Environmental Fate and Ecological Risk Assessment 

for the Registration of Indaziflam 

Indaziflam 

N-[(1R,2S)-2,3-dihydro-2,6-dimethyl-1H-inden-1-yl]-6-[(1RS)-1-fluoroethyl]- 

1,3,5-triazine-2,4-diamine 

CAS Registry Number 950782-86-2 

PC Code 080818 

 

Prepared by:

Reuben Baris, Physical Scientist 

Alicia Korol, Biologist 

Reviewed by: 

Thomas Steeger, Ph.D., Senior Biologist 

Marietta Echeverria, Senior Environmental Scientist 

Elizabeth Behl, Branch Chief 

U. S. Environmental Protection Agency

Office of Pesticide Programs

Environmental Fate and Effects Division

Environmental Risk Branch IV

1200 Pennsylvania Ave., NW

Mail Code 7507P

Washington DC 20460
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1. Executive Summary 

1.1. Nature of Chemical Stressor 

 Bayer CropScience is seeking registration for the new chemical herbicide indaziflam 

(BCS-AA10717), N-[(1R,2S)-2,3-dihydro-2,6-dimethyl-1H-inden-1-yl]-6-[(1RS)-1-fluoroethyl]-

1,3,5-triazine-2,4-diamine. Indaziflam is a fluoroalkyltriazine herbicide, part of the broader 

triazine herbicide family. It differs from other triazine herbicides, with a fluoroethyl group in 

place of a chloride in the chlorotriazines (e.g., atrazine). Indaziflam controls weeds by inhibiting 

cellulose biosynthesis (CB Inhibitors). Indaziflam’s primary modes of action are through 

inhibition of seedling emergence and root development. For most effective control, indaziflam 

needs to be applied prior to weed germination since indaziflam has low post emergent activity. 

Technical grade indaziflam is a mixture of two active diastereoisomers, which are present in the 

technical grade product as 95-100% isomer A and 0-5%, isomer B. 

 This assessment is for a national registration request for selective, pre emergence and 

post emergence control of many annual grasses and broadleaf weeds including crabgrass, 

goosegrass, annual bluegrass, and annual sedges. Proposed use sites include turf, home lawns, 

citrus fruit, stone fruit, pome fruit, grapes, tree nuts, pistachios, olives, ornamentals, trees (e.g., 

Christmas trees, and other commercial forested areas), residential ornamentals, non-crop areas 

(e.g. railway yards), and on hardscapes. Post emergence control claims refer primarily to the 

herbicidal action of mixtures of other active ingredients in formulations with multiple active 

ingredients (e.g., indaziflam plus 2,4-D, dicamba, mecoprop, or penoxsulam), or in tank mixes 

where indaziflam provides residual control for the re-emergence of many annual grasses and 

broadleaf weeds. The Agency does not routinely include in its risk assessments an evaluation of 

mixtures of active ingredients, either those mixtures of multiple active ingredients in product 

formulations or those in the applicator’s tank. In the case of the product formulations of active 

ingredients (that is, a registered product containing more than one active ingredient), each active 

ingredient is subject to an individual risk assessment for regulatory decision regarding the active 

ingredient on a particular use site. The available effects data on multiple active ingredients were 

submitted as requirements for the new registrations of indaziflam’s formulated products. The 

effects data include acute oral toxicity studies using the rat and demonstrate that indaziflam, 

when used in combination with other active ingredients, is not more toxic that the technical grade 

active ingredient (TGAI) alone. 

 Eleven end-use formulations of indaziflam are proposed for registration in the United 

States. According to proposed labeling, indaziflam can be applied to foliage and soil via granule 

treatments, via ground spray as broadcast and banded treatments, and via aerial applications 

(broadcast). Ground applications are proposed with maximum annual application rates ranging 

from 0.089 to 0.134 lbs a.i./A/yr. Aerial applications are proposed with a maximum annual 

application rate of 0.125 lbs a.i./A/yr. 

 The major transformation products resulting from the environmental degradation of 

indaziflam are: triazine-indanone; indaziflam-carboxylic acid; indaziflam-hydroxyethyl; 
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indaziflam-olefin; fluoroethyldiaminotriazine (FDAT, fluoroethyl diamino s-triazine); and 

fluoroethyltriazinanedione. Eco-toxicity data are available for the first five of these 

transformation products (degradates). The toxicity data show that indaziflam-olefin and 

indaziflam-hydroxyethyl are of similar toxicity to the TGAI, based on the most sensitive taxa 

tested, while indaziflam-hydroxyethyl, FDAT, and triazine indanone demonstrate toxicities at 

magnitudes 2-7 times less than that of the parent. Aquatic exposure estimates are thus based on a 

total toxic residue approach of indaziflam + residues of concern (two major photodegradates: 

indaziflam-olefin and indaziflam-hydroxyethyl). Terrestrial exposure estimates are based on the 

residue levels of indaziflam alone. While data are not generally available for screening level 

assessments to assess the terrestrial exposure and effects of degradates, as is the case for this 

assessment of indaziflam, the conservative 35-day foliar dissipation half-life used in the 

terrestrial modeling may account for the formation and toxicity of the degradates (assuming the 

degradates are not any more toxic than the parent). Any effects of degradates to terrestrial plants 

that might occur over a 21 day time period would be captured by the nature of the terrestrial 

plant studies conducted on indaziflam’s formulated products (those without multiple active 

ingredients). However, any signs of toxicity in these studies would be assumed to result from the 

parent indaziflam. 

1.2. Potential Risks to Non-target Organisms 

The results of this baseline assessment on the proposed indaziflam uses indicate that risk 

of adverse effects exists to terrestrial monocotyledons (monocots) and dicotyledons (dicots), and 

aquatic vascular plants. The proposed uses of indaziflam may also have the potential to cause 

adverse direct effects on Federally-listed threatened/endangered (listed) nonvascular plants. A 

submitted Tier III aquatic microcosm study provided confirmatory evidence for the risk 

determinations made to aquatic vascular and non-vascular plants. Due to lack of available data 

or inadequacy of data to demonstrate otherwise, direct risk from chronic exposure is presumed to 

non-listed and listed species of estuarine/marine invertebrates and birds. Direct risk to mammals 

(non-listed and listed) is not expected from proposed indaziflam use based on this screening level 

assessment. Direct adverse effects on terrestrial invertebrates (non-listed and listed) are also not 

expected. 

The results of AgDRIFT modeling, as depicted in Figures 1.1 and 1.2 below, illustrate 

that non-listed and listed species RQs based on ground and aerial broadcast applications to 

roadsides/rights-of-ways, site preparation, and forested areas exceed the LOC for distances at or 

greater than 900 feet from the edge of field. Spray drift buffers ranging from 49-259 feet for 

orchard uses would be necessary to reduce spray drift deposition below the non-listed species 

LOC, and buffers ranging from 89-334 feet would be necessary for listed species. For turf uses, 

buffers of 341 feet would be necessary to create spray drift deposition below the non-listed 

species LOC, while buffers of 528 feet would be necessary to reduce RQs below the listed 

species LOC. Thus, buffers of ~350 feet and buffers of ~550 feet for broadcast applications of 

indaziflam would reduce RQs below the non-listed and listed species LOCs, respectively, for all 

turf and food uses. These buffers would not be protective of all listed and non-listed species for 
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the other proposed broadcast uses of indaziflam, but they are expected to reduce the number of 

species ultimately affected. 

0.1

1

10

100

1000

0 100 200 300 400 500 600 700 800 900 1000

Distance From Edge Of Field

RQ

Food - Normal Orchard

Food- Sparse Orchard

Turf

Roadsides/Rights-of-ways/Site Prep

Forested Areas-Ground

Forested Areas - Aerial

Figure 1.1: RQs for the most sensitive nonlisted terrestrial plant exposed to spray drift 

from propsed broadcast uses of indaziflam. The risk to nonlisted species LOC is 1.0 (RQ = 

1.0). 

0.1

1

10

100

1000

0 100 200 300 400 500 600 700 800 900 1000

Distance From Edge of Field (feet)

RQ

Food - Normal Orchard

Food- Sparse Orchard

Turf

NonCrop

Forested Areas-Ground

Forested Areas - Aerial

Figure 2.2: RQs for the most sensitive listed terrestrial plant exposed to spray drift from 

proposed broadcast uses of indaziflam. The risk to non-listed species LOC is 1.0 (RQ = 

1.0). 
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Potential “may affect” determinations from direct and indirect effects to Federally-listed 

species based on LOC exceedances require an evaluation of the potential co-occurrence with 

areas where indaziflam is proposed for use: proposed uses include both agricultural and nonagricultural areas, where non-agricultural use patterns represent the highest annual application 

rates. For purposes of this assessment, it is assumed that indaziflam may be used nationwide for 

non-agricultural uses. Based on the proposed uses, it is assumed that indaziflam’s risk to listed 

species may extend nationwide. Thus, there is a “may affect” determination made for all listed 

species found to be at risk from indaziflam use. Identified potential direct and indirect risks to 

listed species are summarized in Table 1.1. 

Table 1.1. Potential Effects to Federally Listed Taxa Associated with Direct or Indirect 

Effects from the Proposed New Uses of Indaziflam. 

Listed Taxon Direct 

Effects Uses of Concern Indirect Effects1 Uses of Concern 

Terrestrial and semi-aquatic 

plants - monocots Yes All uses Yesb All uses 

Terrestrial and semi-aquatic 

plants - dicots Yes All uses Yesb All uses 

Terrestrial invertebrates No None Yes All uses 

Birds* Yes All uses Yes All uses 

Terrestrial-phase amphibians 

and reptiles* Yes All uses Yes All uses 

Mammals No None Yes All uses 

Aquatic nonvascular plants Yes Home lawn, 

Ornamentals Yesa All uses 

Aquatic vascular plants Yes All uses Yesb All uses 

Freshwater fish No All uses Yes All uses 

Aquatic-phase amphibians No All uses Yes All uses 

Freshwater crustaceans No All uses Yes All uses 

Mollusks** Yes All uses Yes All uses 

Marine/estuarine fish No All uses Yes All uses 

Marine/estuarine 

invertebrates** Yes All uses Yes All uses 

* Due to presumed chronic risks to birds from inadequacy of data 

** Due to presumed chronic risk from lack of data 

a Potential for indirect adverse effects to those listed species that rely on a specific plant species in their life cycle (termed plant species obligates). b

 Potential for adverse effects to those listed species that rely either on a specific plant species (plant species obligate) or multiple plant species 

(plant dependent) for some important aspect of their life cycle.

1 Potential indirect effects on a taxon attributable to direct effects on that respective taxon and/or direct effects on aquatic and terrestrial plants. 

1.3. Conclusions - Exposure Characterization 

 Indaziflam is expected to be moderately mobile to mobile in soil (Koc < 1000 mL/g oc), 

moderately persistent to persistent in aerobic soil (half-lives > 150 days), persistent in anerobic 

soil (stable), and persistent in aerobic (half-lives > 200 days) and anaerobic (stable) aquatic 

environments. Indaziflam is subject to aqueous photolysis in clear shallow waters (half-life < 5 

days). Indaziflam is not volatile and therefore it is not likely to be transported via atmospheric 

processes following application. It is a weak acid, and is moderately soluble at environmental 

pH values. Indaziflam dissipates in the environment primarily through biotic degradation and 

leaching. Indaziflam degradates are more mobile than the parent (Koc < 100 mL/g oc), and were 
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detected in field studies at the deepest depths sampled (105-120 cm). Particularly, the degradate 

fluoroethyldiaminotraizine (FDAT) which is mobile to highly mobile (Koc ranged from 10 – 50 

mL/g oc), and is a similar to other triazine degradates with the diaminotriazine structure, with the 

exception of the fluoroethyl group in place of the chloride for the chlorotriazine herbicides. 

Field and laboratory data, and the fate properties of the degradate show that FDAT has a 

potential to leach to ground water. These key lines of evidence show that residues of indaziflam, 

particularly fluoroethyldiaminotriazine, are a concern for exposure via ground water. 

 Aquatic exposure estimates are based on a total toxic residue approach of indaziflam + 

residues of concern (two major photodegradates, indaziflam-olefin and indaziflamhydroxyethyl). There were significant amounts of unextrated residues reported in the 

degradation studies, and only a single extraction method was used. It is uncertain whether these 

residues are parent residues, or degradate residues, and/or bound residues that are no longer 

biologically available. Therefore, aquatic exposure estimates were generated using two sets of 

environmental half-lives to account for this uncertainty: 1) parent + residues of concern, and 2) 

parent + residues of concern + un-extracted residues. Acute 1-in-10 year estimated 

environmental concentrations (EECs) in surface water for parent + residues of concern for all 

uses of indaziflam ranged from 0.35 ug/L to 2.66 ug/L; acute 1-in-10 year EECs in surface water 

for parent + residues of concern + unextracted residues ranged from 0.47 ug/L to 6.19 ug/L. 

 Terrestrial exposure estimates are based on the residue levels of indaziflam alone, as 

described above. Spray (aerial and ground) and granule (ground) applications were considered 

as exposure methods of indaziflam to terrestrial environments. For exposures to terrestrial birds 

and mammals from spray applications, pesticide residues in food items were calculated: 0.30 to 

31.7 mg/kg-diet for birds on a dietary basis; and 0.01 - 30.1 mg/kg bw for mammals on a dosebasis. For exposures to terrestrial birds and mammals from granular applications, estimates of 

indaziflam loadings per unit area were calculated: 0.83 mg a.i./ft2

 for birds and mammals. 

Exposure to terrestrial plants was estimated from residue concentrations in off-field runoff as 

well as from spray drift. Estimates of indaziflam exposures to plants ranged from 0.00017 – 

0.01875 lbs a.i./A. 

1.4. Conclusions - Effects Characterization 

Aquatic Organisms 

Indaziflam is categorized highly toxic (EC50 = 0.1 – 1 mg a.i./L) to freshwater and 

estuarine/marine fish, moderately toxic (EC50 = 1 -10 mg a.i./L) to highly toxic (EC50 = 0.1 – 1 

mg a.i./L) to estuarine invertebrates, and slightly toxic (EC50 = 10 - 100 mg a.i./L) to moderately 

toxic (EC50 = 1 -10 mg a.i./L) to freshwater invertebrates on an acute exposure basis. Chronic 

toxicity studies are only available for freshwater fish and invertebrates using the species P. 

promelas and D. magna, respectively. The one chronic freshwater fish toxicity endpoint used in 

this assessment was based on fry survival, total length, and dry weight, with sublethal effects 

immediately preceding mortality at the highest concentrations tested. Of the parameters assessed 

in the one submitted invertebrate life cycle study, indaziflam inhibited the parameters measuring 

both parental (F0) growth and reproduction. Effects to offspring (F1) were not evaluated. Results 
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of toxicity studies of technical grade indaziflam in freshwater and marine nonvascular and 

vascular plants indicate that indaziflam is toxic to aquatic plants. This determination is based on 

the magnitude of EC50 values in the parts per billion (aquatic vascular plants) and parts per 

trillion range (aquatic nonvascular plants). 

 Degradate toxicity data on aquatic vascular and nonvascular plants indicate that 

indaziflam-olefin and indaziflam-hydroxyethyl are of equal or similar toxicity to the parent 

indaziflam. Indaziflam-hydroxyethyl, FDAT, and triazine indanone demonstrate toxicity to 

these same taxa at magnitudes 2-7 times less than the parent. Toxicity data for freshwater fish 

are available for the degradates FDAT and carboxylic acid, which show toxicities of 3 times less 

than that of the parent and are categorized as practically non-toxic to fish on an acute exposure 

basis. 

 Available studies demonstrate that certain formulations of indaziflam are of similar 

toxicity (within the same order of magnitude) to freshwater fish, freshwater invertebrates, and 

aquatic vascular and nonvascular plants. 

Terrestrial Organisms 

Indaziflam is categorized practically nontoxic (LD50/LC50 > 2,000 mg a.i./L) to birds on 

both an acute oral and subacute dietary exposure basis. For chronic studies, treatment-related 

effects on adult female weight gain, adult male weight gain, and adult food consumption were 

observed in avian reproduction studies using mallard duck. Indaziflam is categorized practically 

non-toxic (LD50 > 2,000 mg a.i./L) to mammals on an acute exposure basis. In a reproduction 

test using the rat, parental, offspring, and reproductive toxicity was observed. Parental effects 

included course tremors in females, decreased body weights and body weight gains, decreased 

food consumption, and effects on kidneys in males. Offspring effects included decreased body 

weights, body weight gains, and secondary delays in sexual maturation. Reproductive toxicity 

was based on delayed sexual maturation in F1 and F2 pups. Results of available toxicity studies 

on terrestrial invertebrates indicate that the TGAI is practically nontoxic to honey bees and 

earthworms on an acute contact basis; however, studies demonstrated subacute effects (i.e. 

weight reduction) in earthworms. Tier II studies of the effects of indaziflam formulations BCSAA10717 20WSP and Indaziflam 500 SC on seedling emergence and vegetative vigor in 

terrestrial plants indicated that terrestrial plants are sensitive to indaziflam at application rates 

much less than the proposed registration uses. 

1.5. Uncertainties and Data Gaps 

For purposes of this assessment, data gaps refer to the absence of required data for a new 

chemical registration as specified in 40 CFR Part 158. Without data or sufficient evidence to 

demonstrate otherwise, risk to non-listed and listed species of a taxon is presumed. Only one 

ecological effects data gap for indaziflam was identified: Estuarine/Marine Invertebrate Life 

Cycle (OPPTS 850.1350). Although an early life stage estuarine/marine fish study was not 

submitted as is required for a new chemical registration, sufficient data based on freshwater fish 

provided the basis to make a risk determination to this taxon. As such, an early life stage 
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estuarine/marine fish study is not considered a data gap. An area of considerable uncertainty for 

this assessment surrounds the potential chronic risk to birds. Current data on mallard duck were 

inadequate to derive a definitive NOAEC or make a definitive determination of risk. A second 

avian reproduction study on mallard duck would reduce uncertainty and obviate the need to 

presume risk to this taxon. The adequacy of data for making risk determinations is discussed in 

the context of all lines of evidence in the Risk Characterization. 

 

 There were no environmental fate data gaps identified, however there is considerable 

uncertainty regarding the characterization and quantification of the degradation of indaziflam 

and its transformation products. Degradation quantification was confounded by reported large 

amounts of un-extracted material in the degradation studies conducted in soil and aquatic 

systems. To address this uncertainty estimated environmental concentrations (EECs) were 

completed using two sets of environmental half-lives: 1) high-end conservative estimates which 

were completed using half-lives that included un-extracted residues and 2) the low-end estimates 

based on half-lives that excluded un-extracted residues. It is uncertain whether the un-extracted 

residues were parent (indaziflam), degradate residues, or bound residues that are no longer 

biologically available. 

 Concentrations of indaziflam and its major transformation products were quantitatively 

reported in all field studies when detected between the LOD (0.3 ng·g-1) and the LOQ (1.5 ng·g1

). Detections below the LOQ are not well characterized because there is a large gap between the 

LOD and the LOQ. Therefore, the analytical method may have been too insensitive to 

accurately describe the leaching potential of indaziflam and its major transformation products. 

Replicate values below the LOQ were assumed at 1⁄2(LOQ + LOD) for calculations of dissipation 

half-lives. 

 The high mobility and persistence of the degradates, and data from field studies indicate 

that degradates of indaziflam, particularly FDAT, are likely to leach to ground water. FDAT was 

detected at deeper depths in the field studies compared to the other degradates, and is expected to 

be highly mobile. A prospective ground water study (PGW) would help to characterize potential 

contamination associated with labeled use of indaziflam. 
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Table of Contents

1. Executive Summary ...........................................................................................................................2

1.1. Nature of Chemical Stressor........................................................................................................2 

1.2. Potential Risks to Non-target Organisms ....................................................................................3 

1.3. Conclusions - Exposure Characterization....................................................................................5 

1.4. Conclusions - Effects Characterization .......................................................................................6 

1.5. Uncertainties and Data Gaps .......................................................................................................7 

2. Problem Formulation ....................................................................................................................11

2.1. Nature of Regulatory Action .....................................................................................................11 

2.2. Stressor Source and Distribution ...............................................................................................11 

2.2.1. Nature of Chemical Stressor ...............................................................................................11 

2.2.2. Overview of Pesticide Usage ..............................................................................................12 

2.3. Receptors .................................................................................................................................14 

2.3.1. Aquatic and Terrestrial Effects ...........................................................................................14 

2.3.2. Ecosystems Potentially at Risk ...........................................................................................15 

2.4. Assessment Endpoints ...............................................................................................................15 

2.5. Conceptual Model.....................................................................................................................15 

2.5.1. Risk Hypotheses..................................................................................................................16 

2.5.2. Conceptual Diagram ...........................................................................................................16 

2.6. Analysis Plan ............................................................................................................................18 

2.6.1. Preliminary Identification of Data Gaps and Uncertainties ................................................18 

2.6.2. Evaluation of Multiple Active Ingredients and Mixtures....................................................19 

2.6.3. Measures of Exposure.........................................................................................................20 

2.6.4. Measures of Effect ..............................................................................................................21 

2.6.5. Integration of Exposure and Effects....................................................................................22 

3. Analysis ...........................................................................................................................................23

3.1. Use Characterization..................................................................................................................23 

3.2. Exposure Characterization.........................................................................................................26 

3.2.1. Environmental Fate and Transport Characterization ..........................................................26 

3.2.2. Measures of Aquatic Exposure ...........................................................................................35 

3.2.3. Measures of Terrestrial Exposure .......................................................................................42 

3.3. Ecological Effects Characterization ..........................................................................................46 

3.3.1. Aquatic Toxicity Assessment..............................................................................................47 

3.3.2 Terrestrial Effects Characterization ....................................................................................59 

4. Risk Characterization......................................................................................................................67

4.1. Risk Estimation .........................................................................................................................67 

4.1.1. Aquatic Organisms..............................................................................................................68 

4.1.2. Terrestrial Organisms..........................................................................................................72 

4.2. Risk Description ........................................................................................................................76 

4.2.1 Exposure to Aquatic Organisms ......................................................................................... 77 

4.2.2 Risks to Aquatic Animals ...................................................................................................78 

4.2.3 Risks to Aquatic Plants .......................................................................................................80 

4.2.4. Risks to Mammals...............................................................................................................81 

4.2.5. Risk to Birds .......................................................................................................................82 

4.2.6. Risk to Terrestrial Invertebrates..........................................................................................84 

4.2.7. Risk to Terrestrial & Semi-Aquatic Plants..........................................................................85 

4.3. Uncertainties and Data Gaps .....................................................................................................88 

4.3.1. Aquatic Exposure................................................................................................................88 
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4.3.2. Effects Uncertainties...........................................................................................................90 

4.4. Addressing Risk Hypotheses.....................................................................................................92 

5. Federally Threatened and Endangered (Listed) Species Concerns.............................................92

5.1. Action Area ...............................................................................................................................93 

5.2. Taxonomic Groups Potentially at Risk......................................................................................93 

5.2.1. Probit Dose-Response Analysis.......................................................................................... 95 

5.2.2. Listed Species Occurrence Associated with Indaziflam Use..............................................96 

6. References.........................................................................................................................................98

6.1. Submitted Product Chemistry and Environmental Fate Studies..............................................100 

6.2. Submitted Ecotoxicity Studies.................................................................................................102 

Appendix A. Chemical Names, Structures, and Maximum Reported Amounts of Indaziflam and Its 

Degradates. ..............................................................................................................................................108

Appendix B. Catalog of Submitted Ecological Effects Studies for Indaziflam................................. 122

Appendix C. Summaries of Ecological Effects Studies Submitted for Indaziflam ..........................127

Appendix D. Catalogue of Submitted Environmental Fate Studies for Indaziflam. ....................... 191

Appendix E. Product Chemistry and Environmental Fate Summary of Indaziflam ......................195

Appendix F. Residential Modeling Approach .....................................................................................221

Appendix G. Scenario Selection and Rationale...................................................................................227

Appendix H. Aquatic Model Input/Output Data. ...............................................................................234

Appendix I. Example T-REX Output for Indaziflam.........................................................................238

Appendix J. Example Terrplant (v. 1.2.1) Input and Output for Indaziflam ..................................239

Appendix K. Earthworm Fugacity.......................................................................................................240

Appendix L. LOCATES Output of Listed Species. ............................................................................244
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2. Problem Formulation 

 The purpose of problem formulation is to provide the foundation for the environmental 

fate and ecological risk assessment for the registration of the new chemical indaziflam (also 

known as BCS AA10717; N-[(1R,2S)-2,3-dihydro-2,6-dimethyl-1H-inden-1-yl]-6-[(1RS)-1-

fluoroethyl]-1,3,5-triazine-2,4-diamine; CAS#: 950782-86-2; PC code: 080818). The problem 

formulation sets the objectives for the risk assessment, evaluates the nature of the problem, and 

provides a plan for analyzing the data and characterizing the risk associated with the proposed 

use of indaziflam (USEPA, 1998). 

2.1. Nature of Regulatory Action 

 The U.S. Environmental Protection Agency (EPA or the Agency) is required under the 

Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) to ensure that the newly proposed 

use of indaziflam as an herbicide does not have the potential to cause unreasonable adverse 

effects to the environment. In addition to non-target animals and plants, potential effects to 

listed species (i.e., species on the Federal list of endangered and threatened wildlife and plants) 

and their designated critical habitat are also considered under the Endangered Species Act (ESA) 

in order to ensure that the registration of indaziflam is not likely to jeopardize the continued 

existence of such listed species or adversely modify their critical habitat. In order to meet the 

requirements of FIFRA and the ESA, this assessment follows EPA guidance on conducting 

ecological risk assessments (USEPA, 1998) and Office of Pesticide Program’s Overview 

Document, which contains guidance for assessing pesticide risks to non-target and listed 

organisms (USEPA, 2004). 

 The end result of the EPA pesticide registration process (i.e., the FIFRA regulatory 

action) is an approved product label. The label is a legal document that stipulates how and where 

a given pesticide may be used. Product labels (also known as end-use labels) describe the 

formulation type (e.g., liquid or granular), acceptable methods of application, approved use sites, 

and any restrictions on how applications may be conducted. Therefore, the use, or potential use, 

described by the pesticide’s labels is considered “the action” being assessed. This assessment 

was prepared to support the new chemical registration of indaziflam. 

2.2. Stressor Source and Distribution 

 2.2.1. Nature of Chemical Stressor 

 Indaziflam (BCS-AA10717), N-[(1R,2S)-2,3-dihydro-2,6-dimethyl-1H-inden-1-yl]-6-

[(1RS)-1-fluoroethyl]-1,3,5-triazine-2,4-diamine; CAS#: 950782-86-2; PC code: 080818) is an 

fluoroalkyltriazine herbicide for selective pre-emergence and post-emergence control of many 

annual grasses and broadleaf weeds including crabgrass, goose grass, annual bluegrass, and 

annual sedges in residential turf, ornamentals, hardscapes, golf courses, ball parks, commercial 
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forests, Christmas tree farms, citrus fruit, stone fruit, pome fruit, grapes, tree nuts, pistachios, and 

olives. BCS-AA10717 controls weeds by inhibiting cellulose biosynthesis (CB Inhibitor) and 

subsequently affecting seedling emergence and root development. In some cases, necrosis or 

yellowing may be observed if the herbicide is applied to herbaceous tissue such as leaves and 

green stems. 

 Indaziflam belongs to the chemical class known as fluoroalkyltriazines which are part of 

the broader group of triazine herbicides. It inhibits cell wall biosynthesis and acts on 

meristematic cell growth (CB inhibitor). Indaziflam is a persistent herbicide with residual control 

that affects germinating weed seeds. 

Major degradates of indaziflam (constituting greater than 10% of the applied radiation 

from environmental fate studies, or of toxicological concern) include triazine indanone, FDAT, 

indaziflam-carboxylic acid, indaziflam-olefin, indaziflam-hydroxyethyl, fluoroethyltriazinanedione, and carbon dioxide (chemical names, chemical structures, and data on the 

formation of these degradates are provided in Appendix A.). Indaziflam-hydroxyethyl and 

indaziflam-olefin were included as residues of concern in the aquatic exposure modeling. The 

most sensitive toxicity data for aquatic vascular and nonvascular plants show that indaziflamolefin and indaziflam-hydroxyethyl are of equal toxicity or are within an order of magnitude of 

toxicity lower than that of the parent indaziflam. These two compounds are photolytic products 

that only formed in the aqueous photolysis study (MRID 47443208). These photodegradates are 

an exposure concern where indaziflam quickly reaches shallow relatively clear water bodies. 

 2.2.2. Overview of Pesticide Usage 

 Eleven end-use formulations of indaziflam are proposed for registration in the United 

States that include the following: 

1. BCS AA10717 20 WSP: 20% indaziflam; used on athletic turf (sports turf), golf courses 

(prohibited on greens), sod farms, ornamentals, nurseries, Christmas trees, landscape 

plantings, forestry, and non-crop areas. 

2. Esplanade F: 19.05% indaziflam; used on forested areas. 

3. Esplanade 200 SC: 19.05% indaziflam; used on non-crop areas, railroad and rail yards, 

managed roadsides, established ornamental and perennial plantings, fence rows, utilities, 

hardscapes and other industrial, municipal and government sites, and under asphalt or 

concrete as part of site preparation. 

4. Lawn 3FL Herbicide (Ready-to-Use): 0.0031% indaziflam; 0.309% 2,4-D, 

dimethylaminie salt; 0.034% dicamba, potassium salt; 0.073% mecoprop-p, potassium 

salt; used on established southern home lawns. 

5. Lawn 3FL Herbicide Granule: 0.05% indaziflam; 0.11% dicamba acid; 0.06% 

penoxsulam; used on established southern home lawns. 

6. Lawn 3FL Herbicide Concentrate (Ready-to-Spray): 0.25% indaziflam, 4.89% 2,4-D, 

dimethylaminie salt, 0.54% dicamba, potassium salt, 1.15% mecoprop-p, potassium salt; 

used on established southern home lawns, ornamentals, and hardscapes. 
-Page 13 of 292- 

7. BCS-AA10717 0.0284% Plus Turf Fertilizer (Granule): 0.0284% indaziflam; used on 

athletic turf (sports turf), golf courses (prohibited on greens), and sod farms 

8. BCS-AA10717 0.0213% Plus Turf Fertilizer (Granule): 0.0213% indaziflam; used on 

athletic turf (sports turf), golf courses (prohibited on greens), and sod farms 

9. BCS-AA10717 0.0142% Plus Turf Fertilizer (Granule): 0.0213% indaziflam; used on 

athletic turf (sports turf), golf courses (prohibited on greens), and sod farms 

10. Indaziflam 200 SC Herbicide: 19.05% indaziflam; used on citrus fruit, stone fruit, pome 

fruit, grapes, tree nuts, pistachios, and olives. 

11. Indaziflam 500 SC Herbicide: 45.05% indaziflam; used on citrus fruit, stone fruit, pome 

fruit, grapes, tree nuts, pistachios, and olives. 

 Indaziflam is formulated as water soluble packets (WSP; (BCS-AA10717 20WSP) a 

flowable product (Esplanade F), three suspension concentrate products (Esplanade 200SC, 

Indaziflam 200SC, and Indaziflam 500 SC) three herbicide plus fertilizer formulations (BCSAA10717 0.0284% Plus Turf Fertilizer, BCS-AA10717 0.0213% Plus Turf Fertilizer, and BCSAA10717 0.0142% Plus Turf Fertilizer), a ready-to-use (RTU) multi-herbicide formulation 

(Lawn 3FL Herbicide Ready-to-Use), a ready-to-spray (RTS) multi-herbicide formulation (Lawn 

3FL Herbicide Concentrate) flowable liquid (FL), and a spreadable multi-herbicide granular 

formulation (Lawn 3FL Herbicide Granule). 

 BCS-AA10717 20WSP, Esplanade 200SC, Indaziflam 200SC, and Indaziflam 500 SC 

end-use products are applied by ground broadcast spray methods. BCS-AA10717 0.0284% Plus 

Turf Fertilizer, BCS-AA10717 0.0213% Plus Turf Fertilizer, BCS-AA10717 0.0142% Plus Turf 

Fertilizer, and Lawn 3FL Herbicide Granule end-use products are dry granular formulations and 

are applied by ground broadcast application methods (e.g., spreader). Lawn 3FL Herbicide 

Ready-to-Use end-use product will be available for home use in a pre-packaged battery-operated 

trigger sprayer, which is applied directly from the container using a battery-operated trigger 

sprayer. Lawn 3FL Herbicide Concentrate end-use product is available as a sprayer pump, hoseend sprayer concentrate, or as a pre-packaged hose-end ready-to-spray product that is applied by 

ground broadcast applications. Esplanade F, used on forested areas, is the only end-use product 

of indaziflam that is proposed for both aerial and ground applications. 

 The proposed maximum annual application rates on non-agricultural areas for indaziflam 

formulations with a single active ingredient include 0.089 lbs a.i./A/yr (non-crop areas), 0.10 lbs 

a.i./A/yr (turf), and 0.125 lbs a.i./A/yr (forested areas). The end-use formulations with multiple 

active ingredients (2,4-D, mecoprop-p, dicamba, and penoxsulam) intended for non-agricultural 

areas, i.e., Lawn 3FL ready-to-use and concentrate (2,4-D, mecoprop-p, and dicamba), and 

granule products (dicamba and penoxsulam). These three products have a proposed maximum 

annual application rate of 0.094 lbs a.i./A/yr for home lawn, ornamentals, and hardscapes uses. 

Indaziflam 200SC, and Indaziflam 500 SC have a proposed maximum annual application rate of 

0.134 lbs a.i./A/yr for selected agricultural crop uses (citrus fruit, stone fruit, pome fruit, grapes, 

tree nuts, pistachios, and olives). Application rates for each use are summarized in Table 3.1. 

Usage data are not available for indaziflam because it is a new active ingredient proposed for use 

in the United States. 
-Page 14 of 292- 

2.3. Receptors 

 2.3.1. Aquatic and Terrestrial Effects 

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

Consistent with the process described in the Overview Document (USEPA, 2004), this risk 

assessment uses a surrogate species approach in its evaluation of indaziflam. Toxicity data 

generated using surrogate test species, which are intended to be representative of broad 

taxonomic groups, are used to extrapolate to potential effects on a variety of species (receptors) 

included under these broader taxonomic groupings. Table 2.1 provides the taxonomic groups 

and surrogate species tested to evaluate the potential ecological effects of indaziflam to these 

non-target taxonomic groups. Within each of these very broad taxonomic groups, a measure of 

effect is selected from the available test data. 

Table 2.1. Taxonomic Groups and Test Species Evaluated for Assessing Potential 

Ecological Effects of indaziflam. 

Taxonomic Group Surrogate Species 

Birds1 Mallard duck (Anas platyrhynchos) 

Bobwhite quail (Colinus virginianus) 

Mammals Wistar rat (Ratus norvegicus) 

Sprague-Dawley rat (R. norvegicus) 

Insects Honey bee (Apis mellifera L.) 

Earthworm (Eisenia fetida andrei) 

Freshwater fish2 Bluegill sunfish (Lepomis macrochirus) 

Rainbow trout (Oncorhynchus mykiss) 

Fathead minnow (Pimephales promelas) 

Freshwater invertebrates Water flea (Daphnia magna) 

Midge (Chironomus riparius) 

Estuarine/marine fish Sheepshead minnow (Cyprinodon variegatus) 

Estuarine/marine invertebrates Mysid (Americamysis bahia) 

Eastern oyster (Crassostrea virginica) 

Amphipid (Leptocheirus plumulosus) 

Terrestrial plants3 Monocots – Crop species, such as corn (Zea mays) 

Dicots – Crop Species, such as soybean (Glycine max)

Aquatic plants and algae Duckweed (Lemna gibba) 

Freshwater Algae (Pseudokirchneriella subcapitata) 

Saltwater Diatom (Skeletonema costatum) 

Freshwater Diatom (Navicula pelliculosa) 

Freshwater Cyanobacteria (Anabaena flos-aquae) 1

 Birds represent surrogates for terrestrial-phase amphibians and reptiles. 2

 Freshwater fish may be surrogates for aquatic-phase amphibians. 3

 Four species of two families of monocots, of which one is corn; six species of at least four dicot families, of which one is soybeans.
-Page 15 of 292- 

 2.3.2. Ecosystems Potentially at Risk 

The ecosystems potentially at risk are often extensive in scope; therefore, it may not be 

possible to identify specific ecosystems during the development of a nation-wide ecological risk 

assessment. However, in general terms, terrestrial ecosystems potentially at risk could include 

the treated field and immediately adjacent areas 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. 

Aquatic ecosystems potentially at risk include water bodies adjacent to, or down stream 

from, the treated site and might include impounded bodies such as ponds, lakes and reservoirs, or 

flowing waterways such as streams or rivers including all adjacent off-channel habitats that are 

permanently or intermittently connected to flowing waters. For uses in coastal areas, aquatic 

habitat also includes marine ecosystems, including estuaries, embayment’s, and near shore 

environments. 

2.4. Assessment Endpoints 

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

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

characteristics (USEPA, 1998). For indaziflam, the ecological entities include the following: 

birds, amphibians, reptiles, mammals, freshwater fish and invertebrates, estuarine/marine fish 

and invertebrates, non-target terrestrial plants, insects, and aquatic vascular and non-vascular 

plants. The attributes for each of these entities may include growth, survival, and reproduction 

(Table 2.2 in Section 2.6.2 for further discussion). 

 2.5. Conceptual Model 

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

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

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

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

and a feasible route of exposure. 

 The conceptual model is intended to provide a written description and visual 

representation of the predicted relationships between indaziflam, potential routes of exposure, 

and the predicted effects for the assessment endpoints. The conceptual model consists of two 

major components: risk hypotheses and a conceptual diagram (USEPA, 1998). 
-Page 16 of 292- 

 2.5.1. Risk Hypotheses 

 For indaziflam, the following ecological risk hypotheses are being employed for this 

baseline risk assessment: 

 

Given the uses of indaziflam and its environmental fate properties, there is a likelihood of 

exposure to non-target terrestrial and aquatic organisms. 

When used in accordance with the label, indaziflam results in potential adverse effects 

upon the survival, growth, and reproduction of non-target terrestrial and aquatic 

organisms. 

 2.5.2. Conceptual Diagram 

 The conceptual model is a graphic representation of the predicted relationships between 

the ecological entities, both listed (threatened and endangered) and non-listed species, and the 

stressors to which they may be exposed. The conceptual model specifies the potential routes of 

exposure, biological receptor types, and effects endpoints of potential concern. Indaziflam is 

applied to crop and non-crop areas and given the persistence and mobility of indaziflam and its 

degradates, these chemicals are expected to move off-site via spraydrift and run-off. Table 2.1 

depicts the stressors, exposure pathways, and potential effects to terrestrial organisms from 

proposed uses of indaziflam as a pre-emergent and post-emergent herbicide to control annual 

grasses and broadleaf weeds. Figure 2.2 depicts the stressors, exposure pathways, and potential 

effects to aquatic organisms from proposed uses of indaziflam. Indaziflam and its degradates are 

also expected to leach into ground water which may in turn contribute to exposure of aquatic 

organism in areas where there is interchange of surface and ground water. For both figures, 

dotted lines indicate exposure pathways that have a low likelihood of contributing to ecological 

risk. 

 

 
-Page 17 of 292- 

 

Stressor

Source

Attribute

Change

Indaziflam and Residues of Concern applied to use site

Direct

application Spray drift

Terrestrial 

vertebrates

Terrestrial 

inverts

Individual organisms

Reduced survival

Reduced growth

Reduced reproduction

Food chain

Reduction in prey and food

Modification of PCEs

related to prey availability

Habitat integrity

Reduction in primary productivity

Reduced cover

Community change

Modification of PCEs related

to habitat

Terrestrial plants

grasses/forbs, fruit, seeds 

(trees, shrubs)

Runoff

Terrestrial 

Vertebrates 

Exposure Media 

& Receptors Soil

Ingestion

Ingestion

Ingestion

Dermal uptake/Ingestion

Atmospheric 

transport

Root uptake/contact

Wet/dry deposition

Ingestion

Leaching to

Groundwater Irrigation 

water

Figure 2.1. Conceptual model depicting stressors, exposure pathways, and potential effects 

to terrestrial organisms from the use of indaziflam. 
-Page 18 of 292- 

Stressor

Source

Receptors

Attribute

Change

Indaziflam and Residues of Concern applied to use site

Spray drift

Aquatic animals

Invertebrates 

Vertebrates

Individual organisms

Reduced survival

Reduced growth

Reduced reproduction

Food chain

Reduction in algae and 

vascular plants

Reduction in prey

Modification of PCEs

related to prey availability

Habitat integrity

Reduction in primary productivity

Reduced cover

Community change

Modification of PCEs related to 

habitat

Surface water/

Sediment

Runoff

Aquatic Animals

Invertebrates

Vertebrates

Exposure

Media

Uptake/gills 

or integument

Ingestion Ingestion

Atmospheric 

transport

Wet/dry deposition

Soil Leaching to

Groundwater

Uptake/gills 

or integument

Aquatic Plants

Non-vascular

Vascular

Uptake/cell, 

roots, leaves Riparian plants

terrestrial 

exposure 

pathways see 

Figure 2.1

Figure 2.2. Conceptual model depicting stressors, exposure pathways, and potential effects 

to aquatic organisms from the proposed uses of indaziflam. 

2.6. Analysis Plan 

2.6.1. Preliminary Identification of Data Gaps and Uncertainties 

A catalog of submitted ecological effects studies for indaziflam, its degradates, and 

formulations, along with review classifications (e.g. Acceptable to meet guidelines), can be 

found in Appendix B. For the purposes of this assessment, data gaps refer to the absence of 

required data for a new chemical registration as specified under 40 CFR Part 158; without data or 

evidence to demonstrate otherwise, risk to non-listed and listed species of a taxon is presumed. 

Although an early life stage estuarine/marine fish study was not submitted as is required for a 

new chemical registration, sufficient data based on freshwater fish provided the basis to make a 

risk determination to this taxon. As such, an early life stage estuarine/marine fish study is not 

considered a data gap. An area of considerable uncertainty for this assessment surrounds the 

potential ecological chronic risk to birds. Current data on Mallard duck were inadequate to 

derive a definitive NOAEC or make a definitive determination of risk. A second avian 
-Page 19 of 292- 

reproduction study on mallard duck would reduce uncertainty and obviate the need to assume 

risk to this taxon. The adequacy of data for making risk determinations is discussed in the 

context of all lines of evidence in the Risk Characterization. Complete summaries of all 

submitted effects data are included in Appendix C. 

 

 The following ecological effects data gaps for indaziflam were identified: 

• Estuarine/Marine Invertebrate Life Cycle (850.1350): These data are required because 

the proposed use patterns specific to indaziflam’s registration, terrestrial, forestry, and 

residential outdoor use, indicate indaziflam may enter estuarine/marine environments. 

Acute toxicity data also demonstrate indaziflam to be highly toxic to estuarine/marine 

organisms. 

 No environmental fate data gaps were identified. For the purposes of risk assessment the 

submitted data are adequate. The quality of the submitted data is generally good. A catalog of 

submitted environmental fate studies for indaziflam and its degradates, along with justified 

review classifications, can be found in Appendix D. A complete summary of all submitted 

environmental fate data is included in Appendix E. 

 In addition, the relative persistence and high mobility of the degradates, and data from 

field studies indicate that degradates of indaziflam is likely to leach to ground water, particularly 

the degradate FDAT, as it was detected at deeper depths in the field studies compared to the 

other degradates and is highly mobile. A prospective ground water study (PGW) would help to 

characterize the extent of potential ground water impacts. 

 2.6.2. Evaluation of Multiple Active Ingredients and Mixtures 

The Agency does not routinely include in its risk assessments an evaluation of mixtures 

of active ingredients, either those mixtures of multiple active ingredients in product formulations 

or those in the applicator’s tank. In the case of the product formulations of active ingredients 

(that is, a registered product containing more than one active ingredient), each active ingredient 

is subject to an individual risk assessment for regulatory decision regarding the active ingredient 

on a particular use site. If effects data are available for a formulated product containing more 

than one active ingredient, they may be used qualitatively or quantitatively in accordance with 

the Agency’s Overview Document and the Services’ Evaluation Memorandum (U.S. EPA 2004; 

U.S. FWS/NMFS 2004). 

 Effects data are available for indaziflam’s three product formulations with multiple active 

ingredients: Lawn 3FL Herbicide (Ready-to-Use), MRID 47489402; Lawn 3FL Herbicide 

Concentrate (Ready-to-Spray), MRID 47489302; and Lawn 3FL Herbicide Granule, MRID 

47489202. The first two of these formulations contain the active ingredients 2,4-D, 

dimethylamine salt; dicamba, potassium salt; and mecoprop-p potassium salt. The herbicide 

granule formulation includes dicamba acid and penoxsulum. The available effects data include 

acute oral toxicity studies using the rat, submitted as requirements for the new registrations of 
-Page 20 of 292- 

formulated products. These data indicate that, for acute effects to mammals, indaziflam in 

combination with these other active ingredients is not more toxic than the TGAI alone. This data 

will be used qualitatively in the risk description section of this assessment. 

 2.6.3. Measures of Exposure 

 Measures of exposure are based on terrestrial and aquatic models that estimate 

environmental concentrations of indaziflam using labeled application rates and methods. The 

measure of exposure for aquatic species in water bodies receiving runoff and/or spray drift to 

surface water is a return frequency of 1-in-10 years of the estimated environmental concentration 

(EEC), based on 30 years of simulations. The 1-in-10 year peak concentration is used for 

estimating acute effects to aquatic organisms (plants and animals); the 1-in-10 year 21-day mean 

concentration is used for assessing aquatic invertebrate chronic exposure; and the 1-in-10 year 

60-day mean concentration is used for assessing chronic exposure for fish (and aquatic-phase 

amphibians for which fish serve as surrogates). The exposure to aquatic species from sediment 

concentrations in water bodies was determined to be of concern after a review of the appropriate 

fate and effects data; pore water EECs were calculated for maximum use patterns. The measure 

of exposure for aquatic species in water bodies receiving base flow from ground water leachate 

originating at the site of application is the 90-day mean high concentration. The terrestrial 

measure of exposure for vertebrate and invertebrate animals is the upper 90th percentile 

concentration normalized for application rates on various dietary items. 

 Exposure for terrestrial plants inhabiting dry and semi-aquatic areas (i.e., low-lying wet 

areas that may dry up at times throughout the year) is based on the following: 

(1) the pesticide's water solubility and the amount of pesticide present on the soil surface 

and its top one centimeter, 

(2) potential "sheet runoff" (one treated acre to an adjacent acre) for dry areas, 

(3) potential "channel runoff" (10 acres to a distant low-lying acre) for semi-aquatic or 

wetland areas, 

(4) fractional runoff values of 0.01, 0.02, and 0.05 for pesticide water solubilities of <10, 

10-100, and <100 ppm, respectively, and 

(5) an assumption of 1% spray drift for ground application and 5% for aerial, airblast, 

forced air, and spray chemigation applications. 

Spray drift exposure to terrestrial plants is characterized further in the Risk Description if 

terrestrial plant RQs exceed the risk to plants LOC. Downwind spraydrift buffers are evaluated 

to determine the distance from application site required to dissipate spray drift to the no effect 

and EC25 levels where listed and non-listed species RQ values are below the LOC, respectively. 

 

 The registrant has provided a suite of studies pertinent to most OPPTS 835 guidelines, 

pursuant to 40 CFR part 158 (Data Requirements for Pesticides), which provides environmental 

fate data for these measures of exposure. 
-Page 21 of 292- 

 2.6.4. Measures of Effect 

Measures of effect are obtained from a suite of registrant-submitted guideline studies that 

were conducted with a limited number of surrogate test species (Table 2.1). No additional 

ecotoxicity data on indaziflam were located, based on a November 2009 query of the open 

literature in the ECOTOX database (USEPA, 2009a). 

 The acute measures of effect used in this baseline assessment are the LD50 (median Lethal 

Dose), LC50 (median Lethal Concentration) or EC50 (median Effects Concentration). These are 

measures of acute toxicity which result in 50% of the respective effect in tested organisms. The 

endpoints for chronic measures of exposure are the no observed adverse effect concentration 

(NOAEC) and the no observed adverse effect level (NOAEL). Toxicity studies were submitted 

for freshwater fish and invertebrates, estuarine/marine fish and invertebrates, aquatic plants, 

birds, mammals, bees, and other terrestrial invertebrates. The endpoints used for risk 

characterization are derived from studies which underwent review and were classified as 

“acceptable” (conducted under guideline conditions and considered to be scientifically valid) or 

“supplemental” (conditions deviated from guidelines but the results are considered to be 

scientifically valid). 

 Table 2.2 lists the measures of environmental exposure and ecological effects used to 

assess the potential risks of indaziflam to non-target organisms. The methods used to assess the 

risk are consistent with those outlined in the document “Overview of the Ecological Risk 

Assessment Process in the Office of Pesticide Programs” (USEPA, 2004). 
-Page 22 of 292- 

Table 2.2. Measures of Exposure and Measures of Effect Used in Assessing Potential Risks 

Associated with the Proposed Uses of Indaziflam. 

Assessment Endpoint Surrogate Species and Measures of 

Ecological Effect1 Measures of Exposure 

Survival 

Lowest acute LD50 (single oral dose test) 

and LC50 (subacute dietary test) Birds2

Reproduction 

and Growth 

Lowest NOAEC 

 (21-week reproduction test) 

Survival Lowest acute LD50 (single oral dose test)

Mammals Reproduction 

and Growth 

Lowest NOAEC 

(2-generation reproduction test) 

Upper-bound residues on 

food items 

Survival Lowest tested LC50 or EC50

(acute toxicity test) 

Peak EECs4 

Aquatic Animals 

(Freshwater fish and 

inverts and 

estuarine/marine inverts)3 

Reproduction 

and Growth 

Lowest NOAEC (early life-stage or full 

life-cycle tests) 

21-day EECs for invertebrates 

and 60-day EECs for fish4 

Terrestrial plants5 Survival and 

growth 

Lowest EC25 (for non-listed plants) and 

corresponding NOAEC (for listed 

plants) 

(endpoints derived for monocots and 

dicots from seedling emergence and 

vegetative vigor studies) 

Estimates of runoff and spray 

drift to non-target areas 

Insects6 Survival (not 

quantitatively 

assessed) 

Lowest honeybee LD50 (acute contact 

test)

Lowest Earthworm LC50 

Maximum application rate for 

honeybees and estimates of 

soil concentrations for 

earthworms 

Aquatic plants (vascular 

and non-vascular) 

Survival and 

growth 

Lowest EC25 (for non-listed plants) and 

corresponding NOAEC or EC05 (for 

listed plants)

Peak EECs4

 

1 The most sensitive species tested within taxonomic groups is used for baseline risk assessments. 

2 Birds represent surrogates for terrestrial-phase amphibians and reptiles. 3 Freshwater fish represent surrogates for aquatic-phase amphibians. 4 Aquatic EECs are based on modeling described in Section 3.2.2.1. 5 Four species of two families of monocots - one is corn, six species of at least four dicot families, of which one is soybeans. 6

 Risk to terrestrial invertebrates from indaziflam use is not evaluated, rather the potential hazard to honey bees and earthworms (i.e. the available 

data) are qualitatively assessed. 

 2.6.5. Integration of Exposure and Effects 

The exposure and toxicity data are integrated in order to evaluate the risks of adverse 

ecological effects on non-target species. For the baseline risk assessment of indaziflam, the 

deterministic risk quotient (RQ) method is used to compare estimated exposure concentrations 

and measured toxicity values. The RQ method involves dividing point estimates of 

environmental concentrations by acute and chronic toxicity values. The resulting unitless RQs 

are then compared to the Agency’s Levels of Concern (LOCs) (USEPA, 2004) (Table 2.3). 

These criteria are used to indicate when applications of indaziflam, as directed on the label, have 

the potential to cause adverse effects to listed and non-listed non-target organisms. 
-Page 23 of 292- 

Table 2.3. Agency Risk Quotient (RQ) Metrics and Levels of Concern (LOC) Per Risk 

Class. 

RISK CLASS RISK DESCRIPTION RQ LOC 

Aquatic Animals (fish and invertebrates)

Acute Potential for effects to non-listed animals from acute 

exposures 

Peak EEC/LC501 0.5 

Acute 

Restricted Use 

Potential for effects to animals from acute exposures 

Risks may be mitigated through restricted use classification Peak EEC/LC501

 0.1 

Acute Listed 

Species 

Listed species may be potentially affected by acute 

exposures 

Peak EEC/LC501

 0.05 

60-day EEC/NOAEC 

(fish) Chronic Potential for effects to non-listed and listed animals from 

chronic exposures 21-day EEC/NOAEC 

(invertebrates) 

1 

Aquatic Plants 

Non-Listed Potential for effects to non-listed plants from exposures Peak EEC/LC501 1 

Listed Potential for effects to listed plants from exposures Peak EEC/NOAEC 1 

Terrestrial Animals (mammals and birds) 

EEC2/LC50 (Dietary) Acute Potential for effects to non-listed animals from acute 

exposures EEC/LD50 (Dose) 

0.5 

EEC2 Acute /LC50 (Dietary) 

Restricted Use 

Potential for effects to animals from acute exposures 

Risks may be mitigated through restricted use classification EEC/LD50 (Dose) 

0.2 

EEC2 Acute Listed /LC50 (Dietary) 

Species 

Listed species may be potentially affected by acute 

exposures EEC/LD50 (Dose) 

0.1 

Chronic Potential for effects to non-listed and listed animals from 

chronic exposures EEC 2

/NOAEC 1 

Terrestrial and Semi-Aquatic Plants 

Non-Listed Potential for effects to non-target, non-listed plants from 

exposures 

EEC/ EC25 1 

EEC/ NOAEC Listed Plant Potential for effects to non-target, listed plants from 

exposures EEC/ EC05

1 

1 LC50 or EC50. 2

 Based on upper bound Kenega values for foliar exposure.

3. Analysis 

 3.1. Use Characterization 

 Indaziflam is proposed for use as a selective pre-emergent weed control in perennial tree 

and vine crops (citrus, stone fruit, pome fruit1

, grapes, tree nuts, pistachios, olives), pre-emergent 

and post-emergent weed control on athletic turf (golf courses, athletic fields, parks, recreation 

areas, and sod farms), home lawns, ornamentals and hardscapes (sidewalks, driveways), 

 

1

 Pome fruits are defined as apples, pears, quinces, and Asian pears. 
-Page 24 of 292- 

commercial forests, Christmas tree farms, and other non-crop areas (railroad and rail yards, 

managed roadsides, fence rows, utilities, other industrial, municipal, and government sites). 

End-use products assessed in this document are formulated as a dry granules (Lawn 3FL 

Herbicide Granule), water soluble packets (BCS-AA10717 20WSP), flowable liquid concentrate 

(Lawn 3FL Herbicide Concentrate), suspension concentrate (Indaziflam 500 SC Herbicide, 

Indaziflam 200 SC Herbicide, Esplanade 200 SC, Esplanade F), three granular herbicide plus 

fertilizer products (BCS-AA10717 0.0284% Plus Turf Fertilizer, BCS-AA10717 0.0213% Plus 

Turf Fertilizer, BCS-AA10717 0.0142% Plus Turf Fertilizer), and a multi-a.i. ready-to-use spray 

(Lawn 3FL Ready-to-Use Spray). 

 Proposed maximum application rates and use patterns listed by use according to the 

proposed labels are provided in Table 3.1. Indaziflam 200SC and Indaziflam 500SC have higher 

single maximum application rates for fine textured soils than for coarse textured soils (0.085 lbs 

a.i/A and 0.065 lbs a.i./A, respectively). The proposed fine textured soil application rate (0.085 

lbs a.i./A) was used for aquatic exposure modeling in this assessment. For the purposes of this 

assessment, EECs are based on maximum proposed label rates for six use categories: food 

(citrus, stone fruit, tree nuts, and vine crops), turf (golf courses, athletic fields, and sod farms), 

residential lawns, ornamentals and hardscapes, forestry, and other non-crop areas (railroad and 

rail yards, managed roadsides, fence rows, utilities, other industrial, municipal, and government 

sites). 

 Broadcast applications are proposed on five of the formulated product labels. Four of the 

five labels proposing ground applications explicitly discuss spray drift management (i.e. Spray 

Drift Management Section on label) and direct the user to not apply when wind speeds are 

greater than 10 miles per hour (mph), during temperature inversions, or when fog is present. The 

four labels are Esplanade F, Esplanade 200 SC, Indaziflam 200 SC, and Indaziflam 500 SC; 

BCS-AA10717 20 WSP does not include language on spray drift management. The labels also 

advise that the formulated products should only be applied when the potential for drift to 

adjacent sensitive areas (e.g. bodies of water) is minimal (e.g. wind blowing in opposite 

direction). The label for proposed aerial spraying, Esplanade F, includes language that directs 

the user to apply large droplets (e.g. 150-200 microns) under low spray pressure. 

 The persistence of indaziflam suggests that there would be enough carryover of 

phytotoxic resisdues to subsequent sensitive rotational crops. However, the proposed labels 

restrict the use of indaziflam on crops not contained on the label, including the planting of 

roational crops within a 24 month period after applying indaziflam. Specifically, the label states 

“Do not rotate to any crops not listed on this label within 24 months after the last application.” 

These statements restricting the use of indaziflam on rotational crops prevent injury and damage 

to crops not included on the labels for indaziflam.
-Page 25 of 292- 

Table 3.1. Proposed Maximum Use Patterns of Indaziflam.

Use 

Category Crop/Use Formulated Product 

Formulated 

Product 

Application 

Rate 

Maximum 

Application 

Rate 

(lbs a.i./A) 

Maximum 

Number of 

Applications 

(interval) 

Maximum 

Yearly 

Applicatio

n 

(lbs 

a.i./A/yr) 

Method of 

Application 

Citrus & Pome 

Fruit†

Indaziflam 

500 SC 

2.6 fl oz/A – fine 

textured soils 

0.085 lbs 

a.i./A 

2‡ 

(30days, 90days 

for FL apps) 

0.134 lbs 

a.i./A/yr 

Ground Spray 

(broadcast or 

banded)

Stone Fruit Indaziflam 

500 SC 

2.6 fl oz/A – fine 

textured soils 

0.085 lbs 

a.i./A 

2‡ 

(30days, 90days 

for FL apps) 

0.134 lbs 

a.i./A/yr 

Ground Spray 

(broadcast or 

banded)

Tree Nuts Indaziflam 

500 SC 

2.6 fl oz/A – fine 

textured soils 

0.085 lbs 

a.i./A 

2‡ 

(30days, 90days 

for FL apps)

0.134 lbs 

a.i./A/yr 

Ground Spray 

(broadcast or 

banded)

Food 

Vine Crops 

(Grapes and 

Olives) 

Indaziflam 

500 SC 

2.6 fl oz/A – fine 

textured soils 

0.085 lbs 

a.i./A 

2‡ 

(30days, 90days 

for FL apps)

0.134 lbs 

a.i./A/yr 

Ground Spray 

(broadcast or 

banded)

Turf 

Turf 

(golf courses, 

athletic fields, 

and sod farms) 

BCSAA10717 

0.0213% 

Plus Turf 

Fertilizer 

377 lbs/A 0.080 lbs 

a.i./A 

2‡

(90 days) 

0.1 lbs 

a.i./A/yr 

Ground 

(spreader, 

watered-in) 

Residential 

Lawns 

Residential 

lawns 

Lawn 3FL 

Herbicide 

Concentrate 

6.4 fl oz/1000 ft2 0.047 lbs 

a.i./A 

2 

(2 weeks) 

0.094 lbs 

a.i./A/yr 

Ground Spray 

(hose-end 

sprayer) 

Ornamentals 

Lawn 3FL 

Herbicide 

Concentrate 

12.8 fl oz/1000 

ft2

0.094 lbs 

a.i./A 1 0.094 lbs a.i./A/yr 

Ground Spray 

(hose-end 

sprayer or 

hand pump) Ornamentals 

& 

Hardscapes 

Hardscapes 

Lawn 3FL 

Herbicide 

Concentrate 

12.8 fl oz/1000 

ft2

0.094 lbs 

a.i./A 1 0.094 lbs a.i./A/yr 

Ground Spray 

(hose-end 

sprayer or 

hand pump) 

Other NonCrop Areas†† Esplanade 

200 SC 6.84 fl oz/A/yr 0.089 lbs a.i./A 1 0.089 lbs a.i./A/yr 

Ground Spray 

(broadcast) 

Other Noncrop Areas 

Site 

Preparation 

(under asphalt 

and concrete) 

Esplanade 

200 SC 6.84 fl oz/A/yr 0.089 lbs a.i./A 1 0.089 lbs a.i./A/yr 

Ground Spray 

(broadcast) 

Forestry Forested Areas Esplanade F 9.58 fl oz/A/yr 0.125 lbs 

a.i./A 

1 0.125 lbs 

a.i./A/yr 

Aerial or 

Ground Spray 

(broadcast or 

banded) † Pome fruit include apples, pears, quinces, loquats, mayhaws, and Asian pears. 

‡ The label permits a single application at the maximum application rate and a second application at a reduced rate (e.g., applications of indaziflam for food 

uses: 0.085 lbs a.i./A is the maximum application rate with a permitted second application at a maximum rate of 0.05 lbs a.i./A, equaling an annual 

maximum rate of 0.134 lbs a.i./A). For turf uses a single maximum application rate of 0.08 lbs a.i./A is permitted with a second application of 0.02 lbs 

a.i./A. 

†† Other non-crop areas are, as defined by the proposed label: Railroad and Rail Yards, Managed Roadsides, Fence Rows, Utilities, Other Industrial, 

Municipal, and Government Sites. 

 
-Page 26 of 292- 

3.2. Exposure Characterization 

3.2.1. Environmental Fate and Transport Characterization 

 The general physical/chemical properties of indaziflam are summarized in Table 3.2. 

Environmental fate and transport properties of indaziflam are characterized in further detail in 

the following sections. Our understanding of these properties is limited by the data set available. 

Many of the chemical properties and environmental fate parameters of indaziflam listed in Table 

3.3 are based on single, supplemental studies, summaries of which are in Appendix B. 

Table 3.2 General Physical and Chemical Properties of Indaziflam 

Parameter Value Reference

PC code 080818 

CAS No. 730979-19-8 

Structure (Isomer A) 

N

N

N

3CH

CH3

N

H

NH2

CH3 F

Structure (Isomer B) 

Chemical name 

(IUPAC) 

N-[(1R,2S)-2,3-dihydro-2,6-dimethyl-1H-inden-1-yl]-6-

[(1RS)-1-fluoroethyl]-1,3,5-triazine-2,4-diamine 

Common name Indaziflam (BCS AA10717) 

Chemical formula C16H20FN5 

Molecular weight 301.36 g/mol 47443202 

Water solubility (20 °C) Isomer A Isomer B 

pH 4: 4.4 mg/L 

pH 7: 2.2 mg/L 

pH 9: 2.2 mg/L 

pH 4: 1.7 mg/L 

pH 7: 1.2 mg/L 

pH 9: 1.2 mg/L 

47443202 

Isomer A 6.8 x10-8 Vapor pressure (25 °C) Pa (5.1e-10 mmHg) 

Isomer B 1.1 x10-8 Pa (8.25e-11 mmHg) 

47443202 

Henry's law constant 2.62 x10-10 atm-m3

/mol Calculated, Episuite 

v4.0 

Log KOW (pH 7, 40 °C) 2.8 47443202 

Dissociation Constant Isomer A 3.5 

(pKa) Isomer B 3.6 

47443202 
-Page 27 of 292- 

 Indaziflam is expected to be moderately mobile in soil, moderately persistent to persistent 

in aerobic soil, persistent in anaerobic soil, and persistent in aerobic and anaerobic aquatic 

environments. Indaziflam is a mixture of two diastereoisomers with a ratio of isomer A to 

isomer B as high as 19:1. Both active isomers (N-[(1R,2S)-2,6-dimethyl-2,3-dihydro-1H-inden1-yl]-6-[(1R)-1-fluoroethyl]-1,3,5-triazine-2,4-diamine and N-[(1R,2S)-2,6-dimethyl-2,3-

dihydro-1H-inden-1-yl]-6-[(1S)-1-fluoroethyl]-1,3,5-triazine-2,4-diamine) have similar 

environmental fate characteristics (aerobic soil metabolism half-lives in two soil types reported 

at 45 and 65 days isomer A, and 55 and 89 days isomer B; MRID 47443215). Based on the 

chemical structure of the compound and location of the chiral center, it is expected that the two 

isomers will behave similarly in the environment and have similar toxicity. Submitted fate 

studies were completed using isomer A. 

 Indaziflam and its residues of concern (indaziflam-hydroxyethyl and indaziflam-olefin) 

are expected to persist in both the terrestrial and aquatic environments (half-lives > 200 days); 

the compound is stable to hydrolysis but can degrade through aqueous photolysis (half-life < 5 

days). Under aerobic conditions, the compound can be slowly metabolized (half-lives > 150 

days), but it is stable to anaerobic metabolism. Indaziflam is moderately mobile to mobile 

(Koc’s < 1000 mL/g oc) based on the FAO Soil Mobility Classification Guidance (USEPA, 

2006). However, major degradates of indaziflam are more mobile than the parent (Koc for FDAT 

ranged from 10 - 50 mL/g oc). Indaziflam was detected in the submitted terrestrial field 

dissipation studies above the level of quantitation (LOQ) at depths up to 45-60 cm; however the 

majority of detections were restricted to the 0-15 cm range in the soil profile, with a few 

detections above LOQ in the 15-30 cm, and 30-45 cm depth, and below the LOQ at a maximum 

depth of 105-120 cm. Indaziflam-hydroxyethyl was detected in multiple studies in the top 

sampled segment (0-15 cm). Other major degradates of indaziflam, particularly FDAT, were 

detected in deeper segments than the parent; FDAT was detected at a maximum depth of 105-

120 cm over multiple sampled time points. 

 Field dissipation data also indicate that some of the major transformation products may 

have a higher potential to leach compared to the parent and are more persistent with half-lives on 

an order of magnitude greater than the calculated parent dissipation half-lives. Indaziflam and, 

more importantly, its degradates are a concern for exposure in ground water. The high mobility 

and persistence of the degradates, and data from field studies indicate that degradates of 

indaziflam will leach to ground water, specifically FDAT since it was detected at deeper depths 

in the field studies compared to the other degradates, and is expected to be highly mobile. A 

prospective ground water study (PGW) would help to further characterize the extent of the 

potential impact on ground water quality. 
-Page 28 of 292- 

Table 3.3 Environmental Fate Data Summary for Indaziflam + Residues of Concern 

OPPTS 

Guideline 

Data Requirement Data Summary Source 

835.2120 Hydrolysis t1/2 at 50°C no evidence of degradation 47443207

835.2240 Aqueous photolysis t1/2 at 25°C 

(TTR t1/2) 

3.7 days 

(85.5 days) 

47443208

835.2410 Soil photolysis t1/2 at 25°C 40.3 days 47443209

835.4100 Aerobic soil metabolism t1/2 at 25°C 

Indane, Triazine label 

PARENT ONLY 

87.7, 82.5 days (Nord sandy loam) 

177.7, 147.5 days (NC sandy loam; soil series not identified) 

PARENT + UN-EXTRACTED RESIDUES

203.9, 173.3 days (Nord sandy loam) 

630.1, 630.1 days (NC sandy loam; soil series not identified) 

47443210

47443211

835.4100 Aerobic soil metabolism t1/2 at 20°C 

Indane, Triazine label 

PARENT ONLY 

53.7, 60.3 days (Laacherhof sandy loam) 

35.5, 36.1 days (Laacherhof loam) 

41, 34.8 days (Wumwiese, loam) 

45.3, 45.3 days (Hoefchen, silt loam) 

PARENT + UN-EXTRACTED RESIDUES

101.9, 100.5 days (Laacherhof sandy loam) 

70.5, 69.3 days (Laacherhof loam) 

80.6., 90.0 days (Wumwiese, loam) 

91.2, 79.7 (Hoefchen, silt loam) 

47443212

47443213

835.4100 Aerobic soil metabolism t1/2 at 20°C 

FDAT (degradate as starting test 

substance) 

PARENT ONLY 

42.8 days (Laacherhof sandy loam) 

165 days (Wumwiese loam) 

14.9 days (Hoefchen silt loam)† 

PARENT + UN-EXTRACTED RESIDUES

70.8 days (Laacherhof sandy loam) 

654 days (Wumwiese loam) 

28.0 days (Hoefchen silt loam) 

47443214

835.4200 Anaerobic Soil Metabolism t1⁄2 at 20°C no evidence of degradation 47443216

835.4300 Aerobic aquatic metabolism t1/2 at 20°C PARENT ONLY 

119.5 days (Angler, water-sand sediment system) 

239.0 days (Hoenniger, water-loam sediment system) 

PARENT + UN-EXTRACTED RESIDUES

257.0 days (Angler, water-sand sediment system) 

462.0 days (Hoenniger, water-loam sediment system) 

47443217

835.4400 Anaerobic aquatic metabolism t1/2 at 20°C No evidence of degradation 47443218

47443219

11.1 (0.888) [426.0] (Goldsboro sandy loam) 

10.3 (0.874) [395.8] (Kansas, order not identified, clay loam) 

8.5 (0.867) [468.2] (Laacherhof sandy loam) 

9.5 (0.885) [741.8] (Hoefchen silt loam) 

6.1 (0.887) [449.7] (Wurmwiese loam) 

835.1230 Batch equilibrium, Kf (1/n) [Kfoc] 47443203

Triazine-indanone 

 3.04 (0.84) [304] (Goldsboro sandy loam) 

 5.97 (0.85) [284] (Kansas, order not identified, clay loam) 

 3.00 (0.85) [250] (Laacherhof sandy loam) 

 5.18 (0.87) [183] (Hoefchen silt loam) 

 3.04 (0.86) [146] (Wurmwiese loam) 

47443204
-Page 29 of 292- 

OPPTS 

Guideline 

Data Requirement Data Summary Source 

FDAT 

 0.477 (0.86) [47.7] (Goldsboro sandy loam) 

 0.778 (0.86) [37.1] (Kansas, order not identified, clay loam)

 0.165 (0.91) [12.6] (Laacherhof sandy loam) 

 0.262 (0.94) [10.1] (Hoefchen silt loam) 

 0.303 (0.93) [14.6] (Wurmwiese loam)

Indaziflam-carboxylic acid 

 1.32 (0.83) [132] Goldsboro sandy loam) 

 1.08 (0.83) [51] (Kansas, order not identified, clay loam) 

 0.47 (0.91) [32] (Laacherhof sandy loam) 

 0.67 (0.87) [29] (Hoefchen silt loam) 

 0.64 (0.91) [31] (Wurmwiese loam) 

47443205

47443206

835.6100 Terrestrial field dissipation t1/2 

(bare ground sites, runoff not measured) 

9.3 days (Porterville, CA – Nord fine sandy loam) 

59.2 days (Monticello, FL – Lucy loamy sand) 

45 days (Wayne County, NC – Norfolk loamy sand) 

34.8 days (Ephrata, Washington – Quincy loamy sand) 

21.3 days (North Rose, New York – Oakville loamy sand) 

47443223

47443224

47443225

47743301

47743302

835.6100 Terrestrial field dissipation t1/2 

(sites cropped with Turf, runoff not measured)

25.7 days (Porterville, CA – Nord fine sandy loam)) 

66.6 days (Monticello, FL – Lucy loamy sand) 

69.3 days (Wayne County, NC – Norfolk loamy sand) 

47443220

47443221

47443222

850.1730 Fish bioconcentration (BCF) 

steady state BCF (4-26 days) 

46, 25, 79.2 (low-dose, 0.3 ug a.i./L) whole, edible, inedible) 

64.8, 32.4, 122 (high dose, 3.0 ug a.i./L) whole, edible, 

inedible) 

47443237

3.2.1.1. Transport and Mobility 

Indaziflam is not volatile, with a partial vapor pressure of 5.1 x 10-10 and 8.25 x 10-11 torr 

at 25oC, for isomer A and B, respectively (MRID 47443202). The compound exhibits acid-base 

behavior (pKa = 3.5 and 3.6, isomer A and B, respectively; MRID 47443202), is neutral at 

environmental pH values and it is moderately soluble at environmental pHs 4, 7 and 9 (isomer A: 

4.4, 2.2, 2.2 mg/L, and isomer B: 1.7, 1.2, and 1.2 mg/L; MRID 47443202). . The reported Kow

for indaziflam at 40oC for pH 7 was 631, where pH>pKa, and was undetermined at pH< pKa

(MRID 47443202). 

 Indaziflam is moderately mobile to mobile based on FAO Soil Mobility Classification 

Guidance (USEPA, 2006), with reported Freundlich adsorption values (Kf) from five soils 

ranging from 6.1 to 11.1 (0.885) (MRID 47443203). Batch equilibrium data for indaziflam show 

that adsorption to soil is not well correlated with organic carbon content. The coefficient of 

variation (CV) for Koc (27%) is larger than that for Kf (21%). Further, Kf was not well correlated 

with percent organic carbon (r2 = 0.187, p = 0.47), nor with pH (r2 = 0.001, p = 0.95), nor percent 

clay (r2

 = 0.005, p = 0.91). 

 Leaching and adsorption/desorption studies were conducted on the identified three major 

degradates1

: triazine-indanone, FDAT, and indaziflam-carboxylic acid. These compounds are 

 

1

 A major degradate is defined as a compound that is detected in the fate studies at > 10% of the applied radiation, or 

is of toxicological concern. 
-Page 30 of 292- 

more mobile than the parent. FDAT and indaziflam-carboxylic acid have low soil-water 

partitioning coefficients (respective Kf values ranged from 0.16 to 0.78 and from 0.47 to 1.32). 

FDAT and indaziflam-carboxylic acid are mobile to highly mobile compounds, based on the 

FAO Soil Mobility Classification Guidance (USEPA, 2006). Triazine-indanone is moderately 

mobile in soil, although still more mobile than the parent indaziflam (Kf ranging from 3.00 to 

5.97; MRID 47443204). 

 Compounds with Kf values less than five trigger a ground water advisory (USEPA, 

2008a). The major degradates of indaziflam (triazine-indanone, FDAT, and indaziflamcarboxylic acid) present a potential ground water concern in some soils, especially those that are 

sandy and have low organic carbon content (all Kf values are less than 5; MRID 47443204, 

47443205, 47443206). 

3.2.1.2. Degradation 

Indaziflam is stable to hydrolysis; there was no evidence of degradation at pH 4, 7, and 9 

at 50oC (MRID 47443207). It is rapidly photolyzed in water (combined label, corrected 

environmental half-life of 3.7 days at pH 7; MRID 47443208) and photodegrades comparatively 

slowly in soil (continuously irradiated, combined label, corrected environmental 

photodegredation half-life in soil of 40.3 days in loamy sand at pH 6.5, OC 2.4%; MRID 

47443209). 

 Indaziflam biodegrades in 35 to 178 days in aerobic soil (parent-only half-lives; MRID 

47443210, 47443211, 47443212, 47443213). Un-extracted residues were substantial (17 – 34 

%) in the aerobic soil metabolism studies. Multiple solvent systems were not employed in the 

extraction scheme; therefore it is uncertain whether the un-extracted residues are parent, 

degradates, or bound residues. Thus half-lives were calculated for both parent-only and parent 

and un-extracted residues combined (parent and un-extracted residues non-linear half-lives of 71 

to 630 days). 

 

 Results from six aerobic soil metabolism studies on six different soil types show 

indaziflam degrades via oxidation of the indanyl moiety to indaziflam-triazine indanone and 

indaziflam-carboxylic acid. Indaziflam, indaziflam-triazine indanone and indaziflam-carboxylic 

acid are cleaved at the N bridge to form FDAT from the triazine moiety and unidentified minor 

compounds from the indanyl moiety. Residues are ultimately converted to bound residues and 

CO2. Figure 3.1 illustrates a predicted degradation pathway under aerobic conditions. 

 An aerobic aquatic metabolism study was conducted for indaziflam investigating the 

biotransformation of [triazine-2,4-14C]- and [indane-3-13/14C]-labeled indaziflam in two watersediment systems from Germany: a sand-gravel pit lake water system (Angler Weiher), and a 

loam-pond water system (Hoenniger Weiher). Un-extracted residues were significant in both 

systems (12-15% of the applied radiation; MRID 47443217). Multiple solvent systems were not 

employed in the extraction scheme; therefore it is uncertain whether the un-extracted residues are 

parent residues, metabolite residues, or bound residues. Half-lives were calculated for parent 

only, and for parent and un-extracted residues combined. The rate of biodegradation of 
-Page 31 of 292- 

indaziflam was slower in aquatic environments than terrestrial environments (parent-only nonlinear first order half-life of 120 days (DT90 of 497 days) in the water-sand sediment system at 

pH 7.4-8.6, and 239 days (DT90 of >1000 days) in the water-loam sediment system at pH 6.2-

6.7; MRID 47443217; parent and un-extracted residue non-linear first order half-lives of 257 

days, and 462 days, respectively). The compound quickly dissipated out of the water column 

(water dissipation half-life of 0 to 3 days), and was detected in the sediment. The major 

indentified degradates were triazine-indanone, FDAT, and indaziflam-carboxylic acid. In 

anaerobic aquatic environments, indaziflam is stable to biodegradation; there was no evidence of 

degradation (MRID 47443218, 47443219). 

Figure 3.1 Predicted Transformation Pathway under Aerobic Conditions 

3.2.1.3. Field Studies 

Eight terrestrial field dissipation studies were conducted for indaziflam using five sites in 

the United States. Five studies were conducted on bare ground (MRID 47443223, 47443224, 

47443225, 47443301, 47443302), each with four plots that had <1% slope and no runoff 

collection equipment. Three additional studies were conducted on soil cropped with turf (MRID 

47443220, 47443221, 47443222), each with four plots that had <1% slope and no runoff 

collection equipment. In all eight studies, indaziflam was broadcast once at a target application 
-Page 32 of 292- 

rate of 0.165 kg a.i./ha (0.147 lb a.i./A), which is greater than the proposed maximum application 

rate of 0.125 lb a.i./A (for use on forested areas). Indaziflam dissipation half-lives calculated for 

the total soil profile (0-120 cm) were not significantly different than those from the top 15 cm. 

The results from the field studies show more rapid dissipation under field conditions compared to 

the laboratory degradation studies (dissipation half-lives for indaziflam ranging from 9.3 to 69.3 

days versus laboratory half-lives of 36 to 178 days). This difference could be due to off-site 

movement (for example leaching) which is not tracked in the laboratory degradation studies. 

 Field test sites were analyzed for indaziflam and its major transformation products: 

indaziflam-carboxylic acid, triazine-indanone, FDAT, indaziflam-hydroxyethyl, and indaziflamolefin. The limit of detection (LOD) for parent indaziflam and its transformation products was 

0.3 ng·g-1, and the limit of quatitation (LOQ) was 1.5 ng·g-1 for all studies. A substantial number 

of detections of indaziflam and its major transformation products were reported at levels between 

the LOD and the LOQ in all field studies; replicate values below the LOQ were assumed at 

1⁄2(LOQ + LOD) for calculations of dissipation half-lives. Detections below the LOQ are not 

well characterized because the method of detection may have been too insensitive to accurately 

quantify these values; therefore, leaching potential of indaziflam and its major transformation 

products may not be accurately described by the data. However, data from these eight terrestrial 

field dissipation studies report indaziflam was detected at the deepest increment sampled, and 

major transformation products were detected at this depth at study termination (545 days). These 

data indicate that indaziflam and more importantly its transformation products have a potential to 

leach to ground water. 

 

 Field dissipation half-lives describe how long residues remain on the target field and in 

the upper portion of the subsurface, taking into account both degradation and off-site movement 

(via surface water, ground water, eroded soil or air). Under field conditions, calculated 

dissipation half-lives ranged from 9.3 days to 69.3 days; reported DT90s ranged from 109 to 545 

days (MRID 47443220, 47443221, 47443222, 47443223, 47443224, 47443225, 47743301, and 

47743302). Two studies reported calculated DT90s after the study termination (554 and 545 

days, MRID 47443222 and MRID 47743320). Dissipation half-lives for studies that examined 

plots cropped with turf were longer than those calculated from bare soil sites (9.3 – 59.2 days for 

bare soil sites and 25.7 – 69.3 days for turf sites). However, residues were not measured in the 

turf at any of the three sites cropped with turf (MRID 47443220, 457443221, 47443222). The 

percent carryover for indaziflam + residues of concern from year to year ranged from 0.6 to 

17%; total carryover for all residues for the entire profile ranged from 2.2 to 34%. 

 The most prevalent transformation products in all eight field studies were FDAT, 

triazine-indanone, and indaziflam-carboxylic acid. These compounds were detected in the 0-15 

cm depth at maximum mean parent-equivalent concentrations of 17.6% (at 28 days), 9.1% (at 28 

days), and 5.1% (at 28 days) of the theoretical day-0 recovery of indaziflam, respectively. 

Triazine-indanone and indaziflam-carboxylic acid were detected above the LOQ at a maximum 

depth of 15-30 cm. No detections were reported above the LOQ at depths below 30 cm for both 

triazine-indanone and indaziflam-carboxylic acid. However, FDAT was detected above the 

LOQ at a maximum depth of 60-75 cm 59 days after treatment; detections below the LOQ were 

reported at the bottom of the sampled soil profile at the study termination (545 days after 
-Page 33 of 292- 

treatment; MRID 47743302). Studies consistently reported detections of FDAT at depths of 60-

75 cm, and 45-60cm clearly demonstrating that the FDAT degradate has a potential to leach. 

Detections of both triazine-indanone and indaziflam-carboxylic acid, below the LOQ, were 

reported at a maximum depth of 60-75 cm at the study termination (545 days after treatment), 

indicating that these compounds as well have a potential to leach. 

3.2.1.4. Bioconcentration 

A flow-through bioconcentration study of bluegill sunfish (Lepomis macrochirus) 

exposed to indaziflam in pH 7.5-8.0 water for 26 days indicates that the compound does not 

bioconcentrate. The 26-day exposure period was followed by a 14 day depuration period. 

Bioconcentration factors (BCF) were 46, 25, and 79x for whole fish, edible, and non-edible fish 

tissues, respectively, in low-dose samples (0.3 μg/L), and 65, 32, and 122 for whole fish, edible, 

and non-edible fish tissues, respectively, in high-dose samples (3.0 μg/L). BCF values less than 

1000 do not trigger further evaluation of bioaccumulative compounds [64 Fed. Reg. 60194-

60204 (November 4, 1999)]. 

3.2.1.5. Environmental Degradates 

The transformation products resulting from the environmental degradation processes of 

indaziflam are: triazine-indanone, indaziflam-carboxylic acid, indaziflam-hydroxyethyl, 

indaziflam-olefin, FDAT, and fluoroethyltriazinanedione; all six of which were identified as 

major degradates (Table 3.4). Peak detections of these compounds were identified at a 

maximum of 17.4% (90 DAT), 21.7% (30 DAT), 20.8% (study termination, 3 DAT), 53.9% 

(study termination, 3 DAT), 39% (study termination, 368 DAT), and 25.7% (30 DAT) of the 

applied, respectively. Major degradates that are structurally similar to the parent include 

triazine-indanone, indaziflam-carboxylic acid, indaziflam-hydroxyethyl, and indaziflam-olefin. 

Chemical structures, chemical names, and other pertinent information on these degradation 

products, as well as data on minor degradation products are included in Appendix A. 

 Indaziflam-hydroxyethyl and indaziflam-olefin were included as residues of concern in 

the aquatic surface water exposure modeling. Available toxicity data on the degradates show 

that indaziflam-olefin and indaziflam-hydroxyethyl are of equal toxicity or are within an order of 

magnitude of toxicity lower than that of the parent indaziflam, based on the most sensitive taxa 

tested from available submitted studies, and were included as residues of concern for the 

exposure assessment. These two compounds are photolytic products that only formed in the 

aqueous photolysis study (MRID 47443208). These photodegradates are an exposure concern 

where indaziflam quickly reaches shallow water bodies. For example, on golf courses where the 

proposed uses of indaziflam may be applied near water bodies and could be transported via 

runoff and spray drift (ponds and lakes occur throughout the application sites on golf courses). 

 Chemical structures for minor degradation products were not reported in any study and 

the percent of formation is frequently below 1%, except in a few cases where percent of applied 

radiation reaches 2 to 4% (ROI2; MRID 47443214; Reg #1; MRID 47443208). Further, 

unidentified products were observed at 1 to 4 % of the applied radiation in aerobic aquatic 
-Page 34 of 292- 

systems (MRID 47443217). 

 The main degradation pathway of indaziflam appears to be via oxidation of the indanyl 

moiety to form indaziflam-triazine indanone and indaziflam-carboxylic acid. Indaziflam, 

triazine indanone and indaziflam-carboxylic acid are cleaved at the N bridge to form FDAT from 

the triazine moiety and unidentified minor compounds from the indanyl moiety. Residues are 

ultimately converted to bound residues and CO2. The maximum amounts of these degradation 

products observed in hydrolysis, aerobic aquatic metabolism, anaerobic aquatic metabolism, soil 

column leaching, and aqueous photolysis studies are summarized in Table 3.4. Since indaziflam 

and, more importantly, its degradates are persistent in terrestrial and aquatic environments, the 

degradates could contribute to the herbicidal activity of indaziflam. 

Table 3.4. Table of Transformation Products Formed in Environmental Fate Studies 

Common Name Chemical Name Study in Which Found 

(Maximum % of Parent, or 

equivalent) 

Reference 

MRID 

FDAT 

(R)-6-(1-fluoroethyl)-[1,3,5]triazine2,4-diamine 

(fluoroethyldiaminotriazine, FDAT)

Aerobic Soil Metabolism (39.1%) 

Anaerobic Soil Metabolism (4.6%) 

Soil Photolysis (7.4%) 

Aerobic Aquatic Metabolism (12.8%) 

Terrestrial Field Dissipation (17.6%) 

47443211 

47443216 

47443209 

47443217 

47443223 

Triazine Indanone N-[(1R,2S)-2,3-Dihydro-2,6-

dimethyl-3-oxo-1H-inden-1-yl]-6-

[(1R)-1-fluoroethyl]-1,3,5-triazine2,4-diamine 

(triazine indanone) 

Aerobic Soil Metabolism (15.8%) 

Anaerobic Soil Metabolism (10.2%) 

Soil Photolysis (7.2%) 

Aerobic Aquatic Metabolism (11.2%) 

Terrestrial Field Dissipation (9.1%) 

47443213 

47443216 

47443209 

47443217 

47443223 

Indaziflam -

Carboxylic Acid (2S,3R)-3-({4-Amino-6-[(1R)-1-

fluoroethyl]-1,3,5-triazin-2-

yl}amino)-2-methylindane-5-

carboxylic acid

(indaziflam-carboxylic acid)

Aerobic Soil Metabolism (21.7%) 

Anaerobic Soil Metabolism (14.3%) 

Soil Photolysis (2.4%) 

Aerobic Aquatic Metabolism (20.7%) 

Terrestrial Field Dissipation (5.1%) 

47443213 

47443216 

47443209 

47443217 

47443220 

IndaziflamHydroxyethyl 1-{4-Amino-6-[(1R,2S)-2,6-

dimethyl-2,3-dihydro-1H-inden-1-

ylamino]-1,3,5-triazin-2-yl}ethanol 

(indaziflam-hydroxyethyl)

Aqueous Photolysis (20.8%) 

Terrestrial Field Dissipation (<LOQ1

) 

47443208 

47443223 

Indaziflam-Olefin N-[(1R,2S)-2,6-dimethyl-2,3-

dihydro-1H-inden-1-yl]-6-vinyl1,3,5-triazine-2,4-diamine 

(indaziflam-olefin)

Aqueous Photolysis (53.9%) 47443208 

Fluoroethyltriazinanedione 

(ROI1) 6-[(1R)-1-fluoroethyl]-1,3,5-

triazinane-2,4-dione 

(ROI1, fluoroethyl-triazinanedione)

Aerobic Soil Metabolism (25.7%) 47443214

1

 Detected between the LOD and the LOQ. Detections between the LOD and LOQ are confirmed detections, however are not quantifiable based 

on the method of detection. The method of detection may have been too insensitive to accurately characterize the leaching potential of 

indaziflam and its degradates. 
-Page 35 of 292- 

3.2.2. Measures of Aquatic Exposure 

3.2.2.1. Surface Water Exposure 

The Tier II model Pesticide Root Zone Model (PRZM v3.12.2; May 12, 2005; Carousel 

et al., undated) linked with EXposure Analysis Modeling System (EXAMS v2.98.4.6; Apr. 25, 

2005; Burns, 2004) via the PRZM/EXAMS model shell (PE v5.0, Nov. 15, 2006), i.e., 

PRZM/EXAMS) was used to estimate baseline exposure concentrations in aquatic environments. 

The PRZM model simulates pesticide movement and transformation on and across the 

agricultural field resulting from crop applications. The EXAMS model simulates pesticide 

loading via runoff, erosion, and spray drift assuming a standard 1-ha pond, 2-m deep (20,000 m3) 

with no outlet that borders a 10-ha treated field. Simulations are for multiple (usually 30) years, 

from which the Agency estimates peak values that are expected once every ten years based on 

the daily values estimated. The coupled PRZM/EXAMS model and users manuals are available 

from the U.S. Environmental Protection Agency Water Models web-page (USEPA, 2009b). 

 Exposure estimates generated using this standard pond are intended to represent a wide 

variety of vulnerable water bodies that occur at the top of watersheds including prairie pot holes, 

playa lakes, wetlands, vernal pools, man-made and natural ponds, and intermittent and first-order 

streams. As a group, there are factors that make these water bodies more or less vulnerable than 

the standard surrogate pond. Static water bodies that have larger ratios of pesticide-treated 

drainage area to water body volume would be expected to have higher peak EECs than the 

standard pond. These water bodies will be either smaller in size or have large drainage areas. 

Smaller water bodies have limited storage capacity and thus may overflow and carry pesticide in 

the discharge, whereas the standard pond has no discharge. As watershed size increases, it 

becomes increasingly unlikely that the entire watershed is planted with a non-major single crop 

that is all treated simultaneously with the pesticide. Headwater streams can also have peak 

concentrations higher than the standard pond, but they likely persist for only short periods of 

time and are then carried and dissipated downstream. 

 The general chemical and environmental fate data for indaziflam listed in Table 3.2-3.3 

were used for generating model input parameters for PRZM and EXAMS (listed in Table 3.5). 

Chemical specific and model input values were chosen in accordance with current divisional 

guidance (USEPA, 2009c). These inputs represent the residues of concern (indaziflam-olefin 

and indaziflam-hydroxyethyl) present in the aqueous photolysis study and were determined to be 

of equal toxicity to the parent (MRID 47443265; MRID 47443264; MRID 47443255; MRID 

47443254); therefore aqueous photolysis half-life was recalculated using the total toxic residue 

approach. This modeling strategy requires an assumption that all residues of concern have 

similar physical, chemical, and partitioning characteristics. The formation of persistent, toxic 

degradation products is expected to extend the residual effects of the parent. Therefore, 

methodology outlined in the “White Paper on Methods for Assessing Ecological Risks of 

Pesticides with Persistent, Bioaccumulative and Toxic Characteristics” presented to the FIFRA 

Scientific Advisor Panel, in October, 2008, was followed to calculate total toxic residues of 

concern (parent plus indaziflam-hydroxyethyl, and indaziflam-olefin) (USEPA, 2008b). This 
-Page 36 of 292- 

modeling approach does not consider temporal occurrence of degradation products. These two 

degradates were only formed in an aqueous photolysis study, therefore only impacted the 

aqueous photolysis half-life, for the purposes of aquatic modeling. 

 The degradation studies were characterized by large amounts of un-extracted and 

uncharacterized residues, thus there is considerable uncertainty regarding the degradation of 

indaziflam in soil and aquatic systems. Using the methodology outlined in the White Paper on 

Methods for Assessing Ecological Risks of Pesticides with Persistent, Bioaccumulative and 

Toxic Characteristics,” model estimates were calculated using two sets of aerobic metabolism 

half-lives for indaziflam to address this uncertainty: 1) parent-only + residues of concern, and 2) 

parent + residues of concern + un-extracted residues (USEPA, 2008b). The model simulation 

results are bounded by the conservative upper-bound estimates using the parent + residues of 

concern + un-extracted residue half-lives, and the lower-bound parent-only + residues of concern 

half-lives. 

Table 3.5. PRZM and EXAMS Surface Water Chemical Input Parameters for Indaziflam 

+ Residues of Concern. 

Input Parameter Value Comment Source 

Molecular Mass (g/mol) 301.36 Product Chemistry 47443202 

Isomer A 5.1e-10 torr 

(6.8e-8 Pa) 

Vapor Pressure at 25°C 

(torr) 

Isomer B 8.25e-11 torr 

(1.1e-8 Pa) 

Product Chemistry 47443202 

Solubility in Water at 25oC, 

pH7 (mg/L) 1.2 Product Chemistry 47443202 

Freundlich adsorption 

partition coefficient (Kf) 9.1 Mean Kf (USEPA, 2009c) 47443203 

Aerobic Soil Metabolism 

Half-life (days) 

(parent & unextracted 

residues) 

89 

(275.3) 

Represents upper 90th percentile 

on the mean aerobic soil 

metabolism half-life (USEPA, 

2009c) 

47443210 

47443211 

47443212 

47443213 

Aerobic Aquatic 

Metabolism Half-life (days) 

(parent & unextracted 

residues)

101.6 

(230.4) 

Represents upper 90th percentile 

on the mean aerobic soil 

metabolism half-life (USEPA, 

2009c). 

47443217 

Anaerobic Aquatic 

Metabolism Half-life (days) STABLE (0) No evidence of degradation 47443218 

Hydrolysis Half-lives (days) STABLE (0) No evidence of degradation 47443207 

Aqueous Photolysis 

Half-life (TTR half-life) 85.5 days1 

Corrected TTR environmental 

half-life based on combined labels 

and continuous radiation. 

47443208 

1

 Aqueous photolysis half-life was recalculated using the total toxic residue approach. 
-Page 37 of 292- 

 The model input parameters used in PRZM to simulate indaziflam application and 

management practices are provided in Table 3.6. The initial application date was selected in 

order to reflect labeled crop/commodity timing for applications, consistent with the crop timing 

set by the model scenarios and with crop-profile information provided by the United States 

Department of Agriculture. Application rates were selected in accordance with the proposed 

labels to generate the most conservative estimates of aquatic exposure, which does not 

necessarily constitute selecting the maximum single application rate (e.g., stone fruit, grape, and 

turf uses). For these three uses, conservative estimates were generated using two applications at 

a lower rate (0.067 lbs a.i./A). Other agricultural uses (citrus, pome fruit, tree nuts, olives) were 

modeled using the single maximum application rate (0.085 lbs a.i./A) with a second application 

at a reduced rate (0.05 lbs a.i./A). Both simulations result in an annual maximum application 

rate of 0.134 lbs a.i./A/yr. 

Table 3.6 PRZM/EXAMS Model Input Parameters for Indaziflam 

Use Scenario 

Application 

Rate lbs a.i./A 

(kg a.i./ha) 

1st app, 2nd app 

Applications 

per Year 

Application 

Interval 

(days) 

Date of 

Initial 

Application

Application 

Method 

(CAM) 

Citrus FLcitrusSTD.txt 0.085, 0.05 

(0.095, 0.056) 2 90 May 20 Ground 

Spray (2) 

Tree fruit (pome 

fruit)1 NCappleSTD.txt 0.085, 0.05 

(0.095, 0.056) 2 30 July 22 Ground Spray (2)

Stone fruit ORberriesOP.txt 0.067, 0.067 

(0.075, 0.075) 2 265 March 12 Ground Spray (2)

Tree nuts GApecansSTD.txt 0.085, 0.05 

(0.095, 0.056) 2 90 June 14 Ground 

Spray (2)

Grapes NYgrapesSTD.txt 0.067, 0.067 

(0.075, 0.075) 2 30 August 15 Ground Spray (2)

Olives CAolivesRLF.txt 0.085, 0.05 

(0.095, 0.056) 2 30 Feb 02 Ground 

Spray (2)

Turf (golf courses, 

athletic fields, and 

sod farms) 

FLturfSTD.txt 0.050, 0.050 

(0.056, 0.056) 2 90 Aug 203 

Ground 

Spreader 

(broadcast) 

(2)

Home lawns CAresidentiaRLF.txt 

CAimperviousRLF.txt 

0.047 

(0.053) 2 14 Jan 15 Ground Spray (2)

Ornamentals CAresidentiaRLF.txt 

CAimperviousRLF.txt 

0.094 

(0.105) 1 NA Jan 15 Ground Spray (2)

Hardscapes FLimpervious.txt4 0.094 

(0.105) 1 NA May 26 Ground 

Spray (2) 

Forested areas 

(conifer and 

hardwood areas) 

NCapplesSTD.txt5 0.125 

(0.140) 1 3 months July 22 

Aerial Spray 

(2) 

NA = not applicable 

1

 Pome fruit are defined as apples, pears, quinces, and Asian pears. 

2

 Initial application was selected as March 1, with a second application 265 days later, as permitted on the proposed label (a late fall and an early 

spring application within a 12 month period. 

3

 Label permits two applications per year (a summer application followed by winter, or winter followed by spring, or fall followed by spring, or 

spring followed by fall). The label only permits a maximum of 473 lbs of product/A per 12 months (0.1 lb a.i./A/yr). Initial application rate was 

chosen to coincide with peak rainfall (based on a 30-year average of rainfall events), while following label application instructions. 4

 Florida impervious scenario is currently a provisional scenario. 5

 NC apples scenario was selected as the most vulnerable scenario to represent forestry uses as crop profile for apple orchard is similar to a 

profile for a commercial forest. 

 The modeling for the residential uses (home lawns and ornamentals) of indaziflam uses 

two scenarios in tandem requiring post-processing of the modeled output in order to derive a 
-Page 38 of 292- 

weighted EEC that represents the contribution of both the pervious and the impervious surfaces 

that exist in a residential setting. The residential scenario assumes that less than 100% of the 

watershed of an urban/suburban system will be treated (assuming a typical lot equals 

approximately 1⁄4 of an acre). In addition, this methodology assumes that there is small amount 

of overspray to the impervious surfaces on the lot (e.g., sidewalk, driveway) which result from 

normal applications. In general, incorporation of impervious surfaces into the exposure 

assessment results in increasing runoff volume in the watershed, which tends to reduce overall 

pesticide exposure. This is a conservative approach and assumes that every lawn is treated 

simultaneously. Additional detail regarding this modeling approach is provided in Appendix F. 

 For the hardscape use, a provisional scenario (FLimpervious.txt) was used to represent 

high exposure sites resulting from applications directly to impervious surfaces (e.g., patio, 

sidewalk and driveway cracks, on paths and gravel areas, along fence lines, and other hardscape 

areas). The Florida impervious scenario was modified from an existing California impervious 

scenario (CAimperviousRLF.txt) developed for endangered species assessments in California. 

The provisional scenario represents a conservative high-end exposure resulting from applications 

of indaziflam to hardscapes in West Palm Beach, FL. West Palm Beach, FL was specifically 

chosen to represent conservative exposure estimates because the precipitation is on average 

greater in this region of the country compared to other areas (e.g., Fresno, California). The 

scenario uses weather data from West Palm Beach, FL (W12844). The provisional Florida 

impervious scenario (FLimpervious.txt) is included in Appendix G. 

 In order to conservatively estimate aquatic exposure resulting from applications of 

indaziflam to hardscapes, a number of assumptions were made. Fundamentally, less than 100% 

of the watershed of an urban/suburban system will be impervious (assuming a typical lot equals 

approximately 1⁄4 of an acre, 50% of which is pervious surfaces, and 50% impervious); therefore 

less than 100% of the 10 ha simulated watershed will be treated with indaziflam. The 

assumption concerning a 1⁄4 acre residential lot size, with a 750 square foot driveway, a 250 

square foot sidewalk, and a 300 square foot deck was adopted from the 8/3/06 Chesapeake Bay 

Endangered Species Assessment, which was further refined in the 10/19/07 Pesticide Effects 

Determination for the Risks of Carbaryl Use to the Federally-Listed California Red Legged Frog. 

It was also assumed that the 300 square foot deck could be a 300 square foot patio, resulting in 

12% of the 1⁄4 acre lot covered with impervious surfaces. There are approximately 58 1⁄4 acre lots 

in a 10 ha watershed; therefore there is approximately 7% of the 10 ha watershed would be 

impervious surface that could potentially receive treatment of indaziflam ([1/4 acre lot (10,890 

ft2

) x 12% impervious surface x 58 lots / 1,076,391ft2 x 100 = 7.0%). Additional detail for the 

calculation of impervious surfaces, lot size, and number of lots in the simulated watershed is 

included in Appendix F. 

 The conceptual model for applications to hardscapes has two conservative assumptions. 

First, it assumes that indaziflam could be applied to all of the 12% impervious surfaces on a 1⁄4 

acre lot. Second, it assumes that all hardscapes are treated simultaneously. We varied the 

percentages of impervious surfaces that received treatment in the 1⁄4 acre lot to simulate differences in 

potential use practices; those percentages were 25% 50% and 100% of the total impervious surface in 

the 1⁄4 acre lot (12%). The following algorithm was used to calculate the aquatic EECs for hardscape 

applications: 
-Page 39 of 292- 

Hardscape EEC = [(impervious EECs) x (% impervious surface 

treated) x (12% lot assumed impervious)]

 Further, in order to simulate adsorption during transport across hardscapes, the 

Freundlich adsorption coefficient (Kf) was set to zero (0), as there is nothing for the chemical to 

bind to on an impervious surface (e.g., pavement or concrete). Using an adsorption coefficient 

greater than zero in the modeling results in some amount of adsorption, thus underestimating the 

concentration of indaziflam in runoff. These estimates are conservative; however, it is also 

important to note that this approach may over estimate surface water concentrations as there is 

some amount of binding that would otherwise occur, and aerobic aquatic metabolism data 

indicate that the compound is detected in sediment in aqueous environments. 

 Additional detail and rationale for the selection and use of each scenario environment is 

also included in Appendix G. 

 The modeled aquatic EECs resulting from the proposed indaziflam use areas (listed in 

Table 3.7a and 3.7b) were used for risk estimation in this baseline assessment. The model input 

and output filenames supporting these values are listed in Appendix H. 

Table 3.7a. Modeled aquatic 1-in-10-year Surface Water EECs for Proposed Uses of 

Indaziflam + Residues of Concern (maximum values in bold)1

Uses Scenario Max. App. rate

(lbs a.i./A/yr) Peak (ppb) 21-day (ppb) 60-day (ppb) 

Citrus FL Citrus 0.134 2.46 - 3.76 2.24 - 3.66 1.94 - 3.46 

Pome Fruit2 NC Apples 0.134 2.61 – 3.86 2.44 – 3.74 2.31 – 3.60 

Stone Fruit OR Berries 0.134 1.01 – 1.75 0.99 – 1.73 0.95 – 1.70 

Tree Nuts GA Pecans 0.134 2.31 – 3.43 2.15 – 3.34 1.85 – 3.11 

Grapes NY Grapes 0.134 2.15 – 4.00 2.13 – 3.98 2.09 – 3.95 

Olives CA Olives 0.134 0.72 – 1.02 0.69 – 1.0 0.65 – 0.94 

Turf FL Turf 0.100 0.35 - 0.47 0.33 - 0.45 0.28 - 0.39 

Home Lawns3 CA Residential 

CA Impervious 0.094 2.66 - 5.92 2.58 - 5.89 2.52 - 5.70 

Ornamentals3,4 CA Residential 

CA Impervious 0.094 2.64 – 6.19 2.58 – 6.10 2.53 – 6.05 

Forested Areas NC Apples 0.125 2.66 – 4.03 2.51 – 3.98 2.30 – 3.90 1

 Range in model estimates represent the upper and lower bound model results. Lower bound estimates were completed using the parent + 

residues of concern, and the upper bound were completed using parent + residues of concern + unextracted residues. 2

 Pome fruit include: apples, pears, quinces, and Asian pears. 

3

 Assumes 50% of the watershed is pervious, 50% is impervious. Assumes 50% of an average 1⁄4 acre home lot is treated with indaziflam. 4

 Assumes a conservative estimate of the percent of the lot treated. A lower area treated estimates do not produce significantly lower EECs, 

therefore the exposure estimates from ornamental use represent an upper bound on the 1-in-10 year estimates. 
-Page 40 of 292- 

Table 3.7b. Modeled aquatic 1-in-10-year Surface Water EECs for Proposed Indaziflam + 

Residues of Concern Use on Hardscapes.1,2

Uses Scenario Max. App. rate

(lbs a.i./A/yr) Peak (ppb) 21-day (ppb) 60-day (ppb) 

Hardscapes (100%) FL Impervious 0.094 2.78 – 3.22 2.60 – 3.13 2.24 – 2.94 

Hardscapes (50%) FL Impervious 0.094 1.39 – 1.61 1.30 – 1.57 1.12 – 1.47 

Hardscapes (25%) FL Impervious 0.094 0.70 – 0.80 0.65 – 0.78 0.56 – 0.74 1

 Actual use patterns may differ from modeled approach. Use may be selective spot treatment (e.g., spraying cracks and crevices in driveways). 

