of cyfluthrinand beta-cyfluthrin, the fate and disposition in the environment, and mode of application,a conceptual model was developed that represents the possible relationshipsbetween the stressors, ecologicalreceptors, and the assessment endpoints. Through a preliminary iterativeprocess of examining available data, the conceptual model (i.e., the representation ofthe risk hypothesis) may be refined to reflect the likely exposurepathways 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 (cyfluthrinand/ or beta-cyfluthrin, but the presence of toxicologically important metabolites cannotbe ruled out), the sources and/ or transport pathways, exposuremedia and exposure points, biological receptor types and attribute changes.
In order for a chemical to pose an ecologicalrisk, it must reach ecologicalreceptqrs in biologically significant concentrations.An exposurepathway is the means by which a pesticidemoves in the environment fi-oma source to an ecological receptor. For 

### w ecological exposurepathway to be complete, it must have a source, a release mecpanism, an environmental transport medium, a point of exposurefor 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, especiallyif fbr the chemical, its metabolites1transformationproducts are of greater toxicological coricern than the parent compound. The assessment of ecological exposure pathways, thetefore, includes an examinationofthe source and potential migration pathways for constituents, and the determination of potential exposureroutes. Under the possible uses of cyfluthrinand 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 certainnbnagricultural 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 contaminatedadjacent areas, including bodies of water. ~otice that leaching to groundwater is not considered an important source because cyfluthrinand beta-cyfluthrin are relatively immobile. Due to cyfluthrinand beta-cyfluthrin's dotential for volatilization, atmospheric transport cannot be ruled out. Despite the fact thatcyfluthrin 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-cyfluthrinis relatively low and that this source ofthe chemical is of low importance, compared to spray drift, runoff and/ or direct contact after application.
For aquaticreceptors, the major point of exposure is through direct contact with the water column, sediment, and pore water (gill1integument)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 betacyfluthrinhave 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 contaminatedwith 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 terrestrialplants. The attribute changes used to assessrisk to terrestrial receptors depend on the type of test (e.g.,reduced survival, growth, or reproduction for animals and seedling emergence and vegetativevigor for plants). It should be noted, that these species do not cover all the possible speciesin the animal and plant kingdoms; certain taxa are considered as surrogatesfor other taxa. For example, fish are considered surrogatesfor 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 aboutbiomagnification for a chemical (see piscivorousbirds and mammals in Fig. 6.la). Cyfluthrin and beta-cyfluthrinhave a very high Kow and according to its physicochemical and fate properties, there would be a potential for bioaccumulation/bioconcentrationin aquatic organisms;however, the potential for biomagnification in terrestrial organisms, though at the screen level appears low, is uncertain and has not been quantified. Cyfluthrinand 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 organicmatter, suspendedin the water bodies. Cyfluthrin and beta-cyfluthrin are likely to concentrateand 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 potentiallybe 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 Leachingto 

### : 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 6.1b Aquatic animals Invertebrates Vertebrates **Piscivorous mammals

and birds 

# + v v Habitat integrity Reduction in algae and Reduction in primary productivity Reduced cover Modificationof PCEs Community changei Modificationof PC& relatedto

habitat **Route of exposure includes only ingestion of fish and aquatic inverts.

## 4 I Source Direct 

# 5 1 application



## .................... Irrigation Leaching to Exposure Media water +---...+Groundwaterh-: 

# ................... : 

## . & Receptors ermal uptakellngestion
Terrestrial plants Terrestrial grasses/ forbs, fruit, seeds 

## ............................~etldry deposition4.i invertebrates

# , (trees, shrubs) 

# II -Ingestion

v Terrestrial Ingestion vertebrates

vertebrates 7 Habitat integrity Reduction in primary productivity Reduced cover y and food Community change ~odification of PCEs 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 contributingto ecological risk. PCE=prirnary constituent element Cyfluthrinor beta-cyfluthrinapplied 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 effectsto 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 transportpathway 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). ISourcel 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 Wastewater flow 

# G

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 concentrationto effects concentration) approach. Although risk is often defined as the likelihoodbd magnitude of adverse ecological effects, the risk quotient-based approach does ndt provide a quantitative estimate of likelihood andor magnitude of an adverse effe~ct. However, as outlined in the OverviewDocument 

### (USEPA 2004), the likelihood qf effects to individual organisms from particularuses 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 inthe open literature and the information submittedby 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) ofpotential 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 ecologicalrisk assessment. Cyfluthrinand beta-cyfluthrinmay 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 combinationwith other pesticidesused 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. organicmatter present in sediment and suspended water). Quantitatively predicting the combined effects of all these variables on mixture toxicity to any given taxa with confidenceis beyond the capabilities ofthe available data and methodologies. However, a qualitative discussion of implicationsof the available pesticide mixture effects data on the confidenceofrisk 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 exposuremodeling and resulting risk conclusions will be made based on maximum application rates for the currentuse patterns. Measures of exposure are based on aquatic and terrestrial models that predict estimated environmental concentrationsof cyfluthrin and beta-cyfluthrin using maximum labeled applicationrates and methods, as well as any mitigation measures specificallyindicated 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-cyfluthrinfrom domestic wastewater treatmentplants, the Exposure and Fate Assessment Screening Tool's (EFAST2) down-the-drain module will be used. The model used to predict terrestrial exposureto 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-ombioconcentration in fish studies (e.g.the bioconcentration factors). KABAM is used to estimatepotential bioaccumulation of hydrophobic organic pesticides in freshwater aquatic ecosystemsand risks to mammals and birds consuming aquatic organisms which have bioaccumulated these pesticides.All of these models are parameterizedusing relevantreviewed registrant-submittedenvironmental 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 surfacewater bodies adjacent to application sites. PRZM simulates pesticide application,movement and transformation on an agriculturalfield and the resultant pesticide loadings to a receivingwater 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 ecologicalpesticide assessments assumes application to a 10-hectare agriculturalfield 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 transformationproducts, should they be of concern. The measure of exposure for aquatic species is the 1 -in-10 year return peak or rolling mean concentration. The 1 -in-10year 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 cyfluthrinand beta-cyfluthrinand their likelihood to occur in sediment, the Agency will also consider the potential exposuresresulting 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-yearpeak and 21-day mean EECs for pore water.
To estimate exposurerelated to releases of cyfluthrin and beta-cyfluthrinfrom 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 domesticwastewater treatment. It is suitable for all the sources of cyfluthrinand beta-cyfluthrin that could potentiallybe exposed through a "down-the-drain" scenario. The model provides screening level estimate concentrations of chemicalsin surfacewater that may result fiom household uses and the disposal of consumer products into wastewater using a few simple input parameters (production volume and fiaction ofthe chemical removed during wastewater treatment) (please, refer to Section 7.9.1 for data being required for this analysis; a POTW treatability study isbeing 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 LDsaper 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 calculateEECs. EECs are based upon solubility, application rate and minimum incorporation depth.
As indicated in Table 

### 3.1 and its associated text in Section 

### 3, cyfluthrinand 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-cyfluthrinin 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 ofhydrophobic organic pesticides in freshwater aquatic ecosystems and risks to mammals and birds consuming aquatic organismswhich have bioaccumulated these pesticides. Currently,EFED does not have the modeling capabilities to quantitatively evaluate bioaccumulationand biomagnification in terrestrial food webs5. Therefore,EFED will address these exposureroutes 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-ContinentEcology Division.
The acute measures of effect used for animals in this assessment are the LDsO, LCs0and 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 LCsois the concentration of a chemical that is estimated to kill 50% of the test organisms. EC stands for "Effective Concentration" and the ECsois

5 USEPA. 2009a. SAP Minutes No. 2009-01. A Set of Scientific Issues Being Consideredby 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 concentrationof 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. TheNOAEC (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 ECsofor aquatic plants); for listed plants either the NOAEC or ECo5 is used.
Informationon 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 ofpesticides. 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 effectsmay includebehavioral 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 organismsmakes the assumption that the toxicity of cyfluthrin and beta-cyfluthrin to birds is similar to terrestrial-phase amphibians and reptiles. The same assumptionis 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 ecologicalrisk from the use ofpesticides 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 resultingRQs are then compar$d to the Agency's Levels of Concern (LOCs) (USEPA 2004). These criteriawill be used to indicatewhen 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 MethodsThe quantitative assessment of risk will primarily depend on the deterministicpointestimatebased approachdescribed in the risk assessment. An effort may also be made to further qualitatively describerisk using probabilistic tools that the Agency has developed. These tools have been reviewed by FIFRA ScientificAdvisory Panels (http:llwww.epa.govlscipolylsaplindex.htm) and have been deemed as appropriatemeans of refining assessmentswhere deterministic approaches have identified risks. 7.6. Endangered Species Assessments Consistent with the Agency's responsibilityunder the Endangered Species Act (ESA), the Agency will evaluate risks to Federally-listed threatened andlor endangered (listed) species from registered uses of cyfluthrinand beta-cyfluthrin. This assessment will be conducted in accordance with the OverviewDocument (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 cyfluthrinand betacyfluthrinis 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 ofAgency 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 OverviewDocument (USEPA 2004) considers the results ofthe 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 ofthe 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. Specificmeasures of ecological effect that define the action area for listed species include any direct and indirect effects and/ or potential modificationof 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 extendsto 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 situationswhere 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 appropriatelabel precautions. Based on the results of a single study in honey bees (LD50of 0.037 pg a.i./bee,MRID 00153638), cyfluthrin is classified as highly toxic on an acute contactbasis. This study suggests that the acute toxicity to non-targetbeneficial 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 exposureto terrestrial plants cannot be assessed. In the past, it hadbeen 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 assessmentwill be conducted to support futurehuman health risk assessments of cyfluthrin and beta-cyfluthrin should it be required and based on the newly submitted environmentalfate results. The drinking water assessment will incorporatemodel estimates of cyfluthrinand/ or beta-cyfluthrin in surface and ground waters. Concentrationsin surface waters will be estimated using FQPA Index Reservoir Screening Tool (FIRST, 

### v. 1.1.1, 12118/07) (or subsequently using PRZMI EXAMS, with the Index Reservoir -for description see above -if refinements are required). Ground water estimates of concentrationswill 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 section408(p), EPA has developed the Endocrine Disruptor Screening Program (EDSP) to determine whether certain substances (includingpesticide active and other ingredients)may have an effectin 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 interactwith 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 interactwith E, A, or T hormonal systemswill proceed to the next stage of the EDSP where EPA will determine which, if any, ofthe 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 relationshipbetween the dose and the 

### E, A, or T effect. Between October 2009 and February 2010, 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 chemicalswas selectedbased on the potential for human exposure through pathways such as food and water, residential activity, and certainpostapplication 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 screenedunder 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 ofthe EDSP, the policies and procedures, the list of 67 chemicals, the testguidelines and the Tier 1 screening battery, please refer to the followingwebsite: http://www.epa.aov/endo/

