UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, D.C. 20460

OFFICE OF PREVENTION, PESTICIDESAND TOXIC SUBSTANCES
PC Code 3 9220 1 DP Barcode D345278
MEMORANDUM DATE: May 30,2008 SUBJECT: Environmental Fate and Ecological Risk Assessmentfor the Section

### 3 Registrationofthe New Chemical Spirotetramat

FROM: Jose Luis Melendez, Chemist Michael Hoffmann, Biologist 

# w- (p /Yic Environmental Risk Branch V Environmental Fate and Effects Division (7507P) THROUGH: Mah T. Shamim, Ph.D., Chief Environmental Risk Branch V Environmental Fate and Effects ~i%sion (7507P) TO: Rita Kurnar, Risk Manager Reviewer Venus Eagle, Review Manager #0 1 Meredith Laws, Chief Insecticide-Rodenticide Branch RegistrationDivision (7505P) The attached document contains the Environmental Fate and Effects Division's (EFED) screening-levelenvironmental risk assessment for the new chemical Spirotetramat. The risk assessment has been conducted in accordance with the Agency guidance on ecological risk assessment and the OPP ecological risk assessment Overview document. The proposed agriculturaluses include citrus fruits (Crop Group 1 O), grapes and small fruit climbing (except kiwifruit), pome fruits (Crop Group 1 

### I), stone hits(Crop Group 12),tree nuts (Crop Group 14 plus pistachio), hops, Christmas trees, cucurbit vegetables (Crop Group 9), fruiting vegetables (Crop Group 8 plus okra), leafy vegetables (Crop Group 4), brassica (Cole) leafy vegetables (Crop Group 5), and potatoes and other tuberous and corm vegetables (Crop Subgroup 1C).An evaluation of environmental risk to aquatic and terrestrial organisms as a result ofthe proposed uses ofthe new chemical spirotetramat is summarizedin the Executive Summary and the Risk Characterization sections of the attached Section 3.Data Ga~s and Uncertainties Environmental Fate Data Gaps: A summary ofthe environmental fate data requirements is provided in Table 1 of this memo. The EFED is utilizing the review prepared by the Austrian Agency for Health and Food Safety (AGES) for spirotetramat (as stated in Volume 3, Annex 

### B.9: Fate and behaviour in the environment). The environmental fate database for the chemical is substantially complete and consists mostly of acceptable studies. The database is sufficient to conduct a Tier 1 Risk Assessment ofthe new TerrestrialFood and Non-Food uses of spirotetramat. The available soilphotodegradation study,provides only limited supplemental information and is uncertain because the parent in the dark control samples degraded faster than in the light exposed samples. However, from the study, the degradates dimethyl-benzoic acid (21.8% of the applied radioactivity or AR at 7 days, also observed in the aerobic outdoors study at 3.3% of the AR) and methoxycyclohexanone(10.0% of AR at 2 days, also observed in the aqueous photolysis study conducted with sterile natural water at 17.5% of AR) were identified only in the light exposed samples, 

### in additionto othertransformation products identified in otherbiodegradation studies (e.g., spirotetramat-en01and spirotetramat-ketohydroxy). The amount of such degradatesand the rate of soilphotodegradationon soil areuncertain. 