These estimates are considered reasonably conservative. 2

 Range in model estimates represent the upper and lower bound model results. Lower bound estimates were completed using the parent + 

residues of concern, and the upper bound were completed using parent + residues of concern + unextracted residues. 

 The ecological pond modeled with EXAMS is a static water body of fixed volume with 

no outlet. Since indaziflam is persistent in aquatic environments and since the ecological pond 

has no outlet, the modeling indicates indaziflam accumulates in the pond throughout the 30-year 

simulations. Exposure endpoints, in this assessment, are based on yearly peak concentrations. In 

the case of persistent compounds, a 1-in-10 year EEC does not reflect varying meteorological 

conditions that are expected once every 10 years, since the yearly peaks are not independent but 

are actually correlated to the previous year’s peak concentration. 

3.2.2.2. Sediment Pore Water Exposure 

Environmental fate data show that indaziflam dissipates quickly from the water column 

and was detected in sediment; therefore sediment exposure may be a concern for sediment 

dwelling organisms. Benthic sediment pore water EECs were calculated for the proposed 

maximum use patterns for indaziflam. The model simulation results are bounded by the 

conservative upper-bound estimates using half-lives for parent + residues of concern + unextracted residues, and the lower-bound parent-only + residues of concern half-lives. 

Pore water EECs are provided in Table 3.8. 

Table 3.8. Model Benthic 1-in-10 year Benthic Pore Water EECs for Proposed 

Maximum Use Patterns for Indaziflam

Uses Scenario Max. App. rate

(lbs a.i./A/yr) Peak (ppb) 21-day (ppb) 60-day (ppb) 

Pome Fruit1 NC Apples 0.134 2.00 - 3.46 2.00 - 3.46 1.98 - 3.42 

Turf FL Turf 0.100 0.22 - 0.35 0.21 - 0.35 0.21 - 0.35 

Forested Areas NC Apples 0.125 2.06 - 3.70 2.06 - 3.69 2.04 - 3.67 1

 Pome fruit include: apples, pears, quinces, and Asian pears. 

3.2.2.3. Ground Water Exposure 

The Tier I model Screening Concentration in Ground Water (SCI-GROW v2.3, Jul. 29, 

2003; USEPA, 2002b) was run to estimate baseline exposure of aquatic environments to 

indaziflam in base flow originating from ground water. SCI-GROW is an empirical regressionbased model that was developed by fitting a linear model to ground water concentrations with 

the Relative Index of Leaching Potential (RILP) as the independent variable. Ground water 

concentrations were based on 90-day mean high concentrations from Prospective Ground Water 
-Page 41 of 292- 

studies. The RILP is a function of aerobic soil metabolism and the soil-water partition 

coefficient. The output of SCI-GROW represents the concentration of pesticide residue that 

might be expected in vulnerable shallow unconfined aquifers. Discharge from such aquifers into 

nearby surficial water bodies could impact aquatic wildlife and plants. This single 90-day mean 

value is used to approximate both acute and chronic exposure. The SCI-GROW model and 

user’s manual is available from the EPA Water Models web-page (USEPA, 2002b). 

 Input parameters for the SCI-GROW model appear in Table 3.9. These inputs were 

determined in accordance with current divisional guidance (USEPA, 2002b). The median of five 

reported organic carbon partition coefficients and the median of twelve half-lives (50 d) from six 

aerobic soils were selected. Unextracted residues were significant in all aerobic soil metabolism 

studies; therefore, additional model simulations were completed using the median aerobic soil 

metabolism half-life including un-extracted residues (96 days). 

Table 3.9. SCI-GROW Input Parameters for Indaziflam (Source data are in Tables 

3.1-3.2)

Input Parameter Value Comments Source

Application Rate 

(lbs a.i./A) 

See table 3.10 for 

application 

information 

Maximum proposed single application 

rate. Proposed label. 

Applications per Year 

See table 3.10 for 

application 

information 

Maximum proposed number of 

applications per year at the maximum 

proposed single application rate. 

Proposed label. 

Organic Carbon Partition 

Coefficient (KOC) (L/kgOC) 450 Represents the median of five reported 

Kfoc. MRID 

Aerobic Soil Metabolism 

Half-life (days) 

(including un-extracted 

residues) 

50 

(96) 

Represents the median half-life of 

twelve values from six soils. MRID 

 Three annual application rates were evaluated: an agricultural application rate (0.134 lbs 

a.i./A/yr), a turf rate (0.1 lbs a.i./A/yr), and the highest non-ag rate (0.125 lbs a.i./A/yr for 

forestry). The modeled ground water EECs resulting from the three representative indaziflam 

uses are listed in Table 3.10. The contribution of baseflow to overall flow in waters is variable. 

In some areas of the country and for certain periods of the year, baseflow can account for the 

total flow of some surface water systems. However, the exposure values represent potential 

exposure in shallow unconfined aquifers located directly under application sites; concentrations 

may be reduced prior to discharge by adsorption and degradation during transport through the 

subsurface. The model input/output filename and data supporting this value are reproduced in 

Appendix H. 
-Page 42 of 292- 

Table 3.10. Estimated Environmental Concentrations of Indaziflam in Ground Water

Use 

(modeled annual rate) 

Acute (ppb) Chronic (ppb)

Agricultural (Citrus, Stone Fruit, Pome Fruit, Grapes, Tree 

Nuts, Pistachios, Olives) (0.134 lbs a.i./A) 0.02 – 0.03 <0.03 

Turf (0.100 lbs a.i./A) 0.01 – 0.02 <0.02 

Forested Areas (0.125 lbs a.i./A) 0.02 – 0.03 <0.03 1

 EECs are bounded using two sets of modeled environmental half-lives, parent-only and parent + un-extracted residues. 

3.2.3. Measures of Terrestrial Exposure 

The terrestrial exposure assessment of proposed uses of indaziflam is based on the 

exposure and effects of the parent compound indaziflam only. However, as previously 

mentioned in Section 3.2.1.5, the major transformation products of indaziflam, triazineindanone, indaziflam-carboxylic acid, indaziflam-hydroxyethyl, and indaziflam-olefin, have 

been identified as residues of concern based on structural similarity to the parent. FDAT has 

also been identified as a residue of concern. All five of these degradates have been identified as 

drinking water residues of concern for humans (USEPA, 2009d). Based on this finding, these 

residues could potentially be of concern for mammals and birds, in addition to plants based on 

stuctural similarity. However, in a screening level assessment, fate and effects data sufficient to 

evaluate risk to terrestrial wildlife from exposure to degradates is generally not available, as is 

the case for this screening level assessment. Further discussion of the uncertainties with this 

approach are discussed in the Risk Description, Section 4.2. 

 The application methods for the proposed indaziflam agricultural and non-agricultural 

uses include foliar spray (ground and aerial) and granular applications. Both of these 

applications methods are considered in the terrestrial exposure assessment. 

3.2.3.1. Terrestrial Wildlife 

Terrestrial wildlife exposure estimates are typically calculated for birds and mammals, 

emphasizing a dietary exposure route for uptake of the pesticide active ingredient. Birds are also 

considered surrogates for terrestrial-phase amphibians as well as reptiles. For exposure to 

terrestrial organisms from spray applications, such as birds and mammals, estimation of pesticide 

residues in wildlife food items assumes organisms are exposed to a single pesticide residue in a 

given exposure scenario and focuses on the possible dietary ingestion of residues on vegetative 

matter and insects. For granular applications, estimation of loadings of indaziflam per unit area 

are calculated. This approach, which intends to represent exposures via multiple routes and not 

just direct ingestion, considers observed acute effects (acute oral LD50) in terrestrial toxicology 

studies and relates them to the to surface area where the pesticide is applied (LD50/ft2). 

 The T-REX model (v1.4.1; USEPA, 2008c) is used to calculate dose- and dietary-based 

EECs of indaziflam residues on food items via spray applications for mammals and birds, as well 

as estimated loadings of indaziflam per unit area via granular applications; a 1-year time period 

is simulated. Input values for deriving EECs in T-REX are listed in Table 3.11. Given the 
-Page 43 of 292- 

toxicity data available for indaziflam, only chronic effects to birds and mammals will be assessed 

with the deterministic RQ method and presented in the risk estimation section; all acute effects 

will be assessed qualitatively in the risk description. EECs are thus derived in T-REX for 

indaziflam exposures to terrestrial mammals and birds from upper-bound Kenaga nomogram 

values. Tables 3.12 and Table 3.13 summarize the chronic dose-based (mammals) and chronic 

dietary-based (birds) EECs used in this assessment to calculate RQs based on the maximum 

single application rates by application method for crop and non-crop uses. For liquid 

applications, consideration is given to different types of feeding strategies for mammals, 

including herbivores, insectivores and granivores. For dose-based exposures, three weight 

classes of mammals (15, 35, and 1000 g) are considered. Weight classes of birds are not 

considered for dietary-based exposures. As mentioned above, EECs estimated from granular 

applications intend to represent exposures via multiple routes and not just direct ingestion 

(although not quantified, these routes could include dermal exposures, incidental soil ingestion, 

drinking water exposure, or inhalation of residues from suspension of soil particles/dust). EECs 

for granular uses are presented as milligrams of active ingredient per square foot (mg a.i./ft2), 

and the label rate of application for the active ingredient is the basis for the exposure term. For 

the one modeled granular use of indaziflam, it is assumed that 100% of the granules will be 

available to terrestrial organisms from a broadcast treatment. 

 Uncertainties in the terrestrial EECs for application of the liquid formulations are 

primarily associated with a lack of data on interception and subsequent dissipation of indaziflam 

from foliar surfaces. Residue decline data was unavailable from the open literature and 

unavailable from magnitude of residue studies (OPPTS 860.1500) conducted on pome fruit, 

stone fruit, tree nuts, citrus, grapes, and olives1. A conservative default foliar dissipation halflife of 35 days is used based on the work of Willis and McDowell (1987). An example output 

from the T-REX model is provided in Appendix I. 

 Indaziflam exposures to terrestrial invertebrates are not quantitatively calculated for 

derivation of deterministic RQs. However, risk to this taxon is assessed qualitatively in the Risk 

Estimation, Section 4.1, and then characterized further in the Risk Description, Section 4.2. 

 

1

Available magnitude of residue studies with MRID numbers: pome fruit (MRID 47743402), stone fruit (MRID 

47743403), tree nuts (MRID 47743404), citrus (MRID 47743405), grapes (MRID 47743406), olives (MRID 

47743407) 
-Page 44 of 292- 

Table 3.11. T-REX Input Parameters for Deriving Terrestrial EECs for Indaziflam 

Proposed Uses

Use (Application Method) Maximum Single Application 

Rate (lbs a.i./A) 

Maximum Annual 

Number of Applications 

(Minimum Interval Between 

Applications) 

Food1 (Ground Spray) 0.085 2‡

 

(30 days) 

Home lawns (Ground Spray) 0.047 2 

(14 days) 

Ornamentals & Hardscapes 

(Ground Spray) 0.094 1 

Roadsides/rights-of-way2 & 

Site Preparation3

 (Ground 

Spray) 

0.089 1 

Forested Areas (Aerial and 

Ground Spray) 0.125 1 

0.080 (granule) 2‡

 

Turf (90 days) 4 (Ground Granule and 

Ground Spray) 0.017 (spray) 2‡

(90 days) 

‡

The label permits a single application at the maximum application rate and a second application at a reduced rate (e.g., applications of indaziflam 

for food uses: 0.085 lbs a.i./A is the maximum application rate with a permitted second application at a maximum rate of 0.05 lbs a.i./A, equaling 

an annual maximum rate of 0.134 lbs a.i./A). For athletic turf uses a single maximum application rate of 0.08 lbs a.i./A is permitted for granule 

uses with a second application of 0.02 lbs a.i./A; a single maximum application rate of 0.017 lbs a.i./A is permitted for srpay uses with a second 

application of 0.004 lbs a.i./A. 

1

 Food Uses: Citrus, Pome Fruit, Stone Fruit, Tree Nuts, Vine Crops 

2

 Non-Crop Areas: Railroad and Rail Yards, Managed Roadsides, Fence Rows, Utilities, Other Industrial, Municipal, and Government Sites 3

 Site Preparation: Areas under Aspalt and Concrete 4

 Turf: Golf Courses, Sport Fields, Sod farms 
-Page 45 of 292- 

Table 3.12. Terrestrial Food-Item Residue Estimates for Mammals for Indaziflam 

Proposed Uses 

Herbivore/Insectivore Dose-Based EECs (mg/kg-bw) 

Use Size Class 

(grams) Short Grass Tall 

Grass 

Broadleaf 

Plants/Small 

Insects 

Fruits/Pods/ 

Seeds/Large 

Insects 

Granivore 

Dose-Based 

EECs 

(mg/kg-bw) 

15 30.1 13.8 16.9 1.89 0.42 

Food 35 20.8 9.56 11.7 1.30 0.29 

1000 4.84 2.22 2.72 0.30 0.07 

15 18.9 8.66 10.6 1.18 0.26 

Home Lawns 35 13.1 5.99 7.35 0.82 0.18 

1000 3.03 1.39 1.70 0.19 0.04 

15 21.5 9.86 12.1 1.34 0.30 

35 14.8 6.81 8.36 0.93 0.21 Ornamentals & 

Hardscapes 1000 3.45 1.58 1.94 0.22 0.05 

15 20.3 9.33 11.4 1.27 0.28 

35 14.0 6.45 7.92 0.88 0.20 

Roadsides/righ

ts-of-way & 

Site 

Preparation 1000 3.26 1.50 1.84 0.20 0.05 

15 28.6 13.1 16.1 1.79 0.40 

Forested Areas 35 19.7 9.06 11.1 1.24 0.27 

1000 4.58 2.10 2.58 0.29 0.06 

15 4.54 2.08 2.56 0.28 0.06 

35 3.14 1.44 1.77 0.20 0.04 Turf 

(Ground Spray) 1000 0.73 0.33 0.41 0.05 0.01 

Turf 

(Granule) 

None 

Specified Granular Broadcast Application = 0.83 mg a.i./ft2

Table 3.13. Terrestrial Food-Item Residue Estimates for Birds for Indaziflam Proposed 

Uses

Dietary-based EECs (mg/kg-diet) 

Use Short Grass Tall Grass Broadleaf plants/sm 

insects 

Fruits/pods/ 

seeds/lg insects 

Food 31.7 14.5 17.8 1.98 

Home Lawns 19.8 9.09 11.2 1.24 

Ornamentals & Hardscapes 22.6 10.3 12.7 1.41 

Roadsides/rights-of-way & 

Site Preparation 21.4 9.79 12.0 1.34 

Forested Areas 30.0 13.8 16.9 1.88 

Turf (Ground Spray) 4.77 2.18 2.68 0.30 

Turf 

(Granule) Granular Broadcast Application = 0.83 mg a.i./ft2

2.3.2. Terrestrial and Semi-Aquatic Plants 

 Exposure of naturally-occurring terrestrial and semi-aquatic (wetland) plant species is 

typically estimated using OPP’s TerrPlant (v1.2.2; USEPA, 2006b) model and is assumed to 

encompass areas outside the immediate use site. The TerrPlant model is used to derive EECs in 
-Page 46 of 292- 

runoff and drift for terrestrial and semi-aquatic plants near areas where indaziflam has been 

applied. Runoff exposure is assessed in two scenarios: sheet and channel runoff. In the sheet 

runoff scenario, the treated area generating runoff is assumed to drain into an area with equal 

size containing seedlings, resulting in 1, 2, or 5% of the amount applied being deposited. In the 

channel runoff scenario, a ten-to-one ratio of treatment area to receiving area results in 10, 20, or 

50% of the amount applied being deposited on soil with emerging or emerged seedlings. Spray 

drift is also a source of pesticide loading to non-target areas. The default spray drift assumptions 

are 1% for ground spray applications and 5% for aerial spray and chemigation applications. 

TerrPlant estimates EECs based on application rate, application method, chemical solubility in 

water, type of runoff, and default assumptions of drift. The EECs for terrestrial and semi-aquatic 

plants for a single application of indaziflam at the maximum label rate for proposed agricultural 

and non-agricultural uses are presented in Table 3.13. An example output from the TerrPlant 

model is provided in Appendix J. 

In order to determine terrestrial areas of concern due to exposures through spray drift, it 

is necessary to estimate the distance that spray applications can drift from the treated area and 

still be present at concentrations that may result in an effect. An analysis of spray drift distances 

will be completed in the risk description section of this assessment using AgDRIFT (v. 2.01). 

The analysis does not assess potential exposure through runoff or other exposure pathways. 

 

Table 3.13 EECs* for Terrestrial and Semi-Aquatic Plants Near Indaziflam Use Areas. 

EECs (lbs a.i./A) 

Use and Application 

Single Max. 

Application 

Rate 

(lbs a.i./A) 

Total Loading to 

Semi-Aquatic 

Areas 

 Spray Drift Dry Areas (Total) 

Food Ground 0.085 0.00935 0.00085 0.0017 

Ground 0.017 0.00187 0.00017 0.00034 

 Turf 

Granule 0.080 0.008 N/A 0.0008 

Home Lawns Ground 0.047 0.00517 0.00047 0.00094 

Ornamentals/ 

Hardscapes Ground 0.094 0.01034 0.00094 0.00188 

Roadsides/righ

ts-of-way/ Site 

Preparation 

Ground 0.089 0.00979 0.00089 0.00178 

Ground 0.125 0.01375 0.00125 0.0025 Forested Areas 

Aerial 0.125 0.01875 0.00625 0.0075 

*based on solubility of 1.2 – 4.4 mg/L 

3.3. Ecological Effects Characterization 

 In baseline ecological risk assessments, effects characterization describes the types of 

effects a pesticide can have on aquatic and terrestrial organisms. To date, toxicity tests for 

amphibian or reptiles are not required; birds are used as surrogates for reptiles and terrestrial-
-Page 47 of 292- 

phase amphibians and freshwater fish are used as surrogates for aquatic-phase amphibians. This 

characterization is based on the registrant-submitted toxicity data for on birds, mammals, fish, 

invertebrates, and plants for indaziflam (also referred to as technical grade indaziflam, or 

indaziflam technical grade active ingredient (TGAI)); three of its formulated products including 

BCS-AA10717 20WSP (20% indaziflam), Indaziflam 500 SC (45.05% indaziflam), and 

Indaziflam 200 SC (19.05% indaziflam); and the following degradates: triazine indanone, FDAT, 

indaziflam-carboxylic acid, indaziflam-hydroxyethyl, and indaziflam-olefin. Toxicity tests for 

amphibian or reptiles are not required; birds are used as surrogates for reptiles and terrestrialphase amphibians and freshwater fish are used as surrogates for aquatic-phase amphibians. No 

data were available in the public literature for indaziflam effects characterization (see below). 

Appendix C provides detailed results of all registrant-submitted toxicity studies used to 

characterize effects for this risk assessment. A quick reference to these studies regarding 

acceptibility classifications and associated deficiencies can be found in Appendix B. 

 In addition to the data submitted in support of registration, the ECOTOX (ECOTOXicity) 

database (USEPA, 2009a) was searched for additional toxicity data from the open literature. The 

ECOTOX database is a user-friendly, publicly-available, quality-assured, comprehensive tool for 

locating toxicity data from the open literature and is maintained by EPA Mid-Atlantic Ecology 

Division. More information on ECOTOX can be found at: http://www.epa.gov/ecotox. 

Research papers are thoroughly screened using standard procedures before being accepted into 

ECOTOX thereby ensuring consistent, high quality information. For indaziflam and its 

degradates, no studies were identified in ECOTOX as of November 18, 2009. 

 Given that indaziflam is a new active ingredient with no previous registration in the U.S. or 

any other country, a query of the Agency’s Office of Pesticide Programs Ecological Incident 

Information System (EIIS) was not completed, and it is assumed that no ecological incidents 

exist for indaziflam. 

3.3.1. Aquatic Toxicity Assessment 

The most sensitive acute and chronic effects measurement endpoints associated with indaziflam 

exposure to freshwater and estuarine/marine species are summarized in Table 3.14 

The majority of available toxicity data show the degradates and formulations to be either of 

similar toxicity or to be much less toxic than technical grade indaziflam for aquatic species. For 

aquatic nonvascular plants, toxicity data indicate that the toxicity of indaziflam and its 

degradates are of a similar order of magnitude. For vascular aquatic plants, a study on the 

formulated product demonstrated toxicities slightly lower than for indaziflam alone. As such, all 

measurement endpoints for aquatic organisms are based on studies of the TGAI except for 

aquatic vascular plants. All acceptable and supplemental studies submitted for the registration of 

indaziflam are described in the text and again summarized in Appendix C. 

 Results of acute toxicity studies in freshwater and estuarine/marine fish indicate that 

indaziflam is highly toxic to fish on an acute exposure basis. Dose-dependent sublethal effects 

observed in fish studies included surfacing, lethargy, erratic swimming, loss of equilibrium, loss 
-Page 48 of 292- 

of vertical orientation, labored respiration, and lying on the bottom. Acute toxicity studies on the 

freshwater invertebrate D. magna indicate that indaziflam is slightly to moderately toxic to 

freshwater invertebrates on an acute exposure basis. Quiescience, appearing to be dosedependent, was observed in a test with the TGAI as a sublethal effect in daphnids. Acute 

toxicity to marine invertebrates is categrized as moderately to highly toxic on an acute exposure 

basis. Sublethal effects from one of the estuarine/marine invertebrate toxicity studies included 

surfacing, lethargy, and erratic swimming, and appeared dose-dependent. Due to indaziflam’s 

solubility, 1,200 – 4,400 μg/L (MRID 47443202), effects to freshwater and estuarine/marine 

invertebrates may be limited. 

 Chronic toxicity studies are only available for freshwater fish and invertebrates using the 

species P. promelas and D. magna, repectively. The chronic freshwater fish toxicity endpoint 

used in this assessment was based on fry survival, total length, and dry weight, with sublethal 

effects immediately preceeding mortality at the highest concentrations tesed. Of the parameters 

assessed in the one submitted invertebrate life cycle study, indaziflam inhibited the parameters 

measuring both parental (F0) growth and reproduction. Effects to offspring (F1) were not 

evaluated. 

 Results of toxicity studies of the TGAI to freshwater and marine nonvascular and 

vascular plants indicate that indaziflam is toxic to aquatic plants. This determination is based on 

the magnitude of EC50 values in the parts per billion (μg/L) and parts per trillion (ng/L) range. 
-Page 49 of 292- 

Table 3.14. Most Toxic Acute and Chronic Toxicity Data for Aquatic Organisms and 

Plants Exposed to Indaziflam Technical 

Exposure 

Scenario Species 

Affected 

Endpoint Toxicity Measurement 

Reference 

(Classification) 

Study Test 

Substance 

Freshwater Fish 

Acute Bluegill sunfish 

(Lepomis 

macrochirus) 

Mortality 96-hr LC50 = 320 μg total a.i./L1

 

95 % C.I.: 210-750 μg total a.i./L1 

Slope: N/A 

MRID 47443233 

(Supplemental) 

Chronic Fathead Minnow 

(Pimephales 

promelas) 

Reproduction 

& Growth2

35-day NOAEC = 464 μg total a.i./L1

35-day NOAEC = 1020 μg total 

a.i./L1

MRID 47443236 

(Supplemental) 

Freshwater Invertebrates 

Acute Water flea 

(Daphnia spp.) 

Immobility 48 hr EC50 >9,880 μg total a.i./L1 

95 % C.I.: N/A 

Slope: N/A 

MRID 47443226 

(Supplemental) 

Subacute Midge 

(Chironomus 

tentans) 

Mortality Pore WaterExposure 

10 day LC50 > 2,200 μg a.i./L

MRID 47443238 

(Supplemental) 

Chronic Water flea 

(Daphnia spp.) 

Reproduction 

& Growth 

21-day NOAEC = 340 μg total a.i./L1 

21-day LOAEC = 800 μg total a.i./L1

MRID 47443235 

(Supplemental) 

Estuarine/Marine Fish 

Acute Sheepshead 

minnow 

(Cyprinodon 

variegatus) 

Mortality 96-hr LC50 = 960 μg total a.i./L1 

95 % C.I.: 430-1,560 μg total a.i./L1 

Slope: N/A 

MRID 47443232 

(Supplemental) 

Chronic No studies available 

Estuarine/Marine Invertebrates 

Acute Eastern oyster 

(Crassostrea 

virginica) 

Shell 

Deposition 

96-hr EC50 = 920 μg total a.i./L1 

95 % C.I.: 750-1,100 μg total a.i./L1 

Slope: 4.04 ± 0.737 

MRID 47443228 

(Supplemental) 

Subacute Amphipod 

(Leptocheirus 

plumulosus) 

Mortality Pore WaterExposure 

10-day LC50 > 3,800 μg a.i./kg dw

MRID 47443239 

(Supplemental) 

Chronic No studies available 

Aquatic Plants 

7-day 

exposure 

Duckweed 

(Lemna gibba) 

Frond 

number 

7-day EC50 = 0.061 μg a.i./L* 

95 % C.I.: 0.055-0.068 μg a.i./L 

Slope: 7.92 ± 0.931 

NOAEC = 0.0194 μg a.i./L 

MRID 47743308 

(Supplemental) 

96-hour 

exposure 

Marine Diatom 

(Skeletonema 

costatum) 

Biomass 96-hr EC50 = 27 μg a.i./L 

95 % C.I.: 22-33 μg a.i./L 

Slope: 2.62 ± 0.232 

NOAEC = 5.1 μg a.i./L 

MRID 47443267 

(Acceptable) 

*formulated product BSC-AA10717 SC 500 g/L 44.4% ai) 

1

 Total dissolved and undissolved 

2

 Chronic effects to reproduction and growth based on fry survival, and total fry length and weight. 
-Page 50 of 292- 

3.3.1.1 Toxicity to Freshwater Fish 

Acute Effects 

 The acute toxicity of technical grade indaziflam to freshwater fish was evaluated in three 

studies, with 96-hour LC50 values of 320 μg total a.i./L in bluegill sunfish (Lepomis 

macrochirus; MRID 47443233), 572 μg total a.i./L in rainbow trout (Oncorhynchus mykiss; 

MRID 47443234), and 770 μg total a.i./L in fathead minnow (Pimephales promelas; MRID 

47443229). Based on these results, indaziflam is categorized as highly toxic to freshwater fish 

on an acute exposure basis. Dose-dependent sublethal effects were observed in the three highest 

treatment levels in the bluegill sunfish study, including loss of equilibrium, loss of vertical 

orientation, labored respiration, and lying on the bottom. The NOAEC for this study, based on 

sublethal effects and mortality, was 210 μg total a.i./L. The LC50 based on bluegill sunfish will

be used to assess risk of indaziflam use to freshwater fish. In the rainbow trout study, loss of 

equilibrium was only observed at the highest treatment group at 4 hours; complete mortality in 

this treatment group at 24 hours precluded the ability to observe sublethal effects thereafter. The 

NOAEC was based on mortality, at a value of 420 μg a.i./L. Sublethal effects were observed in 

the three highest treatment levels in the the fathead minnow study. Sublethal effects such as loss 

of equilibrium and erratic behavior were observed to be dose-dependent and resulted in a 

NOAEC of 270 μg total a.i./L. All concentrations reported from these studies are in units of 

total active ingredient per Liter (total a.i./L). Indaziflam was tested up to its solubility limit and 

centrifugation was not conducted to determine the dissolved concentration of indaziflam in the 

test media. Thus, there is uncertainty whether the reported measured concentrations in the media 

are equivalent to the dissolved concentrations that the fish are exposed to. These studies were 

classified Supplemental. 

 Two acceptable studies evaluated the toxicity of the degradates FDAT and indaziflamcarboxylic acid on freshwater fish using the fathead minnow. Both demonstrate a toxicity 3 

times less than that of indaziflam, with 96-hour LC50 values of >101,000 μg a.i./L for FDAT 

(MRID 47443230) and >103,000 μg a.i./L for indaziflam-carboxylic acid (MRID 47443231). 

There were no effects on mortality, and no sublethal effects observed in the controls or treatment 

levels. Based on these results, FDAT and indaziflam-carboxylic acid are categorized as 

practically nontoxic to freshwater fish on an acute exposure basis. Both studies are scientifically 

sound but were classified supplemental for not fulfilling guideline requirements for test 

substance (ie. studies of the TGAI, rather than of degradates or formulations, fulfill guideline 

requirements under 40 CFR Part 158). 

 

 One acute 96-hour freshwater fish study was submitted on the toxicity of the indaziflam 

formulation (SC500; 45% ai) to bluegill sunfish (MRID: 47743305). By 48 hours onward, the 

percent mortalities did not change until the study was terminated at 96 hours. By 48 hours, 

percent mortalities were recorded as 0 (control), 0, 0, 80, 100, and 100%, for the mean-measured 

treatment levels, 0 (control), 113, 225, 451, 902, and 1,800 μg total a.i./L, respectively. The 96-

hour LC50 was 372 μg total ai/L, equivalent to 825 μg total form/L. The NOAEC for mortality 

and sublethal effects was 251 μg total ai/L, equivalent to 557 μg total form/L. Sublethal effects 

were dose-dependent and included fish on the bottom of the aquarium, dark coloration, 

hyperactivity, inactivity, labored respiration, loss of equilibrium with lateral deviation, and/or 
-Page 51 of 292- 

laying on their sides or backs. This study is scientifically sound but was classified Supplemental 

because test media was not centrifuged prior to test substance analysis which is a guideline 

recommendation when test substances are tested up to their solubility limit. Thus, all reported 

measured concentration values are total concentrations of test substance in the test media. Based 

on this study, both Indaziflam SC 500 g/L and indaziflam technical are categorized as highly 

toxic to bluegill sunfish (Lepomis macrochirus) on an acute exposure basis. 

Chronic Effects 

 A 35-day chronic toxicity study (MRID 47443236) of indaziflam to the early-life stages 

of the fathead minnow (P. promelas) resulted in a NOAEC and LOAEC of 464 and 1020 μg 

total a.i./L, respectively, based on fry survival (at day 35), total length (at day 35), and dry 

weight (at day 35). The study began by exposing fertilized eggs/embryos to concentrations of 

indaziflam and ended 35 days later. The following parameters were measured: alevin survival 

(day 5), fry survival (day 35), percent hatch (day 5), and total length and weight (day 35). Based 

on fry survival, the LC50 value is likely to lie between 464.4 and 1020 μg total ai/L. Mortality 

was usually preceded by loss of equilibrium, lying on the bottom, and/or labored respiration. 

This study was classified Supplemental because a significant statistical difference (13%, p < 

0.01) was found between negative and solvent controls for mean dry weight of fish. 

Furthermore, centrifugation was not conducted as part of the analysis for dissolved test 

substance; thus all reported measured concentration values are total concentrations of dissolved 

and undissolved test substance. 

 No chronic toxicity studies of indaziflam’s formulations or degradates in freshwater fish 

were submitted. 

3.3.1.2. Toxicity to Freshwater Invertebrates 

Acute Effects 

An acute toxicity study with TGAI using D.magna/water flea (MRID 47443226) yielded 

a 48-hour EC50 and NOAEC value (where immobility was a proxy for lethality) of >9,880 μg 

total a.i./L and 4,860 μg total a.i./L, respectively. At the highest dose tested, 9,880 μg total 

a.i./L, immobility occurred in 35% of daphnids suggesting that indaziflam would be categorized 

as moderately toxic to slightly toxic to freshwater invertebrates on an acute exposure basis. The 

observed sublethal effects were dose-dependent and included quiescence, resulting in a 48-hour 

NOAEC of 4,860 μg total a.i./L. While a definitive EC50 could not be defined at 9,880 μg/L, the 

solubility of indaziflam’s isomers range from 1,200 – 4,400 μg/L (MRID 47443202) which 

could have inhibited the testing of indaziflam’s toxicity at concentrations greater than 9,880 

μg/L. This study is classified Supplemental because centrifugation was not conducted at test 

termination to determine the dissolved test substance concentration in the test media; thus, all 

reported measured concentration values are total concentrations of test substance in the test 

media. 

 

Two studies on indaziflam formulation were submitted using D. magna/waterflea. In one 

study, MRID 47743303, daphnids were exposed to indaziflam SC 500g/L for 48 hours and 

mortality rates of 10% and 5% were observed in the highest concentration levels tested, 18,000 
-Page 52 of 292- 

μg total a.i./L and 38,000 μg total a.i./L respectively. The 48-hour NOAEC (based on sublethal 

effects) and EC50 values were <2,300 and >38,000 μg total ai/L, respectively, which are 

equivalent to <5,100 and >84,000 μg total form/L, respectively. Sublethal effects such as lying 

on the bottom, quiescent, and paleness, were observed in all concentrations. The other study, 

MRID 47743304, evaluated the 48-hour acute toxicity of the formulated product BSC-AA10717 

SC 200 g/L under static conditions. The NOAEC (based on immobility) and EC50 values were 

8,260 and 37,500 μg total ai/L, respectively, which were equivalent to 43,000 and 195,000 μg 

total formulation/L. Besides treatment-related immobility, no further behavioral effects were 

observed. Both of these tests show dissolution of the active ingredient at concentrations 

exceeding its solubility limit (1,200 – 4,400 μg/L; MRID 47443202). Both of these studies were 

classified Supplemental because the test media was not centrifuged at test termination to 

determine the dissolved concentrations of test substances; thus, all reported measured 

concentration values are total concentrations of test substances in the test media. Based on these 

two studies, the formulated products do not show greater toxicities than the TGAI to freshwater 

invertebrates. 

 A scientifically sound subacute freshwater whole sediment toxicity test provided toxicity 

data on freshwater benthic invertebrates (MRID 47443238). Study endpoints are provided for 

pore water concentrations, as seen in Table 3.14, as well as for the sediment and overlying water 

concentrations. The mean measured concentrations in pore water are used to assess the potential 

toxicity of indaziflam to sediment-dwelling freshwater invertebrates because it is presumed that 

exposure occurs in the pore water, rather than the in sediment or water column. The study was 

conducted for 10 days using spiked natural sediment and evaluated the toxicity of the TGAI on 

midge (Chironomus tentans) survival. With two overlying water volume changes/day, and 

acetone used as the solvent, there were no apparent problems with water quality. Following 10 

days of exposure, percent survival averaged 91 to 98%. The 10-day LC50 based on pore water 

concentrations was >2,200 μg a.i./L; the 10-day LC50 based on mean-measured sediment 

concentrations was >100,000 μg a.i./kg sediment dw; the 10-day EC50 based on mean-measured 

overlying water concentrations was >180 μg total a.i./L. Centrifugation of test media was not 

conducted for the overlying water; thus, there is uncertainty in the dissolved quantity of test 

substance in the test media given indaziflam’s solubility of 1,200 – 4,400 μg/L (MRID 

47443202). The overlying water endpoints from the study are reported as total concentrations of 

the test substance. For this reason, this study was classified Supplemental. Given indaziflam’s 

solubility of 1,200 – 4,400 μg/L (MRID 47443202), the pore water LC50 could have been 

potentially limited by inhibited dissolution of the chemical. 

 

 There are no acute toxicity data to freshwater invertebrates with indaziflam degradates. 

Chronic Effects 

 A 21-day life-cycle toxicity study with indaziflam TGAI in the water flea was submitted 

by the registrant to establish the chronic toxicity of indaziflam to freshwater invertebrates 

(MRID 47443235). First-generation (F0) survival (parental immobilization), reproduction (time 

to first brood release and neonates per reproductive day), growth (total length and dry weight), 

and sublethal signs of toxicity were assessed. The 21-day NOAEC was 340 μg total a.i./L based 

upon treatment-related effects on growth and neonates per reproductive day at the 800 and 2,000 
-Page 53 of 292- 

μg total a.i./L levels at study termination. The paramenter growth was measured as adult length, 

which was reduced by 2.7% (800 μg total a.i./L) and 23% (2,000 μg total a.i./L), and dry weight, 

which was reduced by 10% (800 μg total a.i./L) and 65% (2,000 μg total a.i./L). Neonates per 

reproductive day measured the number of young produced per adult per day, and was reduced by 

15% and 65% for the 800 and 2,000 μg total a.i./L treatment levels, respectively. This study is 

scientifically sound but does not meet guideline standards because effects to offspring (F1

generation), measured as number of immobilized offspring, were not reported. Furthermore, 

centrifugation was not conducted to determine the measured concentrations of indaziflam 

dissolved in the test media, given indaziflam’s solubility (1,200 – 4,400 μg/L; MRID 47443202). 

This study was classified Supplemental. No precipitates in the test media were reported. 

 No chronic toxicity studies of indaziflam formulations or degradates using freshwater 

aquatic invertebrates were submitted. 

3.3.1.3. Toxicity to Estuarine/Marine Fish 

Acute Effects 

An acute toxicity study on the sheepshead minnow (Cyprinodon variegatus) (MRID 

47443232) reported a 96-hour LC50 of 960 μg total a.i./L. The reported NOAEC of 430 μg total 

a.i./L was based on dose-dependent sublethal effects of loss of equilibrium, loss of vertical 

orientation, and lying on the bottom, as well as mortality. Study results indicate that indaziflam 

is highly toxic to estuarine/marine fish on an acute exposure basis. This study was classified 

Supplemental because centrifugation was not conducted to determine the dissolved concentration 

of indaziflam in the test media. 

 No acute toxicity studies of indaziflam formulations or degradates using estuarine/marine 

fish were submitted. 

Chronic Effects 

 No chronic toxicity tests in estuarine/marine fish with the TGAI, formulations, or 

degradates were submitted. 

3.3.1.4. Toxicity to Estuarine/Marine Invertebrates 

Acute Effects 

Acute toxicity tests with estuarine/marine invertebrates exposed to technical grade 

indaziflam were conducted on Eastern oyster (Crassostrea virginica; MRID 47443228), mysid 

shrimp (Americamysis bahia; MRID 47443227), and a marine amphipod (Leptocheirus 

plumulosus; MRID 47443239). Up to an 88% decrease in shell deposition from control was 

observed in the 96-hour acute toxicity test in the Eastern oyster, yielding a 96-hour EC50 of 920 

μg total a.i./L. The corresponding NOAEC was 470 μg total a.i./L. No mortality occurred in 

either the control or treatment groups. Indaziflam is categorized as highly toxic to 

estuarine/marine mollusks on an acute exposure basis. This study is scientifically sound but 

classified Supplemental because the test media was not centrifuged to determine indaziflam’s 

dissolved concentration within the test vessels; thus, all endpoints are reported as total 
-Page 54 of 292- 

concentrations of indaziflam An acute toxicity study of indaziflam conducted on mysid shrimp 

reported a 96-hour LC50 of 1,500 μg a.i./L, indicating that indaziflam is moderately toxic to 

estuarine/marine invertebrates on an acute exposure basis. Sublethal effects of surfacing, 

lethargy, and erratic swimming were observed in the two highest treatment levels. The NOAEC 

(sublethal effects and mortality) was determined to be 1,100 μg a.i./L. This study is classified 

Acceptable. A precipate was noted at the highest concentration, 5,000 μg a.i./L, presumably 

because this concentration exceeds indaziflam’s solubility limit. The study author reported that 

all samples were centrifuged prior to analysis and recoveries were acceptable (80% of nominal at 

test initiation and 100% of initial at 48 hours). 

 A subacute whole sediment toxicity test on L.plumulosus/amphipod was submitted to 

provide toxicity data on marine benthic invertebrates (MRID 47443239). Study endpoints are 

provided for pore water concentrations, as seen in Table 3.13, as well as for the overlying water 

and sediment concentrations. The mean-measured concentrations in pore water are used to 

assess the potential toxicity of indaziflam to sediment-dwelling saltwater invertebrates because it 

is presumed that exposure occurs in the pore water, rather than in sediment or overlying water. 

The study was conducted for 10 days using spiked natural sediment and evaluated the toxicity of 

indaziflam on amphipod survival. No apparent problems were observed with water quality 

throughout the study. Following 10 days of exposure, percent survival averaged 93 to 100%. 

The 10-day LC50 based on pore water concentrations was > 3,800 μg a.i./L; the 10-day LC50

based on mean-measured sediment concentrations was >180,00 μg a.i./kg sediment dry weight; 

the 10-day LC50 based on mean-measured overlying water concentrations was >1,400 μg total 

a.i./L. Parameters other that mortality were not measured. Centrifugation of test media was not 

conducted for the overlying water; thus, there is uncertainty in the dissolved quantity of test 

substance in the test media given indaziflam’s solubility of 1,200 – 4,400 μg/L (MRID 

47443202). The overlying water endpoints from the study are reported as total concentrations of 

the test substance. For this reason, this study was classified Supplemental. Due to indaziflam’s 

solubility, the pore water LC50 could have been potentially limited by inhibited dissolution of the 

chemical. This study is classified Acceptable. Based on the results of this study, indaziflam is 

categorized as no more than moderately toxic to benthic marine invertebrates on a sub-acute 

exposure basis. 

 No acute toxicity studies of indaziflam formulations or degradates using estuarine/marine 

invertebrates were submitted. 

Chronic Effects 

 No chronic toxicity studies of the TGAI, formulations or degradates using 

estuarine/marine invertebrates were submitted. 

3.3.1.5. Toxicity to Aquatic Plants 

Studies were submitted for a freshwater vascular plant (duckweed, Lemna gibba), bluegreen algae (Anabaena flos-aquae), a freshwater diatom (Navicula pelliculosa), a green algae 

(Pseudokirchneriella subcapitata), and a marine alga (Skeletonema costatum) exposed to the 
-Page 55 of 292- 

technical grade indaziflam, triazine indanone, FDAT, indaziflam-carboxylic acid, indaziflamhydroxyethyl, indaziflam-olefine, and the formulations SC200 and SC500. 

Vascular Aquatic Plants

 Indaziflam was toxic to duckweed as indicated by reductions in frond area observed in a 

tier II, 7-day study, with a reported EC50 value of 0.067 μg a.i./L (MRID 47443250). The 

associated NOAEC was 0.031 μg a.i./L. At test termination, the test material was 87.3 to 96.5% 

of nominal. Another affected measured endpoint was frond number, with an EC50 value of 0.087 

μg a.i./L. A nonguideline study using the TGAI was submitted for a 7-day static study using 

duckweed involving a water/sediment system (MRID 47443256). The test substance was 

applied directly to the water column in nominal concentrations of 0, 0.027, 0.067, 0.167, 0.419, 

and 1.05 μg a.i./L. At test initiation, the TGAI was 78.5 to 114% of the nominal test 

concentrations between 0.067 and 1.05 μg/L, and at test termination, the TGAI was 18.1 to 

20.2% of nominal (the lowest test concentration was not measured). The 7-Day EC50 and 

NOAEC values calculated for frond number, the most sensitive endpoint, using mean-measured 

day-0 concentrations were 0.350 and 0.167 μg a.i./L, respectively. This study is classified 

Supplemental because it was conducted using a sediment layer and standard nutrient medium, 

neither of which fall under current OPPTS guideline recommendations. 

 An acceptable study was submitted on effects to duckweek exposed to the formulated 

product Indaziflam SC500 (MRID 47743308). The most sensitive endpoint was yield based on 

frond number, with 7-Day NOAEC and EC50 values of 0.0194 and 0.061 μg ai/L, respectively, 

which are equivalent to 0.050 and 0.130 μg form/L, respectively. The percent inhibition in the 

treated cultures as compared to control ranged from -7 to 93%. Given that the endpoint derived 

from the TGAI (EC50=0.067 μg a.i./L) is roughly equivalent to the endpoint derived from the 

formulated product, the lower of the two endpoints, the EC50 value of 0.061 μg ai/L and 

associated NOAEC of 0.0194, are used to assess risk of indaziflam use to aquatic vascular plants. 

 

 Five studies were submitted on duckweed exposed to five different metabolites of 

technical grade indaziflam: triazine indanone, FDAT, indaziflam-carboxylic acid, indaziflamhydroxyethyl, and indaziflam-olefine. All but the study on FDAT were classified Acceptable; 

the study with FDAT failed to determine the most sensitive endpoint. A comparison of just the 

most sensitive EC50 endpoints between the metabolites and the technical is presented in Table 

3.15. According to these endpoints, the toxicity of triazine indanone, FDAT, and carboxylic acid 

to duckweed is 3 – 7 orders of magnitude less than that of the parent, while indaziflam-olefine 

and indaziflam-hydroxyethyl are one order of magnitude less toxic than the parent. This 

comparison suggests that indaziflam technical is most toxic to duckweed, and thus the toxicity 

endpoints for indaziflam technical will be used to assess risk of indaziflam use to aquatic 

vascular plants. 
-Page 56 of 292- 

Table 3.15. Most Sensitive EC50 Endpoint Comparison Between Indaziflam (TGAI) and 

Degradates for Aquatic Vascular Plants using Duckweed (Lemna gibba) 

Chemical 

Exposure Scenario Species Toxicity Measurement Affected Endpoint 

Reference 

(Classification)a

Indaziflam1 Duckweed 

(Lemna gibba) 

7-day EC50: 

0.061 μg a.i./L (60-74) 

Slope: 7.92 ± 0.931 

Yield, based 

on frond 

number 

MRID: 47443308 

(Acceptable) 

Indaziflam2 Duckweed (L. 

gibba) 

7-day EC50: 

0.067 μg a.i./L (60-74) 

Slope: 6.05 ± 0.51 

Frond Area MRID: 47443250 

(Acceptable) 

Indaziflam-Olefin Duckweed 

(L. gibba) 

7-day EC50: 

0.34 μg a.i./L (0.16-0.74) 

Slope: 1.36 ± 0.21 

Frond Area MRID: 47443255 

(Acceptable) 

IndaziflamHydroxyethyl Duckweed 

(L. gibba) 

7-day EC50: 

0.51 μg a.i./L (0.47-0.55) 

Slope: 5.95 ± 0.50 

Frond Area MRID: 47443254 

(Acceptable) 

Triazine-indanone Duckweed (L. 

gibba) 

7-day EC50: 

12 μg a.i./L (7.5-19) 

Slope: 2.15 ± 0.33 

Frond Area MRID: 47443251 

(Acceptable) 

FDAT Duckweed 

(L. gibba) 

7-day EC50: 

51 μg a.i./L 

Slope: 1.51 ± 0.37 

7-day EC50:

> 35.15 μg a.i./L 

Slope: N/A 

7-day EC50:

> 35.15 μg a.i./L 

Slope: 5.92 ± 0.47 

Frond 

Number 

Frond Area 

Frond Area 

based on 

growth rate 

MRID: 47443252 

(Supplemental) 

IndaziflamCarboxylic Acid Duckweed 

(L. gibba) 

7-day EC50: 

4,000 μg a.i./L (1,500-11,000) 

Slope: 1.36 ± 0.28 

Frond 

Number 

MRID: 47443253 

(Acceptable) 

1

 This endpoint for indaziflam is derived from a study on the formulated product Indaziflam SC500. 2

 This endpoint for indaziflam is derived from a study on the technical grade product. 

Nonvascular Aquatic Plants

 Tier II, 96-hour toxicity tests of freshwater nonvascular plants with technical grade 

indaziflam resulted in the most sensitive 96-hour EC50 values ranging from 74 μg a.i./L for 

reductions in biomass in Pseudokirchneriella subcapitata (MRID 47443261; Acceptable), to 77 

μg a.i./L for reductions in biomass in a second study on P. subcapitata (MRID 47743309; 

Acceptable), to 87 μg total a.i./L for reductions in biomass in N. pelliculosa (MRID 47443266; 

Supplemental), and to 750 μg total a.i./L for reductions in cell density in A. flos-aquae (MRID 

47443268; Supplemental). These latter two studies were classified Supplemental because 

indaziflam was tested up to its solubility limit and test media was not centrifuged to determine 

the its dissolved concentrations; thus, concentrations are reported as total concentration of 

indaziflam. A tier II, 96-hr toxicity test with a marine diatom S. costatum resulted in an EC50

value of 27 μg a.i./L based on reduced biomass (MRID 47443267; Acceptable). The 

corresponding NOAEC is 5.1 μg a.i./L. The study using the marine diatom will be used to assess 

effects of indaziflam on aquatic nonvascular plants. 

 Four 72-hour toxicity studies on P. subcapitata using four different metabolites were 

submitted: FDAT (MRID 47443262), carboxylic acid (MRID: 47443263), indaziflam-
-Page 57 of 292- 

hydroxyethyl (MRID: 47443264), and indaziflam-olefin (MRID: 47443265). These studies were 

classified Supplemental for not meeting guideline recommendations for a 96-120 hour study 

duration, among other minor deviations. Two 72-hour studies with formulated products were 

also submitted on the toxicity of BCS-AA10717 SC 500 g/L (MRID 47743310; Supplemental) 

and BCS-AA10717 SC 200 g/L (MRID 47743311; Supplemental) to P. subcapitata. These 

studies were also classified Supplemental for not meeting guideline recommendations for study 

duration. 

A comparison of the EC50 toxicity on P. subcapitata at 72 hours was made between the 

metabolite endpoints and the endpoints for technical grade indaziflam and is presented in Table 

3.16. As the endpoints indicate, indaziflam-olefin’s toxicity is of the same order of magnitude as 

the TGAI, and indaziflam-hydroxyethyl’s toxicity is of one order of magnitude less toxic than 

the parent compound. Carboxylic acid and diaminotrizaine show toxicity to P. subcapitata at 2-

3 orders of magnitude less than that of the parent. 

Table 3.16. Comparison of 96-hr and 72-hr EC50 values Between Indaziflam (TGAI), its 

Degradates, and Formuted Products, for Green Algae (Pseudokirchneriella subcapitata)

Chemical 

Exposure 

Scenario Species Toxicity Measurement Affected 

Endpoint 

Reference 

(Classification)a

Indaziflam1 Green Algae 96-hr EC50: 

77 μg a.i./L (69-84) 

Slope: 6.34 ± 0.617 

Biomass MRID: 47743309 

(Acceptable) 

Indaziflam1 Green Algae 96-hr EC50: 

74 μg a.i./L (62-88) 

Slope: 4.43 ± 0.56 

72-hr EC50:

64 μg a.i./L (51-79) 

Slope: 3.71 

72-hr EC50:

64 μg a.i./L (54-76) 

Slope: 3.49 

Biomass 

Cell Density 

Biomass 

MRID: 47443261 

(Acceptable) 

Indaziflam2 Green Algae 72-hr EC50: 

51 μg a.i./L (34-75) 

Slope: 3.12 ± 0.553 

Cell Density MRID: 47743310 

(Supplemental) 

Indaziflam3 Green Algae 72-hr EC50: 

53 μg a.i./L (39-73) 

Slope: 2.67 ± 0.383 

Cell Density MRID: 47743311 

(Supplemental) 

IndaziflamOlefin Green Algae 72-hr EC50:

54 μg a.i./L (47-61) 

Slope: 2.66 ± 0.23 

Biomass MRID: 47443265 

(Supplemental) 

IndaziflamHydroxyethyl Green Algae 72-hr EC50:

550 μg a.i./L (320-950) 

Slope: 3.20 ± 0.80 

Cell Density MRID: 47443264 

(Supplemental) 

IndaziflamCarboxylic Acid Green Algae 72-hr EC50:

> 9,400 μg a.i./L 

Slope: N/A 

Could not be 

determined 

MRID: 47443263 

(Supplemental) 

Diaminotriazine Green Algae 72-hr EC50:

11,000 μg a.i./L (9400-14000) 

Slope: 2.86 ± 0.23 

Cell Density MRID: 47443262 

(Supplemental) 

1 Study on technical grade indaziflam. 

2

 Study on the formulated product, Indaziflam SC 500 g/L. 

3

 Study on the formulated product, Indaziflam SC 200 g/L 
-Page 58 of 292- 

Tier III Field Studies

 A 69-day field study was submitted to provide supplemental data based on the Ecological 

Effects Test Guidelines OPPTS 850.4450: Aquatic Plants Field Study, Tier III (MRID 

47443257). Although classified Supplemental, the study does provide valuable information 

regarding the expected biological effects (particularly to macrophytes) derived from nominal 

applications of 0 (control), 0.01, 0.032, 0.10, 0.32, 3.20, 10.0 μg a.i./L of the formulated product 

indaziflam 500 g/L to lentic (static), shallow macrophyte-dominated freshwater ecosystems (i.e. 

20 artificial freshwater ponds exposed to natural sunlight and weather conditions). The test 

substance was introduced once into the outdoor microcosms located at the Sinderhoeve 

Experimental Station, The Netherlands. The study looked at effects to macrophytes, 

phytoplankton, zooplantkton, and community metabolism (assessed via the endpoints alkalinity, 

pH, electrical conductivity (EC), and dissolved oxygen (DO)). A parallel in situ bioassay with 

duckweed was also conducted that sectioned off the duckweed from the rest of the pond, while 

keeping the water quality and natural conditions the same. On day 69, at the end of the 

experiment, approximately 14 – 23% of the nominal concentration could still be detected. 

Another study was submitted (MRID 47443258) that was conducted as a non-guideline 

preliminary/screening test to the aforementioned in-depth, supplemental tier III field study. In 

this nonguideline study, the toxicity of technical grade indaziflam was investigated for 6 weeks 

following a single overlying water application to artificial outdoor ponds containing eight aquatic 

plant species. The water lily (Nymphaea odorata) was the most sensitive species, exhibiting red 

spotting of the (old growth) leaves, chlorotic leaves, and/or curled leaves at all treatment levels: 

control, 0.32, 1.0, and 3.2 μg/L. The resultant NOAEC for sublethal effects was <0.32 μg a.i./L. 

Terminal (day 42) dry weight biomass was also statistically-reduced compared to the control at 

the 1.0 and 3.2 μg a.i./L levels. 

 Overall, in the field study microcosms, macrophyte species were far more sensitive than 

phytoplankton and zooplankton taxa. Of the macrophyte species investigated, the lemnids (L. 

gibba, Spirodela polyrhiza) were the most sensitive, with a NOAEC of 0.01 μg ai/L. The vast 

majority of non- lemnid vascular plants began to exhibit clear effects at the 1.0 μg ai/L level, and 

no recovery was indicated at the 3.2 and 10.0 μg ai/L levels. Vascular plants that showed a 

relatively minor growth in controls (e.g., Ceratophyllum demersum, Ranunculus circinatus, and 

Lemna trisulca) were hardly affected by the test compound. In the microcosm community, 

metabolism endpoints showed relatively minor treatment-related effects, which may be 

explained by the fact that certain primary producers (e.g., Chara) were not affected at all by the 

herbicide. 

 The data provided are beneficial in assessing the effects of the test material on various 

taxa, primarily macrophytes; however, the test deviates from guidelines because only two 

replicate microcosms (ponds) were tested for each treatment level, whereby limiting statistical 

power in assessing results on the pond community as well as on individual taxa; The number of 

replicates was not large enough to assure statistically significant results at the 90-95 percent level 

of confidence, nor large enough to support the 50 percent (EC50) progression criteria statistically. 

It was concluded that for all assessed endpoints for L. gibba (number of fronds, percent growth 
-Page 59 of 292- 

of fronds, and dry weight), the NOAEC was 0.01 μg ai/L during the first 14 days post-treatment. 

The difference in frond numbers at day 14 were considerably larger than the difference at day 7: 

mean frond numbers on day 7 for the 0.01 and 0.032 μg ai/L treatments were 96 and 86, while on 

day 14 the values were 211 and 83. These numbers suggest that the toxicity of the compound is 

not necessarily expressed early on. The NOAEC of 0.01, although derived from a longer 

duration exposure, corresponds in magnitude with the NOAEC of 0.031 μg a.i./L from the 7-day 

toxicity study using L. gibba (MRID 47443250) with a reported EC50 value of 0.067 μg a.i./L. 

3.3.2 Terrestrial Effects Characterization 

The most sensitive acute and chronic toxicity reference values associated with indaziflam 

exposure to mammals, birds, and terrestrial insects are summarized in Table 3.17. The most 

sensitive measurement endpoints for tier II terrestrial plants toxicity data are presented in Table 

3.18. 

 Two studies evaluated the acute toxicity of indaziflam on rats and found indaziflam to be 

practically non-toxic. Four more studies were submitted to evaluate four proposed enduse 

products’ toxicity to rats. These four formulations tested are representative of all proposed nonfood use formulation, and indicate that the various formulations are practically non-toxic to rats 

on an acute exposure basis. The proposed formulations intended for food-uses are not evaluated 

at this time and are not considered as part of this assessment. A 2-generation study on 

reproduction and fertility in the rat showed indaziflam to cause chronic toxicity effects in the 

parents and F1 and F2 generations that would impact reproductive capabilities. 

 Studies of acute oral (dose-based) toxicity in bobwhite quail (Colinus virginianus) and 

zebra finch (Poephila guttata) indicated that indaziflam is practically nontoxic to bobwhite quail 

and zebra finch when administered a single oral dose. Two subacute dietary toxicity studies 

demonstrated that indaziflam TGAI is also practically nontoxic to mallard duck (Anas 

platyrhynchos) and bobwhite quail on a subacute dietary exposure basis. For chronic effects, 

treatment-related effects on adult female weight gain, adult food consumption, and male weight 

gain were observed in two reproductive toxicity studies of indaziflam TGAI in mallard duck. No 

studies of the formulations or the degradates were submitted; all measurement endpoints for 

avian species are based on technical grade indaziflam. 

 Results of available toxicity studies indicate that indaziflam TGAI is practically nontoxic 

to honey bees (Apis mellifera) and earthworms (Eisenia foetida) on an acute contact exposure 

basis. 

 Tier II studies of the effect of the indaziflam formulations BCS-AA10717 20WSP and 

Indaziflam 500 SC on seed emergence and vegetative vigor in terrestrial plants were submitted, 

indicating that terrestrial plants are sensitive to indaziflam at application rates much less than the 

proposed registration uses. 
-Page 60 of 292- 

Table 3.17. Indaziflam Technical Grade Toxicity Measurement Endpoints for Terrestrial 

Animals. 

Exposure 

Scenario 

Species Exposure 

Duration 

Toxicity Reference Value Reference 

(Classification) 

Mammals 

Acute 

(Dose-based) 

Laboratory rat Single oral dose LD50 > 2000 mg a.i./kg bw MRID 47443280 

Acceptable 

MRID 47443281 

Acceptable 

Chronic 

(Dietary-based) 

Laboratory rat Two-generation NOAEL = 69 mg/kg bw/day 

LOAEL = 317 mg/kg bw/day 

Endpoints based on parental, 

offspring, and reproductive 

signs of toxicity to males 

MRID 47443293 

Acceptable 

Birds 

Acute 

(Dose-based) 

Bobwhite quail 

Colinus 

virginianus

14-day single 

oral dose 

LD50 >2000 mg a.i./kg bw 

NOAEL: 2000 mg a.i./kg bw 

MRID 47443240 

(Acceptable) 

Acute 

(Dose-based) 

Zebra Finch 

Poephila 

guttata 

14-day single 

oral dose 

LD50 >2000 mg a.i./kg bw MRID 47443240 

(Acceptable) 

Bobwhite quail 

Colinus 

virginianus

8-day dietary LC50: >5007 mg ai/kg diet 

NOAEC: 5007 mg ai/kg diet 

 

MRID 47443241 

(Acceptable) 

Acute 

(Dietary-based) 

Mallard duck 

Anas 

platyrhynchos 

8-day dietary LC50: >5215 mg ai/kg diet 

NOAEC: 2518 mg ai/kg diet 

(based on treatment related 

effects on body weight and feed 

consumption) 

 

MRID 47443242 

(Acceptable) 

Chronic1 

(Dietary-based) 

Mallard duck 

Anas 

platyrhynchos

ca. 22 week 

avian 

reproduction 

study 

LOAEC: 95 mg ai/kg diet 

NOAEC: < 95 mg ai/kg diet 

(based on female weight gain 

and mean food consumption) 

MRID 47443244 

(Supplemental) 

Chronic1 

(Dietary-based) 

Mallard duck 

Anas 

platyrhynchos

ca. 6 week 

avian 

reproduction 

study 

LOAEC: 44 mg ai/kg diet 

NOAEC: < 44 mg ai/kg diet 

(based on male weight gain) 

MRID 47443244 

(Supplemental) 

Terrestrial Invertebrates 

Acute 

(Contact) 

Honeybee 48-hour LD50 >100 μg a.i./bee 

NOAEL: 100 μg ai/bee 

MRID 47443245 

(Acceptable) 

Acute 

(Oral) 

Honeybee 48-hour LC50 >120 μg a.i./bee 

NOAEC: 120 μg ai/bee 

MRID 474432452 

Acute Earthworm 14-day LC50 > 1,000 mg a.i./kg dw soil 

NOAEC: 316 mg a.i./kg dw soil 

LOAEC: 562 mg a.i./kg dw soil 

MRID 47443269 

(Supplemental)3 

1

 Both chronic avian study endpoints will be used to assess potential chronic risk of indaziflam to birds. 2

 The acute oral study was not classified because it was provided as supplemental information to the acute contact study. Acute oral honey bee 

studies are non-guideline studies and can at best be classified Supplemental. 3

 The earthworm study was conducted as an acute rather than chronic test and is thus a non-guideline study. 
-Page 61 of 292- 

Table 3.18. Indaziflam Toxicity Measurement Endpoints for Terrestrial Plants. 

Exposure 

Scenario 

Formulation Species Exposure 

Duration 

Toxicity Reference Value Reference 

(Classification) 

Plants – Seedling Emergence 

Monocot BCSAA10717 

20WSP 

Ryegrass 21-day test -

single 

application 

EC25 (survival) = 0.00016 lbs 

a.i./A 

95% C.I.: 0.00009 to 0.0003 

lbs a.i./A 

Slope: 2.45 

NOAEC = 0.000062 lbs a.i./A 

MRID 47443246 

(Acceptable) 

Dicot BCSAA10717 

20WSP 

Oilseed 

rape 

21-day test - 

single 

application 

EC25 (emergence) = 0.00011 

lbs a.i./L 

95% C.I.: 0.000053 to 

0.00024 lbs a.i./A 

Slope: 1.81 

NOAEC = 0.000062 lbs a.i./A 

MRID 47443246 

(Acceptable) 

Plants – Vegetative Vigor 

Monocot Indaziflam 

500 SC 

Ryegrass 21-day test -

single 

application 

EC25 (survivial) = 0.0021 lbs 

a.i./A 

95% C.I.: 0.00134 to 0.0032 

lbs a.i./A 

Slope: 2.94 ± 0.433 

NOAEC: 0.000932 lbs a.i./A

MRID 47443249 

(Supplemental)1

Dicot BCSAA10717 

20WSP 

Turnip 21-day test -

single 

application 

EC25 (dry weight) = 

>0.000906, <0.00227 lbs 

a.i./A 2 

95% C.I.: N/A 

Slope: N/A 

NOAEC = <0.000906 lbs 

a.i./A 

MRID 47443248 

(Supplemental) 

1

 This study failed to define a NOAEC or EC05 corresponding to the lowest EC25 for dicots (ie. soybean). 2

 Inhibition at 0.000906 lbs a.i./A was 18%; inhibition at 0.00227 lbs a.i./A was 31%. An adequate dose-response relationship could not be 

constructed to calculate an EC25 between these two concentrations. 

3.3.2.1. Toxicity to Mammals 

Acute Effects

Two acceptable acute oral toxicity studies using female rats were submitted for 

indaziflam. One study (MRID 47443280) derived a 14-day oral LD50 value of > 2,000 mg a.i./kg 

bw. The study was comprised of two groups of 3 female rats, each given a single oral dose of 

2,000 mg/kg bw. No clinical signs or toxicological effects on body weight or weight gain were 

observed, and no gross pathological changes in animals sacrificed were observed. Another study 

(MRID 47443281) also derived a 14-day oral LD50 value of > 2,000 mg a.i./kg bw and was 

comprised of two groups of 3 female rats, each given a single oral dose. One female rat died but 

it was reported that no clinical signs or toxicological effects on body weight or weight gain were 

observed, and that no gross pathological changes were observed in animals sacrificed.

 Four acceptable acute oral 14-day toxicity studies using rats were submitted for the 

following end-use products: Lawn 3FL Herbicide Concentrate (Ready-to-Spray); Lawn 3FL 

Herbicide Granule; BCS AA10717 20 WSP; and BSC AA10717 2% MUP. Both the Lawn 3FL 

Herbicide Concentrate (Ready-to-Spray) and the Lawn 3FL Herbicide Granule are formulated 
-Page 62 of 292- 

products with multiple active ingredients. A study with Lawn 3FL Herbicide Concentrate 

(Ready-to-Spray), MRID 47489302, a formulated product containing 2,4-D dimethylamine salt, 

dicamba (potassium salt), and mecoprop-P (potassium salt), in addition to indaziflam, derived an 

oral LD50 value for female rats of >2,000 mg/kg bw. A study with Lawn 3FL Herbicide Granule, 

MRID 47489202, a formulated product containing dicamba acid and penoxsulam, in addition to 

indazflam, derived an oral LD50 value for female rats of >2,000 mg/kg bw. For both these 

studies with multiple actives ingredients, all test rats survived and gained weight, no clinical 

signs of toxicity were observed, and no gross abnormalities were noted at necropsy. A third 

formulated product study with BCS AA10717 20 WSP, MRID 47488802, derived an oral LD50

value for female rats of >2,000 mg/kg bw, with no clinical signs or gross pathological findings 

observed. A fourth study was conducted with the formulated product BCS-AA10717 2% MUP 

(2.0% indaziflam) (MRID: 47488702), indended for manufacturers’ use only for the purpose of 

manufacturing end-use herbicide products. The study found the acute oral LD50 value for female 

rats to be > 5,000 mg/kg bw. No gross internal findings were observed at necropsy, and while 2 

out of the three 3 test animals were hypoactive immediately after dosing, both animals recovered 

by day 1. All test animals appeared active and healthy for the remainder of the study. 

 An acute oral rat toxicity study was not conducted with the formulated product Lawn 3FL 

Herbicide Ready-to-Use, containing 2,4-D dimethylamine salt, dicamba (potassium salt), and 

mecoprop-P (potassium salt), in addition to indaziflam. Since this formulation is a dilution of 

the formulated product Lawn 3FL Herbicide Concentrate, the submitted data on the concentrate 

formula was deemed adequate to assess the potential toxicity of the ready-to-use formulation 

(MRID 47489402). The data on all three proposed formulated products with multiple active 

ingredients indicate that indaziflam mixed with other active ingredients is not more toxic than 

indaziflam alone based on the acute oral toxicity to the rat. 

Chronic Effects 

 An acceptable 2-generation Wistar rat (Ratus norvegicus) reproduction and fertility 

effects study using indaziflam technical was submitted to establish the toxicity of indaziflam to 

mammals over prolonged periods (MRID 47443293). The overall NOAEL and LOAEL for the 

study were 69/85 mg/kg bw/day (male/female) and 317/355 mg/kg bw/day (male/female), 

respectively, based on parental, offspring, and reproductive toxicity (sexual maturation of F1 and 

F2 pups). Observable adverse effects for parental toxicity included course tremors in females, 

decreased body weights, decreased body weight gains, and decreased food consumption in both 

sexes, and effects on kidneys (tubular degeneration/regeneration; increased kidney weights) in 

the males. The study did not determine whether the effects on the parental generation resulted 

from loss of appetite due to chemical poisoning or decreased food palatability. Effects observed 

for offspring toxicity included decreased body weights, body weight gains, and secondary delays 

in sexual maturation. For reproductive toxicity, the NOAEL and LOAEL were based on delayed 

sexual maturation in F1 and F2 pups. The male NOAEL, at 69 mg/kg bw/day, will be used to 

assess chronic risk of indaziflam use to mammals. 
-Page 63 of 292- 

3.3.2.2. Toxicity to Birds 

Acute Effects 

 An acceptable acute oral (dose-based) toxicity study of indaziflam TGAI in bobwhite 

quail (MRID 47443240) was submitted. A single oral dose of 2000 mg a.i./kg body weight did 

not elicit any treatment-related effects on any parameter in bobwhite quail for the study duration 

of 14 days, indicating that indaziflam TGAI is practically nontoxic to young adult bobwhite quail 

on an acute oral exposure basis. A second acceptable acute oral (dose-based) test was submitted 

for indaziflam on the zebra finch (Poephila guttata) demonstrating indaziflam to be practically 

non-toxic to this avian species (MRID 47743306). The 14-day acute oral LD50 was >2000 mg 

ai/kg body weight. One mortality did occur and gross necropsy demonstrated that the bird’s 

death was related to intestinal and respiratory problems. There is insufficient evidence to 

determine whether or not this mortality and/or intestinal and respiratory problems were 

treatment-related. Observed clinical signs of toxicity in the treatment group included slightly 

ruffled to ruffled appearance, reduced reaction to stimuli (i.e. sound and movement), wing droop, 

and lethargy. The study tested the limit dose of 2,000 mg ai/kg body weight as recommended in 

EPA guidelines; thus, a NOAEL could not be defined for sublethal effects observed at this dose 

level. 

 Subacute (8-day) dietary toxicity studies in bobwhite quail (MRID 47443241) and 

mallard duck (MRID 47443242) established LC50 values of >5007 mg ai/kg diet and >5215 mg 

ai/kg diet, respectively, indicating that indaziflam TGAI is practically nontoxic to birds on a 

subacute dietary basis. No mortality, clinical signs of toxicity, or sublethal effects were observed 

in bobwhite quail over the 8 day study period. In the mallard study, apparently transient 

treatment-related reductions in body weight and food consumption during the first three days at 

the 5125 mg a.i./kg diet level was reported. The NOAEC for this study was 2518 mg a.i./kg diet. 

Study details and results are summarized in Appendix C, Table C-10. 

 No acute toxicity studies were submitted for birds exposed to indaziflam formulations or 

degradates. 

Chronic Effects

 Two chronic studies of the reproductive toxicity of indaziflam TGAI in bobwhite quail 

(MRID 47443243) and mallard duck (MRID 47443244) are available. Study details and results 

are summarized in Appendix C, Table C-11. Results of the ca. 23 week one-generation 

reproductive toxicity study in bobwhite quail showed no treatment-related effects on any adult or 

offspring parameter at any concentration level. The LOAEC and NOAEC for this study were 

>1,023 mg ai/kg diet and 1,023 mg ai/kg diet, respectively. The second reproductive toxicitiy 

study on mallard duck was conducted over ca. 22 weeks and established a LOAEC and NOAEC 

of 95 mg ai/kg diet and <95 mg ai/kg diet, respectively, based on female weight gain and adult 

food consumption. To clarify and reinforce conclusions drawn from the original mallard duck 

study, a 19-week supplemental study was conducted on mallard duck, although the test substance 

(indaziflam) was only administered in the diet during the final 6 weeks of the test (egg-laying 

phase); test concentrations were also lower than the primary study. Effects to adult male weight 

gain were observed in the modified secondary study at all three treatment levels (44, 157, and 
-Page 64 of 292- 

468 mg a.i./kg) and effects to female weight gain were observed at the two highest treatment 

levels (157, and 468 mg a.i./kg). However, there is uncertainty in the effects observed to male 

weight gain because there was a net mean weight loss, rather than weight gain, for all treatment 

levels and control. The results of the secondary study are not directly comparable to the results 

from the primary study since birds in the secondary study were only dosed for 6 weeks. 

However, the results of the secondary study provide supporting evidence that indaziflam has 

effects on adult male and female weight gain. The NOAEC of <44 mg a.i./kg based on male 

weight gain, and the NOAEC of 44 mg a.i./kg based on female weight gain in the secondary 

study supports the NOAEC <95 mg ai/kg determination made in the primary study based on 

female weight gain and adult food consumption. The NOAEC of <95 mg ai/kg diet from the 

primary study, which assessed effects over a length of time (ca. 22 weeks) meeting guideline 

recommendations, will be used to assess chronic risk of proposed indaziflam use to birds. The 

NOAEC of <44 mg ai/kg from the secondary study, which was derived from a reproductive 

study of only 6 weeks, will be discussed further in the risk description to characterize chronic 

risk of proposed indaziflam uses to birds. 

 The lot of birds for the primary and secondary study was considered to be in good health, 

and no mortalities were reported during the acclimation period. It should be noted that not all 

validity criteria were met in the primary study: egg shell thickness in control birds measured 0.33 

mm, less than the definitive test criteria requirement of 0.34 mm, indicating potential stress to the 

birds. Cage size was also reported to be 2410 cm2

/adult bird, rather than the recommended 

10,000 cm2

/adult bird. The mallard duck toxicity study (MRID 47443244) was classified 

Supplemental for failure to determine a definitive NOAEC and for not meeting all validity 

requirements. 

 No chronic toxicity studies of indaziflam formulations or degradates in avian species 

were submitted. 

3.3.2.3. Toxicity to Terrestrial Invertebrates 

Acute Effects 

An acceptable acute contact toxicity study in honey bees using technical grade indaziflam 

yielded a 48-hour contact LD50 >100 μg a.i./bee (MRID 47443245), indicating that indaziflam is 

practically nontoxic to honey bees on an acute contact exposure basis. No mortalities or 

sublethal effects were noted in the control or single treatment level, yielding a NOAEL value of 

100 μg a.i./bee. A nonguideline acute oral toxicity study (MRID 47443245) was submitted 

along with the acute contact study and established an acute oral 48-hour LC50 >120 μg a.i./bee 

for indaziflam TGAI in honey bees. The corresponding NOAEC based on lack of mortality and 

sublethal effects was 120 μg a.i./bee. This study was found scientifically sound and provides 

useful toxicity data for risk assessment purposes. 

 

An acceptable acute contact study and a nonguideline acute oral toxicity study in honey 

bees with the formulated product AE1170437 SC 500 were also submitted (submitted under the 

same MRID: 47743307). By 48 hours in the oral test, mortality was 0%. There were no 

sublethal effects in the control or treated groups. By 48 hours in the contact test, mortality was 
-Page 65 of 292- 

1.7% (one bee died). Study results include a 48-hour LD50 >100 μg a.i./bee (contact study) and 

an LC50 >119.7 μg ai/bee (oral study). Study details and results are summarized in Appendix C, 

Table C-12. Uncertainties associated with the honey bee toxicity data include that the studies 

examine effects only on young adult forage (female) bees and not on potential effects to the 

queen, drones (males), juvenile (nurse) and larval (brood) bees. 

Five earthworm acute toxicity studies were submitted on indaziflam, the formulated 

product BCS-AA10717 SC 500 g/L, and the degradates FDAT, triazine indanone, and carboxylic 

acid. All five studies with the technical, degradates, and formulated product were conducted as 

acute 14-day studies following recommendations outlined in the OECD 207 guideline, 

“Earthworm, Acute Toxicity Tests.” OPPTS guidelines (850.6200) recommend subchronic 

studies with a duration of 28 days. Both OPPTS and OECD guidelines were referenced in 

evaluating these studies, all classified Supplemental. A comparison of the LC50 values for 

indaziflam (based on studies of the technical and formuated product) and the degradates 

demonstrate that the degradates are no more toxic to earthworms than is indaziflam. 

The study with the technical (MRID 47443269) resulted in an LC50 >1000 mg ai/kg dw 

of soil. The NOAEC and LOAEC values, based on percent body weight change, were 316 and 

562 mg ai/kg dw of soil, respectively. Percent body weight loss averaged 5.9% in the negative 

control and ranged from 8.2 to 15.6% in the treatment levels; 15.6 % effects were observed at the 

LOAEC and effects appear dose-dependent (15.0% effects observed at the 1000 mg ai/kg dw of 

soil treatment level). The study with the formulated product BCS-AA10717 SC 500 g/L (MRID 

47743315) resulted in an LC50 value >1000 mg ai/kg dw soil. The NOAEC, based on body 

weight change, was 562 mg ai/kg dw soil. Mean weight loss was 10% in the negative control, 

and was 10, 12, 9, 12, and 15% in the nominal 100, 178, 316, 562, and 1000 mg ai/kg dw soil 

treatment groups, respectively. Although there is uncertainty whether effects on body weight 

change are dose-dependent, the percent effects observed at the highest treatment level were 

statistically different from the control. The acute earthworm study on FDAT (MRID 47743312) 

reported an LC50 value of >1000 mg ai/kg dw soil. The LOAEC and NOAEC were reported as 

1000 and 500 mg ai/kg dw soil, respectively, based on a reduction in body weight. An effect on 

body weight change (9% reduction) was only observed at the highest treatment level and it is 

uncertain whether this effect is dose-dependent. The acute earthworm study on triazineindanone (MRID 47743313) reported similar results to the study on diaminotraizine. The LC50

was reported as >1000 mg ai/kg dw soil, with corresponding LOAEC and NOAEC of 1000 and 

316 mg ai/kg dw soil, respectively, based on body weight reduction (10%). It is uncertain 

whether the weight reduction observed at the highest treatment level is dose-dependent. The 

acute earthworm study on carboxylic acid (MRID 47743314) reported that no endpoints were 

affected thoughout the study: the LC50 was reported as >1000 mg ai/kg dw soil, with 

corresponding NOAEC of 1000 mg ai/kg dw soil. 

Chronic Effects

 A 56-day toxicity study of Indaziflam SC 500 on earthworms (Eisenia fetida) (MRID 

47743316) studied effects to earthworm survival, growth, and reproduction. Adult earthworms 

were exposed to the test substance for the first 28 days and then removed from the test vessels. 

Any offspring that had been produced in the first 28 days were then left in the test vessels for the 

reminaining 28 days. The earthworms were exposed to the test material at nominal 
-Page 66 of 292- 

concentrations of 0 (negative control), 19.1, 34.0, 60.3, 107, and 191 mg a.i./kg dw soil. The 

LC50 and EC50 in the study were both >191 mg a.i./kg dw soil, based on mortality and body 

weight change in adult earthworms. The NOAEC, based on funcundity (i.e. mean number of 

offspring produced per surviving adult), was 34.0 mg ai/kg dw soil. Relative to the control, the 

percent reductions of number of juveniles per surviving adult were 8.7, 13.1, 20.0, 40.6, and 

44.0%, corresponding to the 19.1, 34.0, 60.3, 107, and 191 mg a.i./kg dw soil treatment levels. 

The effects on number of offspring produced appear dose-dependent. This study failed to 

determine a LC50 without testing to guideline recommended concentration limits and was thus 

classified Supplemental. 

 

 No chronic toxicity studies were submitted for indaziflam TGAI or degradates in 

terrestrial invertebrates. 

3.3.2.4. Toxicity to Terrestrial Plants 

Terrestrial plant testing (seedling emergence and vegetative vigor) at the tier II level with 

the typical enduse product is required for known phytotoxicants (i.e. herbicides) that have 

terrestrial, forestry, and residential outdoor use patterns and/or may have endangered or 

threatened plant species associated with the application site. Tier II tests measure the responses 

of plants at five or more test chemical concentrations relative to a control. Tier II studies are 

available on the effect of indaziflam formulations BCS-AA10717 20WSP and Indaziflam 500 

SC on seedling emergence and vegetative vigor in terrestrial plants. A typical enduse product is 

defined as the formulation with the highest percentage active ingredient and/or the one most 

widely used; both BCS-AA10717 20WSP and Indaziflam 500 SC represent the two highest 

percentage active ingredient formulations (20.00% and 45.05%, respectively). The maximum 

labeled rate for Indaziflam 500 SC is evaluated for food uses in this assessment and AA10717 

20WSP is evaluated for spray applications to turf. Details on the most sensitive parameter for all 

species tested can be found in Appendix E. Based on the results of the submitted toxicity tests, 

both monocots and dicots in general appear more sensitive to exposures in seedling emergence 

testing than those from vegetative vigor testing for both formulations. This is consistent with 

indaziflam’s mode of action. Both formulations also exhibit similar levels of toxicity (i.e. of the 

same magnitude) for both monocots and dicots, and are together considered in deriving the most 

sensitive endpoints for terrestrial plants, as is shown in Table 3.18. 

 The effects on seedling emergence of the formulation BCS-10717 20WSP (TEP; 20.0% 

a.i.) were evaluated in an acceptable 21-day study on the following species: monocots (corn, oat, 

barley, and ryegrass) and dicots (cucumber, sugarbeet, oilseed rape, soybean, sunflower, and 

buckwheat) (MRID 47443246). No apparent dose-response relationships for dry weight were 

determined, with some species exhibiting inhibition in weight at lower treatment levels and 

growth promotion at the higher treatment levels. The most sensitive monocot was ryegrass 

(Lolium perenne, var. Temprano) based on survival, with an EC25 of 1.6x10-4 lbs a.i./A. The 

corresponding NOAEC was 6.2x10-5 lbs a.i./L. The most sensitive dicot tested was oilseed rape 

(Brassica napus, var. Licapo) based on emergence, with an EC25 of 1.1x10-4 lbs a.i./L; the 

corresponding NOAEC was 6.2x10-5 lbs a.i./L. 
-Page 67 of 292- 

 An acceptable 21-day seedling emergence test for the formulation Indaziflam 500 SC 

(MRID 47443247) evaluated the toxicity of the formulation on monocots (barley, corn, oat, 

onion, and ryegrass) and dicots (buckwheat, cucumber, oilseed rape, soybean, sugarbeet, 

sunflower, and tomato). Treatment group survival ranged from 0-100%. The most sensitive 

monocot was onion (Allium cepa, var. Braunschweiger blutrot) based on shoot length, with an 

EC25 of 1.7x10-4 lbs a.i./A. The corresponding NOAEC was 1.46x10-4 lbs a.i./L. The most 

sensitive dicot tested was tomato (Lycopersicon esculentum, var. Balkonstar) based on shoot 

length, with an EC25 of 2.4x10-4 lbs a.i./L; the corresponding NOAEC was 1.46x10-4 lbs a.i./L. 

 The effect of BCS-AA10717 20WSP on vegetative vigor in a 21-day study (MRID 

47443248) was assessed in the following species: monocots (corn, onion, oat, and ryegrass); 

dicots (cucumber, turnip, sugarbeet, sunflower, soybean, and buckwheat). The most sensitive 

monocot, based on survival, was ryegrass (L. perenne, var. Temprano) with NOAEC and EC25

values of 2.27x10-3 and 3.1x10-3 lbs a.i./A, respectively. The most sensitive dicot, based on dry 

weight, was turnip (Brassica rapa, var. Wilhelmburger gelbe). Inhibition of this endpoint was 

18% at the lowest treatment level, 9.06x10-4 lbs a.i./A, indicating that the EC25 would be found at 

a higher application rate. However, an adequate dose-response curve was not constructed to 

estimate the EC25 between the two lowest treatment levels. Thus the EC25 was visually 

determined to lie between the lowest concentration, at which 18% inhibition of dry weight was 

observed, and the next highest, at which 31% of the plants were inhibited (EC25 = >9.06x10-4, 

<2.27x10-3 lbs a.i./A). An associated NOAEC or EC05 could not be determined, thus the study 

was classified Supplemental. 

 

 In a 21-day vegetative vigor study (MRID 47443249) on the toxicity of the formulation 

BCS-AA10717 SC500, the following species were tested: monocots (corn, onion, oat, and 

ryegrass) and dicots (cucumber, oilseed rape, sugarbeet, sunflower, soybean, tomato, and 

buckwheat). The most sensitive monocot, based on survival, was ryegrass (L. perenne, var. 

Temprano) with NOAEC and EC25 values of 9.32x10-4 and 2.1 x 10-3 lbs a.i./A, respectively. 

The most sensitive dicot, based on shoot length, was soybean (Glycine max, var. Erin) with 

NOAEC and EC25 values of <3.75x10-4 and 4.3 x 10-3 lbs a.i./A, respectively. This study is 

scientifically sound but fails to define a NOAEC or EC05 corresponding to the lowest EC25 for 

dicots (i.e. soybean); the study was classified Supplemental. 

 

 No terrestrial plant studies were submitted for technical grade indaziflam or the 

degradates. 

4. Risk Characterization 

4.1. Risk Estimation 

 Toxicity data and exposure estimates are used to evaluate the potential for adverse 

ecological effects on non-target species. This baseline assessment of indaziflam relies on the 

deterministic RQ method to provide a metric of potential risks. The RQ provides a comparison 

of exposure estimates to toxicity endpoints (i.e., the estimated exposure concentrations are 
-Page 68 of 292- 

divided by acute and chronic toxicity values). The resulting unitless RQs are compared to the 

Agency’s LOCs, as shown in Table 2.3. LOCs are used by the Agency to indicate when the use 

of a pesticide, as directed by the label, has the potential to cause adverse effects to non-target 

organisms. 

 

 4.1.1. Aquatic Organisms 

 The highest baseline aquatic EECs based on the maximum application rates for each 

proposed use pattern were used to derive RQs. These exposure estimates represent 

concentrations in surface water (Table 3.7), since exposure estimates for ground water (Table 

3.9) were lower. Acute and chronic RQs for certain taxa could not be derived due to lack of data 

and risk to these taxa will be further discussed in the Risk Description section of this assessment. 

Peak EECs are used to represent acute exposure to fish, aquatic invertebrates, and aquatic plants, 

and the highest 21-day and 60-day average EECs represent chronic exposure to aquatic 

invertebrates and fish, respectively. 

4.1.1.1. Freshwater Fish and Invertebrates 

Fish 

 Table 4.1 lists RQs calculated for freshwater fish and aquatic-phase amphibians exposed 

to indaziflam, based on the highest peak EECs generated from PRZM modeling scenarios. 

Results of acute toxicity studies in freshwater and estuarine/marine fish (Table 3.13) indicate that 

indaziflam is “highly toxic” to freshwater fish on an acute exposure basis. However, all RQs for 

proposed uses of indaziflam fell below the Agency’s acute risk to listed species LOC (0.05), as 

well as the Agency’s acute risk to non-listed species LOC of 0.5. RQs for chronic exposures 

also fell below the Agency’s chronic risk to listed and non-listed species LOC (1.0). 

Table 4.1. Risk Quotients for Freshwater Fish and Aquatic-phase Amphibians 

Exposed to Indaziflam. 

EECs 

(ppb) 

Fish and Aquatic-phase Amphibian 

RQs 

LC50 = 320 μg total ai/L 

NOAEC = 464.4 μg total ai/L 

Use 

 

Peak 60-day Acute1,2 Chronic3 

Citrus 3.79 3.46 0.01 0.01 

Pome Fruit 3.86 3.60 0.01 0.01 

Grapes 4.00 3.95 0.01 0.01 

Olives 1.02 0.94 <0.01 <0.01 

Turf 0.47 0.39 <0.01 <0.01 

Home Lawns 5.92 5.70 0.02 0.01 

Ornamentals 6.19 6.05 0.02 0.01 

Hardscapes4 3.22 2.94 0.01 0.01 

Forested Areas 4.03 3.90 0.01 0.01 1

 Acute risk to non-listed species LOC for aquatic fish is 0.5 

2

 Acute risk to listed species LOC for aquatic fish is 0.05 

3

 Chronic risk to listed and nonlisted aquatic animals is 1.0 

4

 Hardscape scenario assumes 100% of the potential treated area is treated. 
-Page 69 of 292- 

Invertebrates 

 Definitive acute toxicity endpoints from studies on the TGAI were unavailable for 

freshwater invertebrates exposed in the water column or in sediment, and thus RQs were not 

calculated. Based on all available acute studies, indaziflam is categorized as “at most, 

moderately toxic” to freshwater invertebrates; however, the toxicity in these studies was in part 

limited by indaziflam’s solubility. The available non-definitive acute toxicity endpoints will be 

discussed the Risk Description, Section 4.2, to characterize acute risk to freshwater invertebrates 

from indaziflam use. The available definitive endpoint derived from a study on the formulated 

product (MRID 47743305) was not used to calculate RQs because of the active ingredient’s 

increased limit of solubility presumably due to the presence of inerts. Definitive chronic 

endpoints are available for freshwater invertebrates and were used to calculate chronic RQs 

presented in Table 4.2. For all use patterns, acute RQ values are based on peak EECs and 

chronic RQs on the highest 21-day EECs. All RQs are below the Agency’s risk to nonlisted and 

listed species LOCs of 0.5 and 0.05, respectively. 

1

 RQs are not calculated for acute toxicity to freshwater invertebrates due to non-definitive endpoints. 2

 Chronic risk to aquatic invertebrate nonlisted and listed species LOC is 1.0. 3

 Hardscape scenario assumies 100% of the potential treated area is treated 

 4.1.1.2. Estuarine and Marine Fish and Invertebrates 

Fish 

 Peak surface water EECs used to derive acute RQs for estuarine/marine fish are located 

in Table 4.3. No available chronic effects studies were available to calculate chronic RQs for 

indaziflam use to estuarine/marine fish. From studies on acute exposures, indaziflam is 

categorized “highly toxic” to estuarine/marine fish. However, based on peak EECs all acute RQs 

fall under the Agency’s risk to nonlisted and listed species LOC values of 0.5 and 0.05, 

respectively. Since toxicity data are unavailable to suggest otherwise, risk to estuarine/marine 

fish is presumed from indaziflam use based on chronic effects. 

Table 4.2. Risk Quotients for Freshwater Invertebrates Exposed to Indaziflam in the 

Water Column 

Surface Water EECs 

(ppb) 

Invertebrate RQs 

LC50 = >9,880 μg total a.i./L 

NOAEC = 340 μg total ai/L 

Use 

 

Peak 21-day Acute1 Chronic2

Citrus 3.79 3.66 -- 0.01 

Pome Fruit 3.86 3.74 -- 0.01 

Grapes 4.00 3.98 -- 0.01 

Olives 1.02 1.00 -- <0.01 

Turf 0.47 0.45 -- <0.01 

Home Lawns 5.92 5.89 -- 0.02 

Ornamentals 6.19 6.10 -- 0.02 

Hardscapes3 3.22 3.13 -- 0.01 

Forested Areas 4.03 3.98 -- 0.01 
-Page 70 of 292- 

Table 4.3. Risk Quotients for Estuarine and Marine Fish Exposed to Indaziflam. 

EECs 

(ppb) 

Fish RQs 

LC50 = 960 μg total ai/L 

NOAEC = not available 

Use 

 

Peak 60-day Acute1,2 Chronic 

Citrus 3.79 3.46 <0.01 - 

Pome Fruit 3.86 3.60 <0.01 - 

Grapes 4.00 3.95 <0.01 - 

Olives 1.02 0.94 <0.01 - 

Turf 0.47 0.39 <0.01 - 

Home Lawns 5.92 5.70 0.01 - 

Ornamentals 6.19 6.05 0.01 - 

Hardscapes3 3.22 2.94 <0.01 - 

Forested Areas 4.03 3.90 <0.01 - 1

 Acute risk to non-listed species LOC for aquatic fish and invertebrates is 0.5 

2

 Acute risk to listed species LOC for aquatic fish and invertebrates is 0.05 3

 Hardscape scenario assuming 100% of the potential treated area is treated 

Invertebrates 

 As shown in Table 4.4, RQ values have been calculated for acute exposures of 

indaziflam to estuarine/marine invertebrates. No chronic toxicity studies are available to provide 

the toxicity endpoints used to derive corresponding chronic RQs. The acute RQ values are based 

on indaziflam exposures in the water column and are calculated using peak surface water EECs. 

Based on available studies, indaziflam is categorized “highly toxic” to “moderately toxic” to 

esturine/marine invertebrates exposed in the water column. Definitive endpoints could not be 

derived from available acute whole sediment toxicity tests with marine amphipods, during which 

no treatment-related mortality was observed; the toxicity, however, was in part limited by 

solubility. Risk of indaziflam use to estuarine/marine benthic invertebrates will be characterized 

in the Risk Description, Section 4.2. All RQs for acute exposures of estuarine/marine 

invertebrates to indaziflam are below the Agency’s acute risk to non-listed and listed species 

LOC values of 0.5 and 0.05, respectively. Based on lack of chronic effects data, risk of longterm effects is presumed to estuarine/marine invertebrates from indaziflam use. 
-Page 71 of 292- 

Table 4.4. Risk Quotients for Estuarine and Marine Invertebrates Exposed to 

Indaziflam. 

EECs 

(ppb) 

Invertebrate RQs 

LC50 = 920 μg total ai/L 

NOAEC = not available 

Use 

 

Peak 21-day Acute1,2,3 Chronic 

Citrus 3.79 3.66 <0.01 - 

Pome Fruit 3.86 3.74 <0.01 - 

Grapes 4.00 3.98 <0.01 - 

Olives 1.02 1.00 <0.01 - 

Turf 0.47 0.45 <0.01 - 

Home Lawns 5.92 5.89 0.01 - 

Ornamentals 6.19 6.10 0.01 - 

Hardscapes4 3.22 3.13 <0.01 - 

Forested Areas 4.03 3.98 <0.01 - 1 Acute RQs based on surface water peak EECs and toxicity data for estuarine/marine invertebrates found in the water column 2

 Acute non-listed LOC for aquatic fish and invertebrates is 0.5 3

 Acute listed LOC for aquatic fish and invertebrates is 0.05 4

 Hardscape scenario assuming 100% of the potential treated area is treated 

4.1.1.3. Aquatic Plants 

As shown in Table 4.5, RQ values for all listed and non-listed vascular aquatic plants 

exceed the Agency’s aquatic plant risk LOC of 1.0, based on the aquatic EECs for each use 

pattern (RQs in bold exceed the LOC). Risks to aquatic vascular plants associated with exposure 

to indaziflam are expected across all of the proposed uses evaluated. 

Table 4.5. Aquatic Vascular Plant Risk Quotients1

 for Exposure to Indaziflam. 

Use Peak EECs (ppb) 

Nonlisted Species RQs 

EC50 = 

0.061 μg ai/L 

Listed Species RQs 

NOAEC = 

 0.0194 μg ai/L 

Citrus 3.79 62.13

 1953

Pome Fruit 3.86 63.33

 1993

Grapes 4.00 65.63

 2063

Olives 1.02 16.73

 52.63

Turf 0.47 7.703

 24.23

Home Lawns 5.92 97.03

 3053

Ornamentals 6.19 1013

 3193

Hardscapes2 3.22 52.83

 1663

Forested Areas 4.03 66.13

 2083

1

 Risk to aquatic vascular and nonvascular plant LOC for nonlisted and listed species is 1.0. 2

 Hardscape scenario assuming 100% of the potential treated area is treated 3

.Exceeds risk to aquatic plant LOC of 1.0. 

 RQs for nonvascular aquatic plants are presented in Table 4.6. All nonlisted RQ values 

fall below the Agency’s LOC value of 1.0. For listed species, RQs exceed the Agency’s 
-Page 72 of 292- 

nonvascular plant risk LOC of 1.0 for two out of the nine uses: home lawns and ornamentals. 

These RQs are shown in bolded script. 

Table 4.6. Aquatic Nonvascular Plant Risk Quotients1

 for Exposure to Indaziflam. 

Use Peak EECs (ppb) 

Nonlisted Species RQs 

EC50 = 

27 μg ai/L 

Listed Species4 RQs 

NOAEC = 

 5.1 μg ai/L 

Citrus 3.79 0.14 0.74 

Pome Fruit 3.86 0.14 0.76 

Grapes 4.00 0.15 0.78 

Olives 1.02 0.04 0.20 

Turf 0.47 0.02 0.09 

Home Lawns 5.92 0.22 1.22

Ornamentals 6.19 0.23 1.22

Hardscapes3 3.22 0.12 0.63 

Forested Areas 4.03 0.15 0.79 1

 Aquatic vascular and nonvascular plant LOC for nonlisted and listed species is 1.0. 2

 Exceeds aquatic nonvascular plant risk LOC. 

3

 Hardscape scenario assuming 100% of the potential treated area is treated 4

 No aquatic nonvascular species are Federally-listed to-date 

 4.1.2. Terrestrial Organisms 

4.1.2.1. Mammals 

Acute RQs were not calculated for mammals because only non-definitive acute oral 

toxicity data are available. Based on the available acute toxicity data, no mortality was observed 

in any of the mammalian studies conducted on indaziflam technical or its formulated products at 

the highest concentrations/doses tested; as such, indaziflam is categorized “practically nontoxic” 

on an acute exposure basis. Further discussion of the predicted exposure values relative to the 

levels at which no mortality was observed is provided as part of the risk description in Section 

4.2.2.2.

 

 Based on the proposed application rate of 0.085 lbs a.i./A (with second application rate of 

0.05 lbs a.i./A) for food uses of indaziflam, dose-based RQs calculated for chronic mammalian 

exposure range from <0.01 to 0.20 using upper 90th percentile Kenaga values (see Table 4.4). 

These RQs, along with RQs calculated for all other indaziflam’s uses besides turf (granule), fall 

below the Agency’s mammalian chronic risk to listed and nonlisted species LOC (1.0). Since 

EFED has no standard methodology for assessing chronic risk to terrestrial organisms from 

granular applications, chronic effects from granular use of indaziflam on turf will be 

characterized in the risk description, Section 4.2. 
-Page 73 of 292- 

Table 4.7. Chronic Mammalian Risk Quotients1

 for Indaziflam Proposed Uses2 

Herbivore/Insectivore Dose-Based RQs 

Use 

Size 

Class 

(grams) Short Grass Tall 

Grass 

Broadleaf 

Plants/Small 

Insects 

Fruits/Pods/ 

Large Insects 

Granivore 

Dose-Based 

(seeds) 

15 0.20 0.09 0.11 0.01 <0.01 

Food 35 0.17 0.08 0.10 0.01 <0.01 

1000 0.09 0.04 0.05 0.01 <0.01 

15 0.12 0.06 0.07 0.01 <0.01 

Home Lawns 35 0.11 0.05 0.06 0.01 <0.01 

1000 0.06 0.03 0.03 <0.01 <0.01 

15 0.14 0.07 0.08 0.01 <0.01 

35 0.12 0.06 0.07 0.01 <0.01 Ornamentals & 

Hardscapes 1000 0.06 0.03 0.04 <0.01 <0.01 

15 0.13 0.06 0.08 0.01 <0.01 

35 0.11 0.05 0.06 0.01 <0.01 

Roadsides/rights

-of-way & Site 

Preparation 1000 0.06 0.03 0.03 <0.01 <0.01 

15 0.19 0.09 0.11 0.01 <0.01 

Forested Areas 35 0.16 0.07 0.09 0.01 <0.01 

1000 0.09 0.04 0.05 0.01 <0.01 

15 0.03 0.01 0.02 <0.01 <0.01 

35 0.03 0.01 0.01 <0.01 <0.01 Turf 

(Ground Spray) 1000 0.01 0.01 0.01 <0.01 <0.01 1

 Mammalian and avian risk to listed and nonlisted species from chronic effects LOC = 1 2

 Chronic mammalian effects from granular use on turf will be characterized in the risk description section. 

 

4.1.2.2. Birds 

Acute RQs were not calculated for birds because only non-definitive acute and sub-acute 

toxicity endpoints are available. Indaziflam was categorized practically non-toxic to zebra finch, 

mallard duck and bobwhite quail on an acute and subacute oral basis. However, treatmentrelated sublethal effects were observed in mallard duck at the highest concentration tested in one 

sub-acute dietary toxicity study, as well as observed in zebra finch at the highest concentration 

tested in an acute toxicity study. Further discussion of the predicted exposure values relative to 

the levels at which no mortality and sublethal effects occurred (inhibition of body weight and 

food consumption for mallard duck; clinical signs of toxicity for zebra finch) is provided as part 

of the risk description in Section 4.2.5. 

 

 Although the measure of effect for chronic risk to birds was a non-defintive endpoint 

(NOAEC <95 mg a.i./kg-diet), RQs were calculated to evaluate the minimum level of potential 

risk. As presented in Table 4.8., all chronic RQs for each proposed spray use pattern and dietary 

item are below the Agency’s risk to birds chronic LOC (1.0). At the lowest dose tested in the 

reproductive toxicity study with mallard duck (95 mg a.i./kg), treatment-related effects were 

observed on female weight gain and adult food consumption. Without toxicity data to determine 

otherwise, chronic risk to birds is presumed from indaziflam’s proposed spray uses. Further 

characterization of potential chronic effects of indaziflam spray uses to birds at concentrations 
-Page 74 of 292- 

lower than 95 mg a.i./kg is provided in the risk description, Section 4.2.5. Characterization of 

chronic effects to birds from the granular turf use will also be assessed in the Risk Description 

section since EFED has no standard methodology for assessing chronic risk to terrestrial 

organisms from granular applications. 

Table 4.8. Chronic Avian Risk Quotients1 for Indaziflam Proposed Uses2

Dietary-based RQs 

Use Short Grass Tall Grass Broadleaf plants/sm 

insects 

Fruits/pods/ 

seeds/lg insects 

Food 0.33 0.15 0.19 0.02 

Home Lawns 0.21 0.10 0.12 0.01 

Ornamentals & Hardscapes 0.24 0.11 0.13 0.01 

Roadsides/rights-of-way & 

Site Preparation 0.22 0.10 0.13 0.01 

Forested Areas 0.32 0.14 0.18 0.02 

Turf (Ground Spray) 0.05 0.02 0.03 <0.01 

Turf 

(Granule) --- 

1

 Mammalian and avian risk to listed and nonlisted species from chronic effects LOC = 1 2

 Chronic avian effects from granular use on turf will be characterized in the risk description section. 

4.1.2.3. Terrestrial Invertebrates 

Indaziflam is categorized as ‘practically non-toxic’ to honey bees on an acute contact and 

oral exposure basis, based on available data for the TGAI and the BCS-AA10717 SC 500 g/L 

formulated product. Indaziflam caused no mortalities to earthworms during 14-days of exposure 

at the highest test concentration of 1,000 mg a.i./kg dw soil based on available data for the TGAI 

and BCS-AA10717 SC 500 g/L formulation. However, due to effects on body weight, the 

NOAEC from the TGAI study was found to be 316 mg a.i./kg dw soil, with a corresponding 

LOAEC of 562 mg a.i./kg dw soil. The NOAEC from the formulated product study was found 

to be 562 mg a.i./kg dw soil, with a corresponding LOAEC of 1000 mg a.i./kg dw soil. A 56-day 

study on survivial, growth, and reproduction reported an LC50 >191 mg a.i./kg dw soil, with 

corresponding NOAEC of 34 mg a.i./kg dw soil, based on fecundity (i.e. mean number of 

offspring per surviving adult). Additional characterization of the potential risks of indaziflam to 

terrestrial invertebrates is provided in the Risk Description, Section 4.2.2.2.

4.1.2.4. Non-target Terrestrial and Semi-Aquatic Plants 

Potential effects to riparian and upland vegetation are assessed deriving RQs from 

terrestrial plant seedling emergence and vegetative vigor EC25 data. Based on the results of the 

submitted terrestrial plant toxicity tests for the two formulated products (BCS-AA10717 20WSP 

and Indaziflam 500 SC), it appears that monocots and dicots exhibit similar sensitivity in the 

vegetative vigor test, as well as in the seedling emergence test. The available data indicate that 

the majority of tested plants exhibited adverse effects in the seedling emergence and vegetative 

vigor tests, and that a variety of terrestrial plants that may inhabit riparian and upland zones may 

be sensitive to indaziflam exposure. 
-Page 75 of 292- 

 A summary of the RQs for monocot and dicot terrestrial plants exposed to indaziflam 

formulations (at application rates ranging from 0.017 to 0.125 lbs a.i./A) is provided in Tables 

4.8 and 4.9, respectively. All RQs exceeded the Agency’s risk to terrestrial plant nonlisted and 

listed species LOC (1.0). Further discussion of risk to monocots and dicots from spray drift will 

be addressed in the Risk Description, Section 4.2.

Table 4.8 RQs1 for Monocots Inhabiting Dry and Semi-Aquatic Areas Exposed to Indaziflam 

via Runoff and Drift 

Spray drift RQ Dry area RQ Semi-aquatic area 

Use Application method RQ

Nonlisted Listed Nonlisted Listed Nonlisted Listed 

Food Ground Spray 5.31 13.7 10.6 27.4 58.4 151 

Ground Spray 1.06 2.74 2.13 5.48 11.7 30.2 

Turf 

Granule NA2 NA 5.00 12.9 50.0 129 

Home Lawns Ground Spray 2.94 7.58 5.88 15.2 32.3 83.4 

Ornamentals/ 

Hardscapes Ground Spray 5.88 15.2 11.8 30.3 64.6 167 

Roadsides/rights

-of-way & 

Site Preparation 

Ground Spray 5.56 14.4 11.1 28.7 61.2 158 

Ground Spray 7.81 20.2 15.6 40.3 85.9 222 

Forested Areas 

Aerial Spray 39.1 101 68.2 121 170 302 1

 All RQs exceed the Agency’s LOC (RQ > 1) 2

 N/A = not applicable 

Table 4.9 RQs1 for Dicots Inhabiting Dry and Semi-Aquatic Areas Exposed to Indaziflam via 

Runoff and Drift 

Spray drift RQ Dry area RQ Semi-aquatic area 

Use Application method RQ

Nonlisted Listed Nonlisted Listed Nonlisted Listed 

Food Ground Spray 7.73 13.7 15.5 27.4 85.0 151 

Ground Spray 1.55 2.74 3.09 5.48 17.0 30.2 

Turf 

Granule N/A2 N/A 7.27 12.9 72.7 129 

Home Lawns Ground Spray 4.27 7.58 8.55 15.2 47.0 83.4 

Ornamentals/ 

Hardscapes Ground Spray 8.55 15.2 17.1 30.3 94.0 167 

Roadsides/rights

-of-way & 

Site Preparation 

Ground Spray 8.09 14.4 16.2 28.7 89.0 158 

Ground Spray 11.4 20.2 22.7 40.3 125 222 

Forested Areas 

Aerial Spray 68.2 121 68.2 121 170 302 1

 All RQs exceed the Agency’s LOC (RQ > 1) 2

 N/A = not applicable 
-Page 76 of 292- 

4.2. Risk Description 

The results of the risk estimation section indicate that proposed uses of indaziflam may 

have direct adverse effects on plants: non-listed and listed aquatic vascular plants, listed aquatic 

nonvascular plants, and listed and nonlisted terrestrial monocots and dicots. While the listed 

species LOC for aquatic nonvascular plants was only slightly exceeded for two uses, tier III field 

studies provide evidence of population level effects at environmentally-relavent concentrations; 

thus direct effects to listed species of nonvascular plants may potentially occur. Proposed 

indaziflam uses result in large LOC exceedances for terrestrial plants. The AgDrift model was 

used to refine the spray drift exposure and assessment of risk. Based on certain proposed uses, 

AgDrift model results indicates that nonlisted species RQs based on ground and aerial broadcast 

applications to roadsides/rights-of-ways, site preparation, and forested areas exceed the nonlisted 

and listed species LOC for distances at or greater than 900 feet from the edge of field. To 

characterize this risk, RQs per use pattern were developed for spray drift exposures ranging from 

distances of 0 (on the field) to 950 feet off the field. Alterations in proposed application rates 

were also explored. These results indicate that risk to non-target terrestrial plants from spray 

drift cannot be easily mitigated for certain uses, but that a spray drift buffer of 350 feet or greater 

for broadcast applications of indaziflam would reduce RQs below the nonlisted species LOC for 

all turf and food uses. 