. 7.9. Preliminary Identificationof 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.
835.4100Aerobic Soil Metabolism -The Agency has aerobic soil metabolism studies performed in two soils for fluorophenyl-labeled cyfluthrin;no data are availablewith cyclopropyl-labeled cyfluthrin. A study performed in two soils should be submitted for cyfluthrin (at least, one of which should be conductedwith 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 (10/26/00),~ 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 enrichedmixtures." (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-cyfluthrinmay be enantioselective (Qin et al. 2006, Li et al. 2008). Aerobic soil metabolism studies with one soil type are generally sufficientfor the evaluation of transformationpathways. 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.
835.4200 Anaerobic Soil Metabolism -The available supplemental anaerobic soil metabolism study, conducted on cyfluthrin, was performed with only one soil and for a period ofroughly one month of anaerobic incubation. A new study is required. Anaerobic studies with one soil type are generally sufficient for the evaluation of transformationpathways. 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.
835.4300Aerobic Aquatic Metabolism -Two soil/ sediment systems are available that were conducted with cyclopropyl-labeled cyfluthrin. The studies availablethat 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, studieswere conducted at above the solubilitylimit, 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 TransformationTest 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 estuarinelmarine 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 shouldbe ofmarine 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 concentrationand no Freundlich correlationsor isotherms are available. A new study is required. According to OCSPP (formerly OPPTS) Fate, Transport and Transformation Test Guideline (835.1230), 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 adsorptionon soils." The available study indicated that cyfluthrinis relatively immobile in the various soilstested 

### (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 giventaxon, 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. Previousreviews on cyfluthrin and beta-cyfluthrinindicate that there is high condern for acute and chronic toxicity to aquatic animals. Certain scenariosmay have triggered acute and chronic levels of concern for freshwater and1or estuarinelmarine aquatic invertebratesand1or for fish and/ or organisms living in the benthos. Therefore,ECMs for water and sediment are required in additionto 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 chemistryrttethods; further,multi-residue methods (MRMs) for soil, water and sediment are preferred, if applicable. The registrant submitted one method (MRID 4 151 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.htmaddition, 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 validationprocedures performed by an independent laboratory should also be submitted. It should include the following information (Corbin et al. 2006): (a) Recovery level(s) ofthe test compound(s) fi-omthe soil, water and sediment (substrates)at various relevant fortificationlevel(s) using the residue analyticalmethodology; (b) a validated method sensitivity level; (c) results of the study and statistical test applied, including a stepwisepresentation ofthe procedure for calculatingpercent recovery from the raw data; (d) all the data/informationnecessary 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 Determiningthe 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 EffluentMonitoring -Request any existing or ongoing POTW effluent monitoring data for the pyrethroidsbe submitted to the Agency. POTW Treatability Study -The Agency is anticipatingrequiring a bench scale study of waste water treatment,to assess the percentageremoved in the biosolidsby 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 percentagesby 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 Programswill continue to confer with the Office of Water with the goal of refining our down-the-drainassessment for registrationreview.
Table 7.1 lists the status of the environmental fate data requirements for cyfluthrin and beta-cyfluthrin.

Table 7.1. Summary ofEnvironmental Fate Data Requirements for Cyfluthrinand 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 Photodegradationin Water Table 7.1. Summary ofEnvironmental Fate Data Requirements for Cyfluthrin and Beta-cyfluthrin

Yes
835.24 10 Photodegradationon Soil Must Additional Data Be Submitted Under FIFRA

3(~)(2)(B)?

Yes Bibliographic Citation

835.2370 Photodegradationin Air Does EPA Have Data To Satisfy This Requirement? Study Identification

Not Available Use Pattern1

Metabolism Studies-Lab: 835.4100 Aerobic Soil Yes
Yes
No No 835.4200 Anaerobic Soil 835.4300 Aerobic Aquatic Not Available 835.4400 Anaerobic Aquatic Mobility Studies: 835.1230 Leaching - Adsorption1Desorption Yes
835.1410 Volatility (Lab) Not Available 835.8100 Volatility (Field) Not Available Dissi~ation Studies-Field: 835.6 100 Terrestrial Field Dissipation Yes

835.6200 Aquatic Field Dissipation Not Applicable
835.6300 Forestry Dissipation Not Applicable Ground Water MonitoringStudies: 835.7100 Ground Water Monitoring Reserved

5158.1100 SPRAY DRIFT 201-1 Droplet Size Spectrum Yes Yes 202-1 Drift Field Evaluation Other Studies:Environmental Chemistry 12 Yes 41511301,47053001, yesg Methods (ECMs) and 47053002 Independent Laboratory Validations(ILVs) Table 7.1. Summary ofEnvironmental Fate Data Requirements for Cyfluthrinand 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 submissionof the SprayDrift 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 EndocrineDisruptor ScreeningProgram; certain data has been required for the chemical under the program (DCI issued on 11/19/09;90-day response by 02127110; order due date 1111911 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 EndocrineDisruptor ScreeningProgram (EDSP) to determine whether certain substances (includingpesticide active and other ingredients)may have an effect inhumans or wildlife similarto 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 statutorilyrequired determinations.Tier 1 consists of a battery of 11 screening assays toidentify 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 systemswill 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 endocrinerelated effects caused by the substance, and establisha dose-response relationshipbetween the dose and the E, A, or T effect. Between October 2009 and February 2010, 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 chemicalswas selectedbased on the potential for human exposure through pathways such as food and water, residential activity, and certainpostapplication agricultural scenarios. This list should not be construed as a list ofknown 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 followingwebsite: 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 pesticideuse 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 traditionallyused 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 sensitivebird species has been submitted (mallard duck). The most sensitive study resulted in a nondefinitiveNOAEC (<250 ppm) and both submitted studieshad issues with controlperformance. A chronic risk assessment for birds is needed based on cyfluthrin's use patterns and potential impact on birds. The avian reproduction toxicity study isjustified for cyfluthrinbecause 1)the avian reproduction studies for both waterfowl and upland game bird species are standard data requirementsfor all outdoor terrestrialuse patterns, 2) evidence of chronic toxicityto mammals indicates possible chronic toxicity in birds, and 3) cyfluthrinuse 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) Cyfluthrinand beta-cyfluthrin have the potential to enter estuarinelmarinewater 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 cyfluthrinTEP effects on estuarinelrnarine species. Testingon Typical end-useproducts 

### (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 concentrationor estimated environmental concentration in the aquatic environmentis greater than or equal to one-halfthe LCj0or ECjoof the TGAI. 3. An ingredient in the end-use formulationother 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 concentrationsin 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 1.62pg 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 SubdivisionJHazardEvaluation: Nontargetplants on Part 120-2(1) on Page 18 as "a pesticideproduct that is representative of a major formulationcategory (e.g., emulsifiable concentrate,granular product, wettablepowder) and pesticide group (e.g., herbicide, fungicide, insecticide etc.) and contains the active ingredient ofthe applicant's product." (Holst and Ellwanger, 1982) Page 5 ofthe Pesticide Assessment GuidelinesSubdivisionJHazardEvaluation: Nontargetplants, provides additional informationon what TEP data should be tested for toxicity testing in the following excerpt. "The Agency seeks to avoid imposing a burden of duplicative testing onapplicants for registration. Therefore, where 40 CFR Part 158 specifies that the test substance should be a representativeend-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 similarproducts." (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-useproducts. 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, appropriateTEPs should be selected from formulations that are registered for agricultural uses, not residential. Guideline Numbers: Non-guideline Study Title: Aquatic Invertebrate Acute Toxicity 

### (Hyalellaazteca) 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 ofHyalella 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 satisfythe Agency's updated data requirements for outdoor uses in 40 CFR Part 158 (October 26,2007). For cyfluthrin, available information indicates that benthic organismsmay be exposed via run-off or spray drift applicationsused 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 chronicwhole sediment toxicity testing under 40 CFR Part 158. Further, the expected half-life of cyfluthrinin sediment (73.5-94.8 for aerobic soil metabolism and 32.9-42 days for aerobic aquaticmetabolism) 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 aquatictaxa tested at levels ranging from 0.00040 - 0.63 yg a.i./L. Finally,the potential for persistent exposurefrom cyfluthrin in sediment is also indicated by open literature studies on pyrethroids (Westonet al. 2005, Mweget al. 2006 and Ding et al. 2009).
For sediment studies involvingpyrethroids, chronic whole sediment tests on Hyalella azteca, Chironomus tentans, and Leptocheirus plumulosus are requested.Although both are freshwater species, Hyalella and Chironomus differ substantiallyin their ecologicalniche (i. e., epibenthic v. infaunal species),physiology, and there is some evidence suggestingHyalella is among the more sensitive invertebrates to some pyrethroidsbased on water column tests (Andersonel al. 2006, Maund et al. 2002). Cyfluthrinhas the potential to enter estuarinelmarinewater bodies based on currentusuage 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 estuarinelmarinebenthic 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 cyfluthrinto nontarget terrestrial plants. Since cyfluthrin has residential outdooruses, vegetativevigor 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-Lemnaspp. Tiers 1/11 No studies for cyfluthrin have been submitted for vascular aquaticplants. 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 requirementsfor cyfluthrin, the following; are required for beta-cvfluthrin as per the 

### EFED Interim Policv for Stereoisomeric ~esticides,~ which savs the following:
"OPPrequires the following minimal data set using species and conditions (including testing laboratories) that are identical to those for the data submitted for theprevious racemic mixture. 

## Ifthe toxicity values are substantially similar for the racemic and enantiomeric enriched mixture and do not result in signlJicantly greaterpotential risk, then no additional ecotoxicity data are needed. 

# a however, the toxicitydata for the racemic and enantiomeric enriched mixture differ significantly and suggests that the enriched mixture poses a signzj?cantlygreater risk, then additional ecotoxicity data may be required on a case-by-case basis. " The data required in the interimpolicy is as follows: Avian

Available at http://~ww.epa.gov/o~pefedI/ecorisk~ders/stereoisomer~lic~.htm

.
70Guideline 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-cyfluthrinreproductive 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-cyfluthrintedhnical were submittedfor freshwater fish, freshwater invertebrates and estuarinefmarine invertebrates.Two studies with mysids were determined to be acceptable. All other aquatic studies with beta-cyfluthrinwere deemed supplemental. o The most sensitive species based on registrant-submitted data is Mysidopsisbahia. At this time, no additional data are required for betacyfluthrin effects on mysids. Guideline 850.1400 or 850.13001850.1350 

## - Fish Early Life Stage or Invertebrate Life Cycle 

### - test most sensitive speciesfrom previous studies with cyfluthrin. o Required for beta-cyfluthrin.Preliminary inspectionofthe results 

### ' indicates that the most sensitive species isMysidopsisbahia. Nontarget Plant Guideline 850.4100 or 850.4150 

## - Seedling Emergence or Vegetative Vigor Test most sensitivemonocotyledon and dicotyledonbased on results of c$fluthrin terrestrialplant 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 additionalnonvascular aquaticplant data are required at this time for beta-cyfluthrin.

