Docket Number EPA-HQ-OPP-2009-0306

http://www.regulations.gov/#!docketDetail;D=EPA-HQ-OPP-2009-0306

Page 1 of 2

OFFICE OF CHEMICAL SAFETY

AND POLLUTION PREVENTION

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON, D.C. 20460

November 25, 2015

PC Code: 011001, 011002, 011102, 011103,

011104, 011107, 011110, 011111, 011112

DP Barcode: 418385 

MEMORANDUM

SUBJECT: Preliminary Environmental Fate and Ecological Risk Assessment for the 

Registration Review of Boric Acid and Sodium Borate Salts

FROM: Donna Judkins, Ph.D., Biologist

James Lin, Ph.D., Environmental Engineer

ERB2/EFED (7507P)

James Breithaupt, Agronomist

Donna M. Randall, Senior Biologist

RASSB/AD (7510P)

REVIEWED Melissa Panger, Ph.D., Senior Scientist

BY: Ronald Parker, Ph. D., Senior Environmental Engineer 

ERB2/EFED (7507P)

THROUGH: Brian Anderson, Branch Chief

Elyssa Arnold, Risk Assessment Process Leader

ERB2/EFED (7507P)

Steven Weiss, Branch Chief

Laura Parsons, Associate Branch Chief

RASSB/AD (7510P)

TO: Moana Appleyard, Chemical Review Manager

Linda Arrington, Branch Chief

RMIBV/PRD (7508P)

Sandra O’Neill, Chemical Review Manager

Rose Kyprianou, Reevaluation Team Leader

Lance Wormell, Branch Chief

RMB2/AD (7510P)
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This memorandum transmits the preliminary ecological risk assessment for the 

registration review of Boric Acid and Sodium Borate Salts. This case includes both conventional 

agricultural use patterns and antimicrobial use patterns. Therefore this ecological risk 

assessment document was jointly prepared by the Environmental Fate and Effects Division 

(EFED) and the Antimicrobials Division (AD). Based on currently registered uses and labeled 

rates, this preliminary assessment identifies potential risks to non-target organisms (i.e., 

terrestrial invertebrates, birds, and mammals). This assessment is focused on species that are not 

Federally listed as threatened or endangered (referred to as “listed”). Due to the ubiquity of 

boron in the natural environment and its moderate to low toxicity, an abbreviated assessment was 

conducted here for the registered pesticide uses. Some currently labeled uses and application 

rates of boric acid and sodium borate salts pose a potential for adverse effects, i.e., risk, to 

terrestrial invertebrates, birds, mammals, reptiles, terrestrial-phase amphibians, aquatic 

organisms, and terrestrial plants. For the terrestrial vertebrate animals, risk is primarily 

associated with the granular formulations and bait uses. For aquatic organisms, risk is primarily 

associated with discharge of swimming pool, hot tub and spa effluent directly to surface waters 

or to storm drains and roadways and potentially from storage practices of post-treated wood. For 

terrestrial plants, risk is primarily associated with discharge of effluent from swimming pools, 

hot tubs and spas to the landscape. Section 3.1.2 addresses ambiguous label language that could 

be revised to reduce conservative assumptions used in assessing potential risks. Elimination of 

gaps in pollinator toxicity data would also help present a clearer risk picture.
Docket Number EPA-HQ-OPP-2009-0306

http://www.regulations.gov/#!docketDetail;D=EPA-HQ-OPP-2009-0306

Preliminary Fate and Ecological Risk Assessment for the 

Registration Review of Boric Acid and Sodium Borate Salts

USEPA PC CODES: 011001, 011102, 011103, 011104,

011107, 011110, 011111, 011112

Boric Acid

CAS 10043-35-3 PC Code 011001

25 November 2015

Environmental Fate and Effects Division Assessment 

Prepared by

Donna Judkins, Ph.D., Biologist

Jim Lin, Ph.D., Environmental Engineer

U.S. Environmental Protection Agency

Office of Pesticide Programs

Environmental Fate and Effects Division 

(EFED)

Environmental Risk Branch II

1200 Pennsylvania Ave., NW

Mail Code 7507P

Washington, DC 20460

Reviewed by

Melissa Panger, Ph.D., Senior Scientist

Ronald Parker, Ph. D., Senior Environmental Engineer 

Approved by

Brian Anderson, MEM, Branch Chief, ERB II

Antimicrobials Division Assessment 

Prepared by

James Breithaupt, Agronomist

Donna M. Randall, Senior Biologist

U.S. Environmental Protection Agency

Office of Pesticide Programs

Risk Assessment & Science Support 

Branch (RASSB)

Antimicrobials Division (AD)

1200 Pennsylvania Ave., NW

Mail Code 7510P

Washington, DC 20460

Reviewed and Approved by

Laura Parsons, Associate Branch Chief, RASSB

Steven Weiss, Branch Chief, RASSB
Docket Number EPA-HQ-OPP-2009-0306

http://www.regulations.gov/#!docketDetail;D=EPA-HQ-OPP-2009-0306

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Table of Contents

1 Executive Summary ................................................................................................................ 7

1.1 Use Summary ................................................................................................................... 7

1.2 General Risk Picture......................................................................................................... 8

1.2.1 Crop and Indoor/Outdoor Conventional Use Patterns.............................................. 8

1.2.2 Antimicrobial Use Patterns..................................................................................... 10

1.3 Major Uncertainties and Data Gaps............................................................................... 10

1.4 Risk Reduction Options ................................................................................................. 11

2 Introduction........................................................................................................................... 13

2.1 Problem Formulation Update ......................................................................................... 13

2.2 Chemical Identification.................................................................................................. 14

2.3 Use Characterization ...................................................................................................... 15

2.3.1 Target Pests and Mode of Action............................................................................ 15

2.3.2 Currently Registered Pesticide Uses....................................................................... 15

2.3.3 Label Uncertainties................................................................................................. 25

3 Exposure Assessment............................................................................................................ 27

3.1 Environmental Fate Summary........................................................................................ 27

3.2 Aquatic Exposures.......................................................................................................... 29

3.2.1 Monitoring Data...................................................................................................... 29

3.3 Terrestrial Exposures...................................................................................................... 30

3.3.1 Birds and Mammals................................................................................................ 30

3.3.2 Terrestrial Invertebrates.......................................................................................... 31

3.3.3 Terrestrial Plants..................................................................................................... 31

4 Effects Analysis.................................................................................................................... 32

4.1 Aquatic Toxicity Data .................................................................................................... 32

4.2 Terrestrial Toxicity Data ................................................................................................ 34

4.3 Endocrine Disruptor Screening Program ....................................................................... 36

5 Environmental Risk Assessment........................................................................................... 38

5.1 Risk Estimates................................................................................................................ 38

5.1.1 Aquatic Organisms.................................................................................................. 38

5.1.2 Terrestrial Species................................................................................................... 39

5.2 Risk Characterization ..................................................................................................... 43

5.2.1 Incidents.................................................................................................................. 43

5.2.2 Impaired Streams and Total Maximum Daily Loads (TMDLs)............................. 46

5.2.3 Agricultural Use Risk Characterization.................................................................. 47

5.2.4 Antimicrobial Uses Risk Characterization.............................................................. 49

5.2.5 Key Uncertainties and Assumptions....................................................................... 52

5.2.6 Risk Conclusions .................................................................................................... 53

6 Listed Species of Concern .................................................................................................... 54

7 References............................................................................................................................. 55

Appendix A Risk Quadrant Figures and Tables...................................................................... 60

Appendix B Boron Mineral Usage and Consumption............................................................. 62

Appendix C Environmental Background Levels of Boron...................................................... 64
3

Appendix D Releases of Boron from Household Products and Manufacturing and Industrial 

Processing65

Appendix E Submitted Studies................................................................................................ 66

Appendix F GENEEC Modeling Summary for Boric acid and Sodium Borate Salts. ........... 77

Appendix G T-REX Model Input and Output ......................................................................... 78

Appendix H TERRPLANT Input and Output ......................................................................... 86

Appendix I Ecotoxicity of Boric Acid and Sodium Borate Salts .............................................. 87

Appendix J ECOTOX........................................................................................................... 118

Appendix K Summary of Incident Information..................................................................... 122
4

List of Tables

Table 1.1. Evidence of Risk to Taxonomic Groups from Current Agricultural and NonAgricultural Outdoor Uses of Boric Acid and Sodium Borate Salts. ................................. 9

Table 2.1. Crop and Indoor/Outdoor Conventional Use Sites for Boric Acid (011001) 

(application timing when needed)..................................................................................... 16

Table 2.2. Crop and Indoor/Outdoor Conventional Use Sites for Boric Acid Sodium Salt 

(011104) (application timing when needed)..................................................................... 16

Table 2.3. Crop and Indoor/Outdoor Conventional Use Sites for Sodium Tetraborate 

Decahydrate (011002)....................................................................................................... 17

Table 2.4. Crop and Indoor/Outdoor Conventional Use Sites for Sodium Borate Pentahydrate 

(011111) (application timing when needed)..................................................................... 18

Table 2.5. Crop and Indoor/Outdoor Conventional Use Sites for Disodium Octaborate 

Tetrahydrate (011103). ..................................................................................................... 18

Table 2.6. Antimicrobial Use Patterns and Application Rates .................................................... 21

Table 2.7. Pounds of Boric acid and Sodium Borate Salts (as Boron)(a) Reported to the 

California Pesticide Monitoring Program from 2009 through 2013................................. 25

Table 3.1. Chemical Properties of Boric Acid............................................................................. 27

Table 3.2 Chemical and Physical Properties of Boric Acid and Sodium Borate Salts in this Case.

........................................................................................................................................... 28

Table 3.3. Boric Acid and Sodium Borate Salts Screening-level EECs...................................... 29

Table 3.4. T-REX Calculated EECs as Food Residues for Terrestrial Animals from Labeled 

Agricultural and Non-Agricultural Outdoor Uses of Boric Acid and Sodium Borate Salts.

........................................................................................................................................... 30

Table 3.5. T-REX Calculated EEC for Granular Applications.................................................... 31

Table 3.6. Calculated EECs for Terrestrial and Semi-Aquatic Plants near Application Areas for 

Boric Acid and Sodium Borate Salts. ............................................................................... 31

Table 4.1. Toxicity Endpoints Selected for Risk Estimation for Aquatic Organisms Exposed to 

Boric Acid and Sodium Borate Salts. ............................................................................... 33

Table 4.2. Toxicity Endpoints Selected for Risk Estimation for Terrestrial Organisms Exposed 

to Boric Acid and Sodium Borate Salts. ........................................................................... 35

Table 4.3. Toxicity Endpoints Selected for Risk Estimation for Terrestrial Plants Exposed to 

Boric Acid and Sodium Borate Salts. ............................................................................... 36

Table 5.1. Acute and Chronic Aquatic Water Column Invertebrate RQ Values for Agricultural 

and Non-Agricultural Outdoor Uses................................................................................. 38

Table 5.2. Acute and Chronic Fish Risk Quotients for Agricultural and Non-Agricultural 

Outdoor Uses. ................................................................................................................... 39

Table 5.3. Aquatic Plant Risk Quotients for Agricultural and Non-Agricultural Outdoor Uses. 39

Table 5.4. Upper Bound Kenaga, Acute and Chronic Avian Dose- and Dietary-Based Risk 

Quotients for Agricultural and Non-Agricultural Outdoor Uses. ..................................... 40

Table 5.5. Amount of Boric Acid and Sodium Borate Salts in the Immediate Application Area 

from Granular Broadcast Applications Expressed as Avian LD50 per Square Foot from 

TREX Calculations. .......................................................................................................... 40

Table 5.6. Upper Bound Kenaga, Acute and Chronic Mammalian Dose- and Dietary-Based Risk 

Quotients for Agricultural and Non-Agricultural Outdoor Uses. ..................................... 41
5

Table 5.7. Amount of Boric Acid and Sodium Borate Salts in the Immediate Application Area 

from Granular Broadcast Applications Expressed as Mammalian LD50 per Square Foot 

from TREX Calculations. ................................................................................................. 42

Table 5.8. Adult Honey Bee Contact Risk Quotient from Maximum Ground Spray Application 

of Boric Acid and Sodium Borate Salts for Agricultural Uses......................................... 42

Table 5.9. Terrestrial Plant Risk Quotients from Maximum Ground Spray Application of 0.0625 

lb a.e./A to Ornamentals, Soybeans and Other Uses. ....................................................... 43

Table 5.10. Summary of incidents reported in the EIIS Database from use of boric acid and 

sodium borate salts............................................................................................................ 43

Table 5.11. The certainty index in EIIS was based on the following. ......................................... 44

Table 5.12. Ecological and domestic animal incidents associated with boric acid and sodium 

borate salts, according to the Aggregate Database.1......................................................... 44

Table 5.13. Detail Showing Animal Incidents by PC Code and Product from the Aggregate 

Database Query................................................................................................................. 45

Table 5.14. Detail Showing Plant Incidents by PC Code and Product from the Aggregate 

Database Query................................................................................................................. 46
6

List of Figures

Figure 1.1. Graphic Summary of Potential Risks from Current Agricultural and NonAgricultural Outdoor Uses of Boric Acid and Sodium Borate Salts. ................................. 9
7

1 Executive Summary

The preliminary risk assessment (PRA) examines the potential ecological risks associated 

with labeled uses of boric acid and sodium borate salts based on the best available scientific and 

commercial information on the use, environmental fate and transport, and effects of boric acid 

and sodium borate salts on non-target organisms.

1.1 Use Summary

Boric acid and sodium borate salts (sodium tetraborate decahydrate, sodium tetraborate 

pentahydrate, sodium tetraborate anhydrous, disodium octaborate tetrahydrate, disodium 

octaborate anhydrous and sodium metaborate) are inorganic compounds used as insecticides, 

acaricides, algaecides, fungicides and wood preservatives (including cellulosic materials). There 

are numerous types of products for these compounds. The product formulations include wettable 

or water-soluble powder, dust, liquid concentrate, paste, pellet, bait, granule, soluble concentrate 

and solid. Multiple types of use sites have registered uses, including: agricultural application to 

numerous food/feed crops; indoor residential areas including pet quarters and wood preservation; 

aquatic nonfood residential; indoor food handling/storage sites and non-food sites; outdoor 

residential; forestry; terrestrial non-food crops; medical/veterinary areas; aquatic non-food 

industrial (sewer systems) sites; in-can/in-container material preservative for latex paints, stains, 

and coatings for surfaces and inks and dyes; material preservative for polystyrene (plastic) for 

insulation; material preservative for coatings used in manufacturing gypsum board and gypsum 

board paper; recirculating cooling water system sites; and recreational water systems (i.e., 

swimming pools, spas and hot tubs). The wood preservative uses includes both industrial 

application sites (i.e., wood treatment facilities), cardboard and particle board manufacturing 

facilities, and interior and exterior sites of in-place (in situ) wooden/cellulosic structures, wood 

posts, poles, timber, dimensional lumber, and railroad crossties. Hereafter, the term “agricultural 

and non-agricultural outdoor uses” will include all outdoor agricultural, forestry, terrestrial nonfood crops and residential pest applications and insect baits, but will exclude outdoor industrial 

and recreational water systems, material preservatives and wood preservation uses. The use 

sites, formulation types, target organisms and application methods/rates for each of the above 

active ingredients of this Reregistration Case are discussed in greater detail in the 1993 

Registration Eligibility Decision (RED) Document for boric acid and its sodium borate salts (US 

EPA, 1993). 

All sodium borate salts in this case yield boric acid (H3BO3) upon contact with water and 

depending on pH, salinity, and boron concentration also yield mono and polyborate ions. Boric 

acid is the predominant form present under most of the environmental conditions being 

considered for this case. Therefore, boric acid or boron will be treated as the chemical stressor 

for this assessment. Boric acid should persist indefinitely until absorbed and metabolized by a 

plant or animal. As an acid, boric acid will be present in the water column, and will be very 

mobile. Boric acid is the stable form of boron in the environment, and is not expected to break 

down any further. Boric acid may act as a Lewis base and complex with an electron pair donor. 

Boric acid dissipates from the point of application by transport from the site in surface or ground 

water.
8

1.2 General Risk Picture

Boron is an essential nutrient for aquatic vertebrates and invertebrates and plants, in small 

quantities. There is also evidence that boron is essential or if not essential, beneficial in birds 

and mammals, in small quantities. At insufficient boron concentrations impairment to sperm 

production, embryogenesis, and reproduction has been observed in fish and in amphibians. It is 

essential in cell wall structure and function for plants. However, at higher concentrations in the 

environment boron is toxic to these organisms. For plants, the range between essential nutrient 

and toxic impact is relatively narrow. Boric acid is classified as practically non-toxic to fish and 

aquatic invertebrates. Similarly, boric acid is classified as practically non-toxic to moderately 

toxic to terrestrial birds and mammals depending on the taxon as well as whether the 

classification is based on boric acid or elemental boron. For birds, all acute toxicity endpoints 

were from studies that did not have toxicity at any concentration tested, but the test levels could 

not rule out slight or moderate toxicity. Boric acid is classified as practically non-toxic to 

terrestrial invertebrates based on the traditional honeybee acute contact test. However, the 

pollinator studies associated with EPA’s recently developed pollinator risk assessment guidance 

have not yet been submitted. Also, boric acid is used as an insecticide and is known to damage 

the exoskeleton of arthropods, and so it is reasonable to assume that arthropods in the immediate 

treatment area would be affected by application of boric acid. Aquatic plants had toxic endpoints 

in the parts per million range but terrestrial plants did not have measureable effects for most test 

species in the highest treatments which are higher than application rates in terms of pounds per 

acre. The United States National Ambient Water Quality criterion for boron in irrigation water 

for protection of crops is 750 ppb.

1.2.1 Crop and Indoor/Outdoor Conventional Use Patterns

Given the amounts of naturally occurring boron found in the environment, the amount of 

non-pesticidal use, and its moderate to low toxicity, an abbreviated assessment was conducted 

here for the registered pesticide uses. This consisted of screening checks to see if broad 

taxonomic groups are at risk. In most cases, risk concerns were limited to terrestrial 

invertebrates in the immediate treatment area, but there was some uncertainty with potential 

effects to birds and mammals when the most conservative assumptions were applied due to label 

deficiencies in specifying maximum application rates.

Figure 1.1 and Table 1.1 give a broad overview of the potential risk concerns and 

supporting evidence for registered uses of boric acid and sodium borate salts for outdoor 

agricultural and non-agricultural uses.
9

Certainty

Risk

Boric Acid and Sodium Borate Salts

Terrestrial Plants

Fish

Mammals

Birds

Terrestrial Invertebrates

Aquatic Invertebrates

Aquatic Plants

Figure 1.1. Graphic Summary of Potential Risks from Current Agricultural and Non-Agricultural 

Outdoor Uses of Boric Acid and Sodium Borate Salts.

Table 1.1. Evidence of Risk to Taxonomic Groups from Current Agricultural and NonAgricultural Outdoor Uses of Boric Acid and Sodium Borate Salts.

Predominant Evidence of Negligible Risk Predominant Evidence of Risk

Fish, aquatic invertebrates and aquatic plants: All 

RQs <LOC for listed and non-listed species. No 

incidents reported.

Mammals: For granular uses, at maximum application

rate, one square foot of treated area would contain 

between 39-919x the rat LD50; for flowable uses, risk 

wasn’t as clear -- using conservative assumption of 

weekly applications at maximum application rate, one 

size/feeding class of mammals had non-listed species 

acute LOC exceedance and four groups of mammals had 

listed species acute LOC exceedance. Incident data also 

support the potential for risk to these taxa (especially for 

the bait uses).

Limited Evidence of Negligible Risk Limited Evidence of Risk

Terrestrial plants: All RQs <LOC for listed and nonlisted species. No incidents reported except five plant 

incidents that were not associated with outdoor 

registered applications. However, some evidence from 

open literature that woody plants may be damaged (see 

475.2.3.2).

Birds (also reptiles and terrestrial-phase 

amphibians): For granular uses, even though no 

toxicity was measured in the highest doses tested, at the 

max. app. rate one sq ft of treated area could not be 

precluded from containing up to 6.5-580x the quail 

LD50; for flowable uses, using conservative assumption 

of weekly applications at the maximum application rate: 

one size/feeding group of birds had listed species LOC 

exceedance. Incident data may support the potential for 

risk to domestic animals (especially for the bait uses), 

but information was not available to determine if any of 

these were bird incidents.

Terrestrial Invertebrates: Risk is assumed, rather than 

calculated. Products registered as insecticides and 

acaricides so expect localized effects in the immediate 

treatment area. No chronic toxicity data or larval 

toxicity data available.

Note: See Appendix A for key to quadrant placement.
10

1.2.2 Antimicrobial Use Patterns

Given the amounts of naturally occurring boron found in the environment, the amount of 

non-pesticidal use inputs to the environment, and boron’s moderate to low toxicity to animals, an 

abbreviated assessment was conducted herein for the registered antimicrobial uses. The agency 

believes there are risks of concern associated with the industrial wood preservative use pattern

primarily with post-treatment storage of treated wood, and that there are risks of concern to 

aquatic organisms and terrestrial plants associated with the recreational water biocide use pattern

due to discharge of pool, spa and hot tub water effluent to storm drains (which no label 

prohibits), or discharge to wetlands, or surface waters which not all labels prohibit. Additionally, 

discharge of pool, spa and hot tub effluent to the landscape may pose risks of concern to 

terrestrial plants from boron. No risks of concern were identified for the material preservative 

use in: interior/exterior paints, stains, and coatings; ink and dyes; coatings for manufacturing 

gypsum board and gypsum board paper; and polystyrene. 

1.3 Major Uncertainties and Data Gaps

Uncertainties specific to this assessment include:

 Label uncertainties were found for many agricultural and non-agricultural outdoor uses, 

mostly because the annual maximum application rates and application intervals were not 

specified. Also many of the non-agricultural uses were for non-broadcast types of 

applications (e.g., spot treatments) that are difficult to quantify on a spatial scale or to 

estimate runoff potential. The role of attractants in bait stations was also unknown.

 Label uncertainties regarding maximum application rates were found for the swimming 

pool, spa and hot tub use, mostly because of language which does not allow calculation 

of a maximum exposure level such as the following: labels either specified the addition of 

a number of pellets or tablets but the weight of individual tablets or pellets are unknown; 

labels called for filling up automatic dispensers or containers but information about 

volume of such containers is not stated on the labels; labels with sanitizer or stabilizers 

present did not require monitoring of boron levels but require or allow multiple 

reapplications based on chlorine residual levels or on the disappearance of a portion of 

the pellets. tablets, or granules; labels call for monitoring by a dealer of the product 

followed by addition of more product but do not specify what is being monitored and 

what monitored value triggers the need for addition of the product; a value to be 

monitored is provided but it is not clear if the value is expressed as the product or boron 

equivalents.

 Label uncertainties for determining maximum application or residues were found for the 

wood preservative (including wood composites) use and were mostly due to the 

following: addition of product to an unknown volume of water with area or volume of 

wood or wood composite to be treated not specified; nebulous or incomplete instructions 

for drilling holes and injecting paste or solutions where one or more of the following 
11

pieces of information is missing such as the number of holes per area, diameter of holes, 

depth of holes, vertical and horizontal spacing of holes, total amount of product to be 

applied per cubic foot of wood; amount of area that a pre-packaged wrap or pouch 

packaging covers.

