UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON D.C., 20460 

PC CODE: 129112 

DP BARCODE: 405629 

DATE: March 18, 2013 

MEMORANDUM 

SUBJECT: Registration Review -Preliminary Problem Formulation for the Ecological 

Risk Assessment in Support of Registration Review for Trifloxystrobin 

TO: Moana Appleyard, Chemical Review Manager 

Linda Arrington, Acting Branch Chief 

Risk Management and Implementation Branch 5 

Pesticide Re-evaluation Division ~ 

FROM: Nick Mastrota, Ph.D., Wildlife Biologist ~ • 

THROUGH: Dana Spatz, Branch C . _ 

Rosanna Louie-Juzwiak, RAP 

Melissa Panger, Ph.D., Senior Sctentist ( 

James Hetrick, Ph.D., Senior Adviso\.._.)~ 

Environmental Risk Branch 3 

Environmental Fate and Effects Division (7507P) 

EFED has completed the Problem Formulation for the Registration Review oftrifloxystrobin. 

This document provides the Division's plan for assessing ecological risks and drinking water 

exposure for all registered uses oftrifloxystrobin. It also summarizes outstanding data 

requirements for these assessments. 

• Page I of60 
 Page 2 of 58 

 

Problem Formulation for the 

Ecological Risk Assessment in Support of the 

Registration Review of Trifloxystrobin

Trifloxystrobin 

Prepared by: 

James K. Wolf, Ph.D., Environmental Scientist 

Nicholas Mastrota, Wildlife Biologist 

Reviewed by: 

Melissa Panger, Ph.D., Senior Biologist 

James Hetrick, Ph.D., Senior Advisor 

Rosanna Louie-Juzwiak, RAPL 

Approved by: 

Dana Spatz, Branch Chief 

Environmental Risk Branch III 

Environmental Fate and Effects Division 

 
 Page 3 of 58 

1.0 Introduction 

The purpose of this problem formulation is to provide EFED’s current understanding of the 

environmental fate and ecological effects of the registered uses of trifloxystrobin [E,E)-alpha-

(methoxyimino)-2-[[[[1-[3-(trifluoromethyl) phenyl] ethylidene]amino]oxy]methyl]-methyl 

ester]. This document provides a plan for analyzing data relevant to trifloxystrobin and for 

assessing potential risk to non-target organisms, including Federally-listed endangered/threatened 

species (hereafter referred to as “listed” species), and potential exposure in drinking water for the 

human health risk assessment. 

Trifloxystrobin is an active ingredient used in numerous agricultural fungicide products used to 

control fungal pathogens on various grain, vegetable, fruit, nut crops, ornamental plants, and turf. 

It is classified as an oximinoacetate fungicide in the strobilurin class. It inhibits spore 

germination and mycelial growth by disrupting microbial respiration. The end-use products are 

formulated with 7.2 to 50% active ingredients, and are often co-formulated with other fungicidal 

active ingredients, such as fluopyram, metalaxyl, propiconazole, prothioconazole, tebuconazole, 

and triademenol. 

Additionally, this problem formulation is intended to identify data gaps, uncertainties, and 

potential assumptions used to address those uncertainties, relative to characterizing the ecological 

risk associated with the registered uses of trifloxystrobin. 

2.0 Description of Regulatory Action 

The Food Quality Protection Act of 1996 mandated the Environmental Protection Agency (EPA) 

to implement a new program for assessing the risks of pesticides, i.e., Registration Review 

(http://www.epa.gov/oppsrrd1/registration_review/). As part of the implementation of the 

Registration Review program pursuant to Section 3(g) of the Federal Insecticide, Fungicide and 

Rodenticide Act (FIFRA), EPA is beginning its evaluation to determine whether trifloxystrobin 

continues to meet the FIFRA standard for registration. 

3.0 Mechanism of Action 

Trifloxystrobin is a broad spectrum foliar fungicide that is currently used to control certain 

diseases in crops and ornamental plants. It also provides both curative and protective properties 

against a variety of pathogens in a variety of crops. Trifloxystrobin is classified as an 

oximinoacetate fungicide in the strobilurin (sterol inhibitors) class. It belongs to the Qol (Group 

11) target site of action group and acts by interfering with respiration in plant pathogenic fungi 

and is a potent inhibitor of spore germination and mycelial growth. The fungicidal properties of 

trifloxystrobin are derived from the parent ester, and the acid (the main metabolite) is essentially 

inactive. It exhibits no known cross-resistance to other chemical classes including 

anilinopyrimidines (AP). 
 Page 4 of 58 

4.0 Use Characterization 

Trifloxystrobin is used to protect agricultural crops, lawns, and ornamental plants from fungal 

pathogens. It is registered for use on various agricultural crops, including grains, beans, 

vegetables, fruits, and nuts. It is applied to these crops as a foliar spray using ground sprayer, air 

blast sprayer, aircraft, or irrigation systems (chemigation). For crops started as transplants, it also 

may be applied with a drench treatment. Multiple applications may be made during a growing 

season. Trifloxystrobin is also registered for use as a foliar spray on turf and ornamental plants. 

Turf and ornamental plant uses may be at residential, municipal, or commercial use sites, 

including golf courses, or on agricultural use sites, such as sod farms and nurseries. Application 

to turf and ornamentals may be made using aircraft, ground equipment, or hand-held sprayers. 

Trifloxystrobin is also registered for treatment of ornamental plants grown in greenhouses. 

Finally, trifloxystrobin is registered for use as a seed treatment for numerous agricultural crops, 

ornamental plants, and turf grasses. 

Detailed information on application sites, application rates, and use restrictions for outdoor foliar 

uses are given in Table 1. Similar crops with similar use restrictions are grouped and will be 

assessed together. 

 
 Page 5 of 58 

Table 1. Use Sites and Application Information for Foliar Applications of Trifloxystrobin

Site Description 

Active 

Ingredient 

Maximum 

Application 

Rate 

Active 

Ingredient 

Maximum 

Seasonal 

Rate1 

Max. 

Apps/ 

Crop 

Cycle2 

Min. 

Retreat 

Interval 

(days) 

Application 

Methods Restrictions 

Artichoke 0.125 0.25 (2) 7 Aircraft, Ground 

Sprayer 

Asparagus 0.125 0.375 (3) 14 Aircraft, Ground 

Sprayer 

Barley 

0.056 0.056 (1) NS 

Aircraft, Ground 

Sprayer, 

Chemigation 

0.056 0.113 (2) 14 

Aircraft, Ground 

Sprayer, 

Chemigation 

Chervil 0.094 0.375 (4) 14 Aircraft, Ground 

Sprayer 

Christmas Tree Plantation 0.047 1.08 (23) 14 Aircraft, Ground 

Sprayer 

Clover 0.0625 NS NS NS Ground Sprayer OR only 

Corn, Field and Pop 0.122 0.244 2 7 

Aircraft, Ground 

Sprayer, 

Chemigation 

Corn, Sweet 0.122 0.489 4 5 

Aircraft, Ground 

Sprayer, 

Chemigation 

Cucurbit vegetables 

(melons, cucumber, gourds, 

pumpkin, squash, 

watermelon, etc.) 

0.125 0.50 (4) 7 Aircraft, Ground 

Sprayer 

0.125 0.445 4 (3.6) 7 Ground Sprayer, 

Chemigation 

Chickory 0.094 0.375 (4) 14 Aircraft, Ground 

Sprayer 

Fruiting vegetables 

(eggplant, peppers, tomato, 

etc) 

0.125 0.50 (4) 7 Aircraft, Ground 

Sprayer 

0.038 0.191 5 7 

Aircraft, Ground 

Sprayer, 

Chemigation 

Fruit Trees, Citrus 0.125 0.50 4 7 Aircraft, Ground 

Sprayer 

Fruit Trees, Pome (apple, 

crabapple, loquat, pear, 

mayhaw, and quince) 

0.094 0.344 4 (3 2/3) 7 

Aircraft, Ground 

Sprayer, 

Chemigation 

0.054 0.218 4 7 Aircraft, Ground 

Sprayer Chemigation 

Fruit Trees, Stone (apricot, 

cherry, peach, plum, prune, 

nectarine) 

0.125 0.50 4 7 Aircraft, Ground 

Sprayer 

0.10 0.30 4 (3) 7 

Aircraft, Ground 

Sprayer, 

Chemigation 

0.092 0.183 (2) 7 

Aircraft, Ground 

Sprayer, 

Chemigation 

Fruit Trees, Tropical and 

Subtropical (mango, papaya, 

etc.) 

0.125 (0.50) 4 7 

Aircraft, Ground 

Sprayer, 

Chemigation 

Grape 

0.125 0.75 6 7 Aircraft, Ground 

Sprayer 

0.10 0.20 4(2) 14 

Aircraft, Ground 

Sprayer, 

Chemigation 

0.125 0.445 6 (3.6) 12 

Aircraft, Ground 

Sprayer, 

Chemigation 
 Page 6 of 58 

Grasses grown for seed 

0.131 0.545 (4.16) NS Aircraft, Ground 

Sprayer 

0.125 0.25 /yr (2) 21 Aircraft, Ground 

Sprayer 

Hops 0.125 0.50 4 10 Ground Sprayer Not CA 

Leafy petiole vegetables 

(cardoon, celery, Chinese 

celery, Florence fennel, 

rhubarb, Swiss chard) 

0.094 0.375 (4) 14 

Aircraft, Ground 

Sprayer, 

Chemigation 

Nuts, Almond 

0.125 0.50 4 7-10 

Aircraft, Ground 

Sprayer, 

Chemigation 

0.125 0.375 3 7 

Aircraft, Ground 

Sprayer, 

Chemigation 

Nuts, Pecan 

0.131 0.785 (3) 7-14 

Aircraft, Ground 

Sprayer, 

Chemigation 

0.125 0.50 (4) 7 Aircraft, Ground 

Sprayer 

0.125 0.75 3 (6) 14 Aircraft, Ground 

Sprayer 

0.125 0.444 6 (3.6) 14 

Aircraft, Ground 

Sprayer, 

Chemigation 

0.081 0.243 3 14 

Nuts, Pistachio 

0.125 0.375 4 (3) 14 

Aircraft, Ground 

Sprayer, 

Chemigation 

0.10 0.30 4(3) 7 

Aircraft, Ground 

Sprayer, 

Chemigation 

Nuts, other (beechnut, Brazil 

nut, butternut, cashew, 

chestnut, chinquapin, filbert, 

hickory nut, macadamia, 

walnut) 

0.125 0.50 4 7 

Aircraft, Ground 

Sprayer, 

Chemigation 

0.125 0.25 2 14 Aircraft, Ground 

Sprayer 

Oat 0.057 0.113 2 14 

Aircraft, Ground 

Sprayer, 

Chemigation 

Ornamental Plants, Woody 

and Herbaceous 

0.0075 oz/g to 

the point of 

drip 

1.08 NS 14 

Aircraft, Ground 

Sprayer, Hand-Held 

or Backpack Sprayer 

0.02 oz/g to 

the point of 

drip 

1.08 NS 7 Aircraft, Ground 

Sprayer 

0.00016 lb/g 3.75 NS 21 Ground Sprayer, 

Drench 

Plants in 

containers 

only, not in 

CA 

Peanuts 

0.12 (0.48) 4 10 

Aircraft, Ground 

Sprayer, 

Chemigation 

0.11 0.44 4 10 

Aircraft, Ground 

Sprayer, 

Chemigation 

0.11 (0.66) 6 10 

Aircraft, Ground 

Sprayer, 

(Chemigation?) 

Potato 0.125 0.75 6 7 

Aircraft, Ground 

Sprayer, 

Chemigation 

Rice 0.15 0.30 2 NS or 14 Aircraft, Ground 

Sprayer 
 Page 7 of 58 

Root vegetables (beet, 

carrot, ginseng, parsnip, 

radish, rutabaga, turnip, etc.) 

0.094 0.375 (4) 14 

Aircraft, Ground 

Sprayer, 

Chemigation 

0.125 0.25 (4) 7 Aircraft, Ground 

Sprayer 

Strawberry 0.10 0.60 (6) 7 

Aircraft, Ground 

Sprayer, 

Chemigation 

Sugar beet 0.11 0.33 3 10 

Aircraft, Ground 

Sprayer, 

Chemigation 

Soybean 0.11 0.31 (3) 10 

Aircraft, Ground 

Sprayer, 

Chemigation 

Turf, Residential, 

Commercial, or Industrial 0.340 1.08 (3) 14 

Aircraft, Ground 

Sprayer, Hand-held 

or Backpack Sprayer 

Turf, Golf Course 

0.340 1.08 (3) 14 

Aircraft, Ground 

Sprayer, Hand-held 

or Backpack Sprayer 

0.31 1.33 6 (4.3) 14 

Ground Sprayer, 

Hand-held or 

Backpack Sprayer 

Triticale 0.081 (0.162) 2 14 

Aircraft, Ground 

Sprayer, 

Chemigation 

Wheat and triticale 

0.085 0.085 (1) NS 

Aircraft, Ground 

Sprayer, 

Chemigation 

0.11 0.22 (2) 14 Aircraft, Ground 

Sprayer 

0.081 (0.162) 2 14 

Aircraft, Ground 

Sprayer, 

Chemigation 

0.098 NS NS 14 Aircraft, Ground 

Sprayer 

1 Numbers given in parentheses are maximum per-season rates calculated by multiplying the maximum per application rate by the maximum 

number of applications allowed per season. 

2 Numbers given in parentheses represent the number of applications that can be made at the maximum per-application rate to reach the 

maximum per-season rate. The number not in parentheses is the maximum number of applications (at any rate) that are allowed by the label. 

Application rates for seed treatments are given in terms of weight of trifloxystrobin applied to 

weight of seed. Application rates range from 0.001 to 0.01 pound active ingredient (a.i.) per 

pound of seed. EFED will estimate upper bound application rates in terms of pounds a.i. per acre 

treated by multiplying these pounds-per-seed rates by maximum expected seed planting rates 

(seeds per acre), which is specific for each crop. Use information provided on the labels for 

trifloxystrobin seed treatment is given in Table 2. 

 
 Page 8 of 58 

Table 2. Application Information for Seed Treatment Uses of Trifloxystrobin

Seed Type Maximum Application Rate 

(lb a.i./lb seed) 

Maximum Seasonal Rate 

(lb a.i./lb seed)1 

Max. Apps/ 

Year 

Alfalfa 0.0050 0.005 1 

Barley 0.0050 (0.015) 3 

Canola 0.010 (0.30) 3 or NS 

Conifers 0.010 NS NS 

Cotton 0.010 NS 3 or NS 

Cucurbit Vegetables 0.010 NS NS 

Fruiting Vegetables 0.010 NS NS 

Legume Vegetables 

(Beans, lentils, and peas) 

0.0050 NS NS 

0.0050 (0.015) 3 

Lupine, grain 0.0050 NS NS 

Mustard 

0.010 NS NS 

0.010 (0.030) 3 

Potato 0.010 NS NS 

Sorghum 

0.010 NS NS 

0.005 (0.015) 3 

Sugarbeet 0.010 NS NS 

Wheat and Triticale 

0.01 NS NS 

0.005 (0.015) 3 

1 Numbers given in parentheses represent the number of applications that can be made at the maximum per-application rate to reach the 

maximum per-season rate. The number not in parentheses is the maximum number of applications (at any rate) that are allowed by the label. 

For selected major crops, the maximum seed treatment rate (lb a.i./lb seed) have been converted 

to a maximum application rate expressed in terms of pounds of a.i. applied per acre. This is done 

by multiplying the maximum seed treatment rate by the maximum expected seeding rate (lb 

seed/A) for that crop (Table 3). The typical range of seeding rates, given in Table 3, were 

provided to EFED by the Biological and Economic Analysis Division (BEAD) and are available 

in the seed-treatment worksheet of the T-REX model. A screening-level risk assessment will be 

conducted based on the maximum predicted seeding rates. 