### Table 7.2 lists the status of the ecological effects data requirementsfor cyfluthrin and beta-cyfluthrin.All additional data requests are for cyfluthrin only, with the exceptionof invertebrate life cycle, seedling emergence, vegetativevigor and vascular aquaticplant growth studiesrequired 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 Yes 7 1 -2(b) Acute Avian Diet, Duck 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 Yes 72-l(b) Acute Fish Toxicity Bluegill (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 Yes Whole sediment: acute freshwater invertebrates Whole sediment: acute marine invertebrates 1,2 Yes No Whole sediment: chronic invertebrates 1,2 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) VegetativeVigor 122-2 Aquatic Plant Growth 124-1 Terrestrial Field Study 124-2 Aquatic Field Study 9158.490 NONTARGET INSECT TESTING 141-1 Honey Bee Acute Contact 1,2 141-2 Honey Bee Residue on Foliage 1,2 141-5 Field Test for Pollinators 1,2 $158.630 AQUATIC ORGANISMS TESTING 850.1730 Bioaccumulationin Fish 1,2 Yes No No

Yes

### Table 7.2. 

### Ecological Effects nata Requirements for Cyfluthrinand 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 ofthe 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 sheepsheadminnow, 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 (Accordingto Part 158,for TEP data requests, the maximum expected environmental concentration or estimated environmental concentration in the aquatic environmentis greater than or equalto 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 andLeptocheivusplurnulosus.

Studies are required for cyfluthrin and beta-cyfluthrin. For beta-cyfluthrin, the most sensitive monocotyledonand 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 EC50was non-definitive (>I81yg 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).8. References Amweg, E.L., D.P.Weston, and N.M. Ureda. 2005. Use and Toxicity of Pyrethroid Pesticides in the Central Valley, California, USA. Environmental Toxicology and Chemistry, Vol. 24, No. 4, pp. 966-972 Amweg, E.L., D.P. Weston, C.S. Johnson, J. You and M.J. Lydy. 2006a. Effect of PiperonylButoxide on Permethrin Toxicity in the Amphipod Hyalella azteca. Environ. Tox. & Chem. 25(7), pp. 1817-1825. Amweg, E.L. D.P. Weston, J. You and M.J. Lydy. 2006b. Pyrethroid Insecticides and Sediment Toxicityin Urban Creeks from Californiaand Tennessee. Environ. Sci. Technol.,2006,40 (9,pp 1700-1706. Amweg, E.L. and D.P. Weston. 2007. Whole-Sediment Toxicity Identification Evaluation Tools for Pyrethroid Insecticides: I. Piperonyl Butoxide Addition.Environ. Toxicol. & Chem., Vol. 26, No. 1 1,pp. 2389-2396,2007 Armitage, J.M., & Gobas, F.A.P.C. 2007. A terrestrial food-chain bioaccumulatioh model for POPS. Environmental Science and Technology, 41,4019-4025. Barile, F.A. 2004. Clinical Toxicology: Principles and Mechanisms. Boca Raton, FL: CRC Press. Brander, S.M., Werner, I., White, J.W. and L.A. Deanovic. 2009. Toxicity of a dissolved Pyrethroid Mixture to Hyalella azteca at environmentally relevant concentrations. Environ. Tox. & Chem. 28 (7), 1493 - 1499. Brown, L.R. and I.L. Maher. 2000. Section 3 and IR-4 for the use of Cyfluthrin (Baythroid)on leafy vegetables-(lettuce,mustard greens, cauliflower, & broccoli), soybeans, corn (pop, field, and seed), dry peas, pigeon peas, chickpeas, and lentils. Memorandum to 

### A. Layne and T. Keigwin dated 09/07/00. DP Barcodes D256960, D263 166,D261263, D2623 12,D2623 14. Environmental Fate and Effects Divisibn, OPP, OPPTS, USEPA. Brown, L.R. 2001. IR-4 RegistrationRequest for Cyfluthrin use on SouthernPeas. Memorandumto S. Brothers and R. Forrest dated 02/27/01. DP Barcode D271494. Environmental Fate and Effects Division, OPP, OPPTS, USEPA. Budd, R, S. Bondarenko, D. Haver, J. Kabashima, and J. Gan. 2007. Occurrence and Bioavailability of Pyrethroids in a Mixed Land Use Watershed. J. Environ. Qual! 36: 1006-1012 (2007). Clark, J.M and F. Matsumura. 1987. The action oftwo classes of pyrethroids on the inhibition of brain Na-Ca and Ca 

## +Mg ATP hydrolyzing activities of the American cockroach, Comp. Biochem. Physiol. C. 86 (1987) (I),pp. 135-145.Corbin, M, W. Eckel, M. Ruhman, D. Spatz,N. Thurman, R. Gangaraju, T. Kuchnicki, R. Mathew, and I. Nicholson. 2006. NAFTA Guidance Document for Conducting TerrestrialField Dissipation Studies. Available at url: http://www.epa.gov/oppefedl/ecorisk derslterrestrial field dissipation.htm(accessed 05/04/10). Dai, D.L., Q. Wang, J. Sun,

### F. Liu, X. Wang, Y. Wu, and 

### T. Zhou. 2010. Effects of SublethalConcentrations of Bifenthrin and Deltamethrin on Fecundity, Growth, and Development of the HoneybeeApis mellifera ligustica. Environ. Toxicol. Chem. 29 (3), pp. 644-649.
Di Toro, D.M., C.S. Zarba, D.J. Hansen, W.J. Berry, R.C. Swartz, C.E. Cowan, S.P. Pavlou, H.E. Allen, N.A. Thomas and P.R. Paquin. 1991. Technical basis for establishing sediment quality criteria for nonionic organic chemicalsusing equilibrium partitioning. Environ. Toxicol. Chem. 10:1541 -1583. Ding, Y., A.D. Harwood, H.M. Foslund, and M.J. Lydy. 2010. Distribution and Toxicity of Sediment-Associated Pesticidesin Urban and Agricultural Waterways from Illinois, USA. Environmental Toxicology and Chemistry, Vol. 29, No. 1,pp. 149-1 57,2010. Federoff, N.E. and J.L. Melendez. 2004. Environmental Risk Assessment for the Registration of the New Uses of Cyfluthrinon Tree Nuts, Grapes and Peanuts, Wheat, Leafy Vegetables, Fruiting Vegetables, Cucurbits,Leafy Brassica, Pome Fruit, Stone Fruit; in Addition to IR-4 Tolerance Petition for the Use of Cyfluthrin on Tuberous and Corm Vegetables, Turnip Greens, Dried Shelled Peas and Beans (except soybeans),Grass Hay, and Grass Forage. Memorandum to G. LaRocca and S. Stanton dated 2/27/06. DP Barcode D2748 13,290926,290922,291313,291 923,294835 and 294488. Environmental Fate and Effects Division, OPP, OPPTS, USEPA. Federoff, N.E. and J.L. Melendez. 2006. Environmental Risk Assessment for the New Use Registrationof Cyfluthrin on Tobacco. Memorandum to G. LaRocca and 0.Odiott dated 2/27/06. DP Barcode D3 163 13. Environmental Fate and Effects Division, OPP, OPPTS, USEPA. Federoff, N.E. and J.L. Melendez. 2007. EFED Section 3 and IR-4 Registration for Cyfluthrin to be used on Grasses. Memorandum to D. Rosenblatt, S. Jackson and G. LaRocca dated 06/06/07. DP Barcodes D33 1952, D3323 12and D3323 13. Environmental Fate and Effects Division, OPP, OPPTS, USEPA. Federoff, N.E. and J.L. Melkndez. 2007. EFED Section 3 and IR-4 Registrationfor Beta-cyfluthrin to be used on Grasses and Crop Group #15 (cereal grains except rice) and #16 (forage, fodder and straw of cereal grains). Memorandum to 0.Odiott and G. LaRocca dated 06/12/07. DP Barcodes D332314 and D339098. Environmental Fate and Effects Division, OPP, OPPTS, USEPA.Federoff, N.E. and J.L. MelCndez. 2007. EFED Section 3 Registration for a Clothianidin and Beta-cyfluthrin CombinationProduct for Use on Sugar Beets as a Seed Treatment. Memorandum to K. Davis and V. Eagle dated 06/12/07. DP Barcode D335254. Environmental Fate and Effects Division, OPP, OPPTS, USEPA. Federoff, N.E. and J.L. MelCndez. 2007. EFED Section 3 Registration Petition for an Increase in Application Rates for Cyfluthrin for use on Alfalfa. Memorandum to 0. Odiott and G. LaRocca dated 713 1/07. DP Barcodes D340740 and D34074 1. Environmental Fate and Effects Division, OPP, OPPTS, USEPA. Ferniindez-Alvarez,M., L. Siinchez-Prado,M. Lores, M. Llompart, C. Garcia-Jares, R. Cela. 2007. Alternative sample preparationmethod for photochemical studiesbased on solidphase microextraction: Syntheticpyrethroid photochemistry. J. of Chromatography A, 1152 (2007)pp. 156-1 67. Food and Agriculture Organizationofthe United Nations. FA0PESTICIDE DISPOSAL SERIES 8. Assessing Soil Contamination:A Reference Manual. Appendix 2. Parameters of pesticides that influence processes inthe soil. Editorial Group, FA0 Information Division: Rome, 2000. 