 The largest data gap was for pollinator toxicity. No acute oral, chronic toxicity data or 

larval toxicity data were available. These exposure routes remain significant 

uncertainties for the assessment of the impact of boric acid and sodium borate salts on 

pollinators. The problem formulation for boric acid and sodium borate salts was 

completed in 2009, prior to the introduction of the requirements for chronic testing on 

honey bees (USEPA et al., 2014). The Agency expects to publish additional guidance on 

addressing gaps in bee toxicity data for pesticides that have undergone Registration 

Review in the near future.

Data gaps include:

 Terrestrial invertebrate studies:

o Non-guideline (Tier 1): Honey bee adult acute oral toxicity

o Non-guideline (Tier 1): Honey bee larvae acute toxicity

o Non-guideline (Tier 1): Honey bee adult chronic oral toxicity

o Non-guideline (Tier 1): Honey bee larvae chronic toxicity

o Non-guideline (Tier 2): Semi-field testing for pollinators (tunnel or colony 

feeding studies)

o Non-guideline (Tier 2): Field trial of residues in pollen and nectar

o OCSPP 850.3040 (Tier 3): Field testing for pollinators

1.4 Risk Reduction Options

Except for recommendations provided for the recreational water and wood preservative 

uses, no additional modifications are recommended for the other antimicrobial use patterns such 

as the material preservative uses. For the agricultural and non-agricultural outdoor use labels, 

without clearly delineated application rates on labels, risk reduction options were not possible to 

meaningfully analyze. Any labeling specifications that would help to clearly define the 

application area, timing and duration would make the risk more containable, since risk concerns 

are mostly confined to the immediate treatment area.

Evidence from incident data suggests that domestic and wild animals may be attracted to 

bait stations and traps. This risk may be reduced by label language specifying careful placement 

of baits and traps to reduce chance of exposure and changes to products to eliminate or reduce 

attractants that attract nontarget organisms.

 Recreational water use (i.e., Swimming pools, spas and hot tubs)

o Add language to all labels prohibiting the discharge of effluent from swimming 

pools, or spa and hot tubs to storm drains or roadways.

o Require all labels to include language requiring a National Pollutant Discharge

Elimination System (NPDES) permit or notification of the permit authority prior 
12

to discharge of effluent from swimming pools, and spas and hot tubs into lakes, 

streams, ponds, estuaries, oceans or other waters. 

o Require all labels to include language requiring notification of the local sewage 

treatment plant authority prior to discharge of swimming pool, or spa and hot tub 

effluent to the sewer system. 

o On labels requiring monitoring, the chemical being monitored and limits 

associated with it needs to be clearly stated.

o Uses where boron concentration greater than 0.75 ppm boron can occur in pool or 

spa and hot tub water based on application instructions should prohibit discharge 

to the landscape and require discharge solely to the sewer system.

 Wood preservative use

o Require treated wood during storage either between treatments at wood treatment 

facilities or prior to transport into commerce be covered to prevent leaching and 

run-off from treated wood to the soil at wood treatment facilities. Wrapping 

wood before going into commerce and keeping it wrapped until final use would 

prevent leaching off-site.
Docket Number EPA-HQ-OPP-2009-0306

http://www.regulations.gov/#!docketDetail;D=EPA-HQ-OPP-2009-0306

13

2 Introduction

The preliminary risk assessment (PRA) examines the potential ecological risks associated 

with labeled uses of boric acid and sodium borate salts based on the best available scientific and 

commercial information on the use, environmental fate and transport, and effects of boric acid 

and sodium borate salts on non-target organisms. The risk assessment methodology used current 

policies, guidances, and tools. This assessment is focused on species that are not federally listed 

as threatened or endangered (referred to as “listed”). 

A problem formulation for registration review and conduct of the ecological risk 

assessment of boric acid and sodium borate salts was developed in 2009 (USEPA, 2009a). The 

purpose of problem formulation is to provide the foundation for the environmental fate and 

ecological risk assessment being conducted for the representative labeled uses of boric acid and 

sodium borate salts. The problem formulation sets the objectives for the risk assessment and 

provides a plan for analyzing the data and characterizing the risk (USEPA, 1998). A brief 

overview of the problem formulation, along with updates, is provided in Section 2.1.

2.1 Problem Formulation Update

At the time of the problem formulation in 2009 the Agency did not anticipate conducting 

an ecological risk assessment for the indoor uses of boric acid and sodium borate salts (USEPA, 

2009a). Since the problem formulation was posted, antimicrobial use patterns once identified as 

indoors have been reclassified under new use patterns in recognition that these uses may result in 

environmental releases to different degrees (40 CFR Part 158 Subpart W). Boric acid and 

sodium borate use patterns affected include recreational water system use patterns such as 

swimming pools, and spas and hot tubs; and the recirculating cooling water system use pattern 

(industrial water process system). A new use of boric acid as an in-can/in-container preservative 

for latex paints, coatings and ink was registered in 2010.

Several ecological risk assessments have been completed since the USEPA 1993 

Reregistration Eligibility Decision (RED) and include a 2006 assessment by the US Forest 

Service (USFS), and specifically for outdoor agricultural use (DP 3118066, 2006), liquid ant bait 

(DP 335979, 2007), and granular bait for fire ants and red imported ants (DP 349994, 2008). An 

ecological hazard assessment was conducted by the Agency in 2010 for the new use of boric acid 

as an in-can/in-container preservative for interior/exterior latex paints, stains, and coatings for 

surfaces; inks and dyes; and for coatings for use in manufacturing gypsum board and gypsum 

board paper (DP 368504). 

EPA Region 5 conducted toxicity testing of aquatic organisms with boric acid in 2011 to 

support two states in the region updating boron water quality criteria for protection of aquatic life 

and to support ongoing consultations with U.S. Fish and Wildlife Service under the Endangered 

Species Act. New criteria were developed and adopted by the state of Illinois in 2012, and 

Boron water quality guidelines for protection of aquatic life were updated by the British 

Columbia Ministry of Water, Land and Air Protection in 2003 (Moss and Nagpal, 2003) and by 

the Canadian Council of Ministers of the Environment in 2009 (CCME, 2009).
14

The risk conclusions from these agency’s ecological risk assessments are summarized 

below:

 For agricultural and non-agricultural outdoor use sites, except bait stations (DP 318066):

Because of the low toxicity of boric acid to a wide variety of organisms, and due to the 

high levels found naturally in the environment, the agency determined that a full 

screening risk assessment was not warranted at the time. This conclusion was made in

both the agency’s risk assessment conducted to support the 1993 RED and in a more 

recent (2006) assessment by the US Forest Service. Terrestrial invertebrates that are 

directly exposed at the time of application (the mode of action is by contact and is not 

systemic) were the only organisms considered to be at risk in these assessments. 

However, some new toxicity data were available and so risk quotients for aquatic and 

terrestrial animals and plants were recalculated.

 For bait stations use sites (DP 335979):

No aquatic exposure is expected from the use of enclosed bait stations. Based on the 

proposed use pattern (enclosed bait stations that are intended to be accessible only to 

crawling insects), crawling insects that are small enough to gain access to the interior of 

the bait stations are the only taxon that would clearly be exposed. Fish, aquatic 

invertebrates and aquatic and terrestrial plants would not be expected to be exposed. 

Exposure of non-target terrestrial organisms other than crawling insects would not be

expected unless they are attracted to the bait stations. However, there is some uncertainty 

due to the potential use of attractants that might also attract mammals, birds, reptiles and 

terrestrial-phase amphibians; the agency does not at this time have an effect method of 

assessing this and incidents with domestic animals show that exposure is possible, and 

this exposure is likely dependent on attractants present.

2.2 Chemical Identification

Boric acid and sodium borate salts include the following registered active ingredients: 

PC Code CAS Registry No. Chemical Name

011001 10043-35-3 Boric acid (H3BO3)

011002 1303-86-2 Boric oxide (B2O3)

011102 1303-96-4 Sodium tetraborate decahydrate (Na2B4O7•10H2O)

011103 12280-03-4 Disodium octaborate tetrahydrate (Na2B8O13•4H2O)

011104 7775-19-1 Sodium metaborate (NaBO2)

011107 12008-41-2 Disodium octaborate anhydrous (Na2B8O13)

011110 12179-04-3 Sodium tetraborate pentahydrate (Na2B4O7•5H2O) 

011111 11130-12-4 Sodium borate pentahydrate (H3BO3Na+•5H2O)

011112 1330-43-4 Sodium tetraborate anhydrous (Na2B4O7)

Of these nine PC Codes, two have no active manufacturing use or end-use product 

registrations (PC Codes 011002 and 011112). The active ingredients in this Case are inorganic 

pesticides which have in common the release or formation of boric acid and borate ions when in 

contact with aqueous media. 
15

Many different formulations are registered for products containing boric acid or sodium 

borate salts, including liquids, soluble and emulsifiable concentrates, granulars, powders, dusts, 

pellets, tablets, solids, paste, baits and crystalline rods. The percentage of active ingredients in 

these products may range from less than 1% to 99-100%. Boric acid and sodium borate salts 

may also be used as inerts in the formulations of other pesticide products.

The chemical and physical properties of boron, boric acid and the sodium borate salt 

compounds covered in this Case are provided in Section 3.1.

All boric acid salts yield boric acid (H3BO3) upon contact with water. The primary form 

in the environmentally relevant pH range and environmental concentration range for freshwater 

is boric acid. In estuarine/marine waters depending on pH and boron concentration, boric acid is 

predominate below pH 8.2 with increasing borate ion concentrations at higher pHs. Both boric 

acid and borate ions can contribute to toxicity. Therefore, both boric acid and boron (total sum 

of boric acid and borate ions) will be treated as the chemical stressors for this assessment. 

Results were converted to boric acid equivalents (a.e.) or boron equivalents, as appropriate to the 

exposure models used.

2.3 Use Characterization

2.3.1 Target Pests and Mode of Action

Boric acid and sodium borate salts act as acaricides, algaecides, fungicides and 

insecticides and are used on a variety of agricultural (including food/feed), non-agricultural, 

residential, commercial, medical, industrial and food/feed handling sites. The antimicrobial uses 

of boric acid and sodium borate salts combined include use as an insecticide/fungicide wood 

preservative, an algaecide in recirculating cooling water systems (industrial process and water 

systems) and recreational water systems (i.e., swimming pools, spas and hot tubs), and as a 

broad-spectrum fungicide and bactericide material preservative for polystyrene (plastic) for 

insulation, latex paints, stains, coatings, inks and dye.

These compounds act as acaricides and insecticides by acting as a stomach poison, 

interfere with the metabolic process, or through starvation by killing off digestive track 

microflora (e.g., bacteria) that allows insects to digest cellulose, or by abrasion or absorption of 

waxes from exoskeletons causing them to dry out (desiccate). When used as algaecides, they act 

by causing desiccation or interruption of the photosynthesis pathway and metabolism (e.g., locks 

up the nucleotide co-enzymes nicotinamide adenine dinucleotide [NAD+] and nicotinamide 

adenine dinucleotide phosphate [NADP+]). In fungi borates stop the production of reproductive 

spores.

2.3.2 Currently Registered Pesticide Uses

2.3.2.1 Crop and Indoor/Outdoor Conventional Use Patterns

Table 2.1 to Table 2.5 lists the registered use sites according to PC Code. The tables are 

based on the draft use tables provided by Borate Task Force. 
16

Table 2.1. Crop and Indoor/Outdoor Conventional Use Sites for Boric Acid (011001) (application 

timing when needed).

Site Application Type/Equipment Max Single Application 

Rate

Barns/Barnyards/Auction Barns Crack and crevice and/or spot treatment/ Duster/ 

pressure sprayer/ spreader 20 lb /1 K sq. ft

Commercial/Institutional/Industrial 

Premises/Equipment (Outdoor) Perimeter treatment/ spreader 0.1875 lb / 1 K sq. ft

Drainage Crack and crevice and/or spot treatment, mop, 

duster 1 -- (L)1

/ 0.495 lb / 1 gal

Manure Dust/duster/spray/pressure sprayer 1 -- (L)

Non-Agricultural Uncultivated Areas/ Soils Crack and crevice treatment/duster, contact and/or 

surface treatment/mop/spreader 1 -- (L) / 0.495 lb / 1 gal

Ornamental and/or Shade Trees Band Treatment/ spreader 0.1875 lb /1 K sq. ft

Ornamental Lawns and Turf Broadcast/ spreader 0.1 lb / 1 K sq. ft

Paths/Patios/pave Areas (roads/sidewalks) Perimeter treatment/ spreader 0.1875 lb /1 K sq. ft

Recreation Areas Contact and/or surface treatment/ spreader/ duster 0.2 lb / 1 K sq. ft

1This notation is thought to mean one liter, but is unclear and is an uncertainty.

Table 2.2. Crop and Indoor/Outdoor Conventional Use Sites for Boric Acid Sodium Salt (011104) 

(application timing when needed).

Site Application Type/Equipment Max Single Application 

Rate

Drainage System, Fencerows/Hedgerows, 

Non-Agricultural Rights-Of-Ways, NonAgricultural Uncultivated Areas/Soils, 

Paths/Patios, Recreation Areas, Urban 

Areas

Broadcast/hand-carried granule applicator, power 

granule applicator, 

3 lb /100 sq. ft

2 applications /year

90 days MRI
17

Table 2.3. Crop and Indoor/Outdoor Conventional Use Sites for Sodium Tetraborate Decahydrate 

(011002).

Site Application Type/Equipment

(Application Timing)

Max Single Application 

Rate

Alfalfa, Cocoa, Coffee, Corn – Field, Corn 

– Pop, Corn – Sweet, Corn (Silage), Grass 

Forage/Fodder/Hay, Pome Fruits, Tobacco

Spray/ground (foliar) 0.0327 lb/A (7 days MRI)

Almond, Apricot, Cherry, Nectarine, Peach, 

Pecan, Pistachio, Plum, Walnut 

(English/Black)

Spray/ground/hand held sprayer/hose-end sprayer/ 

trigger spray bottle (foliar)

0.0327 lb/A (7 days MRI)

0.0143 lb/A (4 days MRI)

Apple 0.0143 lb/A (4 days MRI)

Avocado, Banana, Basil, Bushberries, 

Caneberries, Cress – Water, Grapefruit, 

Guava, Lemon, Mango, Marjoram/Oregano, 

Melons – Cantaloupe, Nasturtium – Garden, 

Orange, Ornamental and/or Shade Trees, 

Ornamental Herbaceous Plants, Papaya, 

Parsley, Peanuts, Pineapple, Rosemary, 

Soybeans (Unspecified), 

Subtropical/Tropical Fruit

Spray/ground (foliar) 0.0625 lb /A (7 days MRI)

Grapes, Hops, Stone Fruits, 0.0327 lb/A (10 days MRI)

Beans, – Dried-Type, - Succulent (Lima), -

(Snap), Blackberry, Blueberry, Broccoli, 

Cabbage, Carrot (including Tops), 

Cauliflower, Celery, Citrus, Cucumber, 

Eggplant, Garbanzos (including Chick 

Peas), Garlic, Lentils, Lettuce – Head, 

Lettuce – Leaf, Melons, Onion, Peas –

Southern, Peas – unspecified, Pepper, 

Potato – White/Irish, Pumpkin, Raspberry 

(Black – Red), Spinach, Squash (All or 

Unspecified), Sugar Beet, Tomato, 

Strawberry

Spray/ground/hand held sprayer/hose-end sprayer/ 

trigger spray bottle (foliar)

0.0625 lb /A (7 days MRI)

0.0286 lb /A (4 days MRI)

Flavoring/Spice Crops 0.0286 lb /A (4 days MRI)

Non-Agricultural Uncultivated Areas/ Soils Bait application/bait station, perimeter treatment/ 

package applicator, duster/ ant trap (when needed) 1 -- (L) 

Ornamental Lawns and Turf

Residential Lawns

Bait application/package applicator (when needed),

Spray/hand held sprayer, hose-end sprayer, pumpup sprayer, trigger spray bottle (foliar)

0.0001969 lb/ft (30 days 

MRI)

0.0003287 lb /1K sq. ft (4 

days MRI)

Ornamental Nonflowering Plants, 

Ornamental Woody Shrubs and Vines

Spray/ground/hand held sprayer/hose-end sprayer/ 

trigger spray bottle (foliar)

0.0625 lb /A (7 days MRI)

0.0006547 lb /1 K sq. ft (4 

days MRI)

Paths/Patio Bait application/syringe (when needed) 0.0094 lb / bait

Recreation Areas Void treatment/Duster (when needed) 1 -- (L)
18

Table 2.4. Crop and Indoor/Outdoor Conventional Use Sites for Sodium Borate Pentahydrate 

(011111) (application timing when needed).

Site Application Type/Equipment Max Single Application 

Rate

Drainage System Crack and crevice and/or spot treatment 0.5 oz / ft

Table 2.5. Crop and Indoor/Outdoor Conventional Use Sites for Disodium Octaborate 

Tetrahydrate (011103).

Site Application Type/Equipment

(Application Timing)

Max Single Application 

Rate

Almond, Avocado, Cherimoya, Citrus, 

Cranberry, Grapes, Pome Fruits. Small 

Fruits, Stone Fruits, Strawberry, 

Subtropical/Tropical Fruit, Tree Nuts 

Bait application/bait station (foliar) 1 part (L) (14 days MRI)

Barns/Barnyards/Auction Barns

Void treatment/foam application, injection 

equipment, mist blower, surface treatment/ 

sprayer, brush, roller, (when needed)

1 part (L)

Commercial/Institutional/Industrial 

Premises/Equipment (Outdoor) Bait application/bait station (when needed) 1 -- (L)

Compost/Compost Piles Compost treatment/by hand, dust gun (when 

needed) 19.6 lb / 1K sq. ft

Forest Trees (All or Unspecified) Stump treatment/ backpack sprayer, hand held 

sprayer (when needed) 1.225 lb/ 1 K sq. ft

Manure Broadcast/by hand, dust gun (when needed) 19.6 lb /1 K sq. ft

Nonagricultural Outdoor Buildings/ 

Structures

Injection treatment/injection equipment, void 

treatment/low pressure ground sprayer, mist 

sprayer

5.021 lb /1 K sq. ft

Non-Agricultural Uncultivated Areas/ Soils Mop, void treatment/ dust gun, sprayer (when 

needed)

0.49 lb / 1 gal

1.5 lb / (L)

Recreation Areas Void treatment/ sprayer, crack and crevice 

treatment/ sprayer (when needed) 1.47 lb /1 gal

Refuse/Solid Waste Sites (Outdoor) Outdoor treatment/ by hand, dust gun, sprayer 

(when needed) 19.6 lb /1 K sq. ft

According to the use site classifications from California Department of Pesticide 

Regulation (see Table 2.7), the agricultural use site is the same as agricultural crops and the bait 

stations use site is similar to pest control. These two use sites have been evaluated previously. 

Therefore, the additional use sites that need to be considered are aquatic areas, forest trees, 

landscape maintenance, premises/structure, right of way, sewage systems and wood protection 

treatments. Specifically, the use sites for right of way and wood protection treatment will be 

under the assessment from Antimicrobial Division (AD). The use sites of sewage systems 

including septic tanks and sewers would represent the enclosed systems, therefore, no exposure 

routes are available for non-target organisms. Notes on these additional use sites are as follows:

1) Aquatic areas:

For the drainage uses, the rates are 3 lb/100 sq. ft (2 applications per year with 90 days 

MRI) for boric acid sodium salt (PC code 011104), 0.5 oz/ft for sodium borate 

pentahydrate (PC code 011111), and 0.495 lb/gal for boric acid (PC code 011001). The 

spot application is for cracks and/or the crevices, with a mop or the duster as the 

equipment. 
19

2) Forest trees:

This use is only for disodium octaborate tetrahydrate (PC code 011103). It is for spot 

treatment on stumps, and can be applied with either a backpack sprayer or a hand held 

sprayer when needed. The application rate is 1.225 lb/1000 sq. ft.

3) Landscape maintenance:

For sodium tetraborate decahydrate (PC code 011002), the rate is 0.0003287 lb/1000 

sq. ft. For boric acid (PC code 011001), the application rate on ornamental lawns and 

turf is 0.1 lb/1000 sq. ft (4.356 lb/ac).

4) Premises/structure:

For boric acid (PC code 011001), the use rate is 20 lb/1000 sq ft. for 

barns/barnyards/action barns. The spot treatment is on cracks and/or crevices with the 

duster, pressure sprayer or spreader. For disodium octaborate tetrahydrate (PC doe 

011103), the use rate is 19.6 lb/1000 sq. ft. to treat refuse/solid waste sites (outdoor) by 

hand with a dust gun, or sprayer when needed.

5) Other uses:

For disodium octaborate tetrahydrate (PC code 011103) the rate is 19.6 lb/1000 sq ft. 

on manure with broadcast by hand with dust gun when needed.

It is a general understanding that application rates for a use site expressed as amount per 

1000 sq ft. together with the labeled application equipment would indicate a spot treatment. 

Considering the amounts of borate ion found naturally in the environment (30 to 100 ppm in soil, 

1 to 200 ppb in fresh water, and 4.5 ppm in ocean water), the spot treatments on aquatic areas, 

forest trees, and premises/structures are not expected to meaningfully impact background borate 

concentrations. The same argument can be made for landscape maintenance with the rate of 

4.356 lb/ac. The high use rates on manure and premises/structures are hand applied and so, 

conceptually, the scale is also expected to be limited. Given the localized nature of these 

additional uses, risk is assumed to be localized for these uses.

2.3.2.2 Antimicrobial Use Patterns

For evaluating environmental exposure, the application rates that are critical for the risk 

assessment are in Table 2.6.

2.3.2.3 Overview of Pesticide Usage

Boric acid and sodium borate salts have more uses in commerce than as pesticides. The 

annual total and major consumptive uses are discussed in detail in Appendix B.

No national scale pesticide usage information is available for boric acid and sodium 

borate salts. The 2004 Kline Report estimated U.S. consumption of borates for the wood 

preservative use as around 4.80 million pounds with potential to increase at an average annual 

rate of 1.7% over five years to 5.2 million pounds by 2009. Disodium tetraborate pentahydrate

(DTP), the active sodium borate salt in all swimming pool and spa and hot tub use labels for the 

boric acid and sodium borate salts case, is not listed among the common specialty biocides for 
20

use in recreational water systems (includes swimming pools and spas) in the 2004 Kline Report. 

The consumption of “Other” specialty biocides is reported as 0.550 million pounds in 2004 with 

the potential to increase at an average rate of 3% over five years to 0.625 million pounds by 

2009. Boric acid, the active ingredient for the material preservative use pattern in paints, 

coatings, and stains, is not listed among the common specialty preservative biocide for paints and 

coatings in the 2004 Kline Report. The consumption of “Other” preservatives for paints and 

coatings is 460,000 pounds in 2004 with potential for increase to 587,000 pounds in 2009. 