Table 3. Maximum Application Rates for Seed Treatments Expressed as Pounds a.i. per Acre 

Seed Description 

Max. Seed 

Treatment Rate 

(lb a.i./lb seed) 

Min. Seeding 

Rate (lb/A) 

Max. Seed Rate 

(lb/A) 

Max. Appl. Rate 

(lb a.i./A) 

Alfalfa 0.15 75.00 90.00 13.50 

Barley 0.005 8.00 138.30 0.69 

Beans (Unspecified) 0.005 20.00 213.53 1.07 

Beans, Dried 0.005 32.02 140.01 0.70 

Beans, Lima 0.005 32.02 163.35 0.82 

Beans, Green 0.005 20.00 213.53 1.07 

Canola 0.01 3.79 30.63 0.31 

Corn (Unspecified) 0.0025 2.90 33.19 0.08 

Corn, Field 0.01 16.50 27.04 0.27 

Corn, Pop 0.01 5.04 27.04 0.27 

Corn, Sweet 0.01 2.90 33.19 0.33 

Cotton 0.01 6.44 150.00 1.50 

Cucurbit Vegetables 0.01 0.04 11.62 0.12 
 Page 9 of 58 

Seed Description 

Max. Seed 

Treatment Rate 

(lb a.i./lb seed) 

Min. Seeding 

Rate (lb/A) 

Max. Seed Rate 

(lb/A) 

Max. Appl. Rate 

(lb a.i./A) 

Fruiting Vegetables 0.01 0.08 170.00 1.70 

Mustard 0.01 0.31 6.00 0.06 

Ornamental Lawns and Turf 0.01 2.00 25.00 0.25 

Peanuts 0.01 6.22 228.26 2.28 

Peas (Unspecified) 0.005 4.23 411.00 2.06 

Peas, Field 0.005 4.23 217.80 1.09 

Peas, Southern/Black Eyed 0.005 6.22 275.00 1.38 

Peas, succulent 0.005 31.11 411.00 2.06 

Potato 0.01 0.08 6969.60 69.70 

Rice 0.01 6.67 129.00 1.29 

Sorghum 0.01 5.00 12.00 0.12 

Soybean 0.005 13.90 166.67 0.83 

Sugar Beet 0.01 0.80 25.00 0.25 

Wheat 0.01 30.00 157.10 1.57 

Trifloxystrobin is widely used on a variety of agricultural crops in all regions of the country. 

Crops with the highest total usage in the United States are corn, rice, wheat, soybeans, grapes, 

peanuts, and pecans, apples, and soybeans. Crops with a high percentage of acres treated with 

trifloxystrobin (≥20% on average) include apples, celery, grapefruit, grapes, and hazelnuts. 

Further details on the usage of trifloxystrobin are provided in the Screening Level Usage Analysis 

(SLUA) report (Appendix A). 

5.0 Conclusions from Previous Risk Assessments 

EFED has conducted multiple ecological risk assessments on trifloxystrobin that serve as a basis 

for this problem formulation. EFED has evaluated the most recent (D388189; 12/30/11) 

ecological risk assessments for trifloxystrobin in association with the updated toxicity, exposure, 

and usage information to determine if sufficient data are available and if further updates are 

needed to support registration review. Recent risk assessments include numerous assessments 

conducted for registrations of new uses of trifloxystrobin, as described below. In addition, EFED 

considered the latest Agency science policies and risk assessment methodologies. 

5.1 Ecological Risk Assessments 

Ecological risks of trifloxystrobin have been previously evaluated by EFED for use on numerous 

commodities including pome fruits, grapes, cucurbits, peanuts, and turf (New Chemical Review, 

D244219, D245281, D254206, D254285, D254286); almonds, fruiting vegetables, hops, potatoes, 

sugar beets, and wheat (D254215, D254220, D254222); root vegetable subgroup 1B (except beet 

and radish) and leaf petiole subgroup 4B (D286427); barley, oats, sweet corn, and soybeans 

(D315580, D314187, D318621, D318623, D363130); grass grown for seed (D332979, 

D332982); asparagus, tropical crops, radish, root vegetables, strawberries (D331915, D339548, 

D348876), and artichoke (D388189). Detailed summaries of these assessments can be found in 
 Page 10 of 58 

the following previous risk assessments: D309489, D331915, and D388189. Trifloxystrobin was 

not subject to reregistration and thus no Reregistration Eligibility Decision (RED) is available. 

Conclusions from previous ecological risk assessments are summarized in Table 4. For most uses 

other than seed treatments, previous risk assessments identified risk quotients (RQs) that 

exceeded the EPA’s level of concern (LOC) for potential adverse effects to endangered and 

threatened freshwater fish, freshwater invertebrates and saltwater invertebrates. Risk quotients 

exceeded the LOC for non-endangered species only from the use on turf. For turf use, risk to 

marine/estuarine invertebrates exceeded the LOC for non-endangered species. For all uses, 

minimal risk was predicted for terrestrial wildlife and aquatic plants. Risk to non-listed terrestrial 

plants was not predicted, but recent risk assessments stated that potential adverse direct effects to 

threatened and endangered species of terrestrial plants could not be precluded because of 

limitations in the available phytotoxicity data. 

Table 4. Summary of Previous Ecological Risk Assessments Conducted by EFED on Trifloxystrobin 

Use Reference (Year) Max. Application 

Rate (lb ai/A) 

Taxa for which risk was 

identified at the Agency’s 

concern levels 

Artichokes D388189 (2011) 0.177 Freshwater fish (endangered 

species LOC), estuarine/marine 

invertebrates (endangered species 

LOC)* 

Alfalfa Seed D378918 (2010) 0.0047 None* 

Soybean (New use rate) D361159 (2009) 0.114 None* 

Asparagus, strawberries, 

radish, and other minor 

crops 

D331915, D339548, 

D348876 (2006) 

0.10-0.71 Estuarine/marine invertebrates 

(endangered species LOC)* 

Grasses grown for seeds D332979 and 

D33292 (2006) 

0.125 Freshwater fish (endangered 

species LOC), estuarine/marine 

invertebrates (endangered species 

LOC)* 

Sweet corn, barley, oat, 

soybean, and seed 

treatments 

D309489, D314187, 

D315580, D316090, 

D316091, D318621, 

and D318623 

(2005) 

0.057-0.082 None* 

Almonds, fruiting 

vegetables, hops, potatoes, 

sugar beets, and wheat 

D254215, D254220, 

and D254222 

(1999) 

0.10-0.125 Freshwater fish and invertebrates 

(endangered species LOC), 

estuarine/marine invertebrates 

(endangered species LOC) 

Pome fruits, grapes, 

cucurbit vegetables, 

peanuts, and turf** 

D244219,D245281, 

D254206, D254285, 

and D254286 

(1998) 

0.056-0.125 Freshwater fish and invertebrates 

(endangered species LOC for turf), 

estuarine/marine invertebrates 

(non-endangered LOC for turf, 

endangered species LOC only for 

other crops) 

*Risk to endangered terrestrial plants is uncertain because phytotoxicity studies did not establish either an NOAEC 

or EC05 value. 

** The highest application rate of trifloxystrobin is for turf, and turf is the use site associated with the greatest 

potential environmental exposures of trifloxystrobin. 
 Page 11 of 58 

In a recent risk assessment conducted for use on alfalfa seed, CGA-321113 (free acid degradate of 

trifloxystrobin) was identified as a major degradation product of trifloxystrobin, but because 

toxicity data indicate that it is considerably less toxic to aquatic organisms than the parent 

compound, the ecological risk assessment will be based on exposure to trifloxystrobin alone 

(D378918). However, because this major degradate has been identified by the Health Effects 

Division as a residue of concern, CGA-321113 will be included in estimation of trifloxystrobin 

concentrations in drinking water for human health risk assessments. 

The major environmental fate and ecological risk conclusions of previous assessments were as 

follows: 

Birds Mammals Terr. 

Plants 

Terr. 

Inverts Fish BCF Aquatic Inverts 

Aquatic 

Plants 

Groundwater 

Contamination Persistence Degradates of Concern 

-- -- -- -- √ -- √ -- -- -- --

“√” signifies that at least one LOC has been exceeded in previous assessments; “--“signifies LOCs have not been 

exceeded in past assessments. 

5.2 Drinking Water Exposure Assessments 

In previous environmental fate reviews, trifloxystrobin has been characterized as generally 

degrading rapidly in soil and water through alkaline-catalyzed hydrolysis, microbial-mediated 

metabolism, and photodegradation. Trifloxystrobin was characterized as having low solubility 

(0.61 mg/L) and low mobility in soil, and therefore was expected to pose little risk of 

contaminating ground water. 

A drinking water assessment was initially conducted during 1998 for a number of uses including 

turf during the New Chemical Review (D244219). The estimated drinking water concentrations 

(EDWCs) were determined for the turf use, which constituted the highest application rate for 

trifloxystrobin, using the GENEEC model. The EDWCs were determined with GENEEC (Table 

5) for trifloxystrobin plus the degradate (CGA-321113) were 47.98 μg/L for acute exposure and 

47.31 μg/L for chronic exposure. The GENEEC model was initially designed to predict pesticide 

concentrations in a standard farm pond for aquatic exposure assessments. It has been shown to be 

a good predictor of upper level pesticide concentrations in small but ecologically important 

upland streams, but not for larger water bodies used as a source for drinking water. Therefore, 

EFED developed the Tier 1 FIRST and Tier 2 PRZM/EXAMS models to estimate pesticide 

concentrations in drinking water from surface water sources1

. 

In order to ensure that previous estimates of trifloxystrobin plus CGA-321113 were not exceeded, 

the EDWCs for the turf use were reassessed due to a change (i.e., increase) in the maximum 

application rate, using the Tier 2 PRZM/EXAMS models (D378919; 11/29/2010). Tier 2 results 

were less than previous exposure estimates (Table 5) of trifloxystrobin plus the degradate (CGA321113): 29.32 μg/L for the 1-in-10-year peak, 22.67 μg/L for the 1-in-10-year annual mean, and 

18.97 μg/L for the 30-year mean for surface water; and, 5.87 μg/L for ground water using the 

SCI-GROW model. Other drinking water assessments for more recently requested crops (e.g., 

artichokes) have been conducted, which resulted in lower EDWCs (D309489; D339548). 

 

1 http://www.epa.gov/oppefed1/models/water/models4.htm
 Page 12 of 58 

Table 5. The highest EDWCs for Trifloxystrobin plus degradate CGA-321113 for the revised drinking water 

assessment on turf (D378919).

Crop

Acute Exposure from 

One in Ten Year Peak 

Values (μg/L) 

Chronic Exposure from 

One in Ten Year Annual 

Mean (μg/L ) 

Average of Yearly 

Average for Cancer 

Exposure (μg/L) 

Initial Turf Assessment 

Surface Water (GENEEC) (D244219, D360307) 

Generic Scenario (turf) 47.99 47.31 47.31 

Revised Turf Assessment 

Surface Water (PRZM/EXAMS) 

Turf (EPA Reg No. 432-

1371) 29.324 22.675 18.974 

Ground Water (SCI-GROW) 

 Not Applicable 5.87 5.87 5.87 

5.3 Clean Water Act Programs 

Trifloxystrobin is not identified as a cause of impairment for any water bodies listed as impaired 

under section 303(d) of the Clean Water Act. No Total Maximum Daily Load (TMDL) criteria 

have been developed for trifloxystrobin. Aquatic benchmarks have been established for 

trifloxystrobin and the degradate CGA-321113 and are available at 

http://www.epa.gov/oppefed1/ecorisk_ders/aquatic_life_benchmark.htm. Any data submitted or 

otherwise located as part of the registration review process may be used to update aquatic life 

benchmarks if applicable. 

Aquatic life benchmarks for trifloxystrobin are reported in Table . Aquatic life benchmarks 

developed by OPP for baseline risk assessments are estimates of the concentrations below which 

pesticides are not expected to harm aquatic life. Each aquatic life benchmark is based on the most 

sensitive, scientifically acceptable toxicity endpoint available to EPA for a given taxon (for 

example, freshwater fish) of all available scientifically acceptable toxicity data multiplied by the 

corresponding level of concern of 0.5 for acute endpoints and 1.0 for chronic and plant endpoints. 

Table 6. OPP Aquatic Life Benchmarks for trifloxystrobin and CGA-321113 in μg a.i./L 

Fish Aquatic Invertebrates Nonvascular 

Plants 

Vascular 

Plants 

Office of Water Aquatic 

Life Criteria 

Trifloxystrobin

Acute Chronic Acute Chronic Acute Acute Maximum 

Conc. 

Continuous 

Conc. 

7 4.3 12.5 2.8 37 > 1,930 

CGA-321113

> 53,000 — > 47,500 3,200 78,800 — 
 Page 13 of 58 

The Agency invites submission of water quality data for this pesticide. To the extent possible, 

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

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

Registration Review Risk Assessment and Management Process (see: 

http://www.epa.gov/oppfead1/cb/ppdc/2006/november06/session1-sop.pdf), in order to ensure 

they can be used quantitatively or qualitatively in pesticide risk assessments. 

6.0 Environmental Chemistry, Fate and Transport 

6.1 Stereochemistry 

A number of isomers of trifloxystrobin and its major degradation/transformation products were 

observed in the environmental fate studies as described below. 

The active geometric isomer in trifloxystrobin is (E,E) isomer of ά-(methoxyiminio)-2-[[[[1-[3-

(trifluoromethyl)phenyl] ethylidene] amino] oxy] methyl]-benzeneacetic acid, methyl ester 

(CGA-279202). There are also three other geometric isomers with similar molecular formula to 

the active isomer in trifloxystrobin. These geometric isomers include (Z,E) isomer of ά-

(methoxyiminio)-2-[[[[1-[3-(trifluoromethyl)phenyl] ethylidene] amino] oxy] methyl]-

benzeneacetic acid, methyl ester (CGA-357261), (E,Z) isomer of ά-(methoxyiminio)-2-[[[[1-[3-

(trifluoromethyl)phenyl] ethylidene] amino] oxy] methyl]-benzeneacetic acid, methyl ester 

(CGA-331409), and (Z,Z) isomer of ά-(methoxyiminio)-2-[[[[1-[3-(trifluoromethyl)phenyl] 

ethylidene] amino] oxy] methyl]-benzeneacetic acid, methyl ester (CGA-357262). The major 

route of dissipation for trifloxystrobin (CGA-279202) is de-esterification of the methyl ester to 

form the free acid of trifloxystrobin (CGA-321113). The other geometric isomers are expected to 

undergo similar de-esterification reactions to form their respective free acid (i.e., CGA-373466 

from CGA-357261; CGA-373465 from CGA-331409; and CGA 381318 from CGA-357262). The 

significance of the chemistry for the group of geometric isomers of parent trifloxystrobin and its 

free acid (E,Z; Z,E; E,E; Z,Z) is that they exhibit the same molecular formula with different 

conformational orientations. Each of these isomers is expected to exhibit different physical and 

chemical properties as well as different toxicities. Inter-conversion of isomers, i.e., “isomerism” 

may be possible if sufficient chemical energy is provided to promote a change in conformational 

orientation. 

The submitted studies indicate that trifloxystrobin has low to moderate mobility and degrades 

rapidly from de-esterification in the soil and aqueous environment into the primary degradate, 

CGA-321113. CGA-321113 is expected to form rapidly, be mobile in the environment, and to 

degrade at a slower rate than trifloxystrobin. In irradiated aquatic environments, photo- induced 

isomerism of trifloxystrobin (E,E) was observed with the formation of CGA-357261 (Z,E) and 

CGA-357262 (Z,Z). In soil environments, minor amounts of isomers of parent and acid were 

detected. Isomers found in soil metabolism studies include Z,E isomer of parent (CGA-373466), 

E,Z isomer of parent (CGA-331409), and Z,E isomer of acid degradate (CGA-373466). Although 

these data do not show extensive isomerism of trifloxystrobin, they do suggest isomerism is 

possible under some conditions (i.e., irradiated water, wet leaf surfaces, or soil). It is anticipated 

that the impact of isomerism is expected to have minimal impact in assessing the environmental 

fate and toxicity of the E,E isomer of trifloxystrobin. 
 Page 14 of 58 

6.2 Environmental Fate 

Trifloxystrobin will enter the environment via spray applied directly onto soil and foliage. It may 

move off-site via spray drift and runoff. 