### http://~~~.fao.org/DOCREP/O03/X257OE/X2570E00.htm Gan, J., S.J. Lee, W.P. Liu, D.L. Haver, and J.N. Kabashima. 2005. Distribution and Persistence of Pyrethroids in Runoff Sediments. J. Environ. Qual. 34:836-841 (2005). Gobas, F.A.P.C., B.C. Kelly and J.A. hot. 2003. Quantitative structure activity relationships for predicting the bioaccumulation of POPSin terrestrial food webs. QSAR Comb. Sci. 22:329-336. Gupta, S. and V.T. Gajbhiye.2002. Persistence and leaching of/?-cyfluthrinin alluvial soil of India. Pest Manag Sci 58:1259-1265. Gupta, S. and V.T. Gajbhiye. 2005. Dissipation ofp-Cyfluthrin in Water as Affeated by Sediment, pH, and Temperature. Bull. Environ. Contam. Toxicol. (2005) 74:40-47 Hintzen, E.P., M.J. Lydy, and J.B. Belden. 2009. Occurrence and potential toxicity of pyrethroids and other insecticides in bed sediments ofurban streamsin central Taxas. Environ Pollut 157:110-1 16. Hodgson, E., & Smart, R. C. (Eds.). 2001. Introduction to Biochemical Toxicolagy (Third ed.). New York: Wiley-Interscience. Holmes, R.W., B.S. Anderson, J.W. Hunt, D.B. Crane, A. Mekebri and V. Connar. 2008. "Statewide Investigation of the Role of Pyrethroid Pesticidesin Sediment Toxicity in California's Urban Waterways." Environ. Sci. Technol. 2008,42, 7003-7009. Laskowski, D.A., 2002. Physical and chemical properties ofpyrethroids. Rev. Environ.Contarn. Toxicol. 2002; 174:49-170. LeBlanc, L. & B. Perkins. 2009. Pyrethroid Analysis for Maine Board of Pesticide Control. University of Maine Food and Chemical Safety Laboratory, Orono Maine. An e:mail communicationfkom G. Fish to R. Gebken, dated 11/02/09and forwarded to EFED on 11/19/09. Original communication from L. LeBlanc to G. Fish and H. Jennings, dated 05/25/09. Li, Z.Y., Z.C. Zhang, L. Zhang and L. Leng. 2008. Stereo and Enantioselective Degradationofp-Cypermethrin andP-Cyfluthrin in Soil. Bull Environ Contam Toxicol (2008) 80:335-339. Matsurnura, F. 1985. Toxicology of insects. 2nd ed. Plenum New York. Moore M.T., R.E. Lizotte Jr. and S. Smith Jr. 2007. Responses of Hyalella aztecato a Pyrethroid Mixture in a ConstructedWetland. Bull Environ Contam Toxicol (2007) 78:245-248. Moore, M.T., C.M. Cooper, S. Smith, Jr., R.F. Cullum, S.S. Knight, M.A. Locke and E.R. Bennett. 2009. Mitigation of two pyrethroid insecticides in a Mississippi Delta constructed wetland. Environmental Pollution 157 (2009) 250-256. Qin, S, R. Budd, S. Bondarenko, W. Liu and J. Gan. 2006. EnantioselectiveDegradation and Chiral Stability of Pyrethroids in Soil and Sediment. J. Agric. Food Chem. 2006, 54, 5040-5045. Rexrode, M. and J.L. Melendez. 2003. EFEDYs rationale for choosing Cyperrnethrin, Esfenvalerate, Bifenthrin, and Cyfluthrin for sediment testing as discussed with the Pyrethroid Working Group (PWG). Memorandum to M. Johnson & G. LaRocca dated 12/22/03. Environmental Fate and Effects Division, OPP, OPPTS, USEPA. Shehata, A., Abdell-All,A. Farag, M. Samaan and Y. Mohareb. 1987. Some factors influencing persistence,hydrolysis, downward movement and leachability of cyfluthrin in Egyptian soils. Annals Agricultural Science, 32(3): 1677-1687. Smith, S., G.H. Willis, and C.M. Cooper. 1995.Cyfluthrin Persistencein Soil as Affected by Moisture, Organic Matter, and Redox Potential. Bull. Environ. Contam. Toxicol. (1995) 55:142-148.
Stout 11, D.M., K Bradham, P.P. Egeghy, P. Jones, C.W. Croghan, P.A. Ashley, E. Pinzer, W. Friedman, M.C. Brinkman, M.G. Nishioka and D.C. Cox. 2009. American Healthy Homes Survey:A National Study of Residential PesticidesMeasured from Floor Wipes. Environ. Sci. Technol., 2009,43, 4294-4300.Trimble,A.J, D.P. Weston, J.B. Belden, and M.J. Lydy. 2009. Identificationand Evaluation of Pyrethroid Insecticide Mixtures in Urban Sediments. Environ Toxic01 & Chem 26 (8) pp. 1687-1 695. Ureda, N. 2004. SedimentLCsoAnalyses of the Pyrethroid Pesticides Cyfluthrin, Deltamethrin, and Lambda-Cyhalothrin. [Available at url: http://nature.berkeley.edu/classes/es

### 196/proiects/2004final/Ureda.pdfaccessed 04/16/10].
U.S. Environmental ProtectionAgency. 1998. Guidelines for Ecological Risk Assessment. Risk Assessment Forum, Office of Research and Development, Washington, D.C. EPAl6301R-951002F. April 1998.
U.S. Environmental ProtectionAgency. 1999. FIFRA ScientificAdvisory Panel Meeting, February 23, 1999held at the Holiday Inn Hotel, Arlington, VA. SAP ReportNo. 99- 03A. March 25, 1999. Office of Pesticide Programs. Available at url: http://www.epa.gov/scipoly/sap/meetinp;s/1999/022399mtg.htm#materials (Accessed December 15,2009) U.S. Environmental ProtectionAgency. 2000. Risk Characterization Handbook. Science Policy Council, U.S. Environmental ProtectionAgency, Washington, D.C. 20460. EPA 100-B-00-002. December 2000.
U.S. Environmental ProtectionAgency. 2002. Technical Basis for the derivation

### of Equilibrium Partitioning Sediment Guidelines (ESGs) for the Protection of Benthic Organisms: Nonionic Organics [Draft]. EPA Document No. 822R02041. October 2002. U.S. Environmental ProtectionAgency. 2004. Overview of the Ecological Risk Assessment Process in the Office of Pesticide Programs, U.S. Environmental Protection Agency. Endangered and Threatened Species Effects Determinations. Office of Prevention, Pesticides and Toxic Substances, Office of Pesticide Programs, Washington, D.C. January 23,2004.


### U.S. Environmental ProtectionAgency. 2005. Generic Format and Guidance for the Level I ScreeningEcological Risk Assessments Conducted in the Environmental Fate and Effects Division. Office of Pesticide Programs, Washington, D.C. January 24,2005. U.S. Environmental ProtectionAgency. 2008. OPPTS835.6100 TerrestrialField Dissipation. EPA 712-C-08-020. October 2008. Office of Prevention, Pesticides, and Toxic Substances. United StatesEnvironmental ProtectionAgency. Available at http://www.epa.gov/opptsfrs/publications/835 6 100.pdf(Accessed March 31,201 0). U.S. Environmental ProtectionAgency. 2009. A Set of ScientificIssues Being Considered by the EPA Regarding: Evaluation of the Common Mechanism of Action of Pyrethroid Pesticides. SAP Minutes No. 2009-07. FIFRA SAP Meeting held 6/16/09 in Arlington, VA. Meeting Minutes dated 9/9/09.U.S. Fish and Wildlife Service (USFWS) and National Marine Fisheries Service (NMFS). 1998.Endangered Species ConsultationHandbook: Procedures for Conducting Consultationand Conference ActivitiesUnder Section 7 of the Endangered Species Act. Final Draft. March 1998. Weston, D.P., J. You and M.J. Lydy. 2004. Distribution and Toxicity of SedimentAssociated Pesticides in Agriculture-Dominated Water Bodies of California's Central Valley. Environ. Sci. Technol. 2004, 38,2752-2759. Weston, D.P., R.W. Holmes, J. You and M.J. Lydy. 2005. Aquatic Toxicity Due to Residential Use of Pyrethroid Insecticides. Environ. Sci. Technol., 2005, 

### 39 (24),pp 9778-9784. Weston, D. 2007. Impacts of Pyrethroid Pesticides on Water Quality from Urban and Agricultural Sectors. Conference Proceedings; California Plant and Soil Conference: Opportunities for CaliforniaAgriculture. California Chapter of the American Society of Agronomy, pp. 35-37. Weston, D.P., J. You, A.D. Harwood and M.J. Lydy. 2009a. Whole SedimentToxicity Identification Evaluation Tools for Pyrethroid Insecticides: 111. Temperature Manipulation. Environ. Tox. & Chem., Vol. 28, No. 1, pp. 173-180,2009 Weston, D.P., R.W. Holmes, and M.J. Lydy. 2009b. Residential runoff as a source of pyrethroid pesticides to urban creeks. Environmental Pollution 157 (2009) 287-294 Weston,D.P. and M.J. Lydy. 2010. Urban and Agricultural Sourcesof Pyrethroid Insecticides to the Sacramento-San Joaquin Delta of California. Environ. Sci. Technol. 2010,44, 1833-1 840. Woudneh, M.B and D.R. Oros. 2006. Pyrethroids, pyrethrins, and piperonyl butoxide in sediments by high-resolutiongas chromatographylhigh-resolution mass spectrometry. J. of Chromatography A 1 135 (2006) 71-77. Yang, W.C., W. Hunter, 

### F. Spurlock and J. Gan. 2007. Bioavailabilityof Permethrin and Cyfluthrin in SurfaceWaters with Low Levels of Dissolved Organic Matter. J. Environ. Qual. 36:1678-1 685 (2007).

### 9. Fate and Eco-Toxicity Bibliography 

### Environmental Fate Cyfluthrin
161 -1 Hydrolysis MRlD Citation Reference

131 492 Mobay Chemical Corp. (1983) Synopsis of Baythroid: The Effects on thle Environment--Environmental Chemistry: ?Summaryl. (Unpub- lished study received Oct 12, 1983 under 31 25-EX-I88; CDL: 072003-A) 131493 Sandie, F.; Thornton, J. (1983) Hydrolysis of Baythroid in Sterile, Aqueous Buffered Solutions: 86051. (Unpublished study received Oct 12, 1983 dnder 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 Buffered Solutions: 86051. (Unpublished study received Feb 13, 1984 under 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 Aqueous Solution and on Soil: 861 82. (Unpublished study received Fe 13, 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, Brochure No. 1239to 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. 45022101 Anderson, C. (1986) Degradation Behavior of (carbon-14)-Cyfluthrin inNatural Water: Lab Project Number: M 113 045-7: 93044. Unpublished study p~repared by Bayer AG. 31 p. 450221 02 Gronberg, R. (1984) Photodecomposition of (~hen~l-UL-(carbon-14))-$aythroid in Aqueous Solution by Sunlight: Lab Project Number: 83R-195: 88598. Unpublished study prepared by Bayer Corporation. 19 p.

MRlD Citation Reference

137543 Puhl, R.; Hurley, J.; Dime, R. (1983) Photodecomposition of Baythroid-14C in Aqueous Solution and on Soil: 86182. (Unpublished study received Feb 13,1984 under 3125-351; submitted by Mobay Chemical Corp., Kansas City, MO; CDL:072362-B) 157043 Chopade, H. (1986) Photodecompositionof [Carbon 141 Baythroid on Soil: 88981. Unpublishedstudy prepared by Mobay Chemical Corp. 25 p. 

### 162-1 Aerobic soil metabolism
MRlD Citation Reference

131492 Mobay Chemical Corp. (1 983) Synopsis of Baythroid: The Effects on the Environment--EnvironmentalChemistry: ?Summaryl. (Unpub- lished study received Oct 12, 1983 under 31 25-EX-188; CDL: 072003-A) 131494 Wagner, K.; Neitzel, H.; Oehlmann, L. (1983) Decompositionof Baythroid in Soil under Aerobic and Anaerobic Conditions: ?Sub- mitterl 86052. (Unpublished study received Oct 12, 1983 under 3125-EX-1 88; prepared by BayerAG, W. Ger., submitted by Mobay Chemical Corp., Kansas City, MO; CDL:072003-C) 

### 162-4
MRlD



### 163-1
MRlD 

### Aerobic aquatic metab. Citation Reference
Dyer, D.; Sabbagh, G. (2006) Cyfluthrin -Aerobic Aquatic Metabolism Overview. Project Number: MEBDPOOI, M11511098519, SVJ1002. Unpublished study prepared by Bayer Corp. 143 p.