RQs for all assessment endpoints with available data did not exceed the Agency’s listed 

or nonlisted acute or chronic effects LOC for any proposed uses. Three assessment endpoints 

could not be fully assessed in the risk estimation due either a lack of data or inadequacy of data, 

i.e. chronic effects to estuarine/marine fish and invertebrates, and birds. For estuarine marine 

invertebrates, risk is presumed based on lack of data. For estuarine/marine fish, the Risk 

Description explores the potential for risk based on a freshwater fish acute-to-chronic ratio and 

finds that risk to estuarine/marine fish is not expected. For birds, risk is presumed to listed and 

nonlisted species based on inadequacy of data. 

The terrestrial exposure assessment of proposed uses of indaziflam evaluated the 

exposure and effects of the parent compound only; however, data suggests that there are other 

degradates that could potentially be of concern to mammals, birds, and plants. While risk from 

these residues of concern, i.e., degradates, cannot be assessed quantitatively, the potential for risk 

can be assessed qualitatively. Given the conservative default estimate for the foliar dissipation 

half-life used in the terrestrial modeling (ie. 35 days), the dietary toxicity to terrestrial wildlife of 

the degradates that do form on foliar surfaces may be accounted for by this conservative half-life 

and by assuming equal toxicity to the parent. Phytotoxic effects of these degradates are also of 

concern based on their structural similarity to the parent. Although a quantitative anlysis of 

concentration vs. effect cannot be evaluated, any hypothetical effects would be captured by the 

design of the 21-day seedling emergence and vegetative vigor toxicity studies but linked back to 

a total concentration of the parent indaziflam. 

Although direct adverse effects to many taxa are not expected based on this baseline 

assessment, indirect effects to all taxa are possible, given the potential for adverse effects to 

terrestrial and aquatic plants. Because plants are vital components of most habitats and 
-Page 77 of 292- 

ecosystems, alterations in the abundance of plants or in the composition of plant communities 

could result in adverse effects to non-plant species. Potential effects include, but are not limited 

to, reduction in food resources, decrease in cover (e.g., for predator avoidance), change in water 

quality parameters (e.g., increases or decreases in temperature and DO), and loss of 

breeding/nesting habitat. The degree to which these effects may occur, or if they occur at all, has 

not been assessed. However, this baseline assessment uses conservative estimates of exposures 

that may in some cases be protective of risks from indirect effects. 

4.2.1 Exposure to Aquatic Organisms 

Surface water EECs resulting from applications of indaziflam to hardscapes are 

conservative estimates of exposure. However, since these estimates were generated using a 

number of assumptions (e.g., 12% of a 1⁄4 acre urban/suburban residential lot would be 

impervious, 58 lots in a 10ha residential watershed, all of which is treated with indaziflam), 

EECs were also completed for exploratory purposes by removing the the assumptions for percent 

of the watershed that is impervious and conversely assuming that the 10 ha watershed (i.e., 

treated field) would be 100% impervious (i.e., a parking lot). Conceptually, this type of scenario 

may exist in urban environments (e.g., parking lot for an event stadium). Therefore, EECs were 

generated assuming that all hardscapes are treated simultaneously, and that 100% of the area 

draining to the pond is impervious. Although the EECs in Table 4.10 are based on potential 

routes of exposure, it is unlikely that every impervious surface will be treated at a single time. 

Table 4.10. Unadjusted EECs for Indaziflam Applications to Hardscapes 

Uses Scenario Max. App. rate

(lbs a.i./A/yr) Peak (ppb) 21-day (ppb) 60-day (ppb) 

Hardscapes 

(unadjusted) FL Impervious 0.094 26.8 26.1 24.5 

 Estimates of aquatic exposure for risk estimatation were calculated based on a fraction 

(12%) of a typical 1⁄4 acre lot that could be impervious surface (hardscape). This resulted in a 

much lower fraction of the watershed that could potentially receive applications of indaziflam. 

For the purposes of characterizing the exposure estimates, EECS were calculated assuming that 

100% of the 10 ha watershed was impervious (Table 4.10). It is unlikely that a 10 ha hardscape 

area would be treated with indaziflam since the end-use products labeled for use on hardscapes 

are formulated for hand-pump sprayers, hose-end sprayers, or battery powered hand-held 

sprayers (i.e., it is unlikely that they are used for broadcast applications over large areas). 

However, for a qualitative discussion of risk, these estimates are presented as a worst case 

scenario for aquatic exposure. 
-Page 78 of 292- 

4.2.2 Risks to Aquatic Animals 

Freshwater Fish 

Acute RQs were calculated in the Risk Estimation section for all proposed uses of 

indaziflam and were found not to exceed the Agency’s acute risk LOC for nonlisted and listed 

species (0.05) based on the most sensitive acute endpoint available, LC50 = 320 μg total a.i./L. 

To explore potential risks to freshwater fish from indaziflam exposures estimated from the 

unadjusted hardscape scenario, as presented above, RQs were calculated for nonlisted and listed 

species based on a peak environment exposure to indaziflam at 26.8 μg/L. At this concentration, 

only the listed species acute RQ, calculated as 0.08, exceeded the Agency’s acute risk LOC 

(0.05). In light of this slight exceedance, risk to listed freshwater fish is discountable given the 

highly conservative assumptions of the unadjusted hardscapes scenario: that a 10 ha watershed 

(i.e., treated field) would be 100% impervious (i.e., a parking lot), that this 10 ha area would be 

treated simultaneously, and that 100% of the applied chemical would drain into an adjacent pond 

(i.e. or other type of water body). Therefore, considering that this is a worst case scenario, and 

that listed and nonlisted species RQs do not exceed the Agency’s acute risk LOC for less 

extreme scenarios, acute risk to nonlisted and listed species from all proposed indaziflam uses is 

not expected. 

 Freshwater fish chronic RQs with values ≤ 0.01 did not exceed the Agency’s chronic risk 

LOC for nonlisted and listed species (1.0). These RQs are based on the most sensitive chronic 

endpoint available from fathead minnow, NOAEC = 464 μg total a.i./L. The corresponding EC50

for fathead minnow from an acute study (MRID 47443229) was found to be 770 μg total a.i./L. 

The most sensitive acute value used in this assessment to derive RQs, however, is derived from 

bluegill sunfish (320 μg total a.i./L). To investigate what a chronic toxicity value would be for 

bluegill sunfish, an acute-to-chronic (ACR) ratio from fathead minnow can be derived. In 

applying the ACR of fathead minnow, calculated to be 1.66 (770/464), to bluegill sunfish, the 

estimated chronic toxicity value for blugill sunfish is 193 μg a.i./L. In comparing this lower 

toxicity value to 60-day EECs, newly derived chronic RQs range from <0.01 to 0.03, still below 

the Agency’s chronic risk to listed and nonlisted species of 1.0. Chronic risk to freshwater fish 

from proposed uses of indaziflam is not expected. 

 

Estuarine/Marine Fish

 Acute RQs for estuarine/marine fish do not exceed the Agency’s LOCs based on the 

highest surface water EECs (ranging 0.47 to 6.19 μg ai/L) for all use patterns. From the one 

available acute study using sheepshead minnow, the LD50 for estuarine/marine fish is 960 μg 

total ai/L, roughly 150 times higher than the highest peak EEC (35 times higher than the highest 

peak EEC based on the highly conservative scenario for proposed use on hardscapes). If a 

comparison is made between the effect level at which no mortality or sublethal effects were 

observed (NOAEC = 430 μg ai/L), the highest peak EEC would still be roughly 65 times less (15 

times less for unadjusted hardscapes use). Since RQ values are below the acute risk LOCs, acute 

mortality to Federally listed or non-listed estuarine/marine fish from proposed uses of indaziflam 

is not expected. Moreover, given indaziflam’s solubility of 1,200 – 4,400 μg ai/L (MRID 

47443202), effects to estuarine/marine fish demonstrated in the toxicity tests could potentially be 

limited under more realistic environments, i.e., absence of a solvent. Indaziflam’s solubility 
-Page 79 of 292- 

might also be lower in esturine/marine environments where the solute concentration is higher 

than in freshwater. 

 Chronic data is unavailable to assess long-term effects of proposed indaziflam uses on 

esturine/maine fish. Accordingly, risk to this taxon was presumed in the risk estimation. 

However, to explore the potential for chronic effects, an ACR derived from freshwater fish can 

be applied to the most sensitive acute measurement endpoint for estuarine/marine fish, which as 

discussed above, is 960 μg total ai/L. An ACR of 1.66 was derived for fathead minnow based on 

acute and chronic studies. An estimate of the chronic endpoint for estuarine/marine fish using 

this ACR results in a NOAEC of 578 μg total ai/L. RQs based on this NOAEC have values ≤

0.01, at a minimum 100 times lower than the Agency’s chronic risk listed and nonlisted species 

LOC (1.0). Based on this extrapolation, chronic risk to estuarine/marine fish is not expected for 

proposed indaziflam uses. 

Freshwater Invertebrates 

 Acute RQs were not calculated due to the non-definitive endpoint (>9,880 μg total ai/L) 

derived from a toxicity study to D. magna using the TGAI (MRID 47443226). The acute study 

exposed daphnids to indaziflam concentrations of <LOQ (controls), 620, 1,230, 2,540, 4,860, 

and 9,880 μg total ai/L, at which 35% immobility was observed at the highest test level. A 

comparison of the highest concentration with peak surface water EECs shows that the 

concentration at which < 50% immoblity occurred far exceeds the predicted peak environmental 

concentrations (ranging 0.47 to 6.19 μg ai/L) by over 1500 times. If compared to the highly 

conservative peak water concentration of 26.8 μg ai/L for hardscapes use, then the highest 

concentration at which < 50% immoblity occurred still exceeds the predicted peak environmental 

concentration by over 350 times. Furthermore, the concentration at which effects occurred 

exceeds the solubility limit of indaziflam (without use of methods to increase dissolution). Thus, 

the effects observed in the study would likely be limited by solubilily under realistic conditions. 

Another non-definitive endpoint (>2,200 μg ai/L) was available from an acute sediment exposure 

test on a freshwater midge species (MRID 47443238). The highest concentration tested at which 

no mortality was observed in the midge study, 2,200 μg ai/L of pore water, is at a minimum 550 

times greater than the highest pore water EECs for all proposed uses, as reported in Table 3.8. 

Indaziflam’s limit of solubility would also likely limit the potential effects to benthic 

invertebrates under realistic conditions. Acute mortality to freshwater invertebrates exposed to 

proposed uses of indaziflam is not expected. 

 Chronic risk to freshwater invertebrates was assessed based on one reproductive study on 

Daphna magna; all RQs were below the Agency’s LOCs. However, there is uncertainty in this 

endpoint because the study from which the toxicity endpoint was derived failed to measure 

reproductive success (i.e. number of immobilized offspring). However, the concentration level 

at which no chronic effects were observed in daphnids, 340 μg total ai/L, is at a minimum 13 

times more than the range of 21-day EECs (0.45 – 26.1 μg ai/L). Therefore, chronic effects to 

freshwater intervetebrates from the proposed uses of indaziflam are not expected. 
-Page 80 of 292- 

Estuarine/Marine Invertebrates

 All acute estuarine/marine invertebrate RQs were well below the Agency’s risk to nonlisted and listed species LOCs. The endpoint used to derive the RQs was based on a toxicity 

study with the Eastern oyster (mollusk). The EC50 of 920 μg total ai/L is roughly 140 times 

greater than the highest peak EEC predicted to be available and is roughly 30 times greater 

compared to the highly conservative EEC for harscapes use. This endpoint is lower than the 

other available EEC of 1,500 μg ai/L based on a study with mysid shrimp (crustacean). 

Moreover, given indaziflam’s solubility of 1,200 – 4,400 μg ai/L (MRID 47443202), effects to 

estuarine/marine invertebrates demonstrated in the toxicity tests could potentially be limited 

under more realistic environments, i.e., absence of a solvent. Indaziflam’s solubility might also 

be lower in esturine/marine environments where the solute concentration is higher than in 

freshwater. A non-definitive endpoint was available from an acute sediment exposure test on 

species of marine amphipods at which no mortality was observed (3,800 μg a.i./L of pore water). 

Pore water EECs were derived and presented in Table 3.8 to characterize the available benthic 

invertebrate toxicity studies. The concentration at which no mortality was observed in the 

amphipod study (3,800 μg ai/L) was 3 orders of magnitude greater than the highest pore water 

EECs for all proposed uses. Moreover, effects to estuarine/marine benthic invertebrates would 

likely be limited by indaziflam’s solubility under realistic conditions. The potential for acute 

mortality to estuarine/marine invertebrates from the proposed uses of indaziflam is not expected 

based on these studies. However, since there are no data that indicate otherwise, chronic direct 

risk to non-listed and listed estuarine/marine invertebrates is presumed. 

4.2.3 Risks to Aquatic Plants 

Aquatic Vascular Species 

As was presented in the risk estimation section, all non-listed and listed aquatic vascular 

plant RQs exceeded the Agency’s LOC by factors ranging from 9 to 319. Peak environmental 

concentrations estimated ranged from 0.47 to 6.19 μg ai/L, while the toxicity data (MRID 

47743308) indicated the surrogate species L. gibba/duckweed to be sensitive to indaziflam at 

much lower concentrations: EC50 = 0.061 μg ai/L; NOAEC = 0.0194 μg ai/L. Direct risks to 

non-listed and listed species are likely given the proposed uses of indaziflam (with direct risks 

more likely considering the unadjusted hardscapes scenario). However, considering that the 

toxicity of indaziflam to vascular plants was demonstrated to be lower using a sediment/water 

system (MRID 47443256), effects to vascular plants under more realistic conditions (i.e. 

presence of sediment) may be lower. 

 

 The submitted 69-day tier III field study on aquatic plants (MRID 47443257), discussed 

in the Effects Characterization, supports the finding of potential risk to aquatic vascular plants. 

Overall, aquatic vasculars in the constructed microcosms were far more sensitive than species in 

the phytoplankton and zooplankton (nonvascular plant) taxa. Of the vascular plant species 

investigated, the lemnids (L. gibba, S. polyrhiza) were the most sensitive, with a NOAEC of 0.01 

μg ai/L. The vast majority of non- lemnid vascular plants began to exhibit clear effects at the 1.0 

μg ai/L level, and no recovery was indicated at the 3.2 and 10.0 μg ai/L levels. It was concluded 

that for all assessed endpoints for L. gibba (number of fronds, percent growth of fronds, and dry 
-Page 81 of 292- 

weight), the NOAEC was 0.01 μg ai/L during the first 14 days post-treatment. Although derived 

from a longer duration exposure, this NOAEC corresponds in magnitude with the NOAEC of 

0.0194 μg a.i./L from the 7-day toxicity study using L. gibba (mentioned above). This study 

allays some uncertainty as to whether studies using L. gibba provide protective endpoints for 

other vascular plants and whether the 7-day studies are protective of longer-term exposures (14-

69 days). 

Aquatic Nonvascular Species 

Risk was determined to listed aquatic nonvasculars in the Risk Estimation: listed species 

RQs for the proposed indaziflam uses on home lawns and ornamentals exceeded the Agency’s 

plant risk LOC (both RQs were calculated as 1.2); listed species RQs for the remaining uses and 

for all non-listed species were below the LOC. Exploring risk from the unadjusted hardscapes 

scenario, only RQs for listed nonvascular species would exceed the LOC (1.0) with an RQ of 

5.3. The submitted tier III aquatic plant field study sheds more light into the effects at the 

population and community level. The study evaluated response of 68 taxa of nonvascular plants 

(phytoplankton) to indaziflam exposure. At the population level, univariate analysis of the 

responses of phytoplankton was performed using the Williams test. Of the 68 taxa, statisticallysignificant treatment-related effects were determined for three taxa: Crucigeniella sp. (NOAEC 

at 7-14 days = 3.2 μg a.i./L), Cosmarium sp. (NOAEC at 14 days 0.1 μg a.i./L, at 56 days 1.0 μg 

a.i./L), and Nitzschia sp (NOAEC at 7 days 1.0 μg a.i./L, 14 days 3.2 μg a.i./L). For 

Crucigeniella, the response was interpreted with caution because of the initial low abundance 

values. At the community level, the number of taxa per sampling interval varied between 9 and 

29 in the control microcosms; however, statistically-significant treatment-related effects on taxa 

richness were not observed. Furthermore, multivariate analysis revealed no clear treatmentrelated response, with more or less similar variability between treatment levels during the preand post-treatment periods. The results from the RQ analysis combined with these microcosms 

results indicate that direct effects to non-listed aquatic non-vasculars is likely to be low; 

however, given the listed species RQ exceedances for certain proposed uses as well as the 

evidence of population level effects at environmentally-relavent concentrations (peak EECs 

range 0.47 – 6.19 μg a.i./L; peak EECs for the unadjusted hardscapes scenario range 0.47 -26.8 

μg a.i./L, direct effects from proposed indaziflam uses to listed aquatic non-vascular species may 

potentially occur. Although no Federally-listed aquatic nonvascular species exist to-date, this 

risk finding is protective of all future listings and any species of nonvasculars that are threatened 

or endangered but have missed Federal recognition. 

 4.2.4. Risks to Mammals 

 Acute RQs were not derived for mammals in the Risk Estimation section of this 

assessment because no mortality to rats was observed at the highest treatment level in the acute 

oral mammalian studies of indaziflam technical or studies of indaziflam’s formulated products. 

To put the non-definitive mammalian endpoint into context, derived from both acute oral studies 

of indaziflam technical, adjusted LD50 values were computed in T-REX based on the nondefinitive acute endpoint of > 2,000 mg a.i/kg bw. For three size classes of mammals (15, 35, & 

1000 grams), the adjusted LD50 values ranged from 1538 to 4395 mg a.i./kg-bw, which at a 
-Page 82 of 292- 

minimum are 50 times higher than the dose-based EECs generated for proposed ground spray 

food uses, 0.067 to 30.1 mg/kg-bw. For the granular application, a ratio of an adjusted LD50 and 

the square footage of applied area was calculated. Employing the conservative assumption that 

the acute LD50 for mammals is 2000 mg ai/kg-bw, the risk estimate for acute exposure to 

indaziflam granules did not exceed the Agency’s acute risk LOCs for any mammalian weight 

class (≤0.01). Direct acute effects to mammals from exposure to indaziflam are not expected. 

Furthermore, based on toxicity studies of formulations of indaziflam and other active ingredients, 

direct risk to mammals due to indaziflam mixed with multiple active ingredients is not expected. 

 

 As was presented in the Risk Estimation, chronic mammalian RQs for all spray 

applications of indaziflam fell below the Agency’s risk to listed and nonlisted species LOC of 

1.0. Chronic effects from granular use of indaziflam were not evaluated in the Risk Estimation 

since EFED has no standard methodology for assessing chronic risk to terrestrial organisms from 

granular applications. The following chronic exposure estimation and risk characterization for 

terrestrial wildlife considers granular routes of exposure through the direct ingestion by birds or 

mammals of soil invertebrates (i.e. earthworms) that have bioconcentrated indaziflam residues of 

granules in soil. Estimates of earthworm concentrations of indaziflam were calculated using a 

fugacity-based (equilibrium partitioning) approach based on the work of Trapp and McFarlane 

(1995) and Mackay and Paterson (1981). A description of the model and an example 

input/output spreadsheet can be found in Appendix K. The model estimates risk by assuming 

100% of the diet is comprised of terrestrial soil invertebrates. Specifically for indaziflam, the 

assumption was made that the pesticide would be present in the top 15-cm of the soil (no direct 

incorporation, but that granules were watered-in). To assess chronic risk to mammals, the 

conservative assumption was employed that the LD50 equals (rather than exceeds) 2000 mg 

ai/kg-bw for mammals. The acute dose-based RQ for a 15g mammal exposed to a single 

granular application of indaziflam at 0.08 lbs ai/A is <0.01, less than the Agency’s acute risk 

LOCs. Considering the toxicity data and all proposed uses and application methods of 

indaziflam, and given that indaziflam is not expected to bioconcentrate in earthworm tissue, 

direct effects to mammals from chronic exposures are not expected. 

 4.2.5. Risk to Birds 

 

 Because the LD50 and LC50 values exceeded the highest treatment levels tested in the 

submitted acute oral and sub-acute dietary avian studies, standard RQs for acute and sub-acute 

exposure were not calculated in the Risk Estimation section of this assessment. However, 

sublethal effects were observed. Clinical signs of toxicity such as ruffled feathers, reduced 

reaction to stimulim, and lethargy were observed at the highest concentration tested (i.e. only 

concentration tested) in the acute dose-based oral study of zebra finch. One mortality also 

occurred in the zebra finch study although it was uncertain whether the mortality was treatmentrelated. Food consumption was inhibited in the mallard duck sub-acute dietary study at the 

highest test concentration of 5,215 mg/kg-diet with no effect reported at 2,518 mg a.i./kg-diet. In 

order to gain a better understanding of how the EECs for the maximum proposed indaziflam 

application rates relate to the toxicity data currently available for birds, T-REX was used to 
-Page 83 of 292- 

compare dose-based EECs with the toxicity endpoints (adjusted-LD50) using the conservative 

assumption that the highest value from the avian acute oral studies (i.e., acute LD50 = 2,000 mg 

a.i./kg-bw) and the NOAEC for the avian sub-acute dietary study (i.e., NOAEC = 2,518 mg 

a.i./kg-diet) represent the actual avian acute endpoints. For the proposed use pattern of 

indaziflam generating the highest terrestrial EECs in TREX (food use) dose-based EECs for 

three size classes of birds (20, 100, & 1000 grams) on all dietary items (short grass, tall grass, 

broadleaf plants/small insects, fruits/pods/seeds/large insects) ranged from 4.22 to 36.1 mg 

a.i./kg-bw. The adjusted toxicity endpoints for the three size categories of birds ranged from 

1440 to 2591 mg ai/kg-bw. Based on these two calculations, it is evident that the environment 

concentrations resulting from proposed uses on food would be at a minimum 39 times less than 

concentrations at which sublethal effects on an acute dose-basis have been observed in birds; the 

environmental concentrations for all other proposed used would be even lower. Using the same 

comparison for sub-acute exposure from proposed uses on food, dietary-based EECs for birds on 

all dietary items ranged from 1.98 to 31.7 mg a.i./kg. A comparison of the NOAEC of 2,518 mg 

a.i./kg-diet with these estimated environmental concentrations from indaziflam use shows that 

the environmental concentrations are at a minimum 79 times less than a concentration at which 

no sub-acute effects were observed in birds. Given these comparisons, and that the real LD50 is 

even greater than 2,000 mg a.i./kg-bw for dose-based exposures, acute and subacute effects from 

spray applications to non-target birds are not expected. 

 

For acute effects from proposed turf use via granules, T-REX was used to calculate a 

ratio of an adjusted LD50 to the square footage of applied area. This ratio, or risk estimate, is 

directly compared to the Agency’s levels of concern. Using the same conservative assumptions 

about the actual avian endpoints, the risk estimate for birds assuming weight classes – 20,100, & 

1000 grams – is ≤ 0.03, less than the acute risk to listed bird species LOC of 0.1. Given that the 

real LD50 is even greater than 2,000 mg a.i./kg-bw for dose-based exposures, acute risk to birds 

from proposed granular uses of indaziflam is low. Based on acute risk findings, mortality in 

birds from sub-acute exposure via granules is not expected. 

 Chronic RQs were derived as a screening exercise in the Risk Estimation section of this 

assessment for the non-definitive risk measure of effect to birds (NOAEC < 95 mg a.i./kg-diet). 

As a minimum level of risk, none of the RQs for any proposed spray uses of indaziflam exceeded 

the Agency’s chronic risk to birds LOC of 1.0. However, the maximum direct chronic risk to 

nonlisted and listed bird species in unknown and cannot be precluded with the available data. 

The toxicity study from which this endpoint is derived was conducted on mallard duck over ca.

22 weeks based on reduction in female weight gain and reduced adult food consumption. The 

study results are questionable and a second study on reproductive effects in mallard duck would 

greatly improve certainty in making a chronic risk call to birds. There is uncertainty regarding 

this study because not all validity criteria were met: egg shell thickness in control birds measured 

0.33 mm, less than the definitive test criteria requirement of 0.34 mm, indicating potential stress 

to the birds. Cage size was also reported to be 2,410 cm2

/adult bird, rather than the 

recommended 10,000 cm2/adult bird. Furthermore, effects observed for adult food consumption 

and female weight gain were also not dose dependent. A second study was conducted on 

mallard duck over the course of 6 weeks during the egg-laying phase. The lowest NOAEC, 

based on male body weight gain, was < 44 mg a.i./kg-diet. The NOAEC for female body weight 
-Page 84 of 292- 

gain was 44 mg a.i./kg-diet. These two endpoints are not directly comparable to the endpoints 

from the study conducted on mallard duck because weight was measured for only 6 weeks, 

instead of 22 weeks. However, these endpoints are lower and exploring what RQs would be 

based on the NOAEC of 44 mg a.i./kg-diet indicates listed and nonlisted species RQs would 

range from 0.72 to 0.01 for all uses (chronic risk to birds LOC = 1.0). Uncertainty exists in this 

6-week study because male birds per treatment level on average lost weight, rather than gained 

weight. Both reproductive studies suggest that indaziflam affects the dietary habitats and weight 

of the adult birds which would translate into decreased fitness and reproductive capacities in the 

environment. Whether reduction in food consumption is due to decreases in food palatibilty or 

loss of appetite is uncertain. Direct chronic risk to listed and nonlisted avian species cannot be 

precluded and is presumed for proposed uses of indaziflam. 

 

The same fugacity-based (equilibrium partitioning) approach that was used for mammals, 

with the same scenarios and assumptions, was used to assess risk of indaziflam granules to birds. 

Using the assumption that the chronic avian endpoint (NOAEC) is equal to 95 mg ai/kg-diet, the 

chronic RQ for a small bird (20 g) consuming indaziflam granules at an application rate of 0.080 

lbs a.i./A falls below the nonlisted and listed species risk LOC of 1.0 (<0.01). Using the 

assumption that the chronic avian endpoint (NOAEC) is equal to 44 mg ai/kg-diet, the chronic 

RQ for a small bird (20 g) consuming indaziflam granules at an application rate of 0.080 lbs 

a.i./A still falls below the nonlisted and listed species risk LOC of 1.0 (<0.01). However, 

because the data indicate the effects would be observed at concentrations lower than the lowest 

concetration tested, either 44 or 95 mg ai/kg, the potential for chronic effects to birds from the 

proposed granular use of indaziflam is presumed. 

 

The potential for direct mortality of nonlisted and listed birds (and to terrestrial-phase 

amphibian and reptiles for which birds serve as surrogates) from acute and subacute exposures of 

indaziflam for all proposed uses is not expected. Direct risk is presumed to nonlisted and listed 

birds from chronic exposures to all proposed uses and application methods of indaziflam. 

 4.2.6. Risk to Terrestrial Invertebrates 

The available toxicity data for honey bees indicate that direct contact and oral exposure to 

indaziflam is not likely to adversely affect beneficial terrestrial invertebrates such as pollinators 

(young adult forage bees) in and around proposed use areas for indaziflam. Affects to body 

weight were observed in earthworms from a 14-day study at concentrations of 562 and 1000 mg 

a.i./kg dw soil. Reproductive effects, i.e. number of offspring produced, were observed in a 56-

day study at concentrations of 60.3, 107, and 191 mg a.i./kg dw soil. As an exercise to 

characterize this toxicity at relevant environmental concentrations, an estimate was made as to 

the expected concentration of indaziflam in soil at the maximum single application rate of 0.125 

lbs a.i./A, assuming a soil depth of 15 cm and bulk density of 1.3 g/cm3

. Given this scenario, 

although rough, the predicted maximum soil concentration of indaziflam is 0.071 mg a.i./kg dw 

soil, which is more than 800 times smaller than the most sensitive effects endpoint from 

earthworm toxicity studies (60.3 a.i./kg dw soil). Therefore, the potential for direct risk to 

earthworms from exposure to indaziflam in soil is not expected. 
-Page 85 of 292- 

 4.2.7. Risk to Terrestrial & Semi-Aquatic Plants 

Tier II plant studies demonstrate the potential for indaziflam to affect terrestrial and semiaquatic plants. As was shown in Table 4.5, RQs exceed the Agency’s risk to plant LOC for 

nonlisted monocots inhabiting dry and semi-aquatic areas exposed to indaziflam via runoff and 

drift for aerial and ground applications for each use pattern with simgle maximum application 

rates ranging from 0.017 lbs a.i./A to 0.125 lbs a.i./A; RQs for listed monocots also exceed the 

Agency’s risk to plant LOC, based on all modeled use patterns and application rates. 

Additionally, the listed and non-listed species LOC is exceeded for all RQs calculated for dicots 

(Table 4.6), based on all proposed indaziflam use patterns. 

 

Given that RQ values for all proposed indaziflam broadcast spray uses are in excess of 

the LOC for terrestrial plants, the AgDRIFT model (Version 2.01) was used to refine the spray 

drift exposure estimate. Downwind spray drift buffers were evaluated to determine the distance 

required to dissipate spray drift RQs to below the LOC based on EC25 and NOAEC values from 

terrestrial plants that demonstrate the most sensitivity from either seedling emergence or 

vegetative vigor testing. Inputs for AgDRIFT modeling are provided in Table 4.11. Dissipation 

to the no effect and EC25 level was modeled in order to provide potential buffer distances that are 

protective of listed and non-listed terrestrial plant species, respectively. Drift buffers were 

derived for all proposed indaziflam uses based on associated application rates, application 

methods, and spray drift label language. For ground broadcast applications, four of the five 

labels proposing this application method explicitly discuss spray drift management (i.e. Spray 

Drift Management Section on label) and direct the user to not apply when wind speeds are 

greater than 10 miles per hour (mph), during temperature inversions, or when fog is present. The 

four labels are Esplanade F, Esplanade 200 SC, Indaziflam 200 SC, and Indaziflam 500 SC; 

BCS-AA10717 20 WSP does not include language on spray drift management. The labels also 

advise that the formulated products should only be applied when the potential for drift to 

adjacent sensitive areas (e.g. bodies of water) is minimal (e.g. wind blowing in opposite 

direction). The label for proposed aerial spraying, Esplanade F, includes language that directs 

the user to apply large droplets, defined as 150-200 microns, under low spray pressure. A 

summary of the results of the AgDRIFT modeling is presented in Table 4.12. Details 

concerning the specifics and uncertainties associated with the AgDRIFT model are available 

online at www.agdrift.com. 

Table 4.11. AgDRIFT Input Parameters: Most Sensitive1

 Terrestrial Plant Measurement 

Endpoints 

Test Type / Crop Most Sensitive 

Study Species 

NOAEC (lbs a.i./A) EC25 (lbs a.i./A) Most Sensitive 

Parameter 

Seedling Emergence: 

Dicot 

Oilseed Rape 0.00011 0.000062 Emergence 

1

 Oilseed rape demonstrated both the lowest NOAEC and EC25 values for terrestrial plants 
-Page 86 of 292- 

Table 4.12. Summary of AgDRIFT Modeling Results for Listed and Non-Listed 

Terrestrial Plant Species By Use Pattern

Distance (ft) from edge of field where LOC 

is no longer exceeded – 

Ground Application 

Distance (ft) from edge of field 

where LOC is no longer exceeded 

— Aerial Applications 

Use1

(Single Max 

Application Rate) Listed Plants4 Non-listed 

Plants5 

Listed Plants4 Non-listed 

Plants5 

Food - Normal Orchard2 

(0.085 lbs ai/A) 89 49 - - 

Food – Sparse Orchard3

(0.085 lbs ai/A) 334 259 - - 

Turf

(0.017 lbs ai/A) 528 341 - - 

Roadsides/Rights-of-way 

& Site Preparation 

(0.089 lbs ai/A) 

>997 900 - - 

Forested Areas 

(0.125 lbs ai/A) >997 >997 >997 >997 

1

 Only proposed uses of indaziflam for broadcast spray via ground or aerial methods were modeled with AgDrift. 2

Agdrift Tier I Orchard Use ‘Normal’ simulates an orchard with stone and pome fruit trees, or a vineyard, with application efficiency of 99.85%. 3

 Agdrift Tier I Orchard Use ‘Sparse’ simulates an orchard with young and dormant trees, with application efficiency of 97.69%. 4

 Most sensitive terrestrial plant NOAEC = 0.000062 lbs a.i./A (6.2x10E-5 lbs a.i./A) 5

 Most sensitive terrestrial plant EC25 = 0.00011 lbs a.i./A (1.1x10E-4 lbs a.i.A) 

 The results of AgDRIFT modeling show that spray drift buffers ranging from 89-334 feet 

for orchard uses would be necessary to reduce spray drift deposition below listed species levels 

of concern, while for non-listed species these buffers would need to be 49-259 feet. For turf, 

buffers of 528 and 341 feet would be necessary to create spray drift deposition below the level of 

concern for listed and non-listed plants, respectively. For ground and aerial broadcast 

applications to roadsides/rights-of-ways, site preparation, and forested areas, RQs exceed the 

nonlisted and listed species LOC for distances at or greater than 900 feet from the edge of field. 

 To further characterize the exposure to terrestrial plant species, RQs per use pattern were 

developed for spray drift exposures ranging from distances of 0 (on the field) to 950 feet off the 

field. Figure 4.1 depicts the nonlisted species RQs relative to distances off field, while Figure 

4.2 shows listed species RQs relative to distances off field. 
-Page 87 of 292- 

0.1

1

10

100

1000

0 100 200 300 400 500 600 700 800 900 1000

Distance From Edge Of Field

RQ

Food - Normal Orchard

Food- Sparse Orchard

Turf

Roadsides/Rights-of-ways/Site Prep

Forested Areas-Ground

Forested Areas - Aerial

 Figure 4.1: RQs for the most sensitive nonlisted terrestrial plant exposed to spray drift 

from propsed broadcast uses of indaziflam. The risk to nonlisted species LOC is 1.0 (RQ = 

1.0). 

0.1

1

10

100

1000

0 100 200 300 400 500 600 700 800 900 1000

Distance From Edge of Field (feet)

RQ

Food - Normal Orchard

Food- Sparse Orchard

Turf

NonCrop

Forested Areas-Ground

Forested Areas - Aerial

Figure 4.2: RQs for the most sensitive listed terrestrial plant exposed to spray drift from 

propsed broadcast uses of indaziflam. The risk to nonlisted species LOC is 1.0 (RQ = 1.0). 
-Page 88 of 292- 

 Alterations in proposed application rates would also reduce risk to terrestrial plants 

associated with spray drift deposition. For example, to be protective of nonlisted plants at a 

spray drift buffer distance of 300 ft, the single maximum application rate would need to be 

reduced to 0.019 lbs a.i./A, or 21% of current rates, for ground sprays to roadsides/rights-of-way 

& site preparation; reduced to 0.019 lbs a.i./A, or 15% of current rates for ground sprays to 

forested areas; and reduced to 0.0048 lbs a.i./A, or 4% of current rates for aerial sprays to 

forested areas. These reduced application rates along with the associated percentage of the 

current rate for distances ranging 200 to 900 feet off field are presented in Table 4.13. 

Table 4.13. Application rate (lbs a.i./A) per use pattern that would generate 

nonlisted terrestrial plant RQs below the LOC at specified distances from field 

(percentage of current rate in parentheses) 

Distance from 

Field (feet) 

Roadsides/Rights-ofways & Site Prep – 

Ground 

(0.089 lbs a.i./A) 

Forested Areas – 

Ground 

(0.125 lbs a.i./A) 

Forested Areas – 

Aerial 

(0.125 lbs a.i./A) 

200 0.012 (14%) 0.012 (9.6%) 0.0031 (2.5%) 

300 0.019 (21%) 0.019 (15%) 0.0048 (3.8%) 

400 0.028 (32%) 0.028 (22%) 0.0064 (5.1%) 

500 0.038 (43%) 0.038 (30%) 0.0078 (6.2%) 

600 0.049 (55%) 0.049 (39%) 0.0091 (7.3%) 

700 0.060 (67%) 0.060 (48%) 0.010 (8.0%) 

800 0.075 (84%) 0.075 (60%) 0.011 (8.8%) 

900 0.090 (101%) 0.090 (101%) 0.012 (9.6%) 

 Based on this anaylsis of spray drift exposure and resulting RQs at varying distances 

from the field, buffers of approximately 350 feet for broadcast applications of indaziflam would 

reduce RQs below the nonlisted species LOC for all turf and food uses; buffers of approximately 

550 feet would reduce RQs below the listed speices LOC for all turf and food uses. While RQs 

based on spray drift for other use patterns would still exceed the nonlisted and listed species 

LOCs, it is expected that these buffers of 350 or 550 feet would reduce the number of plant 

species ultimately affected. 

 

4.3. Uncertainties and Data Gaps 

4.3.1. Aquatic Exposure 

There is considerable uncertainty associated with the impervious (hardscape) and 

residential scenarios. A number of assumptions were employed in the modeling of these uses 

and may not represent actual use patterns. For example, for the estimation of risk, we assumed 

that 12% of a typical 1⁄4 acre residential lot in an urban/suburban environment would be 

impervious (hardscape) and could potentially be treated with indaziflam. It is uncertain how 

much of a residential watershed is considered an impervious surface, and also how much of the 

impervious surface would be treated with indaziflam; however, the assumptions that were made 

for aquatic modeling attempt to characterize a reasonable estimate of treated area. EFED 
-Page 89 of 292- 

recognizes that hardscapes may be spot treated, and not all impervious surfaces in a watershed 

are simultaneously treated, the actual amount of impervious surface in a residential watershed 

may vary. To the extent that actual use patterns and amount of treated impervious surfaces differ 

from modeling assumptions, actual environmental concentrations could be lower. EFED used 

the best available data to make a reasonalbly conservative estimate of the amount of hardscapes 

that could receive applications of indaziflam. 

There is considerable variability in the aerobic degradation rate. Four individual studies 

were submitted to fulfill the aerobic soil metabolism data requirement (OPPTS 835.4100) for all 

outdoor pesticides uses. All four studies were classified as Supplemental for various scientific 

reasons (e.g., replicates were not collected, multiple extraction methods were not employed, 

formation and decline of major degradates was not well characterized). Additional acceptable 

studies would help reduce the variability in the study results while reducing uncertainty of the 

biotic degradation of indaziflam. Particularly, studies that employ multiple extraction methods 

would reduce the uncertainty for aerobic soil half-lives. Further uncertainty regarding the halflives of indaziflam and, more importantly, its degradates would be reduced with additional 

studies conducted for a sufficient duration to accurately characterize the formation and decline of 

all major degradates (e.g., FDAT was detected at increasing concentrations at the termination of 

multiple stuides). 

Field and laboratory data indicate that indaziflam and, more importantly, its residues have 

a potential to leach to ground water, however based on the data submitted, the extent of the 

potential contamination is uncertain. Indaziflam is classified as moderately mobile; however 

transformation products of indaziflam are mobile to highly mobile. Specifically FDAT was 

detected at the deepest depths sampled (105-120 cm) in field studies and adsorption/desorption 

data indicate that it is very mobile. In the field studies, the limit of detection (LOD) for parent 

indaziflam and its transformation products was 0.3 ng a.i./g, and the limit of quatitation (LOQ) 

was 1.5 ng a.i./g for all studies. Indaziflam and its major transformation products were reported 

between the LOD and the LOQ in all field studies. Detections below the LOQ are not accurately 

characterized because of the gap between the LOD and the LOQ; therefore, the analytical 

method may have been too insensitive to accurately describe the leaching potential of indaziflam 

and its major transformation products. Replicate values below the LOQ were assumed at 

1⁄2(LOQ + LOD) for calculations of dissipation half-lives. 

 There is also uncertainty associated with the ability of the aquatic exposure modeling to 

simulate aquatic exposures as well as in the selection of input parameters. In this regard, one of 

the potentially important parameters that can impact concentration estimates is the selection of 

appropriate application dates. Although the pesticide application dates were selected to be most 

appropriate with considerations for application recommendations, model simulated cropping 

dates, and label restrictions, variability nevertheless results because the the time span that a 

pesticide may likely be applied may be large and the actual application dates are unknown. Such 

variability is caused by the temporal proximity of a pesticide application to rain events. As with 

all model estimates, the values presented here should not be viewed as precise estimates. 
-Page 90 of 292- 

4.3.2. Effects Uncertainties 

Terrestrial Modeling with T-REX

The exposure estimates for foliar applications from T-REX (v. 1.4.1) are based on the 

following assumptions. It is assumed that the taxon being modeled occupies, exclusively and 

permanently, the treatment area being modeled. Additionally, the model considers dietary 

exposure alone. Other potential routes of exposure (e.g., inhalation, dermal, incidental soil 

ingestion, or ingestion of drinking water) are currently not considered in the model. However, it 

is assumed that 100% of the diet consumed is contaminated. Furthermore, the organisms 

modeled are assumed to consume 100% of their diet as one food type, thereby eliminating the 

need at the screening level for evaluating mixtures of dietary items. Exposure estimates (EECS) 

from the model are directly related to water content. Eighty percent, as assumed in the model for 

all dietary items except seeds (10% water content for seeds is assumed), represents a high-end 

water content value. Higher water content assumptions would result in higher EECs. 

 For granular, bait, and treated seed applications, estimation of loadings of pesticide per 

unit area are calculated. This approach, which is intended to represent exposure via multiple 

routes and not just direct ingestion, considers observed effects in field studies and relates them to 

the pesticide applied to surface area. The amount of pesticide per square foot (relative to the 

application rate) is calculated using the following assumptions: In-furrow applications assume a 

typical value of 1% granules, bait, or seed remain unincorporated; incorporated banded 

treatments assume that 15% of granules, bait, seeds are unincorporated (this is an average of 

measurements ranging from 6 to 40 %); and broadcast treatment without incorporation assumes 

100% of granules, bait, seeds are unincorporated. 

 For the terrestrial exposure analysis of this risk assessment, a default 35-day foliar 

dissipation half-life was employed as an input to T-REX. The foliar dissipation half-life value is 

representative of the overall fate and transport of a pesticide relevant to foliar surfaces. Data on 

foliar dissipation half-lives was unavailable from the open literature, and residue half-lives could 

not be estimated from registrant-submitted magnitude of residue studies. Environmental fate 

studies demonstrate that indaziflam rapidly photolyzes in water with a half-life of 3.7 days at pH 

7 (MRID 47443208), and comparatively slower in soil with a half-life of 40.3 days in loamy 

same at pH 6.5, OC 2.4% (MRID 47443209). Given the photolysis route of degradation, the 35-

day foliar dissipation half-life may be a conservative assumption for the terrestrial exposure 

modeling of indaziflam’s proposed uses. 

Terrestrial modeling with TerrPlant 

 TerrpPlant (v. 1.2.2) does not consider exposures to plants from multiple applications of a 

pesticide, which could result in the underestimation of risks of effects to non-target plants. In 

addition, TerrPlant’s spray drift estimates are representative of pesticide deposition through 

spray drift on areas that are located approximately 200 feet from the edge of the field, resulting 

in an underestimation of exposure and risk to plants inhabiting areas within 200 feet from the 

edge of the treatment field. 
-Page 91 of 292- 

The magnitude of pesticide runoff is assumed to be dependent on the water solubility and 

incorporation depth of the pesticide, with no consideration of the partitioning or degradation of 

the pesticide. EC25 values of a pesticide for the most sensitive tested monocot and dicot species 

are entered by the model user to define the toxicity of the pesticide to non-listed species. The 

corresponding NOAEC values (or EC05 value if a suitable NOAEC is unavailable) for the same 

species and endpoint are entered to define the toxicity of the pesticide to listed plants. TerrPlant 

derives a total of 12 RQ values for non-listed and listed species of monocots and dicots 

inhabiting dry and semi-aquatic areas by considering exposure from combined runoff and drift 

and from drift alone. RQs are compared to EFED's LOC for non-listed and listed plant species 

(1.0). RQ values exceeding 1.0 indicate potential risk to plants. RQ values less than or equal to 

1.0 indicate that risk is minimal. 

Terrestrial Modeling with AgDrift

 Certain factors, including variations in topography, cover, and meteorological conditions 

over the transport distance are not accounted for by the AgDRIFT model (i.e., it generally 

models spray drift from aerial and ground applications in a flat area with little to no ground cover 

and a steady, constant wind speed and direction). Therefore, in most cases, the drift estimates 

from AgDRIFT may overestimate exposure, especially as the distance increases from the site of 

application, since the model does not account for potential obstructions (e.g., large hills, berms, 

buildings, trees, etc.). Furthermore, default conservative assumptions are made regarding the 

droplet size distributions being modeled (‘ASAE Very Fine to Fine’), release heights (i.e., ‘high 

boom’ for ground applications and 15 ft for aerial applications) and wind speeds (i.e., 15 mph), 

unless application restrictions are otherwise stipulated on the label(s). Alterations in any of these 

inputs would decrease the area of potential effect. Additionally, there is uncertainty associated 

with spray drift and whether multiple applications will result in the same level of exposure to the 

same organisms because spray drift will vary in time and space and organisms may move closer 

to or away from the site of application. 

Degradate Toxicity 

 The toxicity data on aquatic vascular and nonvascular plants indicate that indaziflamolefin and indaziflam-hydroxyethyl are of equal toxicity or are within an order of magnitude of 

toxicity to the parent indaziflam. Based on available studies, indaziflam-hydroxyethyl, FDAT, 

and triazine indanone demonstrate toxicity at magnitudes 2-7 times less than that of the parent. 

Considering all submitted effects studies, indaziflam-olefin and indaziflam-hydroxyethyl are the 

two major degradates of toxicological concern and aquatic exposure estimates are based on a 

total toxic residue approach of indaziflam + residues of concern (indaziflam-olefin and 

indaziflam-hydroxyethyl). One uncertainty with generating aquatic EECs with this total toxic 

residue approach is that the approach assumes that the toxicity of indaziflam-olefin and 

indaziflam-hydroxyethyl to aquatic invertebrates and fish could potentially be of the same order 

of magnitude as their demonstrated toxicities to aquatic plants from the submitted plant data. 

Ecotoxicity studies on fish and invertebrates were not submitted for the degradates indaziflamolefin and indaziflam-hydroxyethyl. Another uncertainty in generating aquatic EECs is that the 

degradate indaziflam-hydroxyethyl is assumed to be of similar toxicity to the TGAI although the 
-Page 92 of 292- 

available effects data show that it is one or more orders of magnitude less toxic to aquatic 

organisms. 

 

4.4. Addressing Risk Hypotheses 

To conclude this baseline risk assessment, it is necessary to address the risk hypotheses 

defined in Section 2.5.1. Based on the results of this assessment, both hypotheses cannot be 

rejected, meaning the statements represent concerns in term of effects of indaziflam use on 

nontarget listed and non-listed species. 

Given the uses of indaziflam and its environmental fate properties, there is a likelihood of 

exposure to non-target terrestrial and aquatic organisms. 

When used in accordance with the label, indaziflam results in potential adverse effects 

upon the survival, growth, and reproduction of non-target terrestrial and aquatic 

organisms. 

5. Federally Threatened and Endangered (Listed) Species 

Concerns 

 Section 7 of the Endangered Species Act, 16 U.S.C. Section 1536(a)(2), requires all 

federal agencies to consult with the National Marine Fisheries Service (NMFS) for marine and 

anadromous listed species, and/or the United States Fish and Wildlife Service (USFWS) for 

listed wildlife and freshwater organisms, if they are proposing an "action" that may affect listed 

species or their designated critical habitat. Each federal agency is required under the Act to 

ensure that any action they authorize, fund, or carry out is not likely to jeopardize the continued 

existence of a listed species or result in the destruction or adverse modification of designated 

critical habitat. To jeopardize the continued existence of a listed species means "to engage in an 

action that reasonably would be expected, directly or indirectly, to reduce appreciably the 

likelihood of both the survival and recovery of a listed species in the wild by reducing the 

reproduction, numbers, or distribution of the species" (50 C.F.R. § 402.02). 

 To facilitate compliance with the requirements of the Endangered Species Act 

(subsection (a)(2)), the Office of Pesticide Programs has established procedures to evaluate 

whether a proposed registration action may directly or indirectly appreciably reduce the 

likelihood of both the survival and recovery of a listed species in the wild by reducing the 

reproduction, numbers, or distribution of any listed species (USEPA, 2004). After the Agency’s 

screening level risk assessment is conducted, if any of the Agency’s listed species LOCs are 

exceeded for either direct or indirect effects, an analysis is conducted to determine if any listed 

or candidate species may co-occur in the area of the proposed pesticide use or areas downstream 

or downwind that could be contaminated from drift or runoff/erosion. If listed or candidate 

species may be present in the proposed action area, further biological assessment is undertaken. 

The extent to which listed species may be at risk is considered, which then determines the need 
-Page 93 of 292- 

for the development of a more comprehensive consultation package, as required by the 

Endangered Species Act. 

 The federal action addressed herein is the proposed new registration of indaziflam on 

agricultural and non-agricultural use sites. Given that indaziflam can be used on both 

agricultural and non-agricultural areas, it is expected that its use could occur nationwide. 

5.1. Action Area 

For listed species assessment purposes, the action area is considered to be the area 

affected directly or indirectly by indaziflam use and not merely the immediate area where 

indaziflam is applied. At the initial baseline, the risk assessment considers broadly described 

taxonomic groups and conservatively assumes that listed species within those broad groups are 

co-located with the pesticide treatment area. This means that listed terrestrial plants and wildlife 

are assumed to be located on or adjacent to the treated site and listed aquatic organisms are 

assumed to be located in a surface water body adjacent to the treated site. The assessment also 

assumes that the listed species are located within an assumed area, which has the relatively 

highest potential exposure to the pesticide, and that exposures are likely to decrease with 

distance from the treatment area. Section 3.1 of this risk assessment presents the proposed 

pesticide use sites that are used to establish initial co-location of species with treatment areas.

 5.2. Taxonomic Groups Potentially at Risk 

 

 If the assumptions associated with the baseline action area result in RQs that are below 

the listed species LOCs, a "no effect" determination conclusion is made with respect to listed 

species in that taxa, and no further refinement of the action area is necessary. Furthermore, RQs 

below the listed species LOCs for a given taxonomic group indicate no concern for indirect 

effects on listed species that depend upon the taxonomic group for which the RQ was calculated. 

However, in situations where the screening assumptions lead to RQs in excess of the listed 

species LOCs for a given taxonomic group, a potential for a "may affect" conclusion exists and 

may be associated with direct effects on listed species belonging to that taxonomic group or may 

extend to indirect effects upon listed species that depend upon that taxonomic group as a 

resource. In such cases, additional information on the biology of listed species, the locations of 

these species, and the locations of use sites are considered to determine the extent to which 

screening assumptions regarding an action area apply to a particular listed organism. These 

subsequent refinement steps will consider how this information would impact the action area for 

a particular listed organism and potentially include areas of exposure that are downwind and 

downstream of the pesticide use site. 

 Assessment endpoints, exposure pathways, and the conceptual models addressing 

proposed new indaziflam uses, and the associated exposure and effects analyses conducted for 

the indaziflam baseline risk assessment are in Sections 2 to 3. The assessment endpoints used in 

the baseline risk assessment include those defined operationally as reduced survival and 

reproductive impairment for both aquatic and terrestrial animal species and survival, 

reproduction, and growth of aquatic and terrestrial plant species from both direct acute and 
-Page 94 of 292- 

chronic exposures. These assessment endpoints are intended to address the standard set forth in 

the Endangered Species Act requiring federal agencies to ensure that any action they authorize 

does not appreciably reduce the likelihood of both the survival and recovery of a listed species in 

the wild by reducing the reproduction, numbers, or distribution of the species. Risk estimates 

(RQs) which, integrating exposure and effects, are calculated for broad based taxonomic groups 

in the baseline risk assessment presented in Section 4.

 Both acute endangered species and chronic risk LOCs are considered in the baseline risk 

assessment to identify direct and indirect effects to taxa of listed species. This section identifies 

direct effect concerns, by taxa, that are triggered by exceeding endangered LOCs in the baseline 

risk assessment, with an evaluation of the potential probability of individual effects for exposures 

that may occur at the established endangered species LOC. Data on exposure and effects 

collected under field and laboratory conditions are evaluated to make determinations on the 

predictive utility of the direct effect screening assessment findings to listed species. 

Additionally, the results of the screen for indirect effects to listed species, using direct 

effect acute and chronic LOCs for each taxonomic group, is presented and evaluated. For plants, 

if plant RQs fall between the endangered species and non-endangered species LOCs (for 

indaziflam’s proposed uses this occurs for aquatic nonvascular species), the Agency concludes a 

no effect determination for listed species that rely on multiple plants species to successfully 

complete their life cycle (termed plant dependent spcies); alternatively, the Agency assumes a 

potential for adverse effects to those listed species that rely on a specific plant species in their 

life cycle (termed plant species obligates). If plant RQs for listed species are above the risk to 

plant LOCs (for indaziflam’s proposed uses this occurs for aquatic vasculars and all terrestrial 

species), the Agency considered this to be indicative of a potential for adverse effects to those 

listed species that rely either on a specific plant species (plant species obligate) or multiple plant 

species (plant dependent) for some important aspect of their life cycle. 
-Page 95 of 292- 

Table 5.1. Potential Effects to Federally Listed Taxa Associated with Direct or Indirect 

Effects from the Proposed New Uses of Indaziflam. 

Listed Taxon Direct 

Effects Uses of Concern Indirect Effects1 Uses of Concern 

Terrestrial and semi-aquatic 

plants - monocots Yes All uses Yesb All uses 

Terrestrial and semi-aquatic 

plants - dicots Yes All uses Yesb All uses 

Terrestrial invertebrates No None Yes All uses 

Birds* Yes All uses Yes All uses 

Terrestrial-phase amphibians 

and reptiles* Yes All uses Yes All uses 

Mammals No None Yes All uses 

Aquatic nonvascular plants Yes Home lawn, 

Onamentals Yesa All uses 

Aquatic vascular plants Yes All uses Yesb All uses 

Freshwater fish No All uses Yes All uses 

Aquatic-phase amphibians No All uses Yes All uses 

Freshwater crustaceans No All uses Yes All uses 

Mollusks** Yes All uses Yes All uses 

Marine/estuarine fish No All uses Yes All uses 

Marine/estuarine 

invertebrates** Yes All uses Yes All uses 

* due to presumed chronic risks to birds from inadequacy of data 

** due to presumed chronic risk from lack of data 

a potential for indirect adverse effects to those listed species that rely on a specific plant species in their life cycle (termed plant species obligates). b

 potential for adverse effects to those listed species that rely either on a specific plant species (plant species obligate) or multiple plant species 

(plant dependent) for some important aspect of their life cycle.

1 Potential indirect effects on a taxon attributable to direct effects on that respective taxon and/or direct effects on aquatic and terrestrial plants.

 5.2.1. Probit Dose-Response Analysis 

The Agency uses the probit dose-response relationship as a tool for providing additional 

information on the potential for acute direct effects to aquatic and terrestrial animals (USEPA, 

2004). As part of this evaluation, the acute RQ for listed species is presented in terms of the 

chance of an individual event (i.e., mortality or immobilization) should exposure at the EEC 

actually occur for a species with sensitivity to indaziflam on par with the acute toxicity endpoint 

selected for RQ calculation. To accomplish this interpretation, the Agency uses the slope of the 

dose-response relationship available from the toxicity study used to establish the acute toxicity 

measures of effect for each taxonomic group that is relevant to this assessment. The individual 

effects probability associated with the acute RQ is based on the mean estimate of the slope and 

an assumption of a probit dose-response relationship. In addition to a single effects probability 

estimate based on the mean, upper and lower estimates of the effects probability are also 

provided to account for variance in the slope, if available. Based on the available acute toxicity 

for indaziflam, a summary of the probit dose-response analysis is provided in Table 5.2. If no 

dose response information is available to estimate a slope for this analysis, a default slope 

assumption of 4.5 (with lower and upper bounds of 2 to 9) (Urban and Cook, 1986) is used. 
-Page 96 of 292- 

 Individual effect probabilities are calculated based on an Excel spreadsheet tool IECV1.1 

(Individual Effect Chance Model Version 1.1) developed by the U.S. EPA, OPP, Environmental 

Fate and Effects Division (June 22, 2004). The model allows for such calculations by entering 

the mean slope estimate (and the 95% confidence bounds of that estimate) as the slope parameter 

for the spreadsheet. The desired threshold for the probability of an individual effect is entered as 

the listed species LOC. In addition, the probability of an individual effect is also derived based 

on the calculated acute RQ, if available. 

Table 5.2. Summary of Indaziflam Probit Dose Response Analysis for Listed Species 

Taxa (study type) Acute Effect1

Slope (95% C.I.) 

Chance of Individual 

Effect at Listed Species 

LOC (95% C.I.) 

Chance of Individual 

Effect at Derived Acute 

RQ1 (95% C.I.) 

Bird oral dose No mortality observed Not calculated; no 

mortality observed 

Not calculated; no 

mortality observed

Bird dietary No mortality observed Not calculated; no 

mortality observed

Not calculated; no 

mortality observed

Mammal oral dose No mortality observed Not calculated; no 

mortality observed

Not calculated; no 

mortality observed

Freshwater fish1 Mortality 

Slope NA = 4.5 (2 - 9) 

1 in 4.18x108

(1 in 216 to 1 in 

1.75x1031)

1 in 9.60x1013

(1 in 2,950 to 2.27x1052) 

Freshwater invertebrate2 

35% 

Immobilization/mortality 

Slope = N/A 

Not Calculated2 Not Calculated 

Estuarine/marine fish3 Mortality 

Slope NA = 4.5 (2 - 9) 

1 in 4.18x108

(1 in 216 to 1 in 

1.75x1031)

1 in 8.86x1018

(1 in 3.16x104

 to 1 in 

1.03x1072)

Estuarine/marine 

invertebrate4 

Mortality 

Slope = 4.04 (3.30 - 4.78) 

1 in 1.36x107

(1 in 1.14x105

 to 1 in 

1 in 3.09x1015

(1 in 4.86x1010 to 1 in 

1.70x1021) 1

 Acute RQ for freshwater fish = 0.02 

2 RQs were not derived because the concentration at which <50% mortality was observed (9,880 μg a.i./L) is well above the peak surface water 

concentration of indaziflam (6.19 μg/L).

3

 Acute RQ for estuarine/marine fish = 0.01 

4

 Acute RQ for estuarine/marine invertebrates = 0.01 

 The probability for acute direct effects (i.e., mortality) to individual listed freshwater fish 

at the listed species LOC (0.05) is 1 in 4.18x108

 (<0.01%). However, at the highest derived RQ 

value for the proposed uses of indaziflam, the chance of an individual effect to listed freshwater 

fish decreases to approximately 1 in 9.60x1013 (<0.01%). The probability for acute direct effects 

to estuatine/marine fish and invertebrates show a similar relationship between the the chance of 

individual effect at the listed species LOC and the chance of individual effects at the derived 

acute RQ. The chance of an individual effect was not derived for taxa if no mortality was 

observed in acute studies or “<50% effect levels” were well above estimated peak concentrations 

of surface water EECs. 

 5.2.2. Listed Species Occurrence Associated with Indaziflam Use 

The goal of the co-location analysis is determine whether sites of pesticide use are 

geographically associated with known locations of listed species [following the convention of the 
-Page 97 of 292- 

Services, the word ‘species’ in this assessment may apply to a ‘species’, ‘subspecies’, or an 

Evolutionary Significant Unit (ESU)]. At the screening level, this analysis is accomplished 

using the LOCATES database (version 2.10.3). The database uses location information for listed 

species at the county level and compares it to agricultural census data (from 2002) for crop 

production at the same county level of resolution. The product is a listing of Federally-listed 

species that are located in counties known to produce the crops upon which the pesticide will be 

used. 

Indaziflam is proposed for use on agricultural and non-agricultural areas, with nonagricultural use patterns representing the highest application rates. Due to the off-site risk to 

terrestrial and aquatic vascular plants, all taxa that rely on these plants for some stage of their life 

cycle may be indirectly affected. Based on the extent of proposed uses and the potential for 

indirect effects, all listed species occurring nationwide may be potentially affected by a new 

registration of indaziflam. Therefore, state- and county-level summaries from LOCATES are not 

provided. However, a summary of listed species that may be directly or indirectly affected by 

the proposed new uses of indaziflam is provided in Appendix M. Based the results of the 

LOCATES database query, there are a total of 2165 listed species from all taxa associated with 

counties where indaziflam may potentially be used nationwide for non-agricultural purposes. 

This preliminary analysis indicates that there is a potential for indaziflam use to overlap 

with listed species and that a more refined assessment is warranted. The more refined 

assessment should involve clear delineation of the action area associated with proposed uses of 

indaziflam and the best available information on the temporal and spatial co-location of listed 

species with respect to the action area. This analysis has not been conducted for this assessment. 
-Page 98 of 292- 

6. References 

Carousel, R.F., J.C. Imhoff, P.R. Hummel, J.M. Cheplick, A.S. Donigian, Jr., L.A. Suarez. 

Undated. PRZM-3, A Model for Predicting Pesticide and Nitrogen Fate in the Crop Root 

and Unsaturated Soil Zones: Users Manual for Release 3.12.2. National Exposure 

Research Laboratory, Office of Research and Development, U.S. Environmental 

Protection Agency, Athens, GA; AQUA TERRA Consultants, Mountain View, CA; 

Waterborne Environmental, Inc., Leesburg, VA. 

Mackay, D. And S. Paterson. 1981. Calculating fugacity. Environ. Sci. Technol. 15: 1006-

1014. 

Trapp, S. And J.C McFarlane (eds.). 1995. Plant Contamination Modeling and Simulation of 

Organic Chemical Processes. Lewis Publishers. Boca Raton, Florida. 

USEPA 1998. Guidelines for Ecological Risk Assessment. EPA/630/R-95/002F. Published in 

63 FR 26846; May 14, 1998. U.S. Environmental Protection Agency, Washington, DC. 

April, 1998. 

USEPA. 2002a. Guidance for Selecting Input Parameters in Modeling the Environmental Fate 

and Transport of Pesticides. U.S. Environmental Protection Agency, Office of 

Prevention, Pesticides and Toxic Substances, Office of Pesticide Programs, 

Environmental Fate and Effects Division, Feb. 28, 2002. Online at: 

http://www.epa.gov/oppefed1/models/water/input_guidance2_28_02.htm/ 

USEPA. 2002b. SCI-GROW User’s Manual. U.S. Environmental Protection Agency, Office of 

Pesticide Programs, Environmental Fate and Effects Division. Nov. 1, 2001; revised 

Aug. 23, 2002. 

USEPA. 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. Online at: 

http://www.epa.gov/oppfead1/endanger/consultation/ecorisk-overview.pdf

USEPA 2006a. Standardized Soil Mobility Classification Guidance. U.S. Environmental 

Protection Agency, Office of Prevention, Pesticides and Toxic Substances, Office of 

Pesticide Programs, Environmental Fate and Effects Division, Memorandum. Apr. 21, 

2006. 

USEPA. 2006b. User’s Guide: TerrPlant Version 1.2.2 (Terrestrial Residue Exposure model). 

 United States Environmental Protection Agency. Environmental Fate and Effects 

 Division. Office of Pesticide Programs. U.S. Environmental protection Agency. 

 Washington, D.C. December 26, 2006. 
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USEPA 2008a. Label Review Manual, November, 2008. US Environmental Protection Agency, 

Office of Pesticide Programs, Washington, D.C. 

http://www.epa.gov/oppfead1/labeling/lrm/. 

USEPA 2008b. White Paper on Methods for Assessing Ecological Risks of Pesticides with 

Persistent, Bioaccumulative and Toxic Characteristics. Submitted to the FIFRA Scientific 

Advisory Panel. October 28-31, 2008. Office of Pesticide Programs, Environmental Fate 

and Effects Division, Washington, D.C. 

USEPA 2008c. User’s Guide: T-REX Version 1.4.1 (Terrestrial Residue Exposure model). 

 United States Environmental Protection Agency. Environmental Fate and Effects 

 Division. Office of Pesticide Programs. U.S. Environmental Protection Agency. 

 Washington, D.C. October 9, 2008. 

USEPA 2009a. ECOTOX (ECOTOXicology) Database (Version 4.0). Office of Research and 

Development (ORD) and the National Health and Environmental Effects Research 

Laboratory's (NHEERL's) Mid-Continent Ecology Division (MED). Online at: 

http://cfpub.epa.gov/ecotox/ecotox_home.cfm 

USEPA 2009b. Water Models. U.S. Environmental Protection Agency, Pesticides: Science and 

Policy, Models and Databases. Last updated Mar. 23, 2009. Online at: 

http://www.epa.gov/oppefed1/models/water/

USEPA 2009c. Guidance for Selecting Input Parameters in Modeling the Environmental Fate 

and Transport of Pesticides. U.S. Environmental Protection Agency, Office of 

Prevention, Pesticides and Toxic Substances, Office of Pesticide Programs, 

Environmental Fate and Effects Division, Oct. 22, 2009. Online at: 

http://www.epa.gov/oppefed1/models/water/input_parameter_guidance.htm

USEPA. 2009d. DP barcode: 371659 Indaziflam. Report of the Residues of Concern 

 Knowledgebase Subcommittee (ROCKS). USEPA/OPP, Washington, DC. 

USFWS/NMFS. 2004. 50 CFR Part 402. Joint Counterpart Endangered Species Act Section 7 

Consultation Regulations; Final Rule. FR 47732-47762. 

Urban, D.J. and N.J. Cook, 1986. Hazard Evaluation Division Standard Evaluation Procedure 

Ecological Risk Assessment. EPA 540/9-85-001. U.S. Environmental Protection 

Agency, Office of Pesticide Programs, Washington D.C. 

Willis, G.H., and L.L. McDowell. 1987. Pesticide Persistence on Foliage in Reviews of 

Environmental Contamination and Toxicology. 100: 23-73. 
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6.1. Submitted Product Chemistry and Environmental Fate Studies 

47443203 Stupp, H.; Augustin, T. (2006) [Triazine-2,4-(Carbon 14)] AE 1170437: Adsorption/Desorption on Five 

Soils. Project Number: M/274409/01/2, MEF/05/383, M1311473/0. Unpublished study prepared by 

Bayer CropScience. 84 p. 

47443204 Simmonds, M. (2006) [Carbon 14]-AE 1170437-triazine-indanone: Adsorption to and Desorption from 

Five Soils. Project Number: M/275499/02/2, CX/05/042. Unpublished study prepared by Battelle UK, 

Ltd. 99 p. 

47443205 Simmonds, M. (2006) [Carbon 14]-AE 1170437-diaminotriazine: Adsorption to and Desorption from 

Five Soils. Project Number: M/275442/01/2, CX/05/041. Unpublished study prepared by Battelle UK, 

Ltd. 96 p. 

47443206 Simmonds, M.; Brett, R. (2006) [Carbon 14]-AE 1170437-carboxylic acid: Adsorption to and 

Desorption from Five Soils. Project Number: M/275561/01/2, CX/05/043. Unpublished study prepared 

by Battelle UK, Ltd. 97 p. 

47443207 Sneikus, J. (2007) [Triazine-2,4-(Carbon 14)] and [indane-3-13/(Carbon 14)]AE 1170437: Hydrolytic 

Degradation. Project Number: M/294681/01/2, MEF/07/177, M1111669/5. Unpublished study prepared 

by Bayer CropScience AG. 70 p. 

47443208 Dehner, D.; Heinemann, O. (2006) [Indane-3-(Carbon 13)/(Carbon 14)] AE 1170437 and [triazine-2,4-

(Carbon 14)] AE 1170437: Phototransformation in Water. Project Number: M/283818/01/2, 

MEF/06/201, M1121572/9. Unpublished study prepared by Bayer CropScience. 99 p. 

47443209 Stupp, H.; Augustin, T. (2007) [Triazine-2,4-(Carbon 14)] and [indane-3-(Carbon 13)/(Carbon 14)]AE 

1170437: Phototransformation on Soil. Project Number: M/295259/01/2, MEF/06/137, M1121506/6. 

Unpublished study prepared by Bayer CropScience. 111 p. 

47443210 Shepherd, J. (2008) [Indane-3-(Carbon 13)/(Carbon 14)]AE 1170437: Aerobic Soil Metabolism in Two 

US Soils. Project Number: M/296489/01/1, MEDHP013. Unpublished study prepared by Bayer 

CropScience. 177 p. 

47443211 Shepherd, J. (2008) [Triazine-2,4-(Carbon 14)]AE 1170437: Aerobic Soil Metabolism in Two US Soils. 

Project Number: M/296492/01/1, MEDHP032. Unpublished study prepared by Bayer CropScience. 186 

p. 

47443212 Stupp, H.; Augustin, T. (2007) [Indane-3-(Carbon 13/14)] AE 1170437: Aerobic Soil Metabolism in 

Four EU Soils. Project Number: M/295160/01/2, MEF/06/19, M1251497/9. Unpublished study prepared 

by Bayer CropScience AG. 98 p. 

47443213 Stupp, H.; Augustin, T. (2007) [Triazine-2,4-(Carbon 14)]AE 1170437: Aerobic Soil Metabolism in 

Four EU Soils. Project Number: M/290409/01/2, MEF/06/299, M1251406/9. Unpublished study 

prepared by Bayer CropScience. 108 p. 

47443214 Sneikus, J. (2008) [Triazine-2,4-(Carbon 14)]AE 1956114 (diaminotriazine): Aerobic Soil Metabolism 

in Three EU Soils. Project Number: M/297565/01/2, MEF/05/517, M1251511/6. Unpublished study 

prepared by Bayer CropScience. 80 p. 

47443215 Heinemann, O. (2008) AE 1170437 and AE 1170438: Comparative Aerobic Soil Degradation in Two 

EU Soils. Project Number: M/299297/01/2, MEF/08/004, M1251704/0. Unpublished study prepared by 

Bayer CropScience. 78 p. 

47443216 Stupp, H. (2006) [Triazine-2,4-(Carbon 14)] and [indane-3-(Carbon 13/Carbon 14)]AE 1170437: 

Anaerobic Soil Metabolism. Project Number: M/283258/01/2, MEF/06/355, M1261526/3. Unpublished 

study prepared by Bayer CropScience AG. 107 p. 
-Page 101 of 292- 

47443217 Stupp, H. (2007) [Triazine-2,4-(Carbon 14)] and [indane-3-Carbon 13/14)]AE 1170437: Aerobic 

Aquatic Metabolism. Project Number: M/296164/01/2, MEF/07/283, M1511579/9. Unpublished study 

prepared by Bayer CropScience AG. 131 p. 

47443218 Mathew, A. (2007) [Indane-3-(Carbon 13/Carbon 14)]AE 1170437: Anaerobic Aquatic Metabolism. 

Project Number: M/290001/01/2, MEDHP017. Unpublished study prepared by Bayer CropScience. 64 

p. 

47443219 Mathew, A. (2007) [Triazine-2,4-(Carbon 14)]AE 1170437: Anaerobic Aquatic Metabolism. Project 

Number: M/289074/01/2, MEDHP022. Unpublished study prepared by Bayer CropScience. 64 p. 

47443220 Lenz, M. (2008) Terrestrial Field Dissipation of AE 1170437 in California Soil Cropped with Turf, 

2006. Project Number: M/303529/01/1, MEDHP014. Unpublished study prepared by Bayer 

CropScience, Agvise Laboratories, and Research for Hire. 251 p. 

47443221 Lenz, M. (2008) Terrestrial Field Dissipation of AE 1170437 in Florida Soil Cropped with Turf, 2006. 

Project Number: M/303697/01/1, MEDHP035, DH/002/S06/01. Unpublished study prepared by Bayer 

CropScience, Agvise Laboratories, and Ag Research Associates. 240 p. 

47443222 Lenz, M. (2008) Terrestrial Field Dissipation of AE 1170437 in North Carolina Soil Cropped with Turf, 

2006. Project Number: M/303532/01/1, MEDHP034, DH/002/506/1. Unpublished study prepared by 

Bayer CropScience, Agvise Laboratories, and Agricultural Systems Associates. 246 p. 

47443223 Lenz, M. (2008) Terrestrial Field Dissipation of AE 1170437 in California Soil, 2006. Project Number: 

M/303704/01/1, MEDHP038, DH/002/S06/01. Unpublished study prepared by Bayer CropScience, 

Agvise Laboratories, and Research for Hire. 251 p. 

47443224 Lenz, M. (2008) Terrestrial Field Dissipation of AE 1170437 in Florida Soil, 2006. Project Number: 

M/303702/01/1, MEDHP037, DH/002/S06/01. Unpublished study prepared by Bayer CropScience, 

Agvise, Inc. and Ag Research Associates. 242 p. 

47443225 Lenz, M. (2008) Terrestrial Field Dissipation of AE 1170437 in North Carolina Soil, 2006. Project 

Number: M/303701/01/1, MEDHP036. Unpublished study prepared by Bayer CropScience, Agvise Inc. 

and Agricultural Systems Associates. 253 p. 

47443237 Matlock, D.; Fischer, D. (2008) [Triazine-2,4-(Carbon 14)] AE 1170437- Bioconcentration and 

Biotransformation in Bluegill Sunfish (Lepomis macrochirus). Project Number: M/303425/01/1, 

MEDHP026. Unpublished study prepared by Bayer CropScience. 218 p. 

47443279 Netzband, D. (2008) Stability of AE1170437 and its Metabolites (AE1170437 Acid, AE1170437 ketone, 

AE1170437 Hydroxy, AE1170437 Olefin, AE1170437 Diaminotriazine) in Soil During Frozen Storage 

(Reported Through a Maximum of 433 Days Storage). Project Number: M/302527/01/1, RADHP041. 

Unpublished study prepared by Bayer CropScience. 56 p. 

47793401 Mislankar, S. (2009) Supplemental Information on Foreign Soils Used in the Aerobic Soil Metabolism 

Study (BCS-AA10717 Technical Herbicide). Unpublished study prepared by Bayer CropScience LP.9 p.

47743301 Lenz, M. (2009) Terrestrial Field Dissipation of AE 1170437 in Washington Soil, 2006. Project 

Number: M/345376/01/1/OCR, MEDHP019. Unpublished study prepared by Bayer CropScience, 

Agvise Laboratories, Inc., and Qualls Ag Laboratory. 264 p. 

47743302 Lenz, M. (2009) Terrestrial Field Dissipation of AE 1170437 in New York Soil, 2006. Project Number: 

M/346142/01/1/OCR, MEDHP033. Unpublished study prepared by Bayer CropScience, Agvise 

Laboratories, Inc., and A.C.D.S. Research, Inc. 268 p. 

47743328 Netzeband, D. (2009) Stability of AE1170437 and its Metabolites (AE1170437 Acid, AE1170437 

Ketone, AE1170437 Hydroxy, AE1170437 Olefin, AE1170437 Diaminotriazine) in Soil During Frozen 

Storage (Reported Through a Maximum of 736 Days Storage). Project Number: M/302527/02/1/OCR, 

RADHP041/1. Unpublished study prepared by Bayer CropScience. 56 p. 
-Page 102 of 292- 

6.2. Submitted Ecotoxicity Studies 

MRID 47443226: Banman, C. S.; Hoffmann, J. M.; Lam, C. V.; Acute toxicity of AE 1170437 technical to the 

 Daphnia magna under static conditions;Bayer CropScience LP, Stilwell, KS, USA; Report No.: 

 EBDHP021; Document No.: M-282376-01-2; December 01, 2006; Pages: 38 

MRID 47443227: Gallagher, S. P.; Kendall, T. Z.; Krueger, H.O.; AE 1170437: A 96-hour static acute toxicity test 

 with the saltwater mysid (Americamysis bahia);Wildlife International Ltd., Easton, MD, USA; Report No.: 

 EBDHP026; Document No.: M-292052-01-1; August 20, 2007; Pages: 44 

MRID 47443228: Gallagher, S. P.; Kendall, T. Z.; Krueger, H. O.; AE 1170437: A 96-hour shell deposition test 

 with the eastern oyster (Crassostrea virginica);Wildlife International Ltd., Easton, MD, USA; Report No.: 

 EBDHP027; Document No.: M-300719-01-1; April 07, 2008; Pages: 62 

MRID 47443229: Matlock, D.; Lam, C. V.; Acute toxicity of AE 1170437 technical to the fathead minnow 

 (Pimephales promelas) under static conditions;Bayer CropScience LP, Stilwell, KS, USA; Report No.: 

 EBDHP122; Document No.: M-302402-01-1; June 05, 2008; Pages: 46 

MRID 47443230: Matlock, D.; Lam, C. V.; Acute toxicity of BCS_AA10365 (AE 1170437-diaminotriazine) to the 

 fathead minnow (Pimephales promelas) under static conditions;Bayer CropScience LP, Stilwell, KS, USA; 

 Report No.: EBDHP126; Document No.: M-302862-01-1; June 17, 2008; Pages: 43 

MRID 47443231: Matlock, D.; Lam, C. V.; Acute toxicity of AE 2158969 (AE 1170437-carboxylic acid) to the 

 fathead minnow (Pimephales promelas) under static conditions;Bayer CropScience LP, Stilwell, KS, USA; 

 Report No.: EBDHP125; Document No.: M-302522-01-1; June 09, 2008; Pages: 43 

MRID 47443232: Banman, C. S.; Lam, C. V.; Acute toxicity of AE 1170437 technical to the sheepshead minnow 

 (Cyprinodon variegatus) under static conditions;Bayer CropScience LP, Stilwell, KS, USA; Report No.: 

 EBDHP019; Document No.: M-288882-01-1; May 08, 2007; Pages: 43 

MRID 47443233: Banman, C. S.; Lam, C. V.; Acute toxicity of AE 1170437 technical to the bluegill (Lepomis 

 machrochirus) under static conditions;Bayer CropScience LP, Stilwell, KS, USA; Report No.: EBDHP018; 

 Document No.: M-288881-01-1; May 08, 2007; Pages: 41 

MRID 47443234: Banman, C. S.; Hoffmann, J. M.; Lam, C. V.; Acute toxicity of AE 1170437 technical to the trout 

 (Oncorhynchus mykiss) under static conditions;Bayer CropScience LP, Stilwell, KS, USA; Report No.: 

 EBDHP039-1; Document No.: M-293173-02-1; June 04, 2008; Pages: 40 

MRID 47443235: Banman, C. S.; Roberts, J. A.; Lam, C. V.; Chronic toxicity of AE 1170437 technical to the 

 Daphnia magna under static renewal conditions;Bayer CropScience LP, Stilwell, KS, USA; Report No.: 

 EBDHP053; Document No.: M-291493-01-1; July 12, 2007; Pages: 69 

MRID 47443236: Banman, C. S.; Roberts, J. A.; Lam, C. V.; Early life stage toxicity of AE 1170437 technical to 

 the fathead minnow (Pimephales promelas) under flow-through conditions;Bayer CropScience LP, Stilwell, 

 KS, USA; Report No.: EBDHP020; Document No.: M-292051-01-1; August 29, 2007; Pages: 100 

MRID 47443237: Matlock, D.; Fischer, D. R.; [Triazine-2,4-14C] AE 1170437- Bioconcentration and 

 biotransformation in Bluegill sunfish (Lepomis macrochirus);Bayer CropScience LP, Stilwell, KS, USA; 

 Report No.: MEDHP026; Document No.: M-303425-01-1; June 30, 2008; Pages: 218 

MRID 47443238: Putt, A. E.; AE1170437 - Toxicity to midge (Chironomus tentans) during a 10-day sediment 

 exposure;Springborn Smithers Laboratories, Wareham, MA, USA; Report No.: EBDHP067; Document 

 No.: M-302577-01-1; June 02, 2008; Pages: 69 
-Page 103 of 292- 

MRID 47443239: Putt, A. E.; AE1170437 - Toxicity to marine amphipods (Leptocheirus plumulosus) during a 10-

 day sediment exposure;Springborn Smithers Laboratories, Wareham, MA, USA; Report No.: EBDHP066; 

 Document No.: M-302580-01-1; June 02, 2008; Pages: 62 

MRID 47443240: Stoughton, T. L.; Christ, M. T.; Toxicity of AE 1170437 technical during an acute oral LD50 with 

 the Northern bobwhite quail (Colinus virginianus);Bayer CropScience LP, Stilwell, KS, USA; Report No.: 

 EBDHP028; Document No.: M-303029-01-1; June 16, 2008; Pages: 29 

MRID 47443241: Stoughton, T. L.; Christ, M. T.; Lam, C. V.; Technical AE 1170437: A subacute dietary LC50 

 with northern bobwhite;Bayer CropScience LP, Stilwell, KS, USA; Report No.: EBDHP030; Document 

 No.: M-303033-01-1; June 17, 2008; Pages: 37 

MRID 47443242: Stoughton, T. L.; Lam, C. V.; Technical AE 1170437: A subacute dietary LC50 with 

 mallards;Bayer CropScience LP, Stilwell, KS, USA; Report No.: EBDHP031; Document No.: M-303037-

 01-1; June 16, 2008; Pages: 37 

MRID 47443243: Christ, M. T.; Lam, C. V.; Effect of technical AE 1170437 on northern bobwhite quail (Colinus 

 virginianus) reproduction;Bayer CropScience LP, RTP, NC, USA; Report No.: EBDHP032 ; Document 

 No.: M-304696-01-1; July 28, 2008; Pages: 72 

MRID 47443244: Christ, M. T.; Lam, C. V.; Toxicity of AE 1170437 technical on reproduction to the mallard duck 

 (Anas platyrhynchos) and modified exposure of AE 1170437 technical on reproduction to the mallard duck 

 (Anas platyrhynchos);Bayer CropScience LP, RTP, NC, USA; Report No.: EBDHP033 & EBUFL002; 

 Document No.: M-304690-01-1; July 28, 2008; Pages: 121 

MRID 47443245: Barth, M.; Acute toxicity of AE 1170437 a.i. tech. to the honeybee Apis mellifera L. under 

 laboratory conditions;BioChem agrar GmbH, Gerichshain, Germany; Report No.: 06 10 48 064; Document 

 No.: M-280047-02-2; June 16, 2008; Pages: 35 

MRID 47443246: Bach, F.; Nguyen, D.-H.; AE 1170437 WP 20 percent w/w: Effects on the seedling emergence 

 and seedling growth of ten species of non-target terrestrial plants (Tier 2);Bayer CropScience GmbH, 

 Frankfurt am Main, Germany; Report No.: SE 07/051; Document No.: M-304041-01-2; July 16, 2008; 

 Pages: 269 

MRID 47443247: Bach, F.; Nguyen, D. H.; AE 1170437 SC 500 g/L - Effects on the seedling emergence and 

 seedling growth of twelve species of non-target terrestrial plants (Tier 2);Bayer CropScience AG, Frankfurt 

 am Main, Germany; Report No.: SE 07/029; Document No.: M-301643-01-2; June 16, 2008; Pages: 276 

MRID 47443248: Bach, F.; Gosch, H.; Nguyen, D. H.; AE 1170437 WP 20 percent w/w: Effects on the vegetative 

 vigour of ten species of non-target terrestrial plants (Tier 2);Bayer CropScience GmbH, Frankfurt am Main, 

 Germany; Report No.: VV 07/052; Document No.: M-303620-01-2; July 16, 2008; Pages: 190 

MRID 47443249: Bach, F.; Gosch, H.; Nguyen, D. H.; AE 1170437 SC 500 g/L - Effects on the vegetative vigour 

 of eleven species of non-target terrestrial plants (Tier 2);Bayer CropScience GmbH, Frankfurt am Main, 

 Germany; Report No.: VV 07/030; Document No.: M-301645-01-2; June 16, 2008; Pages: 219 

MRID 47443250: Dorgerloh, M.; Lemna gibba G3 - growth inhibition test with BCS-AA10717 (tech.) under static 

 conditions;Bayer CropScience AG, Monheim, Germany; Report No.: EBDHX009; Document No.: M-

 283650-02-2; July 16, 2008; Pages: 254 

MRID 47443251: Dorgerloh, M.; Lemna gibba G3 Growth inhibition test with AE 2158968 (AE 1170437-triazine-

 indanone) under static conditions;Bayer CropScience AG, Monheim, Germany; Report No.: EBDHP052; 

 Document No.: M-301522-01-2; June 10, 2008; Pages: 91 
-Page 104 of 292- 

MRID 47443252: Dorgerloh, M.; Lemna gibba G3 growth inhibition test with BCS-AA10365 (AE 1170437-

 diaminotriazine) under static conditions;Bayer CropScience AG, Monheim, Germany; Report No.: 

 EBDHP047; Document No.: M-301519-01-2; June 10, 2008; Pages: 97 

MRID 47443253: Dorgerloh, M.; Lemna gibba G3 growth inhibition test with AE 2158969 (AE 1170437-

 carboxylic acid) under static conditions;Bayer CropScience AG, Monheim, Germany; Report No.: 

 EBDHP044; Document No.: M-303700-01-2; July 15, 2008; Pages: 98 

MRID 47443254: Dorgerloh, M.; Lemna gibba G3 growth inhibition test with BCS-AA10202 (AE 1170437-1-

 hydroxyethyl) under static conditions;Bayer CropScience AG, Monheim, Germany; Report No.: 

 EBDHP054; Document No.: M-301528-01-2; June 10, 2008; Pages: 94 

MRID 47443255: Dorgerloh, M.; Lemna gibba G3 growth inhibition test with BCS-AA10201 (AE 1170437-

 olefine) under static conditions;Bayer CropScience AG, Monheim, Germany; Report No.: EBDHP055; 

 Document No.: M-301973-01-2; June 10, 2008; Pages: 93 

MRID 47443256: Dorgerloh, M.; Lemna gibba G3 growth inhibition test with AE 1170437 in a water/sediment 

 system using spiked water (code: AE 1170437-TE-01);Bayer CropScience AG, Monheim, Germany; 

 Report No.: EBDHP040; Document No.: M-277397-02-2; July 14, 2008; Pages: 174 

MRID 47443257: Brock, T .C. M.; Bruns, E.; Crum, S. J. H.; Ecological effects of the herbicide AE1170437 in 

 outdoor experimental ponds inhabited with macrophytes;ALTERRA, Wageningen UR, The Netherlands; 

 Report No.: ALT.SC.2007.1; Document No.: M-304567-01-2; July 28, 2008; Pages: 280 

MRID 47443258: Hoberg, J. R.; AE 1170437 - Effects on aquatic macrophytes in outdoor simulated 

 ponds;Springborn Laboratories, Inc., Wareham, MA, USA; Report No.: EBDHX004; Document No.: M-

 303082-01-1; June 19, 2008; Pages: 45 

MRID 47443259: Brumhard, B.; Schneider, U.; Analysis of AE 1170437 concentrations in sediment samples of 

 ALTERRA study no. ALT.SC.2007.1;Bayer CropScience AG, Monheim, Germany; Report No.: MR-

 07/329; Document No.: M-298851-01-2; May 13, 2008; Pages: 34 

MRID 47443260: Krebber, R.; Sandau, C.; Analysis of AE 1170437 concentrations in water samples of ALTERRA 

 Study No. ALT.SC.2007.1;Bayer CropScience AG, Monheim, Germany; Report No.: MR-07/298; 

 Document No.: M-299709-01-2; May 13, 2008; Pages: 43 

MRID 47443261: Banman, C. S.; Lam, C. V.; Toxicity of AE 1170437 technical to the green alga 

 Pseudokirchneriella subcapitata;Bayer CropScience LP, Stilwell, KS, USA; Report No.: EBDHP022-1; 

 Document No.: M-293679-02-1; June 30, 2008; Pages: 50 

MRID 47443262: Banman, C. S.; Hoffmann, J. M.; Lam, C. V.; Toxicity of the metabolite BCS-AA10365 (AE 

 1170437-1-diaminotriazine) to the green alga Pseudokirchneriella subcapitata;Bayer CropScience LP, 

 Stilwell, KS, USA; Report No.: EBDHP048; Document No.: M-301715-01-1; May 20, 2008; Pages: 52 

MRID 47443263: Banman, C. S.; Hoffmann, J. M.; Lam, C. V.; Toxicity of the metabolite AE 2158969 (AE 

 1170437-carboxylic acid) to the green alga Pseudokirchneriella subcapitata;Bayer CropScience LP, 

 Stilwell, KS, USA; Report No.: EBDHP045; Document No.: M-302198-01-1; June 04, 2008; Pages: 53 

MRID 47443264: Banman, C. S.; Hoffmann, J. M.; Lam, C. V.; Toxicity of the metabolite BCS-AA10202 (AE 

 1170437-1-hydroxyethyl) to the green alga Pseudokirchneriella subcapitata;Bayer CropScience LP, 

 Stilwell, KS, USA; Report No.: EBDHP057; Document No.: M-301713-01-1; May 19, 2008; Pages: 51 

MRID 47443265: Matlock, D.; Hoffmann, J. M.; Lam, C. V.; Toxicity of the metabolite BCS-AA10201 (AE 

 1170437-1-olefine) to the green alga Pseudokirchneriella subcapitata;Bayer CropScience LP, Stilwell, KS, 

 USA; Report No.: EBDHP056; Document No.: M-302859-01-1; June 17, 2008; Pages: 54 
-Page 105 of 292- 

MRID 47443266: Banman, C. S.; Lam, C. V.; Toxicity of AE 1170437 technical to the freshwater diatom Navicula 

 pelliculosa;Bayer CropScience LP, Stilwell, KS, USA; Report No.: EBDHP024; Document No.: M-

 291758-01-1; August 14, 2007; Pages: 59 

MRID 47443267: Banman, C. S.; Lam, C. V.; Toxicity of AE 1170437 technical to the saltwater diatom 

 Skeletonema costatum;Bayer CropScience LP, Stilwell, KS, USA; Report No.: EBDHP025; Document 

 No.: M-291753-01-1; August 20, 2007; Pages: 60 

MRID 47443268: Banman, C. S.; Daly, R. A.; Lam, C. V.; Toxicity of AE 1170437 technical to the blue green algae 

 Anabaena flos-aquae;Bayer CropScience LP, Stilwell, KS, USA; Report No.: EBDHP023; Document No.: 

 M-294414-01-1; November 08, 2007; Pages: 59 

MRID 47443269: Leicher, T.; AE 1170437, substance technical: acute toxicity to earthworms (Eisenia fetida) tested 

 in artificial soil with 5 percent peat;Bayer CropScience AG, Monheim, Germany; Report No.: LRT/RG-A-

 81/07; Document No.: M-284352-01-2; July 22, 2008; Pages: 25 

MRID 47443280: Schuengel, M.; AE 1170437 - Acute toxicity in the rat after oral administration;Bayer HealthCare 

 AG, Wuppertal, Germany; Report No.: AT03047; Document No.: M-273027-01-2; October 13, 2006; 

 Pages: 27 

MRID 47443281: Schuengel, M.; AE 1170437 - Acute toxicity in the rat after oral administration;Bayer HealthCare 

 AG, Wuppertal, Germany; Report No.: AT04235; Document No.: M-294505-01-2; July 23, 2008; Pages: 

 30 

 

MRID 47443293: Milius, A. D.; Stuart, B. P.; Technical grade BCS-AA10717: A two generation reproductive 

 toxicity study in the Wistar rat;Bayer CropScience LP, Stilwell, KS, USA; Report No.: 201833; Document 

 No.: M-303771-01-1; July 01, 2008; Pages: 1745 

MRID 47488702: Durando, J. (2008) Acute Oral Toxicity Up and Down Procedure in Rats. EPSL Study Number: 

 24047. Unpublished study prepared by Eurofins/Product Saftey Laboratories. March 27, 2008. 

MRID 47488802: Schuengel, M. (2007) AE 1170437 WP 20 – Acute Toxicity in the Rat after Oral Administration. 

 Project Number: M-289026-01-2, AT03848, Y2077828. Unpublished study prepared by Bayer HealthCare 

 AG. 29 p. May 25, 2007. 

MRID 47489202: Moore, G. (2008) 3FL Herbicide Granule – Acute Oral Toxicity Up and Down Procedure in Rats. 

 Study number 24410. Eurofins/Product Safety Laboratories, 2394 US Highway 130, Dayton, NJ 08810. 

 May 22, 2008. 

MRID 47489302: Moore, G. (2008) 3FL Herbicide Granule – Acute Oral Toxicity Up and Down Procedure in Rats 

 – Bayer Advanced Lawn 3FL Herbicide Concentrate. Project Number: M-304206-01-1, 24434, P320/UDP. 

 Unpublished study preparaed by Product Safety Laboratories. 15p. May 28, 2008. 

MRID 47489402: Memoranda on Lawn 3FL Herbicide Read-to-use, DP Barcode D356088. From Technical 

 Review Branch, Registration Division (7505P), to Herbicide Branch, Registration Division (7505P). 

 December 15, 2009. 

MRID 47743602: Schuengel, M.; AE 1170437 SC 500 (spec no 102000014236) – Acute toxicity in the rat after oral 

 administration; Bayer HealthCare AG,Wuppertal, Germany; Report No.: AT04069; Document No.: M-

 294230-01-2; March 25, 2009; Pages: 30 

MRID 47443303: Banman, C.S., J.M. Hoffmann, and C.V. Lam. 2008. Acute Toxicity of AE 1170437 SC500 to 

 Daphnia magna Under Static Conditions. Unpublished study performed by Bayer CropScience, Stilwell, 

 KS. Laboratory Project No. EBDHP006. Study sponsored by Bayer CropScience, Research Triangle Park, 
-Page 106 of 292- 

 NC. Study initiated February 25, 2008 

MRID 47743304: Bruns, E. 2009. Acute toxicity of BCS-AA10717 SC 200 G to the waterflea Daphnia magna in a 

 static laboratory test system. Unpublished study performed by Bayer CropScience, D-40789 Monheim am 

 Rhein, Germany. Laboratory Project No. EBDHP112. Study sponsored by Bayer CropScience, Research 

 Triangle Park, NC. Study initiated February 12, 2009 

MRID 47743305: Ruhland, M. 2008. Acute toxicity of AE 1170437 SC 500 G to fish (Lepomis macrochirus) 

 under static conditions. Unpublished study performed by Bayer CropScience AG, 40789 Monheim, 

 Germany. Laboratory Project No. EBDHP068. Study sponsored by Bayer CropScience, Research Triangle 

 Park, NC. Study initiated October 31, 2007. 

MRID 47743306: Beavers, J.B., Hubbard, P.M. 2008. BCS-AA10717 Technical: An acute oral toxicity study with 

 the zebra finch (Poephila guttata) using a sequential testing procedure. Unpublished study performed by 

 Wildlife International, Ltd, Easton, MD, Laboratory Project No. 149-215. Study sponsored by Bayer 

 CropScience, Ecotoxicology, Stilwell, KS. Study completed December 11, 2008. Pages: 42. 

MRID 47743307: Barth, M. 2006. Acute Toxicity of AE 1170437 SC 500 to the honeybee Apis mellifera L. under 

 laboratory conditions. Unpublished study performed by BioChem agrar, Gerichshain, Germany. 

 Laboratory Project No. 061048130. Study sponsored by Bayer CropScience GmbH, Ecotoxicology, 

 Industriepark Hochst, Frankfurt am Main. Study completed on October 23, 2006. Pages: 30. 

MRID 47743308: Dorgerloh, M. 2008. Lemna gibba G3 – Growth inhibition test with AE 1170437 SC 500 under 

 static conditions. Unpublished study performed by Bayer CropScience AG, Development - Ecotoxicology, 

 Monheim, Germany. Laboratory Project ID: E 412 3261-9. Study sponsored by Bayer CropScience AG, 

 Portfolio Management – Project Management, Monheim, Germany. Study completed October 28, 2008. 

MRID 47743309: Banman, C.S., J.M. Hoffmann, and C.V. Lam. 2009. Toxicity of AE 1170437 Technical to the 

 Green Alga Pseudokirchneriella subcapitata. Unpublished study performed by Bayer CropScience, 

 Ecotoxicology, Stilwell, Kansas. Laboratory Project ID: EBDHX013. Study sponsored by Bayer 

 CropScience, Research Triangle Park, North Carolina. Study completed April 9, 2009. 

MRID 47743310: Banman, C.S., J.M. Hoffmann, and C.V. Lam. 2008. Toxicity of the Formulation AE 1170437 

 SC500 to the Green Alga Pseudokirchneriella subcapitata. Unpublished study performed by Bayer 

 CropScience, Ecotoxicology, Stilwell, Kansas. Laboratory Project ID: EBDHP007. Study sponsored by 

 Bayer CropScience, Research Triangle Park, North Carolina. Study completed June 17, 2008. 

MRID 47743311: Bruns, E. 2009. Pseudokirchneriella subcapitata growth inhibition test with Indaziflam SC 

 200G.Unpublished study performed by Bayer CropScience AG, Development, Environmental Safety, 

 Ecotoxicology, Monheim, Germany. Laboratory Project ID: EBDHP113. Study sponsored by Bayer 

CropScience AG, Monheim, Germany. Study completed June 10, 2009. 

MRID 47743312: Leicher, T. 2007. AE 1170437-diaminotriazine (BCS-AA10365): Acute toxicity to earthworms 

 (Eisenia fetida) tested in artificial soil with 5% peat. Unpublished study performed and sponsored by Bayer 

 CropScience AG, Monheim, Germany. Report LRT/Rg-A-93/07. Study completed October 25, 2007. 

MRID 47743313: Leicher, T. 2007. AE 1170437-triazine-indanone (AE 2158968): acute toxicity to earthworms 

 (Eisenia fetida) tested in artificial soil with 5% peat. Unpublished study performed and sponsored by Bayer 

 CropScience AG, Monheim, Germany. Report LRT/Rg-A-89/07. Study completed August 20, 2007. 

MRID 47743314: Leicher, T. 2008. AE 1170437-carboxylic acid (AE 2158969): Acute toxicity to earthworms 

 (Eisenia fetida) tested in artificial soil with 5% peat. Unpublished study performed and sponsored by Bayer 

 CropScience AG, Monheim, Germany. Report LRT/Rg-A-97/07. Study completed January 9, 2008. 

MRID 47743315: Leicher, T. 2007. BCS-AA10717 SC 500 G: Acute toxicity to earthworms (Eisenia fetida) tested 
-Page 107 of 292- 

 in artificial soil with 5% peat. Unpublished study performed and sponsored by Bayer CropScience AG, 

 Monheim, Germany. Report LRT/Rg-A-111/08. Study completed December 4, 2008. 

MRID 47743316: Leicher, T. 2007. AE 1170437 SC 500 G: Effects on survival, growth and reproduction on the 

 earthworm Eisenia fetida tested in artificial soil with 5% peat. Unpublished study performed and sponsored 

 by Bayer CropScience AG, Monheim, Germany. Report LRT/Rg-R-37/07. Study completed November 

 27, 2007. 

MRID 47743202: Desmarteau, D. A., D.R. Fischer. 2009. AE 1170437 500 SC – Magnitude of the Residue in/on 

 Pome Fruit (CG 11). Unpublished study performed by Bayer CropScience, Stilwell, Kansas. Report No. 

 RADHP029. Study completed May 20, 2009. 

MRID 47743403: Kroski, M.E., J.N. Brungardt, S.M. Stoughton. 2009. AE 1170437 500 SC – Magnitude of the 

 Residue in/on Stone Fruit (CG 12). Unpublished study performed by Bayer CropScience, Stilwell, Kansas. 

 Report No. RADHP030. Study completed May 20, 2009. 

MRID 47743404: Brungardt, J.N., M.E. Krolski. 2009. AE 1170437 500 SC – Magnitude of the Residue in/on Tree 

 Nut (CG 14). Unpublished study performed by Bayer CropScience, Stilwell, Kansas. Report No. 

 RADHP028. Study completed May 18, 2009. 

 

MRID 47743405: Fischer, D.R., Ann M. Harbin. 2009. AE 1170437 500 SC – Magnitude of the Residue in/on 

 Citrus (CG 10). Unpublished study performed by Bayer CropScience, Stilwell, Kansas. Report No. 

 RADHP027. Study completed June 8, 2009. 

MRID 47743406: Sturdivant, D.W., D.R. Fischer. 2009. AE 1170437 500 SC – Magnitude of the Residue in/on 

 Grapes. Unpublished study performed by Bayer CropScience, Stilwell, Kansas. Report No. RADHP033. 

 Study completed May 29, 2009. 

MRID 47743407: Timberlake, B.C., D.R. Fischer. 2009. AE 1170437 500 SC – Magnitude of the Residue in/on 

 Olives. Unpublished study performed by Bayer CropScience, Stilwell, Kansas. Report No. RADHP037. 

 Study completed May 29, 2009. 
-Page 108 of 292- 

Appendix A. Chemical Names, Structures, and Maximum Reported Amounts of Indaziflam Degradates. Table A-1. Indaziflam and Its Major Organic Environmental Degradates. 

Transformation Product Compound/Code 

Chemical Name Chemical Structure Maximum % of AR Time of Peak (Max % of Degradate applied) Ave % of AR at Study Termination (day) MRID 

PARENT 

Not Applicable Not Applicable 31.7 32.5 47443210 47443211 Not Applicable Not Applicable 18.5 14.9 47443210 47443211 Not Applicable Not Applicable 28.6 28.7 47443212 47443213 Not Applicable Not Applicable 14.9 15.3 47443212 47443213 Not Applicable Not Applicable 20.5 19.2 47443212 47443213 Not Applicable Not Applicable 20.3 18.3 47443212 47443213 Not Applicable Not Applicable 56.4 55.6 47443216 Not Applicable Not Applicable 4.09 ng/g (0-15) (554) 47443222 Not Applicable Not Applicable 2.91 ng/g (0-15, 554 d) 47443225 Not Applicable Not Applicable 2.38 ng/g (0-15, 526 d) 47443224 Not Applicable Not Applicable 1.16** ng/g (0-15, 526 d) 47443221 Not Applicable Not Applicable 0.69** ng/g (0-15, 531 d) 47443223 

Parent: Indaziflam IUPAC: N-[(1R,2S)-2,3-

dihydro-2,6-dimethyl-1Hinden-1-yl]-6-[(1RS)-1-fluoroethyl]-1,3,5-triazine2,4-diamineCAS:1,3,5-Triazine-2,4-

diamine, N-[(1R,2S)-2,3-dihydro-2,6-dimethyl-1Hinden-1-yl]-6-(1-fluoroethyl)CAS No.: 950782-86-2 (isomer mixture) 730979-19-8 (Isomer A; AE 1170437) 730979-32-5 (Isomer B; AE 1170438)Common Name: Indaziflam, BCS AA10717

Synonyms: BCS-AA10717, BAY BCHD 1709, BAY BCHD 2003, BAY BCKM 2459, BAY BSP 1089, BAY NLL 7482.