Trifloxystrobin has a low solubility (0.61 mg/L @ pH 7) in water. The vapor pressure is 2.55 x 

10-8 torr at 25 °C, and the calculated Henry’s Law Constant is 2.25 x 10-8 atm-m3 mol-1. These 

values suggest that trifloxystrobin is non-volatile under field conditions from water and moist soil 

surfaces. Volatilization is not a likely route of dissipation. Although trifloxystrobin has a log Kow

of 4.5, evaluation of all the fate data suggest that the bioaccumulation of trifloxystrobin is 

unlikely. 

The submitted studies indicate that trifloxystrobin has low mobility and transforms rapidly in the 

soil and aqueous environment into a series of trifloxystrobin isomers and the primary degradate, 

CGA-321113, a carboxylic acid, a number of minor degradates, and CO2. The environmental fate 

and physiochemical properties of trifloxystrobin and the major degradation product CGA-321113 

are summarized in Tables 7 and 8. 

 

Trifloxystrobin is non-persistent in the terrestrial environment. Laboratory studies indicate that 

biotransformation is an important route of trifloxystrobin transformation in aerobic soil. 

Hydrolysis is important in alkaline soils. Trifloxystrobin degraded rapidly in soils with half-lives 

ranging between 0.41 and 0.91 days. In aerobic soils the major degradate is CGA-321113. Minor 

degradates identified include CGA-373466, CGA-357276, and CO2. Photodegradation is not an 

important route of transformation of trifloxystrobin, but resulted in the isomerization of the parent 

isomer CGA-357261 and degradate CGA-321113 are formed. The photo-induced isomerization 

half-life (t1/2) was 2.1days on soils. Further degradation forms CGA-357276, CGA-373466, CO2

and bound residues. 

CGA-321113 is the major transformation product identified in the soil metabolism studies. The 

fate studies indicate that CGA-321113 is quite persistent (DT50 250 to 350 days) in the soil 

environments (stable to hydrolysis and metabolism); therefore, CGA-321113 is expected to 

degrade at a lower rate than trifloxystrobin. CGA-321113 is a carboxylic acid, and therefore 

being anionic, is expected to be more mobile than parent trifloxystrobin. Therefore, because of its 

persistence and mobility, CGA-321113 would have a greater potential for leaching. 

Laboratory studies indicated that trifloxystrobin was also not persistent in the aquatic 

environment. In water, trifloxystrobin hydrolyzes to CGA-321113 under alkaline conditions (t1/2

= 55.2 days @ pH 7 and 0.83 days @ pH 9), but was stable under acidic conditions (at pH 4). 

Therefore, hydrolysis is only important under alkaline conditions. In the aquatic environment, 

trifloxystrobin will undergo photo-isomerization to parent isomer products (CGA-357261: Z,Eisomer; CGA-357262: Z,Z-isomer). The photo-induced isomerization half-life (t1/2) was 14.8 

days. In an aerobic aquatic sediment system, the major transformation product was CGA-321113. 

The fate studies indicate that CGA-321113 is quite persistent (DT50 = 289 days) in aquatic 

environments (stable to hydrolysis and metabolism). Therefore, CGA-321113 is expected to 

degrade at a slower rate than trifloxystrobin. CGA-321113 is a carboxylic acid, and therefore 

anionic. This, it will be more mobile than parent trifloxystrobin. Because of its persistence and 

mobility, CGA-321113 would have a greater potential for leaching. 
 Page 15 of 58 

Trifloxystrobin demonstrated a “hockey stick type” biphasic degradation pattern (i.e., two distinct 

degradation rates observed in the duration of the study, rate decreasing with time) in field 

dissipation studies conducted in California, New York, and Georgia. For the first degradation 

phase, trifloxystrobin half-life values ranged from 1.9 to 24 days. In the second degradation 

phase, half-life values ranged from 6.5 days to 4 months. 

The proposed degradation pathway of trifloxystrobin in an aquatic system is show in Figure 1. 

This figure gives the structures of the different isomers of trifloxystrobin and its degradation 

products. 

6.3 Mobility 

Based upon the soil organic carbon coefficient, Koc (median Koc =2709 mL/goc), trifloxystrobin 

would fall into the slightly mobile class adapted from the FAO by EFED (USEPA, 20062). 

Studies were also conducted on the mobility of the primary degradate, CGA-321113. The 

laboratory adsorption/desorption mobility classification of CGA-321113 was mobile to 

moderately mobile under the FAO classification. However, in leachates from a field lysimeter 

study, CGA-321113 was not detected above 0.02% of the applied amount. In field dissipation 

studies conducted in Georgia, California, and New York, under bare ground and cropped 

conditions, trifloxystrobin was not detected below 6" and CGA-321113 concentrations reached or 

were slightly above the LOQ of 10 ppb in 12-18, and 30 -36 inch soil segments. Another 

degradate CGA-373466 was detected in the 0-6 and 6-12 inch segments. 

Adsorption/desorption studies were also conducted for the parent isomer CGA-357261 [Koc – 

389 to 567 mL/goc], CGA-357276 (an isomer of CGA-321113) [Koc - 6587 to 9228 mL/goc] and 

CGA-373466 (an isomer of CGA-321113) [Koc - 31 to 166 mL/goc]. Following the FAO mobility 

classification, CGA-357261 was moderately mobile, CGA-357276 was slightly mobile, and 

CGA-373466 was classified as moderately mobile to mobile. 

 

2

 USEPA, 2006. Standardized Soil Mobility Classification Guidance. Memorandum: S. Bradbury, April 21, 2006. 
 Page 16 of 58 

Figure 1. Proposed degradation pathways of trifloxystrobin (CGA-279202EE) in aquatic 

systems 
 Page 17 of 58 

6.4 Bioconcentration 

The log Kow of 4.5 suggests that trifloxystrobin may bioaccumulate. Trifloxystrobin has 

bioconcentration factors in bluegill sunfish edible tissues of 130-166X, 1172-1144X for nonedible 

tissues, and 542-547X in whole fish. The bioaccumulation plateau was rapid (3 days post 

exposure). However, depuration was rapid, with 96.7-98.1% of the total [14C]residues 

accumulated by exposure day 28 eliminated from all tissues by 7 days in the 0.16 μg/L system, 

and 98.3-98.5% eliminated from all tissues by 14 days in the 1.6 μg/L system. Due to the 

relatively low fish bioconcentration factors in fish tissue, rapid aquatic biotransformation to CGA32113 (acid) and the rapid depuration of trifloxystrobin observed in the fish study, 

bioaccumulation is unlikely. 

Selected chemical and fate properties are summarized in Table 7 and Table 8. 

Table 7. Chemical Properties and Environmental Fate and Modeling Input Parameters of Trifloxystrobin for 

Aquatic Exposure. 

Parameter Value Modeling Input Value Source

Molecular mass (molecular 

formula) 

 408.37 g/mol (C20H19F3N2O4) 408.37 (Calculated) 

Vapor pressure (25°C) 2.55 x 10-8 torra,b 2.55 x 10-8 torr 

Aqueous solubility (20C) 0.61 mg/L @ pH7 0.61 mg/L MRID 44502801 

Henry’s Law Constant 

(25°C) 

 2.25 x10-8 atm-m3/mol 2.25 x10-8 atm-m3/mol (Calculated) 

Log octanol-to-water 

partition coefficient 

(log KOW) (25°C) 

4.5 Not Applicable MRID 44502801 

Hydrolysis half-life 

(25±1C) 

pH 4: stable 

pH 7: 55.2 days 

pH 9: 0.83 days 

pH4: stable 

pH7: 55.2 days 

MRID 44496727 

Aqueous photolysis half-life 

(25±1C) 

 14.8 days @pH 5 14.8 days MRID 44496727 

Soil photolysis half-life 

(25±1C) 

 2.1 days 2.1 days MRID 44496729 

Aerobic soil metabolism 

half-life [dissipation halflife A] (25±1°C) 

 0.74, 0.41, and 0.91 days

 

 mean = 0.69 d, std = 0.25 d 

90% upper bound half-life = 

0.964 daysc

MRID 44496732

MRID 44496730 

MRID 44496731 

Anaerobic aquatic 

metabolism half-life (20-

29C) 

 0.72 days 2.16 days (3 times single 

value)c

MRID 44496733

Aerobic aquatic metabolism 

half-life [dissipation halflife A] (25C) 

 0.60 days (supplemental) 1.928 days (2 x aerobic soil 

metabolism (0.964 days)c

MRID 44496734
 Page 18 of 58 

Parameter Value Modeling Input Value Source

Freundlich soil-water 

partition coefficients (KF); 

organic carbon-normalized 

Freundlich coefficients 

(KFOC) 

KF (mL/g); 

6.8, 7.7, 16.0, 59.4, 91.8, 33.2

Mean = 35.82; Std = 33.8 

[7.7 is the lowest non-sand] 

KFOC( mL/gOC) 

2354, 951, 3064, 3927, 9871, 

951 coefficient of 

determination (r2

) = (Kf vs. 

organic matter = 0.03) 

Mean KF = 35.82 mL/g 

Sorption not correlated with 

Organic Carbon 

MRID 44496802 

Fish bioconcentration 

factors (steady-state); 

depuration rate 

130-166 X (edible), 1172-1144 

X(non-edible), 542-547 X 

(whole); 

96.7-98.1% depuration in 7 

days 

Not Applicable MRID 44496813 

Aerial Spray Drift 

Application Efficiency 

(fraction) 0.16 drinking water 

0.95 

EFED Guidance 

FEXTRA - foliar apps PRZM Foliar Extraction 0.5 (frac/cm rain) EFED Guidance 

a

 USEPA Fact Sheet reports 3.4 x 10-6 torr (@25 °C) b

 PMRA Reg2004-03 and Trifloxystrobin (213) report 3.4 x 10-6 Pa @ (@25 °C c EFED Model Input Guidance http://www.epa.gov/oppefed1/models/water/input_parameter_guidance.htm

6.5 Transformation Products 

Information is available on trifloxystrobin degradates. Selected chemical and fate properties of 

the degradate CGA-321113 are summarized in Table 8. The degradation/transformation products 

observed in the environmental fate studies are summarized in Table 9. 

Toxicity testing with CGA-321113 indicates that it has low toxicity to aquatic organisms (Table 

10). Based on its acute toxicity, it is classified as “practically nontoxic” to fish and freshwater 

invertebrates, and the toxicity endpoints for growth and reproduction of algae, and chronic effects 

to freshwater vertebrates, are over 1000 times greater than those of the parent compound. 

Because of this lack of toxicity, EFED does not plan to include exposure to this transformation 

product quantitatively in the risk assessment that will be conducted in registration review. 
 Page 19 of 58 

Table 8. Summary Environmental Fate Data for CGA-321113 and Model Input Parameters Used to Estimate 

the Total Toxic Residues or Residues of Concern (ROC) (trifloxystrobin + degradate CGA-321113) for the 

Drinking Water Assessment.

Parameter Values1 Modeling Input Value2 Source 

CGA-321113 

Molecular Formula C19H17F3N2O4 MRID 44496801 

Molecular Weight 394.35 394.35 MRID 44496801 

Solubility @ 20 ◦C 30.9 mg/L 30.9 mg/L MRID 44496816 

Vapor Pressure 7.5 x 10-08 mm Hg @ 20 ◦

C MRID 44496801 

Henry’s Constant 1.26 x 10-09 atm m3 mol-1 

Hydrolysis Half-life Stable Stable (days) MRID 44496727 

Aquatic Photolysis 

Half-life 

Stable Stable (days) MRID 44496727 

Photolysis on soil Halflife Stable Stable (days) MRID 44496727 

Aerobic Aquatic 

Metabolism Half-life 

stable Stable (days) MRID 44496734 

Anaerobic Aquatic 

Metabolism Half-life ( 

Stable Stable (days) MRID 44496733 

Organic Carbon 

Partition Coefficient 

(Koc) (mL/g) 

127, 235, 130, 48, and 80 

Coef. Determination (r2

) = 

0.89 for Kf vs. om 

mean 124.0 mL/goc

median 127 mL/goc 

MRID 44496801 

Soil Partition 

Coefficient (Kf) 

(mL/g) 

Kf (texture class) 

 4.0 Loam (5.4% om) 

1.9 Sand 

3.2 Clay loam 

0.28 Sandy loam (1% om) 

0.65 Sandy loam 

mean = 2.0 mL/g 

[1/n = 0.81 to 0.85] 

MRID 44496801 

Aerial Spray Drift 

Application Efficiency 

(fraction) 0.16 drinking water 

0.95 

EFED Guidance 

FEXTRA - foliar apps PRZM Foliar Extraction 0.5 (frac/cm rain) EFED Guidance 

Persistence for Residues of Concern (Total Toxic Residues) (parent trifloxystrobin + CGA-321113)(DP 

D309489 see Table 9)

[Residues of Concern]: 

 Aerobic Soil 

Metabolism Half-life 

254.8 days 

271.3 days 

199.7 days 

282.75 days 

(90th percent upper bound on 

mean) 

Median = 254.8 days 

MRID 44496732 

MRID 44496730 

MRID 44496731 

1,2 Values for environmental fate properties used for modeling were obtained for the degradate CGA-321113 

except for the aerobic soil metabolism values which consider the total toxic residues (sum of the concentration 

of parent plus the degradate CGA-321113 versus time), assumed the most conservative values. 
 Page 20 of 58 

Table 9. Trifloxystrobin and Its Major Environmental Transformation Products and Degradates 

Study Type Hydrolysis Photolysis 

(water) 

Photolysis 

(soil) 

Aerobic 

Soil 

Anaerobic 

Aquatic 

Aerobic 

Aquatic 

Terrestrial 

Field Studies

(detections)

MRID 44406727 44496727 44496728 

44496729 

44496730 

44496731 

44496732 

44496733 44496734 

44496808 

44757204 

44657203 

Trifloxystrobin 

CGA-279202 

CAS# 141517-21-7 

C20H19F3N2O4

MW: 408.5 g/mol

 

Degradates 

CGA-321113 

E,E isomer 

CGA-279302 acid 

C19H17F3N2O4

MW: 394.32 g/mol 

pH 5: 

0% 

pH 7: 

29.2% 

pH 9: 

100% 

irradiated: 

9.1% 

irradiated: 

17.2% 

dark:72.3% 

93.2% 

aqueous 

69.3% 

sediment: 

33.8% 

aqueous: 

82.3% 

soil: 

23.3% 

detected 

30” -36” 

CGA-357261 

Z,E isomer 

Z,E parent 

irradiated: 

63.8% 

not detected 

below 18” 

CGA-357262 

Z,Z isomer 

Z,E parent 

irradiated: 

9.1% 

irradiated: 

4.1% <4.1% 

not detected 

below 18” (12” – 

18” –once) 

CGA-373466 

Z,E isomer 

CGA-357261 acid 

irradiated: 

24.8% 

dark: 3.8% 

<4.1% detected 

6” – 12” 

NOA-409480 & 

CGA-357251 

irradiated: 

18.5% 

dark: 2.5% 

CGA-331409 

E,Z isomer 

E,Z parent 

CAS# 141493-03-0 

irradiated: 

4.1% <1.0% .4% 

CGA-320299 <1.0% 

CGA-357276 dark: 

1.9% 5.6% detected 3" -6" 

Unidentified dark 

13.6% 

CO2 5.1% 0.4% 2.5% 

Non-extractable 27.4% 13.8% 

6.6 Monitoring Data 

The following databases and sources were searched for monitoring information on trifloxystrobin 

and CGA-321113 on January 28, 2013: 

 The United States Geological Survey (USGS) National Water-Quality Assessment 

(NAWQA) Program Data Warehouse 

(http://infotrek.er.usgs.gov/traverse/f?p=NAWQA:HOME:1405517206944567) 

 The USGS National Stream Quality Accounting Network (NASQAN) program 

(http://water.usgs.gov/nasqan/) 

 California Department of Pesticide Regulation (CDPR) Surface Water Database 

(http://www.cdpr.ca.gov/docs/emon/surfwtr/surfdata.htm) 

 California Environmental Data Exchange Network (CEDEN; http://www.ceden.org/) 
 Page 21 of 58 

Trifloxystrobin and its degradates have not been included in these monitoring programs. 