Citation Reference

Mobay Chemical Corp. (1983) Synopsis of Baythroid: The Effects on the Environment--Environmental Chemistry: ?Summary]. (Unpub- lished study received Oct 12, 1983 under 3125-EX-188; CDL: 072003-A) Obrist, J.; Thornton, J. (1982) Soil Thin-layer Mobility of Bay FCR 1272, Bay SIR 8514, and Bay SSH 0860: 82232. (Unpublishedstudy received Oct 12, 1983 under 3125-EX-188; submitted by Mobay Chemical Corp., Kansas City, MO; CDLr072003-D) Obrist, J.; Thorton, J. (1982) Soil Thin-layer Mobility of Bay FCR 1272, Bay Sir 8514, and Bay SSH 0860: 82232. (Unpublishedstudy received Feb 13, 1984 under 3125-351; submitted by Mobay Chemi- cal Corp., Kansas City, MO; CDL:072361 -D) Whitfield, S.; Obrist, J. (1983) Soil Thin-layer Mobility of Aged Extractsof Soil Treated with Amethydione, Baythroid, Alsystin, and BAY SLJ 0312: 86158. (Unpublished study received Feb 13, 1984 under 3125-351; submitted by Mobay Chemical Corp., Kansas City, MO; CDL:072362-C) Mobay Chemical Corp. (1 984) 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 onEnvironmental Fate in Soil; 2. Accumulation Study in Bluegill Sunfish]. Unpublished study. 171 p. 40223402 Gronberg, R. (1 987) Adsorption of Baythroid to Sandy Loam: Report No. 94541. Unpublished study prepared by Mobay Corp. 13 p. 45022103 Burhenne, J. (1996) Adsorption/Desorption of Cyfluthrin on Soils: Lab Project Number: 131 0003-8: 107397. Unpublished study prepared by Bayer Corporation. 34 p. 

### 163-3 Volatility 

# - field
MRlD Citation Reference

149596 Mobay Chemical Corp. (1984) Baythroid: Addition No. 1, January 6, 1984, Brochure No. 1239to Brochure Entitled: Baythroid: The Effects on the Environment (Dated September 16, 1983):[Attached: 1. Studies on Environmental Fate in Soil; 2. Accumulation Study in BluegillSunfish]. Unpublished study. 171 p. 

### 164-1 Terrestrial field dissipation
MRlD Citation Reference

42794801 Grace, T.; Cain, K. (1990) Dissipation of Cyfluthrin in California Soils: Lab Project Number: BD830089R01: 1001 52: ML022101. Unpublished study prepared by Siemer and Associates, Inc. and Net Atlantic, Inc. 389 p. 4482290 1 Lam, C.; Dehart, B.; Barney, W. (1995) Terrestrial Field Dissipation of Gyfluthrin on North Carolina Soil, 1992: Lab Project Number: 106949: BD022101 Unpublished study prepared by Bayer Corporation and ABC Laboratori~es, Inc. 247 p. 42752901 Lin, J. (1993) Field Measurement of Cyfluthrin Fate and Runofffrom a Cotton Field in Southern Georgia: Lab Project Number: 10391 9: BD882303. Unpublished study prepared by Miles Inc. 61 p. 42752902 Lin, J. (1992) Field Measurement of Cyfluthrin Fate and Runofffrom a Cotton Field in Benoit, Mississippi: Lab Project Number: 103918. Unpublishedstudy prepared by Miles Inc. 66 p. I ACC 25911 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 25911 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 prepared by Cambridge Analytical Assoc- iates, Inc. 136 p. 41 190202 Leslie, W. (1989) Baythroid--Residues in Field Rotational Cereal Crops-- Addendum No. 1: Mobay Project ID: Baythroid Objective No. 8500: Report No. 98429-1. Unpublished study prepared by Mobay Corp. 20 p. 

### 165-4 Bioaccumulation in fish
MRlD Citation Reference

143143 Carlisle, J.; Roney, D. (1984) Bioconcentration of Cyfluthrin (Baythroid) by Bluegill Sunfish: Study Number 83-766-01. Unpub- lished study prepared by Mobay Chemical Corp. 14 p. 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 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 FollowingAerial ULVApplications 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 Residues of Bifenthrin, Cypermethrin, Cyfluthrin, Deltamethrin, Esfenvalerate, Fenpropathrin, Lambda-cyhalothrin and Permethrin in Sediment. Unpublished 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, Fenpropathrin, Lambda-Cyhalothrin and Permethrin in Sediment: Final Report. Project Number: ML1/06/02, ML06/1286/PWG. Unpublished study prepared byMorse Laboratories Inc. 418 p.


### Environmental Fate Beta-Cyfluthrin


### 162-4 Aerobic aquatic metabolism
MRlD Citation Reference

46824101 Dyer, D.; Sabbagh, G. (2006) Cyfluthrin - Aerobic Aquatic Metabolism Overview. Project Number: MEBDPOOI, M/l51/0985/9, SVJl002. Unpu~blished study prepared by Bayer Corp. 143 p.



### Non Guideline Selections 47647801 Hanzas, J.; Stone, C.; Toth, B.; et al. (2008) Bifenthrin and Beta-Cyfluthrin: Quantification of Pyrethroid Runoff Losses from Treated Turfgrass Under OverIrrigationConditions and Simulated Rainfall: Final Report. Project Numbar: 082018, SE1001. Unpublished study prepared by Stone Environmental, Ijc., CRG Marine Laboratories, Inc. and Agvise Laboratories. 280 p.



### Ecological Effects Cyfluthrin


### I Avian Single Dose Oral Toxicity
MRlD Citation Reference

131498 Carlisle, J.; Carsel, M.; Lamb, D. (1983) Acute Oral LD50 of Tech- nical Cyfluthrin to BobwhiteQuail: Study No. 83-015-02; 85941. (Unpublished study 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 (Colinusvirginianus): 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 Sparrows (Passer domesticus): Lab Project Number: M4711401: 1003'46. Unpublished study prepared by Mobay Corp. 2 p. 

### 71 -2 

### Avian Dietary ToxicityMRlD Citation Reference

131497 Mobay Chemical Corp. (1983) Synopsis of Environmental Toxicology of FCR 1272 (Cyfluthrin): (Summary). (Unpublishedstudy re- ceived Oct 12, 1983 under 3125-EX-188; 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. 83-175-02; 85937. (Unpublishedstudy 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. (Unpublishedstudy 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 Reproduction:Study Number 83-675-08. Unpub- lished study prepared by Mobay Chemical Corp. 94 p. 145331 Carlisle, J. (1984) Effect of Cyfluthrin (Technical Baythroid) on Mallard Duck Reproduction:Study Number 83-675-06. Unpublishedstudy prepared by Mobay Chemical Corp. 85 p. 152829 Carlisle, J. (1985) Effects of Cyfluthrin (Baythroid Technical) on Bobwhite Quail Eggshells: Study No. 85-675-04: Mobay Report No. 90275. Unpublishedstudy prepared by Mobay Chemical Corp. 52 p. 158782 Beavers, J. (1986) Baythroid Technical: A One-generation Reproduc-tion Study with the Mallard (Anas platyrhynchos): Final Report: Project No.: 149-117. Unpublished Mobay Report No. 91888 pre- pared by Wildlife International Ltd. 118 p. 

### 71 -5 Simulated or Actual Field Testing
MRlD Citation Reference

42005415 Fischer, D. (1991) Simulated Field Study of Acute Hazard to House Sparrows and Juvenile Northern Bobwhite Posed by Applications of Aztec 2.1% Granular Insecticideto Cornfields: Lab Project Num- ber: M4752302: 101313. Unpublished study prepared by Mobay Corp. 78 p. 42752601 Idema, P.; Kolaszar, T.; Perritt, J.; et al. (1993) Aztec 2.1% Granular Insecticide:An Evaluationof its Effects Upon Avian Species in and around Corn Fields in Central Iowa: Lab Project Number: M4752303: 105013: 149-170. Unpublished study prepared by Wildlife International Ltd. 534 p. Mixture Phostebuprim/Cyfluthrin 

### 72-1 Acute Toxicity to Freshwater FishCitation 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-188; 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 3125-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. (1984) Acute Toxicity of Fluorphenoxybenzaldehydeto Rhinbow Trout: 86696: Study No. 84-066-07. Unpublished study prepared by Mobay Chemical Corp. I Ip. Carlisle, J. (1984) Acute Toxicity of Dichlorvinylcarboxylic Acid to Rainbow Trout: 87452: Study No. 84-066-08. Unpublished study prepared by Mobay Chemical Corp. I Ip. Bowman, J. (1989) Acute Flow-through Toxicity of Tempo 2 EC to Blue gill (Lepomis macrochirus): Lab Project Number: 38341: 99787. Un published study prepared by Analytical Bio-Chemistry Labora- tories, Inc. 30 p. Bowman, J.; Leak, T. (1991) Acute Flow-through Toxicity of (Carbon 14) Aztec to Bluegill (Lepomis macrochirus): Lab Project Num- ber: 38624: 101217. Unpublished study prepared by Analytical Bio-Chemistry Labs, Inc. 39 p. Bowers, L. (1994) Acute Toxicity of (carbon 14)-FCR4545 to the Rainbow Trout (Oncorhynchus mykiss) Under Flow-Through Conditions: Lab Project Number: F5812202: 106656. Unpublished study prepared by Miles lncl34 p Surprenant, D. (1991) Acute Toxicity of FCR 4545 Technical to Rainbdw Trout (Oncorhynchus mykiss) Under Flow-Through Conditions: Lab Project Number: 103231: 274.0387.6121.108: 89-6-2998. Unpublished study prepared by Springborn Labs., Inc. 58 p. 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 Project Number: E 2810061-8: 99197. Unpublished study prepared bylBayer AG. 19 p. Bowman, J. (1989) Acute Flow-through Toxicity of ?carbon 141-Tempo 2 EC To RainbowTrout (Oncorhynchus mykiss): Lab Project Number: 38342: 99843. Unpublished study prepared by Analytical Bio- Chemistry Laboratories.45426707 Gagliano, G. (1994) Acute Toxicity of (Carbon 14)-Cyfluthrin to the Bluegill Beta-Cyfluthrin (Lepomis macrochirus) Under Flow-Through Conditions: Lab Project Number: BD810301: 106774. Unpublished study prepared by Miles Incorporated.34 p. 45426706 Bowers, L. (1994) Acute Toxicity of (Carbon 14)-FCR 4545 to the Bluegill Beta-Cyfluthrin (Lepomis macrochirus) Under Flow-Through Conditions: Lab Project Number: F5810302: 106655. Unpublished study prepared by Miles Incorporated.34 p. 45426705 Bowers, L. (1994) Acute Toxicity of (Carbon 14)-Cyfluthrinto the Rainbow Befa-Cyfluthrin Trout (Oncorhynchus mykiss) Under Flow-Through Conditions: Lab Project Number: BD812202: 106652. Unpublishedstudy prepared by Miles Incorporated.35 p 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. Unpublishedstudy 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). (Unpublishedstudy 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 FPBALD to Daphnia magna: Report 31761. Unpublishedstudy prepared by Analytical Bio-Chemistry Labs, lnc..35 p. 158556 Forbis,A.; Burgess, D. (1984) Acute Toxicity of DCVA to Daphnia magna: Report 31762. Unpublishedstudy prepared by Analytical Bio-Chemistry Labs, Inc. 35 p. 41494001 Suprenant, D. (1990) 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. Unpublishedstudy prepared by Analytical Bio-Chemistry Labs, Inc. 34 p.42705801 Burgess, D. (1990) Acute Flow-through Toxicity of (carbon 14)-Cyfluthrin to Daphnia magna: Lab Project Number: 37684: 100321. Unpublished study prepared by ABC Labs, Inc. 29 p. 45426701 Forbis, A. (1988) Acute Toxicity of FCR 4545-1 Technicalto Daphnia Magna Beta-Cyfluthrin under Flow-Through Conditions: Lab Project Number: 34561: 98515. 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 Technicalto 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 41558003 

