UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

OFFICE OF 

PREVENTION, PESTICIDES, AND 

TOXIC SUBSTANCES

PC Code: 080818 

DP Barcodes: 356960, 356962, 367091, 368703 

February 25, 2010 

MEMORANDUM 

SUBJECT: Indaziflam: Transmittal of Data Evaluation Records for Environmental Fate 

Studies. 

TO: Erik Kraft, Risk Manager 

Registration Division (7509P) 

James Tompkins, Product Manager 

Registration Division (7509P) 

 

FROM: Reuben Baris, Physical Scientist 

 Environmental Risk Branch IV 

 Environmental Fate and Effects Division (7507P) 

REVIEWED 

BY: Cheryl Sutton, Ph.D., Environmental Scientist 

 Environmental Risk Branch IV 

 Environmental Fate and Effects Division (7507P) 

APPROVED 

BY: Elizabeth Behl, Chief 

Environmental Risk Branch IV 

 Environmental Fate and Effects Division (7507P) 

 

This memo serves to document the Environmental Fate and Effects Division’s (EFED) 

reviews of and conclusions on the acceptability of the submitted indaziflam environmental fate 

studies. EFED study classifications are presented in the attached Table. 
Guideline Study Title MRID Electronic File Name Classification Comments

835.2120 Hydrolysis 47443207 080818 47443207 835.2120.doc Acceptable No significant issues affecting the acceptability of the stud

were noted. 

835.2240 Photodegradation in Water 47443208 080818 47443208 835.2240.doc Supplemental 

Study duration not sufficient. Concentrations of the 2 majotransformation products were still increasing at the study termination, precluding the determination of the patterns oformation and decline for each. 

835.2410 Photodegradation on Soil 47443209 080818 47443209 835.2410.doc Supplemental 

Study duration not sufficient. There was a decline in the dark controls (11%), material balances are acceptable. No explainable reason for decline in dark controls (e.g., stable to hydrolysis) 

47443210 080818 47443210 835.4100.doc Supplemental 

Application rate was 4x the maximum proposed applicatiorate to achieve appropriate sensitivity. Kinetics may not be accurately represented at the higher application mass. Overall recoveries of C14 residues from decreased during the study duration. Authors did not demonstrate that volatile trapping method was efficient at trapping high concentrations of volatile gases (e.g., CO2) 

47443211 080818 47443211 835.4100.doc Supplemental 

Application rate was 4x the maximum proposed applicatiorate to achieve appropriate sensitivity. Kinetics may not be accurately represented at the higher application mass. In the California sandy loam, increasing % of AR for diaminotriazine was observed at the termination of the study precluding the determination of the patterns of formation and decline. 

835.4100 Aerobic Soil Metabolism 

47443212 080818 47443212 835.4100.doc Supplemental 

Study duration not sufficient. This may not be sufficient to accurately establish the pattern of decline of the major transformation products. Replicates were not collected for three of the four soils tested, except for time 0. Moisture content was higher than recommended in study guidelines (55% of max holding capacity vs 75% of 1/3 basoil moisture content) 
Guideline Study Title MRID Electronic File Name Classification Comments

47443213 080818 47443213 835.4100.doc Supplemental

Study duration not sufficient. This may not be sufficient to accurately establish the pattern of decline of the major transformation products. Replicates were not collected for three of the four soils tested, except for time 0. Moisture content was higher than recommended in study guideline (55% of max holding capacity vs 75% of 1/3 bar soil moisture content) 

47443214 080818 47443214 835.4100.doc Supplemental 

Study was conducted using diaminotraizine (a degradate) as the starting material Study duration not sufficient. This may not be sufficient to accurately establish the pattern of decline of the major transformation products. Moisture content was higher than recommended in study guideline (55% of max holding capacity vs 75% of 1/3 bar

47443215 080818 47443215 835.4100.doc Supplemental

A comparison of the behavior of the two active isomers. Samples were analyzed only for the parent compounds. This study does not provide quantitative data for the risk assessment, it shows the behavior of the two active isomer

(diastereomers) of indaziflam (BCS AA10717). 

835.4200 Anaerobic Soil Metabolism 47443216 080818 47443216 835.4200.doc Acceptable Moisture content during the aerobic phase was higher than recommended in study guidelines (55% of max holding capacity vs 75% of 1/3 bar) 835.4300 Aerobic Aquatic Metabolism 47443217 080818 47443217 835.4300.doc Supplemental Study duration not sufficient. Duration not be sufficient to accurately establish the pattern of decline of the major transformation products. 