7.0 Receptors 

Table 10 and Table 12 provide a summary of the toxicity of trifloxystrobin aquatic and terrestrial 

taxonomic groups, respectively, based on toxicity measured in the most sensitive surrogate 

species. Table 11 provides information for the degradate CGA-321113. In addition, the tables 

provide a preliminary overview of the potential acute toxicity of trifloxystrobin by providing the 

acute toxicity classifications. 

7.1 Effects to Aquatic Organisms 

Available toxicity data indicate that trifloxystrobin is highly toxic to fish and aquatic invertebrates 

on an acute exposure basis. Data for green algae (Pseudokirchneriellasubcapitata) indicate 

toxicity to algae occurs at relatively low exposure levels, with toxicity endpoints comparable to 

the acute toxicity endpoints for fish and aquatic invertebrates. On a chronic basis, the most 

sensitive test species was the waterflea (Daphnia magna), in which significant growth and 

reproduction was observed at 5.98 μg ai/L. The waterflea NOAEC was established at 2.76 μg 

ai/L. 

 
 Page 22 of 58 

Table 10. Summary of the Most Sensitive Endpoints from Aquatic Toxicity Studies for 

Trifloxystrobin 

Taxonomic 

Group 

Study 

Type Surrogate Species 

Toxicity Value 

(all units in terms of 

measured active 

ingredient) 

Acute 

Toxicity 

Classification Source 

Freshwater fish1

Acute 

Rainbow Trout 

(Oncorhynchus 

mykiss) 

96-hr LC50 = 14.3 

μg/L 

Very highly 

toxic 

MRID 

44502803 

Chronic 

(Early 

LifeStage) 

Rainbow Trout 

NOAEC = 4.3 μg/L 

LOAEC = 7.7 μg/L 

Endpoint: Post-hatch 

survival 

-- MRID 

44502804 

Freshwater 

invertebrates 

Acute Water Flea 

(Daphnia magna) 

48-hr EC50 = 25.3 

μg/L 

Very highly 

toxic 

MRID 

44496611 

Chronic Water Flea 

NOAEC = 2.76 μg/L 

LOAEC = 5.98 μg/L 

Endpoint: Dry weight 

and fecundity 

-- 44496615 

Estuarine/marine 

fish Acute 

Sheepshead Minnow 

(Cyprinodon 

variegatus) 

96-hr LC50 = 78.0 

μg/L 

Very highly 

toxic 

MRID 

44496612 

Estuarine/marine 

invertebrates Acute 

Mysid 

(Americamysis 

bahia) 

96-hr EC50 = 8.62 

μg/L 

Very highly 

toxic 44496614 

Aquatic plants 

and algae 

Vascular Duckweed 

(Lemna gibba) 

NOAEC = 410 μg/L2

14-d EC50 >1930 

μg/L2

-- MRID 

44496725 

Nonvascular 

Green Algae 

(Pseudokirchneriella 

subcapitata) 

NOAEC = 10.5 μg/L 

5-d EC50 = 37.1 μg/L -- MRID 

44496724 

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

2 These results are uncertain because the test material was unstable and renewals were not done, resulting in dramatic declines of 

the test material during the duration of the exposure period. The study was classified as Supplemental. 

Available toxicity data for CGA-321113, the major degradation product of trifloxystrobin, are 

given in Table 11. The data indicate that this compound is much less toxic to fish, aquatic 

invertebrates, and algae than the parent compound. CGA-321113 is classified as practically 

nontoxic to fish and aquatic invertebrates on an acute basis. A supplemental life-cycle study with 

CGA-32113 established an NOAEC for chronic effects at 3.2 mg/L. The chronic toxicity 

endpoints derived from this study were greater than 3 orders of magnitude greater than that 

obtained for this species when tested with the parent compound. Although the lack of evaluation 

of growth endpoints (dry weight or length) may make this study less sensitive than a study that 

adhered to the test guideline, the study provides sufficient evidence to conclude that this 

degradation product has much less chronic toxicity than the parent compound. 
 Page 23 of 58 

Table 11. Summary of the Most Sensitive Endpoints from Aquatic Toxicity Studies for CGA-321113 

Taxonomic 

Group 

Study 

Type Surrogate Species 

Toxicity Value 

(all units in terms 

of measured active 

ingredient) 

Acute 

Toxicity 

Classification 

Source 

(MRID No.) 

Freshwater fish1 Acute Rainbow trout 96-hr EC50 > 106 

mg/L 

Practically 

nontoxic 44527502 

Freshwater 

invertebrates 

Acute Water Flea 

(Daphnia magna) 

48-hr EC50 > 95.3 

mg/L 

Practically 

nontoxic 44527503 

Chronic Water Flea 

 NOAEC= 3.2 

mg/L2 

LOAEC= 10.0 

mg/L2 

Endpoint: Survival 

-- 44869701 

Aquatic plants 

and algae 

Nonvascular 

Green Algae 

(Pseudokirchneriella 

subcapitata) 

NOAEC = 15.7 

mg/L 

5-d EC50 = 77.1 

mg/L 

-- 44496724 

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

2 This study was classified as Supplemental because it did not follow the experimental design prescribed by the test guideline. 

The study did not evaluate growth parameters (dry weight or length) and thus the results may not be as sensitive as a fully 

acceptable study. 

7.2 Effects to Terrestrial Organisms 

All available acute oral and subacute dietary studies indicate that trifloxystrobin is practically 

nontoxic to birds, mammals, and bees on an acute basis. Acute testing with the rat (Rattus 

norvegicus) show that acute toxicity to mammals from the dermal and inhalation routes of 

exposure is also low. With chronic exposure, trifloxystrobin did not cause any observable toxic 

effect to birds at dietary concentrations up to 320 mg a.i./kg-diet. Chronic toxicity to birds at 

exposures greater than 320 mg ai/kg-diet is not known; however, maximum residues on terrestrial 

food items are not expected to reach this concentration with current registered uses. Chronic 

toxicity studies with the laboratory rat showed frank toxic effects to adult and young with chronic 

exposures of 750 mg a.i./kg-diet and above, with an NOAEL established at 500 mg a.i./kg-diet. 

No reproductive impairment, however, was noted in rats exposed to up to 1500 mg a.i./kg-diet. 

Testing with the honey bee found that trifloxystrobin is practically nontoxic to bees. Tier-1 

phytotoxicity studies found that exposure of trifloxystrobin to terrestrial plants at approximately 

0.25 lb a.i./A caused some inhibition of growth (no more than 13% inhibition). These studies are 

adequate for demonstrating that most uses of trifloxystrobin would have little toxicity to target 

plants that are sprayed directly at the maximum label application rate. However, these tier-1 

studies are not adequate for predicting risk to plants from use on turf, for which the maximum 

single application rate is 0.34 lb a.i./A. 

 
 Page 24 of 58 

Table 12. Summary of the Most Sensitive Endpoints from Terrestrial Toxicity Studies for 

Trifloxystrobin 

Taxonomic 

Group 

Study 

Type 

Surrogate 

Species 

Toxicity Value 

(all units in terms of 

measured active 

ingredient) 

Acute 

Toxicity 

Classification 

Source 

(MRID No.) 

Birds1

Acute 

Bobwhite 

(Colinus 

virginianus) 

LD50 > 2000 mg/kgbw 

Practically 

nontoxic 44496606 

Sub-acute 

dietary 

Bobwhite and 

Mallard (Anas 

platyrhynchos) 

LC50 > 5050 mg/kgdiet 

Practically 

nontoxic 

444966-07 

444966-08 

Chronic Bobwhite quail NOAEC = 320 ppm 

LOAEC > 320 ppm -- 444966-09 

Mammals 

Acute Oral 

Laboratory rat 

(Rattus 

norvegicus) 

LD50 > 5000 mg/kgbw 

practically 

nontoxic 44496622 

Acute 

Dermal Laboratory rat LD50 > 2000 mg/kgbw 

Toxicity 

Category IIIIV 44496627 

Acute 

Inhalation Laboratory rat LC50 > 4.65 mg/L Toxicity 

Category IV 44496630 

Chronic 

(2-Gen. 

Repro.) 

Laboratory rat 

(Rattus 

norvegicus) 

Parental: 

NOAEL: 50 ppm 

LOAEL: 750 ppm 

Endpoint: Reduced 

body weight, body 

weight gain, and food 

consumption 

Offspring: 

NOAEL: 50 ppm 

LOAEL: 750 ppm 

Endpoint: Reduced 

body weight 

Reproduction: 

NOAEL: 1500 ppm 

LOAEL: >1500 ppm 

-- 44496710 

Insects Acute 

contact 

Honey bee 

(Apis mellifera 

L.) 

LD50 > 200 μg/bee Practically 

nontoxic 444967-26 

Terrestrial 

plants 

Seedling 

Emergence 

Dicot – cabbage 

13% inhibition in dry 

weight at 0.249 lb 

a.i./A 

-- 44496723 

Monocot – 

ryegrass 

7% inhibition in dry 

weight at 0.249 lb 

a.i./A 
 Page 25 of 58 

Taxonomic 

Group 

Study 

Type 

Surrogate 

Species 

Toxicity Value 

(all units in terms of 

measured active 

ingredient) 

Acute 

Toxicity 

Classification 

Source 

(MRID No.) 

Vegetative 

vigor 

Dicot – tomato 

10% inhibition in dry 

weight at 0.249 lb 

a.i./A 

 44496723 

Monocot – 

ryegrass 

9% inhibition in dry 

weight at 0.249 lb 

a.i./A 1 Birds represent surrogates for terrestrial-phase amphibians and reptiles. 2

 Study was conducted with USF 2004 500 SC (43.9% trifloxystrobin). Results were adjusted for the percent a.i. 

No in vivo studies are available on the toxicity of CGA-321113 to terrestrial organisms. 

However, an in vitro study of this compound using rat hepatocyte cultures has been submitted to 

the EPA (MRID 44496720). This study found that CGA-321113 does not express the toxic 

mechanism of action of the parent compound, i.e., inhibition of mitochondrial respiration, and is 

much less toxic to hepatocyte cells than is the parent. The NOAEL was 600 μM for CGA-321113 

compared to <30 μM for trifloxystrobin. These results agree with the findings of aquatic toxicity 

studies which also showed that CGA-321113 is much less toxic to animals and plants than 

trifloxystrobin. 

7.3 Ecological Incidents 

The ecological incident information system (EIIS) was queried in October 2012 for incidents 

linked to trifloxystrobin exposure. EIIS is an OPP database that houses ecological incidents that 

have been reported to the Agency. When available, EIIS includes date and location of an 

incident, type and magnitude of effects observed in various species, use(s) of pesticides known or 

suspected of contributing to the incident, and results of any chemical residue analysis or other 

analyses conducted during incident investigation. EIIS incidents are categorized according to the 

certainty that the incident resulted from pesticide exposure. 

The query of EIIS identified 18 ecological incidents that were associated with trifloxystrobin 

exposure. These incidents are summarized in Appendix D. Seventeen of the incidents involved 

damage to a crop after direct application of a product containing trifloxystrobin to the crop. One 

of these incidents (I016036-004) was attributed to contamination of the tank mixture with an 

herbicide, and the exposure to trifloxystrobin was thought to be unrelated to the damage. Other 

than this incident (which was assigned a certainty of “unlikely”), 4 incidents were assigned a 

certainty of “possible” and 12 incidents were assigned a certainty of “probable” for 

trifloxystrobin. Some of the “possible” incidents also involved exposure to a second pesticide, 

and thus the cause was uncertain. Plants that were damaged in these trifloxystrobin incidents 

include grape, wheat, leatherleaf fern, and other ornamental plants. While these incidents do not 

necessarily indicate risk to plants growing off the treatment site, they do demonstrate that 

trifloxystrobin can be toxic to some sensitive plants. 

There was one incident involving bee mortality, which was associated with exposure to 

trifloxystrobin and other pesticides (I022340-001). Trifloxystrobin was one of nine pesticides 

identified in the bee pollen collected from the affected hives. One of the pesticides was 
 Page 26 of 58 

clothianidin, an insecticide which is highly toxic to bees. This insecticide is believed to be the 

primary cause of the bee kill, with possible contribution of toxicity from a second insecticide, 

thiamethoxam. Exposure to the other seven pesticides, including trifloxystrobin, was thought to 

be incidental to the incident and was assigned a certainty level of “unlikely.” Thus, this incident 

does not indicate that trifloxystrobin is toxic to bees. 

Registrants of trifloxystrobin have reported 7 additional minor plant damage incidents in 

aggregated reports submitted to the EPA. These incidents occurred between 2006 and 2012. No 

additional information is available on these incidents. Unless additional information on these 

aggregated incidents becomes available, they will be assumed to be representative of registered 

uses of trifloxystrobin in the risk assessment. 

The Avian Monitoring System (AIMS) is a database administered by the American Bird 

Conservancy that contains publicly available data on reported avian incidents involving 

pesticides. Many of the incidents listed in this database are also in the EIIS. As of October 2012, 

AIMS did not contain any records of ecological incidents associated with exposure to 

trifloxystrobin. 

8.0 Exposure Pathways of Concern 

Based on the use pattern and environmental fate characteristics of this pesticide, the following 

exposure pathways are expected to be most relevant for determining exposure and potential risk 

to nontarget organisms: 

 Direct spray 

 Spray drift 

 Runoff 

 Consumption of treated wildlife food items 

All of these routes of exposure are relevant for foliar spray applications. For seed treatments and 

drench applications, only runoff and consumption of contaminated food items are relevant. 

Trifloxystrobin is moderately to highly lipophilic (log Kow 4.5) and the bioconcentration factors 

measured in fish are moderate (BCFs 542-547x for whole fish and 1172-1144x for nonedible 

tissue). However, the rapid degradation of this compound is expected to preclude the potential for 

bioaccumulation in aquatic ecosystems. Therefore, use of the KABAM model to model 

bioconcentration of trifloxystrobin through the aquatic food chain will not be necessary. 

Due to the low persistence, low solubility, and relatively low mobility, trifloxystrobin has little 

potential for contamination of groundwater. Therefore, movement through groundwater and 

irrigation from groundwater sources are not expected to be a significant route of exposure. The 

degradation product of trifloxystrobin, CGA-321113, is expected to leach, but it has very low 

toxicity and is therefore not considered to be an environmental stressor. Likewise, due to the low 

persistence and low volatility, exposure from atmospheric deposition is expected to be minimal. 

Drinking water and inhalation exposure pathways were screened using the SIP (Screening 

Imbibition Program) and STIR (Screening Tool for Inhalation Risk) screening methods and were 
 Page 27 of 58 

found to be exposure pathways of low concern (no LOC exceedances are expected). SIP and 

STIR are described in detail at: http://www.epa.gov/oppefed1/models/terrestrial/index.htm. The 

SIP model determined that, based on the solubility and toxicity of trifloxystrobin, drinking water 

exposure alone does not have potential to be a pathway of concern for acute or chronic risk to 

wildlife. Likewise, the STIR model determined that, based on the vapor pressure and toxicity of 

trifloxystrobin, inhalation exposure alone does not have potential to be a pathway of concern for 

acute or chronic risk to wildlife. Thus, neither drinking water nor inhalation exposure will be 

included in the risk assessment for terrestrial animals. Output from the SIP and STIR models are 

provided in Appendix C. 