Currently there is no consumption for the recirculating cooling water system use. This is 

because while there is a manufacturing use product (MP) registered for formulating an end-use 

product for the recirculating cooling water system use, there are no end-use products registered 

for this use.
Docket Number EPA-HQ-OPP-2009-0306

http://www.regulations.gov/#!docketDetail;D=EPA-HQ-OPP-2009-0306

21

Table 2.6. Antimicrobial Use Patterns and Application Rates

Use Pattern Use Site Application Type/ 

Equipment Treatment Site % B in EPs[% ai] Application Rate Frequency

Industrial 

processes and 

water systems

Recirculating cooling 

water systems; water 

systems

------------------On technical label only and this information is not provided on technical label, no end-use products ------------------

Bacteriocide Absorbent material such as 

cat litter ------------------On technical label only and this information is not provided on technical label, no end-use products ------------------

Material 

preservative

Manufacturing facilities of 

interior/exterior latex 

paints, stains, and coatings

Any stage in 

manufacturing 

process

Latex paints, stains and coatings 

intended for interior and exterior 

surfaces (wood, shakes, cinder 

block, vinyl & aluminum siding, 

stucco, primed metal, hard board, 

fiber cement board, unglazed 

brick, concrete)

17.48%

(powder)

[100% BA]

0.087% to 1.4% B by 

weight of finished product At manufacturing

Material 

preservative

Manufacturing facilities of 

coatings for gypsum board 

and gypsum board paper

Any stage during

manufacturing 

process

Waterborne coatings for use in 

the manufacture of gypsum board 

and gypsum board paper

17.48%

(powder)

[100% BA]

0.087% to 1.4% B by 

weight of finished product At manufacturing

Material 

preservative

Manufacturing facilities of 

inks and dyes

Any stage during

manufacturing Inks and dyes 17.48% (powder)[100% BA]

0.087% to 0.7% B by 

weight of finished product At manufacturing

Material 

preservative

Manufacturing facilities of 

polystyrene insulation

Mixed with 

polystyrene beads 

prior to bead 

expansion

Polystyrene beads

20.6%

(powder)

[98% DOT]

0.6 to 1.0% B by weight of 

finished product At manufacturing

Material 

preservative

Manufacturing facilities of 

wafer board

Added when wood 

wafers are mixed 

with wax emulsion

Wafer board components

4.9%

(RTU)

[43.5% DTD]

0.0045 to 0.009% B by 

weight At manufacturing(a)

Material 

preservative Cellulose insulation Surface spray Cellulose insulation (manufacturing or in situ)

20.6% (powder)

[98% DOT]

0.041% B by weight of 

treated insulation

At manufacturing, or 

remedial, preventative 

in situ treatment

Material 

preservative

Industrial/manufacturing 

facilities and in situ

Dip, spray, brush, 

roller Paper and cardboard 2.063% (RTU)[0.89% BA+9.1%DOT]

0.000035 lbs B per square 

foot

At manufacturing, or 

remedial, preventative 

in situ treatment

Swimming 

pool algaecide

Residential, public, 

commercial, institutional 

swimming pool

broadcast Water in swimming pools(j)

14.8%

(powder)

[99.5% & 100% DTP]

1.2%, 3.0% & 4.42%

(Granular)

35.0 to 35.6 mg B/L Initial Startup

30-50 mg B/L Maintenance(b)

0.14 to 0.40 mg B/L Initial application(c)

0.14 to 0.40 mg B/L/week Superchlorination or 

Shock treatment(d)

0.0.018 to 0.30 mg B/L/day Maintenance(e)
22

Use Pattern Use Site Application Type/ 

Equipment Treatment Site % B in EPs[% ai] Application Rate Frequency

[8%, 20%, & 29.8% 

DTP]

0.142 to 0.285 mg B/L Algae treatment(f)

0.285 mg B/L Winterization

Automatic 

chlorinators, floaters 

and skimmers

Water in swimming pools(j) 0.74% to 1.48%

(Pellets and tablets)

[5% & 10% DTP]

1.2% & 4.42%

(Granular)

[8% & 29.8% DTP]

0.14 to 0.17 mg B/L Initial Startup(c,g)

0.14 mg B/L per week Shock Treatment(g,h)

0.0076 to 0.036 mg 

B/L/day Maintenance(g,i)

0.142 to 0.285 mg B/L Algae Treatment(f)

0.285 mg B/L Winterization

Spa and hot tub 

water systems

Residential, public, 

commercial, institutional 

spas and hot tubs

broadcast Water in spas or hot tubs 14.8%

(Powder)

[100% DTP]

33.4 mg B/L Initial application

Amount not specified-take 

to dealer for testing Maintenance

Wood 

preservative

(fungicide, 

insecticide, 

termiticide)

Industrial treatment facility Pressure treatment Dimensional lumber, timbers, 

plywood, millwork, and other 

engineered and solid wood 

products that are used only in 

interior, above ground 

applications or exterior, above 

ground applications which are 

protected but may be exposed to 

occasional sources of moisture, 

forest wood products, fencing, 

posts

0.16% to 5%

(RTU) [0.89% to 5.0% 

BA; 0.89% BA+

9.1%DOT; 43.5% 

DTD; 10% DOT]

0.87% (EC)

[5% BA]

1.4%, 11.05%

(Soluble Concentrate)

[8% BA; 25% 

BA+45% DTP]

4.6% to 20.8%

(granular/powder)

[26.3%, 100% BA; 

98%, 99% DOT]

Impregnation 

specifications to adhere to 

those of the the American 

Wood Protection 

Association (AWPA) or 

the company.

[*Note there are two 

products that have dual use 

as fire retardant and wood 

preservative]

0.004 to 0.79% B by 

weight of treated wood

At manufacturing

17.48%

(granular)

[100% BA]

AWPA not identified:

0.07 to 0.14 lbs B/ft3

0.004 to 0.71% B by 

weight of treated wood

At manufacturing

Industrial treatment facility Antisapstain dip or 

spray

Freshly cut lumber and wood 

products: logs, poles, posts, 

composites, veneers and wood, 

chips/sawdust or other similar 

byproducts intended for non-food

contact papermaking.

1.6% (EC)

[9% BA]

20.6% (powder) [98% 

DOT]

0.016% to 5% B by weight 

of solution At manufacturing
23

Use Pattern Use Site Application Type/ 

Equipment Treatment Site % B in EPs[% ai] Application Rate Frequency

Industrial/ Manufacturing 

facilities and in situ

Spray, dip, or flood Wood or wood products such as 

oriented strand board (OSB), 

plywood and LVL

0.16 to 4.12% (RTU)

[0.89% BA+9.1%DOT; 

20% BA; 16.7 to 19.6% 

DOT]

0.16% to 3.5% B – dip At manufacturing,

Brush, Dip, spray

diffusion

Logs and lumber for interior or 

exterior use; unseasoned wood 

utility poles, pilings, posts

0.16% to 20.6%

(RTU) [0.89% BA; 

43.5% DTD; 16.7% 

DOT; 25.3% ]

20.6%, 20.8% (powder) 

[98%, 99% DOT]

0.16% to 4.9% B solutions

At manufacturing, 

prior to placement in 

service

In situ Temporary wrap 

diffusion Wood products 4.9% (RTU) [4.9% DTD] 0.068 to 0.203 lbs B per ft3

In-service structures

Industrial/ Manufacturing 

facilities and in situ

Brush, spray or roll 

onto surfacesInterior and exterior wood, wood 

foam composite and cellulose 

insulation

0.16% to 4.12% (RTU)

[0.89% BA; 10%, 

19.6% DOT]

5.3% (FC) [25.3% 

DOT]

20.6% (powder) [98% 

DOT]

0.00007 to 0.0041 lbs B

per ft2

Preventative and 

remedial treatment

Industrial/ Manufacturing 

facilities and in situ

Inject paste, foam, 

solutions

Logs, utility poles, posts, railroad 

ties, timber, lumber, plywood, 

OSB, particle board and other 

cellulosic materials

2.063% to 30.6%

(RTU) [0.89% 

BA+9.1%DOT; 10% 

BA+4.5%DTP+5%ZB; 

40% to 43.7% DTD; 

25.3%; 30% DOT]

5.3% (FC) [25.3% 

DOT]

20.6% (powder) [98% 

DOT]

0.14 to 2.84 lbs B per ft3 (k) In-service preservative

Industrial/ Manufacturing 

facilities and in situ

Insert solid rods into 

drilled holes

Seasoned wood including 

lumber, timbers, logs, millwork, 

poles, piles, posts, crossties, 

laminated beams, etc.

24.56%, 25.41% (solid 

rods) [96.65%, 100%

DOA]

0.022 to 0.066 lbs B per ft3

Remedial and 

preventative

treatments

In situ Air or mechanical 

pressure pump 

solution into cavity Building structures

0.16% (RTU) [0.89% 

BA]

3.18% (EC) [12.5% 

DOA]

20.6% (powder) [98% 

DOT]

0.0026 to 0.118 lbs B per 

ft3

Preventative and 

remedial treatment
24

Use Pattern Use Site Application Type/ 

Equipment Treatment Site % B in EPs[% ai] Application Rate Frequency

Inject powder, foam

into wall voids and 

galleries

Building structures 20.6% (powder) [98% 

DOT] 0.0026 to 0.62 lbs B per ft2

Spray-ground line Building construction, crawl 

spaces and basement

20.6%, 20.8% (powder) 

[98%, 99% DOT]

0.0020 to 0.0052 lbs B/ft2

(h)

Ground line wraps

(includes both RTU 

wraps and pastes that 

are brushed or 

troweled on and then 

wrapped)-

Utility poles, posts, railroad ties, 

timber bridges, and other 

wooden/timber structures

1.96% to 6.27%

(RTU) [0.85% 

B+8.65% DOT, 10% 

BA+4.5% DTP+5%ZB; 

35% BA; 40% to 

43.7% DTD]

0.005 to 0.497 lbs B per ft2

(l)

In-service preventative 

or control

Brush, trowel or 

roller

Rail ties – tie plate area (~0.7 ft2) 4.5% & 4.9% (RTU)

[40% & 43.5% DTD] 0.055 to 0.108 lbs B per ft2

In situ

BA: boric acid; DOT: disodium octaborate tetrahydrate; DOA: disodium octaborate anhydrous; DTD: disodium tetraborate decahydrate; DTP: disodium tetraborate pentahydrate; 

EC: emulsifiable concentrate; FC: flowable concentrate; RTU: ready-to-use; ZB: zinc borate

(a) There is no language on wood preservative labels which have preventative, pre-treatment, or remedial in-situ applications which prohibit treatment of these materials.

(b) Labels represented here require monthly monitoring to maintain these levels.

(c) Label calls for repeating initial treatment with product until chlorine residual reaches a designated level. Therefore these values may underestimate the maximum rate.

(d) Concentration of boron is decreased only by backwash and water loss from splash out. Label application instructions call for an initial shock treatment followed by weekly 

shock treatments. Assuming weekly shock treatments and no loss from water loss or splash out, the amount of boron applied would result in: 1.8 to 5.09 mg B/L in 90 days; and 

7.4 to 20.7 mg B/L in a year. Labels also allow for more frequent shock treatment applications such as if bather loads are high, water appears hazy or dull, unpleasant odors or eye 

irritation occurs, or after a heavy rain. The values given here do not assume more frequent application and therefore may underestimate maximum boron concentrations.

(e) Concentration of boron is decreased only by backwash and water loss from splash out. Label application instructions call for daily application. Assuming daily applications and 

no loss from water loss or splash out, the amount of boron applied would result in: 0.125 to 2.09 mg B/L in a week; 1.60 to 26.8 mg B/L in 90 days; and 6.5 to 109 mg B/L in a 

year. Labels allow for more frequent applications than once daily to maintain a designated chlorine residual so under some situations the estimates may be on the low side.

(f) Label allows for repeat applications as needed, given values assume a single annual treatment with the higher value for heavy algae growth and the lower for light algae growth.

(g) These values do not reflect all end-use products as the quantity of product per tablet or pellet was unknown for some end-use products. The range of applied boron was higher 

for broadcast applications, and therefore it is likely the range here is under represented.

(h) Concentration of boron is decreased only by backwash and water loss from splash out. Label application instructions call for an initial shock treatment followed by weekly 

shock treatments. Assuming weekly shock treatments and no loss from water loss or splash out, the amount of boron applied would result in: 1.8 mg B/L in 90 days; and 7.4 mg 

B/L in a year. Labels also allow for more frequent shock treatment applications such as if bather loads are high, water appears hazy or dull, unpleasant odors or eye irritation 

occurs, or after a heavy rain. The values given here do not assume more frequent application and therefore may underestimate final boron concentrations in some situations.

(i) Concentration of boron is decreased only by backwash and water loss from splash out. Label application instructions call for daily application. Assuming daily applications and 

no loss from water loss or splash out, the amount of boron applied would result in: 0.053 to 0.25 mg B/L in a week; 0.68 to 3.2 mg B/L in 90 days; and 2.76 to 13.0 mg B/L in a 

year. Labels allow for more frequent applications than once daily to maintain a designated chlorine residual so under some situations the estimates may be on the low side.

(j) Based on label instructions can have an initial/shock treatment plus weekly shock treatments plus daily maintenance treatments. There is also nothing prohibiting the use of or 

intermixing of broadcast and automatic chlorinates, floaters and skimmers. Therefore, total boron application assuming all these actions occur is approximately 0.33 to 0.53 mg 

B/L in a week; 2.62 to 5.14 mg B/L in 90 days; and 10.3 mg B/L to 20.5 mg B/L in 365 days.

(k) Not all labels provide instructions on the number of holes to drill, their spacing, depth, or diameter or the amount of EP as a result that will be applied per cubic foot of wood.

(l) Not all labels provide how many square feet the wrap will cover so that a applications in pounds of EP per square foot can be calculate. 
Docket Number EPA-HQ-OPP-2009-0306

http://www.regulations.gov/#!docketDetail;D=EPA-HQ-OPP-2009-0306

25

The following pesticidal usage information for 2009 through 2013, the most current 

information available, in Table 2.7 is from California Department of Pesticide Regulation. The 

State of California requires full reporting of agricultural pesticide use in the state. The legal 

definition of agricultural use in this program is broad and includes reporting requirements for 

pesticide applications to parks, golf courses, cemeteries, rangeland, pastures, and along roadside 

and railroad rights-of-way. In addition, all postharvest pesticide treatments of agricultural 

commodities must be reported along with all pesticide treatments in poultry and fish production 

as well as some livestock applications. The primary exceptions to the reporting requirements are 

home-and-garden use and most industrial and institutional uses1. According to Table 2.7, the 

biggest use in California is on Premises/Structure, followed by Rights of Way uses.

Table 2.7. Pounds of Boric acid and Sodium Borate Salts (as Boron)(a) Reported to the California 

Pesticide Monitoring Program from 2009 through 2013.

Site Name

Reporting Year

2009 2010 2011 2012 2013

Agricultural Crops 51 36 51 125 93

Aquatic Areas, Water Areas (All Or Unspec) 0 0 127 0 0

Forest Trees, Forest Lands (All Or Unspec) 230 467 1221 507 3603

Landscape Maintenance 210 1520 164 1718 180

Public Health Pest & Regulatory Pest Control, Urban Areas And 

Invertebrate Pest Control 190 274 3 292 437

Premises/Structures (Agricultural, Farm, Household, Domestic 

Dwelling, Structural) 44818 95835 84277 94932 96679

Rights Of Way(b) 11237 8006 11011 7684 14824

Sewage Systems 50 0 0 0 0

Wood Protection Treatments 1427 650 0 174 0

Total Used 58216 106791 96856 105436 115818

Source: CalPIP at http://www.cdpr.ca.gov/docs/pur/purmain.htm accessed June 22, 2015

(a) Values reported in the database as pounds of active ingredient (boric acid, borax, boron oxide, disodium octaborate 

tetrahydrate , sodium metaborate tetrahydrate, disodium octaborate anhydrous, and sodium tetraborate pentahydrate) were 

converted for this assessment to boron equivalents. The sodium tetraborate pentahydrate product reported as used, actually 

contains sodium borate pentahydrate.

(b) Products used were primarily for treatment of wood poles and posts as compared to other applications in rights-of-way. 

Relative to the wood preservative uses, the herbicide, treatment of tree root diseases, and pest control (e.g., ant and roach baits) 

ranged from 3.2 to 109 lbs per year

2.3.3 Label Uncertainties

Many labels do not contain annual maximum application rates or application intervals for 

both agricultural and non-agricultural outdoor uses. Also many of the non-agricultural uses were 

for non-broadcast types of applications (e.g., spot treatments) that are difficult to quantify on a 

spatial scale or to estimate runoff potential. For these applications, risk is assumed to coincide 

mainly with the immediate application area. Additionally, for antimicrobial uses, the water 

processing systems and recirculating cooling water system uses and bacteriostatic use in/on 

 

1 http://www.cdpr.ca.gov/docs/pur/purmain.htm accessed June 22, 2015
26

absorbent material such as kitty litter are included on technical labels, but do not appear on end 

use product labels.
27

3 Exposure Assessment

For crop applications standard available models were used to evaluate potential 

exposures to aquatic and terrestrial organisms as described at

http://www.epa.gov/pesticides/science/models_db.htm. The model results are summarized in 

this Chapter. A qualitative approach was used to assess risks from the antisapstain, wood 

preservative, material preservative, and recreational water treatment use patterns so no EECs 

were modeled for these use patterns. For the qualitative assessment information on natural 

background levels and loading to environmental media (Appendix C), and anthropogenic 

nonpesticidal sources of boron loading to the environment (Appendix D) were used to 

characterize risks from the antimicrobial use patterns.

3.1 Environmental Fate Summary

The chemical properties of boric acid are listed in Table 3.1. Submitted chemistry and 

fate studies are listed in Appendix E. Some physical and chemical properties of boric acid and 

the related compounds are listed in Table 3.2.

Boric acid should persist indefinitely until absorbed and metabolized by a plant or 

animal. As an acid, boric acid will be present in the water column, and will be very mobile. 

Boric acid is the stable form of boron in the environment, and is not expected to break down any 

further. Boric acid may act as a Lewis base and complex with an electron pair donor. Boron 

will readily leach from treated wood exposed to rain, or run-off. Boric acid dissipates by 

transport in surface or ground water. 

Table 3.1. Chemical Properties of Boric Acid.

Parameter Value Source

Common name Boracic acid, ortho boric acid salts, 

borofax

Merck Index, 1983

Chemical name Boric acid

Pesticide type (Chemical class) Inorganic salt

CAS number 10043-35-3 Merck Index, 1983

Empirical formula H3BO3

Molecular mass (g/mol) 61.84

Vapor pressure Volatile with steam

Henry’s Law Constant (atm-m

3

/mol) Not calculated

Solubility in water (g/L) 1 g/18 mL cold water

1 g/4 mL boiling water

Merck Index, 1983

Log Kow Not applicable

pKa (or pKb) pH of 0.1 molar solution: 5.1 Merck Index, 1983
Docket Number EPA-HQ-OPP-2009-0306

http://www.regulations.gov/#!docketDetail;D=EPA-HQ-OPP-2009-0306

28

Table 3.2 Chemical and Physical Properties of Boric Acid and Sodium Borate Salts in this Case.

Property Boric Acid(1) Boron Oxide(1) Borax(1) DOT(2) DOA(2) Borax Pentahydrate(1) Anhydrous Borax(1)

Chemical 

Abstracts 

Registry (CAS) 

No. 

10043-35-3 1303-86-2 1303-96-4 12280-03-4 12008-41-2

12179-04-3; 

11130-12-4

1330-43-4 

U.S. EPA 

Pesticide 

Chemical Code 

011001 011002 029601 or 011102 011103 011107 011110 011112 

Synonyms 

boron trihydroxide; 

trihydroxy borate; 

orthoboric acid; 

boracic acid 

Boric oxide; boron 

trioxide; anhydrous 

boric acid 

Disodium tetraborate 

decahydrate; borax 

decahydrate; borax 10 

Boron sodium oxide, 

tetrahydrate; 

Disodium octaborate 

tetrahydrate (DOT)

Boron sodium 

oxide, anhydrous; 

Disodium 

octaborate

anhydrous (DOA)

Sodium tetraborate 

pentahydrate; Borax 5 

Sodium tetraborate; 

borax glass; disodium 

tetraborate; fused 

borax 

Chemical 

Formula H3BO3 B2O3 Na2B4O7·10H2O Na2B8O13·4H2O Na2B8O13 Na2B4O7·5H2O Na2B4O7 

Molecular 

Weight 61.83 69.62 381.43 412.52 340.46 291.35 201.27 

Boron Content 17.48% 31.05% 11.34% 20.96% 25.41% 14.85% 21.48%

Physical State 

Solid; white or 

colorless crystalline 

granules or powder 

Solid; white or 

colorless vitreous 

granules 

Solid; white or 

colorless crystalline 

granules or powder 

Solid; white colorless 

powder 

Solid, clear, glasslike

Solid; white or 

colorless crystalline 

granules or powder 

Solid; white or 

colorless vitreous 

granules 

Boiling Point 30°C 1,860°C none identified 567 o C 

(decomposition)C Not established none identified 1,575°C (decomposes) 

Melting Point 

171°C (closed space) 

450°C (anhydrous, 

crystal form) 

450°C >62°C (closed space) 815oC 1000 oC <200°C (closed space) 742°C 

Density (at 20 

°C) 1.51 2.46 1.73 320 to 480 kg/m3 1.81 2.37 

Vapor Pressure: 

At 20 °C none identified none identified none identified Negligible NA none identified none identified 

At 25 °C none identified none identified none identified none identified none identified 

Log Kow none identified none identified none identified Inorganic-NA Inorganic-NA none identified none identified 

Log Koc none identified none identified none identified Inorganic-NA Inorganic-NA none identified none identified 

Solubility in: 

Water 

55.6 g/L cold water

250 g/L boiling water

rapidly hydrates to 

boric acid 62.5 g/L at 25°C 223.65 g/L @ 20oC 100% by wt 35.9 g/L at 20°C 482.4 g/L at 100°C 

24.8 g/L at 20°C 

331.2 g/L at 100°C 

Other Solvents methanol, acetone, 

alcohol, glycerol alcohol, glycerol glycerol Not relevant Not relevant glycerol ethylene glycol 

(1)Source: Health Effects Support Document for Boron (EPA-822-R-08-002, 2008). 

(2)Material data safety sheet for technical
Docket Number EPA-HQ-OPP-2009-0306

http://www.regulations.gov/#!docketDetail;D=EPA-HQ-OPP-2009-0306

29

An acceptable wood leaching study for the leaching of boric acid from treated lumber by 

rainfall was submitted (MRID 46074205) and found to be acceptable. The study was submitted 

to support registration of the end-use product Wolsin FL-35. In this AWPA E20-08 study, the 

leaching of boric acid as a component mixture with the separate active ingredients 

fenpropimorph and propiconazole was studied. Lumber was pressure treated with Wolsin FL-35, 

to a retention of 0.025 lbs a.e. per cubic foot (0.0044 lbs boron equivalents per cubic foot) . 

Boric acid leaching occurred separately from the other compounds. The leaching rates of boric 

acid were 1.82 μg/cm2/day (maximum), 0.01 μg/cm2/day (minimum), 0.32 μg/cm2/day 

(average), and 38 μg/cm2(cumulative).

3.2 Aquatic Exposures

Table 3.3 tabulates screening level EECs based on the GENEEC model for the previous 

crop use assessment. At that time, the application rate of 0.07 lb a.e./A was used. The rate is a 

little higher than the current allowed maximum application rate of 0.0625 lb a.e./A for the 

agricultural use sites (see Appendix F for all modeling inputs and results).

Table 3.3. Boric Acid and Sodium Borate Salts Screening-level EECs.