47443218 080818 47443218 835.4400.doc Acceptable Study conducted on Indane labeled compound. 

835.4400 Anaerobic Aquatic 

Metabolism 47443219 080818 47443219 835.4400.doc Acceptable Study conducted on Triazine labeled compound. 

47443203 080818 47443203 835.1230.doc Acceptable No significant issues affecting the acceptability of the stud

were noted. 835.1230 

Mobility - Adsorption / Desorption 

47443204 080818 47443204 835.1230.doc Supplemental The test compound was triazine-indanone a transformation product of AE 1170437. 
Guideline Study Title MRID Electronic File Name Classification Comments

47443205 080818 47443205 835.1230.doc Supplemental The test compound was diaminotriazine a transformation product of AE 1170437. 47443206 080818 47443206 835.1230.doc Supplemental The test compound was AE 1170437-carboxylic acid a transformation product of AE 1170437. 47443220 080818 47443220 835.6100.doc Supplemental

Study conducted on CA Porterville sandy loam cropped with turf. Storage stability study showed slow degradation of degradate over the period of frozen storage. 

47443221 080818 47443221 835.6100.doc Supplemental

Study conducted on FL Monticello loamy sand cropped with turf. Storage stability study showed slow degradation of degradate over the period of frozen storage. 

47443222 080818 47443222 835.6100.doc Supplemental

Study conducted on NC Wayne County loamy sand cropped with turf. Storage stability study showed slow degradation of degradate over the period of frozen storage. 

47443223 080818 47443223 835.6100.doc Supplemental

Study conducted on CA Porterville sandy loam, bare soil. Storage stability study showed slow degradation of degradate over the period of frozen storage. 

47443224 080818 47443224 835.6100.doc Supplemental

Study conducted on FL Jefferson County sand/loamy sandbare soil. Storage stability study showed slow degradation of degradate over the period of frozen storage. 

47443225 080818 47443225 835.6100.doc Supplemental

Study conducted on NC Wayne County loamy sand, bare soil. Storage stability study showed slow degradation of degradate over the period of frozen storage. 

835.6100 Terrestrial Field Dissipation 

47743301 080818 47743301 835.6100.doc Supplemental

Study conducted on Quincy loamy sand, bare soil, in Ephrata, Washington. Storage stability study showed slow degradation of degradate over the period of frozen storage. 
Guideline Study Title MRID Electronic File Name Classification Comments

47743302 080818 47743302 835.6100.doc Supplemental

Study was conducted on Oakville loamy sand, bare soil, in North Rose, New York. Storage stability study showed slow degradation of degradate over the period of frozen storage. 

850.1730 Fish Accumulation 47443237 680818 47443237 850.1730.doc Acceptable No significant issues affecting the acceptability of the stud

were noted. 

Storage stability 47443279 080818 47443279 835.6100.doc Supplemental 

Samples fortified with olefin degraded slowly, (corrected mean recoveries 65-88% following 427-433 days). Samples were not stored for a sufficient duration. 

860.1380 

Storage Stability 47743328 080818 47743328 NG.doc Supplemental 

Study upgrades MRID 47443279; conducted for sufficient duration. Samples fortified with olefin degraded slowly, mean corrected recoveries ranging from 65 to 88% following 427 to 433 days and from 47 to 67% following 732 to 736 days of storage 

Nonguideline Supplemental Information on Foreign Soils 47793401 080818 47793401 NG.tif Supplemental Comparison of foreign (German) soils to location and soil taxonomy of US soil series. Nonguideline ECM method & ILV Review 47443271 47443273 47443274 080818 47443271 47443273 47443274 method validation.pdf Acceptable Method for the determination of indaziflam and its degradates in surface, drinking and ground waters. Nonguideline ECM method Review & ILV review 47443276 47443278 080818 47443276 method validation.pdf Acceptable 

Method for the determination of indaziflam and its degradates in soil and sediment. Method was determined to be acceptable with minor revisions. 

Nonguideline ECM method Review 47443270 N/A Extraneous Submission N/A Nonguideline ECM method Review 47443275 N/A Extraneous Submission N/A Nonguideline ECM method Review 47443277 N/A Extraneous Submission N/A