9.0 Analysis Plan 

9.1 Stressors of Concern 

Ecological Risk Assessment 

The only stressor of ecological concern is the parent compound, trifloxystrobin. The primary 

environmental transformation product, CGA-321113, has been shown to be much less toxic than 

trifloxystrobin and therefore is not considered an ecological stressor. Model input values for 

aquatic exposure are summarized in Table 7. 

Drinking Water 

The Health Effects Division (HED) has previously determined that parent trifloxystrobin and the 

degradation product CGA-321113 should be considered as the residues of concern (ROC) for 

drinking water. Therefore any drinking water assessments conducted to support future human 

health risk assessments of trifloxystrobin will incorporate model estimates of trifloxystrobin 

residues of concern and any available monitoring data, which are parent compound and the 

degradation product CGA-321113. For drinking water the Total Toxic Residue approach is used 

which considers the persistence (half-life) of trifloxystrobin plus CGA-321113 and the most 

mobile chemical species. The values used for the drinking water assessment are summarized in 

Table 8. 

EFED will use standard available models3

 to evaluate potential exposure to pesticides in surface 

water (PRZM and EXAMS) and ground water (PRZM-GW) sources as described at 

http://www.epa.gov/pesticides/science/models_db.htm. The versions used by the Agency at the 

time the risk assessment is completed will be used in the assessment. 

9.2 Measures of Exposure 

EFED will use standard models and methodology to evaluate potential exposures of 

trifloxystrobin to aquatic and terrestrial organisms. Exposure to aquatic animals will be estimated 

 

3 PRZM and EXAMS are Tier II models used to estimate environmental exposure concentrations in surface water. A 

description of these models and the guidelines for selecting input parameters can be found at 

http://www.epa.gov/oppefed1/models/water/
 Page 28 of 58 

using the Pesticide Root Zone Model (PRZM) coupled with the Exposure Analysis Model System 

(EXAMS). EFED will use the most current version of these models available at the time of the 

assessment. EFED’s PE5 program will be used as the user interface to manage parameter inputs 

and to run these models. For ecological risk, the aquatic EECs will be determined for parent 

trifloxystrobin. Model input values are summarized in Table 7. Exposure to terrestrial animals 

will be estimated using the most current version of the Terrestrial Residue Exposure (T-REX) 

model. Exposure to terrestrial plants will be estimated using the most current version of the 

TerrPlant model. These models are described at 

http://www.epa.gov/pesticides/science/models_db.htm. 

Aquatic and terrestrial exposure will be modeled assuming the maximum single application rates 

and the maximum number of applications in a given year. Estimates will be made for uses or 

groups of uses that have unique site-specific model inputs, such as maximum application rate, 

number of applications, and application intervals, as given in Table 1. For uses of trifloxystrobin 

other than seed treatment, exposure will be assessed for ground applications and, as permitted per 

the labels, aerial applications. Ground application will be assumed to be made with an airblast 

sprayer for tree and vine crops, and by boom sprayer for other agricultural crops. Exposure 

estimates for aquatic animals and terrestrial plants will be based on exposure for runoff and spray 

drift. Exposure estimates for terrestrial animals will be based on the dietary dose obtained from 

consuming food items directly sprayed with trifloxystrobin. 

For seed-treatment uses, exposure will be assessed based on the maximum seed treatment rates 

(i.e., maximum pounds of a.i. applied to pound of seeds) and the ranges of expected seeding rate 

(lb seed/A) for selected major crops, as shown in Table 3. A screening-level risk assessment first 

will be conducted based on the predicted maximum application rates (lb a.i./A), which are 

calculated by multiplying the maximum seed-treatment rates by the maximum seeding rates 

(Table 3). If the screening level assessment indicates potential risk (i.e., exceeds the level of 

concern) for these maximum application rates, then risk based on the entire range of seeding rates 

will be considered. For seed treatment uses, exposure to terrestrial plants and all aquatic 

organisms will be based on the calculated maximum application rates, and will assume exposure 

from runoff but not spray drift. For terrestrial animals, the calculated maximum application rate 

will be used to estimate the LD50-per-square-foot risk index. This index is calculated by dividing 

the amount of a.i. available per square foot of planted cropland by the acute LD50 of 

trifloxystrobin. In addition, risk quotients will be calculated based on the predicted dietary dose 

from direct consumption of treated seeds from a planted field. Finally, risk will be further 

characterized by calculating the number of treated seeds animals need to consume to reach a dose 

equal to the acute LD50 and chronic NOAEL. 

Screening level calculations have suggested that drinking water and inhalation exposure pathways 

will not be significant. Therefore, these exposure pathways will not be further considered at the 

time of the risk assessment. 

9.3 Measures of Effect 

Toxicity data presented in Section 3 of this problem formulation will be used to calculate risk 

quotients. Any additional information submitted by the registrant or found in the open literature 

prior to conduct of the risk assessment will also be considered. The open literature studies are 
 Page 29 of 58 

identified using EPA’s ECOTOXicology database (ECOTOX) (USEPA, 2007c), which employs 

a literature search engine for locating chemical toxicity data for aquatic life, terrestrial plants, and 

wildlife. The evaluation of both sources of data can also provide insight into the direct and 

indirect effects of pesticides on biotic communities from loss of species that are sensitive to the 

chemicals and from changes in structure and functional characteristics of the affected 

communities. 

9.4 Endangered Species Assessments 

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

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

registered uses of pesticides in registration review. The process for evaluating potential risks to 

listed species is further described at 

http://www.epa.gov/oppfead1/endanger/litstatus/riskasses.htm. 

 

9.5 Endocrine Disruptor Screening Program 

As required under FFDCA section 408(p), EPA has developed the Endocrine Disruptor Screening 

Program (EDSP) to determine whether certain substances (including pesticide active and other 

ingredients) may have an effect in humans or wildlife similar to an effect produced by a “naturally 

occurring estrogen, or other such endocrine effects as the Administrator may designate.” The 

EDSP employs a two-tiered approach to making the statutorily required determinations. Tier 1 

consists of a battery of 11 screening assays to identify the potential of a chemical substance to 

interact with the estrogen, androgen, and or thyroid (E, A, or T) hormonal systems. Chemicals 

that go through Tier 1 screening and are found to have the potential to interact with E, A, or T 

hormonal systems will proceed to the next stage of the EDSP where EPA will determine which, if 

any, of the Tier 2 tests are necessary based on the available data. Tier 2 testing is designed to 

identify any adverse endocrine related effects caused by the substance, and establish a doseresponse relationship between the dose and the E, A, or T effect. 

Between October 2009 and February 2010, EPA issued test orders/data call-ins for the first group 

of 67 chemicals, which contains 58 pesticide active ingredients and 9 inert ingredients. This list 

of chemicals was selected based on the potential for human exposure through pathways such as 

food and water, residential activity, and certain post-application agricultural scenarios. This list 

should not be construed as a list of known or likely endocrine disruptors. 

Trifloxystrobin was not among the group of 58 pesticide active ingredients that received EDSP 

test orders. For information on the status of the orders issued under the EDSP for each chemical, 

please visit our website at http://www.epa.gov/endo/ and click on the "Status of EDSP 

Orders/DCIs" in the Highlights Box. Additional information on the EDSP, including the policies 

and procedures, the list of 67 chemicals, the test guidelines and the Tier 1 screening battery, can 

also be found at this website. 
 Page 30 of 58 

10.0 Preliminary Identification of Data Gaps 

10.1 Environmental Fate 

Table 13 identifies environmental fate studies with trifloxystrobin that have been submitted for 

each guideline, as well as provides the classifications and whether further data are needed to 

support risk assessment. Table 14 provides information for studies conducted with the 

degradation product, CGA-321113. Rationale for the additional data requested is presented. 

Table 13. Submitted Environmental Fate Data for Trifloxystrobin 

OCSPP 

Guideline Data Requirement Submitted Studies (MRID) Study Classifications 

Are data needed to 

conduct risk 

assessment? 

835.2120 Hydrolysis 44496727 Acceptable No 

835.2240 Aqueous photolysis 44496727 Supplemental No 

835.2410 Soil photolysis 44496728 Acceptable No 

44496729 Acceptable 

835.4100 Aerobic soil metabolism 44496730 

44496731 

44496732 

Acceptable No

Acceptable

Acceptable

835.4200 Anaerobic soil 

metabolism 

No study No 

835.4300 Aerobic aquatic 

metabolism 

44496734 Supplemental No 

835.4400 Anaerobic aquatic 

metabolism 

44496733 Acceptable No 

835.1230 

835.1240 

Adsorption/ desorption 

and leaching 

44496802 Acceptable No 

44496803 Supplemental 

835.1410 Volatility – laboratory No study No 

835.6100 Terrestrial field 

dissipation 

44496897 Supplemental No 

44657203 Supplemental 

44496808 Supplemental 

44757204 Supplemental 

44496809 Supplemental 

44757205 Supplemental 

850.6100 Analytical method in soil 44496811 No 

850.6100 Analytical method in 

water 

44757206 In Review 

835.6200 Aquatic field dissipation 45080803 Supplemental No

 44496814 Supplemental 

44496810

44496811

44496815 
 Page 31 of 58 

OCSPP 

Guideline Data Requirement Submitted Studies (MRID) Study Classifications 

Are data needed to 

conduct risk 

assessment? 

165-4 (850.1730) Fish bioconcentration 44496813 Supplemental No 

Table 14. Submitted Environmental Fate Data for the Trifloxystrobin Degradate, CGA-321113 

OCSPP 

Guideline Data Requirement Submitted Studies (MRID) Study Classifications 

Are data needed to 

conduct risk 

assessment? 

835.2120 Hydrolysis 44496727 Acceptable No 

835.2240 Aqueous photolysis 44496727 Supplemental No 

835.2410 Soil photolysis 44496728 Acceptable No 

44496729 Acceptable 

835.1230 

835.1240 

Adsorption/ 

Desorption 

44496801 Acceptable No 

835.4100 Aerobic soil metabolism 44496730 

44496731 

44496732 

Acceptable No 

Acceptable

Acceptable

835.4300 Aerobic aquatic 

metabolism 

44496734 Supplemental No 

835.4400 Anaerobic aquatic 

metabolism 

44496733 Acceptable No 

835.6200 Aquatic Field Dissipation 45080803 Supplemental No 

835.1230 Adsorption/ desorption 44496801 Acceptable No 

10.2 Effects 

Tables 15 and 16 identify studies that have been submitted on the ecological effects of 

trifloxystrobin to aquatic and terrestrial organisms, respectively. These tables also provide the 

classifications of these studies and indicate whether further data are needed to support risk 

assessment. The ecological effects database for trifloxystrobin is complete except for the 

following studies, which are needed for ecological risk assessment: 

 Guideline 850.4500, Algal Toxicity (The guideline is satisfied for freshwater green algae, 

but additional testing is needed for a, a freshwater diatom, and a saltwater diatom.) 

 Guideline 850.4550, Cyanobacteria Toxicity (Additional testing is needed for a bluegreen 

algae.) 

 Guideline 850.4100, Terrestrial Plant Toxicity, Seedling Emergence Test 

 Guideline 850.4150, Terrestrial Plant Toxicity, Vegetative Vigor Test 

The algal toxicity testing with four species is needed for assessing risk for all outdoor uses of 

trifloxystrobin. To date, acceptable data have been provided for only one of the four 

recommended algal species (Selenastrum capricornutum). This study showed that trifloxystrobin 
 Page 32 of 58 

is toxic to algae at fairly low concentrations (EC50 = 37.1 μg/L), and is considerably more toxic to 

algae than it is to vascular aquatic plants like duckweed (EC50 > 1930 μg/L). Algal toxicity data 

are available for a closely related fungicidal active ingredient, kresoxim-methyl (PC Code 

129111). For this chemical, the algal toxicity levels were highly variable among species, ranging 

from 29.2 to > 233 μg a.i./L. The most sensitive species was Navicula pelliculosa (EC50 = 29.2 

μg/L), which was more sensitive than Selenastrum capricornutum (EC50 = 55.1 μg/L). Therefore, 

obtaining additional toxicity data for trifloxystrobin with other algal species may result in a lower 

endpoint than was obtained with Selenastrum capricornutum and may alter the risk conclusions 

for aquatic plants. 

The two terrestrial plant toxicity studies are needed only for assessing risk from uses of 

trifloxystrobin with maximum single-application rates greater than 0.25 lb a.i./A. Currently only 

turf uses are registered with single-application rates above this level (maximum rate for turf uses 

is 0.34 lb a.i./A). As discussed in Section 7.3, 12 incidents of plant damage have been reported 

that have been attributed to exposure to trifloxystrobin, with a certainty level of “probable.” This 

indicates that trifloxystrobin has the potential to be phytotoxic to sensitive plants. Furthermore, 

the phytotoxicity studies which have been submitted found some inhibition of plant growth in 

plants treated at a rate of 0.249 lb a.i./A (7-13% inhibition compared to the control). Thus, 

exposure at the 0.34 lb a.i./A rate could potentially result in inhibition above the 25% threshold 

for concluding risk to terrestrial plants. 

Table 15. Submitted Aquatic Ecological Effects Data for Trifloxystrobin 

OCSPP 

Guideline 

Data 

Requirement 

Submitted 

Studies 

(MRID) 

Study 

Classifications 

Are data 

needed to 

conduct 

risk 

assessment? 

Comments 

 850.1010 Freshwater 

invertebrate 

acute toxicity 

44496611 Acceptable No -- 

850.1035 

850.1045 

Saltwater 

crustacean 

acute toxicity 

44496614 Acceptable No -- 

850.1025 

850.1055 

Saltwater 

bivalve acute 

toxicity 

44496613 Acceptable No -- 

 850.1075 Freshwater 

fish acute 

toxicity 

44502802 Acceptable No -- 

44502803 Acceptable 

 850.1075 Saltwater fish 

acute toxicity 

44496612 Acceptable No -- 

 

 850.1300 Freshwater 

invertebrate 

life cycle 

44496615 Acceptable No -- 
 Page 33 of 58 

OCSPP 

Guideline 

Data 

Requirement 

Submitted 

Studies 

(MRID) 

Study 

Classifications 

Are data 

needed to 

conduct 

risk 

assessment? 

Comments 

 850.1350 Saltwater 

invertebrates 

life cycle 

-- -- No Chronic toxicity testing with a 

saltwater invertebrate was waived 

in 2011 because trifloxystrobin 

rapidly degrades in water to a 

degradation product with low 

toxicity, and because a risk 

assessment based on previously 

calculated aquatic EECs and a 

mysid EC05 estimated using the 

ACR method indicated that the 

chronic risk quotient would be 

below the LOC (see D389402) 

 850.1400 Freshwater 

fish 

early-life 

stage 

44502804 Acceptable No -- 

 850.1400 Saltwater fish 

early-life 

stage 

 No The acute toxicity data indicate 

that the freshwater test species 

(rainbow trout) is more sensitive to 

trifloxystrobin than the saltwater 

fish species (sheepshead minnow). 

Therefore, results of the rainbow 

trout early-life stage study should 

be protective of saltwater species 

as well. 

 850.1500 Fish life cycle No A fish full life-cycle study is not 

required because trifloxystrobin 

degrades rapidly in aerobic and 

anaerobic aquatic environments 

(half-lives < 1 day) and because 

previous risk assessments (based 

on the fish early-life stage toxicity 

endpoint) have found that the 

chronic RQ for fish is less than 1. 

850.4400 Aquatic plant 

toxicity test 

using Lemna 

spp. 