GENEEC Modeled Use Type of 

Application

Peak 

Exposure (μg/L)

21-day Average 

Exposure (μg/L)

60-day Average 

Exposure (μg/L)

One application of 0.07 lb 

a.e./A Ground 4.10 4.09 4.09

52 applications of 0.07 lb 

a.e./A (7-d interval) Ground 213 213 213

3.2.1 Monitoring Data

Analyses of boron levels in fresh (surface water and public water systems) and sea water 

have been published (summarized in EPA IRIS, 2004 and ATSDR, 1992). Concentrations of 

boron in fresh water vary, depending upon environmental conditions and local soil levels, but 

concentrations in fresh water normally range from < 0.01 to 1.5 ppm (average of 0.1 ppm) but 

may be higher in areas of very high soil boron levels. A survey of 989 public water supply 

systems in the United States showed that 90% had concentrations of 0.4 ppm or less and 99% 

had concentrations less than 1 ppm. On average, sea water contains higher boron concentrations 

(range 0.5 to 9.6 ppm; average 4.6 ppm).

Boron has been identified as a cause of impairment in fifty four streams (sixty-four 

counting tributaries) in the U.S. that are listed as impaired under section 303(d) of the Clean 

Water Act. These water bodies have been assigned TMDLs (Total Maximum Daily Loads)2for 

boron ranging from 0.75 ug/L to 2,000 mg/L, and almost all TMDLs in the Office of Water 

database are currently 750 ug/L, which is the same as the National Ambient Water Quality 

Criteria for boron of 750 μg/L for long-term irrigation3(for more details see Section 5.2.2).

 

2 http://iaspub.epa.gov/tmdl_waters10/attains_nation_cy.cause_detail_303d?p_cause_group_id=885

3 http://water.epa.gov/scitech/swguidance/standards/criteria/current/index.cfm accessed 6/23/2015.
30

3.3 Terrestrial Exposures

3.3.1 Birds and Mammals

EECs for birds and mammals through dietary items based on agriculture uses were 

calculated using T-REX v.1.5.2. EECs are based on application rates, number of applications, 

and intervals presented in Table 2.1 to Table 2.5. A foliar dissipation rate of 35 days was used 

for this analysis to estimate dissipation after each application. Model inputs are detailed in 

Appendix G. Resulting upper bound exposure estimates to birds and mammals are given in 

Table 3.4.

Table 3.4. T-REX Calculated EECs as Food Residues for Terrestrial Animals from Labeled 

Agricultural and Non-Agricultural Outdoor Uses of Boric Acid and Sodium Borate Salts.

Food Type

Dietary-Based EEC

(ppm a.e.)

(Mammals and 

Birds)

Dose-Based EEC for Birds

(mg a.e./kg-bw)

Dose-Based EEC for Mammals

(mg a.e./kg-bw)

All Size Classes Small

(20 g)

Medium

(100 g)

Large

(1000 g)

Small

(15 g)

Medium

(35 g)

Large

(1000 g)

Application Rate of 0.0625 lb a.e./A x 1 application

Short grass 16.8 19.1 10.9 4.88 16.0 11.1 2.57

Tall grass 7.70 8.77 5.00 2.24 7.34 5.07 1.18

Broadleaf plants 9.45 10.8 6.14 2.75 9.01 6.23 1.44

Fruits/pods 1.05 1.20 0.68 0.31 1.00 0.69 0.16

Arthropods 6.58 7.49 4.27 1.91 6.27 4.34 1.01

Seeds 1.05 0.27 0.15 0.07 0.22 0.15 0.04

Application Rate of 0.0625 lb a.e./A x 52 applications (7-day interval)

Short grass 116 132 75.2 33.7 110 76.3 17.7

Tall grass 53.1 60.4 34.5 15.4 50.6 35.0 8.11

Broadleaf plants 65.1 74.2 42.3 18.9 62.1 42.9 9.95

Fruits/pods 7.24 8.24 4.70 2.10 6.90 4.77 1.11

Arthropods 45.4 51.7 29.5 13.2 43.2 29.9 6.93

Seeds 7.24 1.83 1.04 0.47 1.53 1.06 0.25

Exposure estimates for the highest use rate for liquid broadcast applications (for multiple 

agricultural and non-agricultural uses) presented in Table 3.4 are based on the maximum use rate 

of 0.0625 lb a.e./A at 1 application and at 52 applications (with a 7-day interval). The latter is a 

conservative estimate since the labels do not specify an annual maximum application rate.

For granular applications, the highest use rate is 3 lbs a.e./100 sq. ft at 2 applications 

(with a 90-day interval) for drainage systems, fencerows/hedgerows, rights-of-way, recreation 

areas, and other uses. Table 3.5 shows that this application rate would result in 13.6 g 

a.e./square foot.
31

Table 3.5. T-REX Calculated EEC for Granular Applications.

Use Type of Application Application Rate Granular EEC

Drainage System, 

Fencerows/Hedgerows, 

Non-Agricultural Rights-OfWays, Non-Agricultural 

Uncultivated Areas/Soils, 

Paths/Patios, Recreation 

Areas, Urban Areas

Broadcast/hand-carried 

granule applicator, power 

granule applicator

3 lb /100 sq. ft 

(1310 lb a.e./A)

2 applications /year

90 days MRI

13.6 g a.e./sq ft

3.3.2 Terrestrial Invertebrates

The Guidance for Assessing Pesticide Risks to Bees (USEPA et al., 2014) provides 

equations for the calculation of EECs for bees. The Tier I exposure method is intended to 

account for the major routes of pesticide exposure that are relevant to bees (i.e., through diet and 

contact). Exposure routes for bees differ based on application type. Bees foraging in a field 

treated with a pesticide through foliar spray, such as boric acid and sodium borate salts, could 

potentially be exposed to the pesticide through direct spray as well through consuming 

contaminated food. Foraging honey bees may also be exposed to pesticides via consumption of 

water from surface water, puddles, dew droplet formation on leaves, and guttation fluid; 

however, the Tier I exposure method does not include quantification of exposures via these 

routes.

The EECs for a single foliar application of boric acid and sodium borate salts at the 

maximum application rate are calculated below.4

Adult Contact EEC = 0.0625 lbs a.e./A * 2.7 μg a.e./bee = 0.169 μg a.e./bee

3.3.3 Terrestrial Plants

EECs for terrestrial plants were calculated using TERRPLANT v.1.2.2. TERRPLANT 

inputs are detailed in Appendix H. Resulting upper bound exposure estimates to terrestrial and 

semi-aquatic (wetland) plants are given in Table 3.6. EECs are based on the maximum single 

application rate for terrestrial uses, solubility, and spray drift fraction. The default spray drift 

assumptions in the model were updated to reflect the most recent spray drift modeling guidance 

with 6% for ground applications and 12% for aerial applications (USEPA, 2013).

Table 3.6. Calculated EECs for Terrestrial and Semi-Aquatic Plants near Application Areas for 

Boric Acid and Sodium Borate Salts.

Use Site

Single Max. 

Application Rate

(lbs a.e./A)

EECs (lbs a.e./A)

Ground

Dry Areas (Total) Semi-Aquatic Areas 

(Total) Spray Drift 

Ornamentals, Fruits, 

Soybeans, etc. 0.0625 0.00375 0.0319 0.000625

 

4 Based on food consumption rates for larvae (0.124 g/day) and adult (0.292 g/day) worker bees and concentration in 

pollen and nectar.
Docket Number EPA-HQ-OPP-2009-0306

http://www.regulations.gov/#!docketDetail;D=EPA-HQ-OPP-2009-0306

32

4 Effects Analysis

Boron is an essential nutrient for plants, fish, aquatic invertebrates and if not essential 

beneficial to a number of phylogenetic groups, in low quantities. Toxicity of boric acid and the 

sodium borate salts in this case may be partially dependent on pH, there is contradictory 

evidence in the results included in the literature – see Appendices I and J for an annotated 

compilation of toxicity information. A list of submitted studies considered is found in Appendix 

E and a list of open literature papers considered from the July 2014 ECOTOX query (USEPA, 

2009b) is found in Appendix J. These papers were screened and data from some of these 

studies were used in this assessment because they were more sensitive than available data from 

submitted studies; these were reviewed according to the approved procedures (USEPA, 2011). 

Summaries of the most sensitive aquatic and terrestrial toxicity data for boric acid and sodium 

borate salts are found in the following sections.

4.1 Aquatic Toxicity Data

A list of aquatic toxicity endpoints used in risk calculations is found in Table 4.1. Boric 

acid is practically non-toxic to slightly toxic to fish and aquatic invertebrates, depending in part 

on the taxon, but also in part on whether the toxicity classification is based on boric acid or 

elemental boron (Table 4.1, also see Appendix I), which is an artifact of the weight per volume 

classification scheme. Estuarine/marine invertebrates may be slightly more acutely sensitive 

than freshwater invertebrates with the most sensitive useable acute endpoints being 80.1 mg 

a.e./L (LC50 for the whiteleg shrimp, Li, et al., 2008) and 260 (LC50 for the small daphnid, 

Ceriodaphnia dubia, Dethloff, et al., 2009), respectively. Conversely, estuarine/marine 

vertebrates were slightly less sensitive with the most sensitive useable acute endpoints being 555 

(LC50 for the sea bream, Furuta, et al., 2007) and 404 (LC50 for the fathead minnow, EPA, 

2010a,b), respectively. However, the fathead minnow endpoint was from a lower pH (6.75) than 

the sea bream endpoint (pH of 8.1-8.2) and the toxicity endpoint was actually higher than the sea 

bream at higher pH (fathead minnow LC50 of 784 mg a.e./L at a pH of 7.75). The guideline 

(850.1075) allows for the pH in freshwater studies to range from 6.0 to 8.0, and so the lower 

fathead minnow endpoint is still useable. Studies conducted to examine the effect on pH in 

freshwater species by the agency (USEPA 2010a,b) found no pH effect on toxicity.
33

Table 4.1. Toxicity Endpoints Selected for Risk Estimation for Aquatic Organisms Exposed to 

Boric Acid and Sodium Borate Salts.

Taxon Exposure 

Duration Guideline

Most 

Sensitive 

Species 

Tested

Toxicity Value Acute 

Toxicity 

Category

Study 

Classification

MRID or 

Citation Expressed as 

mg a.e./L

Expressed 

as mg B/L

Freshwater 

Invertebrates

Acute NG

Daphnid,

Ceriodaphni

a dubia

48-hr EC50 = 

260

48-hr EC50 = 

45.5

Practically 

Nontoxic

Supplemental/ 

Quantitative

Dethloff, et al., 

2009 (E118810)

Chronic, 

Reproduction

ACRinvert

method

Daphnid,

C. dubia NOAEC = 8.9 NOAEC = 1.6 N/A

ACRinvert = 

29.2 (see 

Table I4 in 

Appendix I)

Lewis and 

Valentine 1981; 

Gersich 1992 

(see Tables I1 

and I3 in 

Appendix I)

Freshwater 

Fish

Acute

ASTM 

E729 which 

is 

comparable 

to 850.1075

Fathead 

minnow, 

Pimephales 

promelas

96-hr LC50 = 

404

96-hr LC50 = 

70.6

Practically 

non-toxic on 

a.e. basis, 

slightly toxic 

on a B basis

Acceptable EPA, 2010a,b

Chronic, 

Early Life 

Stage

850.1400

Fathead 

minnow,

P. promelas

NOAEC = 421 NOAEC = 

7.31 N/A Acceptable 48914601

Estuarine/ 

Marine 

Invertebrates

Acute NG

Whiteleg

shrimp,

Litopenaeus 

vannamei

96-hr LC50 = 

80.1 

96-h LC50 = 

14.0

Slightly 

Toxic

Supplemental/ 

Quantitative

Li, et al., 2008

(E111738)

Chronic N/A No Data -- -- N/A --

2

--

Estuarine/ 

Marine Fish

Acute OECD 203

Red sea 

bream, 

Pagrus 

major

96-hr LC50 = 

555

96-hr LC50 = 

97

Practically 

non-toxic on 

a.e. basis, 

slightly toxic 

on a B basis

Supplemental/ 

Quantitative

Furuta, et al., 

2007 (E166696)

Chronic N/A No Data -- -- N/A --

3

--

Nonvascular 

plant

Tier I and 

Tier II 850.4500

Freshwater 

blue-green 

algae, 

Anabaena 

flos-aquae

IC50 = 81.3 

NOAEC = 9.24

IC50 = 14.2 

NOAEC = 

1.64

N/A Acceptable 48820801

Vascular 

plant

Tier I and 

Tier II 850.4400 Duckweed,Lemna gibba

IC50 = 163

NOAEC = 605

IC50 = 28.5 

NOAEC = 115

N/A Acceptable 48820802

B = elemental boron; ASTM = Amer. Soc. for Testing and Materials; ACR = acute to chronic ratio; N/A = not applicable; NG = 

non-guideline; -- = information unavailable.

1Based on significantly reduced total length.

2 ACR values derived from freshwater organisms are not always applicable to estuarine/marine counterparts and vice versa. An 

ACR from each group is usually needed to provide evidence that the ACR is the same for both (Stephan et al. 1986). For boron, 

an ACR based on a freshwater invertebrate may not be applicable for saltwater invertebrates because its use results in a value 

below background levels (background level of B in seawater is about 5 mg/L). Therefore no chronic value was calculated.

3 At this time there is evidence that an ACR derived using a freshwater species is not applicable to estuarine/marine species. 

Therefore, while an estimated ACR might be derived from the fathead minnow, its application to a saltwater fish is suspect. 

4Based on significantly reduced AUC (area under the curve).

5Based on significantly reduced final biomass.
34

The Office of Pesticide Programs (OPP) publishes Aquatic Life Benchmarks5for 

freshwater species based on toxicity values for the most sensitive species from the most recent 

risk assessments. The aquatic life benchmarks have been published for boric acid salts. These 

are not the same as endpoints used in this assessment since those values have been updated (see 

Table 4.1). The newer fish endpoint is similar and is a definitive value; the invertebrate 

endpoint is lower than the freshwater invertebrate acute endpoint, but similar to the 

estuarine/marine invertebrate endpoint.

Form Fish (μg/L) Invertebrates (μg/L)

Acute Acute

Boric Acid Salts >400,000 66,500

4.2 Terrestrial Toxicity Data

A list of terrestrial toxicity endpoints used in risk calculations is found in Table 4.2 for 

animals and Table 4.3 for plants.

 

5 Office of Pesticide Programs’ Aquatic Life Benchmarks. 

http://www.epa.gov/oppefed1/ecorisk_ders/aquatic_life_benchmark.htm
35

Table 4.2. Toxicity Endpoints Selected for Risk Estimation for Terrestrial Organisms Exposed to 

Boric Acid and Sodium Borate Salts.

Taxon Exposure 

Duration Guideline

Most 

Sensitive 

Species 

Tested

Toxicity Value Acute Toxicity 

Category/

Study Classification

MRID

Expressed as a.e. Expressed as B

Mammals

Acute Oral N/A Rat LD50 = 450 

mg a.e. /kg-bw1

LD50 = 79 

mg B/kg-bw1

Moderately 

toxic/

Acceptable

00005584/ 

Weir and 

Fisher 1972

2 -Generation 

Chronic N/A Mouse NOAEL= 150 mg a.e./kg-diet2

NOAEL = 26 

mg B/kg-diet2

N/A/

Acceptable 00005584

Birds

Acute Oral 850.2100 

Bobwhite 

quail, Colinus 

virginianus

LD50 >1,625 mg 

a.e./kg-bw 

LD50 >284 mg 

B/kg-bw 

At most slightly 

toxic on an a.e. 

basis and at most 

moderately toxic 

on a B basis 

/ Acceptable

00100657

Modified 

Study/Acute 

Dietary

850.2100/ 

850.22003

Canary

Serinus

canaria

LC50 >11,000 mg 

a.e./kg-diet

NOAEC = 1870 

mg a.e./kg

LOAEC = 4570 

mg a.e./kg-diet4

LC50 >1920 mg 

a.e./kg-bw 

NOAEC = 327 

mg a.e./kg

LOAEC = 799 

mg a.e./kg-diet4

Practically 

nontoxic on an

a.e. basis and at 

most slightly 

toxic on a B 

basis/ 

SupplementalQuantitative

48851202

Sub-acute 

Dietary (8 day 

study duration, 

5 day 

exposure)

850.2200 Both mallard 

and bobwhite

LC50 >5,620 mg 

a.e./kg-diet5

(0/10 mortalities)

LC50 >982 mg 

B/kg-diet5

(0/10 

mortalities)

Practically 

nontoxic on an 

a.e. basis and at 

most moderately 

toxic on a B 

basis/ 

Acceptable

ACC254367

Chronic

Reproduction 850.2300

Mallard duck

A. 

platyrhynchos

NOAEC = 249 mg 

a.e./kg-diet 

(21.2 mg a.e./kgbw estimated daily 

dose)6

NOAEC = 43.6 

mg B/kg-diet 

(3.7 mg B/kgbw estimated 

daily dose)6

N/A/

Acceptable 49009801

Terrestrial 

Non-target 

Invertebrates

Acute Contact

NG -

similar to 

850.3020 Honey Bee LD50 = 363 μg a.e./bee

LD50 = 63 μg 

B/bee

Practically 

nontoxic/ 

Acceptable

40269201

-- = information unavailable; a.e. = acid equivalents; B = boron; mg/kg-bw = milligrams per kilogram body weight; mg/kg-diet = 

milligrams per kilogram of diet N/A = not applicable; NG = non-guideline method.

1 Based on mortality.

2 Based on decreased parental organ weight, fertility, and decreased pup weight.

3 This study design (850.2200 modified) is an acceptable alternative to the standard oral acute toxicity test (850.2100) which 

administers a single dose of test substance. The alteration was made because preliminary work by the study authors showed that 

canaries quickly regurgitated the single dosage of boric acid. The primary study endpoint was survival. Observations were also 

made on body weight, food consumption, and changes in behavior. Body weight at study initiation was 18.0 to 29.4g.

4 Based on 5-day weight gain.

5 Based on no mortalities in highest treatment.

6 Based on % hatchlings/ live embryos.

Boric acid is practically non-toxic to moderately toxic to terrestrial birds and mammals 

depending on the taxon as well as whether the classification is based on boric acid or elemental 

boron (Table 4.3, also see Appendix I), since the molecular weight of boric acid is greater than 

elemental boron and the classification is based on concentration (weight per volume. For birds, 

all acute toxicity endpoints were from studies that did not have toxicity in the highest treatment 
36

due to low toxicity, but the test levels could not rule out slight or moderate toxicity. Toxicity to 

passerine bird species was tested, but preliminary studies with oral dosing to canaries resulted in 

regurgitation and so a dietary acute was conducted. Even with test concentrations in the diet of 

>11,000 mg a.e./kg-diet, mortality was not found, though changes in body weight, food 

consumption and behavior were seen at 4570 mg a.e./kg-bw. 

Boric acid is classified as practically non-toxic to terrestrial invertebrates based on the 

traditional honeybee acute contact test (LD50 of 363 μg a.e./bee, MRID 40269201). However, 

pollinator studies associated with new Agency guidance have not yet been submitted.

Table 4.3. Toxicity Endpoints Selected for Risk Estimation for Terrestrial Plants Exposed to Boric 

Acid and Sodium Borate Salts.

Test Type Most Sensitive 

Species Tested Guideline

Toxicity Value

MRID

lb a.e./A lb B/A

Terrestrial 

Plants 

Tier I and 

Tier II

Most sensitive 

monocot: Could 

not be determined1

Seedling 

Emergence

850.4100

using TGAI2

IC25 > 5.0 

NOAEC > 5.0

IC25 > 0.87 

NOAEC > 0.87 48885402

Most sensitive 

dicot: Oilseed rape

IC25 > 5.0 

NOAEC = 0.653

IC25 > 0.87 lb

NOAEC = 0.11

Most sensitive 

monocot and 

dicot: Could not 

be determined1

Vegetative 

Vigor

850.4150

using TGAI2

IC25 > 0.2

NOAEC > 0.2

IC25 > 0.03

NOAEC > 0.03 48885401

1Species tested: monocot (corn, Zea mays; onion, Allium cepa; ryegrass, Lolium perenne; and oat, Avena sativa) and 

dicot (common bean, Phaseolus vulgaris; cucumber, Cucumis sativus; oilseed rape, Brassica napus; radish, 

Raphanus sativus; soybean, Glycine max; and tomato, Lycopersicon esculentum).

2This study was conducted with TGAI (technical-grade active ingredient) rather than the recommended TEP (typical 

end use-product) for conventional use patterns and since plants from conventional use patterns may be exposed 

directly to the whole product, some uncertainty exists as to potential effects from adjuvants in formulated products 

for these use patterns. 

3Based on significant reduction of 9.9% in in shoot length at 1.4 lb a.e./A (p<0.05).

For most plant species tested, boric acid did not cause measureable effects in the highest 

treatments tested, 5.0 lb a.e./A for seedling emergence and 0.2 lb a.e./A for vegetative vigor 

(MRIDs 48885401 and 48885402), with the exception of reduced shoot length in oilseed rape at 

treatments of 1.4 lb a.e./A and higher.

4.3 Endocrine Disruptor Screening Program

As required by FIFRA and FFDCA, EPA reviews numerous studies to assess potential 

adverse outcomes from exposure to chemicals. Collectively, these studies include acute, 

subchronic and chronic toxicity, including assessments of carcinogenicity, neurotoxicity, 

developmental, reproductive, and general or systemic toxicity. These studies include endpoints 

which may be susceptible to endocrine influence, including effects on endocrine target organ 

histopathology, organ weights, estrus cyclicity, sexual maturation, fertility, pregnancy rates, 

reproductive loss, and sex ratios in offspring. For ecological hazard assessments, EPA evaluates 

acute tests and chronic studies that assess growth, developmental and reproductive effects in 

different taxonomic groups. As part of its reregistration decision for boric acid and sodium 

borate salts, EPA reviewed these data and selected the most sensitive endpoints for relevant risk 

assessment scenarios from the existing hazard database. However, as required by FFDCA 
37

section 408(p), boric acid and sodium borate salts are subject to the endocrine screening part of 

the Endocrine Disruptor Screening Program (EDSP).

EPA has developed the 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, 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 dose-response relationship between the dose and the E, A, or T effect. 

Under FFDCA section 408(p), the Agency must screen all pesticide chemicals. 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. A second list 

of chemicals identified for EDSP screening was published on June 14, 20136and includes some 

pesticides scheduled for registration review and chemicals found in water. Neither of these lists 

should be construed as a list of known or likely endocrine disruptors. 

For further information on the status of the EDSP, the policies and procedures, the lists of 

chemicals, future lists, the test guidelines and the Tier 1 screening battery, please visit our 

website.7

 

6 See http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OPPT-2009-0477-0074 for the final second list of 

chemicals.

7 http://www.epa.gov/endo/
38

5 Environmental Risk Assessment 

For this preliminary risk assessment (PRA) of boric acid and sodium borate salts, the 

deterministic RQ method was used to provide a metric of potential risks for the agricultural use 

patterns. A qualitative approach was used to assess risks from the antimicrobial use patterns. 