### In order to obtain an adequate description of the role of soilphotodegradation on the environmental fate of spirotetramat, and the presence and quantities of degradation1transformationproducts, a new photodegradation on soil study, conducted on a sterile soil is required. There is uncertainty with one ofthe five soilsused in the batch equilibrium studyperformed in the parent spirotetramat for which the taxonomic classificationis unknown. The registrant provided "Orthic darkbrown" as the soil taxonomic classificationfor the soil (not a soil taxonomic classification). Due to the sampling location, it is believed to be of the suborder Mollisols. This part ofthe study is considered supplemental. To upgrade the mobility studyto acceptable, the EPA is requiring that the registrant provide the soil taxonomy for the 'Saskatoon' loam soil (from Saskatchewan, Canada). There is uncertainty related to the high levels of non-extracted residues observed very early on in the aerobic soil metabolism studies conducted with spirotetramat (22-35% of AR) and spirotetrarnat-enol(40-60%of AR). Non-extracted residues were high in other studies as well. The registrant indicated that these residues were immobile, but did not provide evidenceto prove their contention. It is unknown if these residues are bioavailable. For the purpose of calculation ofthe half-life ofthe total residues of concern (parent, spirotetramat-en01 and spirotetramatketohydroxy),the non-extracted residues were added as if they were persistent compounds. Environmental Fate Uncertainties: The presence and quantities of aqueous photolysates of sterilebuffer solutionin the environment are uncertain, compared to the presence of aqueous photolysates in natural water. 

### In sterile buffer solution (pH 5), the four major transformation products were spirotetramat-photo-cyclopentyl, spirotetrarnat-photo-methyl, spirotetramat-photo-formyl and spirotetramat-photo-methyl at maxima of 11.5% to 42.9% of the applied radioactivity 

### (AR). These are the result of rearrangement ofthe parent. These transformation products were not observed in the photolysis study conducted with sterile natural water. Spirotetramat-enol's pKa is 5.2, which suggests that it may be ionizable at environmentally relevant pH's; however, the DTS03s for spirotetramat-en01 did not appear to depend on the soil pH's in aerobic soil metabolism studiesconducted in four soils. Nonetheless, the ionization potential of spirotetramat-en01could affect the mobility of the chemical with the soilpH (at highpH's high concentrations of the "enolate" form of the chemical would occur and higher mobility is expected). 

### In the soil column leaching studies, the range ofpH's was 6.1-6.5 for three EU soils and it was 5.4 for the FL SL (as measured in CaClz solution); all the derived Kd'swere within a relatively thin range (0.52-0.86) and the Koc's did not appear to follow a pattern with the pH's. The available Koc's for spirotetramat-en01 were estimated horn a series of soil column leaching studies instead ofthe conventional batch equilibrium study. There is uncertaintyin those values since the chemical is labile under various metabolism conditions; furthermore, it was found that spirotetramat-en01is too labileto withstand a batch equilibrium study (even with sterile soils). Spirotetramat-en01dimers 1 and 2, at up to 5.0 and 7.0% of

### AR, respectively in the soil metabolism studies, were 51.5% of

### AR in the aerobic outdoors study 

### and <0.2% in the field. It is speculated that this may be due to the "hot spots" applicationmethod used for spirotetramat in aerobic soil metabolism studies. 

### In the "hot spots" application method, utilized in the laboratory studies, spirotetramatwas applied in acetonitrileat relativelyhigh concentrations. It is argued due to the type of application, spirotetramat may have been concentrated in small regions or sectors (referredto as "hot spots") in/ on the soil, causing an increased formation of the dimers. For the tests conductedwith spirotetramat-en01(withhigher solubility, it was applied dissolvedin water and, hence, at lower concentrations)and in the aerobic outdoors study and in the field (with broadcast application ofthe formulated product, oil dispersion), the levels of the dimers were lower. 

### Ecological Effects Data Gaps and Uncertainties: A summary ofthe ecological data available for spirotetramat is provided in 

### Table 2 of this memo. 

### In agreementwith internationalgovernmentalpartners associated with registration efforts for this pesticide, ecological effects data evaluation and approval responsibilitiesarebeing met through the efforts ofthe AustrianAgency for Health and Food Safety (AGES). The Agency is using the results ofthe AGES review as they appear in Volume 3, Annex 

### B.9: Ecotoxicology monograph for registration in Europe. AGES foundthat the ecological effects databasewas largely complete and that all studieswere acceptable for risk assessment purposes. However, a few additional data needs have been identified by EFED as described below. OPPTS Guideline 850.2300; Avian Reproduction Study with the Mallard Duck 