44496725 Supplemental No The study was classified as 

Supplemental because the test material 

was unstable. Because the test 

solutions were not renewed, 

concentrations of the test material 

declined dramatically during the 

exposure period. Nevertheless, the 

results demonstrate that duckweed is 

likely less sensitive to trifloxystrobin 

than is algae. Therefore this test does 

not need to be repeated
 Page 34 of 58 

OCSPP 

Guideline 

Data 

Requirement 

Submitted 

Studies 

(MRID) 

Study 

Classifications 

Are data 

needed to 

conduct 

risk 

assessment? 

Comments 

850.4500 Algal 

Toxicity 

44496724 

45561701 

Acceptable 

Invalid 

Yes The submitted study with 

Selenastrum capricornutum was 

acceptable, but satisfies the test 

guideline only for testing of 

freshwater green algae. Testing is 

also needed with a bluegreen alga, 

a freshwater diatom, and a 

saltwater diatom. 

850.4550 Cyanobacteria 

Toxicity 

None None Yes Testing is also needed with a 

bluegreen alga 

Table 16. Submitted Terrestrial Ecological Effects Data for Trifloxystrobin

OCSPP 

Guideline 

Data 

Requirement 

Submitted 

Studies 

(MRID) 

Study 

Classifications 

Are data 

needed for 

risk 

assessment? 

Current Additional Data Need 

 850.2100 Avian oral 

toxicity 

44496605 Acceptable No An acute toxicity study with a 

passerine is not requested because 

acute and subacute testing with the 

bobwhite and mallard indicate that 

trifloxystrobin is practically nontoxic 

to birds. Considering the low use rates 

of trifloxystrobin, acute risk to 

passerine birds is extremely unlikely.

44496606 Acceptable 

 850.2200 Avian dietary 

toxicity 

44496607 Acceptable No -- 

44496608 Acceptable 

 850.2300 Avian 

reproduction 

44496609 Acceptable No -- 

44496610 Acceptable 

Nonguideline Avian 

inhalation 

-- -- No The STIR model determined that 

inhalation exposure alone does not 

have potential to be a pathway of 

concern for acute or chronic risk to 

wildlife. 

 850.3020 Honey bee 

acute contact 

toxicity 

44496726 Acceptable No -- 

850.3030 Honey bee 

residue on 

foliage 

-- -- No Because trifloxystrobin was found to 

be practically nontoxic to bees on an 

acute basis, and does not have a mode 

of action that suggests reproductive or 

developmental effects in insects would 

be likely, higher tier testing with bees 

is not required. 

 850.3040 Field testing 

for pollinators 

-- -- No
 Page 35 of 58 

OCSPP 

Guideline 

Data 

Requirement 

Submitted 

Studies 

(MRID) 

Study 

Classifications 

Are data 

needed for 

risk 

assessment? 

Current Additional Data Need 

850.4100 Terrestrial 

plant toxicity: 

Tier I seedling 

emergence 

44496723 Acceptable Yes While these submitted tier-1 studies 

are acceptable for showing lack of 

phytotoxicity for uses with application 

rates up to 0.25 lb a.i./A, new tier-1 

plant toxicity studies are needed that 

test plants up to the 0.34 lb a.i./A, the 

maximum application rate for use on 

turf.

850.4150 Terrestrial 

plant toxicity: 

Tier I 

vegetative 

vigor 

44496723 Acceptable Yes 

The only degradation product of trifloxystrobin that is expected to occur in the environment in 

significant quantities is CGA-321113. Information on available in vivo toxicity studies is 

provided in Table 17. While these studies have deficiencies that introduce uncertainty in their 

findings, they are adequate to show that this degradation product is much less toxic than the 

parent compound. Toxicity endpoints in these studies were over three orders of magnitude 

greater than those for trifloxystrobin (see Tables 7 and 8). This conclusion is further supported by 

the findings of an in vitro cytotoxicity study using rat hepatocyte cultures (MRID 44496720). 

This study found that CGA-321113 is much less toxic to hepatocyte cells than trifloxystrobin and 

does not cause inhibition of cellular respiration as does the parent compound. Taken together, 

these studies provide adequate evidence that CGA-321113 exhibits much less toxicity to 

nontarget organisms than does the parent compound, trifloxystrobin. Therefore, this degradation 

product will not be considered a stressor of concern in the ecological risk assessment for 

trifloxystrobin, and no additional toxicity data on CGA-321113 are needed. 

Table 17. Aquatic Ecological Effects Data for the Trifloxystrobin Degradate, CGA-321113 

OCSPP 

Guideline 

Data 

Requirement 

Submitted 

Studies 

(MRID) 

Study 

Classifications 

Are data 

needed for 

risk 

assessment? 

Current Additional Data Need 

 850.1010 Freshwater 

invertebrate 

acute toxicity 

44527503 Supplemental No Although water parameters deviated 

from ranges recommended by our test 

guidelines, the study is sufficient to 

demonstrate that this degradation 

product is practically nontoxic to 

freshwater invertebrates and is 

significantly less toxic than the parent 

compound. 

 850.1075 Freshwater fish 

acute toxicity 

44527502 Supplemental No Although water parameters deviated 

from ranges recommended by our test 

guidelines, the study is sufficient to 

demonstrate that this degradation 

product is practically nontoxic to 

freshwater fish and is significantly less 

toxic than the parent compound. 
 Page 36 of 58 

OCSPP 

Guideline 

Data 

Requirement 

Submitted 

Studies 

(MRID) 

Study 

Classifications 

Are data 

needed for 

risk 

assessment? 

Current Additional Data Need 

 850.1300 Freshwater 

invertebrate 

life cycle 

44869701 Supplemental No This study did not follow the experimental 

design prescribed by the test guideline and 

did not evaluate growth parameters (dry 

weight or length). It nevertheless provides 

evidence that the chronic toxicity of this 

degredation product is much less than that 

of the parent compound. 

850.5400 Aquatic Plant 

Growth: 

Tier II algae 

4452704 Supplemental No Although water parameters deviated 

from ranges recommended by our test 

guidelines, the study is sufficient to 

demonstrate that this degradation 

product has much less toxicity to algae 

than the parent compound. 

11.0 References 

USEPA. 2004. Overview of the Ecological Risk Assessment Process in the Office of Pesticide 

Programs. United States Environmental Protection Agency (USEPA). Environmental 

Fate and Effects Division. Office of Pesticide Programs. Available at 

http://www.epa.gov/espp/consultation/ecorisk-overview.pdf.
37

12.0 Appendices 

Appendix A 

Screening Level Usage Analysis (SLUA) 

Trifloxystrobin (129112)

Date: 15 May 2012

What is a Screening Level Usage Analysis (SLUA)?

 Available estimates of pesticide usage data for a particular active ingredient that is 

used on agricultural crops in the United States. 

 Pesticide usage data obtained from various sources. The data are then merged, 

averaged, and rounded so that the presented information is not proprietary, business 

confidential, or trade secret. 

What does it contain? 

 Pesticide usage data for a single active ingredient only. 

 Agricultural use sites (crops) that the pesticide is reported to be used on. 

 Available pesticide usage information from U.S. states that produce 80% or more of a 

crop, in most cases, or less than 80%, in rare cases, depending on the scope of the 

survey and available resources. 

 Annual percent of crop treated (average & maximum) for each agricultural crop. 

 Average annual pounds of the pesticide applied for each agricultural crop (i.e., for the 

states surveyed, not for the entire United States). 

What assumptions can I make about the reported data? 

 Average pounds of active ingredient applied - Values are calculated by merging 

pesticide usage data sources together; averaging across all observations, then 

rounding. Note: If the estimated value is less than 500, then that value is labeled 

<500. Estimated values between 500 & <1,000,000 are rounded to 1 significant 

digit. Estimated values of 1,000,000 or greater are rounded to 2 significant digits.)

 Average percent of crop treated - Values are calculated by merging data sources 

together; averaging by year, averaging across all years, & rounding to the nearest 

multiple of 5. Note: If the estimated value is less than 2.5, then the value is labeled 

<2.5. If the estimated value is less than 1, then the value is labeled <1.

 Maximum percent of crop treated - Value is the single maximum value reported 

across all data sources, across all years, & rounded up to the nearest multiple of 5. 

Note: If the estimated value is less than 2.5, then the value is labeled <2.5.

What are the data sources used? 

 USDA-NASS (United States Department of Agriculture’s National Agricultural 

Statistics Service) – pesticide usage data from 2003 to 2010. 

 Private pesticide market research – pesticide usage data from 2003 to 2010. 

 California Department of Pesticide Regulation (DPR) Pesticide Use Reporting

(PUR) data for 2003 to 2010. 

What are the limitations to the data? 

 Additional registered uses may exist but are not included because the available 

surveys do not report usage (e.g., small acreage crops). 
38

 Lack of reported usage data for the pesticide on a crop does not imply zero usage. 

 Usage data on a particular site may be noted in data sources, but not quantified. In 

these instances, the site would not be reported in the SLUA. 

 Non-agricultural use sites (e.g., turf, post-harvest, mosquito control, etc.) are not 

reported in the SLUA. A separate request must be made to receive these estimates. 

 Some sites show some use, even though they are not on the label. This usage could 

be due to various factors, including, but not limited to Section 18 requests, existing 

stocks of the chemical, data collection errors, and experimental use permits (EUPs). 

 
39

15 May 2012 

Screening Level Estimates of Agricultural Uses of Trifloxystrobin (129112)

Reporting Time: 2003-2010 

Percent Crop Treated 

Crop Lbs. A.I. Average Maximum 

1 Almonds 3,000 5 10 

2 Apples 9,000 25 35 

3 Apricots <500 10 20 

4 Cantaloupes 1,000 10 15 

5 Celery 1,000 20 30 

6 Cherries 2,000 15 30 

7 Corn 60,000 <2.5 <2.5 

8 Cotton (Seed Treatment) <500 5 10 

9 Cucumbers <500 <1 <2.5 

10 Dry Beans/Peas <500 <1 <2.5 

11 Grapefruit 3,000 20 40 

12 Grapes 20,000 25 40 

13 Hazelnuts 2,000 55 75 

14 Nectarines ** <500 N/C N/C 

15 Oranges 3,000 5 10 

16 Peaches <500 <2.5 5 

17 Peanuts 10,000 10 15 

18 Peanuts (Seed Treatment) 1,000 5 10 

19 Pears 1,000 15 30 

20 Pecans 10,000 15 20 

21 Peppers 1,000 5 10 

22 Pistachios 1,000 10 15 

23 Plums/Prunes <500 <2.5 <2.5 

24 Potatoes <500 <1 <2.5 

25 Pumpkins <500 5 15 

26 Rice 50,000 10 20 

27 Soybeans 30,000 <1 <2.5 

28 Soybeans (Seed Treatment) 9,000 5 10 

29 Squash <500 <2.5 5 

30 Strawberries <500 5 5 

31 Sugar Beets 7,000 5 10 

32 Tangelos <500 <1 <2.5 

33 Tangerines <500 5 10 

34 Tomatoes <500 <1 <2.5 

35 Walnuts <500 <1 <2.5 
40

36 Watermelons 1,000 5 10 

37 Wheat 30,000 <2.5 <2.5 

All numbers rounded. 

<500 Less than 500 pounds of active ingredient 

<2.5 Less than 2.5 percent of crop treated 

<1 Less than 1 percent of crop treated 

N/C Not calculated 

** Based on CA DPR data only (valid because a majority of U.S. acres grown are in California) 

++ Crops not known to be listed on active end use product registrations or as Section 18 emergency 

exemptions when this report was run 

 

SLUA data sources include: 

USDA-NASS (United States Department of Agriculture's National Agricultural Statistics Service) 

Private Pesticide Market Research 

California DPR (Department of Pesticide Regulation) 

These results reflect amalgamated data developed by the Agency and are releasable to the public. 

 
41

Appendix B 

Trifloxystrobin Bibliography 

PART A: Ecological Effects 

Avian Single Dose Oral Toxicity 

MRID Citation Reference 

44496605 Palmer, S.; Beavers, J. (1996) An Acute Oral Toxicity of CGA-279202 with the 

Mallard: Lab Project Number: 108-381: 116-96. Unpublished study prepared by 

Wildlife International Ltd. 41 p. 

44496606 Redgrave, V. (1995) Acute Oral Toxicity (LD50) of CGA-279202 to the 

Bobwhite Quail: Lab Project Number: 703/942994: 479-94. Unpublished study 

prepared by Huntingdon Research Centre. 37 p. 

Avian Dietary Toxicity 

MRID Citation Reference 

44496607 Rodgers, M. (1995) Subacute Dietary Toxicity (LC50) of CGA-279202 to the 

Bobwhite Quail: Lab Project Number: 700/942798: 480-94. Unpublished study 

prepared by Huntingdon Research Centre. 34 p. 

44496608 Rodgers, M. (1995) Subacute Dietary Toxicity (LC50) of CGA-279202 to the 

Mallard Duck: Lab Project Number: 701/942791: 481-94. Unpublished study 

prepared by Huntingdon Research Centre. 34 p. 

Avian Reproduction 

MRID Citation Reference 

44496609 Rodgers, M. (1996) CGA-279202: Effects on Reproduction in Bobwhite Quail 

after Dietary Administration: Lab Project Number: 712/952489: 478-94: CBG 

712. Unpublished study prepared by Huntingdon Life Science, Ltd. 258 p. 

44496610 Mitchell, L.; MacGregor, J.; Beavers, J. et al. (1996) CGA-279202: A 

Reproduction Study with the Mallard: Lab Project Number: 108-382: 117-96. 

Unpublished study prepared by Wildlife International Ltd. 178 p. 
42

Acute Toxicity to Freshwater Fish 

MRID Citation Reference 

44502802 Rufli, H. (1997) Acute Toxicity Test of CGA-279202 to Bluegill (Lepomis 

macrochirus) Under Flow-Through Conditions: Lab Project Number: 963541: 

723-97: 23788. Unpublished study prepared by Novartis Crop Protection AG. 

63 p. 

44502803 Rufli, H. (1997) Acute Toxicity Test of CGA-279202 to Rainbow Trout 

(Oncorhynchus mukiss) in the Flow-Through System: Lab Project Number: 

963564: 484-96: 23788. Unpublished study prepared by Novartis Crop 

Protection AG. 56 p. 

44527502 Rufli, H. (1996) Acute Toxicity Test of CGA-321113 (Metabolite of CGA279202) to Rainbow Trout (Oncorhynchus mykiss) in the Flow-Through 

System: Lab Project Number: 953568: 787-95: AN2-95-02. Unpublished study 

prepared by Ciba-Geigy Limited. 45 p. 

Fish acute toxicity test, freshwater and marine 

MRID Citation Reference 

47567514 Dorgerloh, M. (2007) Acute Toxicity of Fluopyram & Trifloxystrobin SC 500 

(250+250) G to Fish (Oncorhynchus mykiss) Under Static Conditions. Project 

Number: M/294350/01/2, EBGMP030, E/280/3307/3. Unpublished study 

prepared by Bayer CropScience AG. 72 p. 

Reviewer Note: Fluopyram still pending registration on 10/02/11 

Acute Toxicity to Freshwater Invertebrates 

MRID Citation Reference 

44496611 Boeri, R.; Magazu, J.; Ward, T. (1997) Acute Toxicity of CGA-279202 to the 

Daphnid, Daphnia magna: Lab Project Number: 1116-CG: 133-94. 

Unpublished study prepared by T.R. Wilbury Laboratories, Inc. 30 p. 

44527503 Neumann, C. (1996) Acute Toxicity Test of CGA-321113 (Metabolite of CGA279202) to the Cladoceran Daphnia magna STRAUS Under Static Conditions: 

Lab Project Number: 953569: 785-95: AN2-95-02. Unpublished study prepared 

by Ciba-Geigy Limited. 43 p. 