5.1 Risk Estimates

The RQ is a comparison of exposure estimates to toxicity endpoints (i.e., RQ = 

EEC/toxicity endpoint). The resulting RQs are compared to the Agency’s risk levels of concern 

(LOC), which are the Agency’s interpretive policy such that when acute or chronic risk LOCs 

are exceeded, the need for regulatory action may be considered. These criteria are used to 

indicate when the use of a pesticide, as directed on the label, has the potential to cause adverse 

effects to non-target organisms. For acute and chronic risks to animals, the LOCs are 0.5 and 1.0, 

respectively, and for plants, the LOC is 1.0. The LOC for terrestrial invertebrates is 0.4. For 

listed aquatic animals, the acute LOC is 0.05 and for listed terrestrial animals the acute LOC is 

0.1. For each taxon, RQs are generated and risks are discussed. This discussion includes 

consideration of additional data and lines of evidence.

5.1.1 Aquatic Organisms

Calculated RQs for aquatic invertebrates, fish and plants are presented in the following 

sections (Sections 5.1.1 - 5.1.3; Tables 5.1 - 5.3) based on the calculated peak EECs of 0.0041 

mg a.e./L for one application and 0.213 mg a.e./L for weekly applications at the maximum 

application rate for ornamentals, soybeans and other crops (Table 3.3).

5.1.1.1 Aquatic Invertebrates

No LOC exceedances were calculated for aquatic invertebrates (Table 5.1).

Table 5.1. Acute and Chronic Aquatic Water Column Invertebrate RQ Values for Agricultural 

and Non-Agricultural Outdoor Uses.

Use Sites

Freshwater RQ Estuarine/Marine RQ

Acute Chronic Acute1

LC50 = 260

mg a.e./L

NOAEC = 8.9 mg 

a.e./L LC50 = 80.1 mg a.e./L

One application of 0.07 lb a.e./A <0.01 <0.01 <0.01

52 applications of 0.07 lb a.e./A (7-d 

interval) <0.01 0.0239 <0.01

Bolded values exceed the LOC for non-listed species of 0.5 for acute risk or 1.0 for chronic risk.

Shaded values exceed the LOC for listed species of 0.05 for acute risk or 1.0 for chronic risk.

1 No acceptable chronic toxicity estimate was available; therefore, the freshwater chronic RQs will be assumed to apply to 

estuarine/marine species.

5.1.1.2 Fish

No LOC exceedances were calculated for fish (Table 5.2). Fish are also surrogate species 

for aquatic-phase amphibians.
39

Table 5.2. Acute and Chronic Fish Risk Quotients for Agricultural and Non-Agricultural Outdoor 

Uses.

Use Sites

Freshwater Estuarine/Marine 

Acute Chronic Acute1

LC50 = 404 mg 

a.e./L

NOAEC = 42

mg a.e./L LC50 = 555 mg a.e./L

One application of 0.07 lb a.e./A <0.01 <0.01 <0.01

52 applications of 0.07 lb a.e./A (7-d interval) <0.01 <0.01 <0.01

Bolded values exceed the LOC for non-listed species of 0.5 for acute risk or 1.0 for chronic risk.

Shaded values exceed the LOC for listed species of 0.05 for acute risk or 1.0 for chronic risk.

1 No acceptable chronic toxicity estimate was available; therefore, the freshwater chronic RQs will be assumed to apply to 

estuarine/marine species.

5.1.1.3 Aquatic Plants

No LOC exceedances were calculated for aquatic plants (Table 5.3).

Table 5.3. Aquatic Plant Risk Quotients for Agricultural and Non-Agricultural Outdoor Uses.

Use Sites

Vascular Non-vascular 

Non-listed Listed Non-listed Listed

IC50 = 163 mg 

a.e./L

NOAEC = 60

mg a.e./L

IC50 = 81.3 mg 

a.e./L

NOAEC = 9.2 

mg a.e./L

One application of 0.07 lb a.e./A <0.01 <0.01 <0.01 <0.01

52 applications of 0.07 lb a.e./A (7-d 

interval) <0.01 <0.01 <0.01 0.02

Bolded values exceed the LOC of 1.0.

5.1.2 Terrestrial Species

5.1.2.1 Birds

Table 5.4 gives RQ calculations based on both one application and the conservative 

estimate assuming weekly applications at the highest broadcast application rate of 0.0625 lb 

a.e./A. Birds are also surrogate species for terrestrial-phase amphibians and reptiles. No LOC 

exceedances were found from one application. One size/feeding class (small birds feeding on 

short grass) could potentially exceed the listed-species LOC (0.1) but this is based on an 

endpoint that was non-definitive (greater than >) due to lack of toxicity at the highest dose rate. 

This is almost certainly an artifact of the study design and conservative assumption of weekly 

applications. The available dietary endpoint for birds, when screened using TREX, did not result 

in any LOC exceedances.
40

Table 5.4. Upper Bound Kenaga, Acute and Chronic Avian Dose- and Dietary-Based Risk 

Quotients for Agricultural and Non-Agricultural Outdoor Uses.

Dietary 

Item

Avian RQs

Acute Dose-based Size Classes Acute 

Dietary-based

Chronic 

20 g 100 g 1000 g Dietary-based

Adjusted LD50 = 

>1170 mg 

a.e./kg-bw1

Adjusted LD50 = 

>1490 mg a.e./kgbw1

Adjusted LD50 = 

>2110 mg 

a.e./kg-bw1

LC50 = 

>5620 mg 

a.e./kg-diet1

NOAEC = 

249 mg 

a.e./kg-diet

Application Rate of 0.0625 lb a.e./A x 1 application

Short grass <0.02 <0.01 <0.01 <0.01 0.07

Tall grass <0.01 <0.01 <0.01 <0.01 0.03

Broadleaf 

plants <0.01 <0.01 <0.01 <0.01 0.04

Fruits/pods <0.01 <0.01 <0.01 <0.01 <0.01

Arthropods <0.01 <0.01 <0.01 <0.01 0.03

Seeds <0.01 <0.01 <0.01 <0.01 <0.01

Application Rate of 0.0625 lb a.e./A x 52 applications (7-day interval)

Short grass <0.13 <0.06 <0.02 <0.02 0.52

Tall grass <0.06 <0.03 <0.01 <0.01 0.24

Broadleaf 

plants <0.07 <0.03 <0.01 <0.01 0.29

Fruits/pods <0.01 <0.01 <0.01 <0.01 0.03

Arthropods <0.05 <0.02 <0.01 <0.01 0.20

Seeds <0.01 <0.01 <0.01 <0.01 0.03

Bolded values exceed the LOC for non-listed species of 0.5 for acute risk or 1.0 for chronic risk.

Shaded values exceed the LOC for listed species of 0.1 for acute risk or 1.0 for chronic risk.

1These endpoints are non-definitive, greater than (>) values due to lack of toxic response in the highest treatment. Therefore, the 

RQs presented here that are calculated using those endpoints are less-than (<) values and are upper-bound estimates for 

screening.

For granular applications, the use rate for drainage systems, fencerows, etc. was higher 

but more localized. The amount calculated of 13.6 g a.e./sq. ft. (see Table 5.5) was compared to 

the available non-definitive avian oral dosing toxicity endpoint and showed that the potential for 

up to 581 times the LD50 may be present per sq. ft. for small birds, up to 91.5 and 6.48 times the 

respective LD50 for medium and large birds.

Table 5.5. Amount of Boric Acid and Sodium Borate Salts in the Immediate Application Area from 

Granular Broadcast Applications Expressed as Avian LD50 per Square Foot from TREX 

Calculations.

Avian Weight Class (grams) Avian LD50/ft2

20 <5811

100 <91.51

1000 <6.481

1The LD50 used was a non-definitive (greater than >) value due to lack of toxicity in the highest treatment and so these estimates 

of toxicity per area are upper-bound estimates only and are not true estimates of the toxicity expected.
41

5.1.2.2 Mammals

No LOC exceedances were found from one application. Using the conservative 

assumption of weekly applications did produce an LOC (0.5) exceedance for non-listed medium 

mammals feeding on short grass and a listed-species LOC (0.1) exceedance for the other two size 

classes in that feeding group. Also medium mammals feeding on tall grass and broadleaf plants 

had listed-species LOC exceedances.

Table 5.6. Upper Bound Kenaga, Acute and Chronic Mammalian Dose- and Dietary-Based Risk 

Quotients for Agricultural and Non-Agricultural Outdoor Uses.

Dietary Item

Mammalian RQs

Acute Dose-based Size Classes Chronic Dose-based Size Classes Chronic 

Dietarybased 15 g 35 g 1000 g 15 g 35 g 1000 g

Adjusted 

LD50 = 989 

mg 

a.e./kg-bw

Adjusted 

LD50 = 800 

mg 

a.e./kg-bw

Adjusted 

LD50 = 346 

mg 

a.e./kg-bw

Adjusted 

NOAEL 

= 161 mg 

a.e./kgbw

Adjusted 

NOAEL 

= 130 mg 

a.e./kgbw

Adjusted 

NOAEL 

= 56.4 mg 

a.e./kgbw

NOAEC = 

249 mg 

a.e./kgdiet

Application Rate of 0.0625 lb a.e./A x 1 application

Short grass 0.02 0.10 0.01 0.08 0.01 0.05 0.02

Tall grass 0.01 0.05 0.01 0.04 <0.01 0.02 0.01

Broadleaf plants 0.01 0.06 0.01 0.05 <0.01 0.03 0.01

Fruits/pods <0.01 0.01 <0.01 0.01 <0.01 <0.01 <0.01

Arthropods 0.01 0.04 0.01 0.03 <0.01 0.02 0.01

Seeds <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01

Application Rate of 0.0625 lb a.e./A x 52 applications (7-day interval)

Short grass 0.13 0.77 0.11 0.66 0.06 0.35 0.13

Tall grass 0.06 0.35 0.05 0.30 0.03 0.16 0.06

Broadleaf plants 0.07 0.43 0.06 0.37 0.03 0.20 0.07

Fruits/pods 0.01 0.05 0.01 0.04 <0.01 0.02 0.01

Arthropods 0.05 0.30 0.04 0.26 0.02 0.14 0.05

Seeds <0.01 0.01 <0.01 0.01 <0.01 <0.01 0.01

Bolded values exceed the LOC for non-listed species of 0.5 for acute risk or 1.0 for chronic risk.

Shaded values exceed the LOC for listed species of 0.1 for acute risk or 1.0 for chronic risk.

The higher granular application for drainage systems, fencerows, etc. was calculated to 

be 13.6 g a.e./sq. ft. (see Table 5.7). When compared to the mammalian oral dosing toxicity 

endpoint, this application rate showed that up to 919 times the LD50 may be present per sq. ft. for 

small mammals and up to 487 and 39.4 times the respective LD50 for medium and large 

mammals.
42

Table 5.7. Amount of Boric Acid and Sodium Borate Salts in the Immediate Application Area from 

Granular Broadcast Applications Expressed as Mammalian LD50 per Square Foot from TREX 

Calculations.

Mammalian Weight class (grams) Mammalian LD50/ft2

15 919

35 487

1000 39.4

5.1.2.3 Terrestrial Invertebrates

The RQ based on honey bee acute contact toxicity did not exceed the pollinator LOC 

(0.4) at the maximum broadcast spray rate (Table 5.8). However, boric acid and sodium borate 

salts are registered insecticides and acaricides and so terrestrial invertebrates in the immediate 

application area would be assumed to be at risk. Additionally, contact toxicity data may have 

underestimated the risk since boric acid is known to be a stomach poison.

Table 5.8. Adult Honey Bee Contact Risk Quotient from Maximum Ground Spray Application of 

Boric Acid and Sodium Borate Salts for Agricultural Uses.

Use Application Rate

EEC

RQ1

Ornamentals, Soybeans and Other 

Uses

0.0625 lb a.e./A

0.169 μg a.e./bee

<0.01

1Based on contact LD50 of 363 μg a.e./bee (MRID 40269201).

No toxicity data are available for calculation of chronic RQs for adult bees or for acute or 

chronic RQs for bee larvae. Therefore, there is uncertainty regarding the potential acute and 

chronic effects of boric acid and sodium borate salts on honey bee larvae as well as potential for 

chronic effects on adult bees and, likewise, other terrestrial invertebrates. While boric acid and 

sodium borate salts are not known to be systemic, residues from sub-lethal concentrations of 

spray drift on plants may be present in pollen and/or nectar and represent a route of exposure for 

bees through both contact and ingestion. Therefore, additional data on pollinators is needed to 

fully characterize the risk associated with boric acid and sodium borate salts use to all 

developmental stages of honey bees, as sensitivity may vary according to life-stage and length of 

exposure (adult vs. larval and acute vs. chronic, respectively). These data are required under the 

Guidance for Assessing Pesticide Risks to Bees (USEPA et al., 2014).

5.1.2.4 Terrestrial Plants

No LOC exceedances were calculated for terrestrial plants (Table 5.9).
43

Table 5.9. Terrestrial Plant Risk Quotients from Maximum Ground Spray Application of 0.0625 lb 

a.e./A to Ornamentals, Soybeans and Other Uses.

Type of Plant Type of Exposure

Dry Areas Semi-Aquatic Areas Spray Drift Only

Monocot

Non-listed <0.1 <0.1 <0.1

Listed <0.1 <0.1 <0.1

Dicot

Non-listed <0.1 <0.1 <0.1

Listed <0.1 <0.1 <0.1

Bolded RQ values exceed the LOC of 1.0.

5.2 Risk Characterization

Risk characterization considers the weight of evidence to determine the potential for any 

of the boric acid and sodium borate salts labeled uses to result in unacceptable adverse effects. 

The weight of evidence in this risk assessment included the risk estimates, information on natural 

background levels and other non-pesticidal sources of boron to the environment, any incidents 

associated with uses and information on environments already at risk such as TMDL sites.

5.2.1 Incidents

Reviews of the Ecological Incident Information System (EIIS, version 2.1.1, USEPA, 

2009c), Incident Data System (IDS), and the Avian Monitoring Information System (AIMS) for 

ecological incidents involving boric acids and associated salts were completed on July 7, 2015. 

Queries were done using PC Codes 011001, 011002, 011102, 011103, 011104, 011107, 011110, 

011111 and 011112 for the EIIS and IDS databases and for the names boric, borate and boron for 

the AIMS database. Output summary tables and spreadsheets are found in Appendix K.

The AIMS database query did not yield any bird incidents, but the other two did return 

some ecological incidents; mostly plant incidents except for one desert tortoise ingestion 

incidents. Note that a lack of reported incidents does not imply that no incidents occurred.

Table 5.10. Summary of incidents reported in the EIIS Database from use of boric acid and sodium 

borate salts.

Type of 

Incident/Species 

Affected

PC Code 

Implicated

EIIS Database1

Certainty/ 

Legality

Incident 

ID Number Notes

Non-Plant:

Desert tortoise 011102 Highly Probable/ 

Unknown I022156-001 In California in 2010 a tortoise was killed by ingesting borax.

Plant:

Unknown woody 

plant

011110 Possible/ 

Unknown I018719-006

In Ohio in 2007 five plants were 

damaged by equipment rinse from home 

exterior use.

Unknown shrub 011110 Probable/ 

Accidental Misuse I008688-008

In 1998 an unknown number of shrubs 

were damaged from accidental spill 

from a swimming pool use.

1 Queried July 7, 2015.
44

Of the 3 incidents reported in the EIIS database (Table 5.10), two involved damage to 

plants and one involved mortality to a desert tortoise from ingesting borax. None were known to 

be from registered uses, one was from a spill, one from equipment rinsing and the one involving 

the tortoise was highly probable (see Table 5.11). In the tortoise incident, the tortoise was found 

dead. High levels of boron residues were detected in its liver and it had large quantities of boron 

in its gut. The cause of death was attributed to poisoning from the ingestion of borax but the 

source of the borax or its legality of use was unknown. It does, however, add support to the line 

of evidence that if terrestrial vertebrates can be exposed to toxic levels of boric acid and sodium 

borate salts.

Table 5.11. The certainty index in EIIS was based on the following.

Certainty Index Criteria

Highly probable 

Pesticide was confirmed as the cause through residue analysis or other reliable evidence, or the 

circumstances of the incident along with knowledge of the pesticide's toxicity or history of 

previous incidents give strong support that this pesticide was the cause.

Probable Circumstances of the incident and properties of the pesticide indicate that this pesticide was the 

cause, but confirming evidence is lacking.

Possible The pesticide possibly could have caused the incident, but there are possible explanations that 

are at least as plausible. Often used when organisms were exposed to more than one pesticide.

Unlikely Evidence exists that a stressor other than exposure to this pesticide caused the incident, but that 

evidence is not conclusive.

Unrelated Conclusive evidence exists that a stressor other than exposure to the given pesticide caused the 

incident.

Of the 1390 incidents reported in the Aggregate database between 1990 and present, only 

4 of these (0.3%) were plant incidents (Tables 5.12); all others were either domestic animal or 

human incidents.

Table 5.12. Ecological and domestic animal incidents associated with boric acid and sodium borate 

salts, according to the Aggregate Database.1

Exposure Severity 

Code Description Number of Incidents

DA Domestic Animal - Fatality 26

DB Domestic Animal - Major 14

DC Domestic Animal - Moderate 63

DCDE Domestic Animal - Moderate, Minor and Unknown 665

DD Domestic Animal - Minor 131

DE Domestic Animal - Unspecified 5

ONT Other Nontarget 0

PB Plant Damage - Minor 4

WB Wildlife - Minor 0

1 Queried July 7, 2015 (1990-present).

Of the 806 incidents that did not involve another active ingredient, the animal and plant 

incidents were further subtotaled by PC Code and product (Tables 5.13 and 5.14). Of the 802 

domestic animal incidents, 567 were linked with sodium tetraborate decahydrate products (PC 
45

Code 011102). Many, perhaps most, of the domestic animal incidents appear to be from 

consumption of baits and traps, though it was not quantifiable from the available information. 

For example, 269 of the 802 incidents were attributed to an unspecified type of Terro Ant Killer 

product. Based on the tally of available domestic animal incidents, it is not possible to determine 

if the incidents are the result of indoor or outdoor uses. The incidents associated with any 

outdoor use are more relevant to the ecological risk assessment for these chemicals. The line of 

evidence, however, does suggest that animals may be attracted and exposed to baits and traps if 

used outdoors.

Of the four plant incidents, all were associated with a swimming pool algicide (Table 

5.14). This is consistent with findings from the EIIS database above, where one of the two plant 

damage incidents was also attributed to the swimming pool use.

Table 5.13. Detail Showing Animal Incidents by PC Code and Product from the Aggregate 

Database Query.

PC Code Product Name

Number of

Animal 

Incidents

Subtotal by 

PC Code

011001 ADVANCE LIQUID ANT BAIT 1 215

BORIC ACID POWDER 5

DRAX ANT KILL GEL 2

ENFORCER ROACH RIDD 48

GREENLIGHT SNAIL & SLUG BAIT 1

HOT SHOT POWDER 58

HOT SHOT ANT BAIT 3

HOT SHOT ANT GEL 4

HOT SHOT UNSPECIFIED 5

INTERRUPT CARPET POWDER (DISCONTINUED) 2

MOTHER EARTH GRANULAR SCATTER BAIT 19

ORTHO ANT-STOP ANT KILLER DUST/POWDER 7

PRESCRIPTION PERMA-DUST PRESSURIZED BORIC ACID 

DUST 1

PRO BORADUST INSECTICIDE DUST (CANADA 19480) 1

REDZONE BAIT 1

SPECTRACIDE PRO 99% BORIC ACID DUST 2

TERRO INSECT/ANT BAIT 42

VERTAGREEN BORIC ACID INSECTICIDE POWDER 13

011102 388B ANT GEL BAIT 4 567

AMDRO KILLS ANTS ANT KILLER/BAIT 7

ANT-B-GON MAX ANT KILLER LIQUID (ORTHO) (CANADA) 1

BORAX 3

GRANT'S KILLS ANTS ANT KILLER 2

HOME DEFENSE MAX ANT TRAPS (ORTHO) (CANADA) 2

PCPA 23372 1

PRESCRIPTION 388B ADVANCE ANT GEL BAIT 3

RAID LIQUID ANT KILLER TRIGGER SPRAY CANADA ONLY 49

TERRO ANT KILLER UNSPECIFIED 269

TERRO ANT KILLER II LIQUID ANT BAITS 200

TERRO OUTDOOR LIQUID ANT BAIT STAKES 6
46

PC Code Product Name

Number of

Animal 

Incidents

Subtotal by 

PC Code

TERRO OUTDOOR LIQUID ANT BAITS 20

011103 CELLUTREAT DOT WOOD PRESERVATIVE 1 13

COMBAT LIQUID ANT BAIT 4 PACK .75 OZ 2

NATURE'S GUARDIAN NATURAL FLEA AND TICK 

HOUSEHOLD SPRAY 1

SPECTRACIDE TERMINATE TERMITE & CARPENTER ANT 

KILLING DUST 6

TIM-BOR INSECTICIDE 3

011110 ENDURE 1 1

011001, 

011102 ENFORCER ANT BAITS II 6 6

Total Animal Incidents 802

Table 5.14. Detail Showing Plant Incidents by PC Code and Product from the Aggregate Database 

Query.

PC Code Product Name Number of Plant Incidents

011110 BIOGUARD ALGAE OPTIMIZER PLUS 4

5.2.2 Impaired Streams and Total Maximum Daily Loads (TMDLs)

There are streams in the U.S. with boron impairments, based on information from the 

EPA Office of Water and the State of California. Based on the EPA Office of Water (OW) 

website, there are 54 streams (64 with tributaries) in the U.S. with boron impairments and 

associated TMDLs. Of these streams, 46 are located in the western U.S. (CA, NV, UT, AZ) and 

8 are located in the Midwest (IL and KS)8. According to the California Central Valley Regional 

Water Quality Control Board comment on TMDLs in Gowda et al., 9/13/20129, there were 31 

water bodies in California that were impaired due to high concentrations of boron. The 2008-

2010 Clean Water Act Section 303(d) list for California10 contains 15 stream segments in the 

Central Valley, 11 segments in the Central Coast region, 4 segments in the Los Angeles region, 

and 1 segment in the Lahontan region that exceed water quality standards for boron. Four of the 

total 31 water bodies impaired for boron statewide currently have a TMDL in place. 

Boron impairments can occur from a variety of sources, and are associated with natural 

sources and human activity. These known natural sources include groundwater, atmospheric 

deposition, and minerals, and the known man-made sources include irrigation, oil and gas, 

mining, and municipal exposure through WWTPs and runoff. There are also many unknown 

sources of causes for boron impairment in various watersheds. However, no impairments have 

been conclusively tied to any pesticidal uses at this time.

 

8 http://iaspub.epa.gov/tmdl_waters10/attains_impaired_waters.control?p_cause_name=BORON (accessed on 

6/4/15)

9 Gowda et al, September 13, 2012, DP Barcode D404927, TMDL comment from State of California

10 http://www. waterboards.ca. gov/water issues/programs/tmdl/integrated2010.shtml, state-specific database 
47

The existing TMDLs range from 0.75 ug/L to 2,000 mg/L, and almost all TMDLs in the 

Office of Water database are 750 ug/L. The National Ambient Water Quality Criteria for boron 

is 750 μg/L for long-term irrigation11. Some of the reasons for a lower value may be that some 

states have more stringent criteria than the National recommended value. The states of 

Minnesota and Illinois, are in the process of revising or developing water quality criteria for 

protection of aquatic life (USEPA, 2010a). There is another TMDL of 5,000 μg/L in the Office 

of Water database for livestock watering.