Formula: C16H20FN5

MW: 301.36 g/mol

Isomer A: Isomer B: 

Not Applicable Not Applicable 0.51** (0-15, 531 

d) 

47443220 
-Page 109 of 292- 

Transformation Product Compound/Code 

Chemical Name Chemical Structure Maximum % of AR Time of Peak (Max % of Degradate applied) Ave % of AR at Study Termination (day) MRID 

Not Applicable Not Applicable Irradiated: 21.3 (3) Dark: 97.9 (3) 47443208 Not Applicable Not Applicable Irradiated: 20.5 (3) Dark: 91.6 (3) 47443208 Not Applicable Not Applicable Irradiated: 47 (10) Dark: 89.9 (10) 47443209 Not Applicable Not Applicable Irradiated: 60.7 (9) Dark: 89.9 (10) 47443209 Not Applicable Not Applicable 

Water: 8.9 (120) 

Sediment: 40.7 

(120) 

System: 49.5 (120) 

47443217 

Not Applicable Not Applicable 

Water: 8.5 (120) 

Sediment: 44.2 

(120) 

System: 52.7 (120) 

47443217 

Not Applicable Not Applicable 

Water: 3.2 (120) 

Sediment: 70.2 

(120) 

System: 73.4 (120) 

47443217 

Not Applicable Not Applicable 

Water: 2.8 (120) 

Sediment: 70.6 

(120) 

System: 73.4 (120) 

47443217 
-Page 110 of 292- 

Transformation Product Compound/Code 

Chemical Name Chemical Structure Maximum % of AR Time of Peak (Max % of Degradate applied) Ave % of AR at Study Termination (day) MRID 

MAJOR (>10%) TRANSFORMATION PRODUCTS 

22.3 120-180 d 12.9 47443211 

39.1* Increasing at study termination (368 d) 37.9 47443211 

17* Increasing at study termination (120 d) 17 47443213 

31.7* Increasing at study termination (120 d) 31.6 47443213 23.7* Increasing at study termination (120 d) 23.4 47443213 11.5* Increasing at study termination (120 d) 11.4 47443213 

4.6 0 d 1.5 47443216 

1.92 ng/g (0-15, 

29 d) 29-126 d 0.64** (0-15, 554 d) 47443222 

2.78 ng/g (0-15, 

374 d) 

14-374 d 

(concentrations 

within acceptable 

range of variability) 

1.17** ng/g (0-15, 

554 d) 47443225 

4.67 ng/g (0-15, 

134 d) 134-280 d 2.11 ng/g (0-15, 526 d) 47443224 

4.26 ng/g (0-15, 

134 d) 134 d 1.11** ng/g (0-15, 526 d) 47443221 

9.20 ng/g (0-15, 

28 d) 28 d 1.74 ng/g (0-15, 531 d) 47443223 

2.45 ng/g (0-15, 

58 d) 58 d 

0.40** ng/g (0-15, 

367 d) 

nd (0-15, 531 d) 

47443220 

7.4 (10) 8-10 d Irradiated: 6.9 (10) Dark: 1.3* (10) 47443209 

Diaminotriazine IUPAC: (R)-6-(1-

fluoroethyl)-[1,3,5]triazine2,4-diamine.CAS: 6-[(1R)-1-Fluoroethyl]-1,3,5-triazine2,4-diamine.CAS No.: Not Reported

Synonyms: AE 1956114, AE1170437-diaminotriazine, Z2, C1070, diaminotriazine, AE1956114, Z3, AE 1170437 diaminotriazine, 1-Fluoroethyl triazinediamine, AE 2300000, BCSAA10365, K-1580, E7-1, E14-1, N7-1, N14-1

Formula: C5H8FN5

MW: 157.15 g/mol

System: 12.8* Increasing at study termination (120 d) 

Water: 8.6 (120) 

Sediment: 3.4 

(120) 

System: 11.9 (120) 

47443217 
-Page 111 of 292- 

Transformation Product Compound/Code 

Chemical Name Chemical Structure Maximum % of AR Time of Peak (Max % of Degradate applied) Ave % of AR at Study Termination (day) MRID 

System: 2.6 62-120 d 

Water: 0.6(120) 

Sediment: 1.8 

(120) 

System: 2.3 (120) 

47443217 

(PARENT) 

Supp study on 

metabolite 

(PARENT) 

Supp study on 

metabolite 

18.4 57.2 

1.1 

47443214# 

17.4 15.4 

90-122 d 60-180 d 

8.9 7.6 

4744321047443211 

9.8 

10.5

23-123 d 

26 d 

2.2 2.2 

4744321047443211 

14.3* Increasing at study termination (122 d) 13.3 (variable) 47443212 

9.8 

38-120 d 

unknown whether 

increasing or 

decreasing at 

termination (120 d) 

9.5 47443213 

6.7 8.1 

13-79 d 21-38 d 

3.9 

6 

47443212 47443213 

13.7 15.8 

30-79 d 21-59 d 

11 

11.6 

47443212 47443213 

10.2 38-91 d 8.3 47443213 11.5 

30-122 d 

unknown whether 

increasing or 

decreasing at 

termination 

10.5 47443212 

10.2 

30-92 d 

(0-62 d postflooding) 8.1 47443216 

10.2 

comparatively 

constant 

concentration, slight 

(~1%) decrease over 

sampling period (0-

210 d) 

7.9 47443216 

Traizine Indanone IUPAC Name: N-[(1R,2S)-

2,3-Dihydro-2,6-dimethyl3-oxo-1H-inden-1-yl]-6-[(1R)-1-fluoroethyl]-1,3,5-triazine-2,4-diamineCAS Name: CAS No.: UnavailableSynonyms: AE 1170437-ketone, AE 2158968, AE 1170437 ketone, K-1579, C-1068, AE 1170437-triazine indanone, Z1, Triazine indanone, AE 1170437-TriazineIndanone, AE1170437-triazine indanone, Triaz. Indanone, Indanone, AE2158968, AE 1170437 triazine-indanone, K-1715, AE 1170437- indanone, AE 1170437 indanone, AE 1170437 Triazine-indanoneFormula: C16H18FN5O

MW: 315.3 g/mol

6.69 ng/g (0-15, 

58 d) 

58-126 d 2.73 ng/g (0-15, 

554 d) 

47443222 
-Page 112 of 292- 

Transformation Product Compound/Code 

Chemical Name Chemical Structure Maximum % of AR Time of Peak (Max % of Degradate applied) Ave % of AR at Study Termination (day) MRID 

4.89 ng/g (0-15, 

280 d) 

58-280 d 

(average 

concentrations 

within acceptable 

range of variability) 

1.59 47443225 

3.29 ng/g (0-15, 

7 d) 7-59 d 0.37** ng/g (0-15, 526 d) 47443224 

5.42 ng/g (0-15, 

59 d) 59 d 1.12** ng/g (0-15, 526 d) 47443221 

9.51 ng/g (0-15, 

14 d) 14 d 0.44** ng/g (0-15, 531 d) 47443223 

6.31 ng/g (0-15, 

58 d) 14-121 d 

0.74** ng/g (0-15, 

531 d) 

2.25 ng/g (0-15, 

367 d) 

47443220 

5.7 3-10 d 5.7 47443209 7.2 Increasing at study termination (9 d) 7 47443209 

System: 11.2* Increasing at study termination (120 d) 

Water: 2.7 (120) 

Sediment: 7.9 

(120) 

System: 10.6 (120) 

47443217 

System: 10.5* Increasing at study termination (120 d) 

Water: 2.6 (120) 

Sediment: 7.7 

(120) 

System: 10.3 (120) 

47443217 

System: 5.9 

62-120 d 

(unable to determine 

if increasing or 

decreasing at study 

termination) 

Water: 0.2 (120) 

Sediment: 5.1 

(120) 

System: 5.3 (120) 

47443217 

System: 7.4 62-120 d 

Water: 0.2 (120)

Sediment: 5.8 (120)

System: 6.0 (120) 

47443217 
-Page 113 of 292- 

Transformation Product Compound/Code 

Chemical Name Chemical Structure Maximum % of AR Time of Peak (Max % of Degradate applied) Ave % of AR at Study Termination (day) MRID 

10.1 10.0 

90-122 d 

122 d 

5.2 3.6 

4744321047443211 

17.3 16.8 

90-178 d 

26-61 d 

9.9 7.3 

4744321047443211 

9.4 

12.1 

30-101 d 

59 d 

5.1 7.1 

47443212 47443213 

21.7 16.8

30-79 d 21-59 d 

17.5 

9.2 

47443212 47443213 

12.4 

7.1 

30 d 38 d 

7 

3.1 

47443212 47443213 

11.8 

8.7 

30-58 d 21-59 d 

5.3 3.7 

47443212 47443213 

14.3 

30-44 d 

Slight decrease % 

(~4%) over 

sampling period 

post-flooding 

10.3 47443216 

11.3 7-92 d 10.2 47443216 

3.18 ng/g (0-15, 

29 d) 29 d 

0.35** ng/g (0-15, 

374 d) 

nd (554 d) 

47443222 

2.11 ng/g (0-15, 

126 d) 126 d 0.97** ng/g (0-15, 554 d) 47443225 

2.34 ng/g (0-15, 

134 d) 134 d 0.63** ng/g (0-15, 526 d) 47443224 

2.54 ng/g (0-15, 

59 d) 28-59 d 

0.55** ng/g (0-15, 

280 d) 

nd (526 d) 

47443221 

5.30 ng/g (0-15, 

14 d) 14 d 0.51** ng/g (0-15, 531 d) 47443223 

4.6 ng/g (0-15, 

28 d) 

actual max = 

6.69 ng/g at this 

sampling point 

(replicated = 

3.44, 4.6, 3.7) 

28-58 d 0.60** ng/g (0-15, 531 d) 47443220 

Carboxylic Acid IUPAC Name: (2S,3R)-3-

({4-Amino-6-[(1R)-1-fluoroethyl]-1,3,5-triazin-2-yl}amino)-2-methylindane5-carboxylic acidCAS Name: (2S,3R)-3-[[4-Amino-6-[(1R)-1-fluoroethyl]-1,3,5-triazin-2-yl]amino]-2,3-dihydro-2-methyl-1H-indene-5-carboxylic acidCAS No.: UnavailableSynonyms: AE 2158969, AE 1170437-Acid, AE 1170437 Acid, K-1581, C1069, AE 1170437-carboxylic acid, Carboxylic acid, Z2, AE 1170437-Carboxylic acid, AE1170437-carboxylic acid, Z8, AE 1170437 carboxylic acid, Carbox. Acid, AE2158969, K-1716, AE 1170437 Carboxylic Acid, N7-9, N14-9, K-1644 Formula: C16H18FN5O2

MW: 331.3 g/mol

1.8 Increasing at study 1.6 47443209 
-Page 114 of 292- 

Transformation Product Compound/Code 

Chemical Name Chemical Structure Maximum % of AR Time of Peak (Max % of Degradate applied) Ave % of AR at Study Termination (day) MRID 

termination (10 d) 

2.4 Increasing at study termination (9 d) 2.1 47443209 

System: 17.7

91-120 d (unable to 

determine if 

increasing or 

decreasing at study 

termination) 

Water: 11.5 (120)

Sediment: 4.8 

(120) 

Water: 16.3 (120) 

47443217 

System: 20.7* Increasing at study termination (120 d) 

Water: 14.1 (120)

Sediment: 5.7 

(120) 

Water: 19.7 (120) 

47443217 

System: 4.2 30-120 d 

Water: 1.0 (120) 

Sediment: 2.7 

(120) 

Water: 3.7 (120) 

47443217 

System: 6.7 

(average, 3.7, 

9.6) 

90 d 

Water: 1.2 (120) 

Sediment: 2.6 

(120) 

Water: 3.8 (120) 

47443217 

21 58-120 d 18.3 47443214# 

Fluoroethyl- triazinanedione (ROI1) IUPAC Name: 6-[(1R)-1- fluoroethyl]-1,3,5- triazinane-2,4-dione 

CAS Name: Unavailable CAS No.: Unavailable Formula: C5H3FN3O2

MW: 

25.7 30-58 d 0.6 47443214# 

1.58 ng/g (0-15, 

29 d) 29-126 d 

0.35** ng/g (0-15, 

374 d) 

nd (0-15, 554 d) 

47443222 

0.41** ng/g (0-

15, 0 d) 

0 d 

no other detections nd (526 d) 47443224 

0.80** ng/g (0-

15, 59 d) 14-59 d nd (526 d) 47443221 

Hydroxyethyl IUPAC Name: 1-{4-

Amino-6-[(1R,2S)-2,6-dimethyl-2,3-dihydro-1Hinden-1-ylamino]-1,3,5-triazin-2-yl}ethanolCAS Name: CAS No.: Synonyms: AE 1170437 Hydroxyethyl, AE2300077, AE 1170437-desfluorohydroxy, AE 1170437-1-

2.0 ng/g (0-15, 

367 d) 

3 detections at 367 d 

sampling time 

period 

(2.0, 0.75, 0.42 ppb) 

nd (531 d) 47443223 
-Page 115 of 292- 

Transformation Product Compound/Code 

Chemical Name Chemical Structure Maximum % of AR Time of Peak (Max % of Degradate applied) Ave % of AR at Study Termination (day) MRID 

0.65** ng/g (0-

15, 58 d) 

58 d 

(nd after through 

termination) 

nd (531 d) 47443220 

20.8* Increasing at study termination (3 d) 20.3 47443208 

Hydroxyethyl, BCSAA10202Formula: C16H21N5O MW: 299.37 g/mol

17.9* Increasing at study termination (3 d) 16.6 47443208 

53.9* Increasing at study termination (3 d) 53.6 47443208 

Olefin IUPAC Name: N-[(1R,2S)-

2,6-dimethyl-2,3-dihydro1H-inden-1-yl]-6-vinyl1,3,5-triazine-2,4-diamine Synonyms: AE1170437-olefin, Reg #6, Compound 2, AE 1170437 olefin, AE 1170437 Olefin, BCSAA10201, K-1656, AE 1170437 olefin, AE 1170437-Olefin Formula: C16H20N5 MW: 

51.7* Increasing at study termination (3 d) 49.9 47443208 

18.3* Increasing at study termination (368 d) 18.3 47443210 38.3* Increasing at study termination (368 d) 37.3 47443210 

3.6* Increasing at study termination (368 d) 3.6 47443211 

14.2* Increasing at study termination (368 d) 14 47443211 23.6* Increasing at study termination (122 d) 23.6 47443212 33.1* Increasing at study termination (122 d) 33.1 47443212 28.2* Increasing at study termination (122 d) 28.2 47443212 32.7* Increasing at study termination (122 d) 32.6 47443212 13.6* Increasing at study termination (120 d) 13.6 47443213 

CO2

(Carbon Dioxide) 

CAS No.: 124-38-9

9.2* Increasing at study termination (120 d) 9.2 47443213 
-Page 116 of 292- 

Transformation Product Compound/Code 

Chemical Name Chemical Structure Maximum % of AR Time of Peak (Max % of Degradate applied) Ave % of AR at Study Termination (day) MRID 

5 Increasing at study termination (120 d) 5 47443213 

31.8* Increasing at study termination (120 d) 30.6 47443213 

49.7 Increasing at study termination (120 d) 48.5 47443214 12.3 Increasing at study termination (120 d) 12.2 47443214 89.3 Increasing at study termination (120 d) 86.8 47443214 

4.7 

Sustained conc. 

through study 

termination (210 d) 

4.7 47443216 

7.3 

Sustained conc. 

through study 

termination (210 d) 

7.3 47443216 

3.3* Increasing at study termination (10 d) 2.9 47443209 1.6* Increasing at study termination (120 d) 1.4 47443217 5.0* Increasing at study termination (120 d) 4.6 47443217 

0.6 62 d 0.2 47443217 1.8 62 d 1.5 47443217 
-Page 117 of 292- 

Table A-2. Minor Organic Environmental Degradates of Indaziflam. 

Transformation Product Compound/Code 

Chemical Name Chemical Structure Maximum % of AR Time of Peak (Max % of Degradate applied) Ave % of AR at Study Termination (day) MRID 

MINOR TRANSFORMATION PRODUCTS 

4.2 14 d 0.9 47443214 

ROI2 Unknown 

3.5 7-14 d ND 47443214 

2.4 150 d 2.1 47443216 

Unknown 1 Unknown 

2.4 150 d 2.2 47443216 

Reg #1 Unknown 3.4* Increasing at study termination (3 d) 3.1 47443208 

3.6 (water only) 91-120 d 

Water: 2.7 (120)

(few minor 

detections in 

sediment over 

course of study) 

47443217 

System: 3.8 

30-120 d (note: peak 

decreased following 

day 30 sampling, 

then increased from 

91-120 d) 

Water: 2.4 (120)

Sediment: 0.4 

(120) 

System: 2.8 

(120) 

47443217 

Unidentified Unknown 

System: 1.2 30 d 

Water: 0.8 (120)

(few minor 

detections in 

sediment over 

course of study) 

47443217 

1* Increasing at study termination (122 d) 1 47443212 

1.8 13-58 d 1.1 47443212 

1.6* 

101-122 d 

Increasing at study 

termination (122 d) 

1.6 47443212 

0.9 30-79 d 0.5 47443212 

1.5* Increasing at study termination (10 d) 1.5 47443209 

Z3 Unknown 

1.3* Increasing at study termination (9 d) 1.3 47443209 
-Page 118 of 292- 

Transformation Product Compound/Code 

Chemical Name Chemical Structure Maximum % of AR Time of Peak (Max % of Degradate applied) Ave % of AR at Study Termination (day) MRID 

0.4 30-79 d ND 47443212 0.8 58-79 d 0.2 47443212 0.4 30-58 d ND 47443212 1.9 21 d ND 47443213 

Z4 Unknown 

2.0* Increasing at study termination (10 d) 2 47443209 

0.6 58-101 d 0.4 47443212 0.6 58-101 d 0.4 47443212 0.6 58 d ND 47443212 0.8 

58-122 d 

relatively constant 

percent of applied 

during this time 

period 

0.7 47443212 

1.9 

120 d 

increasing at study 

termination (120 d) 

1.9 47443213 

1.4* Increasing at study termination (10 d) 1.4 47443209 

Z5 Unknown 

1.2 2-9 d 1.1 47443209 

1* 

58-122 d 

Increasing at study 

termination (122 d) 

1 47443212 

0.6 58-101 d 0.4 47443212 

1.7* Increasing at study termination (122 d) 1.7 47443212 

0.7 

58-122 d 

constant percent of 

applied during this 

time period 

0.7 47443212 

0.8 

detected at final 

sampling time 

period (120 d) 

0.8 47443213 

Z6 Unknown 

0.7 detected at final 

sampling time 

0.6 47443213 
-Page 119 of 292- 

Transformation Product Compound/Code 

Chemical Name Chemical Structure Maximum % of AR Time of Peak (Max % of Degradate applied) Ave % of AR at Study Termination (day) MRID 

period (120 d) 

2.5 

120 d 

increasing at study 

termination (120 d) 

2.5 47443213 

0.7 

detected at final 

sampling time 

period (120 d) 

0.7 47443213 

1.6* Increasing at study termination (10 d) 1.6 47443209 

1.3 6-9 d 1.3 47443209 

0.8* 

79-122 d 

Increasing at study 

termination (122 d) 

0.8 47443212 

0.6 58-101 d 0.4 47443212 

1.2* Increasing at study termination (122 d) 1.2 47443212 

0.8 

detected at final 

sampling time 

period (120 d) 

0.8 47443213 

0.7 

detected at final 

sampling time 

period (120 d) 

0.6 47443213 

1.6 

120 d 

increasing at study 

termination (120 d) 

1.6 47443213 

0.9 

detected at final 

sampling time 

period (120 d) 

0.9 47443213 

1.5 3-8 d 1.1 47443209 

Z7 Unknown 

1.4 3-9 d 1.2 47443209 

0.4 58-79 d ND 47443212 0.6 30 d ND 47443212 0.9 58-79 d ND 47443212 0.8 

detected at final 

sampling time 

period (120 d) 

0.8 47443213 

Z8 Unknown 

1.1 

detected at final 

sampling time 

period (120 d) 

1.1 47443213 
-Page 120 of 292- 

Transformation Product Compound/Code 

Chemical Name Chemical Structure Maximum % of AR Time of Peak (Max % of Degradate applied) Ave % of AR at Study Termination (day) MRID 

1.3 Increasing at study termination (122 d) 1.3 47443213 0.6 79 d 0.4 47443212 0.4 58-79 d 0.2 47443212 0.9 

58-122 d 

Increasing at study 

termination (122 d) 

0.8 47443212 

1.9 

120 d 

increasing at study 

termination (120 d) 

1.8 47443213 

Z9 Unknown 

2 8 d nd 47443209 

0.4 58-101 d ND 47443212 

Z10 Unknown 

0.5 58 d ND 47443212 

UNIDENTIFIED RADIOACTIVITY, NONEXTRACTABLE AND DIFFUSE RESIDUES 

4.9* Increasing at study termination (3 d) 4.7 47443208 

Unidentified Radioactivity Not Applicable Not Applicable 7.4* Increasing at study termination (3 d) 7.3 47443208 

21.9* Increasing at study termination (368 d) -- 47443210 34.3* Increasing at study termination (368 d) -- 47443210 34.3* Increasing at study termination (368 d) -- 47443211 18.3* Increasing at study termination (368 d) -- 47443211 21.2* Increasing at study termination (122 d) -- 47443212 23.1* Increasing at study termination (122 d) -- 47443212 23.5* Increasing at study termination (122 d) -- 47443212 25.5* Increasing at study termination (122 d) -- 47443212 17.3* Increasing at study termination (120 d) -- 47443213 21.5* Increasing at study termination (120 d) -- 47443213 

Non-extractable Residues Not Applicable Not Applicable 

24.9* Increasing at study -- 47443213 
-Page 121 of 292- 

Transformation Product Compound/Code 

Chemical Name Chemical Structure Maximum % of AR Time of Peak (Max % of Degradate applied) Ave % of AR at Study Termination (day) MRID 

termination (120 d) 

20.1* Increasing at study termination (120 d) -- 47443213 

13.6 

31.0* 

7.7 

90 d 

Increasing at study 

termination (120 d) 

7-14 d 

11 

-- 

4.9 

47443214 

22.4* Increasing at study termination (10 d) 21.8 47443209 12.3* Increasing at study termination (9 d) 12.3 47443209 

14.5 Increasing at study termination (120 d) 13.8 47443217 

16* Increasing at study termination (120 d) 15.3 47443217 

13.9 

90 d 

(unable to determine 

if increasing or 

decreasing at study 

termination) 

11.9 47443217 

14.8* Increasing at study termination (120 d) 14.6 47443217 10.6* Increasing at study termination (10 d) 10.5 47443209 

Diffuse Not Applicable Not Applicable 

14 

8 d 

(Note cannot 

determine if 

decreasing at study 

termination) 

12.4 47443209 
-Page 122 of 292- 

Appendix B. Catalog of Submitted Ecological Effects Studies for Indaziflam. 

Table B. Submitted Ecological Effects Studies for Indaziflam, their Review Classifications, 

and Classification Justifications. 

Guideline MRID Study Title Issues Study 

Classification

850.1010 47443226 Indaziflam - Acute Toxicity to Daphnia magna 

in a 48 Hour Static Test 

Test media was not 

centrifuged to 

determine dissolved 

test substance 

concentration. 

Supplemental 

850.1035 47443227 Indaziflam Technical - 96-hr Static Acute 

Toxicity Test with the Saltwater Mysid 

(Americamysis bahia) 

None Acceptable 

850.1025 47443228 Indaziflam Technical - 96-hr Shell Deposition 

Test with the Eastern Oyster (Crassostrea 

virginica) under Flow-through Conditions 

Test media was not 

centrifuged to 

determine dissolved 

test substance 

concentration. 

Supplemental 

850.1075 47443229 Indaziflam Technical - Acute Toxicity Study on 

the Fathead Minnow (Pimephales promelas) in 

a Static System over 96 hours 

Test media was not 

centrifuged to 

determine dissolved 

test substance 

concentration. 

Supplemental 

850.1075 47443230 Fluoroethyldiaminotriazine - Acute Toxicity 

Study on the Fathead Minnow (Pimephales 

promelas) in a Static System Over 96 Hours 

None Acceptable 

850.1075 47443231 Indaziflam-carboxylic Acid - Acute Toxicity 

Study on the Fathead Minnow (Pimephales 

promelas) in a Static System Over 96 Hours 

None Acceptable 

850.1075 47443232 Indaziflam Technical – 96-h Acute Toxicity 

Study on Sheepshead Minnow (Cyprinodon 

variegates) under Static Conditions 

Test media was not 

centrifuged to 

determine dissolved 

test substance 

concentration. 

Supplemental 

850.1075 47443233 Indaziflam Technical - A 96-Hour Static Acute 

Toxicity Test with the Bluegill Sunfish 

(Lepomis macrochirus) 

Test media was not 

centrifuged to 

determine dissolved 

test substance 

concentration. 

Supplemental 

850.1075 47443234 Indaziflam Technical - Acute Toxicity Study on 

the Rainbow Trout (Oncorhynchus mykiss) in a 

Static System Over 96 Hours 

Test media was not 

centrifuged to 

determine dissolved 

test substance 

concentration. 

Supplemental 
-Page 123 of 292- 

850.1300 47443235 Indaziflam Technical – 21-day Chronic 

Toxicity to Daphnia magna under Staticrenewal Conditions 

Effects to offspring 

were not measured & 

test media was not 

centrifuged to 

determine dissolved 

test substance 

concentration. 

Supplemental 

850.1400 47443236 Indaziflam Technical – 35-day Early Life Stage 

Toxicity test on the Fathead Minnow 

(Pimephales promelas) under Flow-through 

Conditions 

Statistically 

significant difference 

between negative and 

solvent controls for 

mean dry weight & 

test media was not 

centrifuged to 

determine dissolved 

test substance 

concentration. 

Supplemental 

850.1735 47443238 Indaziflam Technical – 10-day Acute Whole 

Sediment Toxicity Study with Freshwater 

Midge (Chironomus tetans) 

Overlying water 

concentrations were 

not centrifugedto 

determine dissolved 

test substance 

concentration 

Supplemental 

850.1740 47443239 Indaziflam Technical – 10-day Acute Whole 

Sediment Test with Marine Amphipod 

Leptocheirus plumulosus under Static 

Conditions 

Overlying water 

concentrations were 

not centrifuged to 

determine dissolved 

test substance 

concentration 

Supplemental 

850.2100 47443240 Indaziflam Technical – Acute Toxicity in the 

Bobwhite Quail (Colinus virginiamus) After 

Single Oral Administration (LD50) 

None Acceptable 

850.2200 47443241 Indaziflam Technical – Subacute Dietary LC50 

with Northern Bobwhite Quail (Colinus 

virginiamus) 

None Acceptable 

850.2200 47443242 Indaziflam Technical – Subacute Dietary LC50 

with Mallard Duck (Anas platyrhnchos) 

None Acceptable 

850.2300 47443243 Indaziflam Technical – One Generation 

Reproduction Study on the Bobwhite Quail 

(Colinus virginiamus) 

by Administration in the Diet 

None Acceptable 

850.2300 47443244 Indaziflam Technical – One Generation 

Reproduction Study on the Mallard Duck (Anas 

platyrhnchos) by Administration in the Diet 

Non-definitive 

NOAEC 

Supplemental 

850.3020 47443245 Indaziflam Technical - Acute Contact Toxicity 

Study with the Honey Bee 

None Acceptable 
-Page 124 of 292- 

850.4225 47443246 BCS-AA10717 20WSP - Toxicity Test to 

Determine the Effects of the Test Substance on 

Seedling Emergence of Terrestrial Plant Species

None Acceptable 

850.4225 47443247 Indaziflam 500 SC - Toxicity Test to Determine 

the Effects of the Test Substance on Seedling 

Emergence of Terrestrial Plant Species 

None Acceptable 

850.4250 47443248 BCS-AA10717 20WSP - Toxicity Test to 

Determine the Effects of the Test Substance on 

Vegetative Vigor of Terrestrial Plant Species 

An associated 

NOAEC/EC05 could 

not be determined for 

the lowest EC50

Supplemental 

850.4250 47443249 BCS-AA10717 20WSP - Toxicity Test to 

Determine the Effects of the Test Substance on 

Vegetative Vigor of Terrestrial Plant Species 

Study failed to define 

a NOAEC or EC05 

corresponding to the 

lowest EC25 for 

dicots. 

Supplemental 

850.4400 47443250 Indaziflam Technical – Tier II 7-day Aquatic 

Plant Test on the Growth of Lemna gibba 

None Acceptable 

850.4400 47443251 Triazine-Indanone – Tier II 7-Day Toxicity Test 

with Duckweed (Lemna gibba G3) 

None Acceptable 

850.4400 47443252 Fluoroethyldiaminotriazine – Tier II 7-Day 

Toxicity Test with Duckweed (Lemna gibba 

G3) 

Failed to determine 

most sensitive 

endpoint 

Supplemental 

850.4400 47443253 Indaziflam-carboxylic Acid – Tier II 7-Day 

Toxicity Test with Duckweed (Lemna gibba 

G3) 

None Acceptable 

850.4400 47443254 Indaziflam-hydroxyethyl – Tier II 7-Day 

Toxicity Test with Duckweed (Lemna gibba 

G3) 

None Acceptable 

850.4400 47443255 Indaziflam-olefine – Tier II 7-Day Toxicity 

Test with Duckweed (Lemna gibba G3) 

None Acceptable 

Nonguideline 47443256 Indaziflam Technical – Growth Inhibition Test 

in a Water/Sediment System using Spiked 

Water with Duckweed (Lemna gibba) under 

Static Conditions 

Non-guideline Supplemental 

850.4450 47443257 BCS-AA10717 SC 500 G/L – Tier III 

Ecological Effects Test in Outdoor 

Experimental Ponds Inhabited with 

Macrophytes 

Multiple deviations 

from guideline; was 

submitted as 

supplemental data 

Supplemental 

Nonguideline 47443258 Indaziflam Technical – Non-guideline 

Screening Test on Effects to Aquatic 

Macrophytes in Outdoor Simulated Ponds 

Non-guideline Supplemental 

Nonguideline 47443259 Analysis of AE 1170437 concentrations in 

sediment samples of ALTERRA Study No. 

ALT.SC.2007.1 

Non-guideline Extraneous Data -

No study 

classification 

given. 
-Page 125 of 292- 

Nonguideline 47443260 Analysis of AE 1170437 concentrations in 

water samples of ALTERRA Study No. 

ALT.SC.2007.1 

Non-guideline Extraneous Data -

No study 

classification 

given. 

850.5400 47443261 Indaziflam Technical – 96-hr Test on the 

Growth of the Green Alga Pseudokirchneriella 

subcapitata 

None Acceptable 

850.5400 47443262 Fluoroethyldiaminotriazine - 72-Hour Toxicity 

Test with the Freshwater Green Alga 

(Pseudokirchneriella subcapitata) 

Study length 72 hours Supplemental 

850.5400 47443263 Indaziflam - carboxylic Acid - 72-Hour 

Toxicity Test with the Freshwater Green Alga 

(Pseudokirchneriella subcapitata) 

Study length 72 hours Supplemental 

850.5400 47443264 Indaziflam - hydroxyethyl - 72-Hour Toxicity 

Test with the Freshwater Green Alga 

(Pseudokirchneriella subcapitata) 

Study length 72 hours Supplemental 

850.5400 47443265 Indaziflam - olefine - 72-Hour Toxicity Test 

with the Freshwater Green Alga 

(Pseudokirchneriella subcapitata) 

Study length 72 hours Supplemental 

850.5400 47443266 Indaziflam Technical - 96-Hour Toxicity Test 

with the Freshwater Alga (Navicula pelliculosa)

Test media was not 

centrifuged to 

determine dissolved 

test substance 

concentration. 

Supplemental 

850.5400 47443267 Indaziflam Technical - 96-Hour Toxicity Test 

with the Saltwater Diatom (Skeletonema 

costatum) 

None Acceptable 

850.5400 47443268 Indaziflam Technical - 96-Hour Toxicity Test 

with the Freshwater Cyanobacteria (Anabaena 

flos-aquae) 

Test media was not 

centrifuged to 

determine dissolved 

test substance 

concentration. 

Supplemental 

Nonguideline 

47443269 Indaziflam Technical – Acute Toxicity Study 

on Earthworms (Eisenia fetida andrei) 

A 14-day test instead 

of a 28-day test was 

conducted. 

Supplemental 

850.1010 47743303 Indaziflam 500 SC – Acute toxicity to Daphnia 

magna in a 48 Hour Static Test 

Test media was not 

centrifuged to 

determine dissolved 

test substance 

concentration. 

Supplemental 

850.1010 47743304 Indaziflam 200 SC – Acute toxicity to Daphnia 

magna in a 48 Hour Static Test 

Test media was not 

centrifuged to 

determine dissolved 

test substance 

concentration. 

Supplemental 
-Page 126 of 292- 

850.1075 47743305 Indaziflam 500 SC – Acute toxicity to Bluegill 

Sunfish (Lepomis macrochirus) over 96 hrs 

Test media was not 

centrifuged to 

determine dissolved 

test substance 

concentration. 

Supplemental 

850.2100 47743306 Indaziflam Technical – An Acute Oral Toxicity 

Study with the Zebra Finch 

None Acceptable 

850.3020 47743307 Indaziflam 500 SC – Acute Toxicity Study to 

the honeybee (Apic melifera L.) under 

laboratory conditions 

None Acceptable 

850.4400 47743308 Indaziflam 500 SC – Tier II 7-day Aquatic 

Plant Test on the Growth of Lemna gibba 

None Acceptable 

850.5400 47743309 Indaziflam Technical - 96-hr Test on the 

Growth of the Green Alga Pseudokirchneriella 

subcapitata 

None Acceteptable 

850.5400 47743310 Indaziflam 500 SC - 72-Hour Toxicity Test 

with the Freshwater Green Alga 

(Pseudokirchneriella subcapitata) 

Study length 72 hours Supplemental 

850.5400 47743311 Indaziflam 200 SC - 72-Hour Toxicity Test 

with the Freshwater Green Alga 

(Pseudokirchneriella subcapitata) 

Study length 72 hours; 

light intensities two 

times recommended 

levels 

Supplemental 

Nonguideline 47743312 Fluoroethyldiaminotriazine - Acute Toxicity 

Study on Earthworms (Eisenia fetida andrei) 

A 14-day test instead 

of a 28-day test was 

conducted 

Supplemental 

Nonguideline 47743313 Triazine-indanone - Acute Toxicity Study on 

Earthworms (Eisenia fetida andrei) 

A 14-day test instead 

of a 28-day test was 

conducted 

Supplemental 

Nonguideline 47743314 Indaziflam – carboxylic acid - Acute Toxicity 

Study on Earthworms (Eisenia fetida andrei) 

A 14-day test instead 

of a 28-day test was 

conducted 

Supplemental 

Nonguideline 47743315 Indaziflam 500 SC - Acute Toxicity Study on 

Earthworms (Eisenia fetida andrei) 

A 14-day test instead 

of a 28-day test was 

conducted 

Supplemental 

860.6200 47743316 Indaziflam 500 SC – Survival, Growth, and 

Reproduction toxicity test on Earthworms 

(Eisenia fetida andrei) 

Did not test 

concentrations to 

guideline limit to 

dervive an LC50

Supplemental 
-Page 127 of 292- 

Appendix C. Summaries of Ecological Effects Studies Submitted for 

Indaziflam 

Toxicity to Freshwater Aquatic Animals 

Freshwater Fish, Acute 
-Page 128 of 292- 

Table C-1. Acute Toxicity of Indaziflam (TGAI) and Metabolites to Freshwater Fish. 

Species Chemical a.i. LC50

Toxicity 

Category 

Identification 

Number 

(Study 

Classification)

Indaziflam 94.5 96-h LC50: 0.77 mg total a.i./L Highly 

toxic 

MRID 

47443229 

(Supplemental) 

Fathead 

minnow 

(Pimephales 

promelas) In a 96-h acute toxicity study, fathead minnow (Pimephales promelas) were exposed to AE 

1170437 at nominal concentrations of 0 (negative and solvent control), 0.13, 0.26, 0.52, 1.05, and 

2.09 mg a.i./L; mean-measured concentrations were <0.01 (<LOQ, negative and solvent control), 

0.15, 0.27, 0.55, 1.07, and 2.19 mg total a.i./L under static conditions. Centrifugation was not 

conducted to determine the dissolved test substance concentration in the test media; thus, all 

reported measured concentration values are total concentrations of test substance in the test 

media. 

 

The 96-h LC50 was 0.77 mg total a.i/L. The EC50 and NOAEC values, based on sub-lethal effects, 

were <0.55 and 0.27 mg total a.i./L, respectively. Based on the results of this study, AE 1170437 

would be classified as highly toxic to fathead minnow (Pimephales promelas) on an acute toxicity 

basis, in accordance with the classification system of the U.S. EPA. 

This study is scientifically sound; however, this study does not meet OPPTS 850.1075 guideline 

standards for a freshwater fish acute toxicity test because centrifugation was not conducted as part 

of the analysis for dissolved test substance. This study is classified Supplemental. 

96-h LC50: 0.77 mg total a.i./L (95% C.I.: 0.55 – 1.07 mg total a.i./L; Probit slope: N/A) 

NOAEC (sublethal effects): 0.27 mg total a.i./L 

Bluegill 

sunfish 

Indaziflam 94.5 96-h LC50: 0.32 mg total a.i./L Highly 

toxic 

MRID 

47443233 

(Supplemental) 
-Page 129 of 292- 

Table C-1. Acute Toxicity of Indaziflam (TGAI) and Metabolites to Freshwater Fish. 

Species Chemical a.i. LC50

Toxicity 

Category 

Identification 

Number 

(Study 

Classification)

(Lepomis 

macrochirus) 

In a 96-h acute toxicity study, bluegill (Lepomis macrochirus) were exposed to AE 1170437 at 

nominal concentrations of 0 (negative and solvent control), 0.09, 0.19, 0.38, 0.75, and 1.50 mg 

a.i./L; mean-measured concentrations were <0.006 (negative control), <0.003 (<LOQ, solvent 

control), 0.10, 0.21, 0.39, 0.75, and 1.54 mg total a.i./L under static conditions. The solubility of 

BCS-AA10717 was reported as >1.5 mg a.i./L under testing conditions of 0.1 mL/L solvent load; 

however, the solubility of BCS-AA10717 ranges from 1.2 - 4.4 mg/L (MRID: 47443202). The 

study was conducted up to the limit of solubility (1.50 mg a.i/L, nominal) and centrifugation was 

not conducted to determine the dissolved test substance concentration in the test media. Thus, all 

reported measured concentration values are total concentrations of test substance (total a.i.) in the 

test media. 

Cumulative mortality after 96 hours was 0% in the negative and solvent control, as well as in the 

0.10 and 0.21 mg total a.i./L treatment groups. Mortality was 80%, 100% and 100% in the 0.39, 

0.75, and 1.54 mg total a.i./L treatment groups, respectively. There were no sublethal effects 

observed in the negative and solvent controls or the 0.10 and 0.21 mg total a.i./L treatment 

groups. Toxicological symptoms such as loss of equilibrium, vertical orientation, labored 

respiration, and lying on the bottom were observed in the 0.39 mg total a.i./L treatment group at 

24 hours and in the 1.54 mg total a.i./L treatment level at 4 hours. 

The 96-h LC50 was 0.32 mg total a.i/L. The NOAEC value, based on sub-lethal effects and 

mortality, was 0.21 mg total a.i./L. Based on the results of this study, AE 1170437 would be 

classified as highly toxic to bluegill (Lepomis macrochirus) on an acute toxicity basis, in 

accordance with the classification system of the U.S. EPA. 

This study is scientifically sound; however, this study does not meet OPPTS 850.1075 guideline 

standards for a freshwater fish acute toxicity test because centrifugation was not conducted as part 

of the analysis for dissolved test substance. This study is classified Supplemental. 

96-h LC50: 0.32 mg total a.i./L (95% C.I.: 0.21 – 0.75 mg total a.i./L; Probit slope: N/A) 

NOAEC (sublethal effects): 0.21 mg total a.i./L 

Rainbow trout 

(Oncohynchus 

mykiss)

Indaziflam 94.5 96-h LC50: 0.57 mg total a.i./L Highly 

toxic 

MRID 

47443234 

(Supplemental) 
-Page 130 of 292- 

Table C-1. Acute Toxicity of Indaziflam (TGAI) and Metabolites to Freshwater Fish. 

Species Chemical a.i. LC50

Toxicity 

Category 

Identification 

Number 

(Study 

Classification)

In a 96-h acute toxicity study, rainbow trout (Oncorhynchus mykiss) were exposed to AE 

1170437 (AI: BCS-AA10717) at nominal concentrations of 0 (negative and solvent control), 0.09, 

0.19, 0.38, 0.75, and 1.50 mg a.i./L; mean-measured concentrations were <0.003 (<LOQ, 

negative and solvent control), 0.10, 0.19, 0.42, 0.78, and 1.46 mg total a.i./L under static 

conditions. The solubility of BCS-AA10717 was reported as approximately 10 mg total a.i./L 

under testing conditions of 0.5 ml/L solvent load; however, the solubility of BCS-AA10717 

ranges from 1.2 - 4.4 mg/L (MRID: 47443202). The study was conducted up to the limit of 

solubility (1.50 mg a.i/L, nominal) and centrifugation was not conducted to determine the 

dissolved test substance concentration in the test media. Thus, all reported measured 

concentration values are total concentrations of test substance (total a.i.) in the test media. 

Cumulative mortality after 96 hours was 0% in the negative and solvent control, as well as in the 

0.10-0.42 mg total a.i./L treatment groups. Mortality was 100% in the 0.78 and 1.46 mg total 

a.i./L treatment groups. There were no sublethal effects observed in the negative and solvent 

controls or the 0.10-0.78 mg total a.i./L treatment groups. Loss of equilibrium was observed in 

the 1.46 mg total a.i./L treatment group at 4 hours in six fish. Complete mortality at 24 hours 

precluded the ability to observe sublethal effects thereafter. 

The 96-h LC50 was 0.572 mg total a.i/L. The NOAEC value, based on mortality, was 0.42 mg 

total a.i./L. Based on the results of this study, AE 1170437 would be classified as highly toxic to 

rainbow trout (Oncorhynchus mykiss) on an acute toxicity basis, in accordance with the 

classification system of the U.S. EPA. 

This study is scientifically sound; however, this study does not meet OPPTS 850.1075 guideline 

standards for a freshwater fish acute toxicity test because centrifugation was not conducted as part 

of the analysis for dissolved test substance. This study is classified Supplemental. 

96-h LC50: 0.57 mg total a.i./L (95% C.I.: 0.42 – 0.78 mg total a.i./L; Probit slope: N/A) 

NOAEC (sublethal effects): 0.42 mg total a.i./L 

Fathead 

minnow 

Diaminotriazine 99.3 96-h LC50: > 101 mg a.i./L Practically 

non-toxic 

MRID 

47443230 

(Acceptable) 
-Page 131 of 292- 

Table C-1. Acute Toxicity of Indaziflam (TGAI) and Metabolites to Freshwater Fish. 

Species Chemical a.i. LC50

Toxicity 

Category 

Identification 

Number 

(Study 

Classification)

(Pimephales 

promelas) 

In a 96-h acute toxicity study, conducted as a limit test, fathead minnow (Pimephales promelas) 

were exposed to AE 1170437-diaminotriazine at nominal concentrations of 0 (negative control) 

and 100 mg a.i./L; mean-measured concentrations were <1.01 (<LOQ, negative control) and 101 

mg a.i./L under static conditions. 

There were no effects on mortality or sublethal effects observed in the control or treatment level. 

The 96-h LC50 was >101 mg a.i/L. The EC50 and NOAEC values, based on mortality and sublethal effects, were >101 and 101 mg a.i./L, respectively. Based on the results of this study, AE 

1170437-diaminotriazine would be classified practically non-toxic to fathead minnow 

(Pimephales promelas) on an acute toxicity basis, in accordance with the classification system of 

the U.S. EPA. 

This study is scientifically sound and meets OPPTS 850.1075 guideline standards for an acute 

freshwater fish toxicity study. This study is classified Acceptable. 

96-h LC50: > 101 mg a.i./L (95% C.I.: N/A; Probit slope: N/A) 

NOAEC: 101 mg a.i./L 

Carboxylic 

Acid 

96.5 96-h LC50: > 103 mg a.i./L Practically 

non-toxic 

MRID 

47443231 

(Acceptable) 

Fathead 

minnow 

(Pimephales 

promelas) In a 96-h acute toxicity study, fathead minnow (Pimephales promelas) were exposed to AE 

1170437-carboxylic acid at nominal concentrations of 0 (negative control) and 100 mg a.i./L; 

mean-measured concentrations were <1.00 (<LOQ, negative control) and 103 mg a.i./L under 

static conditions. 

There were no effects on mortality, and no sublethal effects were observed in the control or 

treatment level. The 96-h LC50 was >103 mg a.i/L. The EC50 and NOAEC values, based on 

mortality and sub-lethal effects, were >103 and 103 mg a.i./L, respectively. Based on the results 

of this study, AE 1170437-carboxylic acid would be classified practically non-toxic to fathead 

minnow (Pimephales promelas) on an acute toxicity basis, in accordance with the classification 

system of the U.S. EPA. 

This study is scientifically sound and meets OPPTS 850.1075 guideline standards for an acute 

freshwater fish toxicity study. This study is classified Acceptable.

96-h LC50: > 103 mg a.i./L (95% C.I.: N/A; Probit slope: N/A) 

NOAEC: 103 mg a.i./L 

Bluegill sunfish 

(Lepomis 

macrochirus) 

Indaziflam SC 

500 

45.08 LC50: 0.372 mg total ai/L 

 95% C.I.: 

0.251 to 0.913 mg total ai/L 

Highly 

Toxic 

MRID 

47743305 

(Supplemental) 
-Page 132 of 292- 

Table C-1. Acute Toxicity of Indaziflam (TGAI) and Metabolites to Freshwater Fish. 

Species Chemical a.i. LC50

Toxicity 

Category 

Identification 

Number 

(Study 

Classification)

In a 96-hour acute toxicity study, bluegill sunfish (Lepomis macrochirus) were exposed under 

static conditions to AE 1170437 SC 500 g/L (AI: BCS-AA10717) at nominal concentrations of 0 

(negative control), 0.250, 0.500, 1.00, 2.00, and 4.00 mg formulation/L, equivalent to 0 (negative 

control), 0.113, 0.225, 0.451, 0.902, and 1.80 mg ai/L. Mean-measured concentrations were 

<0.000530 (<LOQ, control), 0.133, 0.251, 0.446, 0.913, and 1.77 mg total ai/L, which are 

equivalent to <LOQ (control), 0.295, 0.556, 0.989, 2.03, and 3.92 mg total formulation/L, 

respectively. The study was conducted up to the limit of solubility (1.80 mg a.i/L, nominal) of 

BCS-AA10717 and centrifugation was not conducted to determine the dissolved test substance 

concentrations in the test media. Thus, all reported measured concentration values are total 

concentrations of test substances (total a.i.) in the test media. The solubility of the formulation 

was not reported. 

After 24 hours, cumulative mortality was 0, 0, 0, 40, 100, and 100% for the control, 0.133, 0.251, 

0.446, 0.913, and 1.77 mg total ai/L levels, respectively (mean-measured concentrations); after 

48, 72, and 96 hours, cumulative mortality was 0, 0, 0, 80, 100, and 100%, respectively. The 96-

hour LC50 was 0.372 mg total ai/L, which is equivalent to 0.825 mg total form/L. Clinical signs 

of toxicity were observed at the mean-measured 0.446 mg total ai/L treatment levels, and 

included fish on the bottom of the aquarium, dark coloration, hyperactivity, inactivity, labored 

respiration, loss of equilibrium with lateral deviation, and/or laying on their sides or backs. The 

NOAEC for mortality and clinical signs of toxicity was 0.251 mg total ai/L, which is equivalent 

to 0.557 mg total form/L. 

Based on the results of this study, AE 1170437 SC 500 g/L (AI: BCS-AA10717) is highly toxic 

to bluegill sunfish (Lepomis macrochirus) in accordance with the classification system of the U.S. 

EPA. 

This study is scientifically sound; however, this study does not meet OPPTS 850.1075 guideline 

standards for a freshwater fish acute toxicity test because centrifugation was not conducted as part 

of the analysis for dissolved test substance. This study is classified Supplemental. 

LC50: 0.372 mg total ai/L 95% C.I.: 0.251 to 0.913 mg total ai/L 

NOAEC: 0.251 mg total ai/L (based on mortality and sublethal effects) 

EC50: Could not be determined 95% C.I.: N/A 

Probit Slope: N/A 95% C.I.: N/A 

Freshwater Fish, Chronic 

Table C-2. Chronic Toxicity of Indaziflam (TGAI) to Freshwater Fish. 

Species Chemical a.i. NOAEC 

Identification 

Number 

(Study 

Classification)

Fathead 

minnow 

(Pimephales 

Indaziflm 94.5 464.4 μg a.i./L based on fry survival, total 

length, and total weight 

MRID 

47443236 

(Supplemental) 
-Page 133 of 292- 

Table C-2. Chronic Toxicity of Indaziflam (TGAI) to Freshwater Fish. 

Species Chemical a.i. NOAEC 

Identification 

Number 

(Study 

Classification)

The 35-day chronic toxicity of BCS-AA10717 (containing 90.3% AE 1170437) to the early lifestage of fathead minnow (Pimephales promelas) was studied under flow-through conditions. 

Fertilized eggs/embryos (140/level, <24 hours old) of fathead minnow were exposed to nominal 

concentrations of 0 (negative and solvent controls), 63, 125, 250, 500, and 1000 μg ai/L (adjusted 

for purity). TWA concentrations were <5.95 (<LOQ, controls), 58.21, 142.6, 286.6, 464.4, and 

1020 μg total ai/L. The test system was maintained at 23.3 to 26.2°C and a pH of 7.3 to 8.1. The 

35-day LC/EC50 was values could not be determined due to a lack of an adequate dose-response 

relationship for any endpoint analyzed. However, based on fry survival, the LC50 value is likely 

to be between 464.4 and 1020 μg total ai/L. Because BCS-AA10717 was tested approximately 

up to its limit of solubility (1,200 – 4,400 μg ai/L), test media should have been centrifuged prior 

to analyzing the measured concentrations to determine the concentration of dissolved test 

substance; thus, all reported measured values are total concentration of test substance in the test 

media. 

 

Hatching occurred at all levels on Days 4 and 5, and hatching success averaged 92.1 to 98.6% for 

all levels, with no statistically significant differences observed. Similarly, survival of hatched 

alevins assessed on Day 5 ranged from 90.0 to 95.7%, with no treatment-related effects indicated. 

Post-hatch survival of fry, however, was adversely affected at the highest treatment level. Posthatch survival (Day 35) ranged from 92.5 to 98.8% for the control through 465.3 μg total ai/L 

levels, but was only 2.5% at the 1013 μg total ai/L level (p<0.05). Death was generally preceded 

by loss of equilibrium, lying on the bottom, and/or labored respiration. 

Standard lengths ranged from 21.6 to 23.5 mm and dry weight ranged from 46.2 to 66.2 mg for 

all levels. A significant difference (p < 0.01) in mean dry weight was detected between the 

negative and solvent controls, with significantly lighter fish (13%) in the solvent control group. 

With the exception of the highest treatment, where growth was promoted 25% relative to the 

negative control (although mortality occurred in 3 out of the 4 replicates for this concentration), 

fish weights were significantly reduced relative to the negative control at all treated levels. The 

reviewer determined that the significant difference between the solvent and negative control casts 

sufficient uncertainty unto the data as to affect its acceptability. However, since no effects were 

detected relative to the solvent control at all treatment levels in which no mortality occurred, and 

effects to length showed similar results, there is confidence in determining a LOAEC and 

NOAEC regardless of whether the solvent control did indeed have a slight effect. The LOAEC 

and NOAEC for dry weight was based on mortality and sublethal effects (ie. behavioral and 

morphological observations) and were determined to be 1013 and 465.3 μg total ai/L, 

respectively. 

This study is scientifically sound but does not fully meet OPPTS 850.1400 guideline standards 

for an early life stage toxicity study with freshwater fish. A significant statistical difference 

(13%, p < 0.01) was found between negative and solvent controls for mean dry weight of fish. 

Furthermore, centrifugation was not conducted as part of the analysis for dissolved test substance. 

This study is classified Supplemental. 

Endpoint NOAEC LOAEC 

Alevin survival (Day 5) 1020 μg total ai/L >1020 μg total ai/L 

Fry survival (Day 35) 464.4 μg total ai/L 1020 μg total ai/L 

Percent hatch (Day 5) 1020 μg total ai/L >1020 μg total ai/L 

Total Length 464.4 μg total ai/L 1020 μg total ai/L 

Dry Weight1 464.4 μg total ai/L 1020 μg total ai/L 
-Page 134 of 292- 

Freshwater Invertebrates, Acute 

Table C-3. Acute Toxicity of Indaziflam (TGAI) to Freshwater Invertebrates. 

Species Chemical % a.i. EC50/LC50

Toxicity 

Category 

Identification 

Number 

(Study 

Classification)

Indaziflam 94.5 48-h EC50: >9.88 mg a.i./L 

(immobility) 

Moderately 

to slightly 

toxic 

MRID 

47443226 

(Supplemental) 

Water flea 

(Daphnia 

magna) 

The 48-hour acute toxicity of AE 1170437 to Daphnia magna was studied under static conditions. 

Daphnids were exposed to nominal concentrations of 0 (negative and solvent control), 0.63, 1.25, 

2.5, 5.0, and 10 mg a.i./L. Mean-measured concentrations were <0.06 mg a.i./L (<LOQ, controls), 

0.62, 1.23, 2.54, 4.86, and 9.88 mg a.i./L. Test levels were set based on the practical limit of 

solubility in the test waters. The study author attempted to find the limit of solubility, both with and 

without the use of the solvent stock. The study authors determined that the limit of solubility for 

indaziflam using the maximum solvent load allowable under OPPTS guidelines of 0.5 ml/L (acetone) 

was 10 mg a.i./L. It was reported that the test material did not go into solution at 10 mg a.i./L at 

solvent loads below 0.5 ml/L. Centrifugation was not conducted to determine the dissolved test 

substance concentration in the test media; thus, all reported measured concentration values are total 

concentrations of test substance in the test media. 

Immobility and sublethal effects were observed at 24 and 48 hours. The 48-hour EC50 (based on 

immobile daphnia) was >9.88 mg a.i./L. The 48-hr NOAEC, based on sublethal behavioral effects, 

was 4.86 mg a.i./L. The observed sublethal effects included quiescence. 

This study suggests that AE 1170437 would be categorized moderately toxic to slightly toxic to 

Daphnia magna on an acute toxicity basis, in accordance with the classification system of the U.S. 

EPA. 

This study is classified as scientifically sound, however centrifugation was not conducted to 

determine the measured concentrations of the dissolved test substance in the test media. This study 

does not fully meet guideline standards for an acute freshwater invertebrate toxicity study. This 

study is classified Supplemental. 

 

48-h EC50: >9.88 mg a.i./L (immobility) 

95% C.I.: N/A; Probit slope: N/A 

NOAEC: 4.86 mg a.i./L (sublethal effects: quiescence) 

Indaziflam 

SC 500 

45.08 EC50: >38 mg total ai/L 

 95% C.I.: N/A 

Slightly 

toxic, at 

most 

MRID 

47743303 

(Supplemental) 

Water flea 

(Daphnia 

magna) 

The 48-hour acute toxicity of the formulated product AE 1170437 SC 500 g/L (AI: BCS-AA10717) 

to Daphnia magna was studied under static conditions. Daphnids (20 organisms/level) were exposed 

to AE 1170437 SC 500 g/L at nominal concentrations of 0 (negative control), 5.7, 11, 23, 45, and 91 

mg formulation/L, equivalent to 0 (control), 2.6, 5.1, 10, 21, and 41 mg ai/L, respectively. Meanmeasured concentrations were <0.26 (<LOQ, control), 2.3, 4.3, 8.4, 18, and 38 mg total ai/L, 

respectively. Mean-measured concentrations in terms of formulated product were <LOQ (control), 

5.1, 9.5, 19, 40, and 84 mg total formulation/L, respectively. Centrifugation was not conducted at 

test termination to determine the dissolved test substance concentration in the test media; thus, all 

reported measured concentration values are total concentrations in the test media. 
-Page 135 of 292- 

Table C-3. Acute Toxicity of Indaziflam (TGAI) to Freshwater Invertebrates. 

Species Chemical % a.i. EC50/LC50

Toxicity 

Category 

Identification 

Number 

(Study 

Classification)

Following 48 hours of exposure, immobility was 0% at the control through mean-measured 8.4 mg 

ai/L levels, 10% at the 18 mg ai/L level, and 5% at the 38 mg ai/L level. Sub-lethal signs of toxicity 

were observed at the 8.4, 18, and 38 mg ai/L levels after 24 hours, and at all treatment levels by 48 

hours. Effects included lying on the bottom, quiescence, and paleness. 

The 48-hour NOAEC (based on sublethal effects) and EC50 values were <2.3 and >38 mg ai/L, 

respectively, which are equivalent to <5.1 and >84 mg form/L, respectively. 

Based on the results of this study, AE 1170437 SC 500 g/L (AI: BCS-AA10717) is slightly toxic, at 

most, to Daphnia magna in accordance with the classification system of the U.S. EPA. 

This study is classified as scientifically sound, however centrifugation was not conducted to 

determine the measured concentrations of the dissolved test substance in the test media. This study 

does not fully meet guideline standards for an acute freshwater invertebrate toxicity study. This 

study is classified Supplemental. 

Based on mean-measured ai: 

LC50: N/A 95% C.I.: N/A 

EC50: >38 mg total ai/L 95% C.I.: N/A 

NOAEC: <2.3 mg total ai/L (based on sublethal effects) 

Probit Slope: N/A 95% C.I.: N/A 

Based on formulated product (45.08% ai): 

LC50: N/A 95% C.I.: N/A 

EC50: >84 mg total form/L 95% C.I.: N/A 

NOAEC: <5.1 mg total form/L (based on sublethal effects) 

Probit Slope: N/A 95% C.I.: N/A 

Indaziflam 

200 SC 

19.2 EC50: 37.5 mg total ai/L 

95% C.I.: 29.8 to 49.5 mg total ai/L 

Probit Slope: 2.6 

 

95% C.I.: 1.8 to 3.4 

 MRID 

47743304 

(Supplemental) 

Water flea 

(Daphnia 

magna) 

The 48-hour acute toxicity of the formulated product BCS-AA10717 SC 200 g/L (containing 19.2% 

indaziflam) to Daphnia magna was studied under static conditions. Daphnids (30 organisms/level) 

were exposed to BCS-AA10717 SC 200 g/L at nominal concentrations of 0 (negative control), 20, 

40, 80, 160, and 320 mg formulation/L, equivalent to 0 (control), 3.8, 7.7, 15, 31, and 61 mg ai/L, 

respectively. Mean-measured concentrations were <0.00384 (<LOQ, control), 4.43, 8.26, 20.3, 32.2, 

and 87.4 mg total ai/L, respectively. Mean-measured concentrations in terms of formulated product 

were <LOQ (control), 23.0, 43.0, 105.7, 168, and 455 mg total formulation/L, respectively. 

Centrifugation was not conducted at test termination to determine the dissolved test substance 

concentration in the test media; thus, all reported measured concentration values are total 

concentrations in the test media. 

Cumulative immobility after 24 hours was 0, 0, 3, 3, 0, and 57% at the control, 4.43, 8.26, 20.3, 32.2, 

and 87.4 mg total ai/L levels, respectively; cumulative immobility after 48 hours was 0, 0, 10, 23, 30, 
-Page 136 of 292- 

Table C-3. Acute Toxicity of Indaziflam (TGAI) to Freshwater Invertebrates. 

Species Chemical % a.i. EC50/LC50

Toxicity 

Category 

Identification 

Number 

(Study 

Classification)

and 90% at the control, 4.43, 8.26, 20.3, 32.2, and 87.4 mg total ai/L levels, respectively. Besides 

treatment-related immobility, no further effects on behavior were observed at any level. 

The NOAEC and EC50 values were 8.26 and 37.5 mg total ai/L, respectively, which were equivalent 

to 43.0 and 195 mg total formulation/L. Based on the results of this study, the formulated product 

BCS-AA10717 SC 200 g/L (containing 19.2% indaziflam) is practically non-toxic to Daphnia magna 

in accordance with the classification system of the U.S. EPA. 

This study is classified as scientifically sound, however centrifugation was not conducted to 

determine the measured concentrations of the dissolved test substance in the test media. This study 

does not fully meet guideline standards for an acute freshwater invertebrate toxicity study. This 

study is classified Supplemental. 

Based on mean-measured ai: 

LC50: N/A 95% C.I.: N/A 

NOAEC: 8.26 mg total ai/L 

EC50: 37.5 mg total ai/L 95% C.I.: 29.8 to 49.5 mg total ai/L 

Probit Slope: 2.6 95% C.I.: 1.8 to 3.4 

Based on formulated product (19.2% ai): 

LC50: N/A 95% C.I.: N/A 

NOAEC: 43.0 mg total ai/L 

EC50: 195 mg total ai/L 95% C.I.: 155 to 258 mg total ai/L 

Probit Slope: 2.6 95% C.I.: 1.8 to 3.4 

Indaziflam 94.5 Pore Water 

10 day LC50: > 2.2 mg ai/L (mortality) 

Bulk Sediment 

10 day LC50: > 100 mg ai/kg dw 

(mortality) 

Overlying water 

10 day LC50: > 0.18 mg ai/L (mortality) 

N/A MRID 

47443238 

(Supplemental) 

Midge 

(Chironomus 

tetans) 

In a 10 day acute whole sediment toxicity study of indaziflam, midges were exposed to nominal 

conencetrations of 0 (negative and solvent controls), 6.6, 14, 26, 52, and 100 mg ai/kg sediment in an 

intermittent flow-through system. Mean measured concentrations for sediment were <LOQ 

(negative and solvent controls), 6.9, 15, 27, 50, 100 mg a.i./kg dw, and mean measured 

concentrations for pore water were <LOQ (negative and solvent controls), 0.042, 0.10, 0.38, 0.72, 

2.2 mg a.i./kg dw. Survival and ash-free dry weight were the measured data endpoints. 

Following 10 days of exposure, percent survival averaged 91 to 98% and mean ash-free dry weight 

(AFDW) averaged 1.21 to 1.47 mg per midge for all levels, with no statistically-significant 

differences from the negative control observed. 

Test concentrations were tested up to BCS-AA10717’s limit of solubility (1.2 - 4.4 mg/L; MRID 

47443202). The reported limit of solubility was 2.8 mg/L at 20°C (pH 6.6 to 6.9). Centrifugation 

was not conducted for the overlying water to determine the dissolved test substance concentration in 

the test media. 
-Page 137 of 292- 

Table C-3. Acute Toxicity of Indaziflam (TGAI) to Freshwater Invertebrates. 

Species Chemical % a.i. EC50/LC50

Toxicity 

Category 

Identification 

Number 

(Study 

Classification)

This study is classified Supplemental 

Based on Mean-Measured Pore Water Concentrations: 

LC50 mortality: >2.2 mg a.i./L 95% C.I.: N/A 

EC50 ash-free dry weights: >2.2 mg a.i./L 95% C.I.: N/A 

NOAEC (mortality): 2.2 mg a.i./L 

NOAEC (dry weights): 2.2 mg a.i./L 

Based on Mean-Measured Sediment Concentrations: 

LC50 mortality: >100 mg a.i./kg dw 95% C.I.: N/A 

EC50 ash-free dry weights: >100 mg a.i./kg dw 95% C.I.: N/A 

NOAEC (mortality): 100 mg a.i./kg dw 

NOAEC (dry weights): 100 mg a.i./kg dw 

Based on Mean-Measured Overlying Water Concentrations: 

LC50 mortality: >0.18 mg a.i./L 95% C.I.: N/A 

EC50 ash-free dry weights: >0.18 mg a.i./L 95% C.I.: N/A 

NOAEC (mortality): 0.18 mg a.i./L 

NOAEC (dry weights): 0.18 mg a.i./L 

Freshwater Invertebrate, Chronic 

Table C-4. Chronic Toxicity of Indaziflam (TGAI) to Freshwater Invertebrates. 

Species Chemical % a.i. NOAEC/LOAEC 

Toxicity 

Category 

Identification 

Number 

(Study 

Classification)

Indaziflam 94.5 21-day NOAEC: 0.34 mg total a.i./L 

21-day LOAEC: 0.80 mg total a.i./L 

(Neonates per reproductive day; adult 

length; adult dry weight) 

N/A MRID 

47443235 

(Supplemental) 

Water flea 

(Daphnia 

magna) 

The 21-day-chronic toxicity of BCS-AA10717 (containing 90.3% AE 1170437) to Daphnia magna 

was studied under static renewal conditions. Daphnids were exposed to BCS-AA10717 at nominal 

concentrations of 0 (negative and solvent controls), 0.05, 0.13, 0.32, 0.80, and 2.0 mg ai/L. Meanmeasured concentrations were <0.003 (<LOQ, controls), 0.06, 0.14, 0.34, 0.80 and 2.0 mg total ai/L, 

respectively. The 21-day EC50 for adult immobility was >2.0 mg total ai/L, the highest 

concentration tested. The 21-day NOAEC was 0.34 mg total ai/L, based upon treatment-related 

effects on growth (body length and dry weight) and neonates per reproductive day at the 0.80 and 2.0 

mg total ai/L levels at study termination; the EC50 values for neonates per reproductive day and dry 

weight were 1.6 and 1.7 mg total ai/L, respectively. Centrifugation was not conducted to determine 

the dissolved test substance concentration in the test media; thus, all reported measured concentration 

values are total concentrations of test substance in the test media. 

Adult immobilization (mortality) was ≤7% at all levels, with no treatment-related pattern observed. 

The time to first brood release increased with increasing concentration level, and was statistically-
-Page 138 of 292- 

Table C-4. Chronic Toxicity of Indaziflam (TGAI) to Freshwater Invertebrates. 

Species Chemical % a.i. NOAEC/LOAEC 

Toxicity 

Category 

Identification 

Number 

(Study 

Classification)

increased (p≤0.05) compared to the negative control group at the 2.0 mg total ai/L level (7.4 versus 

8.4 days). Similarly, the number of offspring per reproductive day was statistically-reduced (p≤0.05) 

at the 0.80 and 2.0 mg total ai/L levels compared to the negative control (7.6 and 18.4 versus 21.8). 

Terminal growth parameters of surviving adults were the most sensitive endpoints, with statisticallysignificant decreases (p≤0.05) compared to the negative control at the 0.81 and 2.0 mg total ai/L 

levels. Length averaged 5.16 to 5.24 mm for the negative control through 0.34 mg total ai/L levels, 

5.09 mm at the 0.81 mg total ai/L level, and 4.02 mm at the 2.0 mg total ai/L level. Dry weight 

averaged 1.396 to 1.465 mg for the negative control through 0.34 mg total ai/L levels, 1.316 mg at 

the 0.80 mg total ai/L level, and 0.508 mg at the 2.0 mg total ai/L level. 

This study is scientifically sound. However, the number of immobilized offspring per adult was not 

reported. Furthermore, centrifugation was not conducted to determine the measured concentrations 

of the dissolved test substance in test media given the solubility limit of the test substance. The 

study does not meet OPPTS 850.1300 guideline standards for a chronic freshwater invertebrate 

toxicity test using Daphnia magna. This study is classified Supplemental. 

 

Parental Immobilization: 

EC50: >2.0 mg total ai/L 95% C.I.: N/A 

Probit Slope: N/A 

NOAEC: 2.0 mg total ai/L 

LOAEC: >2.0 mg total ai/L 

Time to First Brood Release: 

EC50: >2.0 mg total ai/L 95% C.I.: N/A 

Slope: N/A 

NOAEC: 0.80 mg total ai/L 

LOAEC: 2.0 mg total ai/L 

Neonates per Repro. Day: 

EC50: 1.6 mg total ai/L 95% C.I.: 1.4-1.7 mg total ai/L 

Slope: 3.54±0.337 

NOAEC: 0.34 mg total ai/L 

LOAEC: 0.80 mg total ai/L 

Length: 

EC50: >2.0 mg total ai/L 95% C.I.: N/A 

Slope: N/A 

NOAEC: 0.34 mg total ai/L 

LOAEC: 0.80 mg total ai/L 

Dry weight: 

EC50: 1.7 mg total ai/L 95% C.I.: 1.6-1.8 mg total ai/L 

Slope: 4.44±0.497 

NOAEC: 0.34 mg total ai/L 

LOAEC: 0.80 mg total ai/L 

Endpoint(s) Affected: Reproduction (time to first brood release and no. of neonates per reproductive 

day) and growth (length and dry weight) 
-Page 139 of 292- 

Table C-4. Chronic Toxicity of Indaziflam (TGAI) to Freshwater Invertebrates. 

Species Chemical % a.i. NOAEC/LOAEC 

Toxicity 

Category 

Identification 

Number 

(Study 

Classification)

Most Sensitive Endpoint: neonates per reproductive day 

Toxicity to Estuarine and Marine Animals 

Estuarine and Marine Fish, Acute 

Table C-5. Acute Toxicity of Indaziflam (TGAI) to Estuarine/Marine Fish. 

Species Chemical % a.i. LC50

Toxicity 

Category 

Identification 

Number 

(Study 

Classification) 

Sheepshead 

minnow 

(Cyprinodon 

variegates) 

Indaziflam 94.5 96-h LC50: 0.96 mg total a.i./L 

(mortality) 

Highly 

toxic 

MRID 47443232 

(Supplemental) 

 In a 96-h acute toxicity study, sheepshead minnow (Cyprinodon variegatus) were exposed to AE 

1170437 (AI: BCS-AA10717) at nominal concentrations of 0 (negative and solvent control), 0.09, 

0.19, 0.38, 0.75, and 1.50 mg a.i./L; mean-measured concentrations were <0.006 (<LOQ, negative 

and solvent control), 0.10, 0.21, 0.43, 0.77, and 1.56 mg total a.i./L under static conditions. The 

solubility of BCS-AA10717 was reported as ≥ 4.0 mg a.i./L under testing conditions; however, the 

solubility of BCS-AA10717 ranges from 1.2 - 4.4 mg/L (MRID: 47443202). The study was 

conducted up to the limit of solubility (1.50 mg a.i/L, nominal) and centrifugation was not 

conducted to determine the dissolved test substance concentration in the test media. Thus, all 

reported measured concentration values are total concentrations of test substance in the test media. 

The 96-h LC50 was 0.96 mg total a.i/L. The EC50 and NOAEC values, based on sub-lethal effects 

and mortality, were >1.56 and 0.43 mg total a.i./L, respectively. Based on the results of this study, 

AE 1170437 (AI: BCS-AA10717) would be classified as highly toxic to sheepshead minnow 

(Cyprinodon variegatus) on an acute toxicity basis, in accordance with the classification system of 

the U.S. EPA. 

This study is scientifically sound; however, this study does not meet OPPTS 850.1075 guideline 

standards for a freshwater fish acute toxicity test because centrifugation was not conducted as part 

of the analysis for dissolved test substance. This study is classified Supplemental. 

96-h LC50: 0.96 mg total a.i./L 

95% C.I.: 0.43 – 4.56 mg total a.i./L; Probit slope: N/A 

NOAEC: 0.43 mg total a.i./L 

Sublethal effects: 

EC50: 1.56 mg total a.i./L 

NOAEC: 0.43 mg total a.i./L 
-Page 140 of 292- 

Estuarine and Marine Fish, Chronic 

No life cycle toxicity test with estuarine/ marine fish with indaziflam TGAI, formulations, or 

degradates were submitted. 

Estuarine and Marine Aquatic Invertebrates, Acute 

Table C-6. Acute Toxicity of Technical Grade Indaziflam (TGAI) to Estuarine/Marine 

Invertebrates. 

Species Chemical % a.i. EC50/LC50

Toxicity 

Category 

Identification 

Number 

(Study 

Classification)

Eastern Oyster 

(Crassotrea 

virginica) 

Indaziflam 94.5 96-h EC50: 0.92 mg total a.i./L 

(shell growth) 

Highly 

toxic 

MRID 

47443228 

(Supplemental) 

96-h acute toxicity test in the Eastern oyster under flow-through conditions. Nominal 

concentrations: 0 (negative and solvent control), 0.063, 0.13, 0.25, 1.0, and 2.0 mg/L; Timeweighted average concentrations were <0.0400 (<LOQ, controls), 0.061, 0.122, 0.24, 0.47, 0.89, 

and 1.80 mg total a.i./L, respectively. 

Endpoints assessed: mortality and shell growth. 

No mortality occurred during the study. 

A slight amount of white precipitate was noted on the sides of the mixing chamber for the 2.0 mg 

total a.i./L test concentration at test termination. Centrifugation was not conducted to determine 

the dissolved test substance concentration in the test media; thus, there is uncertainty regarding the 

quantity of test substance dissolved in the test media and all reported measured concentration 

values are total concentrations of test substance in the test media. BCS-AA10717’s solubility is 

1.2-4.4 mg/L (MRID 47443202). 

This study is scientifically sound. However, centrifugation was not conducted to determine the 

dissolved test substance concentration in the test media given that the highest test concentration 

exceeds BCS-AA10717’s solubility. This study is classified Supplemental. 

Shell deposition: 

96-h EC50: 0.92 mg total a.i./L 

95% C.I.: 0.75 – 1.1 mg total a.i./L; Probit slope: 4.04 

NOAEC: 0.47 mg total a.i./L 

Indaziflam 94.5 96-h LC50: 1.5 mg a.i./L Moderately 

toxic 

MRID 

47443227 

(Accetpable) 

Saltwater 

mysid 

(Americamysis 

bahia) 96-h acute toxicity test in saltwater mysid under static conditions. Nominal concentrations: 0 

(negative and solvent control), 0.31, 0.63, 1.3, 2.5, and 5.0 mg a.i./L; time-weighted average 

concentrations were <0.100 (<LOQ; controls), 0.261, 0.521, 1.06, 1.88, and 4.00 mg a.i./L, 

respectively. 

Although a precipitate was noted in the nominal 5.0 mg ai/L treatment level, the study author noted 

that samples were centrifuged prior to analysis and recoveries were acceptable (80% of nominal at 
-Page 141 of 292- 

Table C-6. Acute Toxicity of Technical Grade Indaziflam (TGAI) to Estuarine/Marine 

Invertebrates. 

Species Chemical % a.i. EC50/LC50

Toxicity 

Category 

Identification 

Number 

(Study 

Classification)

test initiation and 100% of initial at 48 hours). 

This study is scientifically sound and meets OPPTS 850.1035 guideline standards for a mysid 

acute toxicity test. This study is classified Acceptable. 

96-h LC50: 1.5 mg a.i./L (morality) 

95% C.I.: 1.06 – 1.88 mg a.i./L; 

Probit slope: N/A 

NOAEC: 1.06 mg a.i./L 

(Mortality and sublethal effects) 

Indaziflam 94.5 Pore Water

LC50 mortality: >3.8 mg a.i./L 

NOAEC (mortality): 3.8 mg a.i./L 

Bulk Sediment

LC50 mortality: >180 mg a.i./kg dw

NOAEC (mortality): 180 mg a.i./kg 

dw 

Overlying Water

LC50 mortality: >1.4 mg a.i./L 

NOAEC (mortality): 1.4 mg a.i./L 

N/A MRID 

47443239 

(Acceptable) 

Marine 

Amphipod 

(Leptocheirus 

plumulosus) 

In a 10 day acute whole sediment toxicity study of indaziflam, marine amphipods were exposed to 

nominal conencetrations of 0 (negative and solvent controls), 5.3, 11, 21, 42, and 170 mg ai/kg dw 

sediment in a static system. Mean measured concentrations for sediment were <LOQ (negative 

and solvent controls), 5.7, 12, 26, 40, 180 mg a.i./kg dw. Mean measured pore water 

concentrations were <LOQ (negative and solvent controls), 0.10, 0.24, 0.46, 1.0, and 3.8 mg a.i./L. 

Survival was the measured endpoint. 

Following 10 days of exposure, percent survival averaged 93 to 100%, with no treatment-related 

significant differences from the controls observed. 

This study is scientifically sound, however the overlying water was not centrifuged to determine 

measured concentrations of the dissolved test substance in the test media. This study does not 

fully meet guideline standards for a whole sediment: acute marine invertebrate study using

Leptocheirus plumulosus. This study is classified Supplemental. 

 

Based on Mean-Measured Pore Water Concentrations: 

LC50 mortality: >3.8 mg a.i./L 95% C.I.: N/A 

NOAEC (mortality): 3.8 mg a.i./L 

Based on Mean-Measured Sediment Concentrations: 

LC50 mortality: >180 mg a.i./kg dw 95% C.I.: N/A 

NOAEC (mortality): 180 mg a.i./kg dw 

Based on Mean-Measured Overlying Water:

LC50 mortality: >1.4 mg a.i./L 95% C.I.: N/A 

NOAEC (mortality): 1.4 mg a.i./L 
-Page 142 of 292- 

Estuarine and Marine Invertebrates, Chronic 

No chronic toxicity studies of indaziflam TGAI, formulations, or degradates with 

estuaring/marine invertebrates were submitted. 

Toxicity to Plants Inhabiting Aquatic Environments

Table C-7. Toxicity (Tier II) of Indaziflam (TGAI), Metabolites, and Formulations to Nonvascular Plants Inhabiting Aquatic Environments. 

Species Chemical % a.i. EC50

Identification 

Number 

(Study 

Classification) 

Indaziflam 94.5 96-h EC50: 74 μg a.i./L (Biomass) MRID 47443261 

(Acceptable) 

Freshwater green 

algae 

(Pseudokircheriella 

subcapitata) 

In a 96-hour toxicity study, cultures of the freshwater green algae (Pseudokirchneriella 

subcapitata) were exposed to BCS-AA10717 Technical at nominal concentrations of 0 

(negative and solvent controls), 25, 50, 100, 200, and 400 μg a.i./L under static conditions. 

Reviewer-calculated mean-measured concentrations were <2.92 (<LOQ, controls), 24.2, 51.1, 

102, 196, and 403 μg a.i./L. 

The most sensitive endpoint was biomass, with NOAEC and EC50 values of 24.2 and 74 μg 

a.i./L, respectively. 

There were no abnormalities observed in cell condition at test termination. 

This toxicity study is classified as scientifically sound and meets the OPPTS 850.5400 

guideline standards for a nonvascular aquatic plant toxicity study with the freshwater green 

algae, Pseudokirchneriella subcapitata. This study is classified Acceptable. 

Cell density:

96-h EC50: 84 μg a.i./L 95% C.I.: 64 - 110 μg a.i./L 

96-h EC05: 39 μg a.i./L 95% C.I.: 22 – 70 μg a.i./L 

96-h NOAEC: 24.2 μg a.i./L 

Probit slope: 4.99 ± 1.11 

72-h EC50: 64 μg a.i./ L 95% C.I.: 51-79 μg a.i./L 

Slope 

Biomass (Area under the curve):

96-h EC50: 74 μg a.i./L 95% C.I.: 62 to 88 μg a.i./L 

96-h EC05: 31 μg a.i./L 95% C.I.: 21 to 46 μg a.i./L 

96-h NOAEC: 24.2 μg a.i./L 

Probit Slope: 4.43 ± 0.559 

Growth rate:

96-h EC05: 49 μg a.i./L 95% C.I.: 32 to 77 μg a.i./L 

96-h EC50: 130 μg a.i./L 95% C.I.: 100 to 160 μg a.i./L 

96-h NOAEC: 51.1 μg a.i./L 

Probit Slope: 4.00 ± 0.550 

Most sensitive endpoint(s): Biomass 

Freshwater Diatom Indaziflam 94.5 96-h EC50: 87 μg total a.i./L MRID: 47443266 
-Page 143 of 292- 

Table C-7. Toxicity (Tier II) of Indaziflam (TGAI), Metabolites, and Formulations to Nonvascular Plants Inhabiting Aquatic Environments. 

Species Chemical % a.i. EC50

Identification 

Number 

(Study 

Classification) 

(Navicula (Biomass) (Supplemental) 

pelliculosa) In a 96-hour toxicity study, cultures of the freshwater diatom (Navicula pelliculosa) were 

exposed to BCS-AA10717 Technical at nominal concentrations of 0 (negative control and 

solvent control), 2.0, 6.3, 20, 63, 200, 630, and 2,000 μg a.i./L under static conditions. Meanmeasured concentrations were <0.20 (<LOQ, controls), 1.80, 5.36, 17.7, 57.4, 199, 621, and 

2,019 μg total a.i./L. Centrifugation was not conducted to determine the dissolved test 

substance concentration in the test media; thus, all reported measured concentration values are 

total concentrations of test substance in the test media. 

The most sensitive endpoint was biomass, with NOAEC and EC50 values of 17.7 and 87 μg 

total a.i./L, respectively. Percent inhibition in the treatment groups as compared to the control 

ranged from -8 to 100%. 

There were no abnormalities in cell condition at test termination. 

This toxicity study is scientifically sound but does not meet OPPTS 850.5400 guideline 

standards for a nonvascular aquatic plant toxicity study with the freshwater diatom, Navicula 

pelliculosa. Centrifugation was not conducted to determine the dissolved test substance 

concentration in test media. This study is classified Supplemental.

Cell density

EC05: 37 μg total a.i./L 95% C.I.: 21 to 63 μg total a.i./L 

EC50: 130 μg total a.i./L 95% C.I.: 100 to 170 μg total a.i./L 

NOAEC: 57.4 μg total a.i./L 

Slope: 2.92 ± 0.371 

Biomass (Area Under the Growth Curve) 

EC05: 19 μg total a.i./L 95% C.I.: 11 to 31 μg total a.i./L 

EC50: 87 μg total a.i./L 95% C.I.: 69 to 110 μg total a.i./L 

NOAEC: 17.7 μg total a.i./L 

Slope: 2.44 ± 0.241 

Growth Rate 

EC05: 73 μg total a.i./L 95% C.I.: 60 to 89 μg total a.i./L 

EC50: 390 μg total a.i./L 95% C.I.: 360 to 420 μg total a.i./L 

NOAEC: 57.4 μg total a.i./L 

Slope: 2.27 ± 0.0853 

 

 Endpoint(s) Effected: Cell density, biomass, and growth rate 

Indaziflam 94.5 96-h EC50: 27 μg a.i./L (Biomass) MRID: 47443267 

(Acceptable) 

Marine diatom 

(Skeletonema 

costatum) In a 96-hour toxicity study, cultures of the saltwater diatom (Skeletonema costatum) were 

exposed to BCS-AA10717 Technical at nominal concentrations of 0 (negative and solvent 

control), 2.0, 5.1, 13, 32, 80, and 200 μg a.i./L under static conditions. Mean-measured 

concentrations were <0.50 (<LOQ, controls), 2.0, 5.1, 13, 33, 79, and 231 μg a.i./L
-Page 144 of 292- 

Table C-7. Toxicity (Tier II) of Indaziflam (TGAI), Metabolites, and Formulations to Nonvascular Plants Inhabiting Aquatic Environments. 

Species Chemical % a.i. EC50

Identification 

Number 

(Study 

Classification) 

The most sensitive endpoint was biomass, with NOAEC and EC50 values of 5.1 and 27 μg 

a.i./L, respectively. 

% inhibition in the treatment groups as compared to the control ranged from 4 to 99%. 

There were no abnormalities in cell condition at test termination. 

This toxicity study is classified as scientifically sound and does meet OPPTS 850.5400 

guideline standards for a nonvascular aquatic plant toxicity study with the saltwater diatom, 

Skeletonema costatum. This study is classified as acceptable. 

Cell density

96-h EC50: 34 μg a.i./L 95% C.I.: 28 to 41 μg a.i./L 

96-h EC05: 9.3 μg a.i./L 95% C.I.: 6 to 14 μg a.i./L 

96-h NOAEC: 5.1 μg a.i./L 

Probit Slope: 2.93 ± 0.302 

Biomass (Area Under the Growth Curve) 

96-h EC50: 27 μg a.i./L 95% C.I.: 22 to 33 μg a.i./L 

96-h EC05: 6.3 μg a.i./L 95% C.I.: 4.1 to 9.7 μg a.i./L 

96-h NOAEC: 5.1 μg a.i./L 

Probit Slope: 2.62 ± 0.232 

Growth Rate 

96-h EC50: 83 μg a.i./L 95% C.I.: 74 to 94 μg a.i./L 

96-h EC05: 20 μg a.i./L 95% C.I.: 15 to 27 μg a.i./L 

96-h NOAEC: 13 μg a.i./L 

Probit Slope: 2.66 ± 0.177 

Most sensitive endpoint(s): Biomass 

Indaziflam 94.5 96-h EC50: 750 μg total a.i./L (Cell 

density) 

MRID: 47443268 

(Supplemental) 

Freshwater 

cyanobacteria 

(Anabaena flosaquae) 

In a 96-hour toxicity study, cultures of the freshwater cyanobacteria (Anabaena flos-aquae) 

were exposed to BCS-AA10717 Technical at nominal concentrations of 0 (negative and solvent 

control), 13, 40, 127, 400, 1,270, and 4,000 μg a.i./L under static conditions. Mean-measured 

concentrations were <1.20 (<LOQ, controls), 11.6, 36.3, 115, 406, 1,294, and 3,926 μg total 

a.i./L. Centrifugation was not conducted to determine the dissolved test substance 

concentration in the test media, given BCS-AA10717’s solubility limit (1.2 – 4.4 mg/L; MRID 

47443202). All reported measured concentration values are total concentrations of test 

substance in the test media. 

The most sensitive endpoint was cell density, with NOAEC and EC50 values of 115 and 750 μg 

total a.i./L, respectively. 

% inhibition in the treatment groups as compared to the controls ranged from -12 to 92%. 

There were no abnormalities in cell condition at test termination. 
-Page 145 of 292- 

Table C-7. Toxicity (Tier II) of Indaziflam (TGAI), Metabolites, and Formulations to Nonvascular Plants Inhabiting Aquatic Environments. 

Species Chemical % a.i. EC50

Identification 

Number 

(Study 

Classification) 

This toxicity study is scientifically sound but does not meet OPPTS 850.5400 guideline 

standards for a nonvascular aquatic plant toxicity study with the freshwater cyanobacteria, 

Anabaena flos-aquae. Centrifugation was not conducted to determine the dissolved test 

substance concentration in test media. This study is classified Supplemental. 

Cell density

EC05: 120 μg total a.i./L 95% C.I.: 64 to 240 μg total a.i./L 

EC50: 750 μg total a.i./L 95% C.I.: 560 to 990 μg total a.i./L 

NOAEC: 115 μg total a.i./L 

Slope: 2.11 ± 0.245 

Biomass (Area Under the Growth Curve) 

EC05: 100 μg total a.i./L 95% C.I.: 52 to 200 μg total a.i./L 

EC50: 810 μg total a.i./L 95% C.I.: 620 to 1,100 μg total a.i./L 

NOAEC: 115 μg total a.i./L 

Slope: 1.82 ± 0.191 

Growth Rate 

EC05: 280 μg total a.i./L 95% C.I.: 200 to 410 μg total a.i./L 

EC50: 3,800 μg total a.i./L 95% C.I.: 3,500 to 4,300 μg total a.i./L 

NOAEC: 115 μg total a.i./L 

 Slope: 1.46 ± 0.100 

 Endpoint(s) Effected: Cell density, biomass, and growth rate 

Fluoroethyld

iaminotriazi

ne 

99.3 72-h EC50: 11 mg a.i./L (Cell Density) MRID 47443262 

(Supplemental) 

Freshwater green 

algae 

(Pseudokircheriella 

subcapitata) In a 72-hour toxicity study, cultures of the freshwater green algae (Pseudokirchneriella 

subcapitata) were exposed to BCS-AA10365 at nominal concentrations of 0 (negative control), 

6.25, 12.5, 25, 50, and 100 mg a.i./L 

under static conditions. Mean-measured concentrations were <0.61 (<LOQ, control), 5.37, 

10.6, 22, 45, and 92 mg a.i./L. 

The most sensitive endpoint was cell density, with NOAEC and EC50 values of <5.37 and 11 

mg a.i./L, respectively. 

There were no abnormalities in cell condition at test termination. 

This toxicity study is classified as scientifically sound but does not satisfy OPPTS 158.5400 

guideline standards for a nonvascular aquatic plant toxicity study with the freshwater green 

algae, Pseudokirchneriella subcapitata. The study was conducted for only 72 hours, and a 

definitive NOAEC corresponding to the lowest EC50 value was not determined from the 

concentrations tested. This study is classified Supplemental. 

Cell density

EC05: <5.37 mg a.i./L 95% C.I.: N/A 

EC50: 11 mg a.i./L 95% C.I.: 9.4 to 14 mg a.i./L 

NOAEC: <5.37 mg a.i./L 
-Page 146 of 292- 

Table C-7. Toxicity (Tier II) of Indaziflam (TGAI), Metabolites, and Formulations to Nonvascular Plants Inhabiting Aquatic Environments. 

Species Chemical % a.i. EC50

Identification 

Number 

(Study 

Classification) 

Slope: 2.86 ± 0.230 

Biomass (Area Under the Growth Curve) 

EC05: <5.37 mg a.i./L 95% C.I.: N/A 

EC50: 14 mg a.i./L 95% C.I.: 13 to 16 mg a.i./L 

NOAEC: <5.37 mg a.i./L 

Slope: 3.32 ± 0.180 

Growth Rate 

EC05: 7.3 mg a.i./L 95% C.I.: 4.7 to 12 mg a.i./L 

EC50: 26 mg a.i./L 95% C.I.: 21 to 32 mg a.i./L 

NOAEC: 5.37 mg a.i./L 

Slope: 3.03 ± 0.323 

 

 Endpoint(s) Effected: Cell density, biomass, and growth rate 

Indaziflam -

carboxylic 

acid 

96.5 MRID 47443263 

(Supplemental) 

Freshwater green 

algae 

(Pseudokircheriella 

subcapitata) In a 72-hour toxicity study, cultures of the freshwater green algae (Pseudokirchneriella 

subcapitata) were exposed to AE 2158969 (BCS-AA10717-carboxylic acid, metabolite of 

BCS-AA10717) at nominal concentrations of 0 (negative control), 0.63, 1.25, 2.5, 5.0, and 10 

mg a.i./L under static conditions. Mean-measured concentrations were <0.05 (<LOQ, control), 

0.57, 1.15, 2.3, 4.6, and 9.4 mg a.i./L. 

The most sensitive endpoint could not be determined, as the EC50 values of the endpoints tested 

were greater than the highest test concentration. 

There were no abnormalities in cell condition at test termination. 

This toxicity study is classified as scientifically sound but does meet OPPTS 850.5400 

guideline standards for a nonvascular aquatic plant toxicity study with the freshwater green 

algae, Pseudokirchneriella subcapitata. The most sensitive endpoint could not be determined, 

as the EC50 values of the endpoints tested were greater than the highest test concentration. 

Additionally, the study was conducted for 72 hours. This study is classified Supplemental. 

Cell density

EC05: 4.2 mg a.i./L 95% C.I.: 2.3 to 7.7 mg a.i./L 

EC50: >9.4 mg a.i./L 95% C.I.: N/A 

NOAEC: 4.6 mg a.i./L 

Slope: 3.90 ± 1.36 

Biomass (Area Under the Growth Curve) 

EC05: 4.3 mg a.i./L 95% C.I.: 2.6 to 7.1 mg a.i./L 

EC50: >9.4 mg a.i./L 95% C.I.: N/A 

NOAEC: 4.6 mg a.i./L 

Slope: 4.03 ± 1.20 

Growth Rate 
-Page 147 of 292- 

Table C-7. Toxicity (Tier II) of Indaziflam (TGAI), Metabolites, and Formulations to Nonvascular Plants Inhabiting Aquatic Environments. 

Species Chemical % a.i. EC50

Identification 

Number 

(Study 

Classification) 

EC05: 7.0 mg a.i./L 95% C.I.: 5.4 to 9.1 mg a.i./L 

EC50: >9.4 mg a.i./L 95% C.I.: N/A 

NOAEC: 4.6 mg a.i./L 

Slope: 3.00 ± 1.13 

 

 Endpoint(s) Effected: cell density, biomass, and growth rate 

Indaziflam -

hydroxyethyl 

96.5 72-h EC50: 0.55 mg a.i./L (cell 

density) 

MRID 47443264 

(Supplemental) 

Freshwater green 

algae 

(Pseudokircheriella 

subcapitata) In a 72-hour toxicity study, cultures of the freshwater green algae (Pseudokirchneriella 

subcapitata) were exposed to BCS-AA10202 (BCS-AA10717-1-hydroxyethyl, metabolite of 

BCS-AA10717)at nominal concentrations of 0 (negative control), 0.31, 0.63, 1.25, 2.5, and 5.0 

mg a.i./L under static conditions. Mean-measured concentrations were <0.03 (<LOQ, control), 

0.33, 0.69, 1.38, 2.7, and 5.6 mg a.i./L. 

The most sensitive endpoint was cell density, with NOAEC and EC50 values of 0.33 and 0.55 

mg a.i./L, respectively. % inhibition in the treatment groups as compared to the controls ranged 

from 4 to 98%. 

There were no abnormalities in cell condition at test termination. 

This toxicity study is classified as scientifically sound but does not meet OPPTS 850.5400 

guideline standards for a nonvascular aquatic plant toxicity study with the freshwater green 

algae, Pseudokirchneriella subcapitata. The study was only conducted for 72 hours, rather than 

the recommended 96 to 120 hours. This study is classified Supplemental. 

Cell density

EC05: <0.33 mg a.i./L 95% C.I.: N/A 

EC50: 0.55 mg a.i./L 95% C.I.: 0.32 to 0.95 mg a.i./L 

NOAEC: 0.33 mg a.i./L 

Slope: 3.20 ± 0.795 

Biomass (Area Under the Growth Curve) 

EC05: <0.33 mg a.i./L 95% C.I.: N/A 

EC50: 0.56 mg a.i./L 95% C.I.: 0.36 to 0.88 mg a.i./L 

NOAEC: 0.33 mg a.i./L 

Slope: 2.63 ± 0.448 

Growth Rate 

EC05: <0.33 mg a.i./L 95% C.I.: N/A 

EC50: 1.0 mg a.i./L 95% C.I.: 0.6 to 1.7 mg a.i./L 

NOAEC: 0.33 mg a.i./L 

Slope: 1.87 ± 0.313 

Indaziflam -

olefine 

96.0 72-h EC50: 54 μg a.i./L (Biomass) MRID: 47443265 

(Supplemental) 

Freshwater green 

algae 

(Pseudokircheriella In a 72-hour toxicity study, cultures of the freshwater green algae (Pseudokirchneriella 
-Page 148 of 292- 

Table C-7. Toxicity (Tier II) of Indaziflam (TGAI), Metabolites, and Formulations to Nonvascular Plants Inhabiting Aquatic Environments. 

Species Chemical % a.i. EC50

Identification 

Number 

(Study 

Classification) 

subcapitata) subcapitata) were exposed to BCS-AA10201 (BCS-AA10717-olefine, metabolite of BCSAA10717) at nominal concentrations of 0 (negative control), 0.89, 2.86, 9.16, 29.3, 93.8, and 

300 μg a.i./L under static conditions. Mean-measured concentrations were <0.10 (<LOQ, 

control), 1.01, 3.19, 10.2, 32.6, 103, and 336 μg a.i./L. 

The most sensitive endpoint was biomass, with NOAEC and EC50 values of 10.2 and 54 μg 

a.i./L, respectively. Percent inhibition in the treatment groups as compared to the controls 

ranged from -0.5 to 97.4%. 

There were no abnormalities in cell condition at test termination. 

This toxicity study is classified as scientifically sound but does not meet OPPTS 850.5400 

guideline standards for a nonvascular aquatic plant toxicity study with the freshwater green 

algae, Pseudokirchneriella subcapitata. The study was only conducted for 72 hours, rather than 

the recommended 96 to 120 hours. This study is classified Supplemental. 

Cell density

72-h EC50: 55 μg a.i./L 95% C.I.: 48 to 63 μg a.i./L 

72-h EC05: 14 μg a.i./L 95% C.I.: 11 to 19 μg a.i./L 

72-h NOAEC: 3.19 μg a.i./L 

Probit Slope: 2.82 ± 0.187 

Biomass (Area Under the Growth Curve) 

72-h EC50: 54 μg a.i./L 95% C.I.: 47 to 61 μg a.i./L 

72-h EC05: 13 μg a.i./L 95% C.I.: 9.7 to 17 μg a.i./L 

72-h NOAEC: 10.2 μg a.i./L 

Probit Slope: 2.66 ± 0.163 

Growth Rate 

72-h EC50: 150 μg a.i./L 95% C.I.: 140 to 160 μg a.i./L 

72-h EC05: 36 μg a.i./L 95% C.I.: 31 to 42 μg a.i./L 

72-h NOAEC: 10.2 μg a.i./L 

Probit Slope: 2.65 ± 0.0968 

Most sensitive endpoint(s): Biomass 

Indaziflam – 

technical 

95.7% EC50 = 77 μg ai/L (biomass) MRID: 

47743309 

(Acceptable) 

Freshwater green 

algae 

(Pseudokircheriella 

subcapitata) In a 96-hour acute toxicity study, cultures of green algae (Pseudokirchneriella subcapitata) 

were exposed to AE 1170437 Technical (AI: BCS-AA10717) at nominal concentrations of 0 

(negative and solvent control), 25, 50, 100, 200, and 400 μg ai/L under static conditions. 

Mean-measured concentrations were <2.5 (<LOQ, controls), 18, 38, 77, 151, and 222 μg ai/L. 

The most sensitive endpoint was biomass, with NOAEC and EC50 values of 38 and 77 μg ai/L, 

respectively. Inhibitions of biomass ranged from 1 to 99% as compared to the negative control. 

There were no compound related phytotoxic effects. 
-Page 149 of 292- 

Table C-7. Toxicity (Tier II) of Indaziflam (TGAI), Metabolites, and Formulations to Nonvascular Plants Inhabiting Aquatic Environments. 

Species Chemical % a.i. EC50

Identification 

Number 

(Study 

Classification) 

This toxicity study is classified as scientifically sound and meets guideline standards for a 

nonvascular aquatic plant toxicity study with the freshwater green algae, Pseudokirchneriella 

subcapitata. This study is classified Acceptable. 

Results Synopsis

 Test Organism: Pseudokirchneriella subcapitata

Test Type (Flow-through, Static, Static Renewal): Static 

 

 Cell density 

EC05: 50 μg ai/L 95% C.I.: 41 to 60 μg ai/L 

EC50: 81 μg ai/L 95% C.I.: 73 to 89 μg ai/L 

NOAEC: 38 μg ai/L 

Slope: 7.85 ± 0.970 

Biomass 

EC05: 42 μg ai/L 95% C.I.: 35 to 51 μg ai/L 

EC50: 77 μg ai/L 95% C.I.: 69 to 84 μg ai/L 

NOAEC: 38 μg ai/L 

Slope: 6.34 ± 0.617 

Growth rate 

EC05: 51 μg ai/L 95% C.I.: 36 to 71 μg ai/L 

EC50: 110 μg ai/L 95% C.I.: 98 to 130 μg ai/L 

NOAEC: 38 μg ai/L 

Slope: 4.76 ± 0.600 

Endpoint(s) Effected: cell density, biomass, and growth rate 

Indazilfam 500 

SC 

45.08% EC50 = 51 μg ai/L (cell density) MRID: 

47743310 

(Supplemental) 

Freshwater green 

algae 

(Pseudokircheriella 

subcapitata) In a 72-hour acute toxicity study, cultures of green algae (Pseudokirchneriella subcapitata) 

were exposed to AE 1170437 SC500 (AI: BCS-AA10717) at nominal concentrations of 0 

(negative and solvent control), 26, 51, 103, 205, and 410 μg ai/L under static conditions. 

Mean-measured concentrations were <2.50 (<LOQ, controls), 34, 66, 132, 271, and 543 μg 

ai/L. 

The most sensitive endpoint was cell density, with NOAEC, EC05 and EC50 values of <34, 15, 

and 51 μg ai/L, respectively. Inhibitions of cell density ranged from 31 to 99% as compared to 

the negative control. 

There were no compound related phytotoxic effects. 

This toxicity study is scientifically sound but does not meet OPPTS 850.5400 guideline 

standards for a tier II nonvascular aquatic plant toxicity study with the freshwater green algae, 

Pseudokirchneriella subcapitata. This study was conducted for 72 hours instead of the 
-Page 150 of 292- 

Table C-7. Toxicity (Tier II) of Indaziflam (TGAI), Metabolites, and Formulations to Nonvascular Plants Inhabiting Aquatic Environments. 

Species Chemical % a.i. EC50

Identification 

Number 

(Study 

Classification) 

recommended 96-120 hours. This study is classified Supplemental. 

Cell density 

EC05: 15 μg ai/L 95% C.I.: 6.9 to 33 μg ai/L 

EC50: 51 μg ai/L 95% C.I.: 34 to 75 μg ai/L 

NOAEC: <34 μg ai/L 

Slope: 3.12 ± 0.553 

Biomass 

EC05: 18 μg ai/L 95% C.I.: 10 to 33 μg ai/L 

EC50: 58 μg ai/L 95% C.I.: 43 to 78 μg ai/L 

NOAEC: <34 μg ai/L 

Slope: 3.29 ± 0.463 

Growth rate 

EC05: 21 μg ai/L 95% C.I.: 10 to 41 μg ai/L 

EC50: 90 μg ai/L 95% C.I.: 64 to 130 μg ai/L 

NOAEC: <34 μg ai/L 

 Slope: 2.57 ± 0.336 

Endpoint(s) Effected: cell density, biomass, and growth rate 

Indazilfam – 

200 SC 

19.2% EC50 = 53 μg ai/L (cell density) MRID: 

477743311 

(Supplemental) 

Freshwater green 

algae 

(Pseudokircheriella 

subcapitata) In a 72-hour acute toxicity study, cultures of freshwater green algae (Pseudokirchneriella 

subcapitata) were exposed to BCS-AA10717 SC 200 G (AI: Indaziflam) at nominal 

concentrations of 0 (negative control), 28.6, 91.6, 293.0, 938, and 3000 μg form/L under static 

conditions. The nominal concentrations of the active ingredient component were 0 (negative 

control), 5.49, 17.6, 56.3, 180, and 576 μg ai/L. Mean-measured concentrations were <0.5365 

(<LSC, negative control), 5.9, 16.8, 51.0, 162, and 520 μg ai/L. 

The more sensitive endpoint was cell density, with NOAEC and EC50 values of 16.8 and 53 μg 

ai/L, respectively, which is equivalent to 91.6 and 310 μg form/L. Inhibitions of cell density 

ranged from 0 to 98% as compared to the negative control. 

There were no compound related phytotoxic effects. 

This study is scientifically sound but fails to meet OPPTS 850.5400 guideline standards for a 

tier II nonvascular aquatic plant toxicity study with the freshwater green algae, 

Pseudokirchneriella subcapitata. The study was conducted for only 72 hours and at light 

intensities two times the recommended levels. This study is classified Supplemental. 

Results Synopsis

Test Organism: Pseudokirchneriella subcapitata

Test Type (Flow-through, Static, Static Renewal): 
-Page 151 of 292- 

Table C-7. Toxicity (Tier II) of Indaziflam (TGAI), Metabolites, and Formulations to Nonvascular Plants Inhabiting Aquatic Environments. 

Species Chemical % a.i. EC50

Identification 

Number 

(Study 

Classification) 

 

 AI: Indaziflam 

 Cell density 

EC05: 13 μg ai/L 95% C.I.: 6.5 to 25 μg ai/L 

EC50: 53 μg ai/L 95% C.I.: 39 to 73 μg ai/L 

NOAEC: 16.8 μg ai/L 

Slope: 2.67 ± 0.383 

 Biomass 

EC05: 11 μg ai/L 95% C.I.: 6.2 to 21 μg ai/L 

EC50: 56 μg ai/L 95% C.I.: 43 to 75 μg ai/L 

NOAEC: 16.8 μg ai/L 

Slope: 2.37 ± 0.270 

Growth rate 

EC05: 11 μg ai/L 95% C.I.: <5.9 to 30 μg ai/L 

EC50: 130 μg ai/L 95% C.I.: 88 to 180 μg ai/L 

NOAEC: 16.8 μg ai/L 

 Slope: 1.55 ± 0.220 

Formulation: BCS-AA10717 SC 200 G 

 Cell density 

EC05: 73 μg form/L 95% C.I.: 37 to 140 μg form/L 

EC50: 310 μg form/L 95% C.I.: 220 to 420 μg form/L 

NOAEC: 91.6 μg form/L 

Slope: 2.65 ± 0.378 

 Biomass 

EC05: 57 μg form/L 95% C.I.: 32 to 109 μg form/L 

EC50: 291 μg form/L 95% C.I.: 223 to 390 μg form/L 

NOAEC: 87.5 μg form/L 

Slope: 12.3 ± 1.41 

Growth rate 

EC05: 64 μg form/L 95% C.I.: <28.6 to 170 μg form/L 

EC50: 730 μg form/L 95% C.I.: 510 to 1100 μg form/L 

NOAEC: 91.6 μg form/L 

 Slope: 1.55 ± 0.219 

Endpoint(s) Effected: Cell density, biomass, and growth rate 

Table C-8. Acute Toxicity (Tier II) of Indaziflam (TGAI), Metabolites, and Formulations to 

Vascular Plants Inhabiting Aquatic Environments. 
-Page 152 of 292- 

Species Chemical % a.i. EC50

Identification 

Number 

(Study 

Classification) 

Indaziflam 94.5 7-day EC50: 67 ng a.i./L (Frond area) MRID 47443250 

(Acceptable) 

freshwater 

Duckweed (Lemna 

gibba) In a 7-day toxicity study, the freshwater floating aquatic vascular plants Duckweed (Lemna 

gibba) were exposed to BCS-AA10717 Technical (AI: BCS-AA10717) at nominal 

concentrations of 0 (negative and solvent controls), 3.92, 7.85, 15.7, 31.4, 62.8, and 126 ng 

a.i./L under static conditions. Test levels below the NOAEC were not analytically determined. 

Mean-measured concentrations for the control, 31.4, 62.8, and 126 ng a.i/L test levels were 

<10.39, 30.9, 59.9, and 112 ng ai/L. Because test levels were not measured for every 

concentration, toxicity calculations were performed using the nominal concentrations. 