45561701 Desjardins, D.; Kendall, T.; Krueger, H. (2001) Trifloxystrobin (CGA-279,202): 

A 96-Hour Toxicity Test with the Freshwater Diatom (Navicula pelliculosa): Lab 

Project Number: 149-132A. Unpublished study prepared by Wildlife 

International, Ltd. 51 p. {OPPTS 850.5400} 

Aquatic invertebrate acute toxicity, test, freshwater daphnids 
43

MRID Citation Reference 

47567513 Bruns, E. (2007) Acute Toxicity of AE C656948 + Trifloxystrobin SC 250 + 250 

G to the Waterflea Daphnia magna in a Static Laboratory Test System. Project 

Number: M/292365/01/2, EBGMP031, 320/3236/9. Unpublished study 

prepared by Bayer CropScience AG. 73 p. 

48055701 Grade, R. (1999) Acute Toxicity of CGA 279202 Tech. to the Cladoceran 

Daphnia magna STRAUS in the Static System: Final Report. Project Number: 

993543, MO/01/008203. Unpublished study prepared by Novartis Crop 

Protection, AG. 51 p. 

Acute Toxicity to Estuarine/Marine Organisms 

MRID Citation Reference 

44496612 Boeri, R.; Magazu, J.; Ward, T. (1996) Acute Toxicity of CGA-279202 to the 

Sheepshead Minnow, Cyprinodon variegatus: Lab Project Number: 672-CG: 3-

95. Unpublished study prepared by T.R. Wilbury Laboratories, Inc. 30 p. 

44496613 Boeri, R.; Magazu, J.; Ward, T. (1996) Acute Flow-Through Mollusc Shell 

Deposition Test with CGA-279202: Lab Project Number: 674-CG: 5-95: 

AT871B. Unpublished study prepared by T.R. Wilbury Labs., Inc. 31 p. 

44496614 Boeri, R.; Magazu, J.; Ward, T. (1996) Acute Toxicity of CGA-279202 to the 

Mysid, Mysidopsis bahia: Lab Project Number: 673-CG: 4-95: AT871B. 

Unpublished study prepared by T.R. Wilbury Laboratories, Inc. 31 p. 

Fish Early Life Stage/Aquatic Invertebrate Life Cycle Study 

MRID Citation Reference 

44496615 Boeri, R.; Magazu, J.; Ward, T. (1996) Chronic Toxicity of CGA-279202 to the 

Daphnid, Daphnia magna: Lab Project Number: 1117-CG: 134-94. 

Unpublished study prepared by T.R. Wilbury Laboratories, Inc. 44 p. 

44502804 Rufli, H. (1997) Early-Life Stage Toxicity of CGA-279202 to Rainbow Trout 

(Oncorhynchus mykiss) Using Newly Fertilized "Green" Eggs in a FlowThrough System: Lab Project Number: 943530: 483-96. Unpublished study 

prepared by Novartis Crop Protection AG. 103 p. 

44869701 Memmert, U. (1998) Influence of CGA-321113 (Metabolite of CGA-279202) on 

Survival and Reproduction of Daphnia Magna in a Semi-Static Test Over 22 

Days: Lab Project Number: 690502: 1157-98: 690513. Unpublished study 

prepared by RCC Umweltchemie AG. 41 p. 

 
44

Mysid chronic toxicity test 

MRID Citation Reference 

48424601 Ortego, L. (2011) Waiver Request for a Mysid Life-Cycle Study with 

Trifloxystrobin. Project Number: US0168. Unpublished study prepared by 

Bayer CropScience LP. 4 p. 

Simulated or Actual Field Testing 

MRID Citation Reference 

44496616 Cairns, S.; Kennedy, J.; Melloh, A. et al. (1996) Assessment of the Potential 

Biological Effects of CGA-279202 Exposures on Aquatic Ecosystems as 

Measured in an Outdoor Fiberglass Tank System (Microcosms): Lab Project 

Number: CGA-279202: 94-96: 279202. Unpublished study prepared by Univ. of 

North Texas and ABC Laboratories, Inc. 951 p. 

44496617 Cairns, S. (1997) Assessment of the Potential Biological Effects of CGA279202 Exposures on Aquatic Ecosystems as Measured in an Outdoor 

Fiberglass Tank System: Lab Project Number: 43274: 304-96: 279202. 

Unpublished study prepared by ABC Laboratories, Inc. 357 p. 

Seed Germination/Seedline Emergence and Vegetable Vigor 

MRID Citation Reference 

44496723 Schwab, D. (1997) Evaluating the Effects of CGA-279202 on the 

Emergence and Vegetative Vigor of Non-Target Terrestrial Plants: Lab 

Project Number: 43964: 385-97. Unpublished study prepared by ABC 

Laboratories, Inc. 56 p. 

Terrestrial plant toxicity, Tier 1 (seeding emergence) 

MRID Citation Reference 

47567516 Gosch, H.; Nguyen, D. (2007) Non-target Terrestrial Plants: an Evaluation of 

the Effects of AE C656948 + Trifloxystrobin SC 250 + 250 g/L in the Seedling 

Emergence and Growth Test (Tier 1). Project Number: M/289525/01/2, 

SE07/03, EBGMP028. Unpublished study prepared by Bayer Cropscience AG. 

20 p. 

47567517 Gosch, H.; Nguyen, D. (2007) Non-target Terrestrial Plants: an Evaluation of 
45

the Effects of AE C656948 + Trifloxystrobin SC 250 + 250 g/L in the Vegetative 

Vigour Test (Tier 1). Project Number: M/289527/01/2, VV07/03, EBGMP026. 

Unpublished study prepared by Bayer Cropscience AG. 19 p. 

Terrestrial plant toxicity, Tier 1 (vegetative vigor) 

MRID Citation Reference 

47567517 Gosch, H.; Nguyen, D. (2007) Non-target Terrestrial Plants: an Evaluation of 

the Effects of AE C656948 + Trifloxystrobin SC 250 + 250 g/L in the Vegetative 

Vigour Test (Tier 1). Project Number: M/289527/01/2, VV07/03, EBGMP026. 

Unpublished study prepared by Bayer Cropscience AG. 19 p. 

Aquatic plant growth 

MRID Citation Reference 

44527504 Grade, R. (1996) Growth Inhibition Test of CGA-321113 (Metabolite of CGA279202) to Green Algae (Selenastrum capricornutum) in a Static System: Lab 

Project Number: 953570: 786-95. Unpublished study prepared by Ciba-Geigy 

Limited. 43 p. 

Aquatic plant growth 

MRID Citation Reference 

44496724 Ward, T.; Magazu, J.; Boeri, R. (1996) Toxicity of CGA-279202 to the 

Freshwater Alga, Selenastrum capricornutum CGA-279202: Lab Project 

Number: 670-CG: 8-95. Unpublished study prepared by T.R. Wilbury 

Laboratories, Inc. 32 p. 

44496725 Ward, T.; Magazu, J.; Boeri, R. (1996) Toxicity of CGA-279202 to the 

Duckweed, Lemna gibba G3: Lab Project Number: 671-CG: 7-95. Unpublished 

study prepared by T.R. Wilbury Laboratories, Inc. 32 p. 

Algal toxicity, Tiers 1 and II 

MRID Citation Reference 
46

47567518 Dorgerloh, M. (2007) Pseudokirchneriella subcapitata Growth Inhibition Test 

with Fluopyram & Trifloxystrobin SC 500 (250 + 250)G. Project Number: 

M/292579/01/2, EBGMP032, E/323/3111/4. Unpublished study prepared by 

Bayer CropScience AG. 61 p. 

Honey bee acute contact 

MRID Citation Reference 

44496726 Kleiner, R. (1995) Testing Toxicity of CGA-279202 to Honey Bee--Apis mellifera 

L: Lab Project Number: 95 10 48 023: 774-95. Unpublished study prepared by 

BioChem GmbH Karlsruhe 20 p. 

Honey bee acute contact toxicity 

MRID Citation Reference 

47567515 Schmitzer, S. (2007) Effects of AE C656948+trifloxystrobin SC 250+250 g/L 

(Acute Contact and Oral) on Honey Bees (Apis mellifera L.) in the Laboratory. 

Project Number: M/288193/01/2, 34491035, EBGMP034. Unpublished study 

prepared by Institut fuer Biologische Analytik und Consulting IBACON. 33 p. 

Earthworm subchronic toxicity test 

MRID Citation Reference 

47567519 Leicher, T. (2007) AE C656948 & Trifloxystrobin SC 250 & 250: Acute Toxicity 

to Earthworms (Eisenia fetida) Tested in Artificial Soil with 5 Percent Peat. 

Project Number: M/284363/01/2, LRT/RG/A/77/06, E/310/3224/5. Unpublished 

study prepared by Bayer CropScience AG. 24 p. 

47567520 Leicher, T. (2007) AE C656948 & Trifloxystrobin SC 250 & 250 G: Effects on 

Survival, Growth and Reproduction on the Earthworm Eisenia fetida Tested in 

Artificial Soil with 5 Percent Peat. Project Number: M/283637/01/2, 

LRT/RG/R/28/06, E/312/3217/9. Unpublished study prepared by Bayer 

CropScience AG. 43 p. 

Non Target Beneficial Insect Toxicity 

MRID Citation Reference 

47567521 Roehlig, U. (2007) Dose-response Toxicity (LR50) of AE C656948 & 

Trifloxystrobin SC 250 + 250 g/L to the Predatory Mite Typhlodromus pyri 

(Scheuten) Under Laboratory Conditions. Project Number: M/283552/01/2, 

06/10/48/190, EBGMP036. Unpublished study prepared by Biochem Agrar, 
47

Labor fuer Biologische und Chemische. 26 p. 

47567522 Roehlig, U. (2007) Dose-response Toxicity (LR50) of AE C656948 & 

Trifloxystrobin SC 250 + 250 g/L to the Parasitic Wasp Aphidius rhopalosiphi 

(Destefani-Perez) Under Laboratory Conditions: Final Report. Project Number: 

M/283599/01/2, 06/10/48/189, EBGMP037. Unpublished study prepared by 

Biochem Agrar, Labor fuer Biologische und Chemische. 25 p. 

47567523 Barth, M. (2007) Dose-response Toxicity of AE C656948 & Trifloxystrobin SC 

250 + 250 to the Predatory Bug Orius laevigatus (FIEBER) (Heteroptera: 

Anthocoridae) Under Extended Laboratory Conditions. Project Number: 

M/297476/01/2, 07/10/48/049/A. Unpublished study prepared by Biochem Agrar, 

Labor fuer Biologische und Chemische. 31 p. 

47567526 Barth, M. (2008) Toxicity of AE C656948 & Trifloxystrobin SC 250 + 250 to the 

Predatory Bug Orius laevigatus (FIEBER) (Heteroptera: Anthocoridae) Under 

Extended Laboratory Conditions Using Semi-field-aged Residues on Grapevine: Final Report. Project Number: M/297471/01/2, 07/10/48/005/A, 

EBGMP120. Unpublished study prepared by Biochem Agrar, Labor fuer 

Biologische und Chemische. 48 p. 

Non Guideline Selections 

MRID Citation Reference 

44496618 Pugsley, R.; Williams, W. (1997) Probabilistic Modeling of CGA-279202 Exposure 

to Aquatic Nontarget Organisms Associated with use on Six Crops: Turf, Cucurbits, 

Grapes, Potatoes, Apples, and Peanuts: Lab Project Number: WEI 242.20: 399-97. 

Unpublished study prepared by Waterborne Environmental, Inc. 212 p. 

44496846 Warren, J. (1997) Terrestrial and Aquatic Ecological Risk Assessment for: CGA279202: Lab Project Number: 738-97. Unpublished study prepared by Novartis 

Crop Protection, Inc. 9 p. 

 

 
48

Trifloxystrobin Bibliography 

PART B: Environmental Fate 

Hydrolysis 

MRID Citation Reference 

44496727 Cohen, S. (1997) Photodegradation of (phenyl(A)-(U)-(carbon 14))-CGA279202 in an Aqueous Buffered Solution under Artificial Sunlight and 

Hydrolysis in pH 5, 7 and 9 Buffered Solution: Lab Project Number: ME 

9600199: 273-96. Unpublished study prepared by Pittsburgh Environmental 

Research Laboratory, Inc. 399 p. 

Photodegradation-water 

MRID Citation Reference 

44496727 Cohen, S. (1997) Photodegradation of (phenyl(A)-(U)-(carbon 14))-CGA279202 in an Aqueous Buffered Solution under Artificial Sunlight and 

Hydrolysis in pH 5, 7 and 9 Buffered Solution: Lab Project Number: ME 

9600199: 273-96. Unpublished study prepared by Pittsburgh Environmental 

Research Laboratory, Inc. 399 p. 

Photodegradation-soil 

MRID Citation Reference 

44496728 Cohen, S. (1997) Photodegradation of (phenyl(A)-U-(carbon 14))-CGA279202 on a Loamy Sand under Artificial Sunlight Irradiation: Lab Project 

Number: ME 9400174: 367-94. Unpublished study prepared by Pittsburgh 

Environmental Research Laboratory, Inc. 278 p. 

44496729 Cohen, S. (1997) Photodegradation of (phenyl(B)-U-(carbon 14))-CGA279202 on a Loamy Sand under Artificial Sunlight Irradiation: Lab Project 

Number: ME 9500196: 31-95. Unpublished study prepared by Pittsburgh 

Environmental Research Laboratory, Inc. 398 p. 

Aerobic soil metabolism 

MRID Citation Reference 

44496730 Pike, S. (1997) Metabolism of (phenyl(B)-U-(carbon 14))-CGA-279202 in a 

Typical Sandy Loam Soil Under Aerobic Conditions: Lab Project Number: 
49

1781.1295.6520.760: 670-95: 97-2-6873. Unpublished study prepared by 

Springborn Laboratories, Inc. 379 p. 

44496731 Fackler, P. (1997) Metabolism of (phenyl(A)-U-(carbon 14))-CGA-279202 in a 

Typical Sandy Loam Soil Under Aerobic Conditions: Lab Project Number: 

1781.1295.6518.760: 516-95. Unpublished study prepared by Springborn 

Laboratories, Inc. 462 p. 

44496732 Fathulla, R. (1997) Aerobic Soil Metabolism of (U)(carbon 14)-PhenylGlyoxylat-CGA-279202 in a Loamy Sand Soil: Lab Project Number: HWI 

6117-268: 277-94. Unpublished study prepared by Hazleton Wisconsin, Inc. 

302 p. 

44757201 McLaughlin, S. (1999) Metabolism of (Phenyl(B)-(carbon-14)-CGA-279202 in 

a Typical Sandy Loam Soil under Aerobic Conditions: Amended Final Report: 

Lab Project Number: 1781.1295.6520.00760: 670-958: 97-5-6. Unpublished 

study prepared by Springborn Laboratories, Inc. 401 p. 

Anaerobic aquatic metab. 

MRID Citation Reference 

44496733 Fathulla, R. (1996) Anaerobic Aquatic Metabolism of (U)(carbon 14)-PhenylGlyoxylat-CGA-279202 in a Loamy Sand Soil/Water System: Lab Project 

Number: HWI 6117-266: 0278-94: 6117-266. Unpublished study prepared by 

Hazleton Wisconsin, Inc. 212 p. 

Aerobic aquatic metab. 

MRID Citation Reference 

44496734 Atkins, R.; Nixon, W.; Coody, P. (1997) Aerobic Aquatic Metabolism of 

(phenyl(A)-U-(carbon 14))-CGA-279202: Lab Project Number: 1057: 290-96. 

Unpublished study prepared by PTRL East, Inc. and Agvise Laboratories. 183 

p. 

45080802 Merritt, A. (2000) Response to the US EPA EFED OPP July 28, 1999 Review 

of the Trifloxystrobin Aerobic Aquatic Metabolism Study: Lab Project Number: 

937-99: 1057. Unpublished study prepared by Novartis Crop Protection, Inc. 

55 p. 

Aerobic aquatic metabolism 

MRID Citation Reference 

48441901 Kitschmann, P. (1997) Degradation and Metabolism of [Trifluoromethyl-Phenyl-

(U)-(Carbon 14)] Labeled CGA 279202 in Two Aquatic Systems. Project 

Number: MO/01/001631, 95PK03. Unpublished study prepared by Novartis 
50

Crop Protection, AG. 149 p. 