5.2.3 Agricultural Use Risk Characterization

5.2.3.1 Aquatic Risk Discussion

For aquatic biota, the calculated peak EECs of 0.0041 mg a.e./L for one application up to 

0.213 mg a.e./L for weekly applications at the maximum application rate for ornamentals, 

soybeans and other crips, did not produce LOC exceedances. This is also consistent with much 

higher water quality criteria. EPA’s Office of Water only has a national ambient water quality 

criterion for long-term irrigation, which is 750 μg/L (4.3 mg a.e./L; U.S. EPA, 1986). Canada 

has two water quality criteria of 1.2 mg B/L (6.9 mg a.e./L) for aquatic life and 5.0 mg B/L (28.6 

mg a.e./L) for wildlife and livestock watering (Moss and Nagpal, 2003). These range from three 

times as high to an order of magnitude higher than the conservative estimate assuming weekly 

applications.

However, there are registered algicidal uses for swimming pools and other contained 

systems that are part of the uses overseen by AD. Clearly, algae would be at risk if the 

application rates were at those levels, but the pesticidal application rates subject to runoff and 

spray drift did not cause LOC exceedances and so algae in natural ecosystems would not be 

presumed to be at risk. Incident data (see Section 5.2.1 above) did not produce any fish kills or 

other incidents involving aquatic biota.

5.2.3.2 Terrestrial Risk Discussion

For terrestrial organisms, application rates assessed only produced LOC exceedances 

when the most conservative assumptions were used for flowable uses. However, for granular 

uses, this was not the case – the application rate modeled was simply the maximum rate. Clearly 

effects may result for most taxa in the immediate application area. 

For avian risk from runoff and spray drift, only the most conservative estimate of weekly 

applications exceeded the listed species LOC for one size class/feeding group (small birds 

feeding on short grass) using oral dosing data. The toxicity endpoints used were non-definitive, 

greater-than values due to no toxicity in the highest treatment and were upper-bound estimates 

only. A dietary toxicity study using a small passerine (the canary) did not have effects at a high 

dietary rate than is typically tested, of 11,000 mg a.e./kg-diet. So, the evidence of risk is unclear, 

but likely low for flowable uses. 

For mammalian risk from runoff and spray drift, LOC exceedances were seen in all size 

classes feeding on short grass and medium-sized mammals feeding on other types of plants, 

 

11 http://water.epa.gov/scitech/swguidance/standards/criteria/current/index.cfm accessed 6/23/2015.
48

though only one size/feeding class had a non-listed LOC exceedance (RQ of 0.77) and this is 

using the conservative assumption of weekly applications. So, the implication is that effects may 

be possible but the evidence for risk is not strong, applying only to weekly applications, but 

especially applicable to medium-sized mammals feeding on short grass.

For more localized granular applications, the higher application rate resulted in a 

potential (though this is an upper-bound estimate due to a non-definitive endpoint) for an amount 

between 6 and 581 times the avian LD50 to be in one square foot of the treated area. For 

mammals, this is a more realistic estimate since the LD50 was definitive. For mammals, this 

granular application rate would result in 29 to 919 times the LD50 per square foot. This clearly 

shows that mammals in the immediate treatment area could be exposed to toxic amounts of boric 

acid; however, information was not available for calculating toxicity based on number of 

granules consumed. 

Risk from inhalation or drinking water exposure was not screened using SIP and STIR 

models when the problem formulation was written since those models had not yet been released. 

A check using the models showed that inhalation would not be expected to be an important 

exposure route, but that drinking water could, due to the high solubility of boric acid (55600 

mg/L, see Table 3.2). 

The potential for toxicity from exposure in the immediate treatment area was 

substantiated by 806 domestic animal incidents (though whether these were from indoor outdoor 

uses was unclear), resulting largely from consumption of insect baits and traps and one incident 

where a desert tortoise was killed by ingesting borax. The exposure of wildlife, especially 

mammalian, may depend largely on whether animals will ingest the granules or contents of bait 

stations or traps. The incident reports suggest that animals may ingest them. Ingestion of 

granules may be incidental when granules fall on food items. The risk from bait station and trap 

ingestion may be reduced by label language specifying careful placement and elimination, 

reduction or replacement of attractants to more selectively attract target organisms.

Risk to terrestrial invertebrates is more assumed than confirmed, partly due to lack of 

pollinator toxicity data. No toxicity data are available for calculation of acute oral or chronic 

RQs for adult bees or for acute or chronic RQs for bee larvae. Therefore, there is uncertainty 

regarding the potential acute and chronic effects of boric acid and sodium borate salts on adult 

and larval honey bees. While boric acid is not a systemic compound, residues from sub-lethal 

concentrations of spray drift on plants may be present in pollen and/or nectar and represent a 

route of exposure for bees through both contact and ingestion. Therefore, additional data on 

pollinators is needed to fully characterize the risk associated with boric acid use to all 

developmental stages of honey bees, as sensitivity may vary according to life-stage and length of 

exposure (adult vs. larval and acute vs. chronic, respectively). These data are required under the 

Guidance for Assessing Pesticide Risks to Bees (USEPA et al., 2014). The Agency expects to 

publish additional guidance on addressing gaps in bee toxicity data for pesticides that have 

undergone Registration Review in the near future. No incidents associated with boric acid 

involving terrestrial invertebrates, such as bee kills, have been reported to the Agency. However, 

since boric acid and sodium borate salts are registered insecticides and acaricides terrestrial 

invertebrates in the immediate application area are assumed to be at risk.
49

For terrestrial plants, the maximum single application rate did not cause LOC 

exceedances from runoff and spray drift. As previously mentioned, when used as an algicide, 

boric acid and sodium borate salts act by causing desiccation or interruption of photosynthesis. 

Some trees are reportedly sensitive to boron toxicity, at levels of 0.5 to 1 ppm in the soil. 

Symptoms of boron toxicity can occur in older leaves and resemble symptoms of high salinity or 

of iron or manganese deficiencies (Kratsch, 2004). Since woody plants are not represented in the 

terrestrial plant toxicity tests, this is an uncertainty. Therefore, sensitive plants in the immediate 

application area may be affected. Incident reports helped substantiate that plant damage may 

occur if plants come in direct contact with products, though these were mostly from swimming 

pool algicides, rather than broadcast uses.

5.2.4 Antimicrobial Uses Risk Characterization

5.2.4.1 Recirculating Cooling Water System Use and Any Use Not Listed on the Label

There are manufacturing use products (EPA Reg. #1624-117 and 19713-604) with 

directions for use in formulating end-use products for use in water processing systems, 

recirculating cooling water systems and one label (EPA Reg #19713-604) includes a statement 

for manufacture of end-use products with “any specific use(s) not listed on the label”. The boric 

acid manufacturing use product label (EPA Reg #1624-117) also includes formulation of 

bacteriostatic products for use in/on absorbent materials for inhibiting the growth of bacteria 

which causes odor, i.e. kitty litter, for which there are currently no active end-use products. 

There are also no active end-use product registrations with the active ingredients in these 

products for the water processing systems or recirculating cooling water systems use patterns. 

There are no active end-use products for these active ingredient with uses other than those 

specified on the labels. These manufacturing use product labels do not provide application rates 

for the specific listed uses nor for specific uses(s) not on the label. Formulators and repackagers 

of this product into end-use products are instructed that they are responsible for obtaining their 

own registrations for the specific listed uses and any specific use(s) not listed on the label. As 

there are no end-use products for the water processing systems use; the recirculating cooling 

water system use; the bacteriostatic use for absorbent materials; or for any use not specifically 

listed on the label, there are currently no environmental exposures or risks from such uses. If a 

request for an end-use product with the recirculating cooling water system use or any other use is 

submitted to the Agency a hazard assessment and risk assessment, as needed, would be 

performed at that time. 

5.2.4.2 Recreational Water Biocide Use (Swimming Pools and Spas and Hot Tubs)

The primary loss of boron from a swimming pool, spa, or hot tub will be due to a 

substantial amount of water being removed from these due to draining of the system, splash-out, 

backwashing, or dilution from heavy rains. Evaporation of water will concentrate boron in these 

systems as boron as aqueous boric acid and borate ions will not degrade further. Therefore 

labels that set repeat applications and amount of product to be applied based on free chlorine 

residual or cyanuric acid residual levels, or disappearance of the number of tablets in a feeder or 

skimmer will potentially result in boron building up in these waters over time. The Agency has 

determined that there are conditions under which discharge of effluent from swimming pools, 

and hot tubs and spas treated with disodium tetraborate pentahydrate will pose risks of concern 

to aquatic organisms. These conditions consist of discharge of effluent to storm drains (which no 
50

label prohibits), or discharge to wetlands, or surface waters which not all labels prohibit. 

Additionally, discharge of pool effluent to the landscape may pose risks of concern to terrestrial 

plants from boron. The incident reports include impacts to plants from swimming pool effluent.

While not all labels for the swimming pool, and spa and hot tub uses are written in a 

manner where the maximum boron concentration can be determined based on label application 

instructions, those labels with the highest initial and maintenance application rates provide 

maintenance limits of 30 – 50 ppm boron. This concentration level exceeds the most sensitive 

NOAEC and IC50 endpoint values for algae/cyanobacteria (1.6 ppm and 14.2 ppm, respectively), 

which given its use as an algaecide in pools is not unexpected, but it also exceeds the most 

sensitive NOAEC and IC50 values for aquatic vascular plants (11 and 28.5 ppm boron, 

respectively), the most sensitive NOAEC and IC50 endpoints for freshwater invertebrates (1.6 

and 45.5 ppm boron, respectively) and marine/estuarine invertebrates (<14 ppm boron, and 14 

ppm boron, respectively), the most sensitive NOAEC endpoint for freshwater fish (7.3 ppm 

boron). The 30 – 50 ppm boron concentration also exceeds the National Ambient Water Quality 

Criterion of 0.75 ppm boron, set for irrigation water, indicating that release of such waters to the 

landscape has the potential to directly impact terrestrial plants. 

Discharge of swimming pool and spa and hot tub effluent to the sewer system is not 

expected to result in upsets of wastewater treatment facilities or unacceptable adverse effects to 

aquatic and terrestrial organisms due to the relatively very low use compared to other boron 

inputs, diffused over a large area. From the Kline 2009 market survey, the predominant 

algaecides used for recreational waters are the quarternary ammonium (quat) compounds. All 

“other” algaecides used for recreational water (pool, spa and hot tub) are estimated to comprise 

less than 0.625 million pounds annually. Conservatively setting the annual amount of boron 

used for recreational waters equal to this combined 0.625 million pounds and conservatively 

assuming that all swimming pool and spa and hot tub effluent is discharged to the sewer system 

the amount of boron added to other down-the-drain domestic municipal sources of boron (e.g., 

soaps and detergents, foodstuffs, lotions and other personal care products, water softeners) would 

comprise far less than 0.7% of the total boron municipal load. The predominant input to most 

municipal sewage systems is expected to be from washing agents; the annual amount of boron 

used domestically in detergents and soap is on the order of 85 million pounds annually based on 

extrapolation of USGS percent consumption and historic consumption levels (see Section 

2.3.2.3, Appendices B and D). With an activated sludge respiration inhibition (ASRI) median 

inhibition concentration (IC50) of >1,000 mg B/L, effluent from treated swimming pools and spas 

and hot tubs, which would contain at most around 50 mg B/L, would not impact the functioning 

of wastewater treatment facilities.

Label language issues for the swimming pool and spa and hot tub use that would reduce 

risks include the following considerations. Labels do not prohibit the discharge of effluent 

(treated water) from swimming pools, or spa and hot tubs to storm drains, roads, or to the 

landscape. Not all labels have language requiring a National Pollutant Discharge Elimination 

System (NPDES) permit or notification of the permit authority prior to discharge of effluent 

from swimming pools, and spas and hot tubs into lakes, streams, ponds, estuaries, oceans or 

other waters. Additionally, not all labels require notification of the local sewage treatment plant 

authority prior to discharge of swimming pool, or spa and hot tub effluent to the sewer system. 

Not all labels state the maximum amount of boron to be maintained or if they do make a 
51

statement the type of testing required is not specified on the label. This requires testing which 

some labels recommend be performed at least once a month. A number of labels recommend 

taking the water to a dealer to have the water tested, others specifically state the type of testing to 

perform, and some make no mention of the appropriate type of testing to perform. The label 

should specifically state the compound to be tested and a limit, for it to be an enforceable value. 

Uses where boron concentration greater than 0.75 ppm boron can occur in pool water based on 

application instructions should prohibit discharge to the landscape and require discharge solely to 

the sewer system. 

5.2.4.3 Wood Preservative Uses

The wood preservative use is the predominant pesticidal use for boric acid and the 

sodium borate salts but this use constitutes less than 1% of borates consumed annually. The 

agency believes that the only potential risks of concern for the wood preservative use are 

associated with the post-treatment storage of treated wood. 

Based on information provided by the wood preservation industry, over half of the 

amount consumed for wood preservation consists of industrial applications to wood and 

engineered wood products for framing and sills. The largest environmental exposure in this case 

is expected to occur at the industrial facilities from effluent discharge and loss to soils from 

leaching and run-off from treated lumber during post-treatment storage. Except for a few labels,

there is no requirement for treated wood to be stored under cover or under conditions that would 

prevent leaching and run-off from rain events during storage. The effluent discharge route is not 

expected to result in unacceptable adverse effects because industrial point sources that discharge 

effluent into surface waters are subject to NPDES (National Pollutant Discharge Elimination 

System) permitting process via the EPA's Office of Water. Label statements for these use 

patterns require users or dischargers to contact the EPA or appropriate state agencies before 

discharging effluent into surface waters. There is a national ambient water quality criterion for 

boron in surface waters which permit writers can use to set effluent limits. Additionally, there is 

information available on the toxicity of boric acid to activated sludge organisms which can be 

used to ensure upsets of treatment facilities do not occur from boron loads. Once incorporated 

into the building frame where they are relatively protected from moisture, borate-treated lumber 

is not expected to result in any detectable change in environmental background levels. 

The second highest wood preservative use is for treatment of rail road ties. These can be 

treated at industrial sites or treated in situ. Industry has indicated it is industry practice to apply 

creosote or copper naphthenate over borate treatment, both creosote and naphthenate are 

relatively insoluble in water. The same conditions and conclusions discussed above about 

industrial applications and environmental discharges apply for the rail road tie treatments. The

AWPA retention for railroad ties is 0.25 pounds as DOT per cubic foot (0.052 pounds as B per 

cubic foot). While the rail road tie use pattern requires a high application rate, the amount used 

annually is about 1% of that applied as fertilizer annually. Given the low toxicity of boric acid 

and the sodium borate salts, exposure of wildlife to rail road ties is not considered to be either an 

acute or chronic concern. 

The third highest wood preservative use is for in situ treatment and remedial treatment of 

structures. This includes treatment on the interior of structures and exterior. Exterior 
52

applications require use of waterproof wrapping between the treated area and the surrounding 

soil which will reduce leaching to surrounding soils, and the interior use is expected to result in 

little to no wildlife exposure. While there is potential for some of the boron from the exterior 

treatments to leach to the environment, these will be localized small areas and compared to the 

amounts applied as fertilizer to soils the pounds used annually are relatively small (approx. 1%).

5.2.4.4 Other Material Preservative Uses

The in-can/in-container material preservative use of boric acid in interior/exterior paints, 

stains, and coatings for surfaces; inks and dyes; and in coatings for manufacturing gypsum board 

and gypsum board paper are new uses added since the 1993 RED. The material preservative use 

for polystyrene (plastic) for insulation was added in March of 2000. The material preservative 

use for indoor/exterior paint, stain, and coating for surfaces, inks and dyes, and coatings for 

manufacturing gypsum board and gypsum board paper were added in March of 2010. 

Use of boric acid as a material preservative for interior/exterior paints, stains, coatings, 

dye, ink, and polystyrene is not expected to result in unacceptable adverse effects to aquatic or 

terrestrial organisms. These end-use products are used solely at manufacturing facilities where 

they are mixed into these materials. All end-use product labels require any discharge to 

wastewater containing the product to notify and obtain appropriate National Pollutant Discharge 

Elimination System (NPDES). There is a national ambient water quality criterion for boron 

which permit writers can use for setting a boron limit at these facilities, if required. The limit is 

for protection of irrigating crops, but is lower than the most sensitive aquatic life endpoints. Inservice use of these preserved materials is also not expected to result in unacceptable adverse 

effects to aquatic or terrestrial organisms due to the relatively low content of boron in these 

materials, the relatively low loading to the environment compared to other uses of boric acid and 

borates (a portion would actually result in little to no release to the environment for the life of the 

material—e.g., interior paints, stains and coatings, polystyrene insulation), the large dispersed 

area over which the preserved materials would enter into commerce. For example, from the 

Kline 2004 market survey neither boric acid nor the sodium borate salts are listed as common 

biocides for preserving paints and stains. All “other” non-common preservatives combined for 

use in paints and stains was estimated to comprise 0.46 million pounds annually in 2004 with 

potential to increase to 0.587 million pounds by 2009. This would mean significantly less than 

0.103 million pounds as boron is dispersed annually across the United States for this use. If all 

the boron was conservatively assumed to leach out of the paint annually and run-off to water it 

would constitute <0.3% of the input to surface waters from the detergents and soaps use (see 

Section 2.3.2.3, Appendices B and D). The amount used for all the other material preservative 

uses is likewise low relative to nonbiocidal uses with releases to the environment, and to other 

biocidal use patterns (e.g., wood preservative).

5.2.5 Key Uncertainties and Assumptions

For the assessment of risk from the swimming pool and the spa and hot tub uses, the 

agency assumed that the highest concentration of boron in water would be 50 ppm. This rate 

was based on the maximum limit listed on labels with close to 100% active ingredient which also 

contain monitoring and boron limit levels. There are a number of labels which specify much 

smaller quantities of boron, also allow multiple applications, but have no monitoring 

requirements or limits for boron content of the treated recreational waters. Many of these labels 
53

have monitoring and limits on the label but they are for sanitizers that are coactive ingredients 

with boron. Information about recreational water maintenance practices and product use patterns

would reduce this uncertainty. 

5.2.6 Risk Conclusions

5.2.6.1 Agricultural and Non-Agricultural Outdoor Use Patterns

Taxonomic groups with evidence of risk from registered uses of boric acid and sodium 

borate salts were:

 terrestrial invertebrates (risk is assumed based on the insecticidal uses of the chemicals), 

and

 birds and mammals (acute risk), primarily from the granular formulations and baits 

(though the evidence of risk for birds is uncertain due to non-definitive endpoints)..

Taxonomic groups that had predominant evidence of negligible risk from registered uses 

of boric acid and sodium borate salts were:

 aquatic vertebrates, 

 aquatic invertebrates,

 aquatic plants, and 

 terrestrial plants.

5.2.6.2 Antimicrobial Use Patterns

Potential direct risks exist for the following taxonomic groups from the swimming pool 

and spa and hot tub boron uses, if treated water is not disposed of properly:

 Aquatic vertebrates;

 Aquatic invertebrates;

 Aquatic plants; and

 Terrestrial plants.

Potential indirect effects to terrestrial animals (birds, mammals, amphibians, beneficial 

insects) may result from the direct loss of food resources or habitat.

Potential risks exist for the following taxonomic groups from the wood preservative use, 

if treated wood at industrial wood preservative treatment facilities are not properly protected 

from rain during storage before final use:

 Aquatic vertebrates;

 Aquatic invertebrates; and

 Aquatic plants.
54

6 Listed Species of Concern

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

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

registered uses of pesticides in accordance with the Joint Interim Approaches developed to 

implement the recommendations of the April 2013 National Academy of Sciences (NAS) report, 

Assessing Risks to Endangered and Threatened Species from Pesticides. The NAS report12

outlines recommendations on specific scientific and technical issues related to the development 

of pesticide risk assessments that EPA and the Services must conduct in connection with their 

obligations under the ESA and FIFRA. EPA will address concerns specific to boric acid and 

sodium borate salts in connection with the development of its final registration review decision 

for boric acid and sodium borate salts. 

In November 2013, EPA, the U.S. Fish and Wildlife Service, National Marine Fisheries 

(the Services), and USDA released a white paper containing a summary of their joint Interim 

Approaches for assessing risks to listed species from pesticides. These Interim Approaches were 

developed jointly by the agencies in response to the NAS recommendations, and reflect a 

common approach to risk assessment shared by the agencies as a way of addressing scientific 

differences between the EPA and the Services. Details of the joint Interim Approaches are 

contained in the November 1, 2013 white paper13, Interim Approaches for National-Level 

Pesticide Endangered Species Act Assessments Based on the Recommendations of the National 

Academy of Sciences April 2013 Report. 

Given that the agencies are continuing to develop and work toward implementation of the 

Interim Approaches to assess the potential risks of pesticides to listed species and their 

designated critical habitat, this ecological risk assessment supporting the registration review of 

boric acid and sodium borate salts does not describe the specific ESA analysis, including effects 

determinations for specific listed species or designated critical habitat, to be conducted during 

registration review. While the agencies continue to develop a common method for ESA analysis, 

the risk assessment for the registration review of boric acid and sodium borate salts describes 

only the level of ESA analysis completed at this time. This assessment allows EPA to focus its 

future evaluations on the types of species where the potential for effects exists, once the 

scientific methods being developed by the agencies have been fully vetted. Once the agencies 

have fully developed and implemented the scientific methods necessary to complete risk 

assessments for listed species and their designated critical habitats, these methods will be applied 

to subsequent analyses of boric acid and sodium borate salts as part of completing this 

registration review.

 

12 http://www.nap.edu/catalog.php?record_id=18344

13 http://www.epa.gov/espp/2013/nas.html
Docket Number EPA-HQ-OPP-2009-0306

http://www.regulations.gov/#!docketDetail;D=EPA-HQ-OPP-2009-0306

55

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ENV/JM/MONO(2004)9. 76 pp.

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Biogeochemical Cycles 16(4):20-1 – 20-11.

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Environmental Protection Agency, Washington, DC 20460. Available online at 

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FR 26846; May 14, 1998. U.S. Environmental Protection Agency, Washington, DC. 

April, 1998.

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

Programs, U.S. Environmental Protection Agency. Endangered and Threatened Species 

Effects Determinations. Office of Prevention, Pesticides and Toxic Substances, Office of 

Pesticide Programs, Washington, D.C., January 23, 2004. Available online at 

http://www.epa.gov/oppfead1/endanger/consultation/ecorisk-overview.pdf.

USEPA. 2004b. Section 3 Registration Request for Proposed Use of Boric acid and its sodium 

salts on Wheat. U.S. Environmental Protection Agency, Office of Pesticide Programs, 

Environmental Fate and Effects Division. March 15, 2004. DP Barcodes: D284671, 

D284675, D284677, D284680, D274582, D274584, D274586, D274588, D294147.
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USEPA. 2006. TERRPLANT v. 1.2.2 User’s Guide. Office of Pesticide Programs, 

Environmental Fate and Effects Division, Washington, D.C. December 26, 2006.

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and its sodium salts for New Use on Rangeland. U.S. Environmental Protection Agency, 

Office of Pesticide Programs, Environmental Fate and Effects Division. December 17, 

2008. DP Barcode: 348511.

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the Ecological Risk Assessment of Boric Acid. Internal Memo to the Special Review and 

Reregistration Division, dated May 4, 2009, DP Barcode: 359927. 