### 72-3 Acute Toxicity to EstuarineIMarine Organisms
MRlD Citation Reference

146118 Barrows, B. (1984) 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. (1984) The StaticAcute Toxicity of CyfluthrinTechnical 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- 2130: Mobay Report No. 90274. Unpublished study prepared by Environmental Sciehce and Engineering, Inc. 19 p. 158783 Carr, R. (1986) 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 Sciences. 64 p. 44815302 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. 44815303 Cunningham, F. (1996) MAT 7484: Acute Toxicity to the Sheepshead Minnow(Cyprinodon variegatus) Under Flow-Through Conditions: Lab Project Number: 59608008: 107666: 107527. Unpublishedstudy prepared by Toxikon Environmental Sciences. 73 p. 46591506 Putt, A. (2005) Cyfluthrin - Toxicity to Estuarine Amphipods (Leptocheirus plumulosus) During a 28-Day Sediment Exposure. Project Number: 1365616116. 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. Unpublishedstudy 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. Unpublishedstudy 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-Cyfluthrinto 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 Developmentof Sheepshead Minnow (Cyprinodonvariegatus): 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 Baythroidto the Sheepshead Minnow, Cyprinodonvariegatus: 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: Baythroid2 on cotton: [Including Page 9 of Mobay report no. 91890 and supporting raw data for Mobay report no. 91890, 91887 and 918911. 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) ChronicToxicity 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) Technicalto 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. Unpublishedstudy prepared by Analytical Bio-Chemistry Laboratories, Inc. 905 p. 

### 72-7 Simulated or 

### Actual Field Testing
MRlD Citation Reference

4151 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 Inhibitionof 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. (1984) Growth Inhibitionof Green Algae (Scenedesmus subspicatus) by FCR 1272 (Technical): Report HBFlA102: Study No. A1 04/84. Unpublished study prepared by BayerAG. 15 p. 

### 141-1 Honey bee acute contact MRlD Citation Reference

153638 Atkins, E. (1984) 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) Influenceof 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 PesticideToxicity 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 (1986) Letter sent to Mobay Chemical Corp. dated March 10, 1986: Honey bee residuetesting1Baythroid: [Foliar residues in Alfalfa]: Mobay Report No. 91915. 39 p. 47800530 Chauzat, M.; Carpentier, P.; Martel, A.; et al. (2009) Influenceof 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 FloweringWhite 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: 1365616115. Unpublished studyprepared 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 InternationalConference 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) Integrityof 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 Invertebratesin Microcosms: Lab Project Number: 101 953. Unpublished study prepared by Mobay Corp. 111 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. 144p. 47506603 Hall, L.; Killen, W.; Anderson, R.; et. al. (2008) An Assessment of Benthic Communities with Concurrent Physical Habitat, Pyrethroid, and MetalsAhalysis in an Urban and ResidentialStream 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 followingproposed Data Call-in tables includerationales for requiring the data requested in this problem formulation, explanations of the utility of the data, and explanationsfor how the data might impact risk assessment, following the format provided by PRD.

-- According to 40 CFR Part 1 

### 58, Subpaxt

### N (Environmental Fate) 

### tj 1 58.1 300 (Environmental fate data requirements table), these data are required for all terrestrialuse patterns. The Agency has aerobic soil metabolism studiesperformed 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 enantiomericenriched mixtures." (Current guideline 835.4100) Furthermore, there is evidencein the literature that the degradation of cyfluthrin and beta-cyfluthrinmay 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 transformationpathways. 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 suitablehalf-life. A new study is required. Anaerobic studies with one soil type are generally sufficient for the evaluation of transformationpathways, 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 TransformationTest Guidelines - OCSPP Guideline 835.4100 & 835.4200). 

### Practical-Utility 

### ofSheData

-- 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 interrestrial and aquatic environmentsis important. The results of this study will be usedin 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 ecologicalrisk estimation, and to determine surface drinkingwater concentrations, for drinkingwater 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 assumptionscould lead to higher predicted concentrations(EECs or EDWCs), accordingto 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 ofthese dissipation pathways in detail is essentialto perform a better and accurate environmental fate assessment and risk assessment.
The lack ofthese data will limit the flexibility the Agency and registrantshave in coming into compliance with the Endangered Species Act and could result in use restrictions for cyfluthrin and beta-cyfluthrinthat may be unnecessary.(Environmental fate data requirements table), these data are required for all terrestrialuse patterns. Two aerobic aquatic metabolism studies (soil1sediment systems) are available that were conducted with cyclopropyl-labeled beta-cyfluthrin. The studies availablethat were conducted with fluorophenyl-labeled beta-cyfluthrinwere 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-cyfluthrinhave the potential for use near estuarine1marine 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 ofmarine orinin (see above).

- 0 - -- I bcticaiUtility 

### 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 ecologicalrisk characterization.
In addition, the data will be used to derive the rate ofreaction input parameter to be used in the aquatic models GENEEC2, PRZW EXAMS and FIRST. The results from these models are used for ecologicalrisk 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 metabolismhalf-life input for the anaerobic aquatic metabolism). These conservative assumptionscould lead to higher predicted concentrations(EECs), according to the models, and consequently, higher riskquotients. Also, there would be a higher degree of uncertainty in the environmentalfate assessment. At this time, the anaerobic aquatic metabolism of cyfluthrin and betacyfluthrin is uncertain. Knowledge ofthese dissipationpathways in detail is essentialto perform a better and accurate environmental fate assessment and risk assessment. The lack ofthese data will limit the flexibility the Agency and registrantshave in coming into compliance with the Endangered SpeciesAct and could result in use restrictions for cyfluthrin and beta-cyfluthrin that may be unnecessary.nvironmen

The available study was performed at a single concentrationand no Freundlich correlationsor isotherms are available. According to OCSPP Fate, Transport and Transformation Test Guideline 

### (835.1230), the purpose of the main part of the study in Batch Equilibrium studies is the "Determination of Freundlich adsorption isothermsto determine the influence of concentration on the extent of adsorptionon 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 assumptionscould lead to higher or lower predicted concentrations (EECs), accordingto the models, and consequently, higher or lower risk quotients. The 

### Koc input parameterhas a major effect in the determination of the EECs for benthic organisms. Also, there would be a higher degree ofuncertainty in the environmental fate assessment. Knowledge of the mobility ofthis 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 registrantshave in comingGuideline Number: Non-guideline Study Title: Wood Leachability 

### :

. Rationale fop Requiring 

### $lieIhb 'I $ A study is required. It should be conducted according to the American Wood Preservers ~ssociation standard Method ofDeterminingthe ~eichabilit~ of Wood Preservatives (El 1-06). It is strongly suggested that the registrant provide a protocol to be evaluatedby

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 treatmentto buildings/productsindoor and outdoor and wood protection treatmentto forest products (unseasoned). The results ofthis 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-cyfluthrinbind stronglyto 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% ofthe 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), accordingto the models, and consequently,higher risk quotients. The application rate input parameter has a major effect in the determination ofthe aquatic EECs. Also, there would be a higher degree of uncertainty in the overall transport assessment for ecological effects. Knowledge ofthe leachabilityfi-omtreated wood ofthis chemical in detail is essentialto perform a better and accurate environmentalfate/ transport and risk assessment. The lack ofthese data will limit the flexibility the Agency and registrantshave in coming into compliance with the Endangered SpeciesAct and could result in use restrictions for this chemical that may be unnecessary.along with successful confirmatorymethod trials (validation)by an independent laboratory (i.e. ILVs). The registrant submitted two methods and one independent laboratory validation (MRID 41511301,47053001 and 47053002), that could quantify cyfluthrin in water and sediment. The Agency will verify the suitability of these methods and the appropriatenessoftheir 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 estuarine1marine fish, invertebratesand benthic organisms. Therefore, ECMs for water and sediment are required in addition to the ECM for soil. The ECMs should includeparent 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 orthat are at levels below the toxicological endpointsfor 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, departmentsor entities, to monitor concentrations of the residues of concern. Validated analytical methods in environmental media (a.ka., ECMs) are useful for conducting and evaluating submittedenvironmental 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 ofthe 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-cyfluthrinand 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 registrantshave in coming into compliance with the Endangered Species Act, and could result in use restrictions for cyfluthrin and beta-cyfluthrin which may otherwisebe avoided, or which are unnecessarily severe.-. monitoring data for the pyre&roidsbe submitted to the Agency. 

### POTW Treatability Study -In addition, the Agency is anticipating requiring a bench scale study of waste water treatment,to assessthe 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. 

### PracfiealUtility 

### of the 

### Ma How will the data be used? These data would be used to inform removal percentagesby waste water treatment, which is an input to the Exposure and Fate Assessment Screening Tool's (E-FAST) down-the-drainmodule.
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 ofmodeling from the EPIWEB v.4.0 may be used). These assumptions are likely to be crude and conservative. The lack ofthese data will limit the flexibility the Agency and registrantshave in coming into compliance with the Endangered SpeciesAct, and could result in use restrictions for cyfluthrin and beta-cyfluthrin which may otherwisebe 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 traditionallyused 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 currentrisk 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-targetbirds above the Agency Level of Concern, the Agency may explore decision optionsto mitigate this risk. The lack ofthese data will limit the flexibility the Agency and registrants have in coming into compliancewith the Endangered Species Act, and could result in use restrictions for cyfluthrin which may otherwisebe avoided, or which are unnecessarily severe.No acceptable data on reproductive toxicity to the most sensitivebird specieshas been submitted (mallard duck). A chronicrisk 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) cyfluthrinuse 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 ofthis study would be used to calculate risks to avian reproductionfrom 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 othertaxa indirectly), and use of cyfluthrinmight need to be restricted in areas where endangered species could be exposed. The lack ofthese data will limit the flexibility the Agency and registrantshave in coming into compliance with the Endangered SpeciesAct 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 cyfluthrinTEP effects on estuarinelmarine species. 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-useproduct will be introduced directly into the aquatic environment. 2. The maximum expected environmental concentration or estimated environmental concentrationin the aquatic environment is greater than or equal to one-halfthe LCs0or EC5() of the TGAI. 3. An ingredient in the end-use formulationother than the active ingredient is expected to enhance the toxicity of the active ingredient or cause toxicity to aquatic organisms. Previous assessmentson cyfluthrin indicate that the expected environmentalconcentrations 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 scenarioin the cyfluthrin new use 2004 assessment for a variety of crops, including tree nuts, grapes and leafy vegetables (DP 274813,290926,290922,2913 13,291923,294835and 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 studieswith 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/marineorganisms from exposureto cyfluthrin. The effects data would be used to determine the likelihood that exposureto cyfluthrincan potentially impact aquatic communities, either by direct effects or by indirect effects on other organismsby 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 ofthese data will limit the flexibilitythe Agency and registrants have in coming into compliance with the Endangered Species Act and could result in use restrictionsfor 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 potentiallyimpact aquatic communities, either by direct effects on invertebrates or by indirect effectsby 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 reviewprocess 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 differenceswith cyfluthrin. Since this extrapolation factor would involve uncertainty, it is likelythat a conservative factor would be applied. This may impinge on the Agency's flexibilityin coming into compliance with the Endangered SpeciesAct 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 indicatesthat the freshwater amphipod, Hyalella azteca, is substantiallymore sensitiveto pyrethroids than Daphnia magna, the commonly tested freshwater invertebrate. Information on the acute toxicity of cyfluthrinto 