### (Anas platyrh.vnchos): A definitiveNOAEC based on the available avianreproduction studieshas not been established for spirotetramat; adversereproductive effects were observed at the lowest tested concentrationin the available avian reproduction study with mallards. The most sensitiveNOAEC value of <28.8 mglkg-diet with which chronic avian RQs were calculated, was based on a statistically significant -6.58% reduction in mean hatchlingbodyweight. Although no additional statistically significant effects were observed at this test level, large reductions in other hank effects that were observed at 28.8 mglkg-diet included reductionsin # of 14-day survivors (122%), # of viable 14-day embryos (118%), # of live embryos (118%), and # of eggs hatched (122%). Due to the degree of these reductions, it is hard to indicate that these effects are not biologically significantand are considered meaninsful. Thus, because of the extent of these observed effects, it is reasonableto assumethey are significantbiologically. Therefore, the ability of this studyto statistically detect what could be consideredto be biologically relevant endpoints appears to be limited, and an additional study is needed to reduce uncertainty by establishing a definitiveNOAEC capable of capturing biologically relevant reductionsin endpoints. OPPTS Guideline 850.3040; Field Testing;for PollinatorsDespite that the intrinsichazard potential to bees based on the acute oral and contact studies with honey bees appearsto be low, brood feeding tests withbees and acute toxicity contact studies with other non-target insects (e.g. parasitoid wasps and predatory mites) conducted at less than the maximum application rate suggest there is potential for mortality in adults and pupae, massive perturbation ofbrood development, and early brood termination as a result of spirotetramat use. This information, coupled with the fact that two other chemicals representing the ketoenole class of compounds (spiromesifenand spirodiclofen) have also demonstratedthe potential for chronic effects on bee broods and development while displaying low acute toxicity, suggests that the mode of action of these compounds (i.e., inhibitionof lipid biosynthesis) may adversely affect bee broods and development. Although a study has been submitted for spirotetramat under guideline 850.3040, it was conducted at applicationrates approximatelyhalf ofthe labelrecommended rates and it was not designed in such a manner that adverse effects resulting from treatment could be statisticallydetermined. Therefore, it is recommended that a study designbe developed in collaboration with the Environmental Fate and Effects Division. OPPTS Guideline 850.1075; Freshwater Fish Toxicitv with Fathead Minnows (Pimeohales promelas): Under part 158 of Title 40 in the U.S. Code ofFederal Regulations fort&e registration of conventional pesticideproducts, it is stated that if the species used in a single fish early-life stage toxicity test is different from the two species used forthe freshwater fish acute toxicity tests, an additional 9Chour LCs0 on the species tested in the early-life stage study must be submitted. These conditions apply to spirotetramat and an additional study is requested to fill this data gap. These data would help to reduce the uncertainty associated with chronic risk estimates for freshwater fish. OPPTS Guideline 850.2100; Avian Oral Toxicitv Study with a Passerine Species: Under part 158 of Title 40 in the U.S. Code ofFederal Regulations for the registration of conventional pesticide products, it is stated that data are required on one passerine species in addition to either one waterfowl species or one upland game bird species forterrestrial, aquatic, forestry, and residential outdoor uses. Currently there are no acute oral toxicity studies with passerine species available for spirotetramat. These data would be helpful for characterizing interspecies sensitivity, and testing of a passerine addresses concerns that broad, untested avian taxa may be more sensitivethan previously required mallards and bobwhites. 