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online at http://cfpub.epa.gov/ecotox/.

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2014. Description online at http://www.epa.gov/pesticides/science/models_db.htm.

USEPA. 2009d. Guidance for Selecting Input Parameters in Modeling the Environmental Fate 

and Transport of Pesticides, Version 2.1. U.S. Environmental Protection Agency, Office 

of Prevention, Pesticides and Toxic Substances, Office of Pesticide Programs, 

Environmental Fate and Effects Division, October 22, 2009. Online at: 

http://www.epa.gov/oppefed1/models/water/input_parameter_guidance.htm

USEPA. 2011. Evaluation Guidelines for Ecological Toxicity Data in the Open Literature. U.S. 

Environmental Protection Agency, Office of Prevention, Pesticides and Toxic 

Substances, Office of Pesticide Programs, Environmental Fate and Effects Division, May 

9, 2011. Online at: 

http://www.epa.gov/pesticides/science/efed/policy_guidance/team_authors/endangered_s

pecies_reregistration_workgroup/esa_evaluation_open_literature.htm#memo. 

USEPA. 2013. Guidance on Modeling Offsite Deposition of Pesticides via Spray Drift for 

Ecological and Drinking Water Assessments. U.S. Environmental Protection Agency, 

Office of Pesticide Programs, Environmental Fate and Effects Division, December 20, 

2013.

USEPA. 2014a. BEAD Chemical Profile (BCP) for Registration Review: Propoxycarbazone 

sodium (122019). U.S. Environmental Protection Agency, Office of Pesticide Programs, 

Biological and Economic Analysis Division, October 22, 2014.

USEPA. 2014b. Boric acid and its sodium salts (122019) Label Use Report Package in Support 

of Registration Review. U.S. Environmental Protection Agency, Office of Pesticide 

Programs, Biological and Economic Analysis Division, September 10, 2014.
58

USEPA. 2014c. Boric acid and its sodium salts: Drinking Water Exposure Assessment for 

Registration Review. U.S. Environmental Protection Agency, Office of Pesticide 

Programs, Environmental Fate and Effects Division. December 4, 2014. DP Barcode: 

423552.

USEPA. 2014d Impaired Waters, Cause of Impairment: Boron. Accessed June 4, 2015. 

http://iaspub.epa.gov/tmdl_waters10/attains_impaired_waters.control?p_cause_name=B

ORON

USEPA, PMRA, and CDPR. 2014. Guidance for Assessing Pesticide Risks to Bees. Office of 

Pesticide Programs, USEPA, Washington D.C. Health Canada Pest Management 

Regulatory Agency, Ottawa, ON, Canada. California Department of Pesticide Regulation, 

Sacramento, CA. June 23, 2014.

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Summaries: 2015. 2 p., accessed June 8, 2015 at 

http://minerals.usgs.gov/minerals/pubs/commodity/boron/

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accessed June 8, 2015 at http://minerals.usgs.gov/minerals/pubs/commodity/boron/

USGS. 2013a. Boron statistics from 1975 through 2003; last modified September 15, 2005, in 

Kelly, T.D., and Matos, G.R., comps., Historical statistics for mineral and material 

commodities in the United States (2013 version): U.S. Geological Survey Data Series 

140, x p., accessed June 8, 2015 at http://minerals.usgs.gov/minerals/pubs/historicalstatistics/#boron.

USGS. 2013b. Boron Statistics and Information. Mineral Commodity Summaries: 2013. 2 p., 

accessed June 8, 2015 at http://minerals.usgs.gov/minerals/pubs/commodity/boron/

USGS. 2012. Boron Statistics and Information. Mineral Commodity Summaries: 2012. 2 p., 

accessed June 8, 2015 at http://minerals.usgs.gov/minerals/pubs/commodity/boron/

USGS. 2011. Boron Statistics and Information. Mineral Commodity Summaries: 2011. 2 p., 

accessed June 8, 2015 at http://minerals.usgs.gov/minerals/pubs/commodity/boron/

USGS. 2010. Boron Statistics and Information. Mineral Commodity Summaries: 2010. 2 p., 

accessed June 8, 2015 at http://minerals.usgs.gov/minerals/pubs/commodity/boron/

USGS. 2009. Boron Statistics and Information. Mineral Commodity Summaries: 2009. 2 p., 

accessed June 8, 2015 at http://minerals.usgs.gov/minerals/pubs/commodity/boron/

USGS. 2008. Boron Statistics and Information. Mineral Commodity Summaries: 2008. 2 p., 

accessed June 8, 2015 at http://minerals.usgs.gov/minerals/pubs/commodity/boron/
59

USGS. 2007. Boron Statistics and Information. Mineral Commodity Summaries: 2007. 2 p., 

accessed June 8, 2015 at http://minerals.usgs.gov/minerals/pubs/commodity/boron/

USGS. 2006. Boron Statistics and Information. Mineral Commodity Summaries: 2006. 2 p., 

accessed June 8, 2015 at http://minerals.usgs.gov/minerals/pubs/commodity/boron/

USGS. 2005. Boron Statistics and Information. Mineral Commodity Summaries: 2005. 2 p., 

accessed June 8, 2015 at http://minerals.usgs.gov/minerals/pubs/commodity/boron/
60

Appendix A Risk Quadrant Figures and Tables

Risk quadrant figures and tables are a tool for use by EFED to better communicate with 

risk managers, who need to know which taxa have greater or lower risk and the certainty of the 

risk conclusions. The risk quadrant figure is extremely summarized to display the seven 

assessed taxa in one of four quadrants, whichever quadrant represents the highest risk for the 

taxon. The risk quadrant table summarizes the rationales for the placement of the taxa in the 

figure, as succinctly as possible. A taxon is only discussed once in the table: in the quadrant 

matching its location in the figure.

For example, if there are chronic risks of concern to mammals and acute risks to 

mammals are not of concern, then the term “Mammals” appears in the upper-right quadrant of 

the figure and the table. The table summarizes (under the “Mammals” heading) the chronic RQ 

range and any other salient lines of evidence for chronic risks of concern. In this example, the 

figure and table do not directly indicate low acute risks to mammals; it is implied by the absence 

of discussion. Only the rationales for the location of the taxa in the figure are discussed in the 

table, with one exception: No Effect Determinations are summarized in the upper-left quadrant 

of the table (not the figure).

The risk versus certainty quadrants are represented as four color-coded categories, as 

represented in the examples below. The left quadrants represent no risks of concern (i.e., no LOC 

exceedances). The right quadrants represent a risk of concern (i.e., at least one LOC

exceedance). The upper quadrants represent higher certainty (i.e., a relatively complete data set 

and/or multiple lines of evidence support the risk conclusions). The lower quadrants represent 

lower certainty (i.e., a relatively limited data set and/or lines of evidence are limited or 

conflicting).

While communication of risk is inherently subjective, use of subjective terminology or 

risk management values should be avoided. The intent of the risk quadrant figure is to simply 

display for the risk manager which taxa are of concern and the degree of confidence in the risk 

conclusions. The intent of the risk quadrant table is to simply explain the supporting evidence for 

the placement of taxa in the figure and serves essentially like a key to the figure. The table 

should not summarize all of the risk conclusions, just the conclusions that support the placement 

of taxa in the figure.

The risk quadrant figure and table are placed in an assessment’s Executive Summary, the 

risk transmittal memo, or may be used for formal or informal communications with risk 

managers. A key to the placement of taxa in the figure and graph is as follows:
61

Key to Four Color-Coded Categories in Risk Quadrant Figures and Tables:

Green: Greater Certainty of Negligible Risk Red: Greater Certainty of Risks of Concern

• No LOC exceedance with relatively complete data set 

or risks have been mitigated

• High confidence in data

• Fate and ecotox profiles clearly support lack of a risk 

concern

• Multiple lines of evidence predict effects will occur

• LOC exceedances, fate, and ecotoxicity profile 

should be considered 

• Exposure is expected to occur based on fate profile 

and uses

• Probable or highly probable cause of incident(s)

Yellow: Lower Certainty of Negligible Risk Orange: Lower Certainty of Risks of Concern

• No LOCs exceeded but other non-compelling 

circumstances suggest that there may be issues

• Possible cause of incident(s)

• Missing endpoints, poorly spaced test concentrations, 

low confidence in data showing low toxicity

• An LOC exceedance is judged to not be of concern 

due to use pattern or other circumstances that limit 

exposure potential

• Low risk calls based on extrapolated data

• LOCs exceeded; however, lines of evidence 

predicting risk are either limited or conflicting

• Possible cause of incident(s)

• Chronic risk called for non-persistent chemical

• Risk calls based on lack of data without other lines of 

evidence available

• Risk calls based on uncertain extrapolation methods 

or conflicting data

• Missing endpoints, poorly spaced test concentrations, 

low confidence in data
62

Appendix B Boron Mineral Usage and Consumption

Reported domestic annual consumption of boron minerals, expressed as boric oxide equivalents 

(B2O3)) ranged from 252,926 to 416,116 metric tons (557.61 to 917.38 million pounds B2O3 or 173.14 to 

284.85 million pounds as B equivalents) from 1991 through 2003 (USGS 2013a). Information on the 

amount consumed annually from 2004 through 2014 has been withheld by the USGS (2005, 2006, 2007, 

2008, 2009, 2010, 2011, 2012, 2013b, 2014; 2015) to avoid disclosing company proprietary data. 

According to the latest U.S. Geological Survey (2015) commodity summaries for boron, there are over 

300 end uses for boron minerals. The relative annual boron mineral consumption annually by uses is 

summarized in Figure B1. For the past two decades over 75% of boron minerals (expressed as B2O3 

equivalents) are typically consumed in five applications: the manufacture of glass; as components in 

soaps, detergents and bleaches; as fertilizers in agriculture; as a component in ceramic enamels, glazes, 

and frit; and as a fire retardant primarily with cellulosic insulation (USGS 2005, 2006, 2007, 2008, 2009, 

2010, 2011, 2012, 2013a, b, 2014; 2015). The principal use of boron minerals has been in the production 

of glass (borosilicate glass, insulation grade glass, textile-grade glass fibers), comprising 50.9 to 80.0% of 

the annual reported consumption. Once incorporated into glass, the boron is relatively immobilized in 

terms of environmental exposure. Use in detergents and bleaches ranks second representing 4.0 to 11.2% 

of the annual reported consumption. From 1991 to 2003, 13,800 to 38,500 metric tons (30.42 to 84.88 

million lbs B2O3 or 9.44 to 36.36 million pounds as B equivalents) were consumed annually for 

detergents and bleaches. In soaps and detergents boron minerals are added to act as alkaline buffers, 

enzyme stabilizers, oxygen based bleaching agents, and water softeners. Agricultural use as a 

micronutrient in fertilizer is the third leading use of boron minerals ranging from 2.0% to 7.2% of the 

total reported consumption. The amount consumed annually for fertilizer ranged from 5,710 to 21,200 

metric tons (12.59 to 46.74 million pounds B2O3 or 3.9 to 14.51 million pounds as B equivalents) from 

1991 to 2003. Boron deficient crops occur primarily in the Atlantic coastal plains, the Great Lakes 

region, and the coastal Pacific Northwest. Annual consumption as fire retardants and as components in 

ceramic enamels, frits, and glazes ranged from <1.0 to 5.8% and <1.0 to 5.2%, respectively. The 

remaining uses constitute 9.0 to 30.4% of the annual boron mineral consumption. These minor uses 

include the biocide uses as insecticides, wood preservatives, herbicides, and swimming pool water 

algicide treatment. Other minor uses include nuclear applications, cosmetics, pharmaceuticals, toiletries, 

gypsum board, brake fluids, fuel additives, lubricants, metalworking fluids, adhesives, and water 

treatment chemicals to name a few.
63

Figure B1. The annual percent of boron minerals consumed in the United States by end 

use from 1991 through 2011.
64

Appendix C Environmental Background Levels of Boron

Boron occurs in nature, typically bound to oxygen, in the form of a number of closely related 

compounds, which differ chiefly in the water of hydration associated with the molecule and are not easily 

differentiated. Because of this, the following discussion refers to the group as "boron" or "the boron 

salts." Boric acid, borax, and boron-containing salts are ubiquitous in the natural environment. Natural 

releases to soil and water occur from weathering of boron-containing minerals, desorption from clays, and 

decomposition of boron-containing organic matter (ATSDR 2010). The common range in soils is 2 to 

100 ppm B (Lindsay 1979). Lindsay (1979) provides 10 ppm B as an average background soil 

concentration. The U.S. Geological Survey’s (Shackelette and Boerngen 1984) estimate of the average 

background level in U.S. soil is higher at 33 ppm B. Eckel and Langley’s (1988) estimate of 26 ppm B as 

an average for U.S. soils is similar to the USGS estimate. Boron salts occur naturally in low 

concentrations in most unpolluted waterways. The average boron concentration in surface waters in the 

U.S. is about 0.1 mg/liter with higher averages in the western U.S. of 5 to 15 mg B/L (Butterwick et al. 

1989). Surface waters in areas in California with boron-rich ore deposits range from about 15 mg B/L in 

coastal drainage waters to 360 mg B/L in a lake (ATSDR 2010). Boron concentrations in seawater 

average 4.5 mg/liter (Maier and Knight 1991). The largest flux component of the global geochemical 

boron cycle is the aerosolization of boron to the atmosphere from seawater, with an annual input of 1.44 

Tg B per year, where Tg = 1012 g (Park and Schlesinger 2002). Other natural annual inputs to the air 

include volcanic emissions (0.017-0.022 Tg B/yr), soil dust (0.017-0.033 Tg B/yr), and plant aerosols 

(0.004 Tg B/yr) (Park and Schlesinger 2002). As an essential element for plants, boron is found in the 

tissues, seeds and fruit of plants. Plant leaves contain about 25 to 100 ppm B (Troeh and Thompson 

2005). Most of the naturally occurring boron is inorganic, but because it is an essential element for many 

organisms there is an organically-bound component. It is against this background of naturally occurring 

boron that judgments on the environmental fate and exposure of boron released from pesticidal uses must 

be made. Additionally, boron is an essential nutrient for plants, including aquatic plants, in small 

quantities. There is also evidence that it is an essential trace element for lower and higher order animals, 

including humans (Nielsen 2008; USEPA 2008). This means if the boron content in soil is too low plants 

may not thrive or if it is too low in water aquatic plants, fish, and invertebrates may not thrive.
65

Appendix D Releases of Boron from Household Products and 

Manufacturing and Industrial Processing

Household Products 

There are a number of anthropogenic sources of boron to effluent from household uses. 

A major anthropogenic input is soaps and detergents which was identified in Table X. 

Additionally there will be inputs to surface water via domestic waste from foodstuffs, cosmetics, 

personal care products, and pharmaceuticals (Hunt el al. 1991; Tjandraatmadja et al., 2008)

Manufacturing and Industrial Processing Releases to the Environment 

The Toxic Release Inventory (TRI) Program14, which is a potential source of information 

on manufacturing and industrial releases of chemicals to the environment, has no information on 

release of boric acid and sodium borate salts. These chemicals are not required to be reported as 

part of the inventory program. The TRI program only contains information on the release of 

boron trichloride and boron trifluoride, both of which are classified as extremely hazardous 

substances under the Comprehensive Environmental Response, Compensation, and Liability Act 

of 1980 (CERCLA), neither one is a pesticide. Boron releases to the environment are known to 

occur from the mining of boron ore, from coal bed natural gas produced water, geothermal waste 

water, and in wastewater from coal-burning power plants, copper smelters, and industries using 

boron compounds (ATSDR, 2010).

 

14 http://www2.epa.gov/toxics-release-inventory-tri-program/tri-listed-chemicals accessed June 10, 2015
66

Appendix E Submitted Studies

Submitted Environmental Fate and Chemistry Studies

011102 Borax Acid Fate Bibliography

161-1 Hydrolysis

MRID Citation Reference

46955805 Kay, J. (2006) Public Data Waiver Request for the Submission of Hydrolysis, Photodegradation 

in Water, Photodegradation on Soil, Anaerobic Soil Metabolism, Soil Field Dissipation, Long 

Term Field Dissipation Study, Confined Crop Rotation, and Accumulation in Fish: (Prev-Am 

Ultra). Project Number: OA/200601. Unpublished study prepared by ORO Agri, Inc. 191 p.

161-2 Photodegradation-water

MRID Citation Reference

46955805 Kay, J. (2006) Public Data Waiver Request for the Submission of Hydrolysis, Photodegradation 

in Water, Photodegradation on Soil, Anaerobic Soil Metabolism, Soil Field Dissipation, Long 

Term Field Dissipation Study, Confined Crop Rotation, and Accumulation in Fish: (Prev-Am 

Ultra). Project Number: OA/200601. Unpublished study prepared by ORO Agri, Inc. 191 p.

161-3 Photodegradation-soil

MRID Citation Reference

46955805 Kay, J. (2006) Public Data Waiver Request for the Submission of Hydrolysis, Photodegradation 

in Water, Photodegradation on Soil, Anaerobic Soil Metabolism, Soil Field Dissipation, Long 

Term Field Dissipation Study, Confined Crop Rotation, and Accumulation in Fish: (Prev-Am 

Ultra). Project Number: OA/200601. Unpublished study prepared by ORO Agri, Inc. 191 p.

162-1 Aerobic soil metabolism

MRID Citation Reference

46986401 Pletscher, E. (2004) Determination of the Biological Elimination; Determination of the 

Mineralisation; Determination of Inhibition of Nitrification: (Prevam Ultra). Project Number: 

435033. Unpublished study prepared by EMPA. 7 p.

162-2 Anaerobic soil metabolism

MRID Citation Reference

46955805 Kay, J. (2006) Public Data Waiver Request for the Submission of Hydrolysis, Photodegradation 

in Water, Photodegradation on Soil, Anaerobic Soil Metabolism, Soil Field Dissipation, Long 

Term Field Dissipation Study, Confined Crop Rotation, and Accumulation in Fish: (Prev-Am 

Ultra). Project Number: OA/200601. Unpublished study prepared by ORO Agri, Inc. 191 p.

164-1 Terrestrial field dissipation

MRID Citation Reference
67

46955805 Kay, J. (2006) Public Data Waiver Request for the Submission of Hydrolysis, Photodegradation 

in Water, Photodegradation on Soil, Anaerobic Soil Metabolism, Soil Field Dissipation, Long 

Term Field Dissipation Study, Confined Crop Rotation, and Accumulation in Fish: (Prev-Am 

Ultra). Project Number: OA/200601. Unpublished study prepared by ORO Agri, Inc. 191 p.

164-5 Long term soil dissipation

MRID Citation Reference

46955805 Kay, J. (2006) Public Data Waiver Request for the Submission of Hydrolysis, Photodegradation 

in Water, Photodegradation on Soil, Anaerobic Soil Metabolism, Soil Field Dissipation, Long 

Term Field Dissipation Study, Confined Crop Rotation, and Accumulation in Fish: (Prev-Am 

Ultra). Project Number: OA/200601. Unpublished study prepared by ORO Agri, Inc. 191 p.

165-1 Confined rotational crop

MRID Citation Reference

46955805 Kay, J. (2006) Public Data Waiver Request for the Submission of Hydrolysis, Photodegradation 

in Water, Photodegradation on Soil, Anaerobic Soil Metabolism, Soil Field Dissipation, Long 

Term Field Dissipation Study, Confined Crop Rotation, and Accumulation in Fish: (Prev-Am 

Ultra). Project Number: OA/200601. Unpublished study prepared by ORO Agri, Inc. 191 p.

165-4 Bioaccumulation in fish

MRID Citation Reference

46955805 Kay, J. (2006) Public Data Waiver Request for the Submission of Hydrolysis, Photodegradation 

in Water, Photodegradation on Soil, Anaerobic Soil Metabolism, Soil Field Dissipation, Long 

Term Field Dissipation Study, Confined Crop Rotation, and Accumulation in Fish: (Prev-Am 

Ultra). Project Number: OA/200601. Unpublished study prepared by ORO Agri, Inc. 191 p.

Submitted Ecotoxicity Studies

011001 Boric Acid Eco Effects Bibliography

71-1 Avian Single Dose Oral Toxicity

MRID Citation Reference

145393 Beavers, J. (1984) An Acute Oral Toxicity Study in the Bobwhite with Firebrake ZB: Final 

Report: Project No. 135-107. Unpub- lished study prepared by Wildlife International Ltd. 19 p. 

Boric Acid+ Zinc Oxide mix

48851202 Stafford, J.M. (2012) Canary (Serinus canaria) Dietary Acute Toxicity Test with Boric Acid. 

Unpublished study performed by Smithers Viscient, Carolina Research Center, Snow Camp, 

NC. Project ID: 14018.4100. Study sponsored by Borate Testing Task Force c/o Lewis & 

Harrison LLC, Washington, D.C. Study initiated February 13, 2012 and completed May 30, 

2012.
68

71-2 Avian Dietary Toxicity

MRID Citation Reference

141770 Beavers, J. (1984) A Dietary LC50 Study in the Bobwhite with inert ingredient: Final Report: 

Project No. 176-102A. Unpublished study; 14 p. 

141771 Beavers, J. (1984) A Dietary LC50 Study in the Mallard with inert ingredient: Final Report: 

Project No. 176-103. Unpublished study; 13 p. 

41017501 Sander, J. (1989) Safecide Bait: Determination of Mortality and Boron Tissue Levels in 

Chickens and Turkeys Exposed to Litter Containing Orthoboric Acid. Unpublished study 

prepared by Phoenix Co., Inc. 5 p. 

41086601 Sander, J. (1989) Experimental Design and Tissue Residue Results, Addendum to 

Determination of Mortality and Boron Tissue Levels in Chickens and Turkeys Exposed to Litter 

Containing Orthoboric Acid: SafeCide Bait. Unpublished study prepared by Phoenix Co., Inc. 12 

p. 

850.2200 Avian dietary toxicity test

MRID Citation Reference

47054802

PC Code 075202

Frangos, J. (2007) Toxicity and Ecotoxicity Data on Sodium Fluoride. Project Number: 

TR030107/JF. Unpublished study prepared by Toxikos Pty. Ltd. 222 p. Boric acid is mixed 

with Sodium fluoride as a product

850.2300 Avian Reproduction

MRID Citation Reference

49009801

Stafford, J.M. (2012) Boric Acid Reproductive Toxicity Test with the Mallard (Anas 

platyrhynchos), Following OPPTS 850.2300 and OECD 206. Unpublished study performed by 

Smithers Viscient (CRC), Snow Camp, NC. Laboratory Project No. 14018.4103. Study 

sponsored by Borate Testing Task Force c/o Lewis & Harrison LLC, Washington DC. Study 

initiated October 3, 2011 and completed November 21, 2012.

49185901

Stafford, J.M. (2013) Boric Acid Reproductive Toxicity Test with the Northern Bobwhite (Colinus 

virginianus), Following OPPTS 850.2300 and OECD 206. Unpublished study performed by 

Smithers Viscient (CRC), Snow Camp, NC. Laboratory Project No. 14018.4102. Study 

sponsored by Borate Testing Task Force c/o Lewis & Harrison LLC, Washington DC. Study 

initiated October 19, 20121 and completed May 15, 2013.