The 7-Day NOAEC and EC50 values for frond area, the most sensitive endpoint, were 31.4 and 

67 ng a.i./L, respectively. The % growth inhibition in the treated algal culture as compared to 

the negative control ranged from 0 to 84.6%. 

By test termination, single and small fronds, chlorosis, and slight necrosis, were observed in the 

highest test concentration (126 ng a.i./L), and slight chlorosis was observed in the second 

highest test level (62.8 ng a.i./L). 

This toxicity study is classified as scientifically sound and meets the OPPTS 850.4400 

guideline standards for a Tier II vascular plant toxicity study with the freshwater species, 

Lemna gibba. This study is classified as acceptable.

Results Synopsis

Test Organism: Lemna gibba

Test Type (Flow-through, Static, Static Renewal): Static 

Frond number 

EC05: 51 ng a.i./L 95% C.I.: 45 to 58 ng a.i./L 

EC50: 87 ng a.i./L 95% C.I.: 82 to 92 ng a.i./L 

NOAEC: 31.4 ng a.i./L 

Slope: 7.15 ± 0.484 

Frond number based on growth rate 

EC05: 60 ng a.i./L 95% C.I.: 54 to 66 ng a.i./L 

EC50: 84 ng a.i./L 95% C.I.: 79 to 89 ng a.i./L 

NOAEC: 31.4 ng a.i./L 

Slope: 11.1 ± 0.738 

Frond number based on yield 

EC05: 54 ng a.i./L 95% C.I.: 50 to 59 ng a.i./L 

EC50: 76 ng a.i./L 95% C.I.: 72 to 80 ng a.i./L 

NOAEC: 31.4 ng a.i./L 

 Slope: 11.0 ± 0.713 

Frond area 

EC05: 46 ng a.i./L 95% C.I.: 39 to 54 ng a.i./L 

EC50: 67 ng a.i./L 95% C.I.: 60 to 74 ng a.i./L 

NOAEC: 31.4 ng a.i./L 

 Slope: 6.05 ± 0.508 
-Page 153 of 292- 

Table C-8. Acute Toxicity (Tier II) of Indaziflam (TGAI), Metabolites, and Formulations to 

Vascular Plants Inhabiting Aquatic Environments. 

Species Chemical % a.i. EC50

Identification 

Number 

(Study 

Classification) 

Frond area based on yield 

EC05: 50 ng a.i./L 95% C.I.: 44 to 56 ng a.i./L 

EC50: 76 ng a.i./L 95% C.I.: 71 to 81 ng a.i./L 

NOAEC: 31.4 ng a.i./L 

 Slope: 8.81 ± 0.683 

Endpoint(s) Affected: frond number, frond number based on growth rate, frond number 

based on yield, frond 

area, and frond area based on yield 

Triazineindanone 96.1 7-day EC50: 12 μg/L (frond area) MRID: 47443251 

(Acceptable) 

freshwater 

Duckweed (Lemna 

gibba) In a 7-day toxicity study, the freshwater floating aquatic vascular plants Duckweed (Lemna 

gibba) were exposed to AE 2158968 (metabolite of BCS-AA10717) at nominal concentrations 

of 0 (negative and solvent controls) 6.25, 12.5, 25, 50, and 100 μg/L under static conditions. 

Mean-measured concentrations were <0.4716 (<lowest standard analyzed, controls), 6.09, 12.0, 

22.5, 45.25, and 114.5 μg/L. 

The 7-Day NOAEC and EC50 values for frond area, the most sensitive endpoint, were 6.09 and 

12 μg/L, respectively. The % growth inhibition in the treated algal culture as compared to the 

negative control ranged from 1 to 93%. 

By day 3 there were observed cases of slight and medium necrosis in the three highest test 

concentrations, and by day 5 there were also observed cases of strong necrosis and lethality 

(highest test concentration). By test termination, there was medium chlorosis (12 μg/L), strong 

necrosis (22.5 μg/L), and lethality (45.25 and 114.5 μg/L) that were observed. 

This toxicity study is scientifically sound and satisfies OPPTS 850.4400 guideline standards for 

a Tier II vascular plant toxicity study with the freshwater species, Lemna gibba. This study is 

classified Acceptable. 

Results Synopsis

Test Organism: Lemna gibba

Test Type (Flow-through, Static, Static Renewal): Static 

Frond number 

EC05: <6.25 μg/L 95% C.I.: N/A 

EC50: 12 μg/L 95% C.I.: 6.9 to 21 μg/L 

NOAEC: 6.09 μg/L 

Slope: 2.35 ± 0.478 

Frond number based on growth rate 

EC05: 10 μg/L 95% C.I.: 7.3 to 14 μg/L 

EC50: 17 μg/L 95% C.I.: 15 to 19 μg/L 

NOAEC: 6.09 μg/L 
-Page 154 of 292- 

Table C-8. Acute Toxicity (Tier II) of Indaziflam (TGAI), Metabolites, and Formulations to 

Vascular Plants Inhabiting Aquatic Environments. 

Species Chemical % a.i. EC50

Identification 

Number 

(Study 

Classification) 

Slope: 7.53 ± 1.46 

Frond area 

EC05: 2.1 μg/L 95% C.I.: 0.79 to 5.4 μg/L 

EC50: 12 μg/L 95% C.I.: 7.5 to 19 μg/L 

NOAEC: 6.09 μg/L 

Slope: 2.15 ± 0.327 

 

Frond area based on growth rate 

EC05: 8.4 μg/L 95% C.I.: 7.1 to 10 μg/L 

EC50: 16 μg/L 95% C.I.: 15 to 17 μg/L 

NOAEC: 6.09 μg/L 

Slope: 5.92 ± 0.471 

Endpoint(s) Affected: frond number, frond number based on growth rate, frond area, and 

frond area based on growth rate 

Fluoroethyldiam

inotriazine 

99.3% Most sensitive endpoint could not be 

determined 

MRID: 47443252 

(Supplemental) 

freshwater 

Duckweed (Lemna 

gibba) In a 7-day toxicity study, the freshwater floating aquatic vascular plants Duckweed (Lemna 

gibba) were exposed to BCS-AA10365 (AE1170437-diaminotriazine, metabolite of 

AE1170437) at nominal concentrations of 0 (negative and solvent controls), 9.54, 30.5, 97.7, 

313, and 1,000 μg/L under static conditions. Mean-measured concentrations were <1.026 

(<lowest standard analyzed, controls), 11.1, 35.15, 110.5, 354.5, and 1,111 μg/L. 

During this study, effects to frond number, growth rate and frond area were observed. The only 

definitive EC50 that could be obtained from this study was a value of 51 μg/L based on effects 

to frond number. Effects to frond number and frond area were observed at the lowest treatment 

level (11.1 μg/L), which prevented the establishment of a NOAEC for this study. 

By day 2 there were cases of slight necrosis observed in the two highest test concentrations, and 

by day 4 there were also cases of medium and strong necrosis observed in the three highest test 

concentrations. By test termination, there was lethality in the two highest test concentrations. 

This study is scientifically sound but is classified Supplemental because it does not meet 

OPPTS 850.4400 guideline standards for a tier II aquatic vascular plant study based on the 

following: 

The most sensitive endpoint could not be determined by the reviewer’s analysis, given the poor 

fit of the data to the regression model. The only definitive EC50 that could be obtained from 

this study was a value of 51 μg/L based on effects to frond number. Effects to frond number 

and frond area were observed at the lowest treatment level (11.1 μg/L), which prevented the 

establishment of a NOAEC for this study. 

Results Synopsis

Test Organism: Lemna gibba
-Page 155 of 292- 

Table C-8. Acute Toxicity (Tier II) of Indaziflam (TGAI), Metabolites, and Formulations to 

Vascular Plants Inhabiting Aquatic Environments. 

Species Chemical % a.i. EC50

Identification 

Number 

(Study 

Classification) 

Test Type (Flow-through, Static, Static Renewal): Static 

Frond number 

EC05: 3.4 μg/L 95% C.I.: N/A 

EC50: 51 μg/L 95% C.I.: Beyond range of treatment levels 

NOAEC: <11.1 μg/L 

Slope: 1.41 ± 0.374 

Frond number based on growth rate 

EC05: Could not be determined 95% C.I.: N/A 

EC50: >110.5 μg/L 95% C.I.: N/A 

NOAEC: 35.15 μg/L 

Slope: N/A 

Frond Area 

EC05: Could not be determined 95% C.I.: N/A 

EC50: <110.5 μg/L, but >35.15 μg/L 95% C.I.: N/A 

NOAEC: <11.1 μg/L 

Slope: N/A 

Frond area based on growth rate 

EC05: Could not be determined 95% C.I.: N/A 

EC50: >35.15 μg/L 95% C.I.: N/A 

NOAEC: 35.15 μg/L 

Slope: 5.92 ± 0.471 

Endpoint(s) Affected: frond number, frond number based on growth rate, frond area, and 

frond area based on growth rate 

Indaziflam -

carboxylic 

acid 

96.5 7-day EC50: 4.0 mg/L (Frond number) MRID: 47443253 

(Acceptable) 

freshwater 

Duckweed (Lemna 

gibba) 

 In a 7-day toxicity study, the freshwater floating aquatic vascular plants Duckweed (Lemna 

gibba) were exposed to AE 2158969 (AE1170437-carboxylic acid, metabolite of BCSAA10717) at nominal concentrations of 0 (negative control), 1.00, 3.20, 10.0, 32.0, and 100 

mg/L under static conditions. Mean-measured concentrations were <0.0037 (<lowest standard 

analyzed, control), 1.13, 3.67, 11.1, 35.8, and 113 mg/L. 

The most sensitive endpoint was frond number, with NOAEC and EC50 values of 1.13 and 4.0 

mg/L, respectively. Inhibitions of frond number ranged from 9 to 92% as compared to the 

negative control. 

On day 5 there was slight chlorosis observed in the 11.1, 35.8, and 113.0 mg/L treatment 

groups. On day 7, there was slight chlorosis and medium necrosis observed in the 11.1 mg/L 

treatment group, and there was slight chlorosis, strong necrosis, and lethal plants observed in 

the 35.8, and 113.0 mg/L treatment groups. 
-Page 156 of 292- 

Table C-8. Acute Toxicity (Tier II) of Indaziflam (TGAI), Metabolites, and Formulations to 

Vascular Plants Inhabiting Aquatic Environments. 

Species Chemical % a.i. EC50

Identification 

Number 

(Study 

Classification) 

This study is scientifically sound and meets OPPTS guideline standards for a tier II aquatic 

vascular plant study. This study is classified Acceptable. 

Results Synopsis

Test Organism: Lemna gibba

Test Type (Flow-through, Static, Static Renewal): Static 

Frond number 

EC05: <1.13 mg/L 95% C.I.: 0.032 to 1.9 mg/L 

EC50: 4.0 mg/L 95% C.I.: 1.5 to 11 mg/L 

NOAEC: 1.13 mg/L 

Slope: 1.36 ± 0.277 

Frond number based on growth rate 

EC05: 3.2 mg/L 95% C.I.: 1.6 to 6.3 mg/L 

EC50: 6.2 mg/L 95% C.I.: 4.4 to 8.7 mg/L 

NOAEC: 1.13 mg/L Slope: 5.64 ± 1.47 

Frond area 

EC05: 0.20 mg/L 95% C.I.: 0.021 to 1.9 mg/L 

EC50: 4.2 mg/L 95% C.I.: 1.4 to 12.0 mg/L 

NOAEC: 1.13 mg/L 

Slope: 1.25 ± 0.263 

Frond area based on growth rate 

EC05: <1.13 mg/L 95% C.I.: 0.25 to 3.3 mg/L 

EC50: 5.0 mg/L 95% C.I.: 2.7 to 9.3 mg/L 

NOAEC: 1.13 mg/L 

Slope: 2.21 ± 0.461 

Endpoint(s) Affected: frond number, frond number based on growth rate, frond area, and 

frond area based on growth rate 

Indaziflamhydroxyethyl 

99.0 7-day EC50: 510 ng/L (Frond area) MRID 47443254 

(Acceptable) 

freshwater 

Duckweed (Lemna 

gibba) 

In a 7-day toxicity study, the freshwater floating aquatic vascular plants Duckweed (Lemna 

gibba) were exposed to BCS-AA10202 (AE1170437-1-hydroxyethyl, metabolite of BCSAA10717) at nominal concentrations of 0 (negative control and solvent controls), 62.5, 125, 

250, 500, and 1000 ng/L under static conditions. Mean-measured concentrations were <0.054 

μg/L (<lowest standard analyzed, controls), 101.1, 121.5, 250, 496, and 944.5 ng/L. 

The most sensitive endpoint was frond area, with NOAEC and EC50 values of 250 and 510 

ng/L, respectively. 

Inhibitions of frond area ranged from -14 to 94% as compared to the negative control. 

On day 3 there was slight chlorosis and medium necrosis observed in the 496 and 944.5 ng/L 

treatment groups, respectively. At day 5, there was strong necrosis observed in the highest 
-Page 157 of 292- 

Table C-8. Acute Toxicity (Tier II) of Indaziflam (TGAI), Metabolites, and Formulations to 

Vascular Plants Inhabiting Aquatic Environments. 

Species Chemical % a.i. EC50

Identification 

Number 

(Study 

Classification) 

treatment level. By day 7, there was medium chlorosis and slight necrosis observed in the 496 

ng/L treatment group, and there were lethal plants at the highest treatment level. 

This study is scientifically sound and meets OPPTS guideline standards for a tier II aquatic 

vascular plant study. This study is classified Acceptable. 

Results Synopsis

Test Organism: Lemna gibba

Test Type (Flow-through, Static, Static Renewal): Static 

Reviewer’s Results

Frond number 

EC05: 330 ng/L 95% C.I.: 290 to 380 ng/L 

EC50: 550 ng/L 95% C.I.: 520 to 590 ng/L 

NOAEC: 250 ng/L 

Slope: 7.26 ± 0.565 

Frond number based on growth rate 

EC05: >250 ng/L 95% C.I.: N/A 

EC50: >500 ng/L 95% C.I.: N/A 

NOAEC: 250 ng/L 

Slope: N/A 

Frond area based on growth rate

EC05: >250 ng/L 95% C.I.: N/A 

EC50: >500 ng/L 95% C.I.: N/A 

NOAEC: 250 ng/L 

Slope: N/A 

Frond area 

EC05: 270 ng/L 95% C.I.: 230 to 320 ng/L 

EC50: 510 ng/L 95% C.I.: 470 to 550 ng/L 

NOAEC: 250 ng/L 

Slope: 5.95 ± 0.501 

Study Author’s Results 

Frond number based on growth rate 

EC05: ND 95% C.I.: ND 

EC50: 634 ng/L 95% C.I.: 624 to 645 ng/L 

NOAEC: 250 ng/L 

Slope: ND 

Frond area based on growth rate

EC05: ND 95% C.I.: ND 
-Page 158 of 292- 

Table C-8. Acute Toxicity (Tier II) of Indaziflam (TGAI), Metabolites, and Formulations to 

Vascular Plants Inhabiting Aquatic Environments. 

Species Chemical % a.i. EC50

Identification 

Number 

(Study 

Classification) 

EC50: 590 ng/L 95% C.I.: 579 to 601 ng/L 

NOAEC: 250 ng/L 

Slope: N/A 

Endpoint(s) Affected: frond number, frond number based on growth rate, frond area, and 

frond area based on growth rate 

Indaziflam - 

olefine 

96.0 7 –day EC50: 0.34 μg/L (Frond area) MRID 47443255 

(Acceptable) 

freshwater 

Duckweed (Lemna 

gibba) In a 7-day toxicity study, the freshwater floating aquatic vascular plants Duckweed (Lemna 

gibba) were exposed to BCS-AA10201 (AE1170437-olefine; metabolite of BCS-AA10717) at 

nominal concentrations of 0 (negative control and solvent control), 0.095, 0.305, 0.977, 3.13, 

and 10.0 μg/L under static conditions. Mean-measured concentrations were <0.0515 (<lowest 

standard analyzed, controls), 0.09, 0.32, 1.08, 3.68, and 11.4 μg/L. 

The most sensitive endpoint was frond area, with NOAEC and EC50 values of 0.09 and 0.34 

μg/L, respectively. 

Inhibitions of frond area ranged from -7 to 94% as compared to the negative control. 

At test termination, there was slight necrosis observed in the 0.32 μg/L treatment level, medium 

necrosis observed in the 1.08 μg/L treatment level, strong necrosis observed in the 3.68 μg/L 

treatment level, and lethal plants in the highest treatment level. 

This study is scientifically sound and meets OPPTS 850.4400 guideline standards for a tier II 

aquatic vascular plant study. This study is classified Acceptable. 

Results Synopsis

Test Organism: Lemna gibba

Test Type (Flow-through, Static, Static Renewal): Static 

Frond number 

EC05: <0.09 μg/L 95% C.I.: N/A 

EC50: 0.41 μg/L 95% C.I.: 0.18 to 0.94 μg/L 

NOAEC: 0.09 μg/L 

Slope: 1.48 ± 0.267 

Frond number based on growth rate 

EC05: 0.24 μg/L 95% C.I.: 0.16 to 0.35 μg/L 

EC50: 0.58 μg/L 95% C.I.: 0.48 to 0.69 μg/L 

NOAEC: 0.09 μg/L 

Slope: 4.26 ± 0.523 

Frond area 

EC05: 0.021 μg/L 95% C.I.: 0.0044 to 0.1 

EC50: 0.34 μg/L 95% C.I.: 0.16 to 0.74 μg/L 

NOAEC: 0.09 μg/L 
-Page 159 of 292- 

Table C-8. Acute Toxicity (Tier II) of Indaziflam (TGAI), Metabolites, and Formulations to 

Vascular Plants Inhabiting Aquatic Environments. 

Species Chemical % a.i. EC50

Identification 

Number 

(Study 

Classification) 

Slope: 1.36 ± 0.212 

Frond area based on growth rate 

EC05: 0.17 μg/L 95% C.I.: 0.14 to 0.22 μg/L 

EC50: 0.52 μg/L 95% C.I.: 0.46 to 0.57 μg/L 

NOAEC: 0.09 μg/L 

Slope: 3.47 ± 0.204 

Endpoint(s) Affected: frond number, frond number based on growth rate, frond area, and 

frond area based on growth rate 

Indaziflam 94.5 7-day EC50: 350 ng a.i./L (Frond 

number) 

MRID 47443256 

(Supplemental) 

freshwater 

Duckweed (Lemna 

gibba) In a 7-day toxicity study, the freshwater floating aquatic vascular plants Duckweed (Lemna 

gibba) were exposed to BCS-AA10717 at nominal initial concentrations of 0 (negative and 

solvent controls), 26.8, 67.0, 167, 419, and 1,046 ng a.i./L under static conditions. Meanmeasured concentrations at day 0 were <10.39 (<lowest standard analyzed, controls), 76.2, 154, 

329, and 889 ng a.i./L; the lowest concentration was not measured because it was a test 

concentration below the study author’s NOAEC and because, according to the study author, an 

additional analysis below 67 ng/L was not needed to support the validity of the study. 

The 7-Day NOAEC and EC50 values calculated by the reviewer for frond number, the most 

sensitive endpoint, were 167 and 350 ng a.i./L, respectively. The % growth inhibition for frond 

number in the treated algal culture as compared to the negative control ranged from -13 to 99%. 

By test termination, there was slight chlorosis observed in the 167 ng a.i./L treatment level, 

medium chlorosis observed in the 419 ng a.i./L treatment level, and strong chlorosis observed 

in the highest test concentration. 

This aquatic vascular plant study with Lemna gibba is scientifically sound but was not 

conducted following OPPTS guidelines. This study is classified Supplemental. The test was 

conducted using a sediment layer as well as standard nutrient medium. 

Results Synopsis

Test Organism: Lemna gibba

Test Type (Flow-through, Static, Static Renewal): Static 

Frond number 

EC05: 150 ng a.i./L 95% C.I.: 110 to 210 ng a.i./L 

EC50: 350 ng a.i./L 95% C.I.: 300 to 390 ng a.i./L 

NOAEC: 167 ng a.i./L 

Slope: 4.64 ± 0.532 

Frond number based on growth rate near singular matrix, model unsuitable

EC05: >167 ng a.i./L 95% C.I.: N/A 

EC50: >419 ng a.i./L 95% C.I.: N/A 
-Page 160 of 292- 

Table C-8. Acute Toxicity (Tier II) of Indaziflam (TGAI), Metabolites, and Formulations to 

Vascular Plants Inhabiting Aquatic Environments. 

Species Chemical % a.i. EC50

Identification 

Number 

(Study 

Classification) 

NOAEC: 167 ng a.i./L 

Slope: Could not be determined 

Dry weight based on growth rate 

EC05: 130 ng a.i./L 95% C.I.: 81 to 220 ng a.i./L 

EC50: 440 ng a.i./L 95% C.I.: 360 to 540 ng a.i./L 

NOAEC: 167 ng a.i./L 

 Slope: 3.14 ± 0.413 

 Endpoint(s) Affected: frond number, frond number based on growth rate, and dry weight 

based on growth rate 

Indaziflam 

500 SC 

44.4% EC50 = 61 ng ai/L MRID: 47743308 

(Acceptable) 

freshwater 

Duckweed (Lemna 

gibba) In a 7 day acute toxicity study, the freshwater floating aquatic vascular plants Duckweed 

(Lemna gibba) were exposed to AE 1170437 SC 500 (AI: BCS AA 10717) at nominal 

concentrations of 0 (negative control), 12.5, 25.0, 50.0, 100, 200, and 400 ng form/L under 

static conditions. The nominal concentrations of the active ingredient BCS AA 10717 were 0 

(negative control), 5.55, 11.1, 22.2, 44.4, 88.8, and 177.7 ng ai/L. The mean-measured 

concentrations were <2.03 (<LOQ, negative control), 5.55, 11.1, 19.4, 46.1, 92.6, and 185 ng 

ai/L (the two lowest test levels were not analytically verified, so are reported as nominal 

concentrations). 

The most sensitive endpoint was yield based on frond number, with 7-Day NOAEC and EC50

values of 19.4 and 61 ng ai/L, respectively, which are equivalent to 50 and 130 ng form/L, 

respectively. The percent inhibition in the treated cultures as compared to control ranged from -

7 to 93%. 

The following abnormalities were noted: slight chlorosis, single fronds, medium necrosis, and 

strong necrosis were observed between days 2 and 7. 

This toxicity study is classified as scientifically sound and meets OPPTS 850.4400 guideline 

standards for a Tier II aquatic plant toxicity test with the freshwater species, Lemna gibba. 

This study is classified Acceptable. 

Results Synopsis

Test Organism: Lemna gibba

Test Type (Flow-through, Static, Static Renewal): Static 

 BCS AA 10717 

Frond number 

EC05: 25 ng ai/L 95% C.I.: 18 to 35 ng ai/L 

EC50: 66 ng ai/L 95% C.I.: 57 to 77 ng ai/L 

NOAEC: 19.4 ng ai/L 

Slope: 3.90 ± 0.431 
-Page 161 of 292- 

Table C-8. Acute Toxicity (Tier II) of Indaziflam (TGAI), Metabolites, and Formulations to 

Vascular Plants Inhabiting Aquatic Environments. 

Species Chemical % a.i. EC50

Identification 

Number 

(Study 

Classification) 

Growth rate, based on frond number 

EC05: 45 ng ai/L 95% C.I.: 36 to 56 ng ai/L 

EC50: 72 ng ai/L 95% C.I.: 66 to 79 ng ai/L 

NOAEC: 19.4 ng ai/L 

Slope: 7.94 ± 1.16 

Growth rate, based on frond area 

EC05: 54 ng ai/L 95% C.I.: 38 to 77 ng ai/L 

EC50: 80 ng ai/L 95% C.I.: 72 to 89 ng ai/L 

NOAEC: 46.1 ng ai/L 

Slope: 9.74 ± 2.97 

Yield, based on frond number 

EC05: 38 ng ai/L 95% C.I.: 31 to 46 ng ai/L 

EC50: 61 ng ai/L 95% C.I.: 55 to 68 ng ai/L 

NOAEC: 19.4 ng ai/L 

Slope: 7.92 ± 0.931 

Yield, based on frond area 

EC05: 38 ng ai/L 95% C.I.: 28 to 52 ng ai/L 

EC50: 63 ng ai/L 95% C.I.: 55 to 73 ng ai/L 

NOAEC: 46.1 ng ai/L 

Slope: 7.46 ± 1.30 

 Formulation 

Frond number 

EC05: 53 ng form/L 95% C.I.: 38 to 74 ng form/L 

EC50: 140 ng form/L 95% C.I.: 120 to 160 ng form/L 

NOAEC: 50 ng form/L 

Slope: 3.87 ± 0.417 

Growth rate, based on frond number 

EC05: 97 ng form/L 95% C.I.: 77 to 120 ng form/L 

EC50: 160 ng form/L 95% C.I.: 140 to 170 ng form/L 

NOAEC: 50 ng form/L 

Slope: 7.96 ± 1.16 

Growth rate, based on area 

EC05: 120 ng form/L 95% C.I.: 83 to 160 ng form/L 

EC50: 170 ng form/L 95% C.I.: 160 to 190 ng form/L 

NOAEC: 100 ng form/L 

Slope: 9.69 ± 2.88 

Yield, based on frond number 

EC05: 82 ng form/L 95% C.I.: 67 to 100 ng form/L 

EC50: 130 ng form/L 95% C.I.: 120 to 150 ng form/L 

NOAEC: 50 ng form/L 
-Page 162 of 292- 

Table C-8. Acute Toxicity (Tier II) of Indaziflam (TGAI), Metabolites, and Formulations to 

Vascular Plants Inhabiting Aquatic Environments. 

Species Chemical % a.i. EC50

Identification 

Number 

(Study 

Classification) 

Slope: 7.95 ± 0.935 

Yield, based on frond area 

EC05: 82 ng form/L 95% C.I.: 61 to 110 ng form/L 

EC50: 140 ng form/L 95% C.I.: 120 to 160 ng form/L 

NOAEC: 100 ng form/L 

Slope: 7.46 ± 1.29

Endpoint(s) Effected: Frond number, growth rate, and yield 

Table C-9. Tier III, Aquatic Plant Field Study 

Species Chemical % a.i. EC50/LC50

Identification Number 

(Study Classification) 

Multiple Indaziflam 

500 SC 

44.4% See below MRID: 47443257 

(Supplemental) 

This study was submitted to provide supplemental data for the EPA Ecological Effects Test 

Guidelines OPPTS 850.4450: Aquatic Plants Field Study, Tier III. This study is scientifically sound and 

provides useful information for risk assessment purposes regarding the toxicity of the herbicide BCS-AA10717 

to aquatic plants under simulated field conditions. It is felt that the study design has presented important 

information not obtainable under usual laboratory conditions for acute and chronic bioassay. In general, the 

reviewer’s analysis is in agreement with the study author's overall conclusions, but the reviewer has presently 

not statistically-verified the study results. 

The following are two OPPTS 850.4000 and OPPTS 850.4450 guideline deviations that affect the acceptability of the 

study: 

 

1. Guidelines require the study be conducted using three species from the family Cryptogamae (ferns and 

allies). This study used only one species from this family, Salvinia natans. 

2. The number of replicates was not large enough to assure statistically significant results at the 90-95 percent 

level of confidence, nor large enough to support the 50 percent (EC50) progression criteria statistically. 

Analysis of the water samples 4 hours following application indicated that all microcosms received the intended dose (mean 

recoveries of 102 to 139% of target). Concentrations of AE 1170437 steadily decreased throughout the study, 

and averaged 14 to 18% of nominal concentrations by day 69 (study termination). The metabolite AE 1170437-

1-hydroxyethyl [1-{4-amino-6-[(1R,2S)-2,6-dimethyl-2,3-dihydro-1H-inden-1-ylamino]-1,3,5-triazin-2-

yl}ethanol] was detected at a maximum of 2.3% of nominal in water samples (0.32 μg ai/L level on day 28 posttreatment) and the metabolite AE 1170437-olefine [N-[(1R,2S)-2,6-dimethyl-2,3-dihydro-1H-inden-1-yl]-6-

vinyl-1,3,5-triazine-2,4-diamine] was detected at a maximum of 0.35% of nominal (10 μg ai/L level on day 7 

post-treatment). 

Where statistically-significant differences between treatment and control were observed and considered to be biologically 

significant, the responses were categorized according to the following chart: 

Effect Class Definition of Effect 

------------------------------------------------------------------------------------------------------------------- 

1 Effect could not be demonstrated 

2 Slight effect (minor in duration and magnitude) 

3A Pronounced short-term effects and recovery within 8 weeks after the first application or 

total period of effects <8 weeks followed by recovery 

4 Pronounced effect but study/measurement too short to demonstrate that treatment-related 

effects last <8 weeks 

5A Clear long-term effects lasting longer than 8 weeks but full recovery observed at end of 

experiment 
-Page 163 of 292- 

Table C-9. Tier III, Aquatic Plant Field Study 

Species Chemical % a.i. EC50/LC50

Identification Number 

(Study Classification) 

5B Clear long-term effects lasting longer than 8 weeks but full recovery not observed at the 

end of the experiment 

 ------------------------------------------------------------------------------------------------------------------- 

The following table summarizes the treatment-related effects observed during the study using the effect classes noted 

above: 

 Nominal concentration μg ai/L 

 0.01 0.032 0.1 0.32 1.0 3.2 10.0 

Macrophytes (bioassays) 

Lemna trisulca 1 1 1 1 1 1 1 

Salvinia natans 1 1 1 1 3A↓ 5B↓ 5B↓

Ceratophyllum demersum 1 1 1 1 1 1 1 

Potamogeton natans 1 1 1 1 3A↓ 5B↓ 5B↓

Sagittaria sagittifolia 1 1 1 1 3A↓ 5B↓ 5B↓

Myriophyllum spicatum 1 1 1 2↓ 5B↓ 5B↓ 5B↓

Elodea nuttallii 1 1 1 2↓ 5B↓ 5B↓ 5B↓

Ranunculus circinatus 1 1 1 1 1 1 2↓

Parallel bioassay 

Lemna gibba(a) 1 3A↓(b) 4↓ 4↓ 4↓ 4↓ 4↓

Macrophytes (free-living) 

% cover total macrophytes 1 1 1 1 5B↓(c) 5B↓(c) 5B↓(c)

No. fronds Spirodela 

polyrhiza 

1 2↓ 2↓ 5B↓(c) 5B↓(c) 5B↓(c) 5B↓(c)

% cover Myriophyllum spic. 1 1 1 1 5B↓ 5B↓ 5B↓

End biomass vascular plants 1 1 1 1 1 Sign. ↓ Sign. ↓

Phytoplankton 

Taxa richness 1 1 1 1 1 1 1 

PRC community response 1 1 1 1 1 1 1 

Crucigeniella spec. 1 1 1 1 1 1 2↑

Cosmarium spec. 1 1 1 2↓ 2↓ 3A↓ 3A↓

Nitzschia spec. 1 1 1 1 1 2↑ 3↑

Chrysophyceae 1 1 1 1 1 1 2↑

Chlorophyta 1 1 1 1 1 1 2↑

Streptophyta 1 1 1 2↓ 3A↓ 3A↓ 3A↓

Chlorophyll-a biomass 1 1 1 1 1 2↑ 2↑

Zooplankton 

Taxa richness 1 1 1 1 1 1 1 

PRC community response 1 1 1 1 1 1 2 

Simocephalus vetulus 1 1 1 1 1 2↓ 2↓

Cladocera 1 1 1 1 2↓ 2↓ 3A↓

Community metabolism 

pH morning 1 1 1 1 2↓ 2↓ 2↓

pH evening(d) 1 1 1 1 2-4↓(e) 2-4↓(e) 2-4↓(e)

Alkalinity morning 1 1 1 1 2↑ 2↑ 2↑

(a) No useful information after day 14 post-treatment. 

(b) Based on assumption that recovery starts at concentrations <0.01 μg ai/L. 

(c) Trend of a long-term treatment-related decline. 

(d) Measured on days 8 and 15 post-treatment only. 

(e) Minor effect not larger than 0.5 pH units, but the duration of the effect could not be established. 

Overall, in the microcosms, macrophyte species were far more sensitive than phytoplankton and zooplankton taxa. Of the 

macrophyte species investigated, the lemnids (Lemna gibba, Spirodela polyrhiza) were the most sensitive, with 

a NOAEC of 0.01 μg ai/L. The vast majority of non-lemnid vascular plants began to exhibit clear effects at the 

1.0 μg ai/L level, and no recovery was indicated at the 3.2 and 10.0 μg ai/L levels. Vascular plants that showed 

a relatively minor growth in controls (e.g., Ceratophyllum demersum, Ranunculus circinatus, and Lemna 

trisulca) were hardly affected by the test compound. In the microcosm community, metabolism endpoints 

showed relatively minor treatment-related effects, which may be explained by the fact that certain primary 

producers (e.g., Chara) were not affected at all by the herbicide. 

8. Adequacy of the Study: The data provided are beneficial in assessing the effects of the test material on various taxa, 

primarily macrophytes; however, only two replicate microcosms (ponds) were tested for each treatment level, 
-Page 164 of 292- 

Table C-9. Tier III, Aquatic Plant Field Study 

Species Chemical % a.i. EC50/LC50

Identification Number 

(Study Classification) 

whereby limiting statistical power in assessing results on the pond community as well as on individual taxa. 

A. Classification: Supplemental 

B. Rationale: Although the study does not fully meet OPPTS 850.4450 guideline standards for a tier III field 

test with aquatic plants, it does provide valuable information regarding the expected biological effects 

(particularly to macrophytes) derived from application of the formulated product AE 1170437 (500 g/L) to 

lentic, shallow macrophyte-dominated freshwater ecosystems. 

Indaziflam 

- technical 

100% See Below MRID: 47443258 

(supplemental) 

Multiple 

Conclusions: This study is scientifically sound and provides useful preliminary/screening 

information for a subsequent in-depth field study targeting aquatic plants. 

The toxicity of AE 1170437 technical was investigated for 6 weeks following a single overlying 

water application to artificial outdoor ponds containing the following eight aquatic plant 

species: elodea (Elodea canadensis), Sago pond weed (Potamogeton pectinatus), coontail 

weed (Ceratophyllum demersum), water milfoil (Myriophyllum heterophyllum), pickerel 

weed (Pontederia cordata), water lily (Nymphaea odorata), and duckweed (Lemna gibba

and Lemna minor). Of these eight species, data collected for the duckweed (both species) 

and coontail weed were insufficient to clearly assess the toxicological effects of 

application. For the remaining five species, the NOAEC values are summarized below: 

NOAEC (μg/L) Species Symptomology(a) Dry Weight Biomass(b)

Elodea 3.2 3.2 

Sago pond weed 3.2 3.2 

Water milfoil 0.32 0.32 

Pickerel weed 3.2 3.2 

Water lily <0.32 0.32 

(a) Based on visual observations. 

(a) Based on Dunnett’s Test. 

The water lily (Nymphaea odorata) was the most sensitive species, exhibiting red spotting of the 

(old growth) leaves, chlorotic leaves, and/or curled leaves at all treatment levels. The 

resultant NOAEC for symptomology was <0.32 μg/L. Recovery (in the form of new 

healthy leaf growth) was observed for this species at the 0.32 and 1.0 μg/L levels 

beginning on days 14 and 28 post-treatment, respectively. Terminal (day 42) dry weight 

biomass was also statistically-reduced compared to the control at the 1.0 and 3.2 μg/L 

levels. 

Water milfoil (Myriophyllum heterophyllum) was the next most sensitive species, and the only 

other species affected by treatment under the conditions of the study. Necrotic leaves 

developed during the second half of the post-observation period at the 1.0 and 3.2 μg/L 

levels, resulting in a NOAEC for symptomology of 0.32 μg/L. Terminal (day 42) dry 

weight biomass was also statistically-reduced compared to the control at the 1.0 and 3.2 

μg/L levels. 

Elodea, sago pondweed, and pickerel weed were all unaffected by treatment, with NOAEC values 

of 3.2 μg/L for symptomology and dry weight biomass. 

8. Adequacy of the Study: 
-Page 165 of 292- 

Table C-9. Tier III, Aquatic Plant Field Study 

Species Chemical % a.i. EC50/LC50

Identification Number 

(Study Classification) 

A. Classification: Supplemental 

B. Rationale: The study provides useful preliminary/screening information for a 

subsequent in-depth field study targeting aquatic plants. Though the study was not 

intended to meet any current U.S. EPA guideline, it does provide useful preliminary 

information regarding the expected biological effects derived from a single application of 

technical-grade BCS-AA10717 to lentic, shallow macrophyte-dominated freshwater 

ecosystems. 

Toxicity to Terrestrial Animals 

Birds, Acute and Subacute 

Table C-10. Acute Oral Toxicity of Technical Grade Indaziflam (TGAI) to Birds. 

Species Chemical % a.i. LD50

Toxicity 

Category 

Identification 

Number 

(Study 

Classification) 

Indaziflam 94.5 14-day LD50: >2000 mg ai/kg bw Practically 

non-toxic 

MRID 47443240 

(Acceptable) 

Bobwhite 

quail (Colinus 

virginianus) The acute oral toxicity of BCS-AA10717 (containing 90.3% AE 1170437) to 16-week old Northern 

bobwhite quail (Colinus virginianus) was assessed over 14 days. BCS-AA10717 was administered to 

the birds via gelatine capsule at nominal levels of 0 (control), 500, 1000, and 2000 mg ai/kg bw. The 

14-day acute oral LD50 was >2000 mg ai/kg bw. The 14-day NOAEL was 2000 mg ai/kg bw, as no 

treatment-related effects were observed upon any parameter. BCS-AA10717 (containing 90.3% AE 

1170437) would be classified as practically non-toxic to young adult Northern bobwhite quail 

(Colinus virginianus) in accordance with the classification system of the U.S. EPA. 

This toxicity study is scientifically sound and fully meets OPPTS 850.2100 guideline standards for an 

acute oral toxicity study with Northern bobwhite quail. This study is classified Acceptable. 

Results Synopsis

Test Organism Size/Age at study initiation (Mean Weight): 16-weeks old; 191 to 202 g 

(combined sexes) 

LD50: >2000 mg ai/kg bw 95% C.I.: N/A 

Probit slope: N/A 95% C.I.: N/A 

NOAEL: 2000 mg ai/kg bw 

Endpoint(s) Affected: none 

Indaziflam 94.5% 14-day LD50: >2000 mg ai/kg bw Practicall nontoxic 

MRID 

47743306 

(Acceptable) 

Zebra Finch 

(Poephgila 

guttata) 

The acute oral toxicity of BCS-AA10717 to zebra finch (Poephila gutta) was assessed over 14 days 
-Page 166 of 292- 

Table C-10. Acute Oral Toxicity of Technical Grade Indaziflam (TGAI) to Birds. 

Species Chemical % a.i. LD50

Toxicity 

Category 

Identification 

Number 

(Study 

Classification) 

with a limit test at 2000 mg/kg bw. BCS-AA10717 was administered to the birds via gavage dosing 

at the nominal concentrations of 0 (control) and 2,000 mg a.i./kg bw. Control and treatment groups 

were comprised of 10 birds each, 5 males and 5 females. The 14-day acute oral LD50 was >2000 mg 

ai/kg bw. One mortality did occur and gross necropsy demonstrated that the bird’s death was related 

to intestinal and respiratory problems. There is insufficient evidence to determine whether or not this 

mortality and/or intestinal and respiratory problems were treatment-related. Observed clinical signs 

of toxicity in the treatment group included slightly ruffled to ruffled appearance, reduced reaction to 

stimuli (i.e. sound and movement), wing droop, and lethargy. BCS-AA10717 would be classified as 

practically non-toxic to adult zebra finch (Poephila gutta) in accordance with the classification 

system of the U.S. EPA. 

The resulting LD50 for this study is >2000 mg a.i./kg-bw. 

This toxicity study is scientifically sound and meets OPPTS 850.2100 guideline standards for an 

acute oral toxicity study with zebra finch. This study is classified Acceptable. 
-Page 167 of 292- 

Table C-11. Acute Dietary Toxicity of Technical Grade Indaziflam (TGAI) to Birds. 

Species Chemical % a.i. LC50

Toxicity 

Category 

Identification 

Number 

(Study 

Classification)

Indaziflam 94.5 8-day LC50: >5007 mg ai/kg diet Practically 

nontoxic 

MRID 

47443241 

(Acceptable) 

Bobwhite quail 

(Colinus 

virginianus) 

The acute dietary toxicity of BCS-AA10717 (containing 90.3% AE 1170437) to 10-day old 

northern bobwhite quail (Colinus virginianus) was assessed over 8 days. BCS-AA10717 was 

administered to the birds in the diet at nominal concentrations of 0 (negative control), 313, 625, 

1250, 2500, and 5000 mg ai/kg diet. Mean-measured concentrations were <5.00 (<LOQ, control), 

324, 572, 1234, 2545, and 5007 mg ai/kg diet, respectively. The 8-day acute dietary LC50 was 

>5007 mg ai/kg diet. Based on a lack of treatment-related mortality, clinical signs of toxicity, 

effects on body weight or food consumption, or gross pathological changes, the 8-day NOAEC 

was 5007 mg ai/kg diet. BCS-AA10717 is classified practically non-toxic to juvenile bobwhite 

quail (Colinus virginianus) in accordance with the classification system of the U.S. EPA.

This toxicity study is scientifically sound and fully meets OPPTS 850.2200 guideline standards 

for an acute dietary toxicity study for the Northern bobwhite quail. This study is classified 

Acceptable. 

Results Synopsis

Test organism age; Mean weight at study initiation: 10-days old; 22.5 to 29.1 g 

LC50: >5007 mg ai/kg diet 95% C.I.: N/A 

Probit Slope: N/A 95% C.I.: N/A 

NOAEC: 5007 mg ai/kg diet 

LOAEC: >5007 mg ai/kg diet 

Endpoints affected: none 

Indaziflam 94.5 8-day LC50: >5215 mg ai/kg diet Practically 

nontoxic 

MRID 

47443242 

(Acceptable) 

Mallard duck 

(Anas 

platyrhynchos) 

The acute dietary toxicity of BCS-AA10717 (containing 90.3% AE 1170437) to 8-day old 

mallard ducklings (Anas platyrhynchos) was assessed over 8 days. BCS-AA10717 was 

administered to the birds in the diet at nominal concentrations of 0 (negative control), 313, 625, 

1250, 2500, and 5000 mg ai/kg diet. Mean-measured concentrations were <5.00 (<LOQ, control), 

329, 647, 1320, 2518, and 5125 mg ai/kg diet, respectively. The 8-day acute dietary LC50 was 

>5215 mg ai/kg diet. Based upon (apparent transient) treatment-related reductions in body weight 

and food consumption at the 5125 mg ai/kg diet level, the 8-day NOAEC was 2518 mg ai/kg diet. 

BCS-AA10717 (containing 90.3% AE 1170437) would be classified practically non-toxic to 

juvenile mallard duck (Anas platyrhynchos) in accordance with the classification system of the 

U.S. EPA. 

 

No treatment-related mortality, clinical signs of toxicity, or post-mortem gross lesions or unusual 

observations were observed at any treatment level. On Days 5 and 8, the mean body weights of 

birds from the 5215 mg ai/kg diet level (191.6 and 266.4 g, respectively) were statisticallyreduced (p<0.05) compared to the control (237.4 and 306.8 g, respectively). The body weight 
-Page 168 of 292- 

Table C-11. Acute Dietary Toxicity of Technical Grade Indaziflam (TGAI) to Birds. 

Species Chemical % a.i. LC50

Toxicity 

Category 

Identification 

Number 

(Study 

Classification)

change during the exposure period (Days 0-5) was also statistically-reduced compared to the 

control at the 5215 mg ai/kg diet level (70.1 versus 114.7 g for the control). 

Based upon visual observation of the feed consumption data, an apparent treatment-related 

reduction was indicated during the first 3 days of exposure at the 5215 mg ai/kg diet level. 

During the first 3 days of exposure, feed consumption was 28.8, 30.1, and 39.9 g, respectively, for 

the control group and 16.5, 23.9, and 34.7 g, respectively, for the 5215 mg ai/kg diet level. 

Thereafter, feed consumption at this level was comparable to or exceeded control consumption. 

The study authors reported that the effect on body weight and feed consumption at the 5215 mg 

ai/kg diet level may be recoverable since body weight gain and food consumption were slightly 

higher (although not statistically significant) once the birds were offered untreated food in the 

recovery phase. 

This toxicity study is classified scientifically sound and meets OPPTS 850.2200 guideline 

standards for an acute dietary toxicity study for the mallard duck. This study is classified 

Acceptable. 

Birds, Chronic 

Table C-12. Chronic Toxicity of Technical Grade Indaziflam (TGAI) to Birds. 

Species Chemical % a.i. NOAEC 

Identification 

Number 

(Study 

Classification)

Indaziflam 94.5 23-wk NOAEC: 1023 mg ai/kg diet (meanmeasured) 

Endpoint(s) affected: none 

MRID 

47443243 

(Acceptable) 

Northern 

bobwhite quail 

(Colinus 

virginianus) The one-generation reproductive toxicity of BCS-AA10717 (containing 90.3% AE 1170437) to 

18 pairs per level of 16-week old Northern bobwhite quail (Colinus virginianus) was assessed 

over ca. 23 weeks. BCS-AA10717 was administered to the birds in the diet at nominal 

concentrations of 0 (control), 250, 500, or 1000 mg as/kg diet (corrected for the total purity of the 

test substance, i.e., 94.5%). Mean-measured concentrations (of AE 1170437) were <5.00 

(<LOQ, control), 252, 524, and 1023 mg ai/kg diet, respectively. 

This study is scientifically sound and meets OPPTS 850.2300 guideline standards for an avian 

reproductive toxicity study involving northern bobwhite quail (Colinus virginianus). No 

treatment-related effects were observed on any adult or offspring parameter at any concentration 

level. This study is classified Acceptable. 

Results Synopsis

Test Organism Size/Age (weight range): 16 weeks old; 169-215 g (combined sexes) 
-Page 169 of 292- 

Table C-12. Chronic Toxicity of Technical Grade Indaziflam (TGAI) to Birds. 

Species Chemical % a.i. NOAEC 

Identification 

Number 

(Study 

Classification)

NOAEC: 1023 mg ai/kg diet (mean-measured) 

LOAEC: >1023 mg ai/kg diet (mean-measured) 

Endpoint(s) Affected: none 

Indaziflam 94.5 NOAEC: < 95 mg ai/kg diet (meanmeasured) 

Endpoint(s) affected: female weight gain and 

mean food consumption 

MRID 

47443244 

(Supplemental) 

Mallard duck 

(Anas 

platyrhynchos) 

In a primary study, the one-generation reproductive toxicity of BCS-AA10717 (containing 90.3% 

AE 1170437) to 15 pairs per level of 16-week old mallard duck (Anas platyrhynchos) was 

assessed over ca. 22 weeks. BCS-AA10717 was administered to the birds in the diet at nominal 

concentrations of 0 (control), 100, 320, and 1000 mg as/kg diet (corrected for the total purity of 

the test substance, i.e., 94.5%). Mean-measured concentrations (of the active component AE 

1170437) were <5.00 (<LOQ, control), 95, 334, and 1015 mg ai/kg diet, respectively. 

To clarify and reinforce conclusions drawn during the original study, a 19-week supplemental 

study was conducted using 15 pairs per level of 17-week old mallard duck (Anas platyrhynchos). 

BCS-AA10717 was administered to the birds in the diet at nominal concentrations of 0 (control), 

50, 150, and 450 mg as/kg diet during the final 6 weeks of the study (egg-laying phase), when the 

mallard were 33 weeks old. Mean-measured concentrations (of AE 1170437) were <5.00 

(<LOQ, control), 44, 157, and 468 mg ai/kg diet, respectively. 

The reviewer’s analyses detected statistically significant reductions in adult food consumption 

and female body weight gain at the two lower treatment levels during the primary study. For 

adult food consumption, the percent reduction in means from the control was 15% for the 95 mg 

a.i./kg treatment level and 10% for the 334 mg a.i./kg treatment level. These percent reductions 

in means were found to be statistically significant at exact p = 0.041 and p = 0.051 levels, 

respectively. For female body weight gain, the percent reduction in means was 36% for the 95 

mg a.i./kg treatment level and 29% for the 334 mg a.i./kg treatment level. These percent 

reductions in means were found to be statistically significant at exact p = 0.01 and p = 0.04 

levels, respectively. Furthermore, the reviewer believes the highest treatment group to be of 

biological significance, with a mean percent reduction of 20%. Although not detected to be 

statistically different, the reviewer believes the mean male weight gain in the 1015 mg a.i./kg 

treatment group to be of biological significance. Male birds in the highest treatment level gained 

on average 80% less than control birds, a difference of a 10.5 g weight gain and a 51.7 g weight 

gain, respectively. The reviewer determined the LOAEC and NOAEC for mean food 

consumption and female body weight gain to be 95 mg ai/kg and <95 mg ai/kg, respectively. 

And the LOAEC and NOAEC for male weight gain to be 1015 mg ai/kg and 334 mg ai/kg, 

respectively. These results differ from the study authors’ results for mean food consumption. 

For the secondary study, the reviewer’s analysis determined that effects to male weight gain and 

female weight gain were biologically significant, although these effects were not detected to be 

statistically significant. For male weight gain, results show that all male birds, including the 

control lost weight. The results of mean weight gain for the control, 44, 157, 468 mg a.i./kg 

treatment groups were -15.9, -35.3 (-121%), -46.1(-189), and -57.1 (-259) grams, respectively. 

The number in parenthesis is the respective percent reduction in treatment level mean vs. control 

mean. Birds in the lowest treatment level lost twice as much weight as the control, while the 
-Page 170 of 292- 

Table C-12. Chronic Toxicity of Technical Grade Indaziflam (TGAI) to Birds. 

Species Chemical % a.i. NOAEC 

Identification 

Number 

(Study 

Classification)

birds in the middle treatment group lost 3 times as much weight as the control, and birds in the 

highest treatment group lost 4 times as much weight as the control. The reviewer determined the 

LOAEC and NOAEC to be 44 and <44 mg a.i./kg, respectively. The results of female mean 

weight gain for the control, 44, 157, 468 mg a.i./kg treatment groups were 202, 208 (-3.1), 173 

(15%), 170 (16%) grams, respectively. Again, the number in parenthesis is the respective percent 

reduction in treatment level mean vs. control mean. The reviewer determined the LOAEC and 

NOAEC to 157 and 44 mg a.i./kg, respectively. 

The NOAEC from the primary study is < 95 mg ai/kg diet based on female weight gain and adult 

food consumption. The NOAEC from the modified secondary study is < 44 mg ai/kg diet based 

on male weight gain. The primary study is scientifically sound but does not meet OPPTS 

850.2300 guideline standards for an avian reproduction test because a definitive NOAEC could 

not determined. This study is classified Supplemental. 

The secondary study is scientifically sound but does not meet OPPTS 850.2300 guideline 

standards for an avian reproduction test because birds were treated for 6 weeks with the test 

substance, instead of the guideline recommended 18 or more weeks. The secondary study is 

considered to be supplemental data and supports the NOAEC determination in the first study. 

Results Synopsis

Test Organism Size/Age (mean Weight): 

Primary study: 16 weeks old; 881-1287 g (combined sexes) 

Supplemental study: 17 weeks old; 917-1316 g (combined sexes) 

NOAEC: < 95 mg ai/kg diet (mean-measured) 

LOAEC: 95 mg ai/kg diet (mean-measured) 

Endpoint(s) Affected: female weight gain and mean food consumption 

Mammals, Acute 

Table C-13. Acute Toxicity of Technical Grade Indaziflam (TGAI) to Mammals. 

Species Chemical % a.i. LD50 

Identification 

Number 

(Study 

Classification)

Indaziflam 94.8 LD50 > 2000 mg a.i./kg bw MRID 

47443280 

(Acceptable) 

Wistar HsdCpb: 

Wu rats 

In an acute oral toxicity study, two groups of three female Wistar HsdCpb: Wu rats were given a 

single oral dose of 2000 mg a.i./kg bw of indaziflam technical after being fasted for 

approximately 16-24 hours. The test animals were monitored for mortality and clinical signs 

several times on the day of administration and subsequently at least once daily for a 2-week postobservation period. body weights were recorded on days 1, 8, and 15. On dat 15, surviving 

animals were sacrificed, necropsied and examined for gross pathological changes. Because no 
-Page 171 of 292- 

Table C-13. Acute Toxicity of Technical Grade Indaziflam (TGAI) to Mammals. 

Species Chemical % a.i. LD50 

Identification 

Number 

(Study 

Classification)

deaths and no clinical signs occurred in the first group, the same procedure was repeated with the 

same limit dose level. 

All animals survived and gained weight during rthe study. no clinical signs or gross pathological 

findins were observed. 

Oral LD50 > 2000 mg a.i./kg bw

Indaziflam 95.7 LD50 > 2000 mg a.i./kg bw MRID 47443281 

(Acceptable) 

Wistar Rats 

EXECUTIVE SUMMARY: This study was performed to assess the acute oral 

toxicity to Wistar rats of AE 1170437 (also referenced to as BCS AA-10717), a 

technical grade formulation with a total isomer purity of 95.7%. The test 

compound was formulated in tap water with the aid of 2% Cremophor EL; the 

administration volume was 10 ml/kg body weight. 

Dose (mg/kg 

bw) 

Toxicological 

Result* 

Occurrence of 

Signs 

Time of 

Death 

Mortality 

(%) 

Females 

2000 0 / 0 / 3 – – 0 

(2nd) 2000 1 / 1 / 3 4d 4d 33 

*number of animals which died spontaneously and/or were sacrificed in 

moribund state / number of animals with signs of toxicity / total number of 

animals used per group 

3FL 

Herbicide 

Granule 

0.05 

(indaziflam) 

LD50 > 2000 mg/kg bw MRID 

47489202 

(Acceptable) 

SpragueDawley Rats 

In an acute oral toxicity study, five fasted , young adult female Sprague-Dawley rats were 

given a single dose of 3FL Herbicde Granule at a limit dose of 2000 mg/kg bw by gavage 

and observed for 14 days. Initially, one animal received the 2000 mg/kg dose. Due to 

absence of mortality, four additional females received the same dose level. 

All animals survived and gained weight. No clinical signs oftoxicity were observed. no 

gross abnormalities were noted at necropsy. 

LD50 (males and females) > 2000 mg/kg bw 

Lawn 3FL 

herbicide 

concentrate 

0.25 a.i. 

indaziflam 

LD50 > 2000 mg/kg bw MRID 

47489302 

(Acceptable) 

SpragueDawley Rats 

In an acute oral toxicity study, young adult Sprague-dawley rats were given a single oral dose of 

Lawn 3FL Herbicide concentrate. Following the Up and Down Procedure, an initial limit dose 
-Page 172 of 292- 

Table C-13. Acute Toxicity of Technical Grade Indaziflam (TGAI) to Mammals. 

Species Chemical % a.i. LD50 

Identification 

Number 

(Study 

Classification)

of 2000 mg/kg bw of the test material was administered to one female rat by oral gavage. Due to 

the absence of mortality in this animal, four additional females sequentially received the same 

dose level. Since these animals survived, no additional animals were tested. 

All animals survived, gained body weight, and appeared active and healthy during the study. 

There were no signs of gross toxicity, adverse pharmoacologuc effects, or abnormal behavior. 

No gross abnormalities were noted for any of the animals necropsied at the conclusion of the 14-

day observation period. 

Oral LD50 > 2000 mg/kg bw 

BSCAA10717 

20 WSP 

20.0% LD50 > 2000 mg/kg bw MRID 4748802 

(Acceptable) 

Wistar HsdCpb: 

Wu rats 

In an acute oral toxicity study, two groups of three female Wistar HsdCpb: Wu rats were given a 

single oral dose of 2000 mg/lg bw of BCS-AA10717 20 WSP after being fasted for 

approximately 16-24 hours. Because no deather and no clinical signs occurred in the first group, 

the same procedure was repeated with the same limit dose level. 

All animals surivived and gained weight during the study. No clinical signs or gross 

pathological findings were observed. 

Oral LD50 > 2000 mg/kg bw 

BCSAA10717 

2% MUP 

2.0% Oral LD50 > 5000 mg/kg bw MRID 47488702 

(Acceptable) 

SpragueDawley Rats 

In an acute otal toxicity study, 3 young adult female rats were given a sinlge oral dose of BCSAA10717 5% MUP (not 2%) by gavage at a single limit dose of 5000 mg/kg. Initially, a single 

test animals was dose at 5000 mg/kg; due to this test animal surviving an additional 2 test 

animals were dosed at 5000 mg/kg. Individual body weights were recorded prior to dosing 

(study day 0) and again on study days 7 and 14 post-dosing. The test animals were observed for 

mortality, clinical signs of toxicity and behavioral changes during the first several hours postdosing and at least once daily thereafter for the remainder of the 14 day study period. 

All 3/3 test animals dosed at 5000 mg/kg survived and gained weight throughout the study 

period. Post-dosing, 2/3 test animals were hypoactive; however, these test animals recovered by 

the end of study day 1 and along with the remaining test animals, appeared active and healthy for 

the remainder of the study. No gross internal findings were observed at necropsy. 

Oral LD50 > 5000 mg/kg bw 
-Page 173 of 292- 

Mammals, chronic 

Table C-14. Chronic Toxicity of Technical Grade Indaziflam (TGAI) to Rats 

Species Chemical % a.i. NOAEC/LOAEC 

Identification 

Number 

(Study 

Classification) 

Indaziflam 94.5 NOAEC: 69 mg a.i./kg diet 

LOAEC: 317 mg a.i./kg diet 

NOAEC: Based on parental, offspring, and 

reproductive toxicity endpoints 

LOAEC: Based on offspring and reproductive 

toxicity endpoints 

MRID 

47443293 

(Acceptable) 

Laboratory 

Rat 

(Rattus 

norvegicus) 

In a two-generation reproduction toxicity study, indaziflam was administered 

continuously in the diet to 30 Wistar rats/sex/dose group for two consecutive 

generations. The P generation animals were fed dietary levels of 0, 150, 1000, or 

8000 ppm beginning 10 weeks prior to mating to produce the F1 litters. F1 

offspring (30/sex/dose group) selected to be parents of the next generation were 

initially fed the same test diet concentrations as their parents. However, due to 

severe toxicity in the F1 offspring after weaning but before mating for the next 

generation (age range was 26-38 days old), the high dose of 8,000 ppm was 

reduced to 4,000 ppm. The average daily intake of test material during premating 

for P and F1 animals was 0, 10.4, 69.3 or 560.1 (P)/317.6 (F1) mg/kg/day in males 

and 0, 12.9, 85.2 or 656.2 (P)/355.2 (F1) mg/kg/day in females (note: at high 

dose, P and F1 intakes are given separately rather than averaged due to lowering 

of the dose to 4000 ppm). F1 parents were fed the test diets for approximately six 

weeks prior to mating to produce the F2 generation, and the F2 pups were 

maintained after weaning for evaluation of sexual maturation. 

Parental Toxicity

NOAEC: 69/85 mg a.i./kg diet 

LOAEC: 560/656 mg a.i./kg diet 

Based on coarse tremors in females, decreased body weights, body weight gains, 

food consumption in both sexes, and effects on kidneys 

This study is classified as acceptable/guideline and satisfies the guideline 

requirements (OPPTS 870.3800; OECD 416) for a two-generation reproduction 

study in the rat. 

Offspring Toxicity

NOAEC: 69/85 mg a.i./kg diet 

LOAEC: 317/355 mg a.i./kg diet 

Based on clinical signs of toxicity, decreased body weights, body weight gains, 

and secondary delays in sexual maturation. 
-Page 174 of 292- 

Table C-14. Chronic Toxicity of Technical Grade Indaziflam (TGAI) to Rats 

Species Chemical % a.i. NOAEC/LOAEC 

Identification 

Number 

(Study 

Classification) 

Reproductive Toxicity

NOAEC: 69/85 mg a.i./kg diet 

LOAEC: 317/355 mg a.i./kg diet 

Based on delayed sexual maturation in F1 and F2 pups. 

 

Terrestrial Insects, Acute Contact 

Table C-15. Acute Toxicity of Technical Grade Indaziflam (TGAI) to Honey Bees. 

Species Chemical % a.i. LD50/LC50 

Toxicity 

Category 

Identification 

Number 

(Study 

Classification)

Indaziflam 94.5 48-h LD50: >100 μg a.i./bee 

(contact) 

Practically 

nontoxic 

MRID 

47443245 

(Acceptable) 

Honey bee 

(Apis mellifera) 

The honey bee, Apis mellifera L., was exposed to BCS-AA10717 technical 

(Indaziflam) in the acute contact test. The nominal concentration was 100 μg ai/bee, and no 

mortalities occurred during the 48 hour exposure in the contact toxicity test. The LD50 value 

for the contact test was >100 μg ai/bee. As a result, BCS-AA10717 technical (Indaziflam) 

is categorized as practically non-toxic to honey bees on an acute contact basis. The NOAEL 

for the contact test was 100 μg ai/bee. The study also provided supplemental information on 

acute oral toxicity of the honey bee to BCS-AA10717 technical (Indaziflam). The oral toxicity 

test was conducted for 48 hours at a nominal concentration of 120 μg ai/bee. The actual intake 

concentrations of AE 1170437 technical in the oral toxicity test was 120 μg ai/bee. No 

mortalities occurred during the 48 hour exposure in the oral test. The LC50 value for the oral test

was >120 μg ai/bee. The NOAEC for the oral toxicity test was 120 μg ai/bee. 

This study is scientifically sound and meets OPPTS 850.3020 guideline standards for an acute 

contact toxicity test with honey bees. This study is classified ACCEPTABLE. 

Results - Contact Test:

LD50: >100 μg ai/bee 95% C.I.: N/A 

NOAEL: 100 μg ai/bee Probit Slope: N/A

LOAEL: >100 μg ai/bee

Results - Oral Test: 

LC50: >120 μg ai/bee 95% C.I.: N/A 

NOAEC: 120 μg ai/bee Probit Slope: N/A

LOAEC: >120 μg ai/bee

Honey bee 

(Apis mellifera) 

BCS-AA10717 

SC 500 

514 g/L LC50: >100 μg ai/bee (contact) Practicall 

non-toxic 

MRID 

47743307 

(Acceptable) 
-Page 175 of 292- 

Table C-15. Acute Toxicity of Technical Grade Indaziflam (TGAI) to Honey Bees. 

Species Chemical % a.i. LD50/LC50 

Toxicity 

Category 

Identification 

Number 

(Study 

Classification)

The honey bee, Apis mellifera carnica P., was exposed to AE 1170437 SC 500 (AI: Indaziflam) 

for 48 hours in the oral and the contact test. The oral and contact nominal concentrations were 0 

(negative control) and 120.0 μg a.i./bee (oral) and 0 (negative control) and 100 μg ai/bee 

(contact). 

The actual intake concentration of Indaziflam in the oral toxicity test was 119.7 μg ai/bee. By 

48 hours in the oral test, mortality was 0%. There were no sublethal effects in the control or 

treated groups. By 48 hours in the contact test, mortality was 1.7% (one bee died). There were 

no sublethal effects in the controls or treated group. The LC50 value for the oral test was 

>119.7 μg ai/bee. The LD50 value for the contact test was >100 μg ai/bee. As a result, AE 

1170437 SC 500 (AI: Indaziflam) is categorized as practically nontoxic to honey bees on an 

acute contact basis. The NOAELs for the oral and contact tests were 119.7 and 100 μg ai/bee, 

respectively. 

This study is scientifically sound and meets OPPTS 850.3020 guideline standards for an acute 

contact toxicity test with honey bees. 

Reported Statistical Results - Oral Test:

LC50: >119.7 μg ai/bee 95% C.I.: N/A 

NOAEL: 119.7 μg ai/bee Probit Slope: N/A

LOAEL: >119.7 μg ai/bee

Reported Statistical Results - Contact Test:

LD50: >100 μg ai/bee 95% C.I.: N/A 

NOAEL: 100 μg ai/bee Probit Slope: N/A

LOAEL: >100 μg ai/bee

Earthworms, Acute Toxicity 

Table C-16. Acute and Chronic Toxicity of Technical Grade Indaziflam (TGAI) to 

Earthworms. 

Species Chemical 

% 

a.i. LC50

Identification 

Number 

(Study 

Classification) 

Indaziflam 94.5 14-d LC50: >1000 mg ai/kg dw soil 

14-d NOAEC: 316 mg ai/kg dw soil 

(Percent body weight change) 

MRID 47443269 

(Supplemental) 

Earthworm 

(Eisenia 

fetida 

andrei) In an acute toxicity study, earthworms (Eisenia fetida andrei) were exposed to BCS-AA10717 

(Indaziflam) at 0 (control), 100, 178, 316, 562 and 1000 mg ai/kg dw of soil. As a reference, worms 

were additionally exposed to Chloroacetamide A.R. at nominal concentrations of 5.6, 10, 18, 24 and 

32 mg a.i./kg dw of soil. The 14-day LC50 for the test material, BCS-AA10717, was >1000 mg ai/kg 

dw of soil. The EC50 was >1000 mg ai/kg dw of soil. The NOAEC and LOAEC values, based on % 
-Page 176 of 292- 

Table C-16. Acute and Chronic Toxicity of Technical Grade Indaziflam (TGAI) to 

Earthworms. 

Species Chemical 

% 

a.i. LC50

Identification 

Number 

(Study 

Classification) 

body weight change, were 316 and 562 mg ai/kg dw of soil, respectively. The active ingredient is 

considered to be non-toxic to earthworms up to a concentration of 316 mg ai/kg dw of soil. 

After 14 days of exposure, mean mortality did not exceed 3% in the control or any of the treatment 

groups. Percent body weight loss averaged 5.9% in the negative control and ranged from 8.2 to 

15.6% in the treatment levels. 

This study is scientifically sound but was not conducted following any OPPTS guidelines. This 

study is classified Supplemental. 

14-d EC50: >1000 mg ai/kg dw soil 95% C.I.: N/A 

14-d LC50: >1000 mg ai/kg dw soil 95% C.I.: N/A 

14-d NOAEC: 316 mg ai/kg dw soil 

Probit Slope: N/A 95% 

C.I.: N/A 

Endpoint(s) Affected: Percent body weight change
-Page 177 of 292- 

Table C-16. Acute and Chronic Toxicity of Technical Grade Indaziflam (TGAI) to 

Earthworms. 

Species Chemical 

% 

a.i. LC50

Identification 

Number 

(Study 

Classification) 

Fluoroethyldiaminotriazine 99.3 LC50: >1000 mg ai/kg dw soil 

 

MRID 47743312 

(Supplemental) 

Earthworms 

(Eisenia 

fetida) In a 14-day acute toxicity study, earthworms (Eisenia fetida) were exposed to AE 1170437-

diaminotriazine at 0 (negative control), 62.5, 125, 250, 500, and 1000 mg ai/kg dry weight of 

artificial substrate. The reference chemical used was Chloroacetamide A.R. at 5.6 to 32 mg ai/kg dw 

soil. The LC50 for the reference chemical was 11.1 mg ai/kg dw of soil. 

The LC50 and EC50 values in the study were >1000 mg ai/kg dw soil. The NOAEC, based on body 

weight change from day 0 to day 14 within each treatment level, was 500 mg ai/kg dw soil. The 

LOAEC, based on body weight change was 1000 mg ai/kg dw soil. The active ingredient is 

considered to be toxic to earthworms at and above a concentration of 1000 mg ai/kg dw soil. 

There were no compound related toxic effects. 

This study is scientifically sound but was not conducted following any OPPTS guidelines. This 

study is classified Supplemental. No mortality occurred during the 14-day study. TheLC50 value 

was >1000 mg ai/kg dw soil. Body weight alteration was affected in the highest test level, body 

weight reduction from day 0 to day 14, yielding NOAEC and EC50 values of 500 and >1000 mg ai/kg 

dw soil, respectively.

Results Synopsis

Test Organism Size/Age(Mean Wt): 380 mg; Adult (more than 2 months old)

LC50: >1000 mg ai/kg dw soil 95% C.I.: N/A 

EC50: >1000 mg ai/kg dw soil 95% C.I.: N/A 

NOAEC: 500 mg ai/kg dw soil 

Probit Slope: N/A 95% C.I.: N/A 

Endpoint(s) Affected: % weight change 

Triazineindanone 96.1 LC50: >1000 mg ai/kg dw soil MRID 47743313 

(Supplemental) 

Earthworms 

(Eisenia 

fetida) In a 14-day acute toxicity study, earthworms (Eisenia fetida) were exposed to AE 1170437-triazineindanone at 0 (negative control), 10, 32, 100, 316, and 1000 mg ai/kg dry weight of artificial 

substrate. The reference chemical used was Chloroacetamide A.R. at 5.6, 10, 18, 24, and 32 mg ai/kg 

dw soil. The LC50 for the reference chemical was 11.1 mg ai/kg dw of soil, which was within the 

acceptable concentration range determined by international ring studies. 

The LC50 and EC50 values in the study were >1000 mg ai/kg dw soil. No mortality occurred during 

the 14-day study. The NOAEC, based on body weight change, i.e. reduction, was 316 mg ai/kg dw 

soil. The LOAEC, based on body weight change was 1000 mg ai/kg dw soil. The active ingredient 

is considered to be toxic to earthworms at and above a concentration of 1000 mg ai/kg dw soil. 
-Page 178 of 292- 

Table C-16. Acute and Chronic Toxicity of Technical Grade Indaziflam (TGAI) to 

Earthworms. 

Species Chemical 

% 

a.i. LC50

Identification 

Number 

(Study 

Classification) 

There were no compound related toxic effects. 

This study is scientifically sound but was not conducted following any OPPTS guidelines. This 

study is classified Supplemental. 

Results Synopsis

Test Organism Size;Age(Mean Wt at study initiation): 354 mg; Adult (more than 2 months 

old)

LC50: >1000 mg ai/kg dw soil 95% C.I.: N/A 

EC50: >1000 mg ai/kg dw soil 95% C.I.: N/A 

LOAEC: 1000 mg ai/kg dw soil 

NOAEC: 316 mg ai/kg dw soil (based on weight reduction) 

Probit Slope: N/A 95% C.I.: N/A 

 Endpoint(s) Affected: Weight reduction
-Page 179 of 292- 

Table C-16. Acute and Chronic Toxicity of Technical Grade Indaziflam (TGAI) to 

Earthworms. 

Species Chemical 

% 

a.i. LC50

Identification 

Number 

(Study 

Classification) 

Indaziflam-carboxylic 

acid 

96.5 LC50: >1000 mg ai/kg dw soil MRID 47743314 

(Supplemental) 

Earthworms 

(Eisenia 

fetida) In a 14-day acute toxicity study, earthworms (Eisenia fetida andrei) were exposed to AE 1170437-

carboxylic acid at 0 (negative control), 62.5, 125, 250, 500, and 1000 mg ai/kg dry weight of 

artificial substrate. The reference chemical used was Chloroacetamide A.R. at 5.6, 10, 18, 24, and 32 

mg ai/kg dw soil. The LC50 for the reference chemical was 11.1 mg ai/kg dw of soil, which was 

within the acceptable concentration range determined by international ring studies. 

The LC50 and EC50 values in the study were >1000 mg ai/kg dw soil. No mortality occurred during 

the 14-day study and no endpoints were affected. The overall NOAEC was 1000 mg ai/kg dw soil. 

The LOAEC, based on body weight change was >1000 mg ai/kg dw soil. The active ingredient is 

considered to be non-toxic to earthworms up to a concentration of 1000 mg ai/kg dw soil. 

There were no compound related toxic effects. 

This study is scientifically sound but was not conducted following any OPPTS guidelines. This 

study is classified Supplemental. 

Results Synopsis

Test Organism Size (Mean Wt, day 0); Age: 390 mg; Adult (more than 2 months old)

LC50: >1000 mg ai/kg dw soil 95% C.I.: N/A 

EC50: >1000 mg ai/kg dw soil 95% C.I.: N/A 

NOAEC: 1000 mg ai/kg dw soil 

Probit Slope: N/A 95% C.I.: N/A 

 

 Endpoint(s) Affected: None

BCSAA10717 

500 SC 

44.4 LC50: >1000 mg ai/kg dw soil MRID 47743315 

(Supplemental) 

Earthworms 

(Eisenia 

fetida) 

In a 14-day acute toxicity study, earthworms (Eisenia fetida) were exposed to BCS-AA10717 SC 500 

G (AI: Indaziflam) at nominal concentrations of 0 (negative control), 100, 178, 316, 562, and 1000 

mg ai/kg dry weight of artificial substrate. The reference chemical used was Chloroacetamide A.R. at 

5.6 to 32 mg ai/kg dw soil. The LC50 for the reference chemical was 12.4 mg ai/kg dw of soil. 

The LC50 and EC50 values in the study were >1000 mg ai/kg dw soil. The NOAEC, based on body 

weight change, was 562 mg ai/kg dw soil. Mean % weight loss was 10% in the negative control, and 

was 10, 12, 9, 12, and 15% in the nominal 100, 178, 316, 562, and 1000 mg ai/kg dw soil treatment 

groups, respectively. The LOAEC, based on body weight change was 1000 mg ai/kg dw soil. The 

active ingredient is considered to be toxic to earthworms at and above a concentration of 1000 mg 

ai/kg dw soil. 

There were no compound related toxic effects. 
-Page 180 of 292- 

Table C-16. Acute and Chronic Toxicity of Technical Grade Indaziflam (TGAI) to 

Earthworms. 

Species Chemical 

% 

a.i. LC50

Identification 

Number 

(Study 

Classification) 

This study is scientifically sound but was not conducted following any OPPTS guidelines. This 

study is classified Supplemental. 

Results Synopsis

Test Organism Size/Age(Mean Wt or Length): 380 mg; Adult (more than 2 months old)

Indaziflam 

LC50: >1000 mg ai/kg dw soil 95% C.I.: N/A 

EC50: >1000 mg ai/kg dw soil 95% C.I.: N/A 

NOAEC: 562 mg ai/kg dw soil 

Probit Slope: N/A 95% C.I.: N/A 

 

BCS-AA10717 SC 500 G 

LC50: >2252 mg form/kg dw soil 95% C.I.: N/A 

EC50: >2252 mg form/kg dw soil 95% C.I.: N/A 

NOAEC: 1266 mg form/kg dw soil 

 Probit Slope: N/A 

 Endpoint(s) Affected: % weight change 
-Page 181 of 292- 

Table C-16. Acute and Chronic Toxicity of Technical Grade Indaziflam (TGAI) to 

Earthworms. 

Species Chemical 

% 

a.i. LC50

Identification 

Number 

(Study 

Classification) 

BSC-AA10717 SC 500 43.6 LC50: >191 mg ai/kg dw soil MRID 47743316 

(Supplemental) 

Earthworms 

(Eisenia 

fetida) In a 56-day survival, growth, and reproduction toxicity test, adult earthworms (Eisenia fetida) were 

exposed to AE 1170437 SC 500 G (AI: BCS-AA10717) for 28 days at nominal concentrations of 0 

(negative control), 10.0, 17.8, 31.6, 56.2, and 100.0 L form/ha. The converted concentrations in terms 

of mg ai/kg were 0 (negative control), 43.8, 78.0, 138.4, 246.2, and 438.0 mg form/kg dry weight of 

artificial soil, and are equivalent to 0 (negative control), 19.1, 34.0, 60.3, 107, and 191 mg ai/kg dw 

soil. After 28 days, adult earthworms were removed and any offspring produced were exposed to the 

nominal concentrations for an additional 28 days. The reference chemical used was Carbendazim at 

0.10 to 0.50 kg form/ha. The LC50 for the reference chemical was not reported; however, earthworms 

were reported to be sensitive to the reference test item based on the number of juveniles produced per 

replicate vessel. 

The LC50 and EC50 values in the study were >191 mg ai/kg dw soil. The NOAEC, based on 

reproduction, was 34.0 mg ai/kg dw soil. The LOAEC, based on reproduction was 60.3 mg ai/kg dw 

soil. The active ingredient is considered to be toxic to earthworms at and above a concentration of 

60.3 mg ai/kg dw soil. 

There were no compound related toxic effects. No behavioral abnormalities or pathological 

symptoms were reported. 

This study is scientifically sound. This study follows guideline recommendations for an earthworm 

subchronic toxicity test (OPPTS 850.6200); however this study failed to test concentrations up to the 

guideline recommended limit in an attempt to determine a definitive LC50. This study is classified 

Supplemental. 

Results Synopsis

Test Organism Mean Wt at day 0 (range); Age: 336 mg (250 – 460); Adult (8 months old)

BCS-AA10717 

LC50: >191 mg ai/kg dw soil 95% C.I.: N/A 

EC50: >191 mg ai/kg dw soil 95% C.I.: N/A 

NOAEC: 34.0 mg ai/kg dw soil, based on reproduction 

 Probit Slope: N/A 

AE 1170437 SC 500 G 

LC50: >438.0 mg form/kg dw soil 95% C.I.: N/A 

EC50: >438.0 mg form/kg dw soil 95% C.I.: N/A 

NOAEC: 78.0 mg form/kg dw soil, based on reproduction 

 Probit Slope: N/A 

Endpoint(s) Affected: Reproduction 
-Page 182 of 292- 

Field Studies on Non-Target Terrestrial Invertebrates 

No field studies of indaziflam TGAI, formulations, or degradates in non-target terrestrial 

invertebrates were submitted. 

Plants Inhabiting Terrestrial Environments 

Terrestrial plant testing (seedling emergence and vegetative vigor) at the tier II level with the 

typical enduse product is required for known phytotoxicancts (ie. herbicides) that have terrestrial, 

forestry, and residential outdoor use patterns and/or may have endangered or threatened plant 

species associated with the application site. Seedling emergence and vegetative vigor testing of 

the following plant species and groups should be conducted: (1) six species of at least four 

dicotyledon families, including one soybean species (Glycine max) and one root crop, and (2) 

four species of at least two monocotyledon families, including one which is corn (Zea mays). 

Tier II tests measure the responses of plants at five or more test chemical concentrations relative 

to a control. Tier II studies of the effect of the indaziflam formulations BCS-AA10717 20WSP 

and Indaziflam 500 SC on seed emergence and vegetative vigor in terrestrial plants were 

submitted. A typical enduse product is defined as the formulation with the highest percentage AI 

and/or the one most widely used; both BCS-AA10717 20WSP and Indaziflam 500 SC represent 

the two highest percentage AI formulations (20% and 45.05%, respectively). Study details and 

results of these studies are summarized in Table C-13 (for most sensitive species for seedling 

emergence and vegetative vigor), Table C-14 (synopsis for Tier II seedling emergence testing, 

most sensitive parameter per species), and Table C-15 (synopsis for Tier II vegetative vigor 

testing, most sensitive parameter per species). 

Table C-17. Toxicity of Indaziflam Formulations to Terrestrial Plants — Results of Tier II 

Testing (Seedling Emergence and Vegetative Vigor) for the Most Sensitive Species. 

Formulation Species 

% 

a.i. Toxicity Values 

Identification 

Number 

(Study 

Classification) 

Tier II Seedling Emergence 

Indaziflam 500 

SC 

Monocots: 

corn, Zea mays; onion, 

Allium cepa; oat, Avena 

sativa; barley, Hordeum 

vulgare; and ryegrass, 

Lolium perenne 

Dicots: 

cucumber, Cucumis 

sativa; sugarbeet, Beta 

vulgaris; oilseed rape, 

44.4 Most sensitive monocot: onion (shoot 

length) 

21-day EC25/IC25: 0.00017 lbs a.i./A 

Most sensitive dicot: tomato (shoot 

length) 

21-day EC25/IC25: 0.00024 lbs a.i./A

MRID 47443247 

(Acceptable) 
-Page 183 of 292- 

Table C-17. Toxicity of Indaziflam Formulations to Terrestrial Plants — Results of Tier II 

Testing (Seedling Emergence and Vegetative Vigor) for the Most Sensitive Species. 

Formulation Species 

% 

a.i. Toxicity Values 

Identification 

Number 

(Study 

Classification) 

Brassica napus; 

soybean, Glycine max;

sunflower, Helianthus 

annuus; tomato, 

Lycopersicon 

esculentum; and 

buckwheat, Fagopyrum 

esculentum

21-day seedling emergence study with the formulation Indaziflam 500 SC. Nominal application 

rates: 0 Negative Control: 

0 

Corn, oat, barley, & buckwheat: 

0.000364, 0.000906, 0.002273, 0.005683, 0.01421,and 0.03552 lbs a.i./A 

Cucumber, soybean, & sunflower: 

0.000142, 0.000364, 0.000906, 0.002273, 0.005683, and 0.01421 

lbs a.i./A 

Sugarbeet, oilseed rape, onion, and tomato: 

0.000023, 0.000062, 0.000142, 0.000364, 0.000906, and 0.002273 lbs a.i./A 

Ryegrass: 

0.000009, 0.000023, 0.000062, 0.000142, 0.000364, and 0.000906 lbs a.i./A 

Total range of concentrations: 

0.000009, 0.000023, 0.000062, 0.000142, 0.000364, 0.000906, 0.002273, 0.005683, 0.01421,and 

0.03552 lbs a.i./A 

Mean measured test concentrations were not reported. 

Endpoints measured: emergence, survival, dry weight, shoot length, growth stage, and 

phytotoxicity 

The reviewer determined that the study author provided application rates and endpoints in g 

a.i./ha of test item AE 1170437, the diastereomer. The reviewer provided nominal concentrations 

and conducted statistics in lbs a.i./A of the test item AE 1170437 based on these concentrations. 

The reviewer then converted the most sensitive species into the mixture of isomers, BCSAA10717. 

AI: BCS-AA10717 

Monocot

21-day EC25/IC25: 0.00017 lbs a.i./A 95% C.I.: 0.000095 to 0.00029 lbs a.i./A 

21-day EC50/IC50: 0.00026 lbs a.i./A 95% C.I.: 0.00019 to 0.00036 lbs a.i./A 

21-day NOAEC: 0.000146 lbs a.i./A 

Slope: 3.46 

Std err: 1.17

Most sensitive monocot: Onion 

Most sensitive parameter: Shoot length 

Dicot

21-day EC25/IC25: 0.00024 lbs a.i./A 95% C.I.: 0.000113 to 0.00052 lbs a.i./A 

21-day EC50/IC50: 0.00071 lbs a.i./A 95% C.I.: 0.000463 to 0.001132 lbs a.i./A 

21-day NOAEC: 0.000146 lbs a.i./A 
-Page 184 of 292- 

Table C-17. Toxicity of Indaziflam Formulations to Terrestrial Plants — Results of Tier II 

Testing (Seedling Emergence and Vegetative Vigor) for the Most Sensitive Species. 

Formulation Species 

% 

a.i. Toxicity Values 

Identification 

Number 

(Study 

Classification) 

Slope: 1.42 

Std err: 0.315

Most sensitive dicot: Tomato 

Most sensitive parameter: Shoot length 

This toxicity study is scientifically sound and satisfies the CFR part 158.660 guideline 

requirement for a Tier 2 terrestrial plant seedling emergence toxicity study (OPPTS 850.4225). 

This study is classified Acceptable.

Monocot

corn, Zea mays; onion, 

Allium cepa; oat, Avena 

sativa; barley, Hordeum 

vulgare; and ryegrass, 

Lolium perenne

Dicot

cucumber, Cucumis 

sativa; sugarbeet, Beta 

vulgaris; oilseed rape, 

Brassica napus; 

soybean, Glycine max;

sunflower, Helianthus 

annuus; and buckwheat, 

Fagopyrum esculentum

20.3 Most sensitive monocot: ryegrass 

(survival) 

21-day EC25/IC25: 0.00011 lbs a.i./A 

21-day NOAEC: 0.000062 lbs a.i./A

Most sensitive dicot: oilseed rape 

(emergence) 

21-day EC25/IC25: 0.00011 lbs a.i./A 

21-day NOAEC: 0.000062 lbs a.i./A

MRID 47443246 

(Acceptable) 

BCS-AA10717 

20WSP 

21-day seedling emergence study with the formulation BCS-AA10717 20WSP. Nominal test 

concentrations: 

Negative Control: 

0 

Corn, oat, & buckwheat: 

0.000364, 0.000906, 0.002273, 0.005683, 0.01421,and 0.03552 lbs a.i./A 

Cucumber, soybean, & sunflower: 

0.000142, 0.000364, 0.000906, 0.002273, 0.005683, and 0.01421 

lbs a.i./a 

Sugarbeet, oilseed rape, onion, and barley: 

0.000023, 0.000062, 0.000142, 0.000364, 0.000906, and 0.002273 lbs a.i./A 

Ryegrass: 

0.000009, 0.000023, 0.000062, 0.000142, 0.000364, and 0.000906 lbs a.i./A 

Total range of concentrations: 

0.000009, 0.000023, 0.000062, 0.000142, 0.000364, 0.000906, 0.002273, 0.005683, 0.01421,and 

0.03552 lbs a.i./A 

Mean-measured concentrations were not reported. 

Parameters measured: Emergence, survival, dry weight, shoot length, growth stage, and 

phytotoxicity 

Monocot

21-day EC25/IC25: 0.00016 lbs a.i./A 95% C.I.: 0.00009 to 0.0003 lbs a.i./A 

21-day EC50/IC50: 0.00031 lbs a.i./A 95% C.I.: 0.00021 to 0.00045 lbs a.i./A 

21-day NOAEC: 0.000062 lbs a.i./A 
-Page 185 of 292- 

Table C-17. Toxicity of Indaziflam Formulations to Terrestrial Plants — Results of Tier II 

Testing (Seedling Emergence and Vegetative Vigor) for the Most Sensitive Species. 

Formulation Species 

% 

a.i. Toxicity Values 

Identification 

Number 

(Study 

Classification) 

Slope: 2.45 

Std err: 0.543

Most sensitive monocot: Ryegrass 

Most sensitive parameter: Survival 

Dicot

21-day EC25/IC25: 0.00011 lbs a.i./A 95% C.I.: 0.000053 to 0.00024 lbs a.i./A 

21-day EC50/IC50: 0.00027 lbs a.i./A 95% C.I.: 0.00016 to 0.00044 lbs a.i./A 

21-day NOAEC: 0.000062 lbs a.i./A 

Slope: 1.81 

Std err: 0.303

Most sensitive dicot: Oilseed rape 

Most sensitive parameter: Emergence 

This toxicity study is scientifically sound and satisfies the CFR part 158.660 guideline 

requirement for a Tier 2 terrestrial plant seedling emergence toxicity study (OPPTS 850.4225). 

This study is classified Acceptable. 

Tier II Vegetative Vigor 

Monocot

corn, Zea mays; onion, 

Allium cepa; oat, Avena 

sativa; and ryegrass, 

Lolium perenne 

Dicot

cucumber, Cucumis 

sativa; oilseed rape, 

Brassica napus; 

sugarbeet, Beta 

vulgaris; sunflower, 

Helianthus annuus; 

soybean, Glycine max;

tomato, Lycopersicon 

esculentum, and 

buckwheat, Fagopyrum 

esculentum

44.87 Most sensitive monocot: ryegrass 

(survival) 

21-day EC25/IC25:0.0021 lbs a.i./A 

21-day NOAEC: 0.000932 lbs a.i./A

Most sensitive dicot: soybean (shoot 

length) 

21-day EC25/IC25:0.0043 lbs a.i./A 

21-day EC05/IC05: <0.000375 lbs 

a.i./A 

21-day NOAEC: <0.000375 lbs 

a.i./A

MRID 47443249 

(Supplemental) 

Indaziflam 500 

SC 

A 21-day vegetative vigor study with the formulation AE 11704373 SC 500 g/L (AI: BSCAA10717). Nominal test concentrations: 0 (negative control), 0.000142, 0.000364, 0.000906, 

0.002273, 0.005683, 0.01421, 0.03552 and 0.0888 lbs AE 1170437/A. Parameters measured 

include dry weight, survival, phytotoxicity, growth stage, and shoot length. 

 

The reviewer determined that the study author provided application rates and endpoints in g 

a.i./ha of test item AE 1170437, the diastereomer. The reviewer provided nominal 

concentrations and conducted statistics in lbs a.i./A of the test item AE 1170437 based on these 

concentrations. The reviewer then converted the most sensitive species into the mixture of 

isomers, BCS-AA10717. 

BCS-AA10717 
-Page 186 of 292- 

Table C-17. Toxicity of Indaziflam Formulations to Terrestrial Plants — Results of Tier II 

Testing (Seedling Emergence and Vegetative Vigor) for the Most Sensitive Species. 

Formulation Species 

% 

a.i. Toxicity Values 

Identification 

Number 

(Study 

Classification) 

Monocot 

21-day EC50/IC50: 0.0035 lbs a.i./A 95% C.I.: 0.0026 to 0.00484 lbs a.i./A 

21-day EC25/IC25: 0.0021 lbs a.i./A 95% C.I.: 0.00134 to 0.0032 lbs a.i./A

21-day NOAEC: 0.000932 lbs a.i./A

Slope: 2.94 Std err: 0.433

Most sensitive monocot: Ryegrass 

Most sensitive parameter: Survival 

 

Dicot

21-day EC50/IC50: 0.061 lbs a.i./A 95% C.I.: 0.045 to 0.081 lbs a.i./A 

21-day EC25/IC25:0.0043 lbs a.i./A 95% C.I.: 0.0026 to 0.0073 lbs a.i./A 

21-day EC05/IC05: <0.000375 lbs a.i./A 

21-day NOAEC: <0.000375 lbs a.i./A

Slope: 0.588 Std err: 0.0435

Most sensitive dicot: Soybean 

Most sensitive parameter: Shoot length 

This study is scientifically sound and satisfies CFR 40 part 158.660 nontarget plant protection 

data requirements for a tier II terrestrial vegetative vigor study (OPPTS 850.4250). This study is 

classified Acceptable. 

Monocot: 

corn, Zea mays; 

onion, Allium cepa; 

oat, Avena sativa; and 

ryegrass, Lolium 

perenne 

Dicot:

cucumber, Cucumis 

sativa; turnip, 

Brassica rapa; 

sugarbeet, Beta 

vulgaris; sunflower, 

Helianthus annuus; 

soybean, Glycine 

max; and buckwheat, 

Fagopyrum 

esculentum

19.6 Most sensitive monocot: ryegrass 

(survival) 

21-day EC25/IC25:0.0031 lbs a.i./A 

21-day NOAEC: 0.002273 lbs a.i./A

Most sensitive dicot: turnip (dry weight) 

21-day EC25/IC25:<0.000906 lbs a.i./A 

21-day EC05/IC05: <0.000906 lbs a.i./A 

21-day NOAEC: <0.000906 lbs a.i./A

MRID: 47443248 

(Supplemental) 

BCS-AA10717 

20 WSP 

21-day vegetative vigor study with the formulation BCS-AA10717 20 WSP. Nominal 

concentrations were 0 (negative control), 0.000364 (soybean only), 0.000906, 0.002273, 

0.005683, 0.01421, 0.03552 and 0.0888 lbs a.i./A. 

According to the US EPA memo entitled, “Closure on Nontarget Plant Phytotoxicity Policy 

Issues”, issued October 1994, studies failing to provide a slope value adequate to obtain 

NOAEC, EC05, EC25, and EC50 values for the most sensitive species may be classified as 

Supplemental if the lowest test level and the NOAEC are higher than the EC10, but lower than the 

EC25. There was an 18% reduction in dry weight for turnip at the lowest test level. 
-Page 187 of 292- 

Table C-17. Toxicity of Indaziflam Formulations to Terrestrial Plants — Results of Tier II 

Testing (Seedling Emergence and Vegetative Vigor) for the Most Sensitive Species. 

Formulation Species 

% 

a.i. Toxicity Values 

Identification 

Number 

(Study 

Classification) 

This study is scientifically sound but does not fully satisfy CFR 40 part 158.660 non-target plant 

protection data requirements for a tier II terrestrial vegetative vigor study (OPPTS 850.4250). 

This study is classified Supplemental. This study can be upgraded to Acceptable with the 

submission of a second test using turnip, or an adequate replacement for a dicot species, 

conducted at lower application rates to determine non-target dicot sensitivity to the test 

formulation. 

 

Monocot 

21-day EC50/IC50: 0.0041 lbs a.i./A 95% C.I.: 0.0033 to 0.005 lbs a.i./A 

21-day EC25/IC25:0.0031 lbs a.i./A 95% C.I.: 0.0023 to 0.0044 lbs a.i./A

21-day NOAEC: 0.002273 lbs a.i./A

Slope: 6.06 Std err: 1.57

Most sensitive monocot: Ryegrass 

Most sensitive parameter: Survival 

 

Dicot

21-day EC50/IC50: 0.0087 lbs a.i./A 95% C.I.: 0.0027 to 0.028 lbs a.i./A 

21-day EC25/IC25:<0.000906 lbs a.i./A 95% C.I.: N/A 

21-day EC05/IC05: <0.000906 lbs a.i./A 

21-day NOAEC: <0.000906 lbs a.i./A

Slope: 0.556 Std err: 0.138

Most sensitive dicot: Turnip 

Most sensitive parameter: Dry weight 

Table C-18. Synopsis for Tier II seedling emergence testing with Toxicity of Indaziflam 

Formalations 

Formulation % a.i. Species 

Identification 

Number 

(Study 

Classification)

BCS-AA10717 

20 WSP 

20.3 Monocotyledonous species: Corn (Zea mays, Family Poaceae; 

Magister), Oat (Avena sativa, Family Poaceae; Flamings Stern), 

Ryegrass (Lolium perenne, Family Poaceae; Temprano), and 

Barley (Hordeum vulgare, Family Poaceae; Annabell); 

Dicotyledonous species: Cucumber (Cucumis sativa, Family 

Curcubitaceae; Delikatess), Sugarbeet (Beta vulgaris, Family 

Chenopodiaceae; Mosaik), Oilseed Rape (Brassica napus, Family 

Brassicaceae; Licapo), Sunflower (Helianthus annuus, Family 

MRID 

47443246 

(Acceptable) 
-Page 188 of 292- 

Table C-18. Synopsis for Tier II seedling emergence testing with Toxicity of Indaziflam 

Formalations 

Formulation % a.i. Species 

Identification 

Number 

(Study 

Classification)

Asteraceae; Solara), Soybean (Glycine max, Family Fabaceae; 

Erin), and Buckwheat (Fagopyrum esculentum, Family 

Polygonaceae; no variety reported); 

Most sensitive parameters (lbs a.i./L): 

Species Endpoint NOAEC EC05 EC25 EC50

Buckwheat Survival 0.000364 <0.000364 0.00062 0.0011

Cucumber Shoot length 0.000364 0.00046 0.00077 >0.000906

Oilseed rape Emergence 0.000062 0.000033 0.00011 0.00027

Soybean Emergence 0.000364 <0.000142 0.000142 0.0038

Sugarbeet Survival 0.000023 0.00021 0.00035 0.0005

Sunflower Shoot length 0.000906 0.00035 0.0033 >0.01421

Barley Shoot length 0.000906 0.0004 >0.002273 >0.002273

Corn Shoot length 0.000364 0.0004 0.0028 0.011

Oat Survival 0.000906 0.00084 0.0016 0.0026

Ryegrass Survival 0.000062 0.000066 0.00016 0.00031

44.4 Monocotyledonous species: Corn (Zea mays, Family Poaceae; 

Magister), Oat (Avena sativa, Family Poaceae; Flamings Stern), 

Ryegrass (Lolium perenne, Family Poaceae; Temprano), Onion 

(Allium cepa, Family Liliaceae; Braunschweiger blutrot), and 

Barley (Hordeum vulgare, Family Poaceae; Annabell); 

Dicotyledonous species: Cucumber (Cucumis sativa, Family 

Curcubitaceae; Delikatess), Sugarbeet (Beta vulgaris, Family 

Chenopodiaceae; Mosaik), Oilseed Rape (Brassica napus, Family 

Brassicaceae; Licapo), Sunflower (Helianthus annuus, Family 

Asteraceae; Solara), Soybean (Glycine max, Family Fabaceae; 

Erin), Tomato (Lycopersicon esculentum, Family Solanaceae; 

Balkonstar), and Buckwheat (Fagopyrum esculentum, Family 

Polygonaceae; no variety reported); 

MRID: 

47443247 

(Acceptable) 

Indaziflam 500 

SC 

Most Sensitive Parameters (lbs a.i./L): 

Species Endpoint NOAEC EC25 EC50

Buckwheat Shoot length 0.000374 <0.000932 >0.00585 

Cucumber Dry weight <0.000146 >0.000932 >0.000932 

Oilseed rape Survival 0.000146 0.00076 >0.000932 

Soybean Survival 0.000146 0.00062 0.002 

Sugarbeet Survival 0.000374 0.00099 0.002 

Sunflower Shoot length 0.000932 0.0083 >0.01462 

Tomato Shoot length 0.000146 0.00025 0.00071 

Barley Survival 0.000932 0.004 0.012 

Corn Shoot length 0.000374 0.0032 0.019 

Oat Survival 0.000374 0.0013 0.002 

Onion Shoot length 0.000146 0.00017 0.00026 

Ryegrass Survival 0.000063 0.00027 0.00047 
-Page 189 of 292- 

Table C-18. Synopsis for Tier II Vegetative Vigor Testing with Toxicity of Indaziflam 

Formalations 

Formulation % a.i. Species 

Identification 

Number 

(Study 

Classification)

19.6 Monocotyledonous species: Corn (Zea mays, Family Poaceae; 

Magister), Onion (Allium cepa, Family Liliaceae; Braunschweiger 

blutrot), Oat (Avena sativa, Family Poaceae; Flamings Stern), and 

Ryegrass (Lolium perenne, Family Poaceae; Temprano); EPA 

recommends four monocots in two families, including corn.

Dicotyledonous species: Cucumber (Cucumis sativus, Family 

Curcubitaceae; Delikatess), Turnip (Brassica rapa, Family 

Brassicaceae; Wilhelmburger gelbe), Sugar beet (Beta vulgaris, 

Family Chenopodiaceae); Wichita), Sunflower (Helianthus 

annuus; Family Asteraceae; Solara), Soybean (Glycine

max, Family Fabaceae; Erin), and Buckwheat (Fagopyrum 

esculentum, Family Polygonaceae; no variety 

reported); 

MRID 

47443248 

(Supplemental) 

BCS-AA10717 

20 WSP 

Most sensitive parameters (lbs a.i./L): 

Species Endpoint NOEC EC05 EC25 EC50

Buckwheat Shoot 

length 

0.005683 0.0028 0.012 0.035 

Cucumber Shoot 

length 

0.002273 0.0011 0.0081 0.033

Turnip Dry weight <0.000906 <0.000906 <0.000906 0.0087 

Soybean Dry weight 0.002273 0.00059 0.015 >0.0888

Sugarbeet Shoot 

length 0.005683 0.0024 0.012 0.038 

Sunflower Shoot 

length

0.000906 <0.000906 0.0095 0.059 

Corn Shoot 

length

0.002273 <0.000906 0.0056 0.027

Oat Survival 0.005683 0.0045 0.0078 0.012

Onion Survival 0.01421 0.0083 0.018 0.03

Ryegrass Survival 0.002273 0.0022 0.0031 0.0041
-Page 190 of 292- 

Table C-18. Synopsis for Tier II Vegetative Vigor Testing with Toxicity of Indaziflam 

Formalations 

Formulation % a.i. Species 

Identification 

Number 

(Study 

Classification)

44.87 Monocotyledonous species: Corn (Zea mays, Family Poaceae; 

Magister), Onion (Allium cepa, Family Liliaceae; Braunschweiger 

blutrot), Oat (Avena sativa, Family Poaceae; Flamings Stern), and 

Ryegrass (Lolium perenne, Family Poaceae; Temprano); EPA 

recommends four monocots in two families, including corn.

Dicotyledonous species: Cucumber (Cucumis sativus, Family 

Curcubitaceae; Delikatess), Sugar beet (Beta vulgaris, Family 

Chenopodiaceae); Mosaik), Sunflower (Helianthus annuus; 

Family Asteraceae; Solara),Soybean (Glycine max, Family 

Fabaceae; Erin), Oilseed rape (Brassica napus, Family 

Brassicaceae; Licapo), Tomato (Lycopersicon esculentum, Family 

Solanaceae; Balkonstar), and Buckwheat (Fagopyrum 

esculentum, Family Polygonaceae; no variety reported); 

MRID: 

47443249 

(Acceptable) 

Indaziflam 500 

SC 

Most Sensitive Parameters (lbs a.i./L) 

Species Endpoint NOAEC EC25 EC50

Buckwheat Survival 0.005847 0.011 0.0234 

Cucumber Dry weight 0.002338 0.024 >0.0913 

Oilseed rape Survival 0.005847 0.016 0.027 

Soybean Shoot length <0.000374 0.0043 0.061 

Sugarbeet Survival 0.002338 0.012 0.022 

Sunflower Shoot length 0.002338 0.01 0.063 

Tomato Dry weight 0.005847 0.02 >0.0366 

Corn Survival 0.002338 0.0083 0.02 

Oat Survival 0.002338 0.0048 0.0077 

Onion Survival 0.005847 0.05 0.065 

Ryegrass Survival 0.000932 0.002 0.0035 
-Page 191 of 292- 

Appendix D. Catalogue of Submitted Environmental Fate Studies for 

Indaziflam. 

Table G. Submitted Environmental Fate Studies for Indaziflam, their Review 

Classifications, and Classification Justifications. 

Guideline Study Title MRID Classification Comments

Are data 

adequate for 

Risk 

Assessment? 

Current 

Additional 

Data Need 

835.2120 Hydrolysis 47443207 Acceptable No significant issues affecting the 

acceptability of the study were noted. Yes None 

835.2240 Photodegradation 

in Water 47443208 Supplemental 

Study duration not sufficient. 

Concentrations of the 2 major 

transformation products were still 

increasing at the study termination, 

precluding the determination of the 

patterns of formation and decline for 

each. 

Yes None 

835.2410 Photodegradation 

on Soil 47443209 Supplemental 

Study duration not sufficient. 

There was a decline in the dark controls 

(11%), material balances are acceptable. 

No explainable reason for decline in dark 

controls (e.g., stable to hydrolysis) 

Yes None 

47443210 Supplemental 

Application rate was 4x the maximum 

proposed application rate to achieve 

appropriate sensitivity. Kinetics may not 

be accurately represented at the higher 

application mass. 

Overall recoveries of C14 residues from 

decreased during the study duration. 

Authors did not demonstrate that volatile 

trapping method was efficient at trapping 

high concentrations of volatile gases 

(e.g., CO2) 

835.4100 None 

Aerobic Soil 

Metabolism 

47443211 Supplemental 

Application rate was 4x the maximum 

proposed application rate to achieve 

appropriate sensitivity. Kinetics may not 

be accurately represented at the higher 

application mass. 

In the California sandy loam, increasing 

% of AR for diaminotriazine was 

observed at the termination of the study 

precluding the determination of the 

patterns of formation and decline. 

Yes 

None. 
-Page 192 of 292- 

Guideline Study Title MRID Classification Comments

Are data 

adequate for 

Risk 

Assessment? 

Current 

Additional 

Data Need 

47443212 Supplemental 

Study duration not sufficient. This may 

not be sufficient to accurately establish 

the pattern of decline of the major 

transformation products. 

Replicates were not collected for three of 

the four soils tested, except for time 0. 

Moisture content was higher than 

recommended in study guidelines (55% 

of max holding capacity vs 75% of 1/3 

bar soil moisture content) 

None 

47443213 Supplemental

Study duration not sufficient. This may 

not be sufficient to accurately establish 

the pattern of decline of the major 

transformation products. 

Replicates were not collected for three of 

the four soils tested, except for time 0. 

Moisture content was higher than 

recommended in study guideline (55% of 

max holding capacity vs 75% of 1/3 bar 

soil moisture content) 

None 

47443214 Supplemental 

Study was conducted using 

diaminotraizine (a degradate) as the 

starting material 

Study duration not sufficient. This may 

not be sufficient to accurately establish 

the pattern of decline of the major 

transformation products. 

Moisture content was higher than 

recommended in study guideline (55% of 

max holding capacity vs 75% of 1/3 bar) 

None 

47443215 Supplemental

A comparison of the behavior of the two 

active isomers. Samples were analyzed 

only for the parent compounds. 

This study does not provide quantitative 

data for the risk assessment, it shows the 

behavior of the two active isomers 

(diastereomers) of indaziflam (BCS 

AA10717). 

Used only for 

qualitative 

purposes. 

None 

835.4200 Anaerobic Soil 

Metabolism 47443216 Acceptable 

Moisture content during the aerobic 

phase was higher than recommended in 

study guidelines (55% of max holding 

capacity vs 75% of 1/3 bar) 

Yes None 

835.4300 Aerobic Aquatic 

Metabolism 47443217 Supplemental

Study duration not sufficient. Duration 

not be sufficient to accurately establish 

the pattern of decline of the major 

transformation products. 

Yes None 
-Page 193 of 292- 

Guideline Study Title MRID Classification Comments

Are data 

adequate for 

Risk 

Assessment? 