### 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 ofthe Data How will the data be used? The freshwater acute toxicity study with Hyalella would allow the Agency to analyze acutely toxic effectsto one ofthe 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 effectsby 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 concernswith 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 includeusing an extrapolation factorbased on sensitivity differenceswith 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 SpeciesAct and could result in use restrictions for cyfluthrinwhich are unnecessarilv severe.No chronic sediment toxicity tests for freshwater or marine invertebrates have been submitted to satisfl the Agency's updated data requirementsfor outdoor uses in 40 CFR Part 158 (October 26,2007). For cyfluthrin, available information indicates that benthic organismsmay be exposed via run-off or spray drift applicationsused in agricultural, forest, and residential settings. Specifically, 

### o Based on preliminary calcutions, the peak sedimentporewater 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 oftrigger 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 involvingpyrethroids, 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 estuarinelmarinewater bodies based on currentusuage 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 assessmentfor 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 cyfluthrinon benthic organismsin previous assessments, there was a potential risk associated with adverse effects identified for other aquatic organisms. Acceptable data for benthic organismswill reduce the uncertainty from the previous assessment If the data indicates that registeredcyfluthrinusage may pose a risk of adverse effectsto non-target benthic organisms above the Agency Level of Concern, the Agency may explore decision options to mitigate this risk. The lack ofthese data will limit the flexibility the Agency and registrantshave in coming into compliance with the Endangered SpeciesAct, 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, vegetativevigor and seedlingemergence 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 ofpesticide exposure to non-target terrestrial and aquatic plants and to assess the impact of pesticides on endangered and threatened plants. In addition to the studiesrequired for cyfluthrin, tests conducted on beta-cyfluthrin are required for the most sensitivemonocotyledon and dicotyledon as per requirements of the EFED Interim Policy for StereoisomericPesticides.
Practical 

### USility ofthe 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 cyfluthrinand beta-cyfluthrin. The data will reduce uncertainties associated with the current risk assessment for terrestrial plants and will improve our understanding ofthe 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 environmentalquality, a solid understanding of the potential risks to terrestrial plants is essential for sound environmentalmanagement. Without acceptable plant growth data for cyfluthrin and beta-cyfluthrin, the Agency cannot determine the levels of cyfluthrinthat result in effectsto terrestrial plants. If the data indicates that registered usage may pose a risk of adverse effectsto 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 SpeciesAct, and could result in use restrictions for cyfluthrinwhich may otherwisebe avoided, or which are unnecessarily severe.No studies for cyfluthrinhave been submitted for vascular aquaticplants. The Agency has finalized its update to the data requirementsin 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 additionto 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 aquaticplant toxicity studieswill be used to estimate potential risks ta plants associatedwith uses of cyfluthrin and beta-cyfluthrin. The data will reduce uncertainties associated with the current risk assessment for aquatic plants and will improve our understandingofthe potential effects on vascular aquaticplants.
How could the data change the Agency's decision, or impact the Agency's future decision-making? Because plants form the basis ofmost habitats and significantlycontribute to overall environmental quality, a solid understandingofthe potential risks to aquaticplats is essential for sound environmentalmanagement. Without plant growth data for cyfluthrin,the Agency cannot determine the levels of cyfluthrinthat result in effectsto vascular aquatic plants. If the data indicates that registered usage may pose a risk of adverse effectsto non-target aquatic vascular plants above the Agency Level of Concern, the Agency may explore decision optionsto mitigatethis risk.
If future endangered species risk assessmentsare 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 ofthese data will limit the flexibility the Agency and registrantshave in coming into compliance with the Endangered SpeciesAct 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-4545Betacyfluthrin, 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

00131503 Acceptable

41558001 Supplemental

41558002 Acceptable

45375001 Supplemental

45375002 Supplemental

45375003 Supplemental

45426703 Supplemental

45426705 Acceptable

45426706 Supplemental

45426707 Acceptable

45426708 SupplementalMRID and study classification

00155898 Supplemental

41450401 Acceptable

00131504 Acceptable

45426701 Supplemental

42'105801
Unreviewed

41558003 Acceptable

00151442 Acceptable

46591507
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)

96Endpoint

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

(WaterFlea)

Daphnia magna

(Water Flea)

Daphnia magna

(WaterFlea)

Daphnia magna

(Water Flea)

Chironomus

tentans (Midge)
Cyprinodon variegatus (Sheepshead

minnow) Test Substance

Cyfluthrin

Betacyfluthrin, FCR-4545

Cyfluthrin

Cyfluthrin (TEMPO

2EC)

CyfluthrinSpecies (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

46591506
Inreview
00158785 Supplemental

### Appendix 

### C. Open Literature Information
The following is a cursory search ofthe available literature on cyfluthrin, beta-cyfluthrin and synthetic pyrethroids in general, mostly about their prevalence1occurrence, 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 ofthe prevalence and toxicity of cyfluthrin, and other synthetic pyrethroids, in sediment environmentsof urban and agricultural sites, particularly in California. In a 3-year field test studyinghoney 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 relationshipswere found between colony mortality and the presence ofpesticides overall, the authors state that "more work is needed to determine the role these residuesplay in affecting colony health". In mother study, Dai et al. (2010) examined the sublethal effects oftwo pyrethroids, deltamethrin and bifenthrin, on bee colony health. The authors concluded that both chemicals adversely impacted bees by reducing bee fecundity and decreasingthe rate ofbee development into adulthood. Ureda (2004) determined the LCSOs for deltamethrin,lambda-cyhalothrin and cyfluthrin, using the test speciesHyalella azteca. Also, sediment samples from two locationsin Central Valley, Californiawere tested. They found that there was a linear relationship between the LCsoand 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 1.07pg/goc. The LOEC for cyfluthrin were 0.17-0.77pg/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 syntheticpyrethroids tested, bifenthrin exhibited the highest toxicity, while for cyfluthrin the average sediment 10-daymedian LC50 was roughly an order of magnitude higher (or less toxic) than for bifenthrin. The actual value was 1.08pglgoc, which is ofthe same order of magnitude reported in the Ureda 2004 study. Two major factors that affect the toxicity ofthe pyrethroids include the presence of a synergist, such as piperonyl butoxide (PBO) and the temperature. Amweg et al. 2006a documentedthe 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 sedimentup to seven-fold. Also, Amweg and Weston 2007, documented the effects ofthe 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-dayHyalella 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 orless than 1 with no statistical difference in toxicity for all but chlorpyrifos. Eight field collected sediments, containing a variety of syntheticpyrethroids, 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 sedimentsexhibited 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 altersthe toxicity of some toxicants but not others"), they performed sediment toxicity tests at various temperatures (13, 18,23and 28°C). 10-dayLCSO's to Hyalella azteca were determined for four pyrethroids, (permethrin,bifenthrin, esfenvalerateand 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 temperaturewas decreased from 23 to 1 S°C, and approximately tripled when the temperaturewas further decreased to 13°C. The results at 28°C were mixed, but for some ofthe control samples, survival was low, which could indicate that the test specieswas not tolerant of the change to high temperature. For DDT, there was a similarresponse profile with temperature,but not as pronounced as for the synthetic pyrethroids. For chlorpyrifos and cadmium, the responses with temperaturewere 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 ofthe temperature dependenceofthe 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 organicmatter (DOM) on the bioavailability of the pyrethroids cyfluthrinand permethrin, and their toxicity towards Daphnia magna and Ceriodaphnia dubia. A total of 15 surfacewater samples fi-om southern Californiawere utilized. The dissolved organic content (DOC) ranged from 3.3- 20.2% and the pH ranged from 6.67-7.76. Various indicatorswere 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 bioconcentrationfactors (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 sampleshad 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 availableperrnethrin, but for cyfluthrin, the freely available cyfluthrinwas less than for the control samples in all instances. The KD~~ were less for cyfluthrin than for permethrinby 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 ofthe 

### 15 samples (for 9 samples, the difference was significant). There was a significant correlationbetween the cyfluthrinbody residue and Cfi,,, but not for permethrin. In 96- hour static exposure tests with C. dubia neonates, the cyfluthrinLCsoswere 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 organicmatter, and lower bioavailabilityin 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 chemicalswere surveyed on floors of occupied homes. The survey included several synthetic pyrethroids like cyfluthrin. The most frequentlydetected pesticide was permethrin (89% ofthe samples). Cyfluthrin was detected with a frequency of 17% (n =480 samples; mean not reported for chemicals with detection frequencybelow 30%; maximum value = 129ng/cm2), illustrating that this chemical is commonly applied, detected and present in homes. Cyfluthrin is among the constituentsmonitored 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 microgramsper liter," with a reportedpercent of &mples with this parameter of 9.7 (reportunits of pg/L). The other is "Cyfluthrin solids- recoverabledry weight- microgramsper kilogram," with a reported percent ifsamples 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 subdivisionsof 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 consideredto be the primary cause ofthe toxicity towards the organism, with additional contributions of the pyrethroids cyfluthrin and cypermethrin. The maximum concentrationof cyfluthrin was found to be 169ng/g dry weight, for a tributary ok Kaseberg Creek, in sampling site 11. It was detected in 12out of 24 sediment samples. The authors indicate that the presence of synthetic pyrethroidswas not likely to be due to agricultural uses. In Placer County, the use of syntheticpyrethroids 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 concentrationsand toxicity. Cypermethrin, cyfluthrin, deltamethrinand lambda-cyhalothrin may have contributed to the toxicity in some ofthe sites. The concentrationsof cypermethrinand cyfluthrin were typically higher than for other synthetic pyrethroids (usually 2-30 nglg), but the bifenthrin and permethrin concentrationswere the highest. On the other hand, in Tennessee only a few samples contained synthetic pyrethroids and none of the sampleswere toxic to Hyalella azteca. The differencesbetween the two sites were attributed to different climate, types ofresidential 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 showhigher toxicity at lower temperatures, as indicated above). Seven of eight pyrethroidswere detected in the sediment samples. Fenpropathrin was not detected in any ofthe samples, and deltamethrinand esfenvaleratewere detected infrequently; but bifenthrin was present in all the 30 samples (2.19 to 219 nglg dry weight). Permethrin was the second most detected pyrethroid and cyfluthrin was detected in 16 samples, with a highest concentration of 127nglg dry weight. The results suggested an important role ofthe 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 chlorpyrifoswere the pesticidesmost commonly occurring in toxicologically significant mixtures. Bifenthrin, permethrin and 