### EFED Label Recommendations Manufacturing Use Product: This pesticide is toxic to aquatic invertebratesand oysters. Do not discharge effluent containing this product into lakes, streams, ponds, estuaries, oceans, or other waters unless in accordance with the requirements of a National Pollutant Discharge Elimination System (NPDES) permit and the permitting authority has been notified in writing prior to discharge. Do not discharge effluent containingthis product to sewer systems without previously notifying the local sewage treatment plant authority. For guidance contact your StateWater Board or Regional Office of the EPA. This chemical has properties and characteristicsassociated with chemicals detected in ground water. The use of this chemical in areas where soils arepermeable, particularly where the water table is shallow,may result in ground-water contamination. End-Use Product: This product is potentially toxic to honey bee larvae through residues in pollen and nectar, but not to adult honey bees. Exposure of adult bees to direct treatment or residues on blooming crops can lead to effects on honey bee larvae. See the "Directions forUse" section ofthis label for specific crop application instructions that minimize risk to honey bee larvae.This pesticide is toxic to aquatic invertebrates and oysters. Do not apply directlyto water, to areas where surface water is present, or to intertidal areasbelow the mean high water mark. This product may contaminatewater through drift of spray in wind. Do not apply when weather conditions favor drift from treated areas. Drift and runoff from treated areas may be hazardous to aquatic organisms in neighboring areas. Do not contaminate water when disposing of equipment washwaters or rinsate. This product has a high potential for runoff for several weeks after application. Poorly draining soils and soils with shallow water tables are more prone to produce runoff that contains this product. A level, well maintained vegetative buffer strip between areas to which this product is applied and surface water features such as ponds, streams, and springs will reduce the potential for contaminationof water fromrainfall-runoff. Runoff ofthis product will be reduced by avoiding applicationswhen rainfall is forecasted to occur within 48 hours. Observe all cautions and limitations on labeling of all products used in mixtures. 

### Peer Reviewers This chapter was peer-reviewed by Michael Barrett, Ph.D., Chemist, and Nicholas Federoff, Biologist.Acute Mammalian Ora 835.6100

835.6200 835.6300 850.1730 *An additional study with no MRID; **Waived based on low vapor pressure and Henry's law constant; ***Waived based on low octanoWwater partition coefficient 1. A new study is required. 2. Additional data shouldbe submitted to upgrade the study. TerrestrialField Dissipation

AquaticField Dissipation Forestry Dissipation Accumulation in Fish 46904421, 46904422, 46904423, 46904424, 46904417 No Data No Data No Data Acceptable

NIA NIA Waived*** no

no

no

noMidge 48-hourAcute

No data submitted

No data submitted

No data submitted

No data submittedNo data submitted

144-1 850.3020

141-2 850.3030 850.6200 Non-guideline

Non-guideline Non-guideline Acute Honeybee Contact and Oral

Toxicity Test Residues onFoliage Honey Bee Toxicity Test Earthworm Sub-chronic Toxicity Earthworm Acute Toxicity Earthworm Crowth and Reproductive Toxicity

48-hourContact of ParasitoidWasps with

Dried Residues on Treated Glass Plates

7-day Contact of PredatoryMite with TGAI TEP (SC 240) TEP (OD 150) 46904449 46904469 46904461 No

No

No
No No

No

No No data submitted
Spirotetrarnat-4-methoxy-cyclohexanone TGAI Spirotetramat-ketohydroxy Spirotetramat-en01

TEP (OD 150) TEP (OD 150) 473?9101 46904455 46904472 Moser & Scheffczyk, 2005

Waltersdorfer, 2005a Waltersdorfer, 2005b850.3040 Non-guideline Non-guideline

Standardstudy classifications (i.e., Acceptable, Supplemental, Invalid) were not assigned because ecological effects data evaluation and approval responsibilities are being met through the efforts ofthe AustrianAgency for Health and Food Safety(AGES). The Agency is using the results of the AGES review as they appear in Volume 3, Annex B.9: Ecotoxicology monographforregistration in Europe. AGES found that the ecological effects database was largely complete andthat all studies were accepfable for risk assessmentpurposes. However, a few additionaldata needs have been identifiedby EFED as described above. Field Test for

Pollinators Honey Bee Feeding Test Honey Bee Semi-Field Test Summary ofthe Evaluation of Bee Brood Effects in Tunnel Trial TEP (OD 150) TEP (OD 100) TEP (SC 240) TEP (OD 100) TEP (SC 240) TEP (OD 150) 46904462 46904458 46904470 46904459

47276901 Yes No No

No