48441902 Ulbrich, R. (1997) Degradation and Metabolism of (U)-(Carbon 14)-PhenylGlyoxylat-Labeled CGA 279202 in Two Aquatic Systems. Project Number: 

95UL02, MO/01/001628. Unpublished study prepared by Novartis Crop 

Protection, AG. 132 p. 

Leach/adsorp/desorption 

MRID Citation Reference 

44496801 Heim, L.; Velagaleti, R. (1997) Adsorption-Desorption of (phenyl (A)-U-(carbon 

14)-CGA-321113 in Soil: Lab Project Number: 43333: 274-96: ABC 43333. 

Unpublished study prepared by Analytical Bio-Chemistry (ABC) Labs., Inc. 387 

p. 

44496802 Heim, L.; Velagaleti, R. (1997) Soil Adsorption/Desorption of (carbon 14)-CGA279202 by the Batch Equilibrium Method: Lab Project Number: 42456: 69-95: 

ABC 42456. Unpublished study prepared by Analytical Bio-Chemistry (ABC) 

Labs., Inc. 371 p. 

44496803 Fackler, P. (1997) (Phenyl(A)-U-(carbon 14)-CGA-279202--Determination of 

Mobility in Seven Soils by the Aged-Soil Column Leaching Method and MiniSoil Metabolism Study on Each Soil: Lab Project Number: 437-95: 

1781.0695.6507.780: 96-9-6691. Unpublished study prepared by Springborn 

Labs., Inc. 975 p. 

44496804 Heim, L.; Velagaleti, R. (1997) Adsorption-Desorption of (phenyl (B)-U-(carbon 

14)-CGA-357276 in Soil: Lab Project Number: 43840: 210-97: ABC 43840. 

Unpublished study prepared by Analytical Bio-Chemistry (ABC) Labs., Inc. 348 

p. 

44496805 Heim, L.; Velagaleti, R. (1997) Adsorption-Desorption of (phenyl (B)-U-(carbon 

14)-CGA-357261 in Soil: Lab Project Number: 43839: 211-97: ABC 43839. 

Unpublished study prepared by Analytical Bio-Chemistry (ABC) Labs., Inc. 419 

p. 

44496806 Heim, L.; Velagaleti, R. (1997) Adsorption-Desorption of (phenyl (B)-U-(carbon 

14)-CGA-373466 in Soil: Lab Project Number: 43658: 397-96: ABC 43658. 

Unpublished study prepared by Analytical Bio-Chemistry (ABC) Labs., Inc. 430 

p. 

44496814 Heim, L.; Velagaleti, R. (1997) Mobility and Degradation of (phenyl (A)-U-

(carbon 14)-CGA-279202 as Determined Using Field Lysimeters: Lab Project 

Number: 41925: 294-94: ABC 41925. Unpublished study prepared by 

Analytical Bio-Chemistry (ABC) Labs., Inc. 313 p. 

44757202 Damon, A. (1999) Supplemental Investigation of the Adsorption-Desorption 

Properties of (carbon-14)-CGA-279202 to Soils Z and 144: Lab Project 

Number: 44775: 518-98. Unpublished study prepared by Analytical BioChemistry (ABC) Laboratories, Inc. 270 p. 
51

Terrestrial field dissipation 

MRID Citation Reference 

44496807 Judy, D.; Manuli, P. (1997) Dissipation of CGA-279202 in Soil Under Field 

Conditions with and without Peanuts in Georgia: Final Report: Lab Project 

Number: 22-96: 43289: ABC 43289. Unpublished study prepared by Analytical 

Bio-Chemistry (ABC) Labs., Inc., Research Options, Inc., and En-Cas 

Analytical Labs. 428 p. 

44496808 Leppert, B.; Hofen, J. (1997) Terrestrial Field Dissipation Study for CGA279202 in New York: Lab Project Number: 23-96: SARS-96-NY-87: AG-654. 

Unpublished study prepared by Stewart Agricultural Research Services, Inc., 

ACDS Research, Inc., and EPL Bio-Analytical Services, Inc. 450 p. 

44496809 

 

Belcher, T. (1997) Terrestrial Field Dissipation of CGA-279202 on Crop 

(Cucurbits) and Bare Soil in California: Lab Project Number: 24-96: 96574: 

ADPEN-901-24-96-001. Unpublished study prepared by ABC Labs., Califorinia, 

ADPEN Labs., Inc. and Plant Sciences, Inc. 287 p. 

44757203 Winkler, D. (1998) Dissipation of CGA-279202 in Soil Under Field Conditions 

with and without Peanuts in Georgia: Addendum to Final Report: Lab Project 

Number: 22-96: 96-0067. Unpublished study prepared by EN-CAS Analytical 

Laboratories. 69 p. 

44757204 Mayer, J.; Gold, B. (1998) Terrestrial Field Dissipation Study for CGA-279202 

in New York: Final Report Addendum: Lab Project Number: 23-96: 110S37. 

Unpublished study prepared by EPL Bio-Analytical Services, Inc. 58 p. 

44757205 Perez, R.; Gold, B. (1998) Terrestrial Field Dissipation of CGA-279202 on Crop 

(Cucurbits) and Bare Soil in California: Final Report Addendum: Lab Project 

Number: 24-96: ADPEN-901-96-24-96: ADPEN-901-24-96-001. Unpublished 

study prepared by ADPEN Laboratories, Inc. 75 p. 

Aquatic field dissipation 

MRID Citation Reference 

45080803 Manuli, P.; Jacobson, B. (2000) Aquatic Field Dissipation of CGA-279202 Under 

Field Conditions with Rice in Arkansas: Final Report: Lab Project Number: 

242.40: 283-98: 003-034. Unpublished study prepared by Waterborne 

Environment, Inc. 533 p. 

 
52

Fish Bioaccumulation 

MRID Citation Reference 

44496813 Mollova, N. (1997) (Phenyl(A)-U-(carbon 14)-CGA-279202--Flow-Through 

Bioconcentration and Metabolism Study with Bluegill Sunfish (Lepomis 

macrochirus): Lab Project Number: 1781.1195.6517.140: 19-96: 96-8-6608. 

Unpublished study prepared by Springborn Labs., Inc. 552 p. 

Non Guideline Selections 

44496815 Atkins, R. (1997) Characterization of (phenyl(A)-U-(carbon 14)-CGA-279202 

and its Degradation Products in Soil Extracts and Water Phases of 

Environmental Fate Studies: Lab Project Number: 1072: 373-96. Unpublished 

study prepared by PTRL East, Inc. 122 p. 

45080801 Merritt, A. (2000) Ecochemistry Summary of Trifloxystrobin: Amended Report: 

Lab Project Number: 588-97. Unpublished study prepared by Novartis Crop 

Protection, Inc. 148 p. 

47567524 Leicher, T. (2007) Fluopyram + trifloxystrobin SC 500 (250+250) G : 

Determination of Effects on Carbon Transformation in Soil. Project Number: 

M/294811/01/2, LRT/C/80/07, E/330/3364/2. Unpublished study prepared by 

Bayer CropScience AG. 35 p. 

47567525 Leicher, T. (2007) Fluopyram + Trifloxystrobin SC 500 (250+250) G: 

Determination of Effects on Nitrogen Transformation in Soil. Project Number: 

M/295282/01/2, LRT/N/91/07, E/337/3361/6. Unpublished study prepared by 

Bayer CropScience AG. 32 p. 

N.A. Method Evaluation (ECME) on CGA 302371 (metabolite of CGA 

184927) in soil using the method, "Method of Analysis for the 

Determination of CGA 302371 (UE Metabolite) in soil by LCIMS". 

44757206 Williams, R. (1998) Analytical Method AG-688 for the Determination 

of CGA-279202 and its Metabolites CGA-373466, CGA-321113, 

CGA-357261, CGA-357262, and CGA-331409 in Water and Sediment 

by Liquid Chromatography with Mass Spectrometric Detection, 

Including Validation Data: Lab Project Number: 509-98: AG-688: 

433000. Unpublished study prepared by Novartis Crop Protection, Inc. 

104 p. 

44496810 Chamkasem, N. (1996) Analytical Method for the Determination of 

CGA-279202 and its Metabolites CGA-357261, CGA-357262. CGA331409, CGA-373466 and CGA-321113 in Soil by High Performance 

Liquid Chromatography with UV Detection Including Validation Data: 

Lab Project Number: 654: 14-96: AG-654. Unpublished study prepared 

by Novartis Crop Protection, Inc. 182 p. 

44496811 Chamkasem, N. (1997) Analytical Method for the Determination of 

CGA-279202 and its Metabolites CGA-357261, CGA-357262. CGA-
53

331409, CGA-373466 and CGA-321113 in Soil by High Performance 

Liquid Chromatography with UV Detection Including Validation Data: 

Lab Project Number: 654A: 14-96. Unpublished study prepared by 

Novartis Crop Protection, Inc. 182 p. 

 
54

Appendix C 

Output from SIP and STIR Models 

Output from Screening Imbibition Program (SIP) 

Table 1. Inputs 

Parameter Value 

Chemical name Trifloxystrobin 

Solubility (in water at 25oC; mg/L) 0.61 

 

Mammalian LD50 (mg/kg-bw) 5000 

Mammalian test species laboratory rat 

Body weight (g) of "other" mammalian species 

 

Mammalian NOAEL (mg/kg-bw) 50 

Mammalian test species laboratory rat 

Body weight (g) of "other" mammalian species 

 

Avian LD50 (mg/kg-bw) 5000 

Avian test species northern bobwhite quail 

Body weight (g) of "other" avian species 

Mineau scaling factor 1.15 

 

Mallard NOAEC (mg/kg-diet) 5050 

Bobwhite quail NOAEC (mg/kg-diet) 5050 

NOAEC (mg/kg-diet) for other bird species 

Body weight (g) of other avian species 

NOAEC (mg/kg-diet) for 2nd other bird species 

Body weight (g) of 2nd other avian species 

Table 2. Mammalian Results 

Parameter Acute Chronic 

Upper bound exposure (mg/kg-bw) 0.1049 0.1049 

Adjusted toxicity value (mg/kg-bw) 3845.8028 38.4580 

Ratio of exposure to toxicity 0.0000 0.0027 

Conclusion* 

Drinking water exposure alone 

is NOT a potential concern for 

mammals 

Drinking water exposure alone 

is NOT a potential concern for 

mammals 

Table 3. Avian Results 

Parameter Acute Chronic 

Upper bound exposure (mg/kg-bw) 0.4941 0.4941 

Adjusted toxicity value (mg/kg-bw) 3602.1476 250.5434 

Ratio of exposure to acute toxicity 0.0001 0.0020 

Conclusion* 

Drinking water exposure alone 

is NOT a potential concern for 

birds 

Drinking water exposure alone 

is NOT a potential concern for 

birds 

*Conclusion is for drinking water exposure alone. This does not combine all routes of exposure. Therefore, when aggregated with 

other routes (i.e., diet, inhalation, dermal), pesticide exposure through drinking water may contribute to a total exposure that has 

potential for effects to non-target animals. 
55

Output from Screening Tool for Inhalation Risk (STIR) 

This tool is designed to provide the risk assessor with a rapid method for determining the 

potential significance of the inhalation exposure route to birds and mammals in a risk 

assessment. 

Input 

Application and Chemical Information 

Enter Chemical Name trifloxystrobin 

Enter Chemical Use all 

Is the Application a Spray? (enter y or n) y 

If Spray What Type (enter ground or air) air 

Enter Chemical Molecular Weight (g/mole) 408.4 

Enter Chemical Vapor Pressure (mmHg) 2.55E-08 

Enter Application Rate (lb a.i./acre) 

Toxicity Properties 

Bird 

Enter Lowest Bird Oral LD50 (mg/kg bw) 2000 

Enter Mineau Scaling Factor 1.15 

Enter Tested Bird Weight (kg) 0.178 

Mammal 

Enter Lowest Rat Oral LD50 (mg/kg bw) 5000 

Enter Lowest Rat Inhalation LC50 (mg/L) 4.65 

Duration of Rat Inhalation Study (hrs) 4 

Enter Rat Weight (kg) 0.35 

 
56

Output 

Results Avian (0.020 kg ) 

Maximum Vapor Concentration in Air at Saturation 

(mg/m3) 5.60E-04 

Maximum 1-hour Vapor Inhalation Dose (mg/kg) 7.05E-05 

Adjusted Inhalation LD50 1.04E+01 

Ratio of Vapor Dose to Adjusted Inhalation LD50 6.79E-06

Exposure not Likely 

Significant 

Maximum Post-treatment Spray Inhalation Dose (mg/kg) 0.00E+00 

Ratio of Droplet Inhalation Dose to Adjusted Inhalation 

LD50 0.00E+00

Exposure not Likely 

Significant 

Results Mammalian (0.015 kg ) 

Maximum Vapor Concentration in Air at Saturation (mg/m3) 5.60E-04 

Maximum 1-hour Vapor Inhalation Dose (mg/kg) 8.86E-05 

Adjusted Inhalation LD50 2.77E+02 

Ratio of Vapor Dose to Adjusted Inhalation LD50 3.20E-07 Exposure not Likely 

Significant 

Maximum Post-treatment Spray Inhalation Dose (mg/kg) 0.00E+00 

Ratio of Droplet Inhalation Dose to Adjusted Inhalation LD50 0.00E+00 Exposure not Likely 

Significant 

 
57

Appendix D 

Summary of Ecological Incidents Attributed to Trifloxystrobin 

EIIS Pesticide Summary Report: General Information 

Trifloxystrobin (129112) 

Incident # Date County State Certainty Legal. Formul.

Appl. Method Total Magnitude

PLANTS

Bell peppers

I016036-004 5/17/2004 Stanislaus CA 1 RU

Spray 40 acres

Cereal

I023302-024 6/24/2011 Pennington MN 2 RU SC

Broadcast 100% of 230 acres

Grape

I010837-005 4/4/2000 YOLO CA 3 RU DF

Air blast 44acres

I010837-011 5/10/2000 SAN JOAQUIN CA 3 RU DF

Air blast 343 acres

Ornamental

I010837-010 4/27/2000 VOLUSIA FL 3 RU DF

AIRBLAST; ALL

BROADCAST

I010837-085 10/26/2000 LAKE FL 3 UN DF

N/R ALL

I010837-083 10/26/2000 VOLUSIA FL 3 UN DF

N/R ALL

I010837-081 10/26/2000 VOLUSIA FL 3 UN DF

N/R ALL

I010837-080 10/26/2000 VOLUSIA FL 3 UN DF

N/R ALL

I010837-084 10/26/2000 VOLUSIA FL 3 UN DF

N/R ALL

I010837-079 10/26/2000 VOLUSIA FL 3 UN DF

N/R ALL

Wednesday, October 10, 2012 Certainty Code: 0=Unrelated, 1=Unlikely, 2=Possible, 3=Probable, 4=Highly Probable.

Legality Code: RU=Registered Use, M=Misuse, MA=Misuse (Accidental), MI=Misuse 

(Intentional), U=Unknown.
58

Incident # Date County State Certainty Legal. Formul.

Appl. Method Total Magnitude

I010837-078 10/26/2000 VOLUSIA FL 3 UN DF

N/R ALL

I010837-077 10/26/2000 VOLUSIA FL 3 UN DF

N/R ALL

I010837-082 10/26/2000 VOLUSIA FL 3 UN DF

N/R ALL

Tree farm/plantation

I012110-001 8/13/2001 DADE FL 2 RU N/R

N/R UNKNOWN

Wheat, spring

I015291-045 Cass ND 2 RU EC

Broadcast 120 acres

Wheat, winter

I014029-006 4/5/2003 King William VA 2 RU

Broadcast 51 acres

TERRESTRIAL

Agricultural area

I022340-001 4/23/2010 IN 1 UN

NR 4 apiaries, 1 hive