### DDT were observed in greater than 90% ofthe samples. After normalizing the chemical concentrationsfor organic carbon "to provide better estimates of the biologically available chemical fractions," all the seven pyrethroidsmonitored had levels exceeding the establishedlevel 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 establishedLOI) 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 illustratethe 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 frequentlydetected synthetic pyrethroids, with bifenthrin found in 95-100% ofthe samples. Cyfluthrin was observed less frequently,at a highest concentration of 2.48 uglkg. The highest concentrationswere associated with commercial nurseries. The authors found in this case that the concentrationof synthetic pyrethroids was generally lower in residential or commercial areas as opposed to agricultural sites. Also, the frequency of detections of pyrethroidswas higher during the wet season (e.g., cyfluthrin 33% vs. 5%), but the total concentration was not statistically differentbetween 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 sedimenttests were conducted for Hyalella azteca and Chironomus dilutus (formerlyknown as Chironomus tentans), for some ofthe samples. Syntheticpyrethroids were found in 75% ofthe sediment samples; also they were found,based on a toxicity unit basis, to be sufficientlyhigh to cause toxicity in 40% ofthe samplestoxic to C. dilutus and around 70% ofthe 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 illustratedthe possibility of high levels of several synthetic pyrethroids in agricultural zones.
In a study, Gan et al. 2005 monitored the spatial distributionand enrichment(enrichment ratio, ER, or ratio ofthe concentrationof a substance in eroded sedimentto that ofthe source matrix) of the synthetic pyrethroids permethrin and bifenthrin, along a 260 meters runoff path. A sedimentationpond was used as the source point for the study (permethrin and bifenthrinhad been used extensively at the site, for ant control, in a nursery environment). It was observed that, in general, the sediment concentrationof 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 substanceswas 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 analyticalmethod that includeid among others cyfluthrin and piperonyl butoxide (PBO). Analysis of the SanFrancisco Bay tributary sediment samples (six samples from five sites)revealed that cyfluthtin was detected in one ofthe sediments, at 17.6ng/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 detectedpyretl-iroid from runoff waters from Roseville and Elk Grove urban sites. Cyfluthrin, cypemethrin and permethrinwere also detected frequently. During the dry season, cyfluthrinwas 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 syntheticpyqethroids 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 ofthe studies related to the synthetic pyrethroids were conducted in California,but other studies document the presence of syntheticpyrethroids elsewhere.Hintzen et al. 2009 monitored for 12insecticides and degradation products, including synthetic pyrethroids and fipronyl in Texas stream sedimentsfrom 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-dayLC5() 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 LCs0for 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 discrepanciesbetween 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 conductedmonitoring 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 sampleswere from constructed storm drains, while the agricultural sampleswere from small waterways between farmlands in areas where mostly corn and soybeans were grown and the major pesticidesused were tefluthrin and atrazine. Furthermore, sediment toxicity tests towards Hyalella azteca were performed. In the urban samples,the synthetic pyrethroids were detected in 95% ofthe samples. Bifenthrin was detected in 80% of the samples,while permethrin, lambda-cyhalothrinand fenpropathrinwere also frequentlydetected; cyfluthrin was not detected. In the agricultural samples,bifenthrin, permethrin, cypermethrin and tefluthrin were detected (frequency of detection47%), while cyfluthrin, fenpropathrinand lambda-cyhalothrin were not detected. Ten of 17 urban sediment samplestested were significantlymore toxic to 

### H azteca than the controls. Only one of the agricultural sediment sampleswas significantlymore 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 pesticideprimarily used in agriculture.
LeBlanc & Perkins, 2009, documented the presence of synthetic pyrethroidsin Maine sediments. Of five synthetic pyrethroids monitored, only bifenthrin was detected, at levels of 1.26 - 16.68ng/g (means). The other synthetic pyrethroidsmonitored were lambda-cyhalothrin, permethrin, cyfluthrin and cypermethrin. Four sedimentswere 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 sampledjust prior to discharge to surface waters. And finally, third, agricultural dischargeswere collected at pump stations, where the runoffis lifted over the levees. Sampleswere tested for 8 pyrethroids and chlorpyrifos(LOQ around 1ng/L for most samples). Tests to Hyalella azteca were also performed on the water samples. Cyfluthrinwas 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= 1.9ng/L for H. azteca. The maximum measured cyfluthrin concentrationwas 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 observedwhen the temperature ofthe 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 effluentshad low suspended material and for the possible partitioning with biosolids within the plants. The authors indicated that possible sources of pyrethroids are sewer disposal ofhousehold 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 agriculturaluse, at least in California, one of the few areas where data are available.A similar situationis likely elsewhere where there is substantial urban development. Whereas agriculturaluse of pyrethroids in Californiais about 300,000 lblyr, non-agricultural commercialuse (mostly applicationsdone 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 100,000lblyr. Some of the major urban uses of pyrethroids include cyperrnethrin and permethrin for termite control, permethrinto maintain landscaping, and bifenthrin and cyfluthrin for a variety ofpests around homes."
Various studies provide additional environmental fate characterizationof 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 availablehydrolysis study. In a studyperformed by Fernhdez-Alvarez et al. 2007, the photolyticbehavior of cyfluthrin and various other synthetic pyrethroids was studiedunder artificial and natural light. The detectionwas performed using solid phase micro-extraction (SPME). After 20 minutes of exposureto 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% ofthe residues in the upper 0-5 cm depth. The soil was classified as a sandy loam and it was an inceptisolwith a pH of 7.7. In 2005, the same researchers studied the fate of betacyfluthrin in water, and the effect ofpH, 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, respectivelyin 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 formulationfrom 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 dissipationfrom the soil-sediment was reported to be slower (initial 3.0-4.3 days and 13.5-13.9during the 10-30day 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 Californiawere used for incubation in this study. The incubationswere performed with viable and sterile soils1sediments. The incubationswere performed with cisbifenthrin, cis-permethrinand cypermethrin (however, they did not use cyfluthrin of beta-cyfluthrinin this part ofthe study). Also, duplicate sedimentswere 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, consistentlyc0.25, and 1R-trans-aS 

## + 1 S-trans-aR, consistentlyB0.25. They indicated that, "Of the cis enantiomers, the SF remained around 0.125 for some samples but clearly increased or decreasedin 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 17.16-28.41days, and for the trans-isomers, they were 8.74-12.67days. A similar enantioselectivebehavior 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 runofffiom agricultural fields. The synthetic pyrethroids cyfluthrin and lambda-cyhalothrinwere used as model

10 It was noted that these concentrationsexceed the solubilitylimit for beta-cyfluthrin of near 2 ppb.

122contaminants. Testing withHyalella azteca was performed to determine the efficiencyof the system. There was spatial and temporal variation ofthe two pyrethroids' concentrationsin 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 concentrationof 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 observationperiod even though the pyrethroids' concentrationsdecreased significantly. The authors concluded that the pyrethroids can move, affectingnon-target aquatic organismsfor weeks to months after entering a constructedwetland. In 2009, Moore et al. also used cyfluthrin and lambda-cyhalothrinin constructed wetlands (comprised of a sediment retention basin, and two treatment cells) in a study lasting 

### 55 days. 

### A high percentage ofthe measured cyfluthrinwas associatedwith 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 ofboth chemicals from a 14ha 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 FileName Chemical Name
CropNames Application Rate Day ofApplication (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 applicationwas 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 ,labelBAYTHROIDm 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 of4 values available (124000,180300, 118000,73500) The Koc model was utilized as per the 1999 SAP recommendation. Represents the 90" percentile of the upper confidencebound on the mean oftwo half-life values [values: 73 5,94.8days, mean = 84 15 days; std. dev = 15.06days, t90,n.1 = 3.078 for n=2] ---
--- --- Appropriate for abuffer zone of 150 ft --- Represents the 90" percentile of the upper confidencebound on the mean oftwo 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-cyfluthrinOutputFiles Table 3. InputParameters 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)
HydrolysisatpH 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 TOXNETIHSDB 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 0.087720.05173 0.1755 0.1144 0.09702 0.05525 0.073170.04625 0.0406 0.03489 0.06612 0.0571 0.047120.03802 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 ApplicationMethod) IncorporationDepth (cm) IPSCND, Conditionfor dispositionofpesticide 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 Laskowsky2002

--- ---
--- --- Meteorological file located in Jackson,MS. Foliar applied,linear application Label. Surface applied

Defaultvalue
---

---

--- --- Default forpond scenario,as opposedto 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 0.097020.05545 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 0.096570.08522 0.05173 0.1429 0.09624 0.082310.05163 0.1268 0.09414 0.08218 0.05088 0.1194 0.085540.07362 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 0.069720.063760.04412 0.1062 0.06934 0.06358 0,04412 0.1054 0.0681 0.061310.04367 0.1023 0.067970.060280.04211 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 0.058960.051950.03802 0.08565 0.0571 0.049630,03778 0.07806 0.0558 0,048980.03776 0.076010.05536 0.048710.03503 0.073170.055280.04712 0.03501 0.06612 0.04832 0.045940.03489 0.06339 0.046250.0406 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 manualIncorporation 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 0.019970.019860.01957 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 0.028660.02845 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 0.030610.029670.02113 0.02342 0.02327 0.022810.02125 0.020010.01347 0.02372 0.02365 0.02156 0.02087 0.01984 0.01441 0.02815 0.027980.02708 0.02636 0.02508 0.01878 0.06133 0.06089 0.05683 0.04914 0.044460.02577 0.03603 0.03578 0.033910.030840.0291 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 0.044080.043780.0404 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 0.023010.01637Sorted 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 0.033380.02171 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 0.029620.02087 0.290322580645161 0.03603 0.03578 0.033070.030610.0291 0.02055 0.32258064516129 0.03422 0.03396 0.03246 0.02953 0.028970.02021 0.354838709677419 0.03352 0.03334 0.032270.02787 0.02693 0.01984 0.387096774193548 0.028660.02845 0.027560.02639 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 0.025880.0241 0.01798 0.483870967741936 0.02793 0.027880.027010.025510.0234 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 0.023360.02192 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 0.024760.02237 0.02068 0.01534 0.774193548387097 0.0246 0.02442 0.02382 0.02223 0.020610.01519 0.806451612903226 0.02452 0.0244 0.023440.02191 0.020510.01492 0.838709677419355 0.023920.02383 0.02343 0.02178 0.020380.01441 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 0.020870.019780.01296 0.967741935483871 0.01997 0.019860.01957 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/haInterval 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)