Current 

Additional 

Data Need 

47443218 Acceptable Study conducted on Indane labeled 

compound. Yes None 

835.4400 

Anaerobic 

Aquatic 

Metabolism 47443219 Acceptable Study conducted on Triazine labeled 

compound. Yes None 

47443203 Acceptable No significant issues affecting the 

acceptability of the study were noted. Yes None 

47443204 Supplemental 

The test compound was triazineindanone a transformation product of AE 

1170437. 

Yes None

47443205 Supplemental The test compound was diaminotriazine 

a transformation product of AE 1170437. Yes None

835.1230 

Mobility - 

Adsorption / 

Desorption 

47443206 Supplemental 

The test compound was AE 1170437-

carboxylic acid a transformation product 

of AE 1170437. 

Yes None

47443220 Supplemental

Study conducted on CA Porterville sandy 

loam cropped with turf. 

Storage stability study showed slow 

degradation of degradate over the period 

of frozen storage. 

None 

47443221 Supplemental

Study conducted on FL Monticello 

loamy sand cropped with turf. 

Storage stability study showed slow 

degradation of degradate over the period 

of frozen storage. 

None 

47443222 Supplemental

Study conducted on NC Wayne County 

loamy sand cropped with turf. 

Storage stability study showed slow 

degradation of degradate over the period 

of frozen storage. 

None 

47443223 Supplemental

Study conducted on CA Porterville sandy 

loam, bare soil. 

Storage stability study showed slow 

degradation of degradate over the period 

of frozen storage. 

None 

47443224 Supplemental

Study conducted on FL Jefferson County 

sand/loamy sand, bare soil. 

Storage stability study showed slow 

degradation of degradate over the period 

of frozen storage. 

None 

835.6100 Terrestrial Field 

Dissipation 

47443225 Supplemental

Study conducted on NC Wayne County 

loamy sand, bare soil. 

Storage stability study showed slow 

degradation of degradate over the period 

of frozen storage. 

Yes 

None 
-Page 194 of 292- 

Guideline Study Title MRID Classification Comments

Are data 

adequate for 

Risk 

Assessment? 

Current 

Additional 

Data Need 

47743301 Supplemental

Study conducted on Quincy loamy sand, 

bare soil, in Ephrata, Washington. 

Storage stability study showed slow 

degradation of degradate over the period 

of frozen storage. 

None 

47743302 Supplemental

Study was conducted on Oakville loamy 

sand, bare soil, in North Rose, New 

York. 

Storage stability study showed slow 

degradation of degradate over the period 

of frozen storage. 

None 

850.1730 Fish 

Accumulation 47443237 Acceptable No significant issues affecting the 

acceptability of the study were noted. Yes None 

Storage stability 47443279 Supplemental 

Samples fortified with olefin degraded 

slowly, (corrected mean recoveries 65-

88% following 427-433 days). 

Samples were not stored for a sufficient 

duration. 

N/A None 

860.1380 

Storage Stability 47743328 Supplemental 

Study upgrades MRID 47443279; 

conducted for sufficient duration. 

Samples fortified with olefin degraded 

slowly, mean corrected recoveries 

ranging from 65 to 88% following 427 to 

433 days and from 47 to 67% following 

732 to 736 days of storage 

N/A None 

Nonguideline 

Supplemental 

Information on 

Foreign Soils 

47793401 Supplemental 

Comparison of foreign (German) soils to 

location and soil taxonomy of US soil 

series. 

Yes None 
-Page 195 of 292- 

Appendix E. Product Chemistry and Environmental Fate Summary of 

Indaziflam 

Product Chemistry of Indaziflam 

Chemical Name: Indaziflam (BCS AA10717) 

IUPAC: N-[(1R,2S)-2,3-dihydro-2,6-dimethyl-1H-inden-1-yl]-6-[(1RS)-1-fluoroethyl]-1,3,5-

triazine-2,4-diamine 

CAS: 1,3,5-Triazine-2,4-diamine, N-[(1R,2S)-2,3-dihydro-2,6-dimethyl-1H-inden-1-yl]-6-(1-

fluoroethyl) 

Chemical Abstracts registry number: 950782-86-2 (isomer mixture); 730979-19-8 (Isomer A; 

AE 1170437); 730979-32-5 (Isomer B; AE 1170438) 

Synonyms: BCS-AA10717, BAY BCHD 1709, BAY BCHD 2003, BAY BCKM 2459, BAY 

BSP 1089, BAY NLL 7482 

Molecular Formula: C16H20FN5 

Molecular Weight: 301.36 g/mol 

Chemical Structure(s): 

Isomer A: Isomer B: 

Technical grade indaziflam is a light beige colored powder with no characteristic odor and a 

melting point of 177oC. Indaziflam is a mixture of two active diastereoisomers (AE 1170437 

(isomer A), and AE 1170438 (isomer B)), which are both present in the technical grade product 

in the following percentages, 95-100% isomer A and 0-5%, isomer B. Indaziflam is readily 

soluble in organic solvents. The ultraviolet spectrum of indaziflam shows the maxima above 290 

nm. Indaziflam’s vapor pressure is very low for both isomers (isomer A: 6.8 x 10-8 Pa, and 

isomer B: 1.1 x 10-8 Pa; 5.1 x 10 -10 torr and 8.25 x 10-11 torr) therefore there is low risk of 

transport by air. The compound exhibits acid-base behavior (pKa = 3.5 and 3.6, isomer A and B, 

respectively). It is considered a weak acid, and it is moderately soluble at pH 4, 7 and 9 (isomer 
-Page 196 of 292- 

A: 4.4, 2.2, 2.2 mg/L, and isomer B: 1.7, 1.2, and 1.2 mg/L). The reported logKow for 

indaziflam is 2.8 and indicates a low potential for bioconcentration in fish and living organisms 

(BCF ranged from 36 to 122x). 

Environmental Fate Summaries of Indaziflam (BCS AA10717)

Detailed information regarding the fate and transport of indaziflam in the environment is 

provided in the study summaries below. 

Hydrolysis - - EPA Guideline: 161-1 (835.2120) 

MRID Number: 47443207 Indaziflam (AE1170437) 

Sneikus, J. 2007. [Triazine-2,4-14C] and [indane-3-13/14C]AE 1170437: Hydrolytic degradation. 

Unpublished study performed and sponsored by Bayer CropScience AG, Monheim, Germany; 

submitted by Bayer CropScience LP, Research Triangle Park, North Carolina (pp. 1, 3). Bayer 

CropScience Study No.: M1111669-5. Bayer CropScience AG Report No.: MEF-07/177. 

Experiment started March 5, 2007 and completed April 23, 2007 (p. 6). Final report issued 

October 30, 2007. 

[

14C]AE 1170437, [Triazine-2,4-14C]-labeled, was stable to hydrolysis at pH 4, 7, and 9 at 50oC 

during the 7 days of incubation ranging from averages of 100.0-105.0%, 98.2-107.1%, and 99.5-

105.9% of the applied radiation, pH 4, 7, and 9, respectively. No major transformation products 

were isolated from any of the buffer solutions, and no minor transformation products were 

isolated from the pH 7 or 9 solutions. In the pH 4 solutions, one minor transformation product 

(“B”) averaged a maximum of 1.8% of the applied. Volatiles were not collected. 

This study is classified as ACCEPTABLE. No significant deviations from good scientific 

practices were noted. 

Photolysis in Water - - EPA Guideline: 161-2 (835.2240) 

MRID Number: 47443208 Indaziflam (AE 1170347) 

Dehner, D. and O. Heinemann. 2006. [Indane-3-13C/14C] AE 1170437 and [triazine-2,4-14C] AE 

1170437: Phototransformation in water. Unpublished study performed and sponsored by Bayer 

CropScience AG, Monheim, Germany; and submitted by Bayer CropScience LP, Research 

Triangle Park, North Carolina (pp. 1, 3). Bayer CropScience AG Report No.: MEF-06/201. 

Bayer CropScience Study No: M1121572-9. Experiment started March 1, 2006 and completed 

May 9, 2006 (p. 9). Final report issued December 7, 2006. 

[Indane-3-13C/14C]AE 1170437. In the irradiated solutions, [indane-3-13C/14C]AE 1170437 

declined quickly from an average of 95.8% of the applied at time 0 to 53.0% at 1.25 days posttreatment and 21.3% at 3 days (study termination). The two major transformation products, AE 
-Page 197 of 292- 

1170437-olefine and AE 1170437-1-hydroxyethyl, averaged maximums of 53.6% and 20.3% of 

the applied, respectively, at 3 days post-treatment. Unidentified [14C]residues totaled an average 

maximum of 7.3% of the applied at 3 days post-treatment. At study termination, neither 14CO2

nor volatile [14C]organic compounds were detected in the trapping materials. In the 

corresponding dark controls, [14C]AE 1170437 averaged 95.8% of the applied at time 0 and 

ranged from 97.0% to 99.4% of the applied between 0.125 and 3 days post-treatment. 

[Triazine-2,4-14C]AE 1170437. In the irradiated pH 7 buffer solutions, [triazine-2,4-14C]AE 

1170437 declined quickly from an average of 95.3% of the applied at time 0 to 51.9% at 1.25 

days post-treatment and 20.5% at 3 days (study termination). The two major transformation 

products, AE 1170437-olefine and AE 1170437-1-hydroxyethyl, averaged maximums of 49.9% 

and 16.6% of the applied, respectively, at 3 days post-treatment. One unidentified 

transformation product (Reg #1, Rt ca. 5 minutes) averaged a maximum of 3.1% at 3 days posttreatment. Unidentified [14C]residues totaled an average maximum of 4.7% of the applied at 3 

days post-treatment. At study termination, neither 14CO2 nor volatile [14C]organic compounds 

were detected in the trapping materials. In the corresponding dark controls, [14C]AE 1170437 

ranged from 90.3% to 95.3% of the applied throughout the study. 

Based on first order linear regression analysis (Excel 2003), AE 1170437 (combined labels) 

dissipated with reviewer-calculated half-lives of 1.36 days in the irradiated solutions and 141.5 

days in the dark controls. The half-life determined for the dark controls is of uncertain value 

since it is extrapolated well beyond the duration of the study. The phototransformation halflife for AE 1170437 is 1.37 days (32.9 hours) based on the continuous irradiation used in the 

study or 2.75 days based on a 12-hour light/12-hour dark cycle. The study authors reported that 

ca. 8.7-8.8 hours of artificial light were equivalent to 1 environmental day in June in Phoenix, 

Arizona (33.26°N). Therefore, the environmental phototransformation half-life for AE 

1170437 is ca. 3.7 days. 

A transformation pathway for AE 1170437 was provided by the study authors. AE 1170437 

photodegrades to AE 1170437-olefine by loss of the fluorine or to AE 1170437-1-hydroxyethyl 

by exchange of the fluorine for a hydroxyl group. Minor amounts (<5% of the applied) of 

unidentified nonvolatile transformation products and volatile compounds are also formed. 

This study is classified as SUPPLEMENTAL. The experiment was terminated after 3 days of 

continuous radiation, at which time ca. 21% of the applied remained undegraded in the irradiated 

sample, but at least two half-lives were completed prior to the termination of the study. 

However, formation and decline of two major degradates (AE 1170437-olfine, and AE1170437-

hydroxyethyl) could not be quantified as concentrations of the major transformation products 

were still increasing at the termination of the study. Additionally, there were decreases in the 

percent of applied radiation in the dark controls, however material balances were acceptable and 

sterile conditions were verified. 
-Page 198 of 292- 

Photolysis on Soil - - EPA Guideline: 161-3 (835.2410) 

MRID Number: 47443209 Indaziflam (AE 1170437) 

Stupp H-P. and T. Augustin. 2007. [Triazine-2,4-14C] and [indane-3-13C/14C]AE 1170437: 

Phototransformation on soil. Unpublished study performed and sponsored by Bayer 

CropScience AG, Monheim, Germany, and submitted by Bayer CropScience LP, Research 

Triangle Park, North Carolina (pp. 1, 3). Bayer CropScience AG Report No.: MEF-06/137. 

Bayer CropScience Study No.: M1121506-6. Experiment started June 27, 2005 and completed 

May 16, 2006 (p. 6). Final report issued October 22, 2007. 

[Triazine-2,4-14C]AE 1170437. In the irradiated soil, [triazine-2,4-14C]AE 1170437 decreased 

from an average of 99.5% of the applied at time 0 to 67.8% at 3 days post-treatment and 47.0% 

at 10 days (study termination). No major transformation products were isolated. Three minor 

transformation products, AE 1170437-triazine indanone, AE 1170437-carboxylic acid, and AE 

1170437-diaminotriazine, were identified. AE 1170437-triazine indanone and AE 1170437-

diaminotriazine averaged maximums of 6.3% and 6.9% of the applied, respectively. AE 

1170437-carboxylic acid averaged a maximum of 1.6% of the applied. Individual unidentified 

zones of radioactivity (Z3-Z9) each averaged ≤1.6% of the applied, and diffuse radioactivity 

averaged a maximum of 10.5%. Extractable [14C]residues decreased from an average of 100.1% 

of the applied at day 0 to 78.9% at 10 days post-treatment, while nonextractable [14C]residues 

increased to a maximum average of 21.8% at 10 days. Neither 14CO2 nor volatile [14C]organic 

compounds were detected in the trapping materials. 

In the corresponding dark controls, [14C]AE 1170437 decreased from an average of 99.5% of 

recovered at time 0 to 89.9% at 10 days. No major transformation products were isolated. Two 

minor transformation products, AE 1170437-triazine indanone and AE 1170437-diaminotriazine, 

were identified at maximum average concentrations of 1.3-1.5% of the applied. Unidentified 

diffuse radioactivity averaged a maximum of 5.0% of the applied at 10 days. Extractable 

[

14C]residues decreased from an average of 100.1% of the applied at day 0 to 97.7% at 10 days 

post-treatment, while nonextractable [14C]residues increased to a maximum average of 5.5% at 8 

days and were 4.3% at 10 days. Neither 14CO2 nor volatile [14C]organic compounds were 

detected in the trapping materials. 

[Indane-3-13C/14C]AE 1170437. In the irradiated soil, [indane-3-13/14C]AE 1170437 decreased 

from an average of 98.6% of the applied at time 0 to 74.5% at 3 days post-treatment and 55.6% 

at 9 days (study termination). No major transformation products were isolated. Two minor 

transformation products AE 1170437-triazine indanone and AE 1170437-carboxylic acid, were 

identified at maximum average concentrations of 7.0% and 2.1% of the applied, respectively. 

AE 1170437-carboxylic acid averaged a maximum 2.0%. Individual unidentified zones of 

radioactivity (Z3-Z9) each averaged ≤1.3% of the applied, and diffuse radioactivity averaged 

maximums of 12.4-12.7% at 8-9 days post-treatment. Extractable [14C]residues decreased from 

an average of 100.2% of the applied at day 0 to 81.8% at 9 days post-treatment, while 

nonextractable [14C]residues increased to a maximum average of 12.3% 9 days. At study 

termination, 14CO2 averaged 2.9% of the applied and volatile [14C]organic compounds were not 

detected in the trapping materials. 
-Page 199 of 292- 

In the corresponding dark controls, [14C]AE 1170437 decreased from an average of 98.6% of 

recovered at time 0 to 93.7% at 9 days post-treatment. No major transformation products were 

isolated. The only minor transformation product identified, AE 1170437-triazine indanone, 

averaged a maximum 1.6% of the applied. Unidentified diffuse radioactivity averaged a 

maximum 4.1% of the applied. Extractable [14C]residues decreased from an average of 100.2% 

of the applied at day 0 to 99.0% at 9 days post-treatment, while nonextractable [14C]residues 

increased to a maximum of 3.6-3.8% at 8-9 days. At study termination, neither 14CO2 nor 

volatile [14C]organic compounds were detected in the trapping materials. 

Based on first-order linear regression analysis (Excel 2003), AE 1170437 (combined labels) 

degraded with reviewer-calculated half-lives of 11.4 days in the irradiated soil and 123.8 days in 

the dark controls. The value of the half-life determined for the irradiated samples is somewhat 

uncertain and that of the dark controls is highly uncertain because the data are extrapolated 

beyond the duration of the study. The phototransformation half-life for AE 1170437 is 12.6 

days based on the continuous irradiation used in the study or ca. 25 days based on a 12-hour 

light/12-hour dark cycle. The study authors reported that ca. 7.5 hours of artificial light were 

equivalent to 1 environmental day in June in Phoenix, Arizona (33.26°N). Therefore, the 

environmental phototransformation half-life for AE 1170437 is ca. 40.3 days. 

A transformation pathway for AE 1170437 was provided by the study authors. In both the 

irradiated and dark soils, AE 1170437 degrades via oxidation of the indanyl moiety to form AE 

1170437-triazine indanone and AE 1170437-carboxylic acid. AE 1170437, AE 1170437-triazine 

indanone and AE 1170437-carboxylic acid are cleaved at the N bridge to form AE 1170437-

diaminotriazine from the triazine moiety and unidentified minor compounds from the indanyl 

moiety. Residues are ultimately converted to bound residues and CO2. The transformation 

pathway was thought to be similar under light and dark conditions, with observed differences 

due to the faster rate of dissipation under light. 

This study is classified as SUPPLEMENTAL. The [indane-3-13/14C]-labeled AE 1170437 study 

was terminated after 9 days of continuous irradiation, at which time 55.6% of the applied AE 

1170437 remained undegraded in the irradiated soil. The [traizine-2,4-14C]-labeled AE 1170437 

study was terminated at 10 days of continuous irradiation, at which time 47% of the applied 

radiation remained undegraded, however at least one half-life was completed. It is not expected 

that the half-life for the [indane-3-13/14C]-labeled AE 1170437 would have a drastically different 

phototransformation half-life if the study were completed for a longer duration. 

Aerobic Soil Metabolism EPA Guideline: 162-1 (835.4100) 

MRID Number: 47443210 Indaziflam (AE 1170437) 

Shepherd, J. 2008. [Indane-3-13C/14C]AE 1170437: Aerobic soil metabolism in two US soils. 

Unpublished study performed by Bayer CropScience, Stilwel, Kansas; sponsored and submitted 

by Bayer CropScience, Research Triangle Park, North Carolina. Bayer CropScience Study and 

Report No.: MEDHP013. Experiment started October 14, 2005 and completed May 23, 2007 (p. 
-Page 200 of 292- 

6). Final report issued January 11, 2008. 

[Indane-3-13C/14C]-labeled AE 1170437 is persistent in aerobic soil with non-linear half-lives 

ranging from 87.7-177.7 days, in a sandy loam soil (Nord; pH 8.6, organic carbon 0.5%) from 

Porterville, California (USA), and a sandy loam soil (series not identified; pH 6.5, organic 

carbon 1.7%) from Pikeville, North Carolina (USA). Based on nonlinear regression analyses 

(SigmaPlot v 9; exponential, one compartment/two parameter), AE 1170437 dissipated with 

reviewer-calculated nonlinear half-lives of 87.7 days in the Nord sandy loam soil and 177.7 

days in the North Carolina sandy loam soil, which correspond to observed DT50 times of 70 and 

90 days, respectively; linear half-lives were 141.5 and 239.0 days. Two major transformation 

products, AE 1170437-triazine indanone and AE 1170437-carboxylic acid, were isolated in both 

soil types. No minor transformation products were identified. 

Unextracted residues increased over the course of the study (21.7% of the applied radiation for 

Nord sandy loam, and 17.8% in the North Carolina sandy loam at the study termination (368 

days). Half-lives were recalculated for the parent and unextracted residues. Based on nonlinear 

regression analyses (SigmaPlot v 9; exponential, one compartment/two parameter), AE 1170437 

dissipated with reviewer-calculated parent and unextracted residues nonlinear half-lives of 

203.9 days in the Nord sandy loam soil and 630.1 days in the North Carolina sandy loam soil. It 

is important to note that the dissipation of AE1170437 in the North Carolina sandy loam soil was 

variable; the percent of applied decreases through approximately 180 days, after which 

AE1170437 it increased through 270 days and then decreased through the study termination. 

A transformation pathway was provided by the study author. Based on the study results, AE 

1170437 degrades via oxidation of the indanyl moiety to form AE 1170437-triazine indanone 

and AE 1170437-carboxylic acid. Residues are ultimately converted to bound residues and CO2. 

This study is classified SUPPLEMENTAL and does not completely satisfy the guideline 

requirement for an aerobic biotransformation study in soil, but can be used for risk assessment 

purposes. Application rate was 4x the maximum proposed application rate to achieve 

appropriate sensitivity. Kinetics may not be accurately represented at the higher application 

mass, and overall recoveries of C14 residues from CA decreased during the study duration. 

MRID Number: 47443211 Indaziflam (AE 1170437) 

Shepherd, J. 2008. [Triazine-2,4-14C]AE 1170437: Aerobic soil metabolism in two US soils. 

Unpublished study performed by Bayer CropScience, Stilwell, Kansas; sponsored and submitted 

by Bayer CropScience, Research Triangle Park, North Carolina. Bayer CropScience Study and 

Report No.: MEDHP032. Experiment started October 14, 2005 and completed July 19, 2007 (p. 

6). Final report issued January 11, 2008. 

Overall recoveries of [14C]residues averaged 96.5 ± 2.4% (range 90.9-100.2%) in the California 

sandy loam soil and 99.5 ± 2.0% (94.8-102.8%) in the North Carolina sandy loam soil. There 

was no significant loss of residues over the 368 day incubation from either system. Based on 

nonlinear regression analyses (SigmaPlot v 9; exponential, one compartment/two parameter), AE 

1170437 dissipated with reviewer-calculated non-linear half-lives of 82.5 days in the California 
-Page 201 of 292- 

sandy loam soil and 147.5 days in the North Carolina sandy loam soil; linear half-lives were 

135.9 and 239.0 days, respectively. Three transformation products were identified: 

• (2R,3R)-3-({4-amino-6-[(1R)-1-fluoroethyl]-1,3,5-triazin-2-yl}amino)-2,5-

dimethylindan-1-one (AE 1170437-triazine indanone; AE 2158968); 

• (2S,3R)-3-({4-amino-6-[(1R)-1-fluoroethyl]-1,3,5-triazin-2-yl}amino)-2-methylindane-5-

carboxylic acid (AE 1170437-carboxylic acid; AE 2158969); and 

• 6-[(1R)-1-fluoroethyl]-1,3,5-triazine-2,4-diamine (AE 1170437-diaminotriazine; 

AE1956114). 

All three compounds were major transformation products in both soils. No minor transformation 

products were identified in either soil. CO2 was a major transformation product in the California 

soil and a minor product in the North Carolina soil. 

Unextracted residues increased over the course of the study (18.2% of the applied radiation for 

Nord sandy loam, and 34.2% in the North Carolina sandy loam at the study termination (368 

days). Half-lives were recalculated for the parent and unextracted residues. Based on nonlinear 

regression analyses (SigmaPlot v 9; exponential, one compartment/two parameter), AE 1170437 

dissipated with reviewer-calculated parent and unextracted residues nonlinear half-lives of 

173.3 days in the Nord sandy loam soil and 630.1 days in the North Carolina sandy loam soil. It 

is important to note that the dissipation of AE1170437 in the North Carolina sandy loam soil was 

variable; the percent of applied decreases through approximately 180 days, after which 

AE1170437 it increased through 270 days and then decreased through the study termination. 

A transformation pathway was provided by the study author. Based on the study results, 

AE1170437 degrades via oxidation of the indanyl moiety to form AE1170437-triazine indanone 

and AE1170437-carboxylic acid. AE1170437, AE1170437-triazine indanone and AE1170437-

carboxylic acid are cleaved at the N bridge to form AE1170437-diaminotriazine from the triazine 

moiety and unidentified minor compounds from the indanyl moiety. Residues are ultimately 

converted to bound residues and CO2. 

This study is classified as SUPPLEMENTAL. Application rate was 4x the maximum proposed 

application rate to achieve appropriate sensitivity; however degradation kinetics may not be 

accurately represented at the higher application mass. Also, in the California sandy loam, there 

was a reported increasing percentage of the applied radiation at the termination of the study for 

the major transformation product diaminotriazine. 

MRID Number: 47443212 Indaziflam (AE 1170437) 

Stupp, H-P. and T. Augustin. 2007. [Indane-3-13C/14C]AE 1170437: Aerobic soil metabolism in 

4 EU soils. Unpublished study performed and sponsored by Bayer CropScience AG, Monheim, 

Germany, and submitted by Bayer CropScience, Research Triangle Park, North Carolina. Bayer 

CropScience AG Report MEF-06/19. Study Protocol ID.: M1251497-9. Experiment started 

April 13, 2005, and completed January 18, 2006 (p. 6). Final report issued November 9, 2007. 

The biotransformation of [indane-3-13C/14C]-labeled N-[(1R,2S)-2,6-dimethyl-2,3-dihydro-1Hinden-1-yl]-6-[(1R)-1-fluoroethyl]-1,3,5-triazine-2,4-diamine (AE 1170437, radiochemical 
-Page 202 of 292- 

purity ≥98%) , was studied in four soils from Germany: sandy loam (LH AXXa; pH 6.8, organic 

carbon 1.64%); loam (LH AIIIa; pH 7.1, organic carbon 1.29%); loam (Wurmwiese; pH 6.4, 

organic carbon 2.08%); and a silt loam (Hoefchen; pH 7.2, organic carbon 2.07%). The 

experiments were conducted under aerobic conditions for 122 days in the dark at 19.8 ± 0.9°C 

and 55% of the maximum water holding capacity. Overall recoveries of [14C]residues averaged 

98.5 ± 1.2% (range 96.4-100.1%) of the applied from the LH AXXa sandy loam soil, 98.0 ±

1.3% (94.9-99.8%) from the LH AIIIa loam soil, 98.5 ± 2.1% (range 93.3-101.0%) from the 

Wurmwiese loam soil, and 98.3 ± 1.2% (range 95.8-99.7%) from the Hoefchen silt loam soil. 

There was no significant loss of residues over time from any of the soil systems. 

Based on nonlinear regression analyses (SigmaPlot v 9; exponential, one compartment/two 

parameter), AE 1170437 dissipated with reviewer-calculated non-linear half-lives of 35.5 days 

in the LH AIIIa loam soil, 41.0 days in the Wurmwiese loam soil, 45.3 days in the Hoefchen silt 

loam soil, and 53.7 days in the LH AXXa sandy loam soil, which are consistent with the 

observed DT50 values 45, 27, 28, and 40 days, respectively. Linear half-lives ranged from 43 

days to 62 days. Two transformation products were identified: 

• (2R,3R)-3-({4-amino-6-[(1R)-1-fluoroethyl]-1,3,5-triazin-2-yl}amino)-2,5-

dimethylindan-1-one (AE 1170437-triazine indanone; AE 2158968), and 

• (2S,3R)-3-({4-amino-6-[(1R)-1-fluoroethyl]-1,3,5-triazin-2-yl}amino)-2-methylindane-5-

carboxylic acid (AE 1170437-carboxylic acid; AE 2158969). 

Both transformation products were isolated from all four soils. AE 1170437-triazine indanone 

was a major transformation product in LH AXXa sandy loam soil, Wurmwiese loam soil, and 

Hoefchen silt loam soil. AE 1170437-carboxylic acid was a major transformation product in LH 

AIIIa loam soil, Wurmwiese loam soil, and Hoefchen silt loam soil. CO2 was a major 

transformation product in all four soils. 

Unextracted residues increased over the course of the study in all four soil types. Half-lives were 

recalculated for the parent and unextracted residues. Based on nonlinear regression analyses 

(SigmaPlot v 9; exponential, one compartment/two parameter), AE 1170437 dissipated with 

reviewer-calculated parent and unextracted residues nonlinear half-lives of 70 days in the LH 

AIIIa loam soil, 80.6 days in the Wurmwiese loam soil, 91.2 days in the Hoefchen silt loam soil, 

and 101.9 days in the LH AXXa sandy loam soil. 

A transformation pathway was provided by the study authors. Based on the study results, AE 

1170437 degrades via oxidation of the indanyl moiety to form AE 1170437-triazine indanone 

and AE 1170437-carboxylic acid. Residues are ultimately converted to bound residues and CO2. 

This study is classified as SUPPLEMENTAL. The experiments were terminated after only 122 

days of incubation, at which time 14.9-28.6% of the applied AE 1170437 remained undegraded. 

Also, 122 days may not have been sufficient to accurately establish the pattern of decline of the 

major transformation products. Data should be collected until the decline of the test substance 

and the formation and decline of degradation products are clearly characterized or for one year, 

whichever comes first. This study did not clearly demonstrate that the decline of the parent was 
-Page 203 of 292- 

clearly characterized. Further, replicates were not collected, except at time zero, for three of the 

four soils tested (LH Axxa, LH AIIIa, Wurmwiese). The lack of replicate samples fails to 

address potential variability in the degradation of the parent and the formation and decline of 

transformation products. This study does not satisfy the 835.4100 guideline requirement. 

MRID Number: 47443213 Indaziflam (AE 1170437) 

Stupp, H-P. and T. Augustin. 2007. [Triazine-2,4-14C]AE 1170437: Aerobic soil metabolism in 

4 EU soils. Unpublished study performed and sponsored by Bayer CropScience AG, Monheim, 

Germany, and submitted by Bayer CropScience, Research Triangle Park, North Carolina. Bayer 

CropScience AG Report MEF-06/299. Study Protocol ID.: M1251406-9. Experiment started 

June 16, 2004, and completed May 7, 2007 (p. 6). Final report issued June 25, 2007. 

The biotransformation of [triazine-2,4-14C]-labeled N-[(1R,2S)-2,6-dimethyl-2,3-dihydro-1Hinden-1-yl]-6-[(1R)-1-fluoroethyl]-1,3,5-triazine-2,4-diamine (AE 1170437, radiochemical 

purity >99%) , was studied in four soils from Germany: sandy loam (LH AXXa; pH 6.8, organic 

carbon 1.64%); loam (LH AIIIa; pH 7.1, organic carbon 1.29%); loam (Wurmwiese; pH 6.4, 

organic carbon 2.08%); and a silt loam (Hoefchen; pH 7.2, organic carbon 2.07%). The 

experiments were conducted under aerobic conditions for 120 days in the dark at 19.7 ± 0.2°C 

and 55% of the maximum water holding capacity. Overall recoveries of [14C]residues averaged 

98.2 ± 1.1% (range 96.0-100.1%) in the LH AXXa sandy loam soil; 99.1 ± 1.9% (94.9-101.1%) 

in the LH AIIIa loam soil; 99.3 ± 1.0% (range 96.6-100.7%) in the Wurmwiese sandy loam soil; 

and 99.2 ± 1.5% (range 97.0-102.2%) in the Hoefchen loam soil. There was no significant loss 

of residues over time from any of the soil systems. 

Based on nonlinear (SigmaPlot v. 9.0, exponential, one compartment/two parameter) regression

analyses, AE 1170437 dissipated with reviewer-calculated non-linear half-lives of 34.8 days in 

the Wurmwiese sandy loam soil, 36.1 days in the LH AIIIa loam soil, 45.3 days in the Hoefchen 

loam soil, and 60.3 days in the LH AXXa sandy loam soil; linear half-lives ranged from 44.4-

68.0 days. Three transformation products were identified: 

• (2R,3R)-3-({4-amino-6-[(1R)-1-fluoroethyl]-1,3,5-triazin-2-yl}amino)-2,5-

dimethylindan-1-one (AE 1170437-triazine indanone; AE 2158968), 

• (2S,3R)-3-({4-amino-6-[(1R)-1-fluoroethyl]-1,3,5-triazin-2-yl}amino)-2-methylindane-5-

carboxylic acid (AE 1170437-carboxylic acid; AE 2158969), and 

• 6-[(1R)-1-fluoroethyl]-1,3,5-triazine-2,4-diamine (AE 1170437-diaminotriazine; AE 

1956114). 

All three transformation products were isolated from all four soils. AE 1170437-triazine 

indanone was a major transformation product in LH AXXa sandy loam soil, Wurmwiese sandy 

loam soil, and Hoefchen loam soil. AE 1170437-carboxylic acid was a major transformation 

product in LH AXXa sandy loam soil and LH AIIIa loam soil. AE 1170437-diaminotriazine was 

a major transformation product in all four soils. CO2 was a major transformation product in LH 

AXXa sandy loam soil and Hoefchen loam soil. 

Unextracted residues increased over the course of the study in all four soil types. Half-lives were 
-Page 204 of 292- 

recalculated for the parent and unextracted residues. Based on nonlinear regression analyses 

(SigmaPlot v 9; exponential, one compartment/two parameter), AE 1170437 dissipated with 

reviewer-calculated parent and unextracted residues nonlinear half-lives of 69.3 days in the 

LH AIIIa loam soil, 90 days in the Wurmwiese loam soil, 79.7 days in the Hoefchen silt loam 

soil, and 100.5 days in the LH AXXa sandy loam soil. 

A transformation pathway was provided by the study authors. Based on the study results, 

AE1170437 degrades via oxidation of the indanyl moiety to form AE1170437-triazine indanone 

and AE1170437-carboxylic acid. AE1170437, AE1170437-triazine indanone and AE1170437-

carboxylic acid are cleaved at the N bridge to form AE1170437-diaminotriazine from the triazine 

moiety and unidentified minor compounds from the indanyl moiety. Residues are ultimately 

converted to bound residues and CO2. 

This study is classified as SUPPLEMENTAL. There are no scientific deficiencies that prevent 

the use of these data for the purposes of risk assessment. However, there are deficiencies and 

notable deviations from the OPPTS guideline 835.4100 the experiments were terminated after 

only 120 days of incubation, at which time 15.3-28.7% of the applied AE 1170437 remained 

undegraded. Also, 120 days may not be sufficient to accurately establish the pattern of 

formation and decline of the major transformation products; in all four soils, the maximum 

concentration of AE 1170437-diaminotriazine was measured at the final sampling interval. This 

study did not clearly demonstrate that the decline of the parent was clearly characterized. 

Further, replicates were not collected, except at time zero, for three of the four soils tested (LH 

Axxa, LH AIIIa, Wurmwiese). 

MRID Number: 47443214 Diaminotriazine (AE 1956114) 

Sneikus, J. 2008. [Triazine-2,4-14C] AE1956114 (diaminotriazine): aerobic soil metabolism in 3 

EU soils. Unpublished study performed and sponsored by Bayer CropScience AG, Monheim, 

Germany, and submitted by Bayer CropScience, Research Triangle Park, North Carolina. Bayer 

CropScience AG Report MEF-05/517. Study Number: M12511-6. Experiment started May 30, 

2005 and completed June 9, 2006 (p. 6). Final report issued January 14, 2008. 

The biotransformation of [triazine-2,4-14C]-labeled AE 1170437-diaminotriazine, AE 1956114, a 

transformation product of AE 1170437 (indaziflam), was studied in three soils from Germany: a 

sandy loam (Laacherhof AXXa; LH AXXa; pH 7.7, organic carbon 1.09%), a loam 

(Wurmwiese; pH 6.5, organic carbon 1.39%); and a silt loam (Hoefchen; pH 7.1, organic carbon 

2.18%). The experiments were conducted under aerobic conditions for 120 days in the dark at 

19.7 ± 0.2°C and 55% of the maximum water holding capacity. Overall recoveries of 

[

14C]residues averaged 98.7 ± 2.0% (range 95.7-102.0%) in the Laacherhof AXXa sandy loam 

soil, 97.8 ± 1.8% (93.8-100.6%) in the Wurmwiese loam soil, and 96.8 ± 3.4% (range 90.6-

103.5%) in the Hoefchen silt loam soil. There was no significant loss of residues over time from 

any of the soil systems. Based on nonlinear (SigmaPlot v. 9.0, exponential, one 

compartment/two parameter) regression analyses, AE 1170437-diaminotriazine dissipated with 

reviewer-calculated non-linear half-lives of 14.9 days in the Hoefchen silt loam soil, 42.8 days 

in the Laacherhof AXXa sandy loam soil, and 165.0 days in the Wurmwiese loam soil; linear 

half-lives ranged from 17.2 days to 177.7 days. The half-lives calculated for the Wurmwiese soil 
-Page 205 of 292- 

are of uncertain value because they are extrapolated beyond the 120-day duration of the 

experiment. Only one transformation product was identified: 

• 6-[(1R)-1-fluoroethyl]-1,3,5-triazinane-2,4-dione (AE 1170437-dihydrotriazine). 

AE 1170437-dihydrotriazine was a major transformation product n the Laacherhof AXXa sandy 

loam soil and the Hoefchen silt loam soil. It was not identified in the Wurmwiese loam soil. 

CO2 was a major transformation product in all three soils. 

A transformation pathway was provided by the study author. Based on the study results, AE 

1170437-diaminotriazine degrades to AE 1170437-dihydrotriazine via loss of both amine 

groups. AE 1170437-diaminotriazine and AE 1170437-dihydrotriazine are ultimately converted 

to bound residues and CO2. 

This study is classified as SUPPLEMENTAL. The study was conducted with a transformation 

product of AE 1170437 (diaminotriazine) as the starting material. However, no significant 

deviations from good scientific practices were noted. 

MRID Number: 47443215 Indaziflam, isomers A & B (AE1170437 and AE 1170438) 

Heinemann, O. 2008. AE 1170437 and AE 1170438: comparative aerobic soil degradation in 2 

EU soils. Unpublished study performed and sponsored by Bayer CropScience AG, Monheim, 

Germany, and submitted by Bayer CropScience, Research Triangle Park, North Carolina. Bayer 

CropScience AG Report MEF-08/004. Study Number: M1251704-0. Experiment started 

August 27, 2007, and completed January 15, 2008 (p. 9). Final report issued February 14, 2008. 

The biotransformation of the nonradiolabeled diastereomers AE 1170437 (Isomer A; purity 

98.4%) and AE 1170438 (Isomer B; purity 98.4%) were studied in two soils from Germany: 

a loam (Wurmwiese; pH 5.96, organic carbon 1.50%) and 

a silt loam (Hoefchen; pH 7.22, organic carbon 1.77%). 

In the Wurmwiese loam soil, the concentration of AE 1170437 decreased from 97.4% of the 

applied at time 0 to 63.9% at 21 days posttreatment and 33.7% at 120 days (study termination). 

The concentration of AE 1170438 decreased from 97.2% of the applied at time 0 to 68.9% at 21 

days posttreatment and 39.6% at 120 days. Based on nonlinear (SigmaPlot v. 9.0, exponential, 

one compartment/two parameter) regression analyses, AE 1170437 dissipated with a half-life of 

65.4 days and AE 1170438 dissipated with a half-life of 88.9 days. First order log/linear (Excel 

2003) half-lives for AE 1170437 and AE 1170438 were 78.8 and 101.9 days, respectively. 

In the Hoefchen silt loam soil, AE 1170437 decreased from 97.3% of the applied at time 0 to 

47.4% at 42 days posttreatment and 18.9% at 120 days. AE 1170438 decreased from 96.6% of 

the applied at time 0 to 52.6% at 42 days posttreatment and 23.5% at 120 days. Based on 

nonlinear regression analyses, AE 1170437 dissipated with a half-life of 45.3 days and AE 

1170438 dissipated with a half-life of 54.6 days. First order log/linear half-lives for AE 1170437 

and AE 1170438 were 50.6 and 58.7 days, respectively. 
-Page 206 of 292- 

Transformation products were neither quantified nor identified. Extractable and nonextractable 

soil residues and volatile compounds were not quantified. A transformation pathway was not 

proposed by the study author. A transformation pathway could not be developed based on the 

study results. 

This study is classified as SUPPLEMENTAL. The study was conducted on the two 

diastereoisomers (AE 1170437 and AE 1170438) that are the active compounds in BCS 

AA10717; isomer AE 1170437 (principle active substance) and AE 1170438 (active isomer of 

the principle active substance). The degredation profile of AE 1170438 is similar to AE 

1170437, and both are regarded as active substances in the technical grade material. The 

technical grade substance contains 95% (94.7%) to 100% AE 1170437 and, 0 % to 5 % (5.3 %) 

AE 1170438. Samples were analyzed only for the parent compounds. The test items AE 

1170437 and AE 1170438 were found subject to similar degradation in a typical soil 

environment under aerobic laboratory conditions. Transformation products, extractable and 

unextracted soil residues, and volatile compounds were not quantified. A material balance could 

not be determined. 

Anerobic Soil Metabolism EPA Guideline: 162-2 (835.4200) 

MRID Number: 47443216 Indaziflam (AE 1170437) [triazine-2,4-14C] and [indane-3-

13C/14C]AE 1170437 

Stupp, H-P. 2006. [Triazine-2,4-14C] and [indane-3-13C/14C]AE 1170437: anaerobic soil 

metabolism. Unpublished study performed and sponsored by Bayer CropScience AG, Monheim, 

Germany; and submitted by Bayer CropScience LP, Research Triangle Park, North Carolina (p. 

3). Study No.: M1261526-3. Experimental start date September 7, 2004 and completion date 

September 26, 2006 (p. 6). Final report issued November 30, 2006. 

The biotransformation of [triazine-2,4-14C]- and [indane-3-13C/14C]-labeled (AE 1170437, 

radiochemical purities >99%) was studied in a Hoefchen silt loam soil from Germany for 180 

days under anaerobic conditions. Soil moisture content during the aerobic portion of the study 

was 55% of the maximum water holding capacity. AE 1170437 was applied at 0.4 mg a.i./kg 

soil, which was reported to be equivalent to a field rate of 150 g a.i./ha. the anaerobic phase of 

the study, AE 1170437 was stable; the calculated linear and nonlinear half-lives (combined 

labels) of >7,000 days for the soil and total system are of highly uncertain value because they are 

extrapolated far beyond the duration of the study. Three transformation products were identified: 

• (2R,3R)-3-({4-amino-6-[(1R)-1-fluoroethyl]-1,3,5-triazin-2-yl}amino)-2,5-

dimethylindan-1-one (AE 1170437-triazine indanone; AE 2158968), 

• (2S,3R)-3-({4-amino-6-[(1R)-1-fluoroethyl]-1,3,5-triazin-2-yl}amino)-2-methylindane-5-

carboxylic acid (AE 1170437-carboxylic acid; AE 2158969), and 

• 6-[(1R)-1-fluoroethyl]-1,3,5-triazine-2,4-diamine (AE 1170437-diaminotriazine; AE 

1956114). 
-Page 207 of 292- 

This study is classified as ACCEPTABLE. No deviations from good scientific practices were 

noted. 

Aerobic Aquatic Metabolism EPA Guideline: 162-4 (835.4300) 

MRID Number: 47443217 [Triazine-2,4-14C] and [indane-3-13/14C] labeled AE1170437 

Stupp, H.P. 2007. [Triazine-2,4-14C] and [indane-3-13/14C]AE 1170437: aerobic aquatic 

metabolism. Unpublished study performed and sponsored by Bayer CropScience AG, Monheim, 

Germany, and submitted by Bayer CropScience, Research Triangle Park, North Carolina. Bayer 

CropScience AG Report MEF-07/283. Bayer CropScience Study No.: M1511579-9. Lynx ID: 

MEUFX007/MEDHP015. Experiment started March 7, 2006, and completed May 16, 2007 (p. 

6). Final report issued November 8, 2007. 

The biotransformation of [triazine-2,4-14C]- and [indane-3-13/14C]-labeled AE 1170437 

(radiochemical purity >98%) in two water-sediment systems from Germany: a sand;gravel pit 

lake water system (“Angler Weiher”, water: pH 7.4, total organic carbon <2 mg/L, sediment: pH 

6.9, organic carbon 0.68%) from Germany; and a loam:pond water system (“Hoenniger Weiher”, 

water: pH 7.3, total organic carbon <2 mg/L, sediment: pH 6.3, organic carbon 2.9%). In the 

Angler water:sand sediment systems, redox potentials ranged from +141 to +230 in the water 

and from +137 to +213 in the sediment. In the Hoenniger water:loam sediment systems, redox 

potentials ranged from +185 to +208 in the water and from +162 to +200 in the sediment. 

Dissolved oxygen content of the water of both systems ranged from 83.6% to 95.6%. There was 

no evidence that the aerobicity of any systems was decreasing over time. Based on nonlinear 

regression analysis (SigmaPlot v. 9.0, exponential, one compartment/two parameter), AE 

1170437 (combined label data) dissipated with a half-life of 119.5 days (13.8 days in water, 

173.3 days in sediment) in the Angler pond water-sand sediment total system and 239.0 days (3.6 

days in water, 407.7 days in sediment) in the Hoenniger water-loam sediment total system. 

Linear (Excel 2003) half-lives were 126.0 days for the Angler total system and 247.6 days for the 

Hoenniger total system. Calculated half-lives for the Angler sand sediment and for the 

Hoennigher total system and sediment are of uncertain value because they are extrapolated 

beyond the 120-day duration of the study. Three transformation products were identified: 

• (2R,3R)-3-({4-amino-6-[(1R)-1-fluoroethyl]-1,3,5-triazin-2-yl}amino)-2,5-

dimethylindan-1-one (AE 1170437-triazine indanone; AE 2158968; both labels); 

• (2S,3R)-3-({4-amino-6-[(1R)-1-fluoroethyl]-1,3,5-triazin-2-yl}amino)-2-methylindane-5-

carboxylic acid (AE 1170437-carboxylic acid; AE 2158969; both labels); and 

• 6-[(1R)-1-fluoroethyl]-1,3,5-triazine-2,4-diamine (AE 1170437-diaminotriazine; AE 

1956114; triazine label only). 

All three compounds were major transformation products in the Angler water-sand sediment 

system and minor transformation products in the Hoenniger water-loam sediment system. AE 

1170437-triazine indanone was primarily associated with the sediment. AE 1170437-carboxylic 

acid was primarily associated with the water. AE 1170437-diaminotriazine was primarily 

associated with the water in the Angler water-sand sediment system and with the sediment in the 
-Page 208 of 292- 

Hoenniger water-loam sediment system. 

This study is classified as SUPPLEMENTAL. The study was terminated at 120 days when ca. 

50% of the parent remained undegraded, decline of the parent cannot be accurately 

characterized. Further, major metabolites (>10% of AR) were increasing at the termination of 

the study (120 d), therefore formation and decline of the degradates cannot be accurately 

characterized and may be persistent in the aquatic environment. 

Anerobic Aquatic Metabolism EPA Guideline: 162-3 (835.4400) 

MRID 47443218 [Indane-3-13C/14C] labeled AE 1170437

Mathew, A. 2007. [Indane-3-13C/14C]AE 1170437: Anaerobic aquatic metabolism. Unpublished 

study performed by Bayer CropScience, Stilwell, Kansas; sponsored and submitted by Bayer 

CropScience, Research Triangle Park, North Carolina. Study and Report No.: MEDHP017. 

Experiment started May 1, 2006, and completed November 9, 2006 (p. 6). Final report issued 

July 2, 2007. 

The biotransformation of [indane-3-13C/14C]-labeled AE 1170437 was studied in pond water-clay 

loam sediment from Kansas under anaerobic (static, nitrogen atmosphere) conditions in 

darkness. [14C]AE 1170437 was stable in the total system, averaging 99.9% of the applied at 

time 0, 93.1-98.7% with no pattern of decline at 3-91 days posttreatment, and 98.0% at 199 days. 

[

14C]AE 1170437 quickly partitioned from the water to the sediment, decreasing in the water 

from an average 94.5% of the applied at time 0 to 51.9% at 3 days posttreatment, 18.5% at 15 

days, and 7.9% at 119 days. In the sediment, [14C]AE 1170437 increased from 5.4% of the 

applied at time 0 to 66.6% at 7 days posttreatment and a maximum 90.2% at 119 days. Halflives could not be calculated for the sediment or total system. AE 1170437 dissipated from the 

water with a reviewer-calculated nonlinear (SigmaPlot v 9, exponential, one compartment/two 

parameter) half-life of 4.9 days. No major transformation products were isolated, and no minor 

transformation products were identified in either the water or sediment. 

This study is classified as ACCEPTABLE. However, it is important to note that redox 

potentials for water and sediment were +164.9 and 163.4 mV, respectively. These Eh values are 

classified by (Wolfe et al., 1990) as only moderately reducing. No other significant deviations 

from good scientific practices were noted. 

MRID 47443219 [Triazine-2,4-14C] labeled AE 1170437 

Mathew, A. 2007. [Triazine-2,4-14C]AE 1170437: Anaerobic aquatic metabolism. Unpublished 

study performed by Bayer CropScience, Stilwell, Kansas; sponsored and submitted by Bayer 

CropScience, Research Triangle Park, North Carolina. Study and Report No.: MEDHP022. 

Experiment started April 3, 2006 and completed November 9, 2006 (p. 6). Final report issued 

June 12, 2007. 

The biotransformation of [triazine-2,4-14C]-labeled AE 1170437 was studied in pond water-clay 

loam sediment from Kansas for 122 days under anaerobic (static, nitrogen atmosphere) 
-Page 209 of 292- 

conditions in darkness. [14C]AE 1170437 was applied at a rate of 0.08 mg a.i./L, which is 

equivalent to 5X an overspray field application rate of 150 g a.i./ha. Overall [14C]residue 

recoveries averaged 99.3 ± 1.8% of the applied (range 95.1-101.2%) in the water-clay loam 

sediment systems. There was no significant loss of [14C]residues from the systems over time. 

[

14C]AE 1170437 was relatively stable in the total system, averaging 99.6% of the applied at 

time 0, 93.1-98.7% at 3-93 days posttreatment, and 94.7% at 122 days. [14C]AE 1170437 

quickly partitioned from the water to the sediment, decreasing in the water from an average 

92.0% of the applied at time 0 to 50.2% at 3 days posttreatment, 21.3% at 15 days, and 7.7% at 

122 days. In the sediment, [14C]AE 1170437 increased from 7.7% at time 0 to a maximum 

88.7% at 93 days and was 87.0% at 122 days.Half-lives could not be calculated for the sediment 

or total system. AE 1170437 dissipated from the water with a reviewer-calculated nonlinear 

(SigmaPlot v 9, exponential, one compartment/two parameter) half-life of 5.2 days. No major 

transformation products were isolated, and no minor transformation products were identified in 

either the water or sediment. 

This study is classified as ACCEPTABLE. However it should be noted that redox potential in 

the water layer and sediment were 141.8 mV and 136.8 mV, respectively. These Eh values are 

classified by (Wolfe et al., 1990) as only moderately reducing. Further, dissolved oxygen in the 

water averaged 0.1 mg/L. No other significant deviations from good scientific practices were 

noted 

Terrestrial Field Dissipation EPA Guideline: 164-1 (835.6100) 

MRID 47443220 Indaziflam (AE1170437) 

Lenz, M. 2008. Terrestrial field dissipation of AE 1170437 in California soil cropped with turf, 

2006. Unpublished study performed by Bayer CropScience, Stilwell, Kansas (study director and 

analytical phase), Agvise Laboratories, Northwood, North Dakota, and Research for Hire, Inc., 

Porterville, California (field phase), and sponsored and submitted by Bayer CropScience, 

Research Triangle Park, North Carolina (p. 46). Study No.: MEDHP014. Experiment initiation 

April 25, 2006, and completion January 17, 2008 (pp. 12-13, 46). Final report issued June 30, 

2008. 

Soil dissipation/accumulation of AE 1170437 under U.S. field conditions was studied in a turf 

plot of Nord sandy loam soil at one site in California. AE 1170437 was broadcast once at a 

nominal rate of 0.165 kg a.i./ha (0.147 lb a.i./A) onto four 16.7 x 6.1 m replicate plots. The target 

application rate was 110% of the maximum label rate of 0.150 kg a.i./ha. Rainfall was 

supplemented with irrigation to exceed 500% of the 30-year average rainfall during the study 

period. AE 1170437 decreased to a mean concentration of 33.08 ng a.i./g in the 0-15 cm depth 

by 14 days, 21.17 ng a.i./g by 28 days, 13.07 ng a.i./g by 58 days, 4.59 ng a.i./g by 121 days, 

ranged from 2.10-2.12 ng a.i./g from 269 to 367 days, and was detected at a mean concentration 

below the LOQ at 531 days posttreatment. AE 1170437 was detected in the 15-30 cm depth at 

mean concentrations below the LOQ at 1, 7, 14, and 58 days posttreatment. AE 1170437 was not 

detected below the 30-cm depth with the exception of two single replicate detections in the 30-45 

and 45-60 cm depths at 14 days posttreatment. The most prevalent transformation products were 
-Page 210 of 292- 

AE 1170437 diaminotriazine, AE 1170437 triazine-indanone, and AE 1170437 carboxylic acid, 

which were detected in the 0-15 cm depth at maximum mean concentrations of 5.5% (at 58 

days), 6.9% (at 58 days), and 5.1% (at 28 days) of the theoretical day 0 recovery of AE 1170437, 

respectively, after converting to parent equivalents. No transformation products were detected at 

a mean concentration above the LOQ in soil below the 0-15 cm depth, excluding a mean 

detection of AE 1170437 diaminotriazine in the 15-30 cm depth at 121 days (mean of two 

replicate samples), single replicate detections of AE 1170437 triazine-indanone in each of the 

15-30, 30-45, and 45-60 cm depths at 14 days, and a single replicate detection of AE 1170437 

carboxylic acid in the 30-45 cm depth at 14 days. No transformation products were detected in 

soil below 60 cm. 

Under field conditions at the test site, AE 1170437 had a reviewer-calculated half-life value of 

68.0 days (r2

 = 0.8278) in soil, calculated using linear regression of ln-transformed data from the 

0-15 cm soil layer only. The dissipation was observed to be bi-phasic therefore the reviewer 

calculated a half-life of 25.7 days (r2

 = 0.9686) using Sigmaplot v 9.0 (nonlinear, onecompartment/two-parameter) and individual sample data (0-367 day data; replicate values below 

the LOQ were assumed at 1⁄2(LOQ + LOD)). The observed DT50 value occurred between the 14- 

and 28-day sampling intervals (21 days; reviewer-calculated). The observed DT90 value 

occurred between the 58- and 121-day sampling intervals (114 days; reviewer-calculated). Total 

carryover of residues at the end of the study period (531 days) was 2.2% of the applied amount, 

based on the target application rate (0.6% as AE 1170437, 0.9% as AE 1170437 triazineindanone and 0.7% as AE 1170437 carboxylic acid; reviewer-calculated based on mean 

concentrations below the LOQ). 

The major route of dissipation of AE 1170437 under terrestrial field conditions was 

transformation to AE 1170437 diaminotriazine, AE 1170437 triazine-indanone, and AE 1170437 

carboxylic acid. 

This study is classified SUPPLEMENTAL. The stability of AE 1170437 and its transformation 

products under typical laboratory storage conditions was not clearly demonstrated as field 

samples were stored over 100 days longer than in the laboratory storage study (MRID 

47443279). An additional storage stability study (MRID 47743328) was submitted for a 

sufficient duration, but still demonstrated slow decline in the recoveries of the indaziflam-olefin 

degradate. 

MRID 47443221 Indaziflam (AE1170437) 

Lenz, M. 2008. Terrestrial field dissipation of AE 1170437 in Florida soil cropped with turf, 

2006. Unpublished study performed by Bayer CropScience, Stilwell, Kansas (study director and 

analytical phase), Agvise Laboratories, Northwood, North Dakota and Ag Research Associates, 

Sycamore, Georgia (field phase), and sponsored and submitted by Bayer CropScience, Research 

Triangle Park, North Carolina (p. 46). Study No.: MEDHP035. Experiment initiation April 4, 

2006, and completion January 5, 2008 (pp. 12-13). Final report issued June 30, 2008. 

Soil dissipation/accumulation of AE 1170437 under U.S. field conditions was studied in a turf 

plot of Lucy loamy sand soil at one site in Florida. AE 1170437 was broadcast once at a nominal 
-Page 211 of 292- 

rate of 0.165 kg a.i./ha (0.147 lb a.i./A) onto four 16.4 x 7.3 m replicate plots. The target 

application rate was 110% of the maximum label rate of 0.150 kg a.i./ha. Rainfall was 

supplemented with irrigation to reach 108% of the 30-year average rainfall during the study 

period. Soil samples were collected prior to application and at 0, 1, 3, 7, 14, 28, 59, 134, 182, 

280, 366, and 526 days following application to a depth of 0-120 cm, excluding day 0 samples 

which were collected to a depth of 15 cm. The mean measured concentration of AE 1170437 in 

the 0-15 cm soil depth was 36.96 ng a.i./g at day 0, and was a maximum of 38.89 ng a.i./g at 1 

day, which is 52.8% of the theoretical (reviewer-calculated based on the theoretical day 0 

concentration of 74 ng a.i./g in the 0-15 cm soil depth). AE 1170437 decreased to a mean 

concentration of 29.31 ng a.i./g in the 0-15 cm depth by 28 days, 21.07 ng a.i./g by 59 days, 8.68 

ng a.i./g by 134 days, 4.30 ng a.i./g by 182 days, 2.01 ng a.i./g by 366 days, and was detected at a 

mean concentration below the LOQ at 526 days posttreatment. AE 1170437 was only detected in 

individual replicate samples in the 15-30 cm soil depth, at concentrations ranging from <LOQ to 

3.97 ng a.i./g (at 1, 3, 14, 59, and 366 days posttreatment), and was not detected below the 30-cm 

depth. The most prevalent transformation products were AE 1170437 diaminotriazine, AE 

1170437 triazine-indanone, and AE 1170437 carboxylic acid, which were detected in the 0-15 

cm depth at maximum mean concentrations of 10.5% (at 134 days), 6.1% (at 59 days), and 2.6% 

(at 28 days) of the theoretical day 0 recovery of AE 1170437, respectively, after converting to 

parent equivalents. 

Under field conditions at the test site, AE 1170437 had a reviewer-calculated half-life value of 

92.4 days (r2

 = 0.9217) in soil, calculated using linear regression of ln-transformed data based on 

all replicate concentration data from the 0-15 cm soil layer. However, the dissipation pattern 

was bi-phasic, with a more rapid dissipation phase over the initial six months of the study; linear 

regression analysis did not accurately describe the dissipation using the 0- to 526-day data set. 

The reviewer calculated a half-life of 66.6 days (r2

 = 0.9853). The observed DT50 value 

occurred between the 59- and 134-day sampling intervals (68 days; reviewer-calculated). The 

observed DT90 value occurred between the 182- and 280-day sampling intervals (208 days; 

reviewer-calculated). Total carryover of residues at the end of the study period (526 days) was 

7.1% of the applied amount, based on the target application rate (1.6% as AE 1170437, 4.1% as 

AE 1170437 diaminotriazine, and 1.4% as AE 1170437 triazine-indanone; reviewer-calculated 

based on mean concentrations below the LOQ). The major route of dissipation of AE 1170437 

under terrestrial field conditions was transformation to AE 1170437 diaminotriazine, AE 

1170437 triazine-indanone, and AE 1170437 carboxylic acid. 

This study is classified SUPPLEMENTAL. No significant deviations from good scientific 

practices were noted. However, the stability of AE 1170437 and its transformation products 

under typical laboratory storage conditions was not clearly demonstrated. An additional storage 

stability study (MRID 47743328) was submitted for a sufficient duration, but still demonstrated 

slow decline in the recoveries of the indaziflam-olefin degradate. 

MRID 47443222 Indaziflam (AE1170437) 

Lenz, M. 2008. Terrestrial field dissipation of AE 1170437 in North Carolina soil cropped with 

turf, 2006. Unpublished study performed by Bayer CropScience, Stilwell, Kansas (study director 
-Page 212 of 292- 

and analytical phase), Agvise Laboratories, Northwood, North Dakota, and Agricultural Systems 

Associates, Kinston, North Carolina (field phase), and sponsored and submitted by Bayer 

CropScience, Research Triangle Park, North Carolina (p. 46). Study No.: MEDHP034. 

Experiment initiation April 19, 2006, and completion January 4, 2008 (p. 12). Final report issued 

June 30, 2008. 

Soil dissipation/accumulation of AE 1170437 under U.S. field conditions was investigated in a 

turf plot of Norfolk loamy sand soil at one site in North Carolina. AE 1170437 was broadcast 

once at a nominal rate of 0.165 kg a.i./ha (0.147 lb a.i./A) onto four 16.4 x 7.3 m replicate plots. 

The target application rate was 110% of the maximum label rate of 0.150 kg a.i./ha. Rainfall was 

supplemented with irrigation to reach 115% of the 30-year average rainfall during the study 

period. Soil samples were collected prior to application and at 0, 1, 3, 6, 14, 29, 58, 126, 166, 

280, 374, and 554 days following application, to a depth of 120 cm, excluding day 0 samples 

which were collected to a depth of 15 cm. The mean measured concentration of AE 1170437 in 

the 0-15 cm soil depth was 38.15 ng a.i./g at day 0, and was a maximum of 41.85 ng a.i./g at 1 

day, which is 57.2% of the theoretical (reviewer-calculated based on the theoretical day 0 

concentration of 73 ng a.i./g in the 0-15 cm soil depth). AE 1170437 decreased to a mean 

concentration of 26.74 ng a.i./g in the 0-15 cm depth by 29 days, 19.32 ng a.i./g by 58 days, 

11.23 ng a.i./g by 126 days, 5.39-5.63 ng a.i./g by 280-374 days, and was 4.09 ng a.i./g at 554 

days posttreatment. AE 1170437 was detected in individual replicate samples in the 15-30 cm 

soil depth, at concentrations ranging from <LOQ to 1.78 ng a.i./g (at 1, 3, 14, 29, 58, 280, and 

554 days posttreatment), and was not detected below 30 cm. The most prevalent transformation 

products were AE 1170437 triazine-indanone and AE 1170437 carboxylic acid, which were 

detected in the 0-15 cm depth at maximum mean concentrations of 5.9% (at 58 days) and 2.5% 

(at 29 days) of the theoretical day 0 recovery of AE 1170437, respectively, after converting to 

parent equivalents. No transformation products were detected at a mean concentration above the 

LOQ in soil below the 0-15 cm depth, and no transformation products were detected below 45 

cm. 

Under field conditions at the test site, AE 1170437 had a reviewer-calculated half-life value of 

154 days (r2

 = 0.8080) in soil, calculated using linear regression of ln-transformed data based on 

all replicate concentration data from the 0-15 cm soil layer. However, the dissipation pattern 

was bi-phasic, with a more rapid dissipation phase over the initial six months of the study; linear 

regression analysis did not accurately describe the dissipation using the 0- to 554-day data set. 

The reviewer calculated a half-life of 69.3 days (r2

 = 0.9586) using Sigmaplot v 9.0 (nonlinear, 

one-compartment/two-parameter) and individual sample data (0-554 day data). The observed 

DT50 value occurred at approximately the 58-day sampling interval. The observed DT90 

occurred after the last sampling interval. Total carryover of residues at the end of the study 

period (554 days) was 11.4% of the applied amount based on the target application rate (6.1% as 

AE 1170437, 3.6% as AE 1170437 triazine-indanone, and 1.7% as AE 1170437 diaminotriazine; 

reviewer-calculated). The major route of dissipation of AE 1170437 under terrestrial field 

conditions was transformation to AE 1170437 triazine-indanone and AE 1170437 carboxylic 

acid. 

This study is classified SUPPLEMENTAL. No significant deviations from good scientific 
-Page 213 of 292- 

practices were noted. However, the stability of AE 1170437 and its transformation products 

under typical laboratory storage conditions was not clearly demonstrated as field samples were 

stored over 100 days longer than in the laboratory storage study (MRID 47443279). An 

additional storage stability study (MRID 47743328) was submitted for a sufficient duration, but 

still demonstrated slow decline in the recoveries of the indaziflam-olefin degradate. 

MRID 47443223 Indaziflam (AE1170437) 

Lenz, M. 2008. Terrestrial field dissipation of AE 1170437 in California soil, 2006. Unpublished 

study performed by Bayer CropScience, Stilwell, Kansas (study director and analytical phase), 

Agvise Laboratories, Northwood, North Dakota, and Research for Hire, Inc., Porterville, 

California (field phase), and sponsored and submitted by Bayer CropScience, Research Triangle 

Park, North Carolina (p. 47). Study No.: MEDHP038. Experiment initiation April 25, 2006, and 

completion January 2, 2008 (p. 13). Final report issued June 30, 2008. 

Soil dissipation/accumulation of AE 1170437 under U.S. field conditions was investigated in a 

bare plot of Nord sandy loam soil at one site in California. AE 1170437 was broadcast once at a 

nominal rate of 0.165 kg a.i./ha (0.147 lb a.i./A) onto four 18.2 x 6.1 m replicate plots. The target 

application rate was 110% of the maximum label rate of 0.150 kg a.i./ha. Rainfall was 

supplemented with irrigation to exceed 500% of the 30-year average rainfall during the study 

period. 

The mean measured concentration of AE 1170437 in the 0-15 cm soil depth was 49.50 ng a.i./g 

at day 0, which is 59.0% of the theoretical (reviewer-calculated based on the theoretical day 0 

concentration of 84 ng a.i./g in the 0-15 cm soil depth). AE 1170437 decreased to a mean 

concentration of 27.88 ng a.i./g in the 0-15 cm depth by 7 days, 8.62-15.29 ng a.i./g by 14-58 

days, 3.41 ng a.i./g by 121 days, 1.96-2.39 ng a.i./g by 176-367 days, and was detected at a mean 

concentration below the LOQ at 531 days posttreatment. AE 1170437 was detected in the 15-30 

cm depth at mean concentrations below the LOQ at 1, 3, and 7 days posttreatment. AE 1170437 

was not detected below the 30-cm depth, with the exception of a single replicate detection in the 

30-45 cm depth at 1 day posttreatment. The most prevalent transformation products were AE 

1170437 diaminotriazine, AE 1170437 triazine-indanone, and AE 1170437 carboxylic acid, 

which were detected in the 0-15 cm depth at maximum mean concentrations of 17.6% (at 28 

days), 7.6% (at 14 days), and 4.6% (at 14 days) of the theoretical day 0 recovery of AE 1170437, 

respectively, after converting to parent equivalents. No transformation products were detected at 

a mean concentration above the LOQ in soil below the 0-15 cm depth, with the exception of two 

detections of AE 1170437 diaminotriazine in the 15-30 cm depth at 121 days and 176 days 

(mean of three replicate samples). AE 1170437 Diaminotriazine was detected below the LOQ 

from 121 to 367 days in the 30-45 cm depth, and at 121 days in the 45-60 cm depth. 

AE 1170437 had a reviewer-calculated half-life value of 76.2 days (r2

 = 0.7185) in soil, 

calculated using linear regression of ln-transformed data based on all replicate concentration data 

from the 0-15 cm soil layer. However, the dissipation pattern was bi-phasic, with a more rapid 

dissipation phase during the initial month of the study; linear regression analysis did not 

accurately describe the dissipation using the 0- to 367-day data set. The reviewer calculated a 
-Page 214 of 292- 

half-life of 9.3 days (r2 = 0.9726) using Sigmaplot v 9.0 (nonlinear, one-compartment/twoparameter) and individual sample data (0-367 day data; replicate values below the LOQ were 

assumed at 1⁄2(LOQ + LOD)). The observed DT50 value occurred between the 7- and 14-day 

sampling intervals (9 days; reviewer-calculated). The observed DT90 value occurred between the 

58- and 121-day sampling intervals (109 days; reviewer-calculated). Total carryover of residues 

at the end of the study period (531 days) was 5.9% of the applied amount based on the target 

application rate (0.8% as AE 1170437, 4.0% as AE 1170437 diaminotriazine, 0.5% as AE 

1170437 triazine-indanone, and 0.6% as AE 1170437 carboxylic acid; reviewer-calculated). 

The major route of dissipation of AE 1170437 under terrestrial field conditions was 

transformation to AE 1170437 diaminotriazine, AE 1170437 triazine-indanone, and AE 1170437 

carboxylic acid. 

This study is classified SUPPLEMENTAL. No significant deviations from good scientific 

practices were noted. However, the stability of AE 1170437 and its transformation products 

under typical laboratory storage conditions was not clearly demonstrated as field samples were 

stored over 100 days longer than in the laboratory storage study (MRID 47443279). An 

additional storage stability study (MRID 47743328) was submitted for a sufficient duration, but 

still demonstrated slow decline in the recoveries of the indaziflam-olefin degradate. 

MRID 47443224 Indaziflam (AE1170437) 

Lenz, M. 2008. Terrestrial field dissipation of AE 1170437 in Florida soil, 2006. Unpublished 

study performed by Bayer CropScience, Stilwell, Kansas (study director and analytical phase), 

Agvise Laboratories, Northwood, North Dakota, and Ag Research Associates, Sycamore, 

Georgia (field phase), and sponsored and submitted by Bayer CropScience, Research Triangle 

Park, North Carolina (p. 46). Study No.: MEDHP037. Experiment initiation April 4, 2006, and 

completion January 17, 2008 (p. 12). Final report issued June 30, 2008. 

Soil dissipation/accumulation of AE 1170437 under U.S. field conditions was investigated in a 

bare plot of Lucy sand/loamy sand soil at one site in Florida. AE 1170437 was broadcast once at 

a nominal rate of 0.165 kg a.i./ha (0.147 lb a.i./A) onto four 16.4 x 7.3 m replicate plots. The 

target application rate was 110% of the maximum label rate of 0.150 kg a.i./ha. Rainfall was 

supplemented with irrigation to reach 108% of the 30-year average rainfall during the study 

period. Mean recovery of AE 1170437 from the application monitor pads was 111% of the 

target application rate (reviewer-calculated; 122% of the proposed maximum label rate of 150 g 

a.i./ha). The mean measured concentration of AE 1170437 in the 0-15 cm soil depth was a 

maximum of 66.37 ng a.i./g at day 0, which is 88.2% of the theoretical (reviewer-calculated 

based on the theoretical day 0 concentration of 75 ng a.i./g in the 0-15 cm soil depth). AE 

1170437 decreased to a mean concentration of 37.10 ng a.i./g in the 0-15 cm depth by 28 days, 

29.02 ng a.i./g by 59 days, 14.39 ng a.i./g by 134 days, 5.30 ng a.i./g by 280 days, and 2.38 ng 

a.i./g at 526 days posttreatment. AE 1170437 was initially detected in the 15-30 cm soil depth at 

a mean concentration of 8.23 ng a.i./g at 3 days (mean of two replicate detections), was a 

maximum of 23.28 ng a.i./g at 14 days (single replicate detection), was detected below the LOQ 

at 28 and 280 days (single replicate detections), and was last detected at 4.79 ng a.i./g at 366 
-Page 215 of 292- 

days posttreatment (single replicate detection). AE 1170437 was only detected once in the 30-45 

cm depth (at 3 days) and twice in the 45-60 cm depth (at 3 and 366 days), at concentrations 

below the LOQ (all detections were single replicate detections). The most prevalent 

transformation products were AE 1170437 diaminotriazine, AE 1170437 triazine-indanone, 

and AE 1170437 carboxylic acid, which were detected in the 0-15 cm depth soil layer at 

maximum mean concentrations of 9.7% (at 134 days), 3.7% (at 7 days), and 2.3% (at 7 days) of 

the theoretical day 0 recovery of AE 1170437, respectively, after converting to parent 

equivalents. No transformation products were detected at a mean concentration above the LOQ 

in soil below the 0-15 cm depth, and none were detected below 30 cm, with the exception of two 

single replicate detections of AE 1170437 diaminotriazine in the 30-45 cm depth at 182 and 366 

days posttreatment. 

AE 1170437 had a reviewer-calculated half-life value of 107 days (r2

 = 0.9040) in soil, 

calculated using linear regression of ln-transformed data based on all replicate concentration data 

from the 0-15 cm soil layer. However, the dissipation pattern was bi-phasic, with a more rapid 

dissipation phase over the initial six months of the study; linear regression analysis did not 

accurately describe the dissipation using the 0- to 526-day data set. The reviewer calculated a 

half-life of 59.2 days (r2

 = 0.9613) using Sigmaplot v 9.0 (nonlinear, one-compartment/twoparameter) and individual sample data (0-526 day data). The observed DT50 value occurred 

between the 28- and 59-day sampling intervals (43 days; reviewer-calculated). The observed 

DT90 value occurred between the 182- and 280-day sampling intervals (224 days; reviewercalculated). Total carryover of residues at the end of the study period (526 days) was 10.9% of 

the applied amount based on the target application rate (3.2% as AE 1170437, 6.5% as AE 

1170437 diaminotriazine, 0.5% as AE 1170437 triazine-indanone, and 0.8% as AE 1170437 

carboxylic acid; reviewer-calculated). 

The major route of dissipation of AE 1170437 under terrestrial field conditions was 

transformation to AE 1170437 diaminotriazine, AE 1170437 triazine-indanone, and AE 1170437 

carboxylic acid. 

This study is classified SUPPLEMENTAL. However, the stability of AE 1170437 and its 

transformation products under typical laboratory storage conditions was not clearly demonstrated 

as field samples were stored over 100 days longer than in the laboratory storage study (MRID 

47443279). An additional storage stability study (MRID 47743328) was submitted for a 

sufficient duration, but still demonstrated slow decline in the recoveries of the indaziflam-olefin 

degradate. 

MRID 47443225 Indaziflam (AE1170437) 

Lenz, M. 2008. Terrestrial field dissipation of AE 1170437 in North Carolina soil, 2006. 

Unpublished study performed by Bayer CropScience, Stilwell, Kansas (study director and 

analytical phase), Agvise Laboratories, Northwood, North Dakota, and Agricultural Systems 

Associates, Kinston, North Carolina (field phase), and sponsored and submitted by Bayer 

CropScience, Research Triangle Park, North Carolina (p. 46). Study No.: MEDHP036. 

Experiment initiation April 19, 2006, and completion January 1, 2008 (p. 12). Final report issued 
-Page 216 of 292- 

June 30, 2008. 

Soil dissipation/accumulation of AE 1170437 under U.S. field conditions was investigated in a 

bare plot of Norfolk loamy sand soil at one site in North Carolina. AE 1170437 was broadcast 

once at a nominal rate of 0.165 kg a.i./ha (0.147 lb a.i./A) onto four 16.4 x 7.3 m replicate plots. 

The target application rate was 110% of the maximum label rate of 0.150 kg a.i./ha. Rainfall was 

supplemented with irrigation to reach 115% of the 30-year average rainfall during the study 

period. Mean recovery of AE 1170437 from the application monitor pads was 97.2% of the 

target application rate (reviewer-calculated; 107% of the proposed maximum label rate of 150 g 

a.i./ha). The mean measured concentration of AE 1170437 in the 0-15 cm soil depth was 45.09 

ng a.i./g at day 0, and was a maximum of 46.35 ng a.i./g at 1 day, which is 59.1% of the 

theoretical (reviewer-calculated based on the theoretical day 0 concentration of 78 ng a.i./g in the 

0-15 cm soil depth). AE 1170437 decreased to a mean concentration of 24.61 ng a.i./g in the 0-

15 cm depth by 29 days, 16.84 ng a.i./g by 58 days, 8.05 ng a.i./g by 126 days, 4.08-6.84 ng 

a.i./g by 166-374 days, and was 2.91 ng a.i./g at 554 days posttreatment. AE 1170437 was not 

detected in soil below the 0-15 cm depth, with the exception of a single replicate detection below 

the LOQ in the 45-60 cm depth (at 58 days posttreatment). The most prevalent transformation 

product was AE 1170437 triazine-indanone, which was detected in the 0-15 cm depth at a 

maximum mean concentration of 4.1% (at 58 days) of the theoretical day 0 recovery of AE 

1170437, after converting to parent equivalents. The transformation products AE 1170437 

diaminotriazine and AE 1170437 carboxylic acid were not detected at a mean concentration 

above the LOQ at any sampling interval; however, both analytes were detected consistently at 

mean concentrations below the LOQ in the 0-15 cm soil depth from 1 to 554 days posttreatment. 

No transformation products were detected at a mean concentration above the LOQ in soil below 

the 0-15 cm depth. However, AE 1170437 diaminotriazine was detected at levels below the LOQ 

in all depths analyzed (all five detections in the 30-45 cm depth and both detections in the 45-60 

cm depth were single replicate detections). 

Under field conditions at the test site, AE 1170437 had a reviewer-calculated half-life value of 

131 days (r2

 = 0.7295) in soil, calculated using linear regression of ln-transformed data. The 

observed DT50 value occurred between the 29- and 58-day sampling intervals (37 days; 

reviewer-calculated). The observed DT90 value occurred between the 280- and 374-day 

sampling intervals (359 days; reviewer-calculated). Total carryover of residues at the end of the 

study period (554 days) was 11.7% of the applied amount based on the target application rate 

(3.7% as AE 1170437, 5.0% as AE 1170437 diaminotriazine, 1.9% as AE 1170437 triazineindanone, and 1.1% as AE 1170437 carboxylic acid; reviewer-calculated). 

The major route of dissipation of AE 1170437 under terrestrial field conditions was 

transformation to AE 1170437 triazine-indanone. 

This study is classified SUPPLEMENTAL. No significant deviations from good scientific 

practices were noted. However, the stability of AE 1170437 and its transformation products 

under typical laboratory storage conditions was not clearly demonstrated field samples were 

stored longer than the laboratory storage study (MRID 47443279). An additional storage 

stability study (MRID 47743328) was submitted for a sufficient duration, but still demonstrated 
-Page 217 of 292- 

slow decline in the recoveries of the indaziflam-olefin degradate. 

However, the dissipation pattern was bi-phasic, with a more rapid dissipation phase over the 

initial six months of the study; linear regression analysis did not accurately describe the 

dissipation using the 0- to 554-day data set. The reviewer calculated a half-life of 45.0 days (r2

 = 

0.9501). 

MRID 47743301 Indaziflam (AE1170437) 

A study conducted on loamy sand soil (Quincy soil series) in Ephrata, Washington (MRID 

47443301). Soil samples were collected (0-120 cm depth, excluding day 0 samples collected to 

a depth of 15 cm) through 531 days after treatment. The mean measured concentration of 

indaziflam in the 0-15 cm soil depth was 58.44 ng a.i./g at day 0, which is 72.4% of the 

theoretical day 0 concentration. Indaziflam was not detected above the LOQ at depths greater 

than 15 cm; however it was detected below the LOQ at the 15-30 cm depth 3 and 296 days after 

treatment. Under field conditions at the test site, indaziflam had a calculated linear half-life 

(linear regression of ln-transformed data) of 117 days (r2

 = 0.8253, p < 0.05), and a non-linear 1st

order half-life of 34.8 days (r2

 = 0.9590, p < 0.05). The most prevalent transformation products 

were diaminotriazine, triazine-indanone, and indaziflam-carboxylic acid, which were detected in 

the 0-15 cm depth soil layer at maximum parent-equivalent concentrations of 7.2% (at 14 days), 

9.1% (at 28 days), and 4.4% (at 7 days) of the theoretical day 0 recovery of indaziflam, 

respectively. Triazine-indanone was detected in the 0-15 cm and 15-30 cm soil depths only. 

Diaminotriazine was detected above the LOQ to a maximum depth of 60-75 cm and below the 

LOQ to a maximum depth of 75-90 cm. Indaziflam-carboxylic acid was detected to a maximum 

depth of 90-105 cm, but was not detected above the LOQ in soil below the top 0-15 cm depth. 

These data show that the major degradates of indaziflam may be more mobile than the parent, 

and may have a greater potential to leach. 

This study is classified as SUPPLEMENTAL. The stability of indaziflam and its transformation 

products under typical laboratory storage conditions was not demonstrated. An additional 

storage stability study (MRID 47743328) was submitted for a sufficient duration, but still 

demonstrated slow decline in the recoveries of the indaziflam-olefin degradate. 

MRID 47743302 Indaziflam (AE1170437) 

Lenz, M. 2009. Terrestrial field dissipation of AE 1170437 in New York soil, 2006. Unpublished 

study performed by Bayer CropScience, Stilwell, Kansas (study director and analytical phase), 

AGVISE Laboratories, Northwood, ND, and A.C.D.S Research, Inc., North Rose, New York 

(field phase), and sponsored and submitted by Bayer CropScience, Research Triangle Park, 

North Carolina (p. 47). Study No.: MEDHP033. Experiment initiation May 30, 2006, and 

completion January 30, 2009 (pp. 12-13). Final report issued April 7, 2009. 

A study conducted on loamy sand (Oakville soil series) in North Rose, New York (MRID 

47443302). Soil samples were collected (0-120 cm depth, excluding day 0 samples collected to 

a depth of 15 cm) through 545 days after treatment. The mean measured concentration of 

indaziflam in the 0-15 cm soil depth was 62.61 ng a.i./g at day 0, which is 80.9% of the 
-Page 218 of 292- 

theoretical day 0 concentration. Indaziflam was detected above the LOQ in the 15-30 and 45-60 

cm depths at maximum mean concentrations of 3.5 ng a.i./g (at 365 days) and 2.87 ng a.i./g (at 3 

days), respectively. Indaziflam was detected at a maximum depth of 105-120 cm 365 days after 

treatment, however detections were reported below the LOQ. Under field conditions at the test 

site, indaziflam had a calculated linear half-life (linear regression of ln-transformed data) of 231 

days (r2 = 0.3251, p < 0.05), and a non-linear 1st order half-life of 21.3 days (r2 = 0.9078, p < 

0.05). The most prevalent transformation products were diaminotriazine, triazine-indanone, and 

indaziflam-carboxylic acid, which were detected in the 0-15 cm depth soil layer at maximum 

parent-equivalent concentrations of 9.6% (at 28 days), 5.8% (at 180 days), and 2.5% (at 7 days) 

of the theoretical day 0 recovery of indaziflam, respectively. Triazine-indanone and indaziflamcarboxylic acid were detected in the 0-15 cm soil depth only, excluding one or two detections 

below the LOQ . Diaminotriazine was detected to a maximum depth of 105-120 cm (the deepest 

sample collected); however, all detections were below the LOQ below the top 0-15 cm soil 

depth. These data show that the major degradates of indaziflam are more mobile than the parent, 

and may have a greater potential to leach. 

This study is classified as SUPPLEMENTAL. No significant deviations from good scientific 

practices were noted. However, the recoveries for the application verification were low (82-

95%), and the stability of indaziflam and its transformation products under typical laboratory 

storage conditions was clearly not demonstrated (MRID 47443279). An additional storage 

stability study (MRID 47743328) was submitted for a sufficient duration, but still demonstrated 

slow decline in the recoveries of the indaziflam-olefin degradate. 

Fish Accumulation EPA Guideline 165-4 (850.1730) 

MRID 47443237 [Triazine-2,4-14C] labeled AE 1170437 

Matlock, D. and D.R. Fischer. 2008. [Triazine-2,4-14C]AE 1170437- bioconcentration and 

biotransformation in bluegill sunfish (Lepomis macrochirus). Unpublished study performed by 

Bayer CropScience, Stilwell, Kansas; sponsored and submitted by Bayer CropScience, Research 

Triangle Park, North Carolina. Study ID: MEDHP026. Experimental initiation date April 26, 

2007; experimental completion dates June 5, 2007 (In-Life Phase) and October 3, 2007 

(Analytical Phase; p. 16). Final report issued June 30, 2008. 

The bioconcentration and biotransformation of [triazine-2,4-14C]-labeled AE 1170437 were 

studied in juvenile bluegill sunfish (Lepomis macrochirus) under continuous flow-through 

conditions. The bioconcentration portion of the study was conducted using three 100-L glass 

aquaria: one control (Aquarium A) and two treated aquaria (Aquarium B, low dose; Aquarium C, 

high dose) filled with dilution water. Three groups of 76 fish each were separately exposed to 

three treatments: solvent control at 0.1 mL methanol/L dilution water (Aquarium A); treatment at 

a nominal concentration of 0.3 μg [triazine,2,4-14C]AE 1170437/L (0.1 mL methanol/L dilution 

water; low dose; Aquarium B); and treatment at a nominal concentration of 3.0 μg [triazine 2,4-

14C]AE 1170437/L dilution water (0.1 mL methanol/L dilution water; high dose; Aquarium C). 

For the biotransformation portion of the study, one group of 30 fish was exposed at a nominal 

concentration of 3.0 μg [triazine,2,4-14C]AE 1170437/L dilution water (0.1 mL methanol/L 
-Page 219 of 292- 

dilution water; Aquarium D). The experimental test conditions were as described for the 

bioconcentration portion of the study. No mortalities or adverse effects were observed during 

either experiment. 

Bioconcentration portion of the study:

Low-dose samples (0.3 μg a.i./L; Aquarium B): During the 26-day exposure period, maximum 

[triazine-2,4-14C]AE 1170437 total radioactive residues (TRR) were 0.024 ppm in whole fish, 

0.013 ppm in edible tissues, and 0.041 in non-edible tissues at 4 days. The time to reach 95% of 

steady state was 2.9, 3.2, and 2.6 days for the whole fish, edible tissues, and non-edible tissues, 

respectively. The half-life for clearance (t1/2) was 0.68, 0.74, and 0.59 days for whole fish, edible 

tissues, and non-edible tissues, respectively. Steady state (days 4 to 26) BCF values, based on 

average AE 1170437 residues, were 46.0, 25.0, and 79.2 for whole fish, edible tissues, and nonedible tissues. Reviewer-calculated maximum BCF values were 67 for whole fish, 36 for edible 

tissues, and 114 for non-edible tissues, based on total residues, each occurring at 4 days of 

exposure. 

High-dose samples (3.0 μg a.i./L; Aquarium C): During the 26-day exposure period, maximum 

[triazine-2,4-14C]AE 1170437 TRR were 0.244 ppm in whole fish, 0.112 ppm in edible tissues, 

and 0.461 in non-edible tissues at 4 days. Triazine-2,4-14C]AE 1170437 accounted for 3.07-4.26 

μg/L in the water during the exposure period. The measured TRR in water was <0.28 μg/L 

during the depuration period. The time to reach 95% of Steady State was 3.2, 3.0, and 3.4 days 

for the whole fish, edible tissues, and non-edible tissues, respectively. The half-life for clearance 

(t1/2) was 0.74, 0.69, and 0.78 days for whole fish, edible tissues, and non-edible tissues, 

respectively. Steady state (days 4 to 26) BCF values, based on AE 1170437, were 51.1, 26.7, and 

88.5 for whole fish, edible tissues, and non-edible tissues. Reviewer-calculated maximum BCF 

values were 65 for whole fish, 30 for edible tissues, and 122 for non-edible tissues, based on total 

residues, each occurring at 4 days of exposure. 

Biotransformation portion of the study: A transformation pathway for AE 1170437 was 

proposed the study authors. AE 1170437 is metabolized by bluegill sunfish via benzylic 

oxidation, resulting in the formation of AE 1170437-3-hydroxyindane and hydroxymethyl. 

Subsequent conjugation of AE 1170437-3-hydroxyindane with glucuronic acid forms 3-

hydroxyindane GA. AE 1170437-carboxylic acid forms from further oxidation of 

hydroxymethyl. Oxidative N-dealkylation of AE 1170437 yields AE 1170437-diaminotriazine.

This study is classified as ACCEPTABLE. No significant deviations from good scientific 

practices were noted. 

Storage Stability EPA Guideline (860.1380) 

MRID 47443279 AE1170437 and its metabolites (AE1170437 acid, AE1170437 

ketone, AE1170437 hydroxy, AE1170437 olefin, AE1170437 

diaminotriazine) 

Netzband, D.J. 2008. Stability of AE1170437 and its metabolites (AE1170437 acid, AE1170437 
-Page 220 of 292- 

ketone, AE1170437 hydroxy, AE1170437 olefin, AE1170437 diaminotriazine) in soil during 

frozen storage (reported through a maximum of 433 days storage). Unpublished study performed 

by Bayer CropScience, Stilwell, Kansas and sponsored and submitted by Bayer CropScience, 

Research Triangle Park, North Carolina. Bayer CropScience Study No.: RADHP041. 

Experiment initiation January 29, 2007 and completion April 8, 2008 (p. 10). Final report issued 

June 9, 2008. 

The stability of AE 1170437 and the transformation products AE 1170437 carboxylic acid, 

AE 1170437 triazine-indanone, AE 1170437 hydroxyethyl, AE 1170437 olefin, and AE 1170437 

diaminotriazine was determined in five soils obtained from AE 1170437 terrestrial field 

dissipation studies conducted in Florida (Study No.: MEDHP037; MRID 47443224, 47443221), 

North Carolina (Study No.: MEDHP036; MRID 47443225, 47443222), California (Study No.: 

MEDHP038; MRID 47443220, 47443223), Washington (Study No.: MEDHP019), and New 

York (Study No.: MEDHP033). Storage stability results indicate that AE 1170437 and the 

transformation products AE 1170437 carboxylic acid, AE 1170437 triazine-indanone, AE 

1170437 hydroxyethyl, and AE 1170437 diaminotriazine were stable in all five test soils for the 

duration of the study period (up to 427-433 days) with no pattern of decline, and that the 

transformation product AE 1170437 olefin degraded slowly, with mean corrected recoveries 

ranging from 65 to 88% following 427 to 433 days of storage. 

This study is classified SUPPLEMENTAL. Samples fortified with olefin degraded slowly, 

(corrected mean recoveries 65-88% following 427-433 days). The storage stability study was 

conducted using test site soil stored for a period up to 427 days; however, samples from the test 

site were stored frozen for up to 521 days prior to analysis (Appendix 7, pp. 194-197). To 

determine the stability of samples under typical laboratory storage conditions, the freezer storage 

stability study must be conducted for a period of time at least as long as the maximum storage 

interval for the test samples in the field dissipation study. No other significant deviations from 

good scientific practices were noted. 
-Page 221 of 292- 

Appendix F. Residential Modeling Approach 

Estimation of the fraction of the watershed area which receives application on impervious 

surfaces in residential watersheds 

 This appendix was developed as a generic guidance to characterize the approach and 

provide justification for the method for calculating the impervious surfaces in a watershed for 

aquatic modeling in ecological risk assessments. The exact numbers for the percent of 

impervioius surfaces varies depending on the exact demensions used for sidewalks, driveways, 

patios, and other impervious surfaces. Specific area estimates are not exact estimates and were 

not used in the indaziflam assessment; the approach was used to estimate the fraction of a 

watershed that could potentially receive applications of indaziflam. 

 As will be described below, this appendix describes the method used for calculating the 

fraction of the watershed that is impervious surface and that receives an application of a pesticide 

applied to lawns or ornamental plants in a representative urban/suburban watershed in California. 

Three parameters describing the watershed, the average lot size, the average basal size or 

‘footprint’ of the houses in the watershed and the fraction of impervious surface in the watershed 

are necessary to make this calculation. These three values are then combined, along with an 

assumption about the width of the bands of treated impervious surface from the edge of the lawn, 

or treated area, to estimate the fraction of the residential watershed that is treated impervious 

surface. 

 The procedure for estimating this fraction is 1) Estimate the fraction of the watershed that 

is impervious; and that which is lawn, 2) estimate the average lot size, 3) estimate the dwelling 

footprint, 4) construct a standard lot with an impervious surface consisting of the house, 

sidewalks, and driveway, 5) estimate the area of treated impervious surface associated with each 

lot 6) estimate the number of lots in a standard 10 ha watershed, 7) and finally, estimate the 

fraction of the total watershed that is treated impervious surface. 

1) Estimate the fraction of the watershed that is impervious surface 

 In general, the majority of occupied areas including core areas and critical habitat (as 

defined by FWS) and occurrence data from CNDDB are located in areas where the percentage of 

impervious surface is less than 20%. However, a few selected areas with higher percentages of 

impervious surface (e.g. San Francisco Bay region) were evaluated to determine a representative 

value for residential settings. The conceptual model for the ROW scenario assumes that the 

watershed is represented by equal portions of impervious and pervious surface (50%). Based on 

geospatial data, it is evident that the areas with the highest percentage of impervious cover are 

urban areas outside the occupied areas, and, in general, the occupied areas have impervious 

surface of less than 50% (Figure F-1). Therefore, for purposes of modeling, it is assumed that a 

representative percentage of impervious cover is 50%. In general, as the percentage of 

impervious surface increases, the overall exposure resulting from applications to the pervious 

surface decreases because less mass is applied within the watershed. Additional information on 

the impact of this assumption has been previously characterized in the Barton Springs 
-Page 222 of 292- 

salamander endangered species risk assessment for atrazine (U.S. EPA, 2006). 

Figure F-1. California red-legged frog habitat relative to urban areas in Central California with 

their impervious surface fractions. 
-Page 223 of 292- 

2) Estimate for the typical lot size 

 In order to justify the assumption of 1⁄4 acre lot as a typical exposure scenario, publicly 

available data from the United States Census (Census) 2003 American Housing Survey (AHS) 

was reviewed on July 10, 2006 and is available at the following website. 

http://www.census.gov/hhes/www/housing/ahs/ahs03/ahs03.html

Data for all suburban homes available nationally was considered. It is assumed that most 

residential pesticide applications will occur in suburban settings. In order to test the assumption 

of the 1⁄4 acre lot as the best representation, the AHS data for suburban homes that list total 

number of houses by lot size and by square footage of house (see Table 1C-3 at the AHS website 

above) was evaluated. With a total of 45,552,000 total units reported nationally for all suburban 

areas, 12,368,000 units (the largest class at 27%) were on lots between 1/8 acre and 1⁄4 acre, 

while 9,339,000 units (the second largest class at 21%) were on lots between 1⁄4 acre and 1⁄2 acre. 

Overall, the median lot size was 0.37 acre. This analysis suggests that the 1⁄4 acre lot is a 

reasonable approximation of suburban pesticide use. 

3) Size of House Footprint 

 The AHS survey data reports that of a total of 43,328,000 reported single detached homes 

in suburban areas, 10,124,000 (the largest group at 23%) were between 1,500 and 2,000 square 

feet, while 7,255,000 (the third largest group at 17%) were between 2,000 and 2,500 square feet, 

and 9,513,000 (the second largest group at 22%) were between 1,000 and 1,500 square feet. 

From these data, it was assumed that a typical home is 2,000 square feet with a 1,000 square foot 

footprint. The lower sized houses less than 1,500 square feet are more likely to represent single 

floor structures; thus, the 1,000 square foot estimate for a house footprint is reasonable. 

4) Development of a standard lot 

 Using a quarter acre lot and a house with a 1000 ft2

 footprint, a standard lot was 

developed (Figure F-2). Both the lot and house were assumed to be square, resulting in the side 

of the lot being 104.4 ft in length and the side of the house being 31.6 ft. If the house is placed in 

the center of the lot, the driveway will be 36.4 ft long. If the driveway is assumed to be 15 ft 

wide, then the driveway is 546 ft2

. For sidewalks, it necessary to consider whether it is a corner 

or mid-block lot. If we assume that the driveway is 3 ft wide, the area of the sidewalk is the 

width of the yard minus the width of driveway time three, or 268.1 ft2

 for the mid-block lot and 

572 ft2

 for the corner lot (268.1 + 104.4x3 – 9), the 9 ft2 are subtracted to account for the overlap 

where the sidewalks meet. Therefore, the total impervious surface, (house + driveway + 

sidewalk) for the mid-block lot is 1814.5 ft2 and 2218 ft2 for the corner lot. This leaves 9,075 ft2

and 8,672 ft2

 of lawn for the two lot types respectively. 
-Page 224 of 292- 

Figure F-2. Standard lot for assessment of aquatic exposure from applications of pesticide to residential settings in 

California for the California Red Legged Frog Assessment. The schematic represents a corner lot. Mid-block lots 

have side walk only along the front of the lot and the area of the sidewalk is 268.1 ft2

 rather than 572 ft2 with a 

resulting increase in lawn area to 9,075 ft2

. 

5) Area of treated impervious surface per lot 

 The area of treated impervious surface is estimated by assuming the whole sidewalk, and 

3 ft of the driveway and street along the road get treated. This represents what might occur if the 

homeowner is using a broadcast spreader and makes no effort to avoid applying pesticide to hard 

surfaces bordering the lawn. In this scenario, 268.2 ft2 of side walk is treated during an 

application for the mid-block lot, and 581.4 ft2

 for the corner lot. This is derived from the 

assumption that the perimeter of the property is planted with ornamental plants which are located 

on the property side of the sidewalk. An alternative scenario for home lawn treatments this 

results in 799.7 ft2

 treated surface on a mid-block lot (218.4 +313.2 + 268.1) and 1416 ft2 for a 

corner lot (See Figure F-3). Figure F-3 was developed for home lawn applications, however the 

logic is similar except the amount of impervious area that receives treatment is much less. 

 8672 - lawn 

 1000 - house 

 572 - sidewalk 

+ 546- driveway 

10,890 sq ft = 1⁄4 acre 

Side length of lot = 

104.4 ft 

House 

dimensions: 

31.6 ft x 31.6

Driveway 

dimensions: 

15 ft x 36.4 ft

3 ft wide 

sidewalk
-Page 225 of 292- 

Overspray Zones on Impervious 

Surfaces

3 ft wide 

overspray 

on road

3 ft wide 

overspray on 

both sides of 

driveway

Overspray 

on 3 ft 

wide 

sidewalks

Figure F-3. Impervious surface treated during a broadcast application of a pesticide to 

residential lawns. 

6) Number of lots in a 10 ha watershed. 

 In step 1 above, the fraction of the watershed that is in lawn was estimated to be 50%, 

with the balance being impervious surface, which includes, dwellings, sidewalks, driveways and 

streets. Since we now have an estimate of the treated impervious area associated with each lot, in 

order to estimate the total treated impervious surface, we need an estimate of the number of lots 

in the watershed. Current ecological risk assessments assume a standard watershed size of 10 ha, 

or 1,076,391 ft2

. If we assume that the lots are arranged in blocks of ten (Figure F-4), then 2/5 of 

the houses will be corner lots and 3/5 will be mid-block. Using these fractions, and the lawn 

areas calculated in step 4, we can estimate the number of houses as 2/5x 9,100 x N + 3/5 x 

9,404xN = 1,076,391. Solving this equation for N, the number of lots gives a value of 57.98 ≈ 58 

lots in the watershed 
-Page 226 of 292- 

Urban Watershed

Figure F-4. Schematic for a representative California suburban watershed for use in assessing 

risks to the California Red Legged Frog. 

7) Fraction of treated impervious surface in the watershed. 

 If there are 58 houses in the watershed, as in Figure 4, then 24 are corner lots and 34 are 

mid-block lots. Using the treated areas estimated in step 5, the treated area in the watershed is 

581.4 ft2

 x 24 = 13,953.6 ft2 for the corner lots and 268.2 ft2 x 34 = 9,118.8 ft2 for the mid-block 

lots, for a total of 23,072.4 ft2

. Since the total watershed area of 10 ha is equivalent to 1,107,391 

ft2

, the percent of the watershed that is treated impervious surface is 2.08%. The modeled 

fraction was 5.0%, which may be an underestimation of treated impervious surface, which was 

derived from an application to non-turf crops (e.g., gardens) bordering the house. For home lawn 

treatments, the percent overspray is closer to 5.68% based on the same logic in the preceding 

steps but a larger amount of impervious surface receives treatment (e.g., road, driveway, and 

sidewalk vs just sidewalk). 
-Page 227 of 292- 

Appendix G. Scenario Selection and Rationale 

Table G1. Scenarios Used for Tier 2 Surface Water Modeling of Indaziflam

Crop Scenario Location Soil Weather PCA Ap Date 

Citrus FLcitrusSTD.txt Collier or Hendry 

Counties, FL 

Wabasso fine 

sand 

West Palm Beach, 

FL (W12844) 

0.87 May 20 

Pome Fruit NCapplesSTD.txt Henderson County, 

NC 

Hayesville 

loam 

Ashville, NC 

(W03812) 

0.87 July 22 

Stone Fruit ORberriesOP.txt Marion County, OR Woodburn silt 

loam 

Salem, OR 

(W24232) 

0.87 March 1 

Tree Nuts GApeacansSTD.t

xt 

Mitchell or 

Dougherty Counties, 

GA 

Williston 

loamy fine 

sand 

Tallahassee, FL 

(W93805) 

0.87 June 14 

Grapes NYgrapesSTD.txt Chautauqua County, 

NY 

Lordstown 

channery silt 

loam 

Erie, PA (W14860) 0.87 Aug. 15 

Olives CAolivesRLF.txt San Joaquin Valley, 

CA 

Porterville 

series 

Fresno, CA 

(W93193) 

0.87 Feb. 2 

Turf FLturfSTD.txt Osceola County, FL Adamsville 

sand 

Daytona Beach, F: 

(W12834) 

1.0 Aug. 20 

Home Lawns CAresidentialRL

F.txt 

San Fransisco, CA Teirra alluvial 

deposits 

San Fransisco, CA 

(W23234) 

1.0 Jan. 15 

Ornamentals CAresidentialRL

F.txt 

San Fransisco, CA Teirra alluvial 

deposits 

San Fransisco, CA 

(W23234) 

1.0 Jan. 15 

Hardscapes FLimpervious.txt West Palm Beach, FL -- -- 1.0 May 26 

Forestry NCapples.txt Henderson County, 

NC 

Hayesville 

loam 

Ashville, NC 

(W03812) 

1.0 July 22 

 The field used to represent citrus production is in Florida, located in Collier or Hendry 

Counties in Southwest Florida. According to the 1997 Census of Agriculture, Florida is the 

major producer of citrus (oranges) for the juice market and among the highest for the fresh 

market. The field has Wabasso fine sand, which is a sandy, siliceous, hyperthermic Alfic 

Alaquods. These soils are often used for citrus production and truck crops. The soil is extensive 

in Florida. Wabasso fine sand is a Hydrologic Group D soil. The weather data is from weather 

station W12844 in West Palm Beach, Florida. 

 The field used to represent apple production is in North Carolina, and is located in 

Henderson County, in Western North Carolina. According to the 1997 Census of Agriculture, 

North Carolina is among the major producers of apples (7th to 8th overall) in the U.S., and is one 

of the southern most production areas. There are four primary apple production areas in western 

North Carolina, all long-term perennial regions, grown on a variety of soils, in different climate 

regions. Henderson County produces between 60 to 70 percent of the apple crop. The field has 

Hayesville loam, which is a fine, kaolinitic, mesic, Typic Kanhapludults. Hayesville loam is a 

Hydrologic Group C soil. The weather data is from weather station W03812 in Ashville, North 

Carolina. 

For the stone fruit use, a field representing blackberry production in Marion County, 

Oregon was used. Blackberries are a bramble fruit, known as aggregated drupe fruit (stone fruit) 

composed of small, individual drupes. According to the 1997 Census of Agriculture, Oregon is 
-Page 228 of 292- 

the leading state in the production of blackberries in the U.S. Marion County leads Oregon in 

acres planted in 1997. The field has Woodburn silt loam, which is a fine-silty mixed, 

superactive, mesic Aquultic Agrixerolls. The series is used to produce berries, orchards, cannery 

crops, grain, hay, and pasture. The series is extensive in the Willamette Valley, where the 

scenario is located. Woodburn silt loam is a Hydrologic Group C soil. The weather data is from 

weather station W24232 in Salem, Oregon. 

The field used to represent tree nut production is in Georgia is located in Mitchell or 

Dougherty County in Southwest Georgia (MLRA133) and the weather station representing the 

orchard’s weather is located in Tallahassee, FL (W93805). The scenario was developed to 

represent pecan production. Pecans are grown throughout the southwestern part of the state. 

Georgia and Texas generally compete from year to tear for status as the top U.S. producer. Trees 

are very large, growing up to 100 feet tall and living 80 or more years, although production 

declines as the trees reach the end of its life span. The field has Williston loamy fine sand, 

which is a fine, mixed, superactive, hyperthermic Typic Hapludalfs. Williston loamy fine sand is 

a Hydrologic Group C soil. 

Indazilfam use on grapes was represented using a vineyard in New York located in 

Chautauqua County in Southwest New York along Lake Erie (MLRA100/101) with the weather 

station representing the vineyard’s weather located in Erie, PA (W14860). Grapes are grown 

throughout the state, but are concentrated in the western part of the state where the macroclimate 

is best suited for grape production. New York is among the leading Eastern U.S. state in both 

wine and table grape production. Chautauqua County has the highest acreage in the state and 

New York remains the 3rd or 4th highest production state in the U.S. The soil selected to simulate 

the vineyard is a Lordstown channery silt loam. Lordstown channey silt loam is a coarse-loamy, 

mixed, active, mesic Typic Dystrudepts. 

 Indaziflam use on olives was represented using a scenario intended to represent olive 

production in California’s San Joaquin Valley, primarily in Tulare, Madera, Fresno, and Kings 

Counties. Over 99% of the olives grown in the United States are grown in California with 

approximately 35,300 bearing acres of olives (USDA, 1999). Nearly 65% of California’s olive 

acreage is located in the San Joaquin Valley, primarily in Tulare County (53% of the total) 

(USDA, 1999). Moreover, based on 2005 California Pesticide Usage Reporting (CalPIP, 2006), 

approximately 80% of pesticides used on California olives (by pounds of chemical) were applied 

in San Joaquin Valley. The Porterville series is the third most common soil found where olives 

are grown, and was used to represent this field. It is a fine, smectitic, thermic Aridic 

Haploxererts. Porterville is a Hydrologic Group D soil. The weather data is from weather 

station W93193 in Fresno, California. 

 The field used to represent turf grass in Florida is located in Osceola County within 

MLRA 155, although turf grasses (golf courses, sod farms, etc.) are located throughout the state. 

This turf scenario is considered to be essentially generic, with no distinction made between sod 

farms, golf course fairways, greens and tees, or residential lawns. To develop a turf scenario the 

soil was modified by adding a 2 cm thick layer of thatch on top of the soil profile. The thatch 

layer has the following properties: bulk density = 0.37; field capacity = 0.47; wilting point = 
-Page 229 of 292- 

0.27; organic carbon = 7.5%. Curve numbers were selected based on good condition open space 

areas as specified in TR-55, that is for hydrologic soil groups C. A 2 cm layer of thatch is typical 

for golf course fairways, but is probably thicker than average for golf course greens. The soil 

selected to simulate turf grass is an Adamsville sand, a hyperthermic, uncoated Aquic 

Quartzipsamment. Adamsville sand ranges from a Hydrologic Group A soil to a Hydrologic 

Group C soil, depending on the water table. For the purpose of this modeling, EFED used the 

curve numbers from the PIC of the Adamsville sand as a Group C soil. The weather data is from 

weather station W12834 in Daytona Beach, Florida. 

 The residential scenario is intended to be used as a surrogate for all urban/suburban home 

and residential uses in the San Francisco Bay area of California. Crop parameters have been 

chosen to reflect residential turf areas, primarily lawns, within the urban area. Residential Lawns 

are irrigated year round, even during the wet season. Tierra soils were chosen to represent 

residential areas. Tierra is a Hydrologic Group D soil which account for approximately 40% of 

urban soils in drainage, these soils are fine alluvial deposits. The weather data is from weather 

station W23234 in San Fransisco, CA. 

 Indaziflam use on forestry was represented by a surrogate scenario, North Carolina 

Apples (NCapplesSTD.txt). This scenario is described above. It was selected as a surrogate to 

represent a vulnerable scenario for forestry applications due to the precipitation that it receives, 

and the soil types. It is reasonable to use the apple scenario as a surrogate for forestry uses since 

the apple tree is physiologically similar to commercial forestry trees. 

 For the hardscape use, a provisional scenario (FLimpervious.txt) was used to represent 

high exposure sites resulting from applications directly to impervious surfaces (e.g., patio, 

sidewalk and driveway cracks, on paths and gravel areas, along fence lines). The Florida 

impervious scenario was modified from an existing California impervious scenario 

(CAimperviousRLF.txt) developed for the endangered species assessments in California. The 

provisional scenario represents a conservative high-end exposure resulting from applications of 

indaziflam to hardscapes in West Palm Beach. Florida was chosen, specifically West Palm 

Beach, to represent conservative exposure estimates because the precipitation is on average 

greater in this region of the country compared to other areas (e.g., Fresno, California). The 

scenario uses weather data from West Palm Beach, FL (W12844). The scenario, in its entirety is 

included below. 

FLimpervious.txt

 PRZM Variable 

Record # Name Value Parameter Name and Guidance Source Comments 

1 TITLE "FLimpervious.txt, 1/5/2010" Title of input file 

2 HTITLE "West Palm Beach, FL; MLRA 155; Metfile: W12844.dvf" Short 

description of file: modification of CA impervious scenario 

3 PFAC 0.77 Pan factor (dimensionless) 

 SFAC 0 Snowmelt factor (cm/C) 

 IPEIND 0 Pan factor flag - 0 = pan data read from meteorology 

file 

 ANETD 33 Min. depth from which evaporation is extracted during 
-Page 230 of 292- 

fallow period (cm); 10 cm = soil with limited drainage 

 INICRP 1 "Flag for initial crop if simulation date is before 

emergence date (see Record 10); 1 = yes, 2 = no" Always should be 1 

 ISCOND 1 "Surface condition of initial crop if INICRP = 1; 1 = 

fallow, 2 = cropping, 3 = residue" 

 

6 ERFLAG 4 "Flag to calculate erosion; 0 = none, 2 = MUSLE, 3 = 

MUST, 4 = MUSS; note that a value of 1 is meaningless; MUSS selected by EPA 

and industry as most appropriate." 

7 "Only needed if ERFLAG = 2,3, or 4 (Record 6)" 

 USLEK 0 Universal soil loss equation (K) of soil erodability 

 USLELS 5.18 Universal soil loss equation (LS) length-slope 

topographic factor 

 USLEP 1 Universal soil loss equation (P) practice factor 

 AFIELD 172 Area of field or plot (ha); EPA default is 10 email 

from Sid Abel (98 12 28) 

 IREG 4 Location of NRCS 24-hour hyetograph/Soil Conservation 

Service rainfall distribution region 

 SLP 15 Land slope (%) 

 HL 600 "Hydraulic length (m); for a circular 10 ha field emptying 

into a 1 ha pond (when linked to EXAMS), default HL = 354 m" 

8 NDC 1 Number of different crops in simulation (1 to 5) 

FL Impervious 

9 (repeat this record NDC times) 

 ICNCN 1 Crop number 

 CINTCP 0 Maximum interception storage of crop (cm) 

 AMXDR 0 Maximum rooting depth of crop (cm) 

 COVMAX 0 Maximum areal coverage of canopy (%) 

 ICNAH 1 "Surface condition of crop after harvest date (see Record 

11); 1 = fallow, 2 = cropping, 3 = residue" 

 CN (x3) 98 "Runoff curve numbers of antecedent moisture 

condition for fallow, cropping, and residue (three values); note that runoff 

and leaching are very sensitive to these factors." 

 98 

 98 

 WFMAX 0 "Maximum dry weight of crop at full canopy (kg/m2), 

required if CAM = 3 (Record 16) else set to 0.0" 

 HTMAX 0 Maximum canopy height (cm) at maturation date (Record 11) 

 RECORD9A 1 24 Crop Number and Number of RUSLE Dates 

 RECORD9B 0101 1601 0102 1602 0103 1603 0104 1604 0105 1605 0106 1606 

0107 1607 0108 1608 RUSLE Dates 

 RECORD9C .000 .000 .000 .000 .000 .000 .000 .000 .000 .000 .000 .000 

.000 .000 .000 .000 USLEC 

 RECORD9D .011 .011 .011 .011 .011 .011 .011 .011 .011 .011 .011 .011 

.011 .011 .011 .011 Mannings N 

 RECORD9E 98 98 98 98 98 98 98 98 98 98 98 98 

98 98 98 98 Curve Number 

 RECORD9B 0109 1609 0110 1610 0111 1611 0112 1612 RUSLE Dates 

 RECORD9C .000 .000 .000 .000 .000 .000 .000 .000 USLEC 

 RECORD9D .011 .011 .011 .011 .011 .011 .011 .011 Mannings N 

 RECORD9E 98 98 98 98 98 98 98 98 Curve Number 
-Page 231 of 292- 

10 NCPDS 30 Number of cropping periods (sum of NDC for all cropping 

dates in Record 11) 

11 (Repeat this record NCPDS times) 

FL Impervious EMD 1 Integer day of crop emergence 

 EMM 1 Integer month of crop emergence 

 IYREM 61 Integer year of crop emergence 

 MAD 2 Integer day of crop maturation 

 MAM 1 Integer month of crop maturation 

 IYRMAT 61 Integer year of crop maturation 

 HAD 31 Integer day of crop harvest 

 HAM 12 Integer month of crop harvest 

 IYRHAR 61 Integer year of crop harvest 

 INCROP 1 Crop number associated with NDC (Record 8) 

19 STITLE unclassified silt loam, West Palm Beach County Brief 

description of soil properties 

20 CORED 46 Total depth of soil core (cm); must be sum of all horizon 

thicknesses in Record 33 and at least as deep as the root depth in Record 9 

 BDFLAG 0 "Bulk density flag; 0 = bulk density known and 

entered in Record 33, 1 = mineral value entered" 

 THFLAG 0 "Field capacity and wilting point flag; 0 = water 

contents are entered, 1 = calculated by model." 

 KDFLAG 0 "Soil adsorption coefficient; 0 = Kd entered in 

Record 37, 1 = calculated by model." Submission studies 

 HSWZT 0 "Drainage flag; 0 = free draining, 1 = restricted (should 

be set to zero)" email from Sid Abel (99 03 10) 

 MOC 0 "Method of characteristics flag; 1 = yes, 0 = no; this flag 

is used for the leaching program and PRZM is not recommended as a leaching 

model by the EPA at this time." email from Sid Abel (99 03 10) 

 IRFLAG 0 "Irrigation flag; 0 = no irrigation, 1 = year round, 

2 = during cropping period only." 

 ITFLAG 0 "Soil temperature simulation flag; 1 = yes, 0 = no 

(must = 1 if nitrogen is being simulated)" 

 IDFLAG 0 "Thermal conductivity and heat capacity flag; 1 = 

yes, 0 = no." 

 BIOFLG 0 "Biodegradation flag; 1 = yes, 0 = no; this flag is 

used when transformation occurs only by the microbial pathway and requires 

knowledge of microbe population characteristics" email from Sid Abel (99 

03 10) 

 

33 NHORIZ 3 Number of horizons 

Horizon 1: 

34 "(Repeat Records 34, 36, and 37 for each horizon)" 

 HORIZN 1 Horizon number 

 THKNS 10 Thickness of horizon (cm) 

 BD 1.9 Bulk density if BDFLAG = 0 or mineral density if BDFLAG = 1 

(Record 20) (g/cm3) 

 THETO 0.28 "Initial soil water content in horizon (cm3/cm3); if sitespecific value not known, use field capacity" 
-Page 232 of 292- 

 AD 0 "Soil drainage parameter if HSWZT = 1 (Record 20), else set 

to 0.0 (day-1); note that the # of compartments (= DPN/THKNS) is needed to 

determine AD" 

 DISP 0 Pesticide hydrodynamic solute dispersion coefficient for 

each NCHEM; should be set to zero unless field data are available for 

calibration 

 ADL 0 Lateral soil drainage parameter if HSWZT = 1 (Record 20) 

(should be set to zero) 

37 DPN 0.1 Thickness of compartments in horizon (cm) 

 THEFC 0.28 Field capacity in horizon (cm3/cm3) 

 THEWP 0.28 Wilting point in horizon (cm3/cm3) 

 OC 0 Organic carbon in horizon (%) 

Horizon 2: 

34 "(Repeat Records 34, 36, and 37 for each horizon)" 

 HORIZN 2 Horizon number 

 THKNS 5 Thickness of horizon (cm) 

 BD 1.4 Bulk density if BDFLAG = 0 or mineral density if BDFLAG = 1 

(Record 20) (g/cm3) 

 THETO 0.28 "Initial soil water content in horizon (cm3/cm3); if sitespecific value not known, use field capacity" 

 AD 0 "Soil drainage parameter if HSWZT = 1 (Record 20), else set 

to 0.0 (day-1); note that the # of compartments (= DPN/THKNS) is needed to 

determine AD" 

 DISP 0 Pesticide hydrodynamic solute dispersion coefficient for 

each NCHEM; should be set to zero unless field data are available for 

calibration 

 ADL 0 Lateral soil drainage parameter if HSWZT = 1 (Record 20) 

(should be set to zero) 

37 DPN 5 Thickness of compartments in horizon (cm) 

 THEFC 0.28 Field capacity in horizon (cm3/cm3) 

 THEWP 0.164 Wilting point in horizon (cm3/cm3) 

 OC 1.16 Organic carbon in horizon (%) 

Horizon 3: 

34 "(Repeat Records 34, 36, and 37 for each horizon)" 

 HORIZN 3 Horizon number 

 THKNS 31 Thickness of horizon (cm) 

 BD 1.43 Bulk density if BDFLAG = 0 or mineral density if BDFLAG = 1 

(Record 20) (g/cm3) 

 THETO 0.252 "Initial soil water content in horizon (cm3/cm3); if sitespecific value not known, use field capacity" 

 AD 0 "Soil drainage parameter if HSWZT = 1 (Record 20), else set 

to 0.0 (day-1); note that the # of compartments (= DPN/THKNS) is needed to 

determine AD" 

 DISP 0 Pesticide hydrodynamic solute dispersion coefficient for 

each NCHEM; should be set to zero unless field data are available for 

calibration 

 ADL 0 Lateral soil drainage parameter if HSWZT = 1 (Record 20) 

(should be set to zero) 

37 DPN 1 Thickness of compartments in horizon (cm) 

 THEFC 0.252 Field capacity in horizon (cm3/cm3) 
-Page 233 of 292- 

 THEWP 0.145 Wilting point in horizon (cm3/cm3) 

 OC 0.73 Organic carbon in horizon (%) 

40 ILP 0 "Flag for initial pesticide levels before simulation start 

date; 1 = yes, 0 = no" 

 CFLAG 0 "Conversion flag for initial pesticide levels; 0 = mg/kg, 1 

= kg/ha, blank if ILP = 0" 
-Page 234 of 292- 

Appendix H. Aquatic Model Input/Output Data. 

Table H-1. Summary of Input/Output Files. 

File name Date Location/Simulation 

Input/Output File for SCI-GROW 

Saf-eco.sci Apr. 15, 2009 National screen 

Input Files for PRZM/EXAMS

FLcitrus.prz Nov. 13, 2009 Citrus Use 

NCapples.prz Nov. 13, 2009 Pome Fruit use 

ORstonefruit.prz Nov. 10, 2009 Stone Fruit use 

GAtreenuts.prz Nov. 10, 2009 Tree Nut use 

NYgrapes.prz Nov. 13, 2009 Grape use 

CAolives.prz Nov. 23, 2009 Olive use 

FLturf.prz Nov. 10, 2009 Turf uses 

CAresidential.prz Nov. 13, 2009 Residential lawn use 

CAresidentialORN.prz Nov. 16, 2009 Ornamental use 

NCforestry.prz Nov. 23, 2009 Forestry use 

Crop Scenario Files for PRZM/EXAMS

FLcitrusSTD.txt May 29, 2007 Collier and Hendry Counties, FL/ Citrus Use 

NCapplesSTD.txt May 29, 2007 Henerson County, NC/Pome Fruit & Forestry Uses 

ORberriesOP.txt June 14, 2007 Marion County, OR/Stone Fruit Use 

GApecansSTD.txt 

Mitchell and Doughtery Counties, GA/Tree Nut 

Use 

NYgrapesSTD.txt May 29, 2007 Chautauqua County, NY/Grape Use 

CAolivesRLF_V2.txt March 26, 2008 Porterville, CA/Olive Use 

FLtufSTD.txt Feb. 21, 2006 

Lake Kissimmee/Inidan River Region, FL/Turf 

Use 

CAresidentialRLF.txt Feb. 20, 1007 

San Fransico Bay Area, California 

Home Lawn Use 

Ornamental Use 

Hardscape Use 

CAimperviousRLF.txt Feb. 20, 2007 

San Fransico Bay Area, California 

Home Lawn Use 

Ornamental Use 

Hardscape Use 

FLimpervious.txt Jan. 6, 2010 West Palm Beach, Florida/Hardscape use 

Weather Data Files for PRZM/EXAMS

W12844.dvf July 3, 2002 West Palm Beach, Florida 

W03812.dvf July 3, 2002 Asheville, North Carolina 

W24232.dvf July 3, 2002 Salem, Oregon 

W93805.dvf July 3, 2002 Tallahassee/Apalachicola, Florida 

W14860.dvf July 3, 2002 Erie, Pennsylvania 

W93193.dvf July 3, 2002 Fresno, California 

W12834.dvf July 3, 2002 Daytona Beach, Florida 

W23234.dvf July 3, 2002 San Fransico, California 
-Page 235 of 292- 

Example Input/Output Data for Individual Simulations 

SCI-GROW Input/Output File. 

 SCIGROW 

 VERSION 2.3 

 ENVIRONMENTAL FATE AND EFFECTS DIVISION 

 OFFICE OF PESTICIDE PROGRAMS 

 U.S. ENVIRONMENTAL PROTECTION AGENCY 

 SCREENING MODEL 

 FOR AQUATIC PESTICIDE EXPOSURE 

 

 SciGrow version 2.3 

 chemical:indaziflam ag 

 time is 1/ 8/2010 11:36: 6 

 ------------------------------------------------------------------------ 

 Application Number of Total Use Koc Soil Aerobic 

 rate (lb/acre) applications (lb/acre/yr) (ml/g) metabolism (days) 

 ------------------------------------------------------------------------ 

 0.134 1.0 0.134 4.50E+02 50.0 

 ------------------------------------------------------------------------ 

 groundwater screening cond (ppb) = 1.74E-02 

 ************************************************************************ 

PRZM/EXAMS Example Input/Output File. 

stored as FLcitrus_2.out 

Chemical: indaziflam 

PRZM environment: FLcitrusSTD.txt modified Tueday, 29 May 2007 at 12:45:56 

EXAMS environment: pond298.exv modified Tueday, 26 August 2008 at 05:14:08 

Metfile: w12844.dvf modified Tueday, 26 August 2008 at 05:14:22 

Water segment concentrations (ppb) 

Year Peak 96 hr 21 Day 60 Day 90 Day Yearly 

1961 0.529 0.5245 0.5134 0.4924 0.4821 0.2479 

1962 1.313 1.298 1.267 1.182 1.134 0.7093 

1963 1.189 1.182 1.15 1.086 1.054 0.8842 

1964 2.614 2.593 2.551 2.498 2.434 1.594 

1965 2.869 2.853 2.816 2.716 2.575 2.122 

1966 2.881 2.858 2.801 2.679 2.592 2.339 

1967 2.429 2.413 2.351 2.261 2.21 2.053 

1968 4.178 4.144 4.095 3.834 3.645 2.715 

1969 3.246 3.218 3.129 2.927 2.829 2.642 

1970 3.08 3.052 2.949 2.81 2.704 2.339 

1971 2.31 2.29 2.251 2.111 2.069 1.863 

1972 2.319 2.295 2.228 2.099 2.01 1.693 

1973 2.165 2.147 2.114 2.045 2.017 1.769 

1974 1.732 1.719 1.683 1.602 1.566 1.49 

1975 2.434 2.411 2.373 2.231 2.142 1.634 

1976 3.527 3.49 3.344 3.223 3.138 2.454 

1977 3.77 3.754 3.68 3.457 3.287 2.863 

1978 3.582 3.55 3.447 3.242 3.14 2.711 
-Page 236 of 292- 

1979 3.487 3.454 3.373 3.176 3.057 2.544 

1980 3.303 3.273 3.213 3.078 2.961 2.668 

1981 3.655 3.618 3.515 3.461 3.352 2.663 

1982 2.898 2.875 2.817 2.694 2.605 2.431 

1983 2.715 2.69 2.643 2.491 2.378 2.093 

1984 2.977 2.953 2.862 2.758 2.649 2.176 

1985 2.21 2.193 2.155 2.049 2.024 1.938 

1986 1.977 1.965 1.925 1.844 1.805 1.638 

1987 2.127 2.106 2.059 1.981 1.922 1.527 

1988 4.25 4.203 4.017 3.712 3.569 2.447 

1989 2.882 2.87 2.821 2.719 2.647 2.273 

1990 2.69 2.671 2.623 2.487 2.39 2.012 

Sorted results 

Prob. Peak 96 hr 21 Day 60 Day 90 Day Yearly 

0.032258064516129 4.25 4.203 4.095 3.834 3.645 2.863 

0.0645161290322581 4.178 4.144 4.017 3.712 3.569 2.715 

0.0967741935483871 3.77 3.754 3.68 3.461 3.352 2.711 

0.129032258064516 3.655 3.618 3.515 3.457 3.287 2.668 

0.161290322580645 3.582 3.55 3.447 3.242 3.14 2.663 

0.193548387096774 3.527 3.49 3.373 3.223 3.138 2.642 

0.225806451612903 3.487 3.454 3.344 3.176 3.057 2.544 

0.258064516129032 3.303 3.273 3.213 3.078 2.961 2.454 

0.290322580645161 3.246 3.218 3.129 2.927 2.829 2.447 

0.32258064516129 3.08 3.052 2.949 2.81 2.704 2.431 

0.354838709677419 2.977 2.953 2.862 2.758 2.649 2.339 

0.387096774193548 2.898 2.875 2.821 2.719 2.647 2.339 

0.419354838709677 2.882 2.87 2.817 2.716 2.605 2.273 

0.451612903225806 2.881 2.858 2.816 2.694 2.592 2.176 

0.483870967741936 2.869 2.853 2.801 2.679 2.575 2.122 

0.516129032258065 2.715 2.69 2.643 2.498 2.434 2.093 

0.548387096774194 2.69 2.671 2.623 2.491 2.39 2.053 

0.580645161290323 2.614 2.593 2.551 2.487 2.378 2.012 

0.612903225806452 2.434 2.413 2.373 2.261 2.21 1.938 

0.645161290322581 2.429 2.411 2.351 2.231 2.142 1.863 

0.67741935483871 2.319 2.295 2.251 2.111 2.069 1.769 

0.709677419354839 2.31 2.29 2.228 2.099 2.024 1.693 

0.741935483870968 2.21 2.193 2.155 2.049 2.017 1.638 

0.774193548387097 2.165 2.147 2.114 2.045 2.01 1.634 

0.806451612903226 2.127 2.106 2.059 1.981 1.922 1.594 

0.838709677419355 1.977 1.965 1.925 1.844 1.805 1.527 

0.870967741935484 1.732 1.719 1.683 1.602 1.566 1.49 

0.903225806451613 1.313 1.298 1.267 1.182 1.134 0.8842 

0.935483870967742 1.189 1.182 1.15 1.086 1.054 0.7093 

0.967741935483871 0.529 0.5245 0.5134 0.4924 0.4821 0.2479 

0.1 3.7585 3.7404 3.6635 3.4606 3.3455 2.7067 

 Average of yearly averages:

 2.01774666666667 

Inputs generated by pe5.pl - Novemeber 2006 

Data used for this run: 

Output File: FLcitrus_2 

Metfile: w12844.dvf 
-Page 237 of 292- 

PRZM scenario: FLcitrusSTD.txt 

EXAMS environment file: pond298.exv 

Chemical Name: indaziflam 

Description Variable Name Value Units Comments 

Molecular weight mwt 301.36 g/mol 

Henry's Law Const. henry 2.62e-10 atm-m^3/mol 

Vapor Pressure vapr 5.1e-10 torr 

Solubility sol 1.2 mg/L 

Kd Kd 9.1 mg/L 

Koc Koc mg/L 

Photolysis half-life kdp 85.5 days Half-life 

Aerobic Aquatic Metabolism kbacw 230.4 days Halfife 

Anaerobic Aquatic Metabolism kbacs days Halfife 

Aerobic Soil Metabolism asm 275.3 days Halfife 

Hydrolysis: pH 4 0 days Half-life 

Hydrolysis: pH 7 0 days Half-life 

Hydrolysis: pH 9 0 days Half-life 

Method: CAM 2 integer See PRZM manual 

Incorporation Depth: DEPI 0 cm 

Application Rate: TAPP 0.095 kg/ha 

Application Efficiency: APPEFF 0.99 fraction 

Spray Drift DRFT 0.01 fraction of application rate applied to pond 

Application Date Date 20-05 dd/mm or dd/mmm or dd-mm or dd-mmm 

Interval 1 interval 90 days Set to 0 or delete line for single app. 

app. rate 1 apprate 0.056 kg/ha 

Record 17: FILTRA 

 IPSCND 1 

 UPTKF 

Record 18: PLVKRT 

 PLDKRT 

 FEXTRC 0.5 

Flag for Index Res. Run IR EPA Pond 

Flag for runoff calc. RUNOFF none none, monthly or total(average of entire run) 
-Page 238 of 292- 

Appendix I. Example T-REX Output for Indaziflam. 

Dose-based Upper Bound Kenaga EECs and Chronic RQs for Mammmals 

Based on the Proposed Crop (food) Uses of Indaziflam (Chronic RQs for birds 

and acute RQs for birds and mammals were not calculated because definitive 

toxicity endpoints were unavailable) 

Table I.1c. Upper Bound Kenaga, Chronic Mammalian Dose-Based Risk Quotients 

EECs and RQs 

Short Grass Tall Grass 

Broadleaf 

Plants/ 

Small Insects 

Fruits/Pods/ 

Seeds/ 

Large 

Insects 

Granivore 

Size 

Class 

(grams) 

Adjusted 

NOAEL 

EEC RQ EEC RQ EEC RQ EEC RQ EEC RQ 

15 151.65 30.1 0.20 13.8 0.09 16.9 0.11 1.89 0.01 0.42 <0.01 

35 122.70 20.8 0.17 9.56 0.08 11.7 0.10 1.30 0.01 0.29 <0.01 

1000 53.07 4.84 0.09 2.22 0.04 2.72 0.05 0.30 0.01 0.06 <0.01 

TREX Upper Bound Kenaga Mammalian Results 

Mammalian Body 

Ingestion 

(Fdry) 

Ingestion 

(Fwet) % body wgt FI 

Class Weight (g bwt/day) (g/day) consumed (kg-diet/day) 

 15 3 14 95 1.43E-02 

Herbivores/ 35 5 23 66 2.31E-02 

insectivores 1000 31 153 15 1.53E-01 

 15 3 3 21 3.18E-03 

Grainvores 35 5 5 15 5.13E-03 

 1000 31 34 3 3.40E-02 

Mammalian Body Adjusted Adjusted 

Class Weight LD50 NOAEL 

 15 0.00 151.65 

Herbivores/ 35 0.00 122.70 

insectivores 1000 0.00 53.07 

 15 0.00 151.65 

Grainvores 35 0.00 122.70 

 1000 0.00 53.07 
-Page 239 of 292- 

Appendix J. Example Terrplant (v. 1.2.1) Input and Output for Indaziflam 

TerrPlant v. 1.2.2 

Green values signify user inputs (Tables 1, 2 and 4). 

Input and output guidance is in popups indicated by red arrows. 

 

Table 1. Chemical Identity. 

Chemical Name Indaziflam 

PC code 80818 

Use Food 

Application Method Ground Spray 

Application Form liquid 

Solubility in Water 

(ppm) 1.2-4.4 

 

Table 2. Input parameters used to derive EECs. 

Input Parameter Symbol Value Units 

Application Rate A 0.085 lbs ai/A 

Incorporation I 1 none 

Runoff Fraction R 0.01 none 

Drift Fraction D 0.01 none 

 

Table 3. EECs for Indaziflam. Units in lbs ai/A. 

Description Equation EEC 

Runoff to dry areas (A/I)*R 0.00085 

Runoff to semi-aquatic areas (A/I)*R*10 0.0085 

Spray drift A*D 0.00085 

Total for dry areas ((A/I)*R)+(A*D) 0.0017 

Total for semi-aquatic areas ((A/I)*R*10)+(A*D) 0.00935 

 

Table 4. Plant survival and growth data used for RQ derivation. Units are in lbs ai/A. 

 Seedling Emergence Vegetative Vigor 

Plant type EC25 NOAEC EC25 NOAEC 

Monocot 0.00016 0.000062 0.0021 0.000932 

Dicot 0.00011 0.000062 0.00011 0.000062 

 

Table 5. RQ values for plants in dry and semi-aquatic areas exposed to Indaziflam through runoff 

and/or spray drift.* 

Plant Type Listed Status Dry Semi-Aquatic Spray Drift 

Monocot non-listed 10.63 58.44 5.31 

Monocot listed 27.42 150.81 13.71 

Dicot non-listed 15.45 85.00 7.73 

Dicot listed 27.42 150.81 13.71 

*If RQ > 1.0, the LOC is exceeded, resulting in potential for risk to that plant group. 
-Page 240 of 292- 

Appendix K. Earthworm Fugacity 

Use of fugacity approach to estimate exposures to small mammals consuming earthworms 

contaminated with pesticides 

The T-REX model (USEPA 2008) is useful for assessing exposures of terrestrial animals to 

pesticide residues on foliar surfaces of crops and seeds. The model cannot be used to assess 

pesticide exposures to terrestrial animals resulting from consumption of earthworms 

contaminated with pesticide mass present in the soil of the application site. In order to explore 

the potential exposures of mammals and birds to pesticides in the soil and earthworms on the 

treatment site, a simple fugacity approach can be employed to estimate concentrations of the 

pesticide of interest earthworms. 

Fugacity is most often regarded as the "escaping tendency" of a chemical from a particular 

phase. Fugacity (F) has units of pressure, generally pascals (Pa), and can be related to phase 

concentrations. For any particular environmental phase (e.g., water, soil, air, or biota) there is a 

corresponding "fugacity capacity" with units of mol/m3

-Pa and is denoted by Z. The relationship 

between fugacity, fugacity capacity and chemical concentration (C) is defined by Equation 1. 

Fugacity capacities for a given chemical are calculated for the phases of interest as part of the 

exposure point estimation methodology (Mackay and Paterson 1981). The following 

calculations of fugacity capacities for soil (ZS) and earthworms (ZE) (Equations 2 and 3, 

respectively) require several chemical-specific parameters and assumptions of system 

temperature (25oC) and steady state equilibrium. Parameter values relevant to Equations 2 and 3 

are defined in Table 1. 

Fugacity capacities for a given chemical are calculated for the phases of interest as part of the 

exposure point concentration estimation methodology. By definition, the ratio between Z values 

of different phases (compartments) equals the partitioning coefficient (e.g., Equation 4). 

In this approach, it is assumed that a pesticide partitions between the soil, the (pore) water and 

the air contained within the soil of the treatment site. It is assumed that earthworms dwelling 

within the soil are exposed to a pesticide via ingestion of contaminated soil. The concentration 

of a pesticide in earthworm tissues can be calculated according to Equation 5 (see Table 1 for 

Equation = *.1 FZC

H

K

Equation Z Sd

S

* ρ .2 =

H

KL

Equation Z OW

E

*

.3 =

OW

water

oloc K

Z

Z

Equation = tan .4
-Page 241 of 292- 

parameter definitions). 

Table 1. Summary of parameters relevant to earthworm fugacity model. 

Symbol Definition Units 

CE Chemical concentration in earthworm tissue mol/m3

CE' Chemical concentration in earthworm tissue g/kg 

CS Chemical concentration in soil mol/m3

H Henry’s Law constant m3-Pa/mol 

Kd Soil partitioning coefficient cm3/g 

KOW Octanol to water partition coefficient none 

L Lipid fraction of earthworm none 

MW molecular weight of chemical g/mol 

ZE Fugacity capacity of pesticide in earthworms mol/m3-Pa 

ZS Fugacity capacity of pesticide in soil mol/m3-Pa 

ρE density of earthworm kg/m3

ρS Bulk density of soil g/cm3

Equation 5 can be redefined using equations 2 and 3 as follows in Equation 6. Equation 6 is used 

to calculate the concentration of a pesticide in earthworms inhabiting the soil of treatment sites. 

CS is intended to be representative of the steady-state concentrations of the pesticide of interest in 

soil. This value is calculated using PRZM. Kd and Kow are chemical-specific parameters. Kd 

should be consistent with the value input into PRZM. ρS is dependant upon the soil properties of 

the selected PRZM scenario used to derive CS. L is based on the lipid content of earthworms, 

which was assumed to be 0.01 (Cobb et al. 1995). The resulting CE value is in units of mol/m3

. 

This value is converted to units of g/kg using equation 7. The density of the earthworm (ρE) is 

assumed to be 1000 kg/m3 (equivalent to density of water). 

References: 

Cobb, G.P., E.H. Hol, P.W. Allen, J.A Gagne, R.J. Kendall. 1995. Uptake, metabolism, and 

toxicity of terbufos in the earthworm (Lumbricus terrestris) exposed to COUNTER-15G in 

artificial soils. Environ. Toxicol. Chem. 14(2):279-285. 

Mackay, D. and S. Paterson. 1981. Calculating fugacity. Environ. Sci. Technol. 15: 1006-

1014. 

sd

S ow

E K

KLC Equation C

* ρ

**

.6 =

E

E

E

MWC Equation C

ρ

*

.7 ' =

⎟

⎟

⎠

⎞

⎜

⎜

⎝

⎛ =

S

E

SE Z

Z

Equation .5 CC *
-Page 242 of 292- 

USEPA. 2008. User’s Guide: T-REX Version 1.4.1 (Terrestrial Residue Exposure model). 

United States Environmental Protection Agency. Environmental Fate and Effects Division. 

Tables 2 -7 Input/Outputs, EECs and RQs for Chronic Toxicity of Indaziflam 

to Mammals and Birds from Proposed Granular Uses on Turf (Assumptions 

for Acute and Chronic Toxicities due to Non-definitive Endpoints) 

 

 Real 

Toxicity 

Endpoint 

Table 2. Characteristics of indazilfam. 

Parameter (symbol) Value Units 

Pesticide Name indaziflam none 

Molecular weight (MW) 301.36 g/mol 

Octanol-water Partition Coefficient (Kow) 631 none 

Soil partition coefficient (Kd) 9.1 cm3

/g 

 

Table 3. Soil parameters. 

Parameter (symbol) Value Units 

Bulk density of soil (ρs)* 1.65 g/cm3 

Concentration of pesticide in soil (estimated using PRZM) 0.06 g/m3 

Concentration of indazilfam in soil (Cs) 1.99E-04 mol/m3 

 

Table 4. Earthworm parameters. 

Parameter (symbol) Value Units 

Lipid fraction of earthworm (L) 0.01 none 

Water fraction of earthworm (W) 0.84 none 

Density of earthworm (ρE) 1000 kg/m3 

Concentration of indazilfam in earthworm (CE) 8.37E-05 mol/m3 

Concentration of indazilfam in earthworm (CE') 0.000025 g/kg* 

*equivalent to mg/g 
-Page 243 of 292- 

 

Table 5. Mammalian toxicity data for indazilfam. 

Endpoint/Parameter (symbol) Value Units 

Acute oral LD50 2000 mg/kg-bw LD50>2000 

Body weight of acute test animal* (TW) 350 g 

Chronic NOAEL 317 mg/kg-bw NOAEL=317

Chronic NOAEC 69 mg/kg-diet NOAEC=69 

Body weight of chronic test animal* (TW) 350 g 

Body weight of assessed animal (AW) 15 g 

Food intake of assessed animal (F) 17.9 g/day 

Body weight normalized food intake of assessed animal 

(FN) 1192 g/kg-bw-day 

*For rats, the default body weight is 350 g, if no other data are available. 

 

Table 6. Avian toxicity data for indaziflam. 

Endpoint/Parameter (symbol) Value Units 

Acute oral LD50 2000 mg/kg-bw LD50>2000 

Body weight of test animal for LD50* (TW) 1580 g 

Subacute dietary LC50 5007 mg/kg-diet LC50>5007 

Chronic NOAEC 95 mg/kg-diet NOAEC<95 

Mineau Scaling Factor** 1.15 none 

Body weight of assessed animal (AW) 20 g 

Food intake of assessed animal (F) 28.47 g/day 

Body weight normalized food intake of assessed animal 

(FN) 1424 g/kg-bw-day 

*Unless study specific data are available: For bobwhite quail, assume 178 g. For mallard duck, 

assume 1580 g. 

**Default value is 1.15. Consult Mineau et al. (1996) to obtain pesticide specific values. 

 

Table 7. Mammalian and avian risk quotients for indaziflam. 

Endpoint EEC 

Toxicity 

Value RQ 

Mammalian, acute dose-based 0.03 4395.7 0.00 

Mammalian, chronic dose-based 0.03 696.7 0.00 

Mammalian, chronic dietary-based 0.03 69.0 0.00 

Avian, acute, dose-based 0.04 1038.5 0.00 

Avian, acute, dietary-based 0.03 5007.0 0.00 

Avian, chronic, dietary-based 0.03 95.0 0.00 
-Page 244 of 292- 

Appendix L. LOCATES Output of Listed Species. 

Table M. Species Listing forProposed Uses of Indaziflam 

zhqSel_StateTaxa2

INVNAME SCINAME Status Taxa

Abalone, White Haliotis sorenseni Endangered Gastropod

Abutilon eremitopetalum (ncn) Abutilon eremitopetalum Endangered Dicot

Abutilon sandwicense (ncn) Abutilon sandwicense Endangered Dicot

Achyranthes mutica (ncn) Achyranthes mutica Endangered Dicot

Achyranthes splendens var. rotundata 

(ncn)

Achyranthes splendens var. rotundata Endangered Dicot

Adobe Sunburst, San Joaquin Pseudobahia peirsonii Threatened Dicot

A'e (Zanthoxylum dipetalum var. 

tomentosum)

Zanthoxylum dipetalum var. tomentosum Endangered Dicot

A'e (Zanthoxylum hawaiiense) Zanthoxylum hawaiiense Endangered Dicot

'Aiea (Nothocestrum breviflorum) Nothocestrum breviflorum Endangered Dicot

'Aiea (Nothocestrum peltatum) Nothocestrum peltatum Endangered Dicot

'Akepa, Hawaii Loxops coccineus coccineus Endangered Bird

'Akepa, Maui Loxops coccineus ochraceus Endangered Bird

'Akia Loa, Kauai (Hemignathus procerus) Hemignathus procerus Endangered Bird

'Akia Pola'au (Hemignathus munroi) Hemignathus munroi Endangered Bird

'Akoko (Chamaesyce celastroides var. 

kaenana)

Chamaesyce celastroides var. kaenana Endangered Dicot

'Akoko (Chamaesyce deppeana) Chamaesyce deppeana Endangered Dicot

'Akoko (Chamaesyce herbstii) Chamaesyce herbstii Endangered Dicot

'Akoko (Chamaesyce kuwaleana) Chamaesyce kuwaleana Endangered Dicot

'Akoko (Chamaesyce rockii) Chamaesyce rockii Endangered Dicot

'Akoko (Chamaesyce skottsbergii var. 

skottsbe

Chamaesyce skottsbergii var. kalaeloana Endangered Dicot

'Akoko (Euphorbia haeleeleana) Euphorbia haeleeleana Endangered Dicot

Alani (Melicope adscendens) Melicope adscendens Endangered Dicot

Alani (Melicope balloui) Melicope balloui Endangered Dicot

Alani (Melicope haupuensis) Melicope haupuensis Endangered Dicot

Alani (Melicope knudsenii) Melicope knudsenii Endangered Dicot

Alani (Melicope lydgatei) Melicope lydgatei Endangered Dicot

Alani (Melicope mucronulata) Melicope mucronulata Endangered Dicot

Alani (Melicope munroi) Melicope munroi Endangered Dicot

Alani (Melicope ovalis) Melicope ovalis Endangered Dicot

Alani (Melicope pallida) Melicope pallida Endangered Dicot

Alani (Melicope quadrangularis) Melicope quadrangularis Endangered Dicot

Alani (Melicope reflexa) Melicope reflexa Endangered Dicot

Alani (Melicope saint-johnii) Melicope saint-johnii Endangered Dicot

Alani (Melicope zahlbruckneri) Melicope zahlbruckneri Endangered Dicot

Albatross, Short-tailed Phoebastria (=Diomedea) albatrus Endangered Bird

Allocarya, Calistoga Plagiobothrys strictus Endangered Dicot

Alopecurus, Sonoma Alopecurus aequalis var. sonomensis Endangered Monocot
-Page 245 of 292- 

zhqSel_StateTaxa2

INVNAME SCINAME Status Taxa

Alsinidendron obovatum (ncn) Alsinidendron obovatum Endangered Dicot

Alsinidendron trinerve (ncn) Alsinidendron trinerve Endangered Dicot

Alsinidendron viscosum (ncn) Alsinidendron viscosum Endangered Dicot

Amaranth, Seabeach Amaranthus pumilus Threatened Dicot

Amaranth, Seabeach Amaranthus pumilus Threatened Dicot

Amaranth, Seabeach Amaranthus pumilus Threatened Dicot

Amaranth, Seabeach Amaranthus pumilus Threatened Dicot

Amaranthus brownii (ncn) Amaranthus brownii Endangered Dicot

Ambersnail, Kanab Oxyloma haydeni kanabensis Endangered Gastropod

Ambrosia, San Diego Ambrosia pumila Endangered Dicot

Ambrosia, South Texas Ambrosia cheiranthifolia Endangered Dicot

Amole, Cammatta Canyon Chlorogalum purpureum var. reductum Threatened Monocot

Amole, Purple Chlorogalum purpureum var. purpureum Threatened Monocot

Amphianthus, Little Amphianthus pusillus Threatened Dicot

Amphianthus, Little Amphianthus pusillus Threatened Dicot

Amphianthus, Little Amphianthus pusillus Threatened Dicot

Amphipod, Hay's Spring Stygobromus hayi Endangered Crustacean

Amphipod, Illinois Cave Gammarus acherondytes Endangered Crustacean

Amphipod, Kauai Cave Spelaeorchestia koloana Endangered Crustacean

Amphipod, Noel's Gammarus desperatus Endangered Crustacean

Amphipod, Peck's Cave Stygobromus (=Stygonectes) pecki Endangered Crustacean

'Anaunau (Lepidium arbuscula) Lepidium arbuscula Endangered Dicot

Anole, Culebra Island Giant Anolis roosevelti Endangered Reptile

'Anunu (Sicyos alba) Sicyos alba Endangered Dicot

Aristida chaseae (ncn) Aristida chaseae Endangered Monocot

Arrowhead, Bunched Sagittaria fasciculata Endangered Monocot

Arrowhead, Bunched Sagittaria fasciculata Endangered Monocot

Asplenium fragile var. insulare (ncn) Asplenium fragile var. insulare Endangered Ferns

Aster, Decurrent False Boltonia decurrens Threatened Dicot

Aster, Decurrent False Boltonia decurrens Threatened Dicot

Aster, Florida Golden Chrysopsis floridana Endangered Dicot

Aster, Ruth's Golden Pityopsis ruthii Endangered Dicot

Auerodendron pauciflorum (ncn) Auerodendron pauciflorum Endangered Dicot

Aupaka (Isodendrion hosakae) Isodendrion hosakae Endangered Dicot

Aupaka (Isodendrion laurifolium) Isodendrion laurifolium Endangered Dicot

Aupaka (Isodendrion longifolium) Isodendrion longifolium Threatened Dicot

Avens, Spreading Geum radiatum Endangered Dicot

Avens, Spreading Geum radiatum Endangered Dicot

'Awikiwiki (Canavalia molokaiensis) Canavalia molokaiensis Endangered Dicot

'Awiwi (Centaurium sebaeoides) Centaurium sebaeoides Endangered Dicot

'Awiwi (Hedyotis cookiana) Hedyotis cookiana Endangered Dicot

Ayenia, Texas Ayenia limitaris Endangered Dicot

Baccharis, Encinitas Baccharis vanessae Threatened Dicot

Bankclimber, Purple Elliptoideus sloatianus Threatened Bivalve

Bankclimber, Purple Elliptoideus sloatianus Threatened Bivalve

Barbara Buttons, Mohr's Marshallia mohrii Threatened Dicot
-Page 246 of 292- 

zhqSel_StateTaxa2

INVNAME SCINAME Status Taxa

Barbara Buttons, Mohr's Marshallia mohrii Threatened Dicot

Barberry, Island Berberis pinnata ssp. insularis Endangered Dicot

Barberry, Nevin's Berberis nevinii Endangered Dicot

Bariaco Trichilia triacantha Endangered Dicot

Bat, Gray Myotis grisescens Endangered Mammal

Bat, Gray Myotis grisescens Endangered Mammal

Bat, Gray Myotis grisescens Endangered Mammal

Bat, Gray Myotis grisescens Endangered Mammal

Bat, Gray Myotis grisescens Endangered Mammal

Bat, Gray Myotis grisescens Endangered Mammal

Bat, Gray Myotis grisescens Endangered Mammal

Bat, Gray Myotis grisescens Endangered Mammal

Bat, Gray Myotis grisescens Endangered Mammal

Bat, Gray Myotis grisescens Endangered Mammal

Bat, Gray Myotis grisescens Endangered Mammal

Bat, Gray Myotis grisescens Endangered Mammal

Bat, Gray Myotis grisescens Endangered Mammal

Bat, Gray Myotis grisescens Endangered Mammal

Bat, Gray Myotis grisescens Endangered Mammal

Bat, Gray Myotis grisescens Endangered Mammal

Bat, Hawaiian Hoary Lasiurus cinereus semotus Endangered Mammal

Bat, Indiana Myotis sodalis Endangered Mammal

Bat, Indiana Myotis sodalis Endangered Mammal

Bat, Indiana Myotis sodalis Endangered Mammal

Bat, Indiana Myotis sodalis Endangered Mammal

Bat, Indiana Myotis sodalis Endangered Mammal

Bat, Indiana Myotis sodalis Endangered Mammal

Bat, Indiana Myotis sodalis Endangered Mammal

Bat, Indiana Myotis sodalis Endangered Mammal

Bat, Indiana Myotis sodalis Endangered Mammal

Bat, Indiana Myotis sodalis Endangered Mammal

Bat, Indiana Myotis sodalis Endangered Mammal

Bat, Indiana Myotis sodalis Endangered Mammal

Bat, Indiana Myotis sodalis Endangered Mammal

Bat, Indiana Myotis sodalis Endangered Mammal

Bat, Indiana Myotis sodalis Endangered Mammal

Bat, Indiana Myotis sodalis Endangered Mammal

Bat, Indiana Myotis sodalis Endangered Mammal

Bat, Indiana Myotis sodalis Endangered Mammal

Bat, Indiana Myotis sodalis Endangered Mammal

Bat, Indiana Myotis sodalis Endangered Mammal

Bat, Indiana Myotis sodalis Endangered Mammal

Bat, Indiana Myotis sodalis Endangered Mammal

Bat, Indiana Myotis sodalis Endangered Mammal

Bat, Indiana Myotis sodalis Endangered Mammal

Bat, Indiana Myotis sodalis Endangered Mammal
-Page 247 of 292- 

zhqSel_StateTaxa2

INVNAME SCINAME Status Taxa

Bat, Indiana Myotis sodalis Endangered Mammal

Bat, Indiana Myotis sodalis Endangered Mammal

Bat, Lesser (=Sanborn's) Long-nosed Leptonycteris curasoae yerbabuenae Endangered Mammal

Bat, Lesser (=Sanborn's) Long-nosed Leptonycteris curasoae yerbabuenae Endangered Mammal

Bat, Mexican Long-nosed Leptonycteris nivalis Endangered Mammal

Bat, Mexican Long-nosed Leptonycteris nivalis Endangered Mammal

Bat, Ozark Big-eared Corynorhinus (=Plecotus) townsendii ingens Endangered Mammal

Bat, Ozark Big-eared Corynorhinus (=Plecotus) townsendii ingens Endangered Mammal

Bat, Virginia Big-eared Corynorhinus (=Plecotus) townsendii virginianus Endangered Mammal

Bat, Virginia Big-eared Corynorhinus (=Plecotus) townsendii virginianus Endangered Mammal

Bat, Virginia Big-eared Corynorhinus (=Plecotus) townsendii virginianus Endangered Mammal

Bat, Virginia Big-eared Corynorhinus (=Plecotus) townsendii virginianus Endangered Mammal

Bat, Virginia Big-eared Corynorhinus (=Plecotus) townsendii virginianus Endangered Mammal

Beaked-rush, Knieskern's Rhynchospora knieskernii Threatened Monocot

Bear, Grizzly Ursus arctos horribilis Threatened Mammal

Bear, Grizzly Ursus arctos horribilis Threatened Mammal

Bear, Grizzly Ursus arctos horribilis Threatened Mammal

Bear, Grizzly Ursus arctos horribilis Threatened Mammal

Bear, Louisiana Black Ursus americanus luteolus Threatened Mammal

Bear, Louisiana Black Ursus americanus luteolus Threatened Mammal

Bear, Louisiana Black Ursus americanus luteolus Threatened Mammal

Beardtongue, Penland Penstemon penlandii Endangered Dicot

Beargrass, Britton's Nolina brittoniana Endangered Monocot

Bear-poppy, Dwarf Arctomecon humilis Endangered Dicot

Beauty, Harper's Harperocallis flava Endangered Monocot

Bedstraw, El Dorado Galium californicum ssp. sierrae Endangered Dicot

Bedstraw, Island Galium buxifolium Endangered Dicot

Beetle, American Burying Nicrophorus americanus Endangered Insect

Beetle, American Burying Nicrophorus americanus Endangered Insect

Beetle, American Burying Nicrophorus americanus Endangered Insect

Beetle, American Burying Nicrophorus americanus Endangered Insect

Beetle, American Burying Nicrophorus americanus Endangered Insect

Beetle, American Burying Nicrophorus americanus Endangered Insect

Beetle, American Burying Nicrophorus americanus Endangered Insect

Beetle, American Burying Nicrophorus americanus Endangered Insect

Beetle, American Burying Nicrophorus americanus Endangered Insect

Beetle, American Burying Nicrophorus americanus Endangered Insect

Beetle, American Burying Nicrophorus americanus Endangered Insect

Beetle, Coffin Cave Mold Batrisodes texanus Endangered Insect

Beetle, Comal Springs Dryopid Stygoparnus comalensis Endangered Insect

Beetle, Comal Springs Riffle Heterelmis comalensis Endangered Insect

Beetle, Delta Green Ground Elaphrus viridis Threatened Insect

Beetle, Helotes Mold Batrisodes venyivi Endangered Insect

Beetle, Hungerford's Crawling Water Brychius hungerfordi Endangered Insect

Beetle, Kretschmarr Cave Mold Texamaurops reddelli Endangered Insect

Beetle, Mount Hermon June Polyphylla barbata Endangered Insect
-Page 248 of 292- 

zhqSel_StateTaxa2

INVNAME SCINAME Status Taxa

Beetle, Northeastern Beach Tiger Cicindela dorsalis dorsalis Threatened Insect

Beetle, Northeastern Beach Tiger Cicindela dorsalis dorsalis Threatened Insect

Beetle, Northeastern Beach Tiger Cicindela dorsalis dorsalis Threatened Insect

Beetle, Ohlone Tiger Cicindela ohlone Endangered Insect

Beetle, Puritan Tiger Cicindela puritana Threatened Insect

Beetle, Puritan Tiger Cicindela puritana Threatened Insect

Beetle, Puritan Tiger Cicindela puritana Threatened Insect

Beetle, Salt Creek Tiger Cicindela nevadica lincolniana Endangered Insect

Beetle, Tooth Cave Ground Rhadine persephone Endangered Insect

Beetle, Valley Elderberry Longhorn Desmocerus californicus dimorphus Threatened Insect

Bellflower, Brooksville Campanula robinsiae Endangered Dicot

Birch, Virginia Round-leaf Betula uber Threatened Dicot

Bird's-beak, Palmate-bracted Cordylanthus palmatus Endangered Dicot

Bird's-beak, Pennell's Cordylanthus tenuis ssp. capillaris Endangered Dicot

Bird's-beak, salt marsh Cordylanthus maritimus ssp. maritimus Endangered Dicot

Bird's-beak, Soft Cordylanthus mollis ssp. mollis Endangered Dicot

Birds-in-a-nest, White Macbridea alba Threatened Dicot

Bittercress, Small-anthered Cardamine micranthera Endangered Dicot

Bittercress, Small-anthered Cardamine micranthera Endangered Dicot

Blackbird, Yellow-shouldered Agelaius xanthomus Endangered Bird

Bladderpod, Dudley Bluffs Lesquerella congesta Threatened Dicot

Bladderpod, Kodachrome Lesquerella tumulosa Endangered Dicot

Bladderpod, Lyrate Lesquerella lyrata Threatened Dicot

Bladderpod, Missouri Lesquerella filiformis Threatened Dicot

Bladderpod, Missouri Lesquerella filiformis Threatened Dicot

Bladderpod, San Bernardino Mountains Lesquerella kingii ssp. bernardina Endangered Dicot

Bladderpod, Spring Creek Lesquerella perforata Endangered Dicot

Bladderpod, White Lesquerella pallida Endangered Dicot

Bladderpod, Zapata Lesquerella thamnophila Endangered Dicot

Blazing Star, Ash Meadows Mentzelia leucophylla Threatened Dicot

Blazing Star, Heller's Liatris helleri Threatened Dicot

Blazing Star, Scrub Liatris ohlingerae Endangered Dicot

Bluecurls, Hidden Lake Trichostema austromontanum ssp. compactum Threatened Dicot

Bluegrass, Hawaiian Poa sandvicensis Endangered Monocot

Bluegrass, Mann's (Poa mannii) Poa mannii Endangered Monocot

Bluegrass, Napa Poa napensis Endangered Monocot

Bluegrass, San Bernardino Poa atropurpurea Endangered Monocot

Blue-star, Kearney's Amsonia kearneyana Endangered Dicot

Bluet, Roan Mountain Hedyotis purpurea var. montana Endangered Dicot

Bluet, Roan Mountain Hedyotis purpurea var. montana Endangered Dicot

Boa, Mona Epicrates monensis monensis Threatened Reptile

Boa, Puerto Rican Epicrates inornatus Endangered Reptile

Bobwhite, Masked Colinus virginianus ridgwayi Endangered Bird

Bonamia menziesii (ncn) Bonamia menziesii Endangered Dicot

Bonamia, Florida Bonamia grandiflora Threatened Dicot

Boxwood, Vahl's Buxus vahlii Endangered Dicot
-Page 249 of 292- 

zhqSel_StateTaxa2

INVNAME SCINAME Status Taxa

Brodiaea, Chinese Camp Brodiaea pallida Threatened Monocot

Brodiaea, Thread-leaved Brodiaea filifolia Threatened Monocot

Broom, San Clemente Island Lotus dendroideus ssp. traskiae Endangered Dicot

Buckwheat, Cushenbury Eriogonum ovalifolium var. vineum Endangered Dicot

Buckwheat, Ione (incl. Irish Hill) Eriogonum apricum (incl. var. prostratum) Endangered Dicot

Buckwheat, Scrub Eriogonum longifolium var. gnaphalifolium Threatened Dicot

Buckwheat, Southern Mountain Wild Eriogonum kennedyi var. austromontanum Threatened Dicot

Buckwheat, Steamboat Eriogonum ovalifolium var. williamsiae Endangered Dicot

Bulrush, Northeastern (=Barbed Bristle) Scirpus ancistrochaetus Endangered Monocot

Bulrush, Northeastern (=Barbed Bristle) Scirpus ancistrochaetus Endangered Monocot

Bulrush, Northeastern (=Barbed Bristle) Scirpus ancistrochaetus Endangered Monocot

Bulrush, Northeastern (=Barbed Bristle) Scirpus ancistrochaetus Endangered Monocot

Bulrush, Northeastern (=Barbed Bristle) Scirpus ancistrochaetus Endangered Monocot

Bulrush, Northeastern (=Barbed Bristle) Scirpus ancistrochaetus Endangered Monocot

Bush-mallow, San Clemente Island Malacothamnus clementinus Endangered Dicot

Bush-mallow, Santa Cruz Island Malacothamnus fasciculatus var. nesioticus Endangered Dicot

Buttercup, Autumn Ranunculus aestivalis (=acriformis) Endangered Dicot

Butterfly Plant, Colorado Gaura neomexicana var. coloradensis Threatened Dicot

Butterfly Plant, Colorado Gaura neomexicana var. coloradensis Threatened Dicot

Butterfly Plant, Colorado Gaura neomexicana var. coloradensis Threatened Dicot

Butterfly, Bay Checkerspot (Wright's 

euphydryas)

Euphydryas editha bayensis Threatened Insect

Butterfly, Behren's Silverspot Speyeria zerene behrensii Endangered Insect

Butterfly, Callippe Silverspot Speyeria callippe callippe Endangered Insect

Butterfly, El Segundo Blue Euphilotes battoides allyni Endangered Insect

Butterfly, Fender's Blue Icaricia icarioides fenderi Endangered Insect

Butterfly, Karner Blue Lycaeides melissa samuelis Endangered Insect

Butterfly, Karner Blue Lycaeides melissa samuelis Endangered Insect

Butterfly, Karner Blue Lycaeides melissa samuelis Endangered Insect

Butterfly, Karner Blue Lycaeides melissa samuelis Endangered Insect

Butterfly, Karner Blue Lycaeides melissa samuelis Endangered Insect

Butterfly, Karner Blue Lycaeides melissa samuelis Endangered Insect

Butterfly, Karner Blue Lycaeides melissa samuelis Endangered Insect

Butterfly, Karner Blue Lycaeides melissa samuelis Endangered Insect

Butterfly, Lange's Metalmark Apodemia mormo langei Endangered Insect

Butterfly, Lotis Blue Lycaeides argyrognomon lotis Endangered Insect

Butterfly, Mission Blue Icaricia icarioides missionensis Endangered Insect

Butterfly, Mitchell's Satyr Neonympha mitchellii mitchellii Endangered Insect

Butterfly, Mitchell's Satyr Neonympha mitchellii mitchellii Endangered Insect

Butterfly, Mitchell's Satyr Neonympha mitchellii mitchellii Endangered Insect

Butterfly, Mitchell's Satyr Neonympha mitchellii mitchellii Endangered Insect

Butterfly, Myrtle's Silverspot Speyeria zerene myrtleae Endangered Insect

Butterfly, Oregon Silverspot Speyeria zerene hippolyta Threatened Insect

Butterfly, Oregon Silverspot Speyeria zerene hippolyta Threatened Insect

Butterfly, Oregon Silverspot Speyeria zerene hippolyta Threatened Insect

Butterfly, Palos Verdes Blue Glaucopsyche lygdamus palosverdesensis Endangered Insect
-Page 250 of 292- 

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INVNAME SCINAME Status Taxa

Butterfly, Quino Checkerspot Euphydryas editha quino (=E. e. wrighti) Endangered Insect

Butterfly, Saint Francis' Satyr Neonympha mitchellii francisci Endangered Insect

Butterfly, Saint Francis' Satyr Neonympha mitchellii francisci Endangered Insect

Butterfly, San Bruno Elfin Callophrys mossii bayensis Endangered Insect

Butterfly, Schaus Swallowtail Heraclides aristodemus ponceanus Endangered Insect

Butterfly, Smith's Blue Euphilotes enoptes smithi Endangered Insect

Butterfly, Uncompahgre Fritillary Boloria acrocnema Endangered Insect

Butterweed, Layne's Senecio layneae Threatened Dicot

Butterwort, Godfrey's Pinguicula ionantha Threatened Dicot

Button-celery, San Diego Eryngium aristulatum var. parishii Endangered Dicot

Cactus, Arizona Hedgehog Echinocereus triglochidiatus var. arizonicus Endangered Dicot

Cactus, Bakersfield Opuntia treleasei Endangered Dicot

Cactus, Black Lace Echinocereus reichenbachii var. albertii Endangered Dicot

Cactus, Brady Pincushion Pediocactus bradyi Endangered Dicot

Cactus, Bunched Cory Coryphantha ramillosa Threatened Dicot

Cactus, Chisos Mountain Hedgehog Echinocereus chisoensis var. chisoensis Threatened Dicot

Cactus, Cochise Pincushion Coryphantha robbinsorum Threatened Dicot

Cactus, Key Tree Pilosocereus robinii Endangered Dicot

Cactus, Knowlton Pediocactus knowltonii Endangered Dicot

Cactus, Knowlton Pediocactus knowltonii Endangered Dicot

Cactus, Kuenzler Hedgehog Echinocereus fendleri var. kuenzleri Endangered Dicot

Cactus, Lee Pincushion Coryphantha sneedii var. leei Threatened Dicot

Cactus, Lloyd's Mariposa Echinomastus mariposensis Threatened Dicot

Cactus, Mesa Verde Sclerocactus mesae-verdae Threatened Dicot

Cactus, Mesa Verde Sclerocactus mesae-verdae Threatened Dicot

Cactus, Nellie Cory Coryphantha minima Endangered Dicot

Cactus, Nichol's Turk's Head Echinocactus horizonthalonius var. nicholii Endangered Dicot

Cactus, Peebles Navajo Pediocactus peeblesianus peeblesianus Endangered Dicot

Cactus, Pima Pineapple Coryphantha scheeri var. robustispina Endangered Dicot

Cactus, San Rafael Pediocactus despainii Endangered Dicot

Cactus, Siler Pincushion Pediocactus (=Echinocactus,=Utahia) sileri Threatened Dicot

Cactus, Siler Pincushion Pediocactus (=Echinocactus,=Utahia) sileri Threatened Dicot

Cactus, Sneed Pincushion Coryphantha sneedii var. sneedii Endangered Dicot

Cactus, Sneed Pincushion Coryphantha sneedii var. sneedii Endangered Dicot

Cactus, Star Astrophytum asterias Endangered Dicot

Cactus, Tobusch Fishhook Ancistrocactus tobuschii Endangered Dicot

Cactus, Uinta Basin Hookless Sclerocactus glaucus Threatened Dicot

Cactus, Uinta Basin Hookless Sclerocactus glaucus Threatened Dicot

Cactus, Winkler Pediocactus winkleri Threatened Dicot

Cactus, Wright Fishhook Sclerocactus wrightiae Endangered Dicot

Calyptranthes Thomasiana (ncn) Calyptranthes thomasiana Endangered Dicot

Campeloma, Slender Campeloma decampi Endangered Gastropod

Campion, Fringed Silene polypetala Endangered Dicot

Campion, Fringed Silene polypetala Endangered Dicot

Capa Rosa Callicarpa ampla Endangered Dicot

Caracara, Audubon's Crested Polyborus plancus audubonii Threatened Bird
-Page 251 of 292- 

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INVNAME SCINAME Status Taxa

Caribou, Woodland Rangifer tarandus caribou Endangered Mammal

Caribou, Woodland Rangifer tarandus caribou Endangered Mammal

Catchfly, Spalding's Silene spaldingii Threatened Dicot

Catchfly, Spalding's Silene spaldingii Threatened Dicot

Catchfly, Spalding's Silene spaldingii Threatened Dicot

Catchfly, Spalding's Silene spaldingii Threatened Dicot

Catesbaea Melanocarpa (ncn) Catesbaea melanocarpa Endangered Dicot

Catfish, Yaqui Ictalurus pricei Threatened Fish

Cat's-eye, Terlingua Creek Cryptantha crassipes Endangered Dicot

Cavefish, Alabama Speoplatyrhinus poulsoni Endangered Fish

Cavefish, Ozark Amblyopsis rosae Threatened Fish

Cavefish, Ozark Amblyopsis rosae Threatened Fish

Cavefish, Ozark Amblyopsis rosae Threatened Fish

Cavesnail, Tumbling Creek Antrobia culveri Endangered Gastropod

Ceanothus, Coyote Ceanothus ferrisae Endangered Dicot

Ceanothus, Pine Hill Ceanothus roderickii Endangered Dicot

Ceanothus, Vail Lake Ceanothus ophiochilus Threatened Dicot

Centaury, Spring-loving Centaurium namophilum Threatened Dicot

Centaury, Spring-loving Centaurium namophilum Threatened Dicot

Chaffseed, American Schwalbea americana Endangered Dicot

Chaffseed, American Schwalbea americana Endangered Dicot

Chaffseed, American Schwalbea americana Endangered Dicot

Chaffseed, American Schwalbea americana Endangered Dicot

Chaffseed, American Schwalbea americana Endangered Dicot

Chaffseed, American Schwalbea americana Endangered Dicot

Chaffseed, American Schwalbea americana Endangered Dicot

Chaffseed, American Schwalbea americana Endangered Dicot

Chamaecrista glandulosa (ncn) Chamaecrista glandulosa var. mirabilis Endangered Dicot

Chamaesyce Halemanui (ncn) Chamaesyce halemanui Endangered Dicot

Checker-mallow, Keck's Sidalcea keckii Endangered Dicot

Checker-mallow, Kenwood Marsh Sidalcea oregana ssp. valida Endangered Dicot

Checker-mallow, Nelson's Sidalcea nelsoniana Threatened Dicot

Checker-mallow, Nelson's Sidalcea nelsoniana Threatened Dicot

Checker-mallow, Pedate Sidalcea pedata Endangered Dicot

Checker-mallow, Wenatchee Mountains Sidalcea oregana var. calva Endangered Dicot

Chub, Bonytail Gila elegans Endangered Fish

Chub, Bonytail Gila elegans Endangered Fish

Chub, Bonytail Gila elegans Endangered Fish

Chub, Bonytail Gila elegans Endangered Fish

Chub, Bonytail Gila elegans Endangered Fish

Chub, Borax Lake Gila boraxobius Endangered Fish

Chub, Chihuahua Gila nigrescens Threatened Fish

Chub, Gila Gila intermedia Endangered Fish

Chub, Gila Gila intermedia Endangered Fish

Chub, Humpback Gila cypha Endangered Fish

Chub, Humpback Gila cypha Endangered Fish
-Page 252 of 292- 

zhqSel_StateTaxa2

INVNAME SCINAME Status Taxa

Chub, Humpback Gila cypha Endangered Fish

Chub, Humpback Gila cypha Endangered Fish

Chub, Hutton Tui Gila bicolor ssp. Threatened Fish

Chub, Hutton Tui Gila bicolor ssp. Threatened Fish

Chub, Mohave Tui Gila bicolor mohavensis Endangered Fish

Chub, Oregon Oregonichthys crameri Endangered Fish

Chub, Owens Tui Gila bicolor snyderi Endangered Fish

Chub, Pahranagat Roundtail Gila robusta jordani Endangered Fish

Chub, Slender Erimystax cahni Threatened Fish

Chub, Slender Erimystax cahni Threatened Fish

Chub, Sonora Gila ditaenia Threatened Fish

Chub, Spotfin Erimonax monachus Threatened Fish

Chub, Spotfin Erimonax monachus Threatened Fish

Chub, Spotfin Erimonax monachus Threatened Fish

Chub, Spotfin Erimonax monachus Threatened Fish

Chub, Spotfin Erimonax monachus Threatened Fish

Chub, Virgin River Gila seminuda (=robusta) Endangered Fish

Chub, Virgin River Gila seminuda (=robusta) Endangered Fish

Chub, Virgin River Gila seminuda (=robusta) Endangered Fish

Chub, Yaqui Gila purpurea Endangered Fish

Chumbo, Higo Harrisia portoricensis Threatened Dicot

Chupacallos Pleodendron macranthum Endangered Dicot

Cladonia, Florida Perforate Cladonia perforata Endangered Lichen

Clarkia, Pismo Clarkia speciosa ssp. immaculata Endangered Dicot

Clarkia, Presidio Clarkia franciscana Endangered Dicot

Clarkia, Springville Clarkia springvillensis Threatened Dicot

Clarkia, Vine Hill Clarkia imbricata Endangered Dicot

Cliffrose, Arizona Purshia (=cowania) subintegra Endangered Dicot

Clover, Fleshy Owl's Castilleja campestris ssp. succulenta Threatened Dicot

Clover, Leafy Prairie Dalea foliosa Endangered Dicot

Clover, Leafy Prairie Dalea foliosa Endangered Dicot

Clover, Leafy Prairie Dalea foliosa Endangered Dicot

Clover, Monterey Trifolium trichocalyx Endangered Dicot

Clover, Prairie Bush Lespedeza leptostachya Threatened Dicot

Clover, Prairie Bush Lespedeza leptostachya Threatened Dicot

Clover, Prairie Bush Lespedeza leptostachya Threatened Dicot

Clover, Prairie Bush Lespedeza leptostachya Threatened Dicot

Clover, Running Buffalo Trifolium stoloniferum Endangered Dicot

Clover, Running Buffalo Trifolium stoloniferum Endangered Dicot

Clover, Running Buffalo Trifolium stoloniferum Endangered Dicot

Clover, Running Buffalo Trifolium stoloniferum Endangered Dicot

Clover, Running Buffalo Trifolium stoloniferum Endangered Dicot

Clover, Showy Indian Trifolium amoenum Endangered Dicot

Cobana Negra Stahlia monosperma Threatened Dicot

Combshell, Southern (=Penitent mussel) Epioblasma penita Endangered Bivalve

Combshell, Southern (=Penitent mussel) Epioblasma penita Endangered Bivalve
-Page 253 of 292- 

zhqSel_StateTaxa2

INVNAME SCINAME Status Taxa

Combshell, Upland Epioblasma metastriata Endangered Bivalve

Combshell, Upland Epioblasma metastriata Endangered Bivalve

Combshell, Upland Epioblasma metastriata Endangered Bivalve

Condor, California Gymnogyps californianus Endangered Bird

Condor, California Gymnogyps californianus Endangered Bird

Coneflower, Smooth Echinacea laevigata Endangered Dicot

Coneflower, Smooth Echinacea laevigata Endangered Dicot

Coneflower, Smooth Echinacea laevigata Endangered Dicot

Coneflower, Tennessee Purple Echinacea tennesseensis Endangered Dicot

Coot, Hawaiian (=Alae keo keo) Fulica americana alai Endangered Bird

Coqui, Golden Eleutherodactylus jasperi Threatened Amphibian

Cordia bellonis (ncn) Cordia bellonis Endangered Dicot

Coyote-thistle, Loch Lomond Eryngium constancei Endangered Dicot

Crane, Mississippi Sandhill Grus canadensis pulla Endangered Bird

Crane, Whooping Grus americana Endangered Bird

Crane, Whooping Grus americana Endangered Bird

Crane, Whooping Grus americana Endangered Bird

Crane, Whooping Grus americana Endangered Bird

Crane, Whooping Grus americana Endangered Bird

Crane, Whooping Grus americana Endangered Bird

Crane, Whooping Grus americana Endangered Bird

Crane, Whooping Grus americana Endangered Bird

Crane, Whooping Grus americana Endangered Bird

Crane, Whooping Grus americana Endangered Bird

Crane, Whooping Grus americana Endangered Bird

Cranichis Ricartii Cranichis ricartii Endangered Monocot

Crayfish, Cave (Cambarus aculabrum) Cambarus aculabrum Endangered Crustacean

Crayfish, Cave (Cambarus aculabrum) Cambarus aculabrum Endangered Crustacean

Crayfish, Cave (Cambarus zophonastes) Cambarus zophonastes Endangered Crustacean

Crayfish, Nashville Orconectes shoupi Endangered Crustacean

Crayfish, Shasta Pacifastacus fortis Endangered Crustacean

Creeper, Hawaii Oreomystis mana Endangered Bird

Creeper, Molokai (Kakawahie) Paroreomyza flammea Endangered Bird

Creeper, Oahu (Alauwahio) Paroreomyza maculata Endangered Bird

Crocodile, American Crocodylus acutus Threatened Reptile

Crow, Hawaiian ('Alala) Corvus hawaiiensis Endangered Bird

Crownbeard, Big-leaved Verbesina dissita Threatened Dicot

Crownscale, San Jacinto Valley Atriplex coronata var. notatior Endangered Dicot

Cui-ui Chasmistes cujus Endangered Fish

Curlew, Eskimo Numenius borealis Endangered Bird

Curlew, Eskimo Numenius borealis Endangered Bird

Curlew, Eskimo Numenius borealis Endangered Bird

Curlew, Eskimo Numenius borealis Endangered Bird

Cyanea undulata (ncn) Cyanea undulata Endangered Dicot

Cycladenia, Jones Cycladenia jonesii (=humilis) Threatened Dicot

Cycladenia, Jones Cycladenia jonesii (=humilis) Threatened Dicot
-Page 254 of 292- 

zhqSel_StateTaxa2

INVNAME SCINAME Status Taxa

Cypress, Gowen Cupressus goveniana ssp. goveniana Threatened Conf/cycds

Cypress, Santa Cruz Cupressus abramsiana Endangered Conf/cycds

Dace, Ash Meadows Speckled Rhinichthys osculus nevadensis Endangered Fish

Dace, Ash Meadows Speckled Rhinichthys osculus nevadensis Endangered Fish

Dace, Blackside Phoxinus cumberlandensis Threatened Fish

Dace, Blackside Phoxinus cumberlandensis Threatened Fish

Dace, Blackside Phoxinus cumberlandensis Threatened Fish

Dace, Clover Valley Speckled Rhinichthys osculus oligoporus Endangered Fish

Dace, Desert Eremichthys acros Threatened Fish

Dace, Foskett Speckled Rhinichthys osculus ssp. Threatened Fish

Dace, Independence Valley Speckled Rhinichthys osculus lethoporus Endangered Fish

Dace, Kendall Warm Springs Rhinichthys osculus thermalis Endangered Fish

Dace, Moapa Moapa coriacea Endangered Fish

Dace, Moapa Moapa coriacea Endangered Fish

Daisy, Lakeside Hymenoxys herbacea Threatened Dicot

Daisy, Lakeside Hymenoxys herbacea Threatened Dicot

Daisy, Lakeside Hymenoxys herbacea Threatened Dicot

Daisy, Maguire Erigeron maguirei Threatened Dicot

Daisy, Parish's Erigeron parishii Threatened Dicot

Daisy, Willamette Erigeron decumbens var. decumbens Endangered Dicot

Daphnopsis hellerana (ncn) Daphnopsis hellerana Endangered Dicot

Darter, Amber Percina antesella Endangered Fish

Darter, Amber Percina antesella Endangered Fish

Darter, Bayou Etheostoma rubrum Threatened Fish

Darter, Bluemask (=jewel) Etheostoma / Endangered Fish

Darter, Bluemask (=jewel) Etheostoma / Endangered Fish

Darter, Boulder Etheostoma wapiti Endangered Fish

Darter, Boulder Etheostoma wapiti Endangered Fish

Darter, Cherokee Etheostoma scotti Threatened Fish

Darter, Duskytail Etheostoma percnurum Endangered Fish

Darter, Duskytail Etheostoma percnurum Endangered Fish

Darter, Etowah Etheostoma etowahae Endangered Fish

Darter, Fountain Etheostoma fonticola Endangered Fish

Darter, Goldline Percina aurolineata Threatened Fish

Darter, Goldline Percina aurolineata Threatened Fish

Darter, Leopard Percina pantherina Threatened Fish

Darter, Leopard Percina pantherina Threatened Fish

Darter, Maryland Etheostoma sellare Endangered Fish

Darter, Niangua Etheostoma nianguae Threatened Fish

Darter, Okaloosa Etheostoma okaloosae Endangered Fish

Darter, Relict Etheostoma chienense Endangered Fish

Darter, Slackwater Etheostoma boschungi Threatened Fish

Darter, Slackwater Etheostoma boschungi Threatened Fish

Darter, Snail Percina tanasi Threatened Fish

Darter, Snail Percina tanasi Threatened Fish

Darter, Snail Percina tanasi Threatened Fish
-Page 255 of 292- 

zhqSel_StateTaxa2

INVNAME SCINAME Status Taxa

Darter, Vermilion Etheostoma chermocki Endangered Fish

Darter, Watercress Etheostoma nuchale Endangered Fish

Dawn-flower, Texas Prairie (=Texas 

Bitterweed)

Hymenoxys texana Endangered Dicot

Deer, Columbian White-tailed Odocoileus virginianus leucurus Endangered Mammal

Deer, Columbian White-tailed Odocoileus virginianus leucurus Endangered Mammal

Deer, Key Odocoileus virginianus clavium Endangered Mammal

Delissea rhytodisperma (ncn) Delissea rhytidosperma Endangered Dicot

Diellia erecta (ncn) Diellia erecta Endangered Ferns

Diellia falcata (ncn) Diellia falcata Endangered Ferns

Diellia pallida (ncn) Diellia pallida Endangered Ferns

Diellia unisora (ncn) Diellia unisora Endangered Ferns

Diplazium molokaiense (ncn) Diplazium molokaiense Endangered Ferns

Dogweed, Ashy Thymophylla tephroleuca Endangered Dicot

Dragonfly, Hine's Emerald Somatochlora hineana Endangered Insect

Dragonfly, Hine's Emerald Somatochlora hineana Endangered Insect

Dragonfly, Hine's Emerald Somatochlora hineana Endangered Insect

Dragonfly, Hine's Emerald Somatochlora hineana Endangered Insect

Dragonfly, Hine's Emerald Somatochlora hineana Endangered Insect

Dropwort, Canby's Oxypolis canbyi Endangered Dicot

Dropwort, Canby's Oxypolis canbyi Endangered Dicot

Dropwort, Canby's Oxypolis canbyi Endangered Dicot

Dropwort, Canby's Oxypolis canbyi Endangered Dicot

Dubautia latifolia (ncn) Dubautia latifolia Endangered Dicot

Dubautia pauciflorula (ncn) Dubautia pauciflorula Endangered Dicot

Duck, Hawaiian (Koloa) Anas wyvilliana Endangered Bird

Duck, Laysan Anas laysanensis Endangered Bird

Dudleya, Conejo Dudleya abramsii ssp. parva Threatened Dicot

Dudleya, Marcescent Dudleya cymosa ssp. marcescens Threatened Dicot

Dudleya, Santa Clara Valley Dudleya setchellii Endangered Dicot

Dudleya, Santa Cruz Island Dudleya nesiotica Threatened Dicot

Dudleya, Santa Monica Mountains Dudleya cymosa ssp. ovatifolia Threatened Dicot

Dudleya, Verity's Dudleya verityi Threatened Dicot

Dwarf-flax, Marin Hesperolinon congestum Threatened Dicot

Eagle, Bald Haliaeetus leucocephalus Threatened Bird

Eider, Spectacled Somateria fischeri Threatened Bird

Eider, Steller's Polysticta stelleri Threatened Bird

Elepaio, Oahu Chasiempis sandwichensis ibidis Endangered Bird

Elimia, Lacy Elimia crenatella Threatened Gastropod

Elktoe, Appalachian Alasmidonta raveneliana Endangered Bivalve

Elktoe, Appalachian Alasmidonta raveneliana Endangered Bivalve

Erubia Solanum drymophilum Endangered Dicot

Eugenia Woodburyana Eugenia woodburyana Endangered Dicot

Evening-primrose, Antioch Dunes Oenothera deltoides ssp. howellii Endangered Dicot

Evening-primrose, Eureka Valley Oenothera avita ssp. eurekensis Endangered Dicot

Evening-primrose, San Benito Camissonia benitensis Threatened Dicot
-Page 256 of 292- 

zhqSel_StateTaxa2

INVNAME SCINAME Status Taxa

Fairy Shrimp, Conservancy Fairy Branchinecta conservatio Endangered Crustacean

Fairy Shrimp, Longhorn Branchinecta longiantenna Endangered Crustacean

Fairy Shrimp, Riverside Streptocephalus woottoni Endangered Crustacean

Fairy Shrimp, San Diego Branchinecta sandiegonensis Endangered Crustacean

Fairy Shrimp, Vernal Pool Branchinecta lynchi Threatened Crustacean

Fairy Shrimp, Vernal Pool Branchinecta lynchi Threatened Crustacean

Falcon, Northern Aplomado Falco femoralis septentrionalis Endangered Bird

Falcon, Northern Aplomado Falco femoralis septentrionalis Endangered Bird

Falcon, Northern Aplomado Falco femoralis septentrionalis Endangered Bird

Fanshell Cyprogenia stegaria Endangered Bivalve

Fanshell Cyprogenia stegaria Endangered Bivalve

Fanshell Cyprogenia stegaria Endangered Bivalve

Fanshell Cyprogenia stegaria Endangered Bivalve

Fanshell Cyprogenia stegaria Endangered Bivalve

Fanshell Cyprogenia stegaria Endangered Bivalve

Fanshell Cyprogenia stegaria Endangered Bivalve

Fanshell Cyprogenia stegaria Endangered Bivalve

Fatmucket, Arkansas Lampsilis powelli Threatened Bivalve

Fern, Adiantum vivesii Adiantum vivesii Endangered Ferns

Fern, Alabama Streak-sorus Thelypteris pilosa var. alabamensis Threatened Ferns

Fern, Aleutian Shield Polystichum aleuticum Endangered Ferns

Fern, American hart's-tongue Asplenium scolopendrium var. americanum Threatened Ferns

Fern, American hart's-tongue Asplenium scolopendrium var. americanum Threatened Ferns

Fern, American hart's-tongue Asplenium scolopendrium var. americanum Threatened Ferns

Fern, American hart's-tongue Asplenium scolopendrium var. americanum Threatened Ferns

Fern, American hart's-tongue Asplenium scolopendrium var. americanum Threatened Ferns

Fern, Elaphoglossum serpens Elaphoglossum serpens Endangered Ferns

Fern, Pendant Kihi (Adenophorus periens) Adenophorus periens Endangered Ferns

Fern, Thelypteris inabonensis Thelypteris inabonensis Endangered Ferns

Fern, Thelypteris verecunda Thelypteris verecunda Endangered Ferns

Fern, Thelypteris yaucoensis Thelypteris yaucoensis Endangered Ferns

Ferret, Black-footed Mustela nigripes Endangered Mammal

Ferret, Black-footed Mustela nigripes Endangered Mammal

Ferret, Black-footed Mustela nigripes Endangered Mammal

Ferret, Black-footed Mustela nigripes Endangered Mammal

Ferret, Black-footed Mustela nigripes Endangered Mammal

Ferret, Black-footed Mustela nigripes Endangered Mammal

Ferret, Black-footed Mustela nigripes Endangered Mammal

Ferret, Black-footed Mustela nigripes Endangered Mammal

Ferret, Black-footed Mustela nigripes Endangered Mammal

Fiddleneck, Large-flowered Amsinckia grandiflora Endangered Dicot

Finch, Laysan Telespyza cantans Endangered Bird

Finch, Nihoa Telespyza ultima Endangered Bird

Flannelbush, Mexican Fremontodendron mexicanum Endangered Dicot

Flannelbush, Pine Hill Fremontodendron californicum ssp. decumbens Endangered Dicot

Fleabane, Zuni Erigeron rhizomatus Threatened Dicot
-Page 257 of 292- 

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INVNAME SCINAME Status Taxa

Fleabane, Zuni Erigeron rhizomatus Threatened Dicot

Fly, Delhi Sands Flower-loving Rhaphiomidas terminatus abdominalis Endangered Insect

Flycatcher, Southwestern Willow Empidonax traillii extimus Endangered Bird

Flycatcher, Southwestern Willow Empidonax traillii extimus Endangered Bird

Flycatcher, Southwestern Willow Empidonax traillii extimus Endangered Bird

Flycatcher, Southwestern Willow Empidonax traillii extimus Endangered Bird

Flycatcher, Southwestern Willow Empidonax traillii extimus Endangered Bird

Flycatcher, Southwestern Willow Empidonax traillii extimus Endangered Bird

Four-o'clock, Macfarlane's Mirabilis macfarlanei Threatened Dicot

Four-o'clock, Macfarlane's Mirabilis macfarlanei Threatened Dicot

Fox, San Joaquin Kit Vulpes macrotis mutica Endangered Mammal

Fox, San Miguel Island Urocyon littoralis littoralis Endangered Mammal

Fox, Santa Catalina Island Urocyon littoralis catalinae Endangered Mammal

Fox, Santa Cruz Island Urocyon littoralis santacruzae Endangered Mammal

Fox, Santa Rosa Island Urocyon littoralis santarosae Endangered Mammal

Frankenia, Johnston's Frankenia johnstonii Endangered Dicot

Fringe Tree, Pygmy Chionanthus pygmaeus Endangered Dicot

Fringepod, Santa Cruz Island Thysanocarpus conchuliferus Endangered Dicot

Fritillary, Gentner's Fritillaria gentneri Endangered Monocot

Frog, California Red-legged Rana aurora draytonii Threatened Amphibian

Frog, Chiricahua Leopard Rana chiricahuensis Threatened Amphibian

Frog, Chiricahua Leopard Rana chiricahuensis Threatened Amphibian

Frog, Dusky Gopher (Mississippi DPS) Rana capito sevosa Endangered Amphibian

Frog, Mountain Yellow-legged Gopherus agassizii Endangered Amphibian

Fruit, Earth (=geocarpon) Geocarpon minimum Threatened Dicot

Fruit, Earth (=geocarpon) Geocarpon minimum Threatened Dicot

Fruit, Earth (=geocarpon) Geocarpon minimum Threatened Dicot

Fruit, Earth (=geocarpon) Geocarpon minimum Threatened Dicot

Gahnia Lanaiensis (ncn) Gahnia lanaiensis Endangered Monocot

Gambusia, Big Bend Gambusia gaigei Endangered Fish

Gambusia, Clear Creek Gambusia heterochir Endangered Fish

Gambusia, Pecos Gambusia nobilis Endangered Fish

Gambusia, Pecos Gambusia nobilis Endangered Fish

Gambusia, San Marcos Gambusia georgei Endangered Fish

Gecko, Monito Sphaerodactylus micropithecus Endangered Reptile

Geranium, Hawaiian Red-flowered Geranium arboreum Endangered Dicot

Gerardia, Sandplain Agalinis acuta Endangered Dicot

Gerardia, Sandplain Agalinis acuta Endangered Dicot

Gerardia, Sandplain Agalinis acuta Endangered Dicot

Gerardia, Sandplain Agalinis acuta Endangered Dicot

Gerardia, Sandplain Agalinis acuta Endangered Dicot

Gesneria pauciflora (ncn) Gesneria pauciflora Threatened Dicot

Gilia, Hoffmann's Slender-flowered Gilia tenuiflora ssp. hoffmannii Endangered Dicot

Gilia, Monterey Gilia tenuiflora ssp. arenaria Endangered Dicot

Gnatcatcher, Coastal California Polioptila californica californica Threatened Bird

Goby, Tidewater Eucyclogobius newberryi Endangered Fish
-Page 258 of 292- 

zhqSel_StateTaxa2

INVNAME SCINAME Status Taxa

Goetzea, Beautiful (Matabuey) Goetzea elegans Endangered Dicot

Golden Sunburst, Hartweg's Pseudobahia bahiifolia Endangered Dicot

Goldenrod, Blue Ridge Solidago spithamaea Threatened Dicot

Goldenrod, Blue Ridge Solidago spithamaea Threatened Dicot

Goldenrod, Houghton's Solidago houghtonii Threatened Dicot

Goldenrod, Short's Solidago shortii Endangered Dicot

Goldenrod, Short's Solidago shortii Endangered Dicot

Goldenrod, White-haired Solidago albopilosa Threatened Dicot

Goldfields, Burke's Lasthenia burkei Endangered Dicot

Goldfields, Contra Costa Lasthenia conjugens Endangered Dicot

Goose, Hawaiian (Nene) Branta (=Nesochen) sandvicensis Endangered Bird

Gooseberry, Miccosukee Ribes echinellum Threatened Dicot

Gooseberry, Miccosukee Ribes echinellum Threatened Dicot

Gouania hillebrandii (ncn) Gouania hillebrandii Endangered Dicot

Gouania meyenii (ncn) Gouania meyenii Endangered Dicot

Gouania vitifolia (ncn) Gouania vitifolia Endangered Dicot

Gourd, Okeechobee Cucurbita okeechobeensis ssp. 

okeechobeensis

Endangered Dicot

Grass, California Orcutt Orcuttia californica Endangered Monocot

Grass, Colusa Neostapfia colusana Threatened Monocot

Grass, Eureka Dune Swallenia alexandrae Endangered Monocot

Grass, Fosberg's Love Eragrostis fosbergii Endangered Monocot

Grass, Hairy Orcutt Orcuttia pilosa Endangered Dicot

Grass, Sacramento Orcutt Orcuttia viscida Endangered Dicot

Grass, San Joaquin Valley Orcutt Orcuttia inaequalis Threatened Monocot

Grass, Slender Orcutt Orcuttia tenuis Threatened Dicot

Grass, Solano Tuctoria mucronata Endangered Monocot

Grass, Tennessee Yellow-eyed Xyris tennesseensis Endangered Monocot

Grass, Tennessee Yellow-eyed Xyris tennesseensis Endangered Monocot

Grass, Tennessee Yellow-eyed Xyris tennesseensis Endangered Monocot

Grasshopper, Zayante Band-winged Trimerotropis infantilis Endangered Insect

Ground-plum, Guthrie's Astragalus bibullatus Endangered Dicot

Groundsel, San Francisco Peaks Senecio franciscanus Threatened Dicot

Guajon Eleutherodactylus cooki Threatened Amphibian

Gumplant, Ash Meadows Grindelia fraxino-pratensis Threatened Dicot

Gumplant, Ash Meadows Grindelia fraxino-pratensis Threatened Dicot

Haha (Cyanea acuminata) Cyanea acuminata Endangered Dicot

Haha (Cyanea asarifolia) Cyanea asarifolia Endangered Dicot

Haha (Cyanea copelandii ssp. copelandii) Cyanea copelandii ssp. copelandii Endangered Dicot

Haha (Cyanea copelandii ssp. 

haleakalaensis)

Cyanea copelandii ssp. haleakalaensis Endangered Dicot

Haha (Cyanea Crispa) (=Rollandia crispa) Cyanea (=Rollandia) crispa Endangered Dicot

Haha (Cyanea dunbarii) Cyanea dunbarii Endangered Dicot

Haha (Cyanea glabra) Cyanea glabra Endangered Dicot

Haha (Cyanea grimesiana ssp. 

grimesiana)

Cyanea grimesiana ssp. grimesiana Endangered Dicot
-Page 259 of 292- 

zhqSel_StateTaxa2

INVNAME SCINAME Status Taxa

Haha (Cyanea grimesiana ssp. obatae) Cyanea grimesiana ssp. obatae Endangered Dicot

Haha (Cyanea hamatiflora ssp. carlsonii) Cyanea hamatiflora carlsonii Endangered Dicot

Haha (Cyanea hamatiflora ssp. 

hamatiflora)

Cyanea hamatiflora ssp. hamatiflora Endangered Dicot

Haha (Cyanea humboldtiana) Cyanea humboldtiana Endangered Dicot

Haha (Cyanea koolauensis) Cyanea koolauensis Endangered Dicot

Haha (Cyanea longiflora) Cyanea longiflora Endangered Dicot

Haha (Cyanea Macrostegia var. gibsonii) Cyanea macrostegia ssp. gibsonii Endangered Dicot

Haha (Cyanea mannii) Cyanea mannii Endangered Dicot

Haha (Cyanea mceldowneyi) Cyanea mceldowneyi Endangered Dicot

Haha (Cyanea pinnatifida) Cyanea pinnatifida Endangered Dicot

Haha (Cyanea platyphylla) Cyanea platyphylla Endangered Dicot

Haha (Cyanea procera) Cyanea procera Endangered Dicot

Haha (Cyanea recta) Cyanea recta Threatened Dicot

Haha (Cyanea remyi) Cyanea remyi Endangered Dicot

Haha (Cyanea shipmanii) Cyanea shipmannii Endangered Dicot

Haha (Cyanea stictophylla) Cyanea stictophylla Endangered Dicot

Haha (Cyanea St-Johnii) (=Rollandia StJohnii)Cyanea st-johnii Endangered Dicot

Haha (Cyanea superba) Cyanea superba Endangered Dicot

Ha'Iwale (Cyrtandra crenata) Cyrtandra crenata Endangered Dicot

Ha'Iwale (Cyrtandra dentata) Cyrtandra dentata Endangered Dicot

Ha'Iwale (Cyrtandra giffardii) Cyrtandra giffardii Endangered Dicot

Ha'Iwale (Cyrtandra limahuliensis) Cyrtandra limahuliensis Threatened Dicot

Ha'Iwale (Cyrtandra munroi) Cyrtandra munroi Endangered Dicot

Ha'Iwale (Cyrtandra polyantha) Cyrtandra polyantha Endangered Dicot

Ha'Iwale (Cyrtandra subumbellata) Cyrtandra subumbellata Endangered Dicot

Ha'Iwale (Cyrtandra tintinnabula) Cyrtandra tintinnabula Endangered Dicot

Ha'Iwale (Cyrtandra viridiflora) Cyrtandra viridiflora Endangered Dicot

Hala Pepe (Pleomele hawaiiensis) Pleomele hawaiiensis Endangered Monocot

Haplostachys Haplostachya (ncn) Haplostachys haplostachya Endangered Dicot

Harebells, Avon Park Crotalaria avonensis Endangered Dicot

Harperella Ptilimnium nodosum Endangered Dicot

Harperella Ptilimnium nodosum Endangered Dicot

Harperella Ptilimnium nodosum Endangered Dicot

Harperella Ptilimnium nodosum Endangered Dicot

Harperella Ptilimnium nodosum Endangered Dicot

Harperella Ptilimnium nodosum Endangered Dicot

Harperella Ptilimnium nodosum Endangered Dicot

Harperella Ptilimnium nodosum Endangered Dicot

Harvestman, Bee Creek Cave Texella reddelli Endangered Arachnid

Harvestman, Bone Cave Texella reyesi Endangered Arachnid

Harvestman, Robber Baron Cave Texella cokendolpheri Endangered Arachnid

Hau Kauhiwi (Hibiscadelphus woodi) Hibiscadelphus woodii Endangered Dicot

Hau Kuahiwi (Hibiscadelphus distans) Hibiscadelphus distans Endangered Dicot

Hawk, Hawaiian (Io) Buteo solitarius Endangered Bird
-Page 260 of 292- 

zhqSel_StateTaxa2

INVNAME SCINAME Status Taxa

Hawk, Puerto Rican Broad-winged Buteo platypterus brunnescens Endangered Bird

Hawk, Puerto Rican Sharp-shinned Accipiter striatus venator Endangered Bird

Heartleaf, Dwarf-flowered Hexastylis naniflora Threatened Dicot

Heartleaf, Dwarf-flowered Hexastylis naniflora Threatened Dicot

Heather, Mountain Golden Hudsonia montana Threatened Dicot

Heau (Exocarpos luteolus) Exocarpos luteolus Endangered Dicot

Hedyotis degeneri (ncn) Hedyotis degeneri Endangered Dicot

Hedyotis parvula (ncn) Hedyotis parvula Endangered Dicot

Hedyotis St.-Johnii (ncn) Hedyotis st.-johnii Endangered Dicot

Hesperomannia arborescens (ncn) Hesperomannia arborescens Endangered Dicot

Hesperomannia arbuscula (ncn) Hesperomannia arbuscula Endangered Dicot

Hesperomannia lydgatei (ncn) Hesperomannia lydgatei Endangered Dicot

Hibiscus, Clay's Hibiscus clayi Endangered Dicot

Higuero De Sierra Crescentia portoricensis Endangered Dicot

Hilo Ischaemum (Ischaemum byrone) Ischaemum byrone Endangered Monocot

Holei (Ochrosia kilaueaensis) Ochrosia kilaueaensis Endangered Dicot

Holly, Cook's Ilex cookii Endangered Dicot

Honeycreeper, Crested ('Akohekohe) Palmeria dolei Endangered Bird

Howellia, Water Howellia aquatilis Threatened Dicot

Howellia, Water Howellia aquatilis Threatened Dicot

Howellia, Water Howellia aquatilis Threatened Dicot

Hypericum, Highlands Scrub Hypericum cumulicola Endangered Dicot

Iguana, Mona Ground Cyclura stejnegeri Threatened Reptile

'Ihi'Ihi (Marsilea villosa) Marsilea villosa Endangered Ferns

Ilex sintenisii (ncn) Ilex sintenisii Endangered Dicot

Iliau (Wilkesia hobdyi) Wilkesia hobdyi Endangered Dicot

Ipomopsis, Holy Ghost Ipomopsis sancti-spiritus Endangered Dicot

Iris, Dwarf Lake Iris lacustris Threatened Monocot

Iris, Dwarf Lake Iris lacustris Threatened Monocot

Irisette, White Sisyrinchium dichotomum Endangered Monocot

Irisette, White Sisyrinchium dichotomum Endangered Monocot

Isopod, Lee County Cave Lirceus usdagalun Endangered Crustacean

Isopod, Madison Cave Antrolana lira Threatened Crustacean

Isopod, Socorro Thermosphaeroma thermophilus Endangered Crustacean

Ivesia, Ash Meadows Ivesia kingii var. eremica Threatened Dicot

Ivesia, Ash Meadows Ivesia kingii var. eremica Threatened Dicot

Jacquemontia, Beach Jacquemontia reclinata Endangered Dicot

Jaguar Panthera onca Endangered Mammal

Jaguar Panthera onca Endangered Mammal

Jaguarundi, Gulf Coast Herpailurus (=Felis) yagouaroundi cacomitli Endangered Mammal

Jaguarundi, Sinaloan Herpailurus (=Felis) yagouaroundi tolteca Endangered Mammal

Jaguarundi, Sinaloan Herpailurus (=Felis) yagouaroundi tolteca Endangered Mammal

Jewelflower, California Caulanthus californicus Endangered Dicot

Jewelflower, Metcalf Canyon Streptanthus albidus ssp. albidus Endangered Dicot

Jewelflower, Tiburon Streptanthus niger Endangered Dicot

Joint-vetch, Sensitive Aeschynomene virginica Threatened Dicot
-Page 261 of 292- 

zhqSel_StateTaxa2

INVNAME SCINAME Status Taxa

Joint-vetch, Sensitive Aeschynomene virginica Threatened Dicot

Joint-vetch, Sensitive Aeschynomene virginica Threatened Dicot

Joint-vetch, Sensitive Aeschynomene virginica Threatened Dicot

Kamakahala (Labordia cyrtandrae) Labordia cyrtandrae Endangered Dicot

Kamakahala (Labordia lydgatei) Labordia lydgatei Endangered Dicot

Kamakahala (Labordia tinifolia var. 

lanaiensis)

Labordia tinifolia var. lanaiensis Endangered Dicot

Kamakahala (Labordia tinifolia var. 

wahiawaen)

Labordia tinifolia var. wahiawaensis Endangered Dicot

Kamakahala (Labordia triflora) Labordia triflora Endangered Dicot

Kamanomano (Cenchrus agrimonioides) Cenchrus agrimonioides Endangered Monocot

Kanaloa kahoolawensis (ncn) Kanaloa kahoolawensis Endangered Dicot

Kangaroo Rat, Fresno Dipodomys nitratoides exilis Endangered Mammal

Kangaroo Rat, Giant Dipodomys ingens Endangered Mammal

Kangaroo Rat, Morro Bay Dipodomys heermanni morroensis Endangered Mammal

Kangaroo Rat, San Bernardino Merriam's Dipodomys merriami parvus Endangered Mammal

Kangaroo Rat, Stephens' Dipodomys stephensi (incl. D. cascus) Endangered Mammal

Kangaroo Rat, Tipton Dipodomys nitratoides nitratoides Endangered Mammal

Kauila (Colubrina oppositifolia) Colubrina oppositifolia Endangered Dicot

Kaulu (Pteralyxia kauaiensis) Pteralyxia kauaiensis Endangered Dicot

Kidneyshell, Triangular Ptychobranchus greenii Endangered Bivalve

Kidneyshell, Triangular Ptychobranchus greenii Endangered Bivalve

Kidneyshell, Triangular Ptychobranchus greenii Endangered Bivalve

Kio'Ele (Hedyotis coriacea) Hedyotis coriacea Endangered Dicot

Kiponapona (Phyllostegia racemosa) Phyllostegia racemosa Endangered Dicot

Kite, Everglade Snail Rostrhamus sociabilis plumbeus Endangered Bird

Koki'o (Kokia drynarioides) Kokia drynarioides Endangered Dicot

Koki'o (Kokia kauaiensis) Kokia kauaiensis Endangered Dicot

Koki'o Ke'oke'o (Hibiscus arnottianus ssp. 

immaculatus)

Hibiscus arnottianus ssp. immaculatus Endangered Dicot

Koki'o Ke'oke'o (Hibiscus waimeae ssp. 

hannerae)

Hibiscus waimeae ssp. hannerae Endangered Dicot

Kolea (Myrsine juddii) Myrsine juddii Endangered Dicot

Kolea (Myrsine linearifolia) Myrsine linearifolia Threatened Dicot

Ko'oko'olau (Bidens micrantha ssp. 

kalealaha)

Bidens micrantha ssp. kalealaha Endangered Dicot

Ko'oko'olau (Bidens wiebkei) Bidens wiebkei Endangered Dicot

Ko'oloa'ula (Abutilon menziesii) Abutilon menziesii Endangered Dicot

Kopa (Hedyotis schlechtendahliana var. 

remyi)

Hedyotis schlechtendahliana var. remyi Endangered Dicot

Kuawawaenohu (Alsinidendron 

lychnoides)

Alsinidendron lychnoides Endangered Dicot

Kulu'I (Nototrichium humile) Nototrichium humile Endangered Dicot

Ladies'-tresses, Canelo Hills Spiranthes delitescens Endangered Monocot

Ladies'-tresses, Navasota Spiranthes parksii Endangered Monocot

Ladies'-tresses, Ute Spiranthes diluvialis Threatened Monocot

Ladies'-tresses, Ute Spiranthes diluvialis Threatened Monocot
-Page 262 of 292- 

zhqSel_StateTaxa2

INVNAME SCINAME Status Taxa

Ladies'-tresses, Ute Spiranthes diluvialis Threatened Monocot

Larkspur, Baker's Delphinium bakeri Endangered Dicot

Larkspur, San Clemente Island Delphinium variegatum ssp. kinkiense Endangered Dicot

Larkspur, Yellow Delphinium luteum Endangered Dicot

Lau'ehu (Panicum niihauense) Panicum niihauense Endangered Monocot

Laukahi Kuahiwi (Plantago hawaiensis) Plantago hawaiensis Endangered Dicot

Laukahi Kuahiwi (Plantago princeps) Plantago princeps Endangered Dicot

Laulihilihi (Schiedea stellarioides) Schiedea stellarioides Endangered Dicot

Layia, Beach Layia carnosa Endangered Dicot

Lead-plant, Crenulate Amorpha crenulata Endangered Dicot

Leather-flower, Alabama Clematis socialis Endangered Dicot

Leather-flower, Morefield's Clematis morefieldii Endangered Dicot

Lepanthes eltorensis (ncn) Lepanthes eltoroensis Endangered Monocot

Leptocereus grantianus (ncn) Leptocereus grantianus Endangered Dicot

Lessingia, San Francisco Lessingia germanorum (=L.g. var. germanorum) Endangered Dicot

Lichen, Rock Gnome Gymnoderma lineare Endangered Lichen

Lichen, Rock Gnome Gymnoderma lineare Endangered Lichen

Lichen, Rock Gnome Gymnoderma lineare Endangered Lichen

Lily, Minnesota Trout Erythronium propullans Endangered Monocot

Lily, Pitkin Marsh Lilium pardalinum ssp. pitkinense Endangered Monocot

Lily, Tiburon Mariposa Calochortus tiburonensis Threatened Monocot

Lily, Western Lilium occidentale Endangered Monocot

Lily, Western Lilium occidentale Endangered Monocot

Limpet, Banbury Springs Lanx sp. Endangered Gastropod

Lipochaeta venosa (ncn) Lipochaeta venosa Endangered Dicot

Liveforever, Laguna Beach Dudleya stolonifera Threatened Dicot

Liveforever, Santa Barbara Island Dudleya traskiae Endangered Dicot

Lizard, Blunt-nosed Leopard Gambelia silus Endangered Reptile

Lizard, Coachella Valley Fringe-toed Uma inornata Threatened Reptile

Lizard, Island Night Xantusia riversiana Threatened Reptile

Lo`ulu (Pritchardia affinis) Pritchardia affinis Endangered Monocot

Lo`ulu (Pritchardia kaalae) Pritchardia kaalae Endangered Monocot

Lo`ulu (Pritchardia munroi) Pritchardia munroi Endangered Monocot

Lo`ulu (Pritchardia napaliensis) Pritchardia napaliensis Endangered Monocot

Lo`ulu (Pritchardia remota) Pritchardia remota Endangered Monocot

Lo`ulu (Pritchardia schattaueri) Pritchardia schattaueri Endangered Monocot

Lo`ulu (Pritchardia viscosa) Pritchardia viscosa Endangered Monocot

Lobelia monostachya (ncn) Lobelia monostachya Endangered Dicot

Lobelia niihauensis (ncn) Lobelia niihauensis Endangered Dicot

Lobelia oahuensis (ncn) Lobelia oahuensis Endangered Dicot

Locoweed, Fassett's Oxytropis campestris var. chartacea Threatened Dicot

Logperch, Conasauga Percina jenkinsi Endangered Fish

Logperch, Conasauga Percina jenkinsi Endangered Fish

Logperch, Roanoke Percina rex Endangered Fish

Lomatium, Bradshaw's Lomatium bradshawii Endangered Dicot

Lomatium, Cook's Lomatium cookii Endangered Dicot
-Page 263 of 292- 

zhqSel_StateTaxa2

INVNAME SCINAME Status Taxa

Loosestrife, Rough-leaved Lysimachia asperulaefolia Endangered Dicot

Loosestrife, Rough-leaved Lysimachia asperulaefolia Endangered Dicot

Lousewort, Furbish Pedicularis furbishiae Endangered Dicot

Lupine, Clover Lupinus tidestromii Endangered Dicot

Lupine, Kincaid's Lupinus sulphureus (=oreganus) ssp. kincaidii 

(=var. kincaidii)

Threatened Dicot

Lupine, Kincaid's Lupinus sulphureus (=oreganus) ssp. kincaidii 

(=var. kincaidii)

Threatened Dicot

Lupine, Nipomo Mesa Lupinus nipomensis Endangered Dicot

Lupine, Scrub Lupinus aridorum Endangered Dicot

Lynx, Canada Lynx canadensis Threatened Mammal

Lynx, Canada Lynx canadensis Threatened Mammal

Lynx, Canada Lynx canadensis Threatened Mammal

Lynx, Canada Lynx canadensis Threatened Mammal

Lyonia truncata var. proctorii (ncn) Lyonia truncata var. proctorii Endangered Dicot

Lysimachia filifolia (ncn) Lysimachia filifolia Endangered Dicot

Lysimachia lydgatei (ncn) Lysimachia lydgatei Endangered Dicot

Lysimachia maxima (ncn) Lysimachia maxima Endangered Dicot

Madtom, Neosho Noturus placidus Threatened Fish

Madtom, Neosho Noturus placidus Threatened Fish

Madtom, Neosho Noturus placidus Threatened Fish

Madtom, Pygmy Noturus stanauli Endangered Fish

Madtom, Scioto Noturus trautmani Endangered Fish

Madtom, Smoky Noturus baileyi Endangered Fish

Madtom, Yellowfin Noturus flavipinnis Threatened Fish

Madtom, Yellowfin Noturus flavipinnis Threatened Fish

Madtom, Yellowfin Noturus flavipinnis Threatened Fish

Madtom, Yellowfin Noturus flavipinnis Threatened Fish

Mahoe (Alectryon macrococcus) Alectryon macrococcus Endangered Dicot

Makou (Peucedanum sandwicense) Peucedanum sandwicense Threatened Dicot

Malacothrix, Island Malacothrix squalida Endangered Dicot

Malacothrix, Santa Cruz Island Malacothrix indecora Endangered Dicot

Mallow, Kern Eremalche kernensis Endangered Dicot

Mallow, Peter's Mountain Iliamna corei Endangered Dicot

Manaca, palma de Calyptronoma rivalis Threatened Monocot

Manatee, West Indian Trichechus manatus Endangered Marine mml

Manatee, West Indian Trichechus manatus Endangered Marine mml

Manatee, West Indian Trichechus manatus Endangered Marine mml

Manatee, West Indian Trichechus manatus Endangered Marine mml

Manatee, West Indian Trichechus manatus Endangered Marine mml

Manatee, West Indian Trichechus manatus Endangered Marine mml

Manioc, Walker's Manihot walkerae Endangered Dicot

Manzanita, Del Mar Arctostaphylos glandulosa ssp. crassifolia Endangered Dicot

Manzanita, Ione Arctostaphylos myrtifolia Threatened Dicot

Manzanita, Morro Arctostaphylos morroensis Threatened Dicot

Manzanita, Pallid Arctostaphylos pallida Threatened Dicot
-Page 264 of 292- 

zhqSel_StateTaxa2

INVNAME SCINAME Status Taxa

Manzanita, Presidio (=Raven's) Arctostaphylos hookeri var. ravenii Endangered Dicot

Manzanita, Santa Rosa Island Arctostaphylos confertiflora Endangered Dicot

Ma'o Hau Hele (Hibiscus brackenridgei) Hibiscus brackenridgei Endangered Dicot

Ma'oli'oli (Schiedea apokremnos) Schiedea apokremnos Endangered Dicot

Ma'oli'oli (Schiedea kealiae) Schiedea kealiae Endangered Dicot

Mapele (Cyrtandra cyaneoides) Cyrtandra cyaneoides Endangered Dicot

Mariscus fauriei (ncn) Mariscus fauriei Endangered Monocot

Mariscus pennatiformis (ncn) Mariscus pennatiformis Endangered Monocot

Marstonia, Royal (=Royal Snail) Pyrgulopsis ogmorhaphe Endangered Gastropod

Meadowfoam, Butte County Limnanthes floccosa ssp. californica Endangered Dicot

Meadowfoam, Large-flowered Woolly Limnanthes floccosa ssp. Grandiflora Endangered Dicot

Meadowfoam, Sebastopol Limnanthes vinculans Endangered Dicot

Meadowrue, Cooley's Thalictrum cooleyi Endangered Dicot

Meadowrue, Cooley's Thalictrum cooleyi Endangered Dicot

Mehamehame (Flueggea neowawraea) Flueggea neowawraea Endangered Dicot

Meshweaver, Braken Bat Cave Cicurina venii Endangered Arachnid

Milkpea, Small's Galactia smallii Endangered Dicot

Milk-vetch, Applegate's Astragalus applegatei Endangered Dicot

Milk-vetch, Ash Meadows Astragalus phoenix Threatened Dicot

Milk-vetch, Braunton's Astragalus brauntonii Endangered Dicot

Milk-vetch, Clara Hunt's Astragalus clarianus Endangered Dicot

Milk-vetch, Coachella Valley Astragalus lentiginosus var. coachellae Endangered Dicot

Milk-vetch, Coastal Dunes Astragalus tener var. titi Endangered Dicot

Milk-vetch, Cushenbury Astragalus albens Endangered Dicot

Milk-vetch, Deseret Astragalus desereticus Threatened Dicot

Milk-vetch, Fish Slough Astragalus lentiginosus var. piscinensis Threatened Dicot

Milk-vetch, Heliotrope Astragalus montii Threatened Dicot

Milk-vetch, Holmgren Astragalus holmgreniorum Endangered Dicot

Milk-vetch, Holmgren Astragalus holmgreniorum Endangered Dicot

Milk-vetch, Jesup's Astragalus robbinsii var. jesupi Endangered Dicot

Milk-vetch, Jesup's Astragalus robbinsii var. jesupi Endangered Dicot

Milk-vetch, Lane Mountain Astragalus jaegerianus Endangered Dicot

Milk-vetch, Mancos Astragalus humillimus Endangered Dicot

Milk-vetch, Mancos Astragalus humillimus Endangered Dicot

Milk-vetch, Osterhout Astragalus osterhoutii Endangered Dicot

Milk-vetch, Pierson's Astragalus magdalenae var. peirsonii Threatened Dicot

Milk-vetch, Sentry Astragalus cremnophylax var. cremnophylax Endangered Dicot

Milk-vetch, Shivwits Astragalus ampullarioides Endangered Dicot

Milk-vetch, Triple-ribbed Astragalus tricarinatus Endangered Dicot

Milk-vetch, Ventura Marsh Astragalus pycnostachyus var. lanosissimus Endangered Dicot

Milkweed, Mead's Asclepias meadii Threatened Dicot

Milkweed, Mead's Asclepias meadii Threatened Dicot

Milkweed, Mead's Asclepias meadii Threatened Dicot

Milkweed, Mead's Asclepias meadii Threatened Dicot

Milkweed, Mead's Asclepias meadii Threatened Dicot

Milkweed, Welsh's Asclepias welshii Threatened Dicot
-Page 265 of 292- 

zhqSel_StateTaxa2

INVNAME SCINAME Status Taxa

Milkweed, Welsh's Asclepias welshii Threatened Dicot

Millerbird, Nihoa Acrocephalus familiaris kingi Endangered Bird

Minnow, Devils River Dionda diaboli Threatened Fish

Minnow, Loach Tiaroga cobitis Threatened Fish

Minnow, Loach Tiaroga cobitis Threatened Fish

Minnow, Rio Grande Silvery Hybognathus amarus Endangered Fish

Mint, Garrett's Dicerandra christmanii Endangered Dicot

Mint, Lakela's Dicerandra immaculata Endangered Dicot

Mint, Longspurred Dicerandra cornutissima Endangered Dicot

Mint, Otay Mesa Pogogyne nudiuscula Endangered Dicot

Mint, San Diego Mesa Pogogyne abramsii Endangered Dicot

Mint, Scrub Dicerandra frutescens Endangered Dicot

Mitracarpus Maxwelliae Mitracarpus maxwelliae Endangered Dicot

Mitracarpus Polycladus Mitracarpus polycladus Endangered Dicot

Monardella, Willowy Monardella linoides ssp. viminea Endangered Dicot

Monkey-flower, Michigan Mimulus glabratus var. michiganensis Endangered Dicot

Monkshood, Northern Wild Aconitum noveboracense Threatened Dicot

Monkshood, Northern Wild Aconitum noveboracense Threatened Dicot

Monkshood, Northern Wild Aconitum noveboracense Threatened Dicot

Monkshood, Northern Wild Aconitum noveboracense Threatened Dicot

Moorhen, Hawaiian Common Gallinula chloropus sandvicensis Endangered Bird

Morning-glory, Stebbins Calystegia stebbinsii Endangered Dicot

Moth, Blackburn's Sphinx Manduca blackburni Endangered Insect

Moth, Kern Primrose Sphinx Euproserpinus euterpe Threatened Insect

Mountain Beaver, Point Arena Aplodontia rufa nigra Endangered Mammal

Mountainbalm, Indian Knob Eriodictyon altissimum Endangered Dicot

Mountain-mahogany, Catalina Island Cercocarpus traskiae Endangered Dicot

Mouse, Alabama Beach Peromyscus polionotus ammobates Endangered Mammal

Mouse, Anastasia Island Beach Peromyscus polionotus phasma Endangered Mammal

Mouse, Choctawhatchee Beach Peromyscus polionotus allophrys Endangered Mammal

Mouse, Key Largo Cotton Peromyscus gossypinus allapaticola Endangered Mammal

Mouse, Pacific Pocket Perognathus longimembris pacificus Endangered Mammal

Mouse, Perdido Key Beach Peromyscus polionotus trissyllepsis Endangered Mammal

Mouse, Perdido Key Beach Peromyscus polionotus trissyllepsis Endangered Mammal

Mouse, Preble's Meadow Jumping Zapus hudsonius preblei Threatened Mammal

Mouse, Preble's Meadow Jumping Zapus hudsonius preblei Threatened Mammal

Mouse, Salt Marsh Harvest Reithrodontomys raviventris Endangered Mammal

Mouse, Southeastern Beach Peromyscus polionotus niveiventris Threatened Mammal

Mouse, St. Andrew Beach Peromyscus polionotus peninsularis Endangered Mammal

Mucket, Orangenacre Lampsilis perovalis Threatened Bivalve

Mucket, Orangenacre Lampsilis perovalis Threatened Bivalve

Mucket, Pink (Pearlymussel) Lampsilis abrupta Endangered Bivalve

Mucket, Pink (Pearlymussel) Lampsilis abrupta Endangered Bivalve

Mucket, Pink (Pearlymussel) Lampsilis abrupta Endangered Bivalve

Mucket, Pink (Pearlymussel) Lampsilis abrupta Endangered Bivalve

Mucket, Pink (Pearlymussel) Lampsilis abrupta Endangered Bivalve
-Page 266 of 292- 

zhqSel_StateTaxa2

INVNAME SCINAME Status Taxa

Mucket, Pink (Pearlymussel) Lampsilis abrupta Endangered Bivalve

Mucket, Pink (Pearlymussel) Lampsilis abrupta Endangered Bivalve

Mucket, Pink (Pearlymussel) Lampsilis abrupta Endangered Bivalve

Mucket, Pink (Pearlymussel) Lampsilis abrupta Endangered Bivalve

Mucket, Pink (Pearlymussel) Lampsilis abrupta Endangered Bivalve

Mucket, Pink (Pearlymussel) Lampsilis abrupta Endangered Bivalve

Mucket, Pink (Pearlymussel) Lampsilis abrupta Endangered Bivalve

Munroidendron racemosum (ncn) Munroidendron racemosum Endangered Dicot

Murrelet, Marbled Brachyramphus marmoratus marmoratus Threatened Bird

Murrelet, Marbled Brachyramphus marmoratus marmoratus Threatened Bird

Murrelet, Marbled Brachyramphus marmoratus marmoratus Threatened Bird

Mussel, Acornshell Southern Epioblasma othcaloogensis Endangered Bivalve

Mussel, Acornshell Southern Epioblasma othcaloogensis Endangered Bivalve

Mussel, Alabama Moccasinshell Medionidus acutissimus Threatened Bivalve

Mussel, Alabama Moccasinshell Medionidus acutissimus Threatened Bivalve

Mussel, Alabama Moccasinshell Medionidus acutissimus Threatened Bivalve

Mussel, Alabama Moccasinshell Medionidus acutissimus Threatened Bivalve

Mussel, Black (=Curtus' Mussel) Clubshell Pleurobema curtum Endangered Bivalve

Mussel, Clubshell Pleurobema clava Endangered Bivalve

Mussel, Clubshell Pleurobema clava Endangered Bivalve

Mussel, Clubshell Pleurobema clava Endangered Bivalve

Mussel, Clubshell Pleurobema clava Endangered Bivalve

Mussel, Clubshell Pleurobema clava Endangered Bivalve

Mussel, Clubshell Pleurobema clava Endangered Bivalve

Mussel, Clubshell Pleurobema clava Endangered Bivalve

Mussel, Clubshell Pleurobema clava Endangered Bivalve

Mussel, Coosa Moccasinshell Medionidus parvulus Endangered Bivalve

Mussel, Coosa Moccasinshell Medionidus parvulus Endangered Bivalve

Mussel, Coosa Moccasinshell Medionidus parvulus Endangered Bivalve

Mussel, Cumberland Combshell Epioblasma brevidens Endangered Bivalve

Mussel, Cumberland Combshell Epioblasma brevidens Endangered Bivalve

Mussel, Cumberland Combshell Epioblasma brevidens Endangered Bivalve

Mussel, Cumberland Combshell Epioblasma brevidens Endangered Bivalve

Mussel, Cumberland Elktoe Alasmidonta atropurpurea Endangered Bivalve

Mussel, Cumberland Elktoe Alasmidonta atropurpurea Endangered Bivalve

Mussel, Cumberland Elktoe Alasmidonta atropurpurea Endangered Bivalve

Mussel, Cumberland Pigtoe Pleurobema gibberum Endangered Bivalve

Mussel, Dark Pigtoe Pleurobema furvum Endangered Bivalve

Mussel, Dwarf Wedge Alasmidonta heterodon Endangered Bivalve

Mussel, Dwarf Wedge Alasmidonta heterodon Endangered Bivalve

Mussel, Dwarf Wedge Alasmidonta heterodon Endangered Bivalve

Mussel, Dwarf Wedge Alasmidonta heterodon Endangered Bivalve

Mussel, Dwarf Wedge Alasmidonta heterodon Endangered Bivalve

Mussel, Dwarf Wedge Alasmidonta heterodon Endangered Bivalve

Mussel, Dwarf Wedge Alasmidonta heterodon Endangered Bivalve

Mussel, Fine-lined Pocketbook Lampsilis altilis Threatened Bivalve
-Page 267 of 292- 

zhqSel_StateTaxa2

INVNAME SCINAME Status Taxa

Mussel, Fine-lined Pocketbook Lampsilis altilis Threatened Bivalve

Mussel, Fine-lined Pocketbook Lampsilis altilis Threatened Bivalve

Mussel, Fine-rayed Pigtoe Fusconaia cuneolus Endangered Bivalve

Mussel, Fine-rayed Pigtoe Fusconaia cuneolus Endangered Bivalve

Mussel, Fine-rayed Pigtoe Fusconaia cuneolus Endangered Bivalve

Mussel, Flat Pigtoe (=Marshall's Mussel) Pleurobema marshalli Endangered Bivalve

Mussel, Gulf Moccasinshell Medionidus penicillatus Endangered Bivalve

Mussel, Gulf Moccasinshell Medionidus penicillatus Endangered Bivalve

Mussel, Heavy Pigtoe (=Judge Tait's 

Mussel)

Pleurobema taitianum Endangered Bivalve

Mussel, Heavy Pigtoe (=Judge Tait's 

Mussel)

Pleurobema taitianum Endangered Bivalve

Mussel, Heelsplitter Carolina Lasmigona decorata Endangered Bivalve

Mussel, Heelsplitter Carolina Lasmigona decorata Endangered Bivalve

Mussel, Heelsplitter Inflated Potamilus inflatus Threatened Bivalve

Mussel, Heelsplitter Inflated Potamilus inflatus Threatened Bivalve

Mussel, Heelsplitter Inflated Potamilus inflatus Threatened Bivalve

Mussel, Ochlockonee Moccasinshell Medionidus simpsonianus Endangered Bivalve

Mussel, Oval Pigtoe Pleurobema pyriforme Endangered Bivalve

Mussel, Oval Pigtoe Pleurobema pyriforme Endangered Bivalve

Mussel, Ovate Clubshell Pleurobema perovatum Endangered Bivalve

Mussel, Ovate Clubshell Pleurobema perovatum Endangered Bivalve

Mussel, Ovate Clubshell Pleurobema perovatum Endangered Bivalve

Mussel, Ovate Clubshell Pleurobema perovatum Endangered Bivalve

Mussel, Oyster Epioblasma capsaeformis Endangered Bivalve

Mussel, Oyster Epioblasma capsaeformis Endangered Bivalve

Mussel, Oyster Epioblasma capsaeformis Endangered Bivalve

Mussel, Oyster Epioblasma capsaeformis Endangered Bivalve

Mussel, Ring Pink (=Golf Stick Pearly) Obovaria retusa Endangered Bivalve

Mussel, Ring Pink (=Golf Stick Pearly) Obovaria retusa Endangered Bivalve

Mussel, Ring Pink (=Golf Stick Pearly) Obovaria retusa Endangered Bivalve

Mussel, Ring Pink (=Golf Stick Pearly) Obovaria retusa Endangered Bivalve

Mussel, Rough Pigtoe Pleurobema plenum Endangered Bivalve

Mussel, Rough Pigtoe Pleurobema plenum Endangered Bivalve

Mussel, Rough Pigtoe Pleurobema plenum Endangered Bivalve

Mussel, Rough Pigtoe Pleurobema plenum Endangered Bivalve

Mussel, Rough Pigtoe Pleurobema plenum Endangered Bivalve

Mussel, Scaleshell Leptodea leptodon Endangered Bivalve

Mussel, Scaleshell Leptodea leptodon Endangered Bivalve

Mussel, Scaleshell Leptodea leptodon Endangered Bivalve

Mussel, Shiny Pigtoe Fusconaia cor Endangered Bivalve

Mussel, Shiny Pigtoe Fusconaia cor Endangered Bivalve

Mussel, Shiny Pigtoe Fusconaia cor Endangered Bivalve

Mussel, Shiny-rayed Pocketbook Lampsilis subangulata Endangered Bivalve

Mussel, Shiny-rayed Pocketbook Lampsilis subangulata Endangered Bivalve

Mussel, Shiny-rayed Pocketbook Lampsilis subangulata Endangered Bivalve
-Page 268 of 292- 

zhqSel_StateTaxa2

INVNAME SCINAME Status Taxa

Mussel, Southern Clubshell Pleurobema decisum Endangered Bivalve

Mussel, Southern Clubshell Pleurobema decisum Endangered Bivalve

Mussel, Southern Clubshell Pleurobema decisum Endangered Bivalve

Mussel, Southern Pigtoe Pleurobema georgianum Endangered Bivalve

Mussel, Southern Pigtoe Pleurobema georgianum Endangered Bivalve

Mussel, Southern Pigtoe Pleurobema georgianum Endangered Bivalve

Mussel, Speckled Pocketbook Lampsilis streckeri Endangered Bivalve

Mussel, Winged Mapleleaf Quadrula fragosa Endangered Bivalve

Mussel, Winged Mapleleaf Quadrula fragosa Endangered Bivalve

Mussel, Winged Mapleleaf Quadrula fragosa Endangered Bivalve

Mussel, Winged Mapleleaf Quadrula fragosa Endangered Bivalve

Mustard, Carter's Warea carteri Endangered Dicot

Mustard, Penland Alpine Fen Eutrema penlandii Threatened Dicot

Mustard, Slender-petaled Thelypodium stenopetalum Endangered Dicot

Myrcia Paganii Myrcia paganii Endangered Dicot

Na'ena'e (Dubautia herbstobatae) Dubautia herbstobatae Endangered Dicot

Na'ena'e (Dubautia plantaginea ssp. 

humilis)

Dubautia plantaginea ssp. humilis Endangered Dicot

Nani Wai'ale'ale (Viola kauaensis var. 

wahiawaensis)

Viola kauaiensis var. wahiawaensis Endangered Dicot

Nanu (Gardenia mannii) Gardenia mannii Endangered Dicot

Na'u (Gardenia brighamii) Gardenia brighamii Endangered Dicot

Naucorid, Ash Meadows Ambrysus amargosus Threatened Insect

Naupaka, Dwarf (Scaevola coriacea) Scaevola coriacea Endangered Dicot

Navarretia, Few-flowered Navarretia leucocephala ssp. pauciflora (=N. 

pauciflora)

Endangered Dicot

Navarretia, Many-flowered Navarretia leucocephala ssp. plieantha Endangered Dicot

Navarretia, Spreading Navarretia fossalis Threatened Dicot

Nehe (Lipochaeta fauriei) Lipochaeta fauriei Endangered Dicot

Nehe (Lipochaeta kamolensis) Lipochaeta kamolensis Endangered Dicot

Nehe (Lipochaeta lobata var. leptophylla) Lipochaeta lobata var. leptophylla Endangered Dicot

Nehe (Lipochaeta micrantha) Lipochaeta micrantha Endangered Dicot

Nehe (Lipochaeta tenuifolia) Lipochaeta tenuifolia Endangered Dicot

Nehe (Lipochaeta waimeaensis) Lipochaeta waimeaensis Endangered Dicot

Neraudia angulata (ncn) Neraudia angulata Endangered Dicot

Neraudia ovata (ncn) Neraudia ovata Endangered Dicot

Neraudia sericea (ncn) Neraudia sericea Endangered Dicot

Nightjar, Puerto Rico Caprimulgus noctitherus Endangered Bird

Nioi (Eugenia koolauensis) Eugenia koolauensis Endangered Dicot

Niterwort, Amargosa Nitrophila mohavensis Endangered Dicot

Niterwort, Amargosa Nitrophila mohavensis Endangered Dicot

Nohoanu (Geranium multiflorum) Geranium multiflorum Endangered Dicot

Nuku Pu'u Hemignathus lucidus Endangered Bird

Oak, Hinckley Quercus hinckleyi Threatened Dicot

Ocelot Leopardus (=Felis) pardalis Endangered Mammal

Ocelot Leopardus (=Felis) pardalis Endangered Mammal
-Page 269 of 292- 

zhqSel_StateTaxa2

INVNAME SCINAME Status Taxa

'Oha (Delissea rivularis) Delissea rivularis Endangered Dicot

'Oha (Delissea subcordata) Delissea subcordata Endangered Dicot

'Oha (Delissea undulata) Delissea undulata Endangered Dicot

'Oha (Lobelia gaudichaudii koolauensis) Lobelia gaudichaudii ssp. koolauensis Endangered Dicot

'Oha Wai (Clermontia drepanomorpha) Clermontia drepanomorpha Endangered Dicot

'Oha Wai (Clermontia lindseyana) Clermontia lindseyana Endangered Dicot

'Oha Wai (Clermontia oblongifolia ssp. 

brevipes)

Clermontia oblongifolia ssp. brevipes Endangered Dicot

'Oha Wai (Clermontia oblongifolia ssp. 

mauiensis)

Clermontia oblongifolia ssp. mauiensis Endangered Dicot

'Oha Wai (Clermontia peleana) Clermontia peleana Endangered Dicot

'Oha Wai (Clermontia pyrularia) Clermontia pyrularia Endangered Dicot

'Oha Wai (Clermontia samuelii) Clermontia samuelii Endangered Dicot

'Ohai (Sesbania tomentosa) Sesbania tomentosa Endangered Dicot

'Ohe'ohe (Tetraplasandra gymnocarpa) Tetraplasandra gymnocarpa Endangered Dicot

'Olulu (Brighamia insignis) Brighamia insignis Endangered Dicot

Onion, Munz's Allium munzii Endangered Monocot

'O'o, Kauai (='A'a) Moho braccatus Endangered Bird

Opuhe (Urera kaalae) Urera kaalae Endangered Dicot

Orchid, Eastern Prairie Fringed Platanthera leucophaea Threatened Monocot

Orchid, Eastern Prairie Fringed Platanthera leucophaea Threatened Monocot

Orchid, Eastern Prairie Fringed Platanthera leucophaea Threatened Monocot

Orchid, Eastern Prairie Fringed Platanthera leucophaea Threatened Monocot

Orchid, Eastern Prairie Fringed Platanthera leucophaea Threatened Monocot

Orchid, Eastern Prairie Fringed Platanthera leucophaea Threatened Monocot

Orchid, Eastern Prairie Fringed Platanthera leucophaea Threatened Monocot

Orchid, Eastern Prairie Fringed Platanthera leucophaea Threatened Monocot

Orchid, Eastern Prairie Fringed Platanthera leucophaea Threatened Monocot

Orchid, Western Prairie Fringed Platanthera praeclara Threatened Monocot

Orchid, Western Prairie Fringed Platanthera praeclara Threatened Monocot

Orchid, Western Prairie Fringed Platanthera praeclara Threatened Monocot

Orchid, Western Prairie Fringed Platanthera praeclara Threatened Monocot

Orchid, Western Prairie Fringed Platanthera praeclara Threatened Monocot

Orchid, Western Prairie Fringed Platanthera praeclara Threatened Monocot

Orchid, Western Prairie Fringed Platanthera praeclara Threatened Monocot

Orchid, Western Prairie Fringed Platanthera praeclara Threatened Monocot

Otter, Northern Sea Enhydra lutris kenyoni Threatened Marine mml

Otter, Southern Sea Enhydra lutris nereis Threatened Marine mml

'O'u (Honeycreeper) Psittirostra psittacea Endangered Bird

Owl, Mexican Spotted Strix occidentalis lucida Threatened Bird

Owl, Mexican Spotted Strix occidentalis lucida Threatened Bird

Owl, Mexican Spotted Strix occidentalis lucida Threatened Bird

Owl, Mexican Spotted Strix occidentalis lucida Threatened Bird

Owl, Mexican Spotted Strix occidentalis lucida Threatened Bird

Owl, Northern Spotted Strix occidentalis caurina Threatened Bird

Owl, Northern Spotted Strix occidentalis caurina Threatened Bird
-Page 270 of 292- 

zhqSel_StateTaxa2

INVNAME SCINAME Status Taxa

Owl, Northern Spotted Strix occidentalis caurina Threatened Bird

Oxytheca, Cushenbury Oxytheca parishii var. goodmaniana Endangered Dicot

Paintbrush, Ash-grey Indian Castilleja cinerea Threatened Dicot

Paintbrush, Golden Castilleja levisecta Threatened Dicot

Paintbrush, San Clemente Island Indian Castilleja grisea Endangered Dicot

Paintbrush, Soft-leaved Castilleja mollis Endangered Dicot

Paintbrush, Tiburon Castilleja affinis ssp. neglecta Endangered Dicot

Palila Loxioides bailleui Endangered Bird

Palo Colorado (Ternstroemia luquillensis) Ternstroemia luquillensis Endangered Dicot

Palo de Jazmin Styrax portoricensis Endangered Dicot

Palo de Nigua Cornutia obovata Endangered Dicot

Palo de Ramon Banara vanderbiltii Endangered Dicot

Palo de Rosa Ottoschulzia rhodoxylon Endangered Dicot

Pamakani (Viola chamissoniana ssp. 

chamissoniana)

Viola chamissoniana ssp. chamissoniana Endangered Dicot

Panicgrass, Carter's (Panicum fauriei 

var.carteri)

Panicum fauriei var. carteri Endangered Monocot

Panther, Florida Puma (=Felis) concolor coryi Endangered Mammal

Parrot, Puerto Rican Amazona vittata Endangered Bird

Parrotbill, Maui Pseudonestor xanthophrys Endangered Bird

Pauoa (Ctenitis squamigera) Ctenitis squamigera Endangered Ferns

Pawpaw, Beautiful Deeringothamnus pulchellus Endangered Dicot

Pawpaw, Four-petal Asimina tetramera Endangered Dicot

Pawpaw, Rugel's Deeringothamnus rugelii Endangered Dicot

Pearlshell, Louisiana Margaritifera hembeli Threatened Bivalve

Pearlymussel, Alabama Lamp Lampsilis virescens Endangered Bivalve

Pearlymussel, Alabama Lamp Lampsilis virescens Endangered Bivalve

Pearlymussel, Appalachian Monkeyface Quadrula sparsa Endangered Bivalve

Pearlymussel, Appalachian Monkeyface Quadrula sparsa Endangered Bivalve

Pearlymussel, Appalachian Monkeyface Quadrula sparsa Endangered Bivalve

Pearlymussel, Birdwing Conradilla caelata Endangered Bivalve

Pearlymussel, Birdwing Conradilla caelata Endangered Bivalve

Pearlymussel, Cracking Hemistena lata Endangered Bivalve

Pearlymussel, Cracking Hemistena lata Endangered Bivalve

Pearlymussel, Cracking Hemistena lata Endangered Bivalve

Pearlymussel, Cracking Hemistena lata Endangered Bivalve

Pearlymussel, Cumberland Bean Villosa trabalis Endangered Bivalve

Pearlymussel, Cumberland Bean Villosa trabalis Endangered Bivalve

Pearlymussel, Cumberland Bean Villosa trabalis Endangered Bivalve

Pearlymussel, Cumberland Monkeyface Quadrula intermedia Endangered Bivalve

Pearlymussel, Cumberland Monkeyface Quadrula intermedia Endangered Bivalve

Pearlymussel, Cumberland Monkeyface Quadrula intermedia Endangered Bivalve

Pearlymussel, Curtis' Epioblasma florentina curtisii Endangered Bivalve

Pearlymussel, Dromedary Dromus dromas Endangered Bivalve

Pearlymussel, Dromedary Dromus dromas Endangered Bivalve

Pearlymussel, Dromedary Dromus dromas Endangered Bivalve
-Page 271 of 292- 

zhqSel_StateTaxa2

INVNAME SCINAME Status Taxa

Pearlymussel, Fat Pocketbook Potamilus capax Endangered Bivalve

Pearlymussel, Fat Pocketbook Potamilus capax Endangered Bivalve

Pearlymussel, Fat Pocketbook Potamilus capax Endangered Bivalve

Pearlymussel, Fat Pocketbook Potamilus capax Endangered Bivalve

Pearlymussel, Fat Pocketbook Potamilus capax Endangered Bivalve

Pearlymussel, Fat Pocketbook Potamilus capax Endangered Bivalve

Pearlymussel, Fat Pocketbook Potamilus capax Endangered Bivalve

Pearlymussel, Green-blossom Epioblasma torulosa gubernaculum Endangered Bivalve

Pearlymussel, Green-blossom Epioblasma torulosa gubernaculum Endangered Bivalve

Pearlymussel, Higgins' Eye Lampsilis higginsii Endangered Bivalve

Pearlymussel, Higgins' Eye Lampsilis higginsii Endangered Bivalve

Pearlymussel, Higgins' Eye Lampsilis higginsii Endangered Bivalve

Pearlymussel, Higgins' Eye Lampsilis higginsii Endangered Bivalve

Pearlymussel, Higgins' Eye Lampsilis higginsii Endangered Bivalve

Pearlymussel, Little-wing Pegias fabula Endangered Bivalve

Pearlymussel, Little-wing Pegias fabula Endangered Bivalve

Pearlymussel, Little-wing Pegias fabula Endangered Bivalve

Pearlymussel, Little-wing Pegias fabula Endangered Bivalve

Pearlymussel, Orange-footed Plethobasus cooperianus Endangered Bivalve

Pearlymussel, Orange-footed Plethobasus cooperianus Endangered Bivalve

Pearlymussel, Orange-footed Plethobasus cooperianus Endangered Bivalve

Pearlymussel, Orange-footed Plethobasus cooperianus Endangered Bivalve

Pearlymussel, Orange-footed Plethobasus cooperianus Endangered Bivalve

Pearlymussel, Pale Lilliput Toxolasma cylindrellus Endangered Bivalve

Pearlymussel, Pale Lilliput Toxolasma cylindrellus Endangered Bivalve

Pearlymussel, Purple Cat's Paw Epioblasma obliquata obliquata Endangered Bivalve

Pearlymussel, Purple Cat's Paw Epioblasma obliquata obliquata Endangered Bivalve

Pearlymussel, Purple Cat's Paw Epioblasma obliquata obliquata Endangered Bivalve

Pearlymussel, Tubercled-blossom Epioblasma torulosa torulosa Endangered Bivalve

Pearlymussel, Tubercled-blossom Epioblasma torulosa torulosa Endangered Bivalve

Pearlymussel, Tubercled-blossom Epioblasma torulosa torulosa Endangered Bivalve

Pearlymussel, Tubercled-blossom Epioblasma torulosa torulosa Endangered Bivalve

Pearlymussel, Turgid-blossom Epioblasma turgidula Endangered Bivalve

Pearlymussel, Turgid-blossom Epioblasma turgidula Endangered Bivalve

Pearlymussel, White Cat's Paw Epioblasma obliquata perobliqua Endangered Bivalve

Pearlymussel, White Cat's Paw Epioblasma obliquata perobliqua Endangered Bivalve

Pearlymussel, White Wartyback Plethobasus cicatricosus Endangered Bivalve

Pearlymussel, White Wartyback Plethobasus cicatricosus Endangered Bivalve

Pearlymussel, White Wartyback Plethobasus cicatricosus Endangered Bivalve

Pearlymussel, White Wartyback Plethobasus cicatricosus Endangered Bivalve

Pearlymussel, White Wartyback Plethobasus cicatricosus Endangered Bivalve

Pearlymussel, Yellow-blossom Epioblasma florentina florentina Endangered Bivalve

Pearlymussel, Yellow-blossom Epioblasma florentina florentina Endangered Bivalve

Pebblesnail, Flat Lepyrium showalteri Endangered Gastropod

Pelos del Diablo Aristida portoricensis Endangered Monocot

Penny-cress, Kneeland Prairie Thlaspi californicum Endangered Dicot
-Page 272 of 292- 

zhqSel_StateTaxa2

INVNAME SCINAME Status Taxa

Pennyroyal, Todsen's Hedeoma todsenii Endangered Dicot

Penstemon, Blowout Penstemon haydenii Endangered Dicot

Pentachaeta, Lyon's Pentachaeta lyonii Endangered Dicot

Pentachaeta, White-rayed Pentachaeta bellidiflora Endangered Dicot

Peperomia, Wheeler's Peperomia wheeleri Endangered Dicot

Petrel, Hawaiian Dark-rumped Pterodroma phaeopygia sandwichensis Endangered Bird

Phacelia, Clay Phacelia argillacea Endangered Dicot

Phacelia, Island Phacelia insularis ssp. insularis Endangered Dicot

Phacelia, North Park Phacelia formosula Endangered Dicot

Phlox, Texas Trailing Phlox nivalis ssp. texensis Endangered Dicot

Phlox, Yreka Phlox hirsuta Endangered Dicot

Phyllostegia hirsuta (ncn) Phyllostegia hirsuta Endangered Dicot

Phyllostegia kaalaensis (ncn) Phyllostegia kaalaensis Endangered Dicot

Phyllostegia knudsenii (ncn) Phyllostegia knudsenii Endangered Dicot

Phyllostegia mannii (ncn) Phyllostegia mannii Endangered Dicot

Phyllostegia mollis (ncn) Phyllostegia mollis Endangered Dicot

Phyllostegia parviflora (ncn) Phyllostegia parviflora Endangered Dicot

Phyllostegia velutina (ncn) Phyllostegia velutina Endangered Dicot

Phyllostegia waimeae (ncn) Phyllostegia waimeae Endangered Dicot

Phyllostegia warshaueri (ncn) Phyllostegia warshaueri Endangered Dicot

Phyllostegia wawrana (ncn) Phyllostegia wawrana Endangered Dicot

Pigeon, Puerto Rican Plain Columba inornata wetmorei Endangered Bird

Pilo (Hedyotis mannii) Hedyotis mannii Endangered Dicot

Pink, Swamp Helonias bullata Threatened Monocot

Pink, Swamp Helonias bullata Threatened Monocot

Pink, Swamp Helonias bullata Threatened Monocot

Pink, Swamp Helonias bullata Threatened Monocot

Pink, Swamp Helonias bullata Threatened Monocot

Pink, Swamp Helonias bullata Threatened Monocot

Pink, Swamp Helonias bullata Threatened Monocot

Pinkroot, Gentian Spigelia gentianoides Endangered Dicot

Piperia, Yadon's Piperia yadonii Endangered Monocot

Pitaya, Davis' Green Echinocereus viridiflorus var. davisii Endangered Dicot

Pitcher-plant, Alabama Canebrake Sarracenia rubra alabamensis Endangered Dicot

Pitcher-plant, Green Sarracenia oreophila Endangered Dicot

Pitcher-plant, Green Sarracenia oreophila Endangered Dicot

Pitcher-plant, Green Sarracenia oreophila Endangered Dicot

Pitcher-plant, Green Sarracenia oreophila Endangered Dicot

Pitcher-plant, Mountain Sweet Sarracenia rubra ssp. jonesii Endangered Dicot

Pitcher-plant, Mountain Sweet Sarracenia rubra ssp. jonesii Endangered Dicot

Platanthera holochila (ncn) Platanthera holochila Endangered Monocot

Plover, Piping Charadrius melodus Endangered Bird

Plover, Piping Charadrius melodus Endangered Bird

Plover, Piping Charadrius melodus Endangered Bird

Plover, Piping Charadrius melodus Endangered Bird

Plover, Piping Charadrius melodus Endangered Bird
-Page 273 of 292- 

zhqSel_StateTaxa2

INVNAME SCINAME Status Taxa

Plover, Piping Charadrius melodus Endangered Bird

Plover, Piping Charadrius melodus Endangered Bird

Plover, Piping Charadrius melodus Endangered Bird

Plover, Piping Charadrius melodus Endangered Bird

Plover, Piping Charadrius melodus Endangered Bird

Plover, Piping Charadrius melodus Endangered Bird

Plover, Piping Charadrius melodus Endangered Bird

Plover, Piping Charadrius melodus Endangered Bird

Plover, Piping Charadrius melodus Endangered Bird

Plover, Piping Charadrius melodus Endangered Bird

Plover, Piping Charadrius melodus Endangered Bird

Plover, Piping Charadrius melodus Endangered Bird

Plover, Piping Charadrius melodus Endangered Bird

Plover, Piping Charadrius melodus Endangered Bird

Plover, Piping Charadrius melodus Endangered Bird

Plover, Piping Charadrius melodus Endangered Bird

Plover, Piping Charadrius melodus Endangered Bird

Plover, Piping Charadrius melodus Endangered Bird

Plover, Piping Charadrius melodus Endangered Bird

Plover, Piping Charadrius melodus Endangered Bird

Plover, Piping Charadrius melodus Endangered Bird

Plover, Piping Charadrius melodus Endangered Bird

Plover, Piping Charadrius melodus Endangered Bird

Plover, Piping Charadrius melodus Endangered Bird

Plover, Piping Charadrius melodus Endangered Bird

Plover, Piping Charadrius melodus Endangered Bird

Plover, Piping Charadrius melodus Endangered Bird

Plover, Piping Charadrius melodus Endangered Bird

Plover, Piping Charadrius melodus Endangered Bird

Plover, Piping Charadrius melodus Endangered Bird

Plover, Western Snowy Charadrius alexandrinus nivosus Threatened Bird

Plover, Western Snowy Charadrius alexandrinus nivosus Threatened Bird

Plover, Western Snowy Charadrius alexandrinus nivosus Threatened Bird

Plum, Scrub Prunus geniculata Endangered Dicot

Poa siphonoglossa (ncn) Poa siphonoglossa Endangered Monocot

Po'e (Portulaca sclerocarpa) Portulaca sclerocarpa Endangered Dicot

Pogonia, Small Whorled Isotria medeoloides Threatened Monocot

Pogonia, Small Whorled Isotria medeoloides Threatened Monocot

Pogonia, Small Whorled Isotria medeoloides Threatened Monocot

Pogonia, Small Whorled Isotria medeoloides Threatened Monocot

Pogonia, Small Whorled Isotria medeoloides Threatened Monocot

Pogonia, Small Whorled Isotria medeoloides Threatened Monocot

Pogonia, Small Whorled Isotria medeoloides Threatened Monocot

Pogonia, Small Whorled Isotria medeoloides Threatened Monocot

Pogonia, Small Whorled Isotria medeoloides Threatened Monocot

Pogonia, Small Whorled Isotria medeoloides Threatened Monocot
-Page 274 of 292- 

zhqSel_StateTaxa2

INVNAME SCINAME Status Taxa

Pogonia, Small Whorled Isotria medeoloides Threatened Monocot

Pogonia, Small Whorled Isotria medeoloides Threatened Monocot

Pogonia, Small Whorled Isotria medeoloides Threatened Monocot

Pogonia, Small Whorled Isotria medeoloides Threatened Monocot

Pogonia, Small Whorled Isotria medeoloides Threatened Monocot

Pogonia, Small Whorled Isotria medeoloides Threatened Monocot

Pogonia, Small Whorled Isotria medeoloides Threatened Monocot

Polygala, Lewton's Polygala lewtonii Endangered Dicot

Polygala, Tiny Polygala smallii Endangered Dicot

Polygonum, Scott's Valley Polygonum hickmanii Endangered Dicot

Polystichum calderonense (ncn) Polystichum calderonense Endangered Ferns

Pondberry Lindera melissifolia Endangered Dicot

Pondberry Lindera melissifolia Endangered Dicot

Pondberry Lindera melissifolia Endangered Dicot

Pondberry Lindera melissifolia Endangered Dicot

Pondberry Lindera melissifolia Endangered Dicot

Pondberry Lindera melissifolia Endangered Dicot

Pondweed, Little Aguja Creek Potamogeton clystocarpus Endangered Monocot

Poolfish, Pahrump (= Pahrump Killifish) Empetrichthys latos Endangered Fish

Po'ouli Melamprosops phaeosoma Endangered Bird

Popcornflower, Rough Plagiobothrys hirtus Endangered Dicot

Popolo 'Aiakeakua (Solanum 

sandwicense)

Solanum sandwicense Endangered Dicot

Popolo Ku Mai (Solanum incompletum) Solanum incompletum Endangered Dicot

Poppy, Sacramento Prickly Argemone pleiacantha ssp. pinnatisecta Endangered Dicot

Poppy-mallow, Texas Callirhoe scabriuscula Endangered Dicot

Potato-bean, Price's Apios priceana Threatened Dicot

Potato-bean, Price's Apios priceana Threatened Dicot

Potato-bean, Price's Apios priceana Threatened Dicot

Potato-bean, Price's Apios priceana Threatened Dicot

Potato-bean, Price's Apios priceana Threatened Dicot

Potentilla, Hickman's Potentilla hickmanii Endangered Dicot

Prairie Dog, Utah Cynomys parvidens Threatened Mammal

Prairie-chicken, Attwater's Greater Tympanuchus cupido attwateri Endangered Bird

Prickly-apple, Fragrant Cereus eriophorus var. fragrans Endangered Dicot

Prickly-ash, St. Thomas Zanthoxylum thomasianum Endangered Dicot

Primrose, Maguire Primula maguirei Threatened Dicot

Pronghorn, Sonoran Antilocapra americana sonoriensis Endangered Mammal

Pseudoscorpion, Tooth Cave Tartarocreagris texana Endangered Arachnid

Pteris lidgatei (ncn) Pteris lidgatei Endangered Ferns

Pua'ala (Brighamia rockii) Brighamia rockii Endangered Dicot

Pupfish, Ash Meadows Amargosa Cyprinodon nevadensis mionectes Endangered Fish

Pupfish, Comanche Springs Cyprinodon elegans Endangered Fish

Pupfish, Desert Cyprinodon macularius Endangered Fish

Pupfish, Desert Cyprinodon macularius Endangered Fish

Pupfish, Devils Hole Cyprinodon diabolis Endangered Fish
-Page 275 of 292- 

zhqSel_StateTaxa2

INVNAME SCINAME Status Taxa

Pupfish, Leon Springs Cyprinodon bovinus Endangered Fish

Pupfish, Owens Cyprinodon radiosus Endangered Fish

Pupfish, Warm Springs Cyprinodon nevadensis pectoralis Endangered Fish

Purple Bean Villosa perpurpurea Endangered Bivalve

Purple Bean Villosa perpurpurea Endangered Bivalve

Purple Bean Villosa perpurpurea Endangered Bivalve

Pussypaws, Mariposa Calyptridium pulchellum Threatened Dicot

Pu'uka'a (Cyperus trachysanthos) Cyperus trachysanthos Endangered Monocot

Pygmy-owl, Cactus Ferruginous Glaucidium brasilianum cactorum Endangered Bird

Quillwort, Black-spored Isoetes melanospora Endangered Ferns

Quillwort, Black-spored Isoetes melanospora Endangered Ferns

Quillwort, Louisiana Isoetes louisianensis Endangered Ferns

Quillwort, Louisiana Isoetes louisianensis Endangered Ferns

Quillwort, Louisiana Isoetes louisianensis Endangered Ferns

Quillwort, Mat-forming Isoetes tegetiformans Endangered Ferns

Rabbit, Lower Keys Marsh Sylvilagus palustris hefneri Endangered Mammal

Rabbit, Pygmy Brachylagus idahoensis Endangered Mammal

Rabbit, Riparian Brush Sylvilagus bachmani riparius Endangered Mammal

Rabbitsfoot, Rough Quadrula cylindrica strigillata Endangered Bivalve

Rabbitsfoot, Rough Quadrula cylindrica strigillata Endangered Bivalve

Rail, California Clapper Rallus longirostris obsoletus Endangered Bird

Rail, Light-footed Clapper Rallus longirostris levipes Endangered Bird

Rail, Yuma Clapper Rallus longirostris yumanensis Endangered Bird

Rail, Yuma Clapper Rallus longirostris yumanensis Endangered Bird

Rail, Yuma Clapper Rallus longirostris yumanensis Endangered Bird

Rattlesnake, New Mexican Ridge-nosed Crotalus willardi obscurus Threatened Reptile

Rattlesnake, New Mexican Ridge-nosed Crotalus willardi obscurus Threatened Reptile

Rattleweed, Hairy Baptisia arachnifera Endangered Dicot

Reed-mustard, Barneby Schoenocrambe barnebyi Endangered Dicot

Reed-mustard, Clay Schoenocrambe argillacea Threatened Dicot

Reed-mustard, Shrubby Schoenocrambe suffrutescens Endangered Dicot

Remya kauaiensis (ncn) Remya kauaiensis Endangered Dicot

Remya montgomeryi (ncn) Remya montgomeryi Endangered Dicot

Remya, Maui Remya mauiensis Endangered Dicot

Rhadine exilis (ncn) Rhadine exilis Endangered Insect

Rhadine infernalis (ncn) Rhadine infernalis Endangered Insect

Rhododendron, Chapman Rhododendron chapmanii Endangered Dicot

Rice Rat (=Silver Rice Rat) Oryzomys palustris natator Endangered Mammal

Ridge-cress (=Pepper-cress), Barneby Lepidium barnebyanum Endangered Dicot

Riffleshell, Northern Epioblasma torulosa rangiana Endangered Bivalve

Riffleshell, Northern Epioblasma torulosa rangiana Endangered Bivalve

Riffleshell, Northern Epioblasma torulosa rangiana Endangered Bivalve

Riffleshell, Northern Epioblasma torulosa rangiana Endangered Bivalve

Riffleshell, Northern Epioblasma torulosa rangiana Endangered Bivalve

Riffleshell, Tan Epioblasma florentina walkeri (=E. walkeri) Endangered Bivalve

Riffleshell, Tan Epioblasma florentina walkeri (=E. walkeri) Endangered Bivalve
-Page 276 of 292- 

zhqSel_StateTaxa2

INVNAME SCINAME Status Taxa

Riffleshell, Tan Epioblasma florentina walkeri (=E. walkeri) Endangered Bivalve

Riversnail, Anthony's Athearnia anthonyi Endangered Gastropod

Riversnail, Anthony's Athearnia anthonyi Endangered Gastropod

Rock-cress, Hoffmann's Arabis hoffmannii Endangered Dicot

Rock-cress, Large (=Braun's) Arabis perstellata E. L. Braun var. ampla Rollins Endangered Dicot

Rock-cress, Large (=Braun's) Arabis perstellata E. L. Braun var. ampla Rollins Endangered Dicot

Rock-cress, McDonald's Arabis mcdonaldiana Endangered Dicot

Rock-cress, Santa Cruz Island Sibara filifolia Endangered Dicot

Rock-cress, Shale Barren Arabis serotina Endangered Dicot

Rock-cress, Shale Barren Arabis serotina Endangered Dicot

Rock-cress, Small Arabis perstellata E. L. Braun var. perstellata 

Fernald

Endangered Dicot

Rock-cress, Small Arabis perstellata E. L. Braun var. perstellata 

Fernald

Endangered Dicot

Rock-pocketbook, Ouachita (=Wheeler's 

pm)

Arkansia wheeleri Endangered Bivalve

Rock-pocketbook, Ouachita (=Wheeler's 

pm)

Arkansia wheeleri Endangered Bivalve

Rocksnail, Painted Leptoxis taeniata Threatened Gastropod

Rocksnail, Plicate Leptoxis plicata Endangered Gastropod

Rocksnail, Round Leptoxis ampla Threatened Gastropod

Rosemary, Apalachicola Conradina glabra Endangered Dicot

Rosemary, Cumberland Conradina verticillata Threatened Dicot

Rosemary, Cumberland Conradina verticillata Threatened Dicot

Rosemary, Etonia Conradina etonia Endangered Dicot

Rosemary, Short-leaved Conradina brevifolia Endangered Dicot

Roseroot, Leedy's Sedum integrifolium ssp. leedyi Threatened Dicot

Roseroot, Leedy's Sedum integrifolium ssp. leedyi Threatened Dicot

Rush-pea, Slender Hoffmannseggia tenella Endangered Dicot

Rush-rose, Island Helianthemum greenei Threatened Dicot

Salamander, Barton Springs Eurycea sosorum Endangered Amphibian

Salamander, California Tiger Ambystoma californiense Endangered Amphibian

Salamander, Cheat Mountain Plethodon nettingi Threatened Amphibian

Salamander, Desert Slender Batrachoseps aridus Endangered Amphibian

Salamander, Flatwoods Ambystoma cingulatum Threatened Amphibian

Salamander, Flatwoods Ambystoma cingulatum Threatened Amphibian

Salamander, Flatwoods Ambystoma cingulatum Threatened Amphibian

Salamander, Flatwoods Ambystoma cingulatum Threatened Amphibian

Salamander, Red Hills Phaeognathus hubrichti Threatened Amphibian

Salamander, San Marcos Eurycea nana Threatened Amphibian

Salamander, Santa Cruz Long-toed Ambystoma macrodactylum croceum Endangered Amphibian

Salamander, Shenandoah Plethodon shenandoah Endangered Amphibian

Salamander, Sonora Tiger Ambystoma tigrinum stebbinsi Endangered Amphibian

Salamander, Texas Blind Typhlomolge rathbuni Endangered Amphibian

Salmon, Atlantic Salmo salar Endangered Fish

Salmon, Chinook (California Coastal Run) Oncorhynchus (=Salmo) tshawytscha Threatened Fish

Salmon, Chinook (Central Valley Fall Run) Oncorhynchus (=Salmo) tshawytscha Threatened Fish
-Page 277 of 292- 

zhqSel_StateTaxa2

INVNAME SCINAME Status Taxa

Salmon, Chinook (Central Valley Spring 

Run)

Oncorhynchus (=Salmo) tshawytscha Threatened Fish

Salmon, Chinook (Lower Columbia River) Oncorhynchus (=Salmo) tshawytscha Threatened Fish

Salmon, Chinook (Lower Columbia River) Oncorhynchus (=Salmo) tshawytscha Threatened Fish

Salmon, Chinook (Puget Sound) Oncorhynchus (=Salmo) tshawytscha Threatened Fish

Salmon, Chinook (Sacramento River 

Winter Run)

Oncorhynchus (=Salmo) tshawytscha Endangered Fish

Salmon, Chinook (Snake River Fall Run) Oncorhynchus (=Salmo) tshawytscha Threatened Fish

Salmon, Chinook (Snake River Fall Run) Oncorhynchus (=Salmo) tshawytscha Threatened Fish

Salmon, Chinook (Snake River Fall Run) Oncorhynchus (=Salmo) tshawytscha Threatened Fish

Salmon, Chinook (Snake River 

spring/summer)

Oncorhynchus (=Salmo) tshawytscha Threatened Fish

Salmon, Chinook (Snake River 

spring/summer)

Oncorhynchus (=Salmo) tshawytscha Threatened Fish

Salmon, Chinook (Snake River 

spring/summer)

Oncorhynchus (=Salmo) tshawytscha Threatened Fish

Salmon, Chinook (Upper Columbia River 

Spring)

Oncorhynchus (=Salmo) tshawytscha Endangered Fish

Salmon, Chinook (Upper Columbia River 

Spring)

Oncorhynchus (=Salmo) tshawytscha Endangered Fish

Salmon, Chinook (Upper Willamette 

River)

Oncorhynchus (=Salmo) tshawytscha Threatened Fish

Salmon, Chinook (Upper Willamette 

River)

Oncorhynchus (=Salmo) tshawytscha Threatened Fish

Salmon, Chum (Columbia River 

population)

Oncorhynchus (=Salmo) keta Threatened Fish

Salmon, Chum (Columbia River 

population)

Oncorhynchus (=Salmo) keta Threatened Fish

Salmon, Chum (Hood Canal Summer 

population)

Oncorhynchus (=Salmo) keta Threatened Fish

Salmon, Coho (Central California Coast 

population)

Oncorhynchus (=Salmo) kisutch Endangered Fish

Salmon, Coho (Southern OR/Northern CA 

Coast)

Oncorhynchus (=Salmo) kisutch Threatened Fish

Salmon, Coho (Southern OR/Northern CA 

Coast)

Oncorhynchus (=Salmo) kisutch Threatened Fish

Salmon, Sockeye (Ozette Lake 

population)

Oncorhynchus (=Salmo) nerka Threatened Fish

Salmon, Sockeye (Snake River 

population)

Oncorhynchus (=Salmo) nerka Endangered Fish

Salmon, Sockeye (Snake River 

population)

Oncorhynchus (=Salmo) nerka Endangered Fish

Salmon, Sockeye (Snake River 

population)

Oncorhynchus (=Salmo) nerka Endangered Fish

Sandalwood, Lanai (='Iliahi) Santalum freycinetianum var. lanaiense Endangered Dicot

Sandlace Polygonella myriophylla Endangered Dicot

Sand-verbena, Large-fruited Abronia macrocarpa Endangered Dicot

Sandwort, Bear Valley Arenaria ursina Threatened Dicot

Sandwort, Cumberland Arenaria cumberlandensis Endangered Dicot

Sandwort, Cumberland Arenaria cumberlandensis Endangered Dicot
-Page 278 of 292- 

zhqSel_StateTaxa2

INVNAME SCINAME Status Taxa

Sandwort, Marsh Arenaria paludicola Endangered Dicot

Sanicula mariversa (ncn) Sanicula mariversa Endangered Dicot

Sanicula purpurea (ncn) Sanicula purpurea Endangered Dicot

Sawfish, Smalltooth Pristis pectinata Endangered Fish

Schiedea haleakalensis (ncn) Schiedea haleakalensis Endangered Dicot

Schiedea helleri (ncn) Schiedea helleri Endangered Dicot

Schiedea hookeri (ncn) Schiedea hookeri Endangered Dicot

Schiedea kaalae (ncn) Schiedea kaalae Endangered Dicot

Schiedea kauaiensis (ncn) Schiedea kauaiensis Endangered Dicot

Schiedea lydgatei (ncn) Schiedea lydgatei Endangered Dicot

Schiedea membranacea (ncn) Schiedea membranacea Endangered Dicot

Schiedea nuttallii (ncn) Schiedea nuttallii Endangered Dicot

Schiedea sarmentosa (ncn) Schiedea sarmentosa Endangered Dicot

Schiedea spergulina var. leiopoda (ncn) Schiedea spergulina var. leiopoda Endangered Dicot

Schiedea spergulina var. spergulina (ncn) Schiedea spergulina var. spergulina Threatened Dicot

Schiedea verticillata (ncn) Schiedea verticillata Endangered Dicot

Schiedea, Diamond Head (Schiedea 

adamantis)

Schiedea adamantis Endangered Dicot

Schoepfia arenaria (ncn) Schoepfia arenaria Threatened Dicot

Scrub-Jay, Florida Aphelocoma coerulescens Threatened Bird

Sculpin, Pygmy Cottus paulus (=pygmaeus) Threatened Fish

Sea turtle, green Chelonia mydas Endangered Reptile

Sea turtle, green Chelonia mydas Endangered Reptile

Sea turtle, green Chelonia mydas Endangered Reptile

Sea turtle, green Chelonia mydas Endangered Reptile

Sea turtle, green Chelonia mydas Endangered Reptile

Sea turtle, green Chelonia mydas Endangered Reptile

Sea turtle, green Chelonia mydas Endangered Reptile

Sea turtle, green Chelonia mydas Endangered Reptile

Sea turtle, green Chelonia mydas Endangered Reptile

Sea turtle, green Chelonia mydas Endangered Reptile

Sea turtle, green Chelonia mydas Endangered Reptile

Sea turtle, green Chelonia mydas Endangered Reptile

Sea turtle, green Chelonia mydas Endangered Reptile

Sea turtle, green Chelonia mydas Endangered Reptile

Sea turtle, green Chelonia mydas Endangered Reptile

Sea turtle, green Chelonia mydas Endangered Reptile

Sea turtle, hawksbill Eretmochelys imbricata Endangered Reptile

Sea turtle, hawksbill Eretmochelys imbricata Endangered Reptile

Sea turtle, hawksbill Eretmochelys imbricata Endangered Reptile

Sea turtle, hawksbill Eretmochelys imbricata Endangered Reptile

Sea turtle, hawksbill Eretmochelys imbricata Endangered Reptile

Sea turtle, hawksbill Eretmochelys imbricata Endangered Reptile

Sea turtle, hawksbill Eretmochelys imbricata Endangered Reptile

Sea turtle, hawksbill Eretmochelys imbricata Endangered Reptile

Sea turtle, hawksbill Eretmochelys imbricata Endangered Reptile
-Page 279 of 292- 

zhqSel_StateTaxa2

INVNAME SCINAME Status Taxa

Sea turtle, hawksbill Eretmochelys imbricata Endangered Reptile

Sea turtle, hawksbill Eretmochelys imbricata Endangered Reptile

Sea turtle, hawksbill Eretmochelys imbricata Endangered Reptile

Sea turtle, hawksbill Eretmochelys imbricata Endangered Reptile

Sea turtle, hawksbill Eretmochelys imbricata Endangered Reptile

Sea turtle, hawksbill Eretmochelys imbricata Endangered Reptile

Sea turtle, hawksbill Eretmochelys imbricata Endangered Reptile

Sea turtle, hawksbill Eretmochelys imbricata Endangered Reptile

Sea turtle, hawksbill Eretmochelys imbricata Endangered Reptile

Sea turtle, Kemp's ridley Lepidochelys kempii Endangered Reptile

Sea turtle, Kemp's ridley Lepidochelys kempii Endangered Reptile

Sea turtle, Kemp's ridley Lepidochelys kempii Endangered Reptile

Sea turtle, Kemp's ridley Lepidochelys kempii Endangered Reptile

Sea turtle, Kemp's ridley Lepidochelys kempii Endangered Reptile

Sea turtle, Kemp's ridley Lepidochelys kempii Endangered Reptile

Sea turtle, Kemp's ridley Lepidochelys kempii Endangered Reptile

Sea turtle, Kemp's ridley Lepidochelys kempii Endangered Reptile

Sea turtle, Kemp's ridley Lepidochelys kempii Endangered Reptile

Sea turtle, Kemp's ridley Lepidochelys kempii Endangered Reptile

Sea turtle, Kemp's ridley Lepidochelys kempii Endangered Reptile

Sea turtle, Kemp's ridley Lepidochelys kempii Endangered Reptile

Sea turtle, Kemp's ridley Lepidochelys kempii Endangered Reptile

Sea turtle, Kemp's ridley Lepidochelys kempii Endangered Reptile

Sea turtle, Kemp's ridley Lepidochelys kempii Endangered Reptile

Sea turtle, Kemp's ridley Lepidochelys kempii Endangered Reptile

Sea turtle, leatherback Dermochelys coriacea Endangered Reptile

Sea turtle, leatherback Dermochelys coriacea Endangered Reptile

Sea turtle, leatherback Dermochelys coriacea Endangered Reptile

Sea turtle, leatherback Dermochelys coriacea Endangered Reptile

Sea turtle, leatherback Dermochelys coriacea Endangered Reptile

Sea turtle, leatherback Dermochelys coriacea Endangered Reptile

Sea turtle, leatherback Dermochelys coriacea Endangered Reptile

Sea turtle, leatherback Dermochelys coriacea Endangered Reptile

Sea turtle, leatherback Dermochelys coriacea Endangered Reptile

Sea turtle, leatherback Dermochelys coriacea Endangered Reptile

Sea turtle, leatherback Dermochelys coriacea Endangered Reptile

Sea turtle, leatherback Dermochelys coriacea Endangered Reptile

Sea turtle, leatherback Dermochelys coriacea Endangered Reptile

Sea turtle, leatherback Dermochelys coriacea Endangered Reptile

Sea turtle, leatherback Dermochelys coriacea Endangered Reptile

Sea turtle, leatherback Dermochelys coriacea Endangered Reptile

Sea turtle, leatherback Dermochelys coriacea Endangered Reptile

Sea turtle, leatherback Dermochelys coriacea Endangered Reptile

Sea turtle, leatherback Dermochelys coriacea Endangered Reptile

Sea turtle, leatherback Dermochelys coriacea Endangered Reptile

Sea turtle, leatherback Dermochelys coriacea Endangered Reptile
-Page 280 of 292- 

zhqSel_StateTaxa2

INVNAME SCINAME Status Taxa

Sea turtle, leatherback Dermochelys coriacea Endangered Reptile

Sea turtle, leatherback Dermochelys coriacea Endangered Reptile

Sea turtle, leatherback Dermochelys coriacea Endangered Reptile

Sea turtle, loggerhead Caretta caretta Threatened Reptile

Sea turtle, loggerhead Caretta caretta Threatened Reptile

Sea turtle, loggerhead Caretta caretta Threatened Reptile

Sea turtle, loggerhead Caretta caretta Threatened Reptile

Sea turtle, loggerhead Caretta caretta Threatened Reptile

Sea turtle, loggerhead Caretta caretta Threatened Reptile

Sea turtle, loggerhead Caretta caretta Threatened Reptile

Sea turtle, loggerhead Caretta caretta Threatened Reptile

Sea turtle, loggerhead Caretta caretta Threatened Reptile

Sea turtle, loggerhead Caretta caretta Threatened Reptile

Sea turtle, loggerhead Caretta caretta Threatened Reptile

Sea turtle, loggerhead Caretta caretta Threatened Reptile

Sea turtle, loggerhead Caretta caretta Threatened Reptile

Sea turtle, loggerhead Caretta caretta Threatened Reptile

Sea turtle, loggerhead Caretta caretta Threatened Reptile

Sea turtle, loggerhead Caretta caretta Threatened Reptile

Sea turtle, loggerhead Caretta caretta Threatened Reptile

Sea turtle, loggerhead Caretta caretta Threatened Reptile

Sea turtle, loggerhead Caretta caretta Threatened Reptile

Sea turtle, loggerhead Caretta caretta Threatened Reptile

Sea turtle, olive ridley Lepidochelys olivacea Threatened Reptile

Sea-blite, California Suaeda californica Endangered Dicot

Seagrass, Johnson's Halophila johnsonii Threatened Monocot

Seal, Caribbean Monk Monachus tropicalis Endangered Marine mml

Seal, Caribbean Monk Monachus tropicalis Endangered Marine mml

Seal, Guadalupe Fur Arctocephalus townsendi Threatened Marine mml

Seal, Hawaiian Monk Monachus schauinslandi Endangered Marine mml

Sea-lion, Steller (eastern) Eumetopias jubatus Threatened Marine mml

Sea-lion, Steller (eastern) Eumetopias jubatus Threatened Marine mml

Sea-lion, Steller (eastern) Eumetopias jubatus Threatened Marine mml

Sea-lion, Steller (eastern) Eumetopias jubatus Threatened Marine mml

Sedge, Golden Carex lutea Endangered Monocot

Sedge, Navajo Carex specuicola Threatened Monocot

Sedge, Navajo Carex specuicola Threatened Monocot

Sedge, White Carex albida Endangered Monocot

Shagreen, Magazine Mountain Mesodon magazinensis Threatened Gastropod

Shearwater, Newell's Townsend's Puffinus auricularis newelli Threatened Bird

Sheep, Peninsular Bighorn Ovis canadensis Endangered Mammal

Sheep, Sierra Nevada Bighorn Ovis canadensis californiana Endangered Mammal

Shiner, Arkansas River Notropis girardi Threatened Fish

Shiner, Arkansas River Notropis girardi Threatened Fish

Shiner, Arkansas River Notropis girardi Threatened Fish

Shiner, Arkansas River Notropis girardi Threatened Fish
-Page 281 of 292- 

zhqSel_StateTaxa2

INVNAME SCINAME Status Taxa

Shiner, Beautiful Cyprinella formosa Threatened Fish

Shiner, Beautiful Cyprinella formosa Threatened Fish

Shiner, Blue Cyprinella caerulea Threatened Fish

Shiner, Blue Cyprinella caerulea Threatened Fish

Shiner, Blue Cyprinella caerulea Threatened Fish

Shiner, Cahaba Notropis cahabae Endangered Fish

Shiner, Cape Fear Notropis mekistocholas Endangered Fish

Shiner, Palezone Notropis albizonatus Endangered Fish

Shiner, Palezone Notropis albizonatus Endangered Fish

Shiner, Palezone Notropis albizonatus Endangered Fish

Shiner, Pecos Bluntnose Notropis simus pecosensis Threatened Fish

Shiner, Topeka Notropis topeka (=tristis) Endangered Fish

Shiner, Topeka Notropis topeka (=tristis) Endangered Fish

Shiner, Topeka Notropis topeka (=tristis) Endangered Fish

Shiner, Topeka Notropis topeka (=tristis) Endangered Fish

Shiner, Topeka Notropis topeka (=tristis) Endangered Fish

Shiner, Topeka Notropis topeka (=tristis) Endangered Fish

Shrew, Buena Vista Lake Ornate Sorex ornatus relictus Endangered Mammal

Shrike, San Clemente Loggerhead Lanius ludovicianus mearnsi Endangered Bird

Shrimp, Alabama Cave Palaemonias alabamae Endangered Crustacean

Shrimp, California Freshwater Syncaris pacifica Endangered Crustacean

Shrimp, Kentucky Cave Palaemonias ganteri Endangered Crustacean

Shrimp, Squirrel Chimney Cave Palaemonetes cummingi Threatened Crustacean

Silene alexandri (ncn) Silene alexandri Endangered Dicot

Silene hawaiiensis (ncn) Silene hawaiiensis Threatened Dicot

Silene lanceolata (ncn) Silene lanceolata Endangered Dicot

Silene perlmanii (ncn) Silene perlmanii Endangered Dicot

Silverside, Waccamaw Menidia extensa Threatened Fish

Silversword, Haleakala ('Ahinahina) Argyroxiphium sandwicense ssp. 

macrocephalum

Threatened Dicot

Silversword, Ka'u (Argyroxiphium 

kauense)

Argyroxiphium kauense Endangered Dicot

Silversword, Mauna Kea ('Ahinahina) Argyroxiphium sandwicense ssp. sandwicense Endangered Dicot

Skink, Blue-tailed Mole Eumeces egregius lividus Threatened Reptile

Skink, Sand Neoseps reynoldsi Threatened Reptile

Skipper, Carson Wandering Pseudocopaeodes eunus obscurus Endangered Insect

Skipper, Carson Wandering Pseudocopaeodes eunus obscurus Endangered Insect

Skipper, Laguna Mountain Pyrgus ruralis lagunae Endangered Insect

Skipper, Pawnee Montane Hesperia leonardus montana Threatened Insect

Skullcap, Florida Scutellaria floridana Threatened Dicot

Skullcap, Large-flowered Scutellaria montana Threatened Dicot

Skullcap, Large-flowered Scutellaria montana Threatened Dicot

Slabshell, Chipola Elliptio chipolaensis Threatened Bivalve

Smelt, Delta Hypomesus transpacificus Threatened Fish

Snail, Armored Pyrgulopsis (=Marstonia) pachyta Endangered Gastropod

Snail, Bliss Rapids Taylorconcha serpenticola Threatened Gastropod
-Page 282 of 292- 

zhqSel_StateTaxa2

INVNAME SCINAME Status Taxa

Snail, Chittenango Ovate Amber Succinea chittenangoensis Threatened Gastropod

Snail, Flat-spired Three-toothed Triodopsis platysayoides Threatened Gastropod

Snail, Iowa Pleistocene Discus macclintocki Endangered Gastropod

Snail, Iowa Pleistocene Discus macclintocki Endangered Gastropod

Snail, Lioplax Cylindrical Lioplax cyclostomaformis Endangered Gastropod

Snail, Morro Shoulderband Helminthoglypta walkeriana Endangered Gastropod

Snail, Newcomb's Erinna newcombi Threatened Gastropod

Snail, Noonday Mesodon clarki nantahala Threatened Gastropod

Snail, O'ahu Tree (Achatinella abbreviata) Achatinella abbreviata Endangered Gastropod

Snail, O'ahu Tree (Achatinella apexfulva) Achatinella apexfulva Endangered Gastropod

Snail, O'ahu Tree (Achatinella bellula) Achatinella bellula Endangered Gastropod

Snail, O'ahu Tree (Achatinella buddii) Achatinella buddii Endangered Gastropod

Snail, O'ahu Tree (Achatinella bulimoides) Achatinella bulimoides Endangered Gastropod

Snail, O'ahu Tree (Achatinella byronii) Achatinella byronii Endangered Gastropod

Snail, O'ahu Tree (Achatinella caesia) Achatinella caesia Endangered Gastropod

Snail, O'ahu Tree (Achatinella casta) Achatinella casta Endangered Gastropod

Snail, O'ahu Tree (Achatinella cestus) Achatinella cestus Endangered Gastropod

Snail, O'ahu Tree (Achatinella 

concavospira)

Achatinella concavospira Endangered Gastropod

Snail, O'ahu Tree (Achatinella curta) Achatinella curta Endangered Gastropod

Snail, O'ahu Tree (Achatinella decipiens) Achatinella decipiens Endangered Gastropod

Snail, O'ahu Tree (Achatinella decora) Achatinella decora Endangered Gastropod

Snail, O'ahu Tree (Achatinella dimorpha) Achatinella dimorpha Endangered Gastropod

Snail, O'ahu Tree (Achatinella elegans) Achatinella elegans Endangered Gastropod

Snail, O'ahu Tree (Achatinella fulgens) Achatinella fulgens Endangered Gastropod

Snail, O'ahu Tree (Achatinella fuscobasis) Achatinella fuscobasis Endangered Gastropod

Snail, O'ahu Tree (Achatinella juddii) Achatinella juddii Endangered Gastropod

Snail, O'ahu Tree (Achatinella juncea) Achatinella juncea Endangered Gastropod

Snail, O'ahu Tree (Achatinella lehuiensis) Achatinella lehuiensis Endangered Gastropod

Snail, O'ahu Tree (Achatinella 

leucorraphe)

Achatinella leucorraphe Endangered Gastropod

Snail, O'ahu Tree (Achatinella lila) Achatinella lila Endangered Gastropod

Snail, O'ahu Tree (Achatinella livida) Achatinella livida Endangered Gastropod

Snail, O'ahu Tree (Achatinella lorata) Achatinella lorata Endangered Gastropod

Snail, O'ahu Tree (Achatinella mustelina) Achatinella mustelina Endangered Gastropod

Snail, O'ahu Tree (Achatinella papyracea) Achatinella papyracea Endangered Gastropod

Snail, O'ahu Tree (Achatinella phaeozona) Achatinella phaeozona Endangered Gastropod

Snail, O'ahu Tree (Achatinella 

pulcherrima)

Achatinella pulcherrima Endangered Gastropod

Snail, O'ahu Tree (Achatinella 

pupukanioe)

Achatinella pupukanioe Endangered Gastropod

Snail, O'ahu Tree (Achatinella rosea) Achatinella rosea Endangered Gastropod

Snail, O'ahu Tree (Achatinella 

sowerbyana)

Achatinella sowerbyana Endangered Gastropod

Snail, O'ahu Tree (Achatinella spaldingi) Achatinella spaldingi Endangered Gastropod

Snail, O'ahu Tree (Achatinella stewartii) Achatinella stewartii Endangered Gastropod

Snail, O'ahu Tree (Achatinella swiftii) Achatinella swiftii Endangered Gastropod
-Page 283 of 292- 

zhqSel_StateTaxa2

INVNAME SCINAME Status Taxa

Snail, O'ahu Tree (Achatinella taeniolata) Achatinella taeniolata Endangered Gastropod

Snail, O'ahu Tree (Achatinella thaanumi) Achatinella thaanumi Endangered Gastropod

Snail, O'ahu Tree (Achatinella turgida) Achatinella turgida Endangered Gastropod

Snail, O'ahu Tree (Achatinella valida) Achatinella valida Endangered Gastropod

Snail, Painted Snake Coiled Forest Anguispira picta Threatened Gastropod

Snail, Pecos Assiminea Assiminea pecos Endangered Gastropod

Snail, Pecos Assiminea Assiminea pecos Endangered Gastropod

Snail, Snake River Physa Physa natricina Endangered Gastropod

Snail, Stock Island Tree Orthalicus reses (not incl. nesodryas) Threatened Gastropod

Snail, Tulotoma Tulotoma magnifica Endangered Gastropod

Snail, Utah Valvata Valvata utahensis Endangered Gastropod

Snail, Virginia Fringed Mountain Polygyriscus virginianus Endangered Gastropod

Snake, Atlantic Salt Marsh Nerodia clarkii taeniata Threatened Reptile

Snake, Concho Water Nerodia paucimaculata Threatened Reptile

Snake, Eastern Indigo Drymarchon corais couperi Threatened Reptile

Snake, Eastern Indigo Drymarchon corais couperi Threatened Reptile

Snake, Eastern Indigo Drymarchon corais couperi Threatened Reptile

Snake, Eastern Indigo Drymarchon corais couperi Threatened Reptile

Snake, Eastern Indigo Drymarchon corais couperi Threatened Reptile

Snake, Giant Garter Thamnophis gigas Threatened Reptile

Snake, Lake Erie Water Nerodia sipedon insularum Threatened Reptile

Snake, Northern Copperbelly Water Nerodia erythrogaster neglecta Threatened Reptile

Snake, Northern Copperbelly Water Nerodia erythrogaster neglecta Threatened Reptile

Snake, Northern Copperbelly Water Nerodia erythrogaster neglecta Threatened Reptile

Snake, San Francisco Garter Thamnophis sirtalis tetrataenia Endangered Reptile

Snakeroot Eryngium cuneifolium Endangered Dicot

Sneezeweed, Virginia Helenium virginicum Threatened Dicot

Sneezeweed, Virginia Helenium virginicum Threatened Dicot

Snowbells, Texas Styrax texanus Endangered Dicot

Sparrow, Cape Sable Seaside Ammodramus maritimus mirabilis Endangered Bird

Sparrow, Florida Grasshopper Ammodramus savannarum floridanus Endangered Bird

Sparrow, San Clemente Sage Amphispiza belli clementeae Threatened Bird

Spermolepis hawaiiensis (ncn) Spermolepis hawaiiensis Endangered Dicot

Spider, Government Canyon Cave Neoleptoneta microps Endangered Arachnid

Spider, Kauai Cave Wolf Adelocosa anops Endangered Arachnid

Spider, Madla's Cave Cicurina madla Endangered Arachnid

Spider, Robber Baron Cave Cicurina baronia Endangered Arachnid

Spider, Spruce-fir Moss Microhexura montivaga Endangered Arachnid

Spider, Spruce-fir Moss Microhexura montivaga Endangered Arachnid

Spider, Tooth Cave Neoleptoneta myopica Endangered Arachnid

Spider, Vesper Cave Cicurina vespera Endangered Arachnid

Spikedace Meda fulgida Threatened Fish

Spikedace Meda fulgida Threatened Fish

Spinedace, Big Spring Lepidomeda mollispinis pratensis Threatened Fish

Spinedace, Little Colorado Lepidomeda vittata Threatened Fish

Spinedace, White River Lepidomeda albivallis Endangered Fish
-Page 284 of 292- 

zhqSel_StateTaxa2

INVNAME SCINAME Status Taxa

Spineflower, Ben Lomond Chorizanthe pungens var. hartwegiana Endangered Dicot

Spineflower, Howell's Chorizanthe howellii Endangered Dicot

Spineflower, Monterey Chorizanthe pungens var. pungens Threatened Dicot

Spineflower, Orcutt's Chorizanthe orcuttiana Endangered Dicot

Spineflower, Robust Chorizanthe robusta var. robusta Endangered Dicot

Spineflower, Scotts Valley Chorizanthe robusta var. hartwegii Endangered Dicot

Spineflower, Slender-horned Dodecahema leptoceras Endangered Dicot

Spineflower, Sonoma Chorizanthe valida Endangered Dicot

Spinymussel, James River Pleurobema collina Endangered Bivalve

Spinymussel, James River Pleurobema collina Endangered Bivalve

Spinymussel, James River Pleurobema collina Endangered Bivalve

Spinymussel, Tar River Elliptio steinstansana Endangered Bivalve

Spiraea, Virginia Spiraea virginiana Threatened Dicot

Spiraea, Virginia Spiraea virginiana Threatened Dicot

Spiraea, Virginia Spiraea virginiana Threatened Dicot

Spiraea, Virginia Spiraea virginiana Threatened Dicot

Spiraea, Virginia Spiraea virginiana Threatened Dicot

Spiraea, Virginia Spiraea virginiana Threatened Dicot

Spiraea, Virginia Spiraea virginiana Threatened Dicot

Springfish, Hiko White River Crenichthys baileyi grandis Endangered Fish

Springfish, Railroad Valley Crenichthys nevadae Threatened Fish

Springfish, White River Crenichthys baileyi baileyi Endangered Fish

Springsnail, Alamosa Tryonia alamosae Endangered Gastropod

Springsnail, Bruneau Hot Pyrgulopsis bruneauensis Endangered Gastropod

Springsnail, Koster's Juturnia kosteri Endangered Gastropod

Springsnail, Roswell Pyrgulopsis roswellensis Endangered Gastropod

Springsnail, Socorro Pyrgulopsis neomexicana Endangered Gastropod

Spurge, Deltoid Chamaesyce deltoidea ssp. deltoidea Endangered Dicot

Spurge, Garber's Chamaesyce garberi Threatened Dicot

Spurge, Hoover's Chamaesyce hooveri Threatened Dicot

Spurge, Telephus Euphorbia telephioides Threatened Dicot

Squawfish, Colorado Ptychocheilus lucius Endangered Fish

Squawfish, Colorado Ptychocheilus lucius Endangered Fish

Squawfish, Colorado Ptychocheilus lucius Endangered Fish

Squawfish, Colorado Ptychocheilus lucius Endangered Fish

Squawfish, Colorado Ptychocheilus lucius Endangered Fish

Squirrel, Carolina Northern Flying Glaucomys sabrinus coloratus Endangered Mammal

Squirrel, Carolina Northern Flying Glaucomys sabrinus coloratus Endangered Mammal

Squirrel, Carolina Northern Flying Glaucomys sabrinus coloratus Endangered Mammal

Squirrel, Delmarva Peninsula Fox Sciurus niger cinereus Endangered Mammal

Squirrel, Delmarva Peninsula Fox Sciurus niger cinereus Endangered Mammal

Squirrel, Delmarva Peninsula Fox Sciurus niger cinereus Endangered Mammal

Squirrel, Delmarva Peninsula Fox Sciurus niger cinereus Endangered Mammal

Squirrel, Mount Graham Red Tamiasciurus hudsonicus grahamensis Endangered Mammal

Squirrel, Northern Idaho Ground Spermophilus brunneus brunneus Threatened Mammal

Staghorn coral Acropora cervicornis Threatened Coral
-Page 285 of 292- 

zhqSel_StateTaxa2

INVNAME SCINAME Status Taxa

Steelhead, (California Central Valley 

population)

Oncorhynchus (=Salmo) mykiss Threatened Fish

Steelhead, (Central California Coast 

population)

Oncorhynchus (=Salmo) mykiss Threatened Fish

Steelhead, (Lower Columbia River 

population)

Oncorhynchus (=Salmo) mykiss Threatened Fish

Steelhead, (Lower Columbia River 

population)

Oncorhynchus (=Salmo) mykiss Threatened Fish

Steelhead, (Middle Columbia River 

population)

Oncorhynchus (=Salmo) mykiss Threatened Fish

Steelhead, (Middle Columbia River 

population)

Oncorhynchus (=Salmo) mykiss Threatened Fish

Steelhead, (Northern California 

population)

Oncorhynchus (=Salmo) mykiss Threatened Fish

Steelhead, (Snake River Basin 

population)

Oncorhynchus (=Salmo) mykiss Threatened Fish

Steelhead, (Snake River Basin 

population)

Oncorhynchus (=Salmo) mykiss Threatened Fish

Steelhead, (Snake River Basin 

population)

Oncorhynchus (=Salmo) mykiss Threatened Fish

Steelhead, (South-Central California 

population)

Oncorhynchus (=Salmo) mykiss Threatened Fish

Steelhead, (Southern California 

population)

Oncorhynchus (=Salmo) mykiss Endangered Fish

Steelhead, (Upper Columbia River 

population)

Oncorhynchus (=Salmo) mykiss Threatened Fish

Steelhead, (Upper Columbia River 

population)

Oncorhynchus (=Salmo) mykiss Threatened Fish

Steelhead, (Upper Willamette River 

population)

Oncorhynchus (=Salmo) mykiss Threatened Fish

Steelhead, (Upper Willamette River 

population)

Oncorhynchus (=Salmo) mykiss Threatened Fish

Steelhead, Puget Sound Oncorhynchus mykiss Threatened Fish

Stenogyne angustifolia (ncn) Stenogyne angustifolia var. angustifolia Endangered Dicot

Stenogyne bifida (ncn) Stenogyne bifida Endangered Dicot

Stenogyne campanulata (ncn) Stenogyne campanulata Endangered Dicot

Stenogyne kanehoana (ncn) Stenogyne kanehoana Endangered Dicot

Stickleback, Unarmored Threespine Gasterosteus aculeatus williamsoni Endangered Fish

Stickseed, Showy Hackelia venusta Endangered Dicot

Stickyseed, Baker's Blennosperma bakeri Endangered Dicot

Stilt, Hawaiian (=Ae'o) Himantopus mexicanus knudseni Endangered Bird

Stirrupshell Quadrula stapes Endangered Bivalve

Stonecrop, Lake County Parvisedum leiocarpum Endangered Dicot

Stork, Wood Mycteria americana Endangered Bird

Stork, Wood Mycteria americana Endangered Bird

Stork, Wood Mycteria americana Endangered Bird

Stork, Wood Mycteria americana Endangered Bird

Stork, Wood Mycteria americana Endangered Bird

Stork, Wood Mycteria americana Endangered Bird
-Page 286 of 292- 

zhqSel_StateTaxa2

INVNAME SCINAME Status Taxa

Sturgeon, Alabama Scaphirhynchus suttkusi Endangered Fish

Sturgeon, green Acipenser medirostris Threatened Fish

Sturgeon, Gulf Acipenser oxyrinchus desotoi Threatened Fish

Sturgeon, Gulf Acipenser oxyrinchus desotoi Threatened Fish

Sturgeon, Gulf Acipenser oxyrinchus desotoi Threatened Fish

Sturgeon, Gulf Acipenser oxyrinchus desotoi Threatened Fish

Sturgeon, Gulf Acipenser oxyrinchus desotoi Threatened Fish

Sturgeon, Gulf Acipenser oxyrinchus desotoi Threatened Fish

Sturgeon, Pallid Scaphirhynchus albus Endangered Fish

Sturgeon, Pallid Scaphirhynchus albus Endangered Fish

Sturgeon, Pallid Scaphirhynchus albus Endangered Fish

Sturgeon, Pallid Scaphirhynchus albus Endangered Fish

Sturgeon, Pallid Scaphirhynchus albus Endangered Fish

Sturgeon, Pallid Scaphirhynchus albus Endangered Fish

Sturgeon, Pallid Scaphirhynchus albus Endangered Fish

Sturgeon, Pallid Scaphirhynchus albus Endangered Fish

Sturgeon, Pallid Scaphirhynchus albus Endangered Fish

Sturgeon, Pallid Scaphirhynchus albus Endangered Fish

Sturgeon, Pallid Scaphirhynchus albus Endangered Fish

Sturgeon, Pallid Scaphirhynchus albus Endangered Fish

Sturgeon, Pallid Scaphirhynchus albus Endangered Fish

Sturgeon, Shortnose Acipenser brevirostrum Endangered Fish

Sturgeon, Shortnose Acipenser brevirostrum Endangered Fish

Sturgeon, Shortnose Acipenser brevirostrum Endangered Fish

Sturgeon, Shortnose Acipenser brevirostrum Endangered Fish

Sturgeon, Shortnose Acipenser brevirostrum Endangered Fish

Sturgeon, Shortnose Acipenser brevirostrum Endangered Fish

Sturgeon, Shortnose Acipenser brevirostrum Endangered Fish

Sturgeon, Shortnose Acipenser brevirostrum Endangered Fish

Sturgeon, Shortnose Acipenser brevirostrum Endangered Fish

Sturgeon, Shortnose Acipenser brevirostrum Endangered Fish

Sturgeon, Shortnose Acipenser brevirostrum Endangered Fish

Sturgeon, Shortnose Acipenser brevirostrum Endangered Fish

Sturgeon, Shortnose Acipenser brevirostrum Endangered Fish

Sturgeon, White Acipenser transmontanus Endangered Fish

Sturgeon, White Acipenser transmontanus Endangered Fish

Sucker, June Chasmistes liorus Endangered Fish

Sucker, Lost River Deltistes luxatus Endangered Fish

Sucker, Lost River Deltistes luxatus Endangered Fish

Sucker, Modoc Catostomus microps Endangered Fish

Sucker, Razorback Xyrauchen texanus Endangered Fish

Sucker, Razorback Xyrauchen texanus Endangered Fish

Sucker, Razorback Xyrauchen texanus Endangered Fish

Sucker, Razorback Xyrauchen texanus Endangered Fish

Sucker, Razorback Xyrauchen texanus Endangered Fish

Sucker, Razorback Xyrauchen texanus Endangered Fish
-Page 287 of 292- 

zhqSel_StateTaxa2

INVNAME SCINAME Status Taxa

Sucker, Santa Ana Catostomus santaanae Threatened Fish

Sucker, Shortnose Chasmistes brevirostris Endangered Fish

Sucker, Shortnose Chasmistes brevirostris Endangered Fish

Sucker, Warner Catostomus warnerensis Threatened Fish

Sucker, Warner Catostomus warnerensis Threatened Fish

Sumac, Michaux's Rhus michauxii Endangered Dicot

Sumac, Michaux's Rhus michauxii Endangered Dicot

Sumac, Michaux's Rhus michauxii Endangered Dicot

Sunflower, Pecos Helianthus paradoxus Threatened Dicot

Sunflower, Pecos Helianthus paradoxus Threatened Dicot

Sunflower, San Mateo Woolly Eriophyllum latilobum Endangered Dicot

Sunflower, Schweinitz's Helianthus schweinitzii Endangered Dicot

Sunflower, Schweinitz's Helianthus schweinitzii Endangered Dicot

Sunflower, Schweinitz's Helianthus schweinitzii Endangered Dicot

Sunray, Ash Meadows Enceliopsis nudicaulis var. corrugata Threatened Dicot

Tadpole Shrimp, Vernal Pool Lepidurus packardi Endangered Crustacean

Taraxacum, California Taraxacum californicum Endangered Dicot

Tarplant, Gaviota Deinandra increscens ssp. villosa Endangered Dicot

Tarplant, Otay Deinandra (=Hemizonia) conjugens Threatened Dicot

Tarplant, Santa Cruz Holocarpha macradenia Threatened Dicot

Tectaria Estremerana Tectaria estremerana Endangered Ferns

Tern, California Least Sterna antillarum browni Endangered Bird

Tern, California Least Sterna antillarum browni Endangered Bird

Tern, Interior (population) Least Sterna antillarum Endangered Bird

Tern, Interior (population) Least Sterna antillarum Endangered Bird

Tern, Interior (population) Least Sterna antillarum Endangered Bird

Tern, Interior (population) Least Sterna antillarum Endangered Bird

Tern, Interior (population) Least Sterna antillarum Endangered Bird

Tern, Interior (population) Least Sterna antillarum Endangered Bird

Tern, Interior (population) Least Sterna antillarum Endangered Bird

Tern, Interior (population) Least Sterna antillarum Endangered Bird

Tern, Interior (population) Least Sterna antillarum Endangered Bird

Tern, Interior (population) Least Sterna antillarum Endangered Bird

Tern, Interior (population) Least Sterna antillarum Endangered Bird

Tern, Interior (population) Least Sterna antillarum Endangered Bird

Tern, Interior (population) Least Sterna antillarum Endangered Bird

Tern, Interior (population) Least Sterna antillarum Endangered Bird

Tern, Interior (population) Least Sterna antillarum Endangered Bird

Tern, Interior (population) Least Sterna antillarum Endangered Bird

Tern, Interior (population) Least Sterna antillarum Endangered Bird

Tern, Roseate Sterna dougallii dougallii Endangered Bird

Tern, Roseate Sterna dougallii dougallii Endangered Bird

Tern, Roseate Sterna dougallii dougallii Endangered Bird

Tern, Roseate Sterna dougallii dougallii Endangered Bird

Tern, Roseate Sterna dougallii dougallii Endangered Bird

Tern, Roseate Sterna dougallii dougallii Endangered Bird
-Page 288 of 292- 

zhqSel_StateTaxa2

INVNAME SCINAME Status Taxa

Tern, Roseate Sterna dougallii dougallii Endangered Bird

Ternstroemia subsessilis (ncn) Ternstroemia subsessilis Endangered Dicot

Tetramolopium arenarium (ncn) Tetramolopium arenarium Endangered Dicot

Tetramolopium capillare (ncn) Tetramolopium capillare Endangered Dicot

Tetramolopium filiforme (ncn) Tetramolopium filiforme Endangered Dicot

Tetramolopium lepidotum ssp. lepidotum 

(ncn)

Tetramolopium lepidotum ssp. lepidotum Endangered Dicot

Tetramolopium remyi (ncn) Tetramolopium remyi Endangered Dicot

Tetramolopium rockii (ncn) Tetramolopium rockii Threatened Dicot

Thelypody, Howell's Spectacular Thelypodium howellii spectabilis Threatened Dicot

Thistle, Chorro creek Bog Cirsium fontinale var. obispoense Endangered Dicot

Thistle, Fountain Cirsium fontinale var. fontinale Endangered Dicot

Thistle, La Graciosa Cirsium loncholepis Endangered Dicot

Thistle, Pitcher's Cirsium pitcheri Threatened Dicot

Thistle, Pitcher's Cirsium pitcheri Threatened Dicot

Thistle, Pitcher's Cirsium pitcheri Threatened Dicot

Thistle, Pitcher's Cirsium pitcheri Threatened Dicot

Thistle, Sacramento Mountains Cirsium vinaceum Threatened Dicot

Thistle, Suisun Cirsium hydrophilum var. hydrophilum Endangered Dicot

Thornmint, San Diego Acanthomintha ilicifolia Threatened Dicot

Thornmint, San Mateo Acanthomintha obovata ssp. duttonii Endangered Dicot

Threeridge, Fat (Mussel) Amblema neislerii Endangered Bivalve

Threeridge, Fat (Mussel) Amblema neislerii Endangered Bivalve

Thrush, Large Kauai Myadestes myadestinus Endangered Bird

Thrush, Molokai (Oloma'o) Myadestes lanaiensis rutha Endangered Bird

Thrush, Small Kauai (Puaiohi) Myadestes palmeri Endangered Bird

Toad, Arroyo Southwestern Bufo californicus (=microscaphus) Endangered Amphibian

Toad, Houston Bufo houstonensis Endangered Amphibian

Toad, Puerto Rican Crested Peltophryne lemur Threatened Amphibian

Toad, Wyoming Bufo baxteri (=hemiophrys) Endangered Amphibian

Topminnow, Gila (Yaqui) Poeciliopsis occidentalis Endangered Fish

Topminnow, Gila (Yaqui) Poeciliopsis occidentalis Endangered Fish

Torreya, Florida Torreya taxifolia Endangered Conf/cycds

Torreya, Florida Torreya taxifolia Endangered Conf/cycds

Tortoise, Desert Gopherus agassizii Threatened Reptile

Tortoise, Desert Gopherus agassizii Threatened Reptile

Tortoise, Desert Gopherus agassizii Threatened Reptile

Tortoise, Desert Gopherus agassizii Threatened Reptile

Tortoise, Gopher Gopherus polyphemus Threatened Reptile

Tortoise, Gopher Gopherus polyphemus Threatened Reptile

Tortoise, Gopher Gopherus polyphemus Threatened Reptile

Towhee, Inyo Brown Pipilo crissalis eremophilus Threatened Bird

Townsendia, Last Chance Townsendia aprica Threatened Dicot

Tree Fern, Elfin Cyathea dryopteroides Endangered Ferns

Trematolobelia singularis (ncn) Trematolobelia singularis Endangered Dicot

Trillium, Persistent Trillium persistens Endangered Monocot
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zhqSel_StateTaxa2

INVNAME SCINAME Status Taxa

Trillium, Persistent Trillium persistens Endangered Monocot

Trillium, Relict Trillium reliquum Endangered Monocot

Trillium, Relict Trillium reliquum Endangered Monocot

Trillium, Relict Trillium reliquum Endangered Monocot

Trout, Apache Oncorhynchus apache Threatened Fish

Trout, Bull Salvelinus confluentus Threatened Fish

Trout, Bull Salvelinus confluentus Threatened Fish

Trout, Bull Salvelinus confluentus Threatened Fish

Trout, Bull Salvelinus confluentus Threatened Fish

Trout, Bull Salvelinus confluentus Threatened Fish

Trout, Bull Salvelinus confluentus Threatened Fish

Trout, Bull (Columbia River population) Salvelinus confluentus Threatened Fish

Trout, Bull (Columbia River population) Salvelinus confluentus Threatened Fish

Trout, Bull (Columbia River population) Salvelinus confluentus Threatened Fish

Trout, Bull (Columbia River population) Salvelinus confluentus Threatened Fish

Trout, Bull (Klamath River population) Salvelinus confluentus Threatened Fish

Trout, Bull (Klamath River population) Salvelinus confluentus Threatened Fish

Trout, Bull (Klamath River population) Salvelinus confluentus Threatened Fish

Trout, Bull (Klamath River population) Salvelinus confluentus Threatened Fish

Trout, Gila Oncorhynchus gilae Endangered Fish

Trout, Gila Oncorhynchus gilae Endangered Fish

Trout, Greenback Cutthroat Oncorhynchus clarki stomias Threatened Fish

Trout, Lahontan Cutthroat Oncorhynchus clarki henshawi Threatened Fish

Trout, Lahontan Cutthroat Oncorhynchus clarki henshawi Threatened Fish

Trout, Lahontan Cutthroat Oncorhynchus clarki henshawi Threatened Fish

Trout, Lahontan Cutthroat Oncorhynchus clarki henshawi Threatened Fish

Trout, Little Kern Golden Oncorhynchus aguabonita whitei Threatened Fish

Trout, Paiute Cutthroat Oncorhynchus clarki seleniris Threatened Fish

Tuctoria, Green's Tuctoria greenei Endangered Dicot

Turtle, Alabama Red-bellied Pseudemys alabamensis Endangered Reptile

Turtle, Bog (Northern population) Clemmys muhlenbergii Threatened Reptile

Turtle, Bog (Northern population) Clemmys muhlenbergii Threatened Reptile

Turtle, Bog (Northern population) Clemmys muhlenbergii Threatened Reptile

Turtle, Bog (Northern population) Clemmys muhlenbergii Threatened Reptile

Turtle, Bog (Northern population) Clemmys muhlenbergii Threatened Reptile

Turtle, Bog (Northern population) Clemmys muhlenbergii Threatened Reptile

Turtle, Bog (Northern population) Clemmys muhlenbergii Threatened Reptile

Turtle, Flattened Musk Sternotherus depressus Threatened Reptile

Turtle, Plymouth Red-bellied Pseudemys rubriventris bangsi Endangered Reptile

Turtle, Ringed Sawback Graptemys oculifera Threatened Reptile

Turtle, Ringed Sawback Graptemys oculifera Threatened Reptile

Turtle, Yellow-blotched Map Graptemys flavimaculata Threatened Reptile

Twinpod, Dudley Bluffs Physaria obcordata Threatened Dicot

Uhiuhi (Caesalpinia kavaiensis) Caesalpinia kavaiense Endangered Dicot

Ulihi (Phyllostegia glabra var. lanaiensis) Phyllostegia glabra var. lanaiensis Endangered Dicot

Umbel, Huachuca Water Lilaeopsis schaffneriana var. recurva Endangered Dicot
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zhqSel_StateTaxa2

INVNAME SCINAME Status Taxa

Uvillo Eugenia haematocarpa Endangered Dicot

Vernonia Proctorii (ncn) Vernonia proctorii Endangered Dicot

Vervain, California Verbena californica Threatened Dicot

Vetch, Hawaiian (Vicia menziesii) Vicia menziesii Endangered Dicot

Vigna o-wahuensis (ncn) Vigna o-wahuensis Endangered Dicot

Viola helenae (ncn) Viola helenae Endangered Dicot

Viola lanaiensis (ncn) Viola lanaiensis Endangered Dicot

Viola oahuensis (ncn) Viola oahuensis Endangered Dicot

Vireo, Black-capped Vireo atricapilla Endangered Bird

Vireo, Black-capped Vireo atricapilla Endangered Bird

Vireo, Least Bell's Vireo bellii pusillus Endangered Bird

Vole, Amargosa Microtus californicus scirpensis Endangered Mammal

Vole, Florida Salt Marsh Microtus pennsylvanicus dukecampbelli Endangered Mammal

Vole, Hualapai Mexican Microtus mexicanus hualpaiensis Endangered Mammal

Wahane (Pritchardia aylmer-robinsonii) Pritchardia aylmer-robinsonii Endangered Monocot

Wahine Noho Kula (Isodendrion 

pyrifolium)

Isodendrion pyrifolium Endangered Dicot

Wallflower, Ben Lomond Erysimum teretifolium Endangered Dicot

Wallflower, Contra Costa Erysimum capitatum var. angustatum Endangered Dicot

Wallflower, Menzie's Erysimum menziesii Endangered Dicot

Walnut, Nogal Juglans jamaicensis Endangered Dicot

Warbler (=Wood), Golden-cheeked Dendroica chrysoparia Endangered Bird

Warbler (=Wood), Kirtland's Dendroica kirtlandii Endangered Bird

Warbler (=Wood), Kirtland's Dendroica kirtlandii Endangered Bird

Warbler (=Wood), Kirtland's Dendroica kirtlandii Endangered Bird

Warbler (=Wood), Kirtland's Dendroica kirtlandii Endangered Bird

Warbler, Bachman's Vermivora bachmanii Endangered Bird

Warbler, Bachman's Vermivora bachmanii Endangered Bird

Warea, Wide-leaf Warea amplexifolia Endangered Dicot

Watercress, Gambel's Rorippa gambellii Endangered Dicot

Water-plantain, Kral's Sagittaria secundifolia Threatened Monocot

Water-plantain, Kral's Sagittaria secundifolia Threatened Monocot

Water-willow, Cooley's Justicia cooleyi Endangered Dicot

Wawae'Iole (Phlegmariurus (=Huperzia) 

mannii)

Huperzia mannii Endangered Ferns

Wawae'Iole (Phlegmariurus 

(=Lycopodium) nutans)

Lycopodium (=Phlegmariurus) nutans Endangered Ferns

Whale, Finback Balaenoptera physalus Endangered Marine mml

Whale, Finback Balaenoptera physalus Endangered Marine mml

Whale, Finback Balaenoptera physalus Endangered Marine mml

Whale, Finback Balaenoptera physalus Endangered Marine mml

Whale, Finback Balaenoptera physalus Endangered Marine mml

Whale, Finback Balaenoptera physalus Endangered Marine mml

Whale, Finback Balaenoptera physalus Endangered Marine mml

Whale, Finback Balaenoptera physalus Endangered Marine mml

Whale, Finback Balaenoptera physalus Endangered Marine mml
-Page 291 of 292- 

zhqSel_StateTaxa2

INVNAME SCINAME Status Taxa

Whale, Finback Balaenoptera physalus Endangered Marine mml

Whale, Finback Balaenoptera physalus Endangered Marine mml

Whale, Finback Balaenoptera physalus Endangered Marine mml

Whale, Finback Balaenoptera physalus Endangered Marine mml

Whale, Finback Balaenoptera physalus Endangered Marine mml

Whale, Finback Balaenoptera physalus Endangered Marine mml

Whale, Finback Balaenoptera physalus Endangered Marine mml

Whale, Finback Balaenoptera physalus Endangered Marine mml

Whale, Finback Balaenoptera physalus Endangered Marine mml

Whale, Finback Balaenoptera physalus Endangered Marine mml

Whale, Finback Balaenoptera physalus Endangered Marine mml

Whale, Humpback Megaptera novaeangliae Endangered Marine mml

Whale, Humpback Megaptera novaeangliae Endangered Marine mml

Whale, Humpback Megaptera novaeangliae Endangered Marine mml

Whale, Humpback Megaptera novaeangliae Endangered Marine mml

Whale, Humpback Megaptera novaeangliae Endangered Marine mml

Whale, Humpback Megaptera novaeangliae Endangered Marine mml

Whale, Humpback Megaptera novaeangliae Endangered Marine mml

Whale, Humpback Megaptera novaeangliae Endangered Marine mml

Whale, Humpback Megaptera novaeangliae Endangered Marine mml

Whale, Humpback Megaptera novaeangliae Endangered Marine mml

Whale, Humpback Megaptera novaeangliae Endangered Marine mml

Whale, Humpback Megaptera novaeangliae Endangered Marine mml

Whale, Humpback Megaptera novaeangliae Endangered Marine mml

Whale, Humpback Megaptera novaeangliae Endangered Marine mml

Whale, Humpback Megaptera novaeangliae Endangered Marine mml

Whale, Humpback Megaptera novaeangliae Endangered Marine mml

Whale, Humpback Megaptera novaeangliae Endangered Marine mml

Whale, Humpback Megaptera novaeangliae Endangered Marine mml

Whale, Humpback Megaptera novaeangliae Endangered Marine mml

Whale, Humpback Megaptera novaeangliae Endangered Marine mml

Whale, northern right Eubalaena glacialis (incl. australis) Endangered Marine mml

Whale, northern right Eubalaena glacialis (incl. australis) Endangered Marine mml

Whale, northern right Eubalaena glacialis (incl. australis) Endangered Marine mml

Whale, northern right Eubalaena glacialis (incl. australis) Endangered Marine mml

Whale, northern right Eubalaena glacialis (incl. australis) Endangered Marine mml

Whale, northern right Eubalaena glacialis (incl. australis) Endangered Marine mml

Whale, northern right Eubalaena glacialis (incl. australis) Endangered Marine mml

Whale, northern right Eubalaena glacialis (incl. australis) Endangered Marine mml

Whale, northern right Eubalaena glacialis (incl. australis) Endangered Marine mml

Whale, northern right Eubalaena glacialis (incl. australis) Endangered Marine mml

Whale, northern right Eubalaena glacialis (incl. australis) Endangered Marine mml

Whale, northern right Eubalaena glacialis (incl. australis) Endangered Marine mml

Whale, northern right Eubalaena glacialis (incl. australis) Endangered Marine mml

Whipsnake (=Striped Racer), Alameda Masticophis lateralis euryxanthus Threatened Reptile

Whitlow-wort, Papery Paronychia chartacea Threatened Dicot
-Page 292 of 292- 

zhqSel_StateTaxa2

INVNAME SCINAME Status Taxa

Wild-buckwheat, Clay-loving Eriogonum pelinophilum Endangered Dicot

Wild-buckwheat, Gypsum Eriogonum gypsophilum Threatened Dicot

Wild-buckwheat, Gypsum Eriogonum gypsophilum Threatened Dicot

Wild-rice, Texas Zizania texana Endangered Monocot

Wings, Pigeon Clitoria fragrans Threatened Dicot

Wire-lettuce, Malheur Stephanomeria malheurensis Endangered Dicot

Wireweed Polygonella basiramia Endangered Dicot

Woodland-star, San Clemente Island Lithophragma maximum Endangered Dicot

Woodpecker, Ivory-billed Campephilus principalis Endangered Bird

Woodpecker, Red-cockaded Picoides borealis Endangered Bird

Woodpecker, Red-cockaded Picoides borealis Endangered Bird

Woodpecker, Red-cockaded Picoides borealis Endangered Bird

Woodpecker, Red-cockaded Picoides borealis Endangered Bird

Woodpecker, Red-cockaded Picoides borealis Endangered Bird

Woodpecker, Red-cockaded Picoides borealis Endangered Bird

Woodpecker, Red-cockaded Picoides borealis Endangered Bird

Woodpecker, Red-cockaded Picoides borealis Endangered Bird

Woodpecker, Red-cockaded Picoides borealis Endangered Bird

Woodpecker, Red-cockaded Picoides borealis Endangered Bird

Woodpecker, Red-cockaded Picoides borealis Endangered Bird

Woodpecker, Red-cockaded Picoides borealis Endangered Bird

Woodpecker, Red-cockaded Picoides borealis Endangered Bird

Woodrat, Key Largo Neotoma floridana smalli Endangered Mammal

Woodrat, Riparian Neotoma fuscipes riparia Endangered Mammal

Woolly-star, Santa Ana River Eriastrum densifolium ssp. sanctorum Endangered Dicot

Woolly-threads, San Joaquin Monolopia (=Lembertia) congdonii Endangered Dicot

Woundfin Plagopterus argentissimus Endangered Fish

Woundfin Plagopterus argentissimus Endangered Fish

Woundfin Plagopterus argentissimus Endangered Fish

Xylosma crenatum (ncn) Xylosma crenatum Endangered Dicot

Yellowhead, Desert Yermo xanthocephalus Threatened Dicot

Yerba Santa, Lompoc Eriodictyon capitatum Endangered Dicot

Ziziphus, Florida Ziziphus celata Endangered Dicot