72-1 Acute Toxicity to Freshwater Fish

MRID Citation Reference

143244 Sousa, J. (1984) Acute Toxicity of Firebrake ZB to Rainbow Trout ...; BW-84-10-1647. 

Unpublished study prepared by Springborn Bionomics, Inc. 13 p. Boric Acid+Zinc Oxide -

mixture

40594601 LeLievre, M. (1988) Static Acute Toxicity of 20 Mule Team Boric Acid Granular Technical to 

Rainbow Trout (Salmo gairdneri): Report #88-2-2620: Study #10994.1187.6102.103. 

Unpublished study prepared by Springborn Life Sciences, Inc. 25 p. 

40594602 LeLievre, M. (1988) Static Acute Toxicity of 20 Mule Team Boric Acid Granular Technical to 

Bluegill (Lepomis macrochirus): Report #88-2-2631: Study #10994.1187.6102.100. 

Unpublished study prepared by Springborn Life Sciences, Inc. 26 p. 

46074203 Hertl, D. (2003) Acute Toxicity of Wolsin FL-35 to Rainbow Trout (Oncorhynchus mykiss) in a 

96 hour Semi Static Test: (Final Report). Project Number: 14643230. Unpublished study 
69

prepared by Institut fuer Biologische Analytik und. 78 p. Apparently a Mixture with Boric 

Acid+Fenpropimorph + Propiconazole

850.1075 Fish acute toxicity test, freshwater and marine

MRID Citation Reference

47054802 Frangos, J. (2007) Toxicity and Ecotoxicity Data on Sodium Fluoride. Project Number: 

TR030107/JF. Unpublished study prepared by Toxikos Pty. Ltd. 222 p. Boric Acid+Sodium 

fluoride (075201)mix?

47069401 Fenzl, C. (2003) Wolmanit CX-LP 15172: Acute Toxicity Study for Zebra fish. Project Number: 

WOL67. Unpublished study prepared by Austrian Research Center (ARC). 34 p. Boric 

Acid+Copper carbonate + bis-(N-Cyclohexyldiazeniumdioxy)-Copper (PC Code 235500)

47069404 Hettler, W. (2007) Supplement to Data Evaluation Record Acute Toxicity to Fish, Freshwater: 

(Protectol CX Type A). Project Number: WOLFH070102. Unpublished study prepared by Dr. 

Wolman GmbH. 19 p.

850.1400 Fish Early Life Stage

MRID Citation Reference

48914601

Hoberg, J.R. (2012) Boric Acid - Early Life-Stage Toxicity Test with Fathead Minnow, 

Pimephales promelas, Following OPPTS Draft Guideline 850.1400. Unpublished study 

performed by Smithers Viscient, Wareham, MA. Laboratory Study No. 14018.6108. Study 

sponsored by Borate Testing Task Force c/o Lewis & Harrison LLC, Washington, DC. Study 

initiated October 25, 2011 and completed August 21, 2012

72-2 or 850.1010 Acute Toxicity to Freshwater Invertebrates

MRID Citation Reference

143245 Hoberg, J. (1984) Acute Toxicity of Firebrake ZB to Daphnids ...: Report #BW-84-10-1648. 

Unpublished study prepared by Springborn Bionomics, Inc. 13 p. Boric Acid+ Zinc Oxide 

mixture

46074204 Hertl, D. (2003) Acute Toxicity of Wolsin FL-35 to Daphnia magna in a 48 hour Immobilization 

Test. Project Number: 14642220. Unpublished study prepared by Institut fuer Biologische 

Analytik und. 69 p. Apparently a Mixture with Boric Acid+Fenpropimorph + Propiconazole

47054802 Frangos, J. (2007) Toxicity and Ecotoxicity Data on Sodium Fluoride. Project Number: 

TR030107/JF. Unpublished study prepared by Toxikos Pty. Ltd. 222 p. Sodium biflouride is 

mixed with Boric acid

850. 1300 Freshwater Invertebrate Life Cycle Test

MRID Citation Reference

48507004

Hooftman, R.N., D. van Drongelen-Sevenhuijsen, and H.P.M. de Haan. (2000) Semi-Static 

Reproduction Test with Boric Acid, Manufacturing Grade and Daphnia magna (OECD Guideline 

No. 211). Unpublished study performed by TNO Nutrition and Research Institute, Department 

of Environmental Toxicology, Delft, The Netherlands. Laboratory Project ID: IMW-99-9047-10. 

Study sponsored by Borax Europe Limited, Guildford, UK. Study initiated July 12, 1999 and 

completed March 3, 2000.

72-3 or 850.1025 Oyster acute toxicity test (shell deposition)

MRID Citation Reference
70

47320503 Gallagher, S.; Kendall, T.; Krueger, H. (2007) bis-(N-Cyclohexyldiazeniumdioxy)-Copper: A 

96-Hour Shell Deposition Test with the Eastern Oyster (Crassostrea virginica). Project Number: 

147A/230, 99F0679/899202. Unpublished study prepared by Wildlife International, Ltd. 41 p. 

Contained in mixture with Boric Acid

72-3 or 850.1035 Mysid acute toxicity test

MRID Citation Reference

47320504 Gallagher, S.; Kendall, T.; Krueger, H. (2007) Bis-(N-Cyclohexyldiazeniumdioxy)-Copper; A 

96-Hour Static Acute Toxicity Test with the Saltwater Mysid (Americamysis bahia). Project 

Number: 147A/229A, 99F0679/899206. Unpublished study prepared by Wildlife International, 

Ltd. 42 p. Contained in mixture with Boric Acid

47320502 Thomson, N. (2007) Assessment of the Aquatic-Phase Toxicity of bis-(NCyclohexyldiazeniumdioxy)-Copper to the Marine Fish Cyprinodon variegatus. Project 

Number: 99F0679/899201, 896/26, 07/007. Unpublished study prepared by Opus Plus Limited. 

21 p. Contained in mixture with Boric Acid

47537801 Hettller, W. (2008) Supplement to Environmental Toxicity Studies MRID No.'s 47320502, 

47355201, 47210203 of Protectol CX Type A. Project Number: WOL/ETCXA/080831. 

Unpublished study prepared by DR. Wolman GmbH. 8 p.

141-1 Honey bee acute contact

MRID Citation Reference

40269201 Atkins, E. (1987) Laboratory Bee Adult Toxicity Dusting Tests (BATDT) for Boric Acid, 

Powdered, 100% ai Technical: Laboratory Project ID: 445 and 446. Unpublished study 

prepared by Univ. of California--Riverside, Dept. of Entomology. 14 p. 

850.3020 Honey bee acute contact toxicity

MRID Citation Reference

47125501 Schur, A. (1999) Assessment of Side Effects of Fenpropimorph to the Honey Bee, Apis 

mellifera L. in the Laboratory. Project Number: 99343/01/BLEU. Unpublished study prepared by 

Arbeitsgemeinschaft GAB Biotechnologie. 23 p.

850.4225 Seedling emergence, Tier II

MRID Citation Reference

46325401 Jatzek (2003) Protectol CX Type A - Determination of the Effect on the Emergence, Growth 

and the Observation of Morphological Changes of Rice (Oryza sativa L.). Project Number: 

03/0050/65/1. Unpublished study prepared by BASF Aktiengesellschaft. 42 p.

47069405 Schwartz, R. (2007) Supplement to The Rice Seedling Emergence Study for Protectol CX 

Type A (CU-HDO). Project Number: WOL ET070105. Unpublished study prepared by Dr. 

Wolman GmbH. 4 p.

48885402 Martin, J.A. (2012) Boric Acid: Seedling Emergence Test Following U.S. EPA OPPTS Draft 

Guideline 850.4225. Unpublished study performed by Smithers Viscient, Wareham, 

Massachusetts. Study sponsored by Borate Testing Task Force, Washington, D.C. Study No.: 

14018.6101. Study completed July 10, 2012.
71

850.4250 Vegetative vigor, Tier II

MRID Citation Reference

46325401 Jatzek (2003) Protectol CX Type A - Determination of the Effect on the Emergence, Growth 

and the Observation of Morphological Changes of Rice (Oryza sativa L.). Project Number: 

03/0050/65/1. Unpublished study prepared by BASF Aktiengesellschaft. 42 p. Boric 

Acid+Copper carbonate + bis-(N-Cyclohexyldiazeniumdioxy)-Copper (PC Code 235500)

47069405 Schwartz, R. (2007) Supplement to The Rice Seedling Emergence Study for Protectol CX 

Type A (CU-HDO). Project Number: WOL ET070105. Unpublished study prepared by Dr. 

Wolman GmbH. 4 p.

48885401 Martin, J.A. (2012) Boric Acid: Vegetative Vigor Test Following U.S. EPA OPPTS Draft 

Guideline 850.4225. Unpublished study performed by Smithers Viscient, Wareham, 

Massachusetts. Study sponsored by Borate Testing Task Force, Washington, D.C. Study No.: 

14018.6102. Study completed July 10, 2012.

850.4400 Aquatic plant toxicity test using Lemna spp. Tiers I and II

MRID Citation Reference

46522304 Jovanovich, A.; Obenshain, K.; Kroger, K.; et. al. (2005) Specific Responses to #2 Deficiency 

Review Notes for Impralit KDS: Non-Target Plants. Project Number: 2003/0363. Unpublished 

study prepared by Keller and Heckman LLP. 20 p.

48820802 Softcheck, K.A. (2012) Boric Acid- 7-Day Toxicity Test with Duckweed (Lemna gibba) Following 

OPPTS Draft Guideline 850.4400. Study performed by Smithers Viscient, Wareham, MA. Study 

number 14018.6103. Study sponsored by the Borate Testing Task Force c/o Lewis & Harrison 

LLC, Washington, DC. Study initiated 28 September 2011 and completed 30 April 2012.

850.5400 Algal toxicity, Tiers 1 and II

MRID Citation Reference

47210203 Hudson, B. (2007) Assessment of the Algal Toxicity, Tiers I and II (96H EC50) of Wolmanit 

CX-LP 15172 to the Marine Alga Skeletonema costatum, the Freshwater Algae Selenastrum 

capricornutum and Anabaena flos aquae. Project Number: 893/27, 06/083, 0101. Unpublished 

study prepared by Opus Plus Limited. 67 p.

Boric Acid+Copper carbonate + bis-(N-Cyclohexyldiazeniumdioxy)-Copper (PC Code 

235500)

47355201 Cafarella, M. (2007) Wolmanit CX-LP 15172: Alga, Growth Inhibition Test with Navicula 

pelliculosa. Project Number: 1111/000440, 20071476/01/UW, 1111/000/440. Unpublished 

study prepared by Springborn Smithers Laboratories (Europe). 90 p. Boric Acid+Copper 

carbonate + bis-(N-Cyclohexyldiazeniumdioxy)-Copper (PC Code 235500)

47537801 Hettller, W. (2008) Supplement to Environmental Toxicity Studies MRID No.'s 47320502, 

47355201, 47210203 of Protectol CX Type A. Project Number: WOL/ETCXA/080831. 

Unpublished study prepared by DR. Wolman GmbH. 8 p.

48507003 Hanstvelt, A.O., Oldersma, H. (2000) Determination of the effect of boric acid, manufacturing 

grade on the growth of freshwater green alga, Selenastrum capricornutum. Study performed by 

TNO Nutrition and Food Research Institute, Department of Environmental Toxicology, The 

Netherlands. Study ID number IMW-99-9047-05. Report number V99.157. Study sponsored by 

Borax Europe Limited and submitted by U.S. Borax. Study completed 07 March 2000.

48820802 Softcheck, K.A. (2012) Boric Acid- 7-Day Toxicity Test with Duckweed (Lemna gibba) Following 

OPPTS Draft Guideline 850.4400. Study performed by Smithers Viscient, Wareham, MA. Study 

number 14018.6103. Study sponsored by the Borate Testing Task Force c/o Lewis & Harrison 

LLC, Washington, DC. Study initiated 28 September 2011 and completed 30 April 2012.
72

48820803 Softcheck, K.A. (2012) Boric Acid- 96-Hour Toxicity Test with the Marine Diatom, Skeletonema 

costatum, Following OPPTS Draft Guideline 850.5400. Study performed by Smithers Viscient, 

Wareham, MA. Study number 14018.6106. Study sponsored by the Borate Testing Task Force 

c/o Lewis & Harrison LLC, Washington, DC. Study initiated 28 September 2011 and completed 

30 April 2012.

48810804 Softcheck, K.A. (2012) Boric Acid- 96-Hour Toxicity Test with the Freshwater Green Alga, 

Pseudokirchneriella subcapitata, Following OPPTS Draft Guideline 850.5400. Study performed 

by Smithers Viscient, Wareham, MA. Study number 14018.6104. Study sponsored by the 

Borate Testing Task Force c/o Lewis & Harrison LLC, Washington, DC. Study initiated 28 

September 2011 and completed 30 April 2012.

48851201 Softcheck, K.A. (2012) Boric Acid—96-Hour Toxicity Test with the Freshwater Diatom, Navicula 

pelliculosa, Following OPPTS Draft Guideline 850.5400. Study performed by Smithers Viscient, 

Wareham, MA. Study number 14018.6105. Study sponsored by the Borate Testing Task Force, 

Washington, DC. Study completed 30 May 2012.

PC Code 011002 Boron oxide B2O3 ECO Effects Bibliography

Contains no additional ecotoxicity data

PC Code 011102 Borax ECO Effects Bibliography

71-1 Avian Single Dose Oral Toxicity

MRID Citation Reference

60198 Reinert, H.K.; Parke, G.S.E. (1976) Acute Oral Toxicity in Bobwhite Quail: Compound: Grotan 

HD-11: Laboratory No. 6E-2370. (Unpublished study received Nov 15, 1976 under 10000-3; 

prepared by Cannon Laboratories, Inc., submitted by Hallemite Lehn & Fink, Montvale, N.J.; 

CDL:226912-A) 

75031 Fletcher, D. (1973) Report to U.S. Borax Research Corporation: Acute Oral Toxicity Study with 

Borax in Bobwhite Quail: IBT No. J2632. (Unpublished study received Mar 12, 1973 under 

1624- 94; prepared by Industrial Bio-Test Laboratories, Inc., sub- mitted by United States Borax 

& Chemical Corp., Los Angeles, Calif.; CDL:006476-A) 

100657 Fink, R.; Beavers, J.; Joiner, G.; et al. (1982) Final Report: Acute Oral LD50--Bobwhite Quail: 

20 Mule Team Borax, Granular: Project No. 135-106. (Unpublished study received Apr 30, 

1982 under 1624-94; prepared by Wildlife International Ltd., submitted by United States Borax 

& Chemical Corp., Los Angeles, CA; CDL:247369-A)

145393 Beavers, J. (1984) An Acute Oral Toxicity Study in the Bobwhite with Firebrake ZB: Final 

Report: Project No. 135-107. Unpub- lished study prepared by Wildlife International Ltd. 19 p.

71-2 Avian Dietary Toxicity

MRID Citation Reference

67969 Terrell, Y.; Parke, G.S.E. (1974) Report: Eight Day Dietary LC50 Study of Grotan HD II in 

Bobwhite Quail and Mallard Ducks: Laboratory No. 4E-3071. (Unpublished study received Feb 

20, 1975 under 10000-3; prepared by Cannon Laboratories, Inc., submitted by Hallemite Lehn 

& Fink, Montvale, N.J.; CDL:232140-E)

73956 Fletcher, D. (1977) Report to Kerr McGee Chemical Corporation: 8-day Dietary LC 50 Study 

with Borax in Mallard Ducklings: IBT No. 8580-10598; prepared by Industrial Bio-Test 

Laboratories, Inc. Unpublished study; 12 p. 
73

73957 Phillips, B.M.; Reinart, D.; Fletcher, D. (1977) Report to Kerr McGee Chemical Corporation: 8-

day Dietary LC 50 Study with Borax in Bobwhite Quail: IBT No. 8580-10597; prepared by 

Industrial Bio-Test Laboratories, Inc. Unpublished study; 12 p. 

149195 Reinart, D.; Fletcher, D. (1977) 8-Day Dietary LC50 Study with Borax in Bobwhite Quail: IBT 

No. 8580-10597. Unpublished study prepared by Industrial Bio-Test Laboratories, Inc. 14 p.

72-1 Acute Toxicity to Freshwater Fish

MRID Citation Reference

67968 Davis, A.C. (1974) Ninety-six Hour LC50 of Grotan HD II in Rainbow Trout and Bluegill Sunfish: 

Laboratory No. 4E-3069. (Unpublished study received Feb 20, 1975 under 10000-3; prepared 

by Cannon Laboratories, Inc., submitted by Hallemite Lehn & Fink, Montvale, N.J.; 

CDL:232140-D) 

90307 McCann, J.A. (1972) Steri-soil: Rainbow Trout (Salmo gairdneri): Test No. 456. (U.S. 

Agricultural Research Service, Pesticides Regulation Div., Animal Biology Laboratory, Fish 

Toxicity Laboratory; unpublished study; CDL:130478-A) 

90308 McCann, J.A. (1972) Steri-soil: Bluegill (Lepomis macrochirus): Test No. 444. (U.S. Agricultural 

Research Service, Pesticides Regulation Div., Animal Biology Laboratory, Fish Toxicity 

Laboratory; unpublished study; CDL:130479-A) 

72-2 Acute Toxicity to Freshwater Invertebrates

MRID Citation Reference

60199 Reinert, H.K.; Parke, G.S.E. (1976) Report: Static 48-Hour Toxicity Study of Grotan HD 11 in 

Daphnids: Laboratory No. 6E-2371. (Un- published study received Nov 15, 1976 under 10000-

3; prepared by Cannon Laboratories, Inc., submitted by Hallemite Lehn & Fink, Montvale, N.J.; 

CDL:226912-B)

122-1 Seed Germination/Seedline Emergence and Vegetable Vigor

MRID Citation Reference

46955802 Kay, J. (2006) Public Data and Waiver Request for the Submission of Seed Germination. 

Seedling Emergence and Vegetative Vigor Data: (Prev-Am Ultra). Project Number: OA/200602. 

Unpublished study prepared by ORO Agri, Inc. 27 p.

122-2 Aquatic plant growth

MRID Citation Reference

46955801 Sullivan, J. (2003) The Acute Toxicity of Citrus Oil Products PREV-Am to the Freshwater Algae, 

Selenastrum capricornutum, Freshwater Crustacean, Daphnia magna, and the Freshwater 

Fish, Salmo Gairdneri. Project Number: 038801. Unpublished study prepared by Bioanalytical 

Corporation. 19 p.

141-1 Honey bee acute contact

MRID Citation Reference
74

46955803 Londzin, W. (2005) Acute Oral Toxicity for Honey Bees (Apis Mellifera L.): (Prev-Am Ultra). 

Project Number: B/12/05. Unpublished study prepared by Institute of Organic Industry, Branch 

Pszczna: Department of Ecotoxicological Studies. 22 p.

46955804 Londzin, W. (2005) Acute Dorsal Contact Toxicity for Honey-Bees (Apis Mellifera L.). Project 

Number: B/13/05: (Prev-Am Ultra). Unpublished study prepared by Institute of Organic Industry, 

Branch Pszczna: Department of Ecotoxicological Studies. 22 p.

142-3 Simulated or Actual Field Testing

MRID Citation Reference

60632 Johansen, C.; Eves, J. (1967) Bee Research Investigations, 1967: Report No. 21866. 

(Unpublished study received Mar 27, 1974 un- der 4F1485; prepared by Washington State 

Univ., submitted by Chemagro Corp., Kansas City, Mo.; CDL:092011-M) 

PC Code 011103 Sodium octaborate, tetrahydrate Eco Effects Bibliography

71-1 Avian Single Dose Oral Toxicity

MRID Citation Reference

107904 Fink, R.; Beavers, J.; Joiner, G.; et al. (1982) Final Report: Acute Oral LD50--Bobwhite Quail: 

Polybor: Project No. 135-105. (Unpublished study received Apr 30, 1982 under 1624-2; 

prepared by Wildlife International Ltd., submitted by United States Borax & Chemical Corp., Los 

Angeles, CA; CDL:247364-B) 

71-2 Avian Dietary Toxicity

MRID Citation Reference

100636 Fink, R.; Beavers, J.; Joiner, G.; et al. (1982) Final Report: Eight-day Dietary LC50--Mallard 

Duck: Polybor: Project No. 135- 104. (Unpublished study received Apr 30, 1982 under 1624-2; 

prepared by Wildlife International Ltd., submitted by United States Borax & Chemical Corp., Los 

Angeles, CA; CDL:247364-C) 

100637 Fink, R.; Beavers, J.; Joiner, G.; et al. (1982) Final Report: Eight-day Dietary LC50--Bobwhite 

Quail: Polybor: Project No. 135-103. (Unpublished study received Apr 30, 1982 under 1624-2; 

prepared by Wildlife International Ltd., submitted by United States Borax & Chemical Corp., Los 

Angeles, CA; CDL: 247364-D) 

PC Code 011104 Boric acid, sodium salt ECO Effects Bibliography

71-2 Avian Dietary Toxicity

MRID Citation Reference
75

73954 Fletcher, D. (1977) Report to Kerr McGee Chemical Corporation: 8- day Dietary LC 50 Study 

with Sodium Metaborate in Mallard Duck- lings: IBT No. 8580-10602; prepared by Industrial BioTest Lab- oratories, Inc. Unpublished study; 12 p. 

73955 Phillips, B.M.; Reinart, D.; Fletcher, D. (1949?) Report to Kerr McGee Chemical Corporation: 8-

day Dietary LC50 Study with Sodium Metaborate in Bobwhite Quail: IBT No. 8580-10601. 

Unpublished study prepared by Industrial Bio-Test Laboratories, Inc. 12 p. 

72-1 Acute Toxicity to Freshwater Fish

MRID Citation Reference

74975 McCann, J. (1970) Permatox 100 Liquid Fungicide Concentrate: Rain- bow Trout|: Test No. 267. 

(U.S. Agricultural Research Service, Pesticides Regulation Div., Animal Biology Laboratory; 

unpublished study; CDL:104618-A) 

107146 McCann, J. (1971) Permatox Liquid Fungicide Concentrate: Fathead Minnow|: Test No. 381. 

(U.S. Agricultural Research Service, Pesticides Regulation Div., Animal Biology Laboratory; 

unpublished study; CDL:130367-A) 

110816 Hutchinson, C. (1971) The Acute Toxicity of Permatox 100 to Blue-gill and Rainbow Trout 

(Salmo gairdneri). (Unpublished study received Nov 5, 1971 under 1022-465; prepared by 

Bionomics, Inc., submitted by Chapman Chemical Co., Memphis, TN; CDL:005434-A) 

72-4 Fish Early Life Stage/Aquatic Invertebrate Life Cycle Study

MRID Citation Reference

24964 McCann, J.A. (1972) (Ureabor: Toxicity to Rainbow Trout): Test No. 457. (U.S. Agricultural 

Research Service, Pesticides Regulation Div., Animal Biology Laboratory, unpublished report.) 

24965 McCann, J.A. (1972) (Ureabor: Toxicity to Bluegill): Test No. 447. (U.S. Agricultural Research 

Service, Pesticides Regulation Div., Animal Biology Laboratory, unpublished report.) 

24967 Pitcher, F.G. (1974) Weedgard G: Toxicity to Rainbow Trout|: Test No. 773. (U.S. Environmental 

Protection Agency, Chemical & Biological Investigations Branch, TSD, Animal Biology Laboratory, unpublished report.) 

24969 Pitcher, F.G. (1973) Weedgard G: Toxicity to Bluegill|: Test No. 643. (U.S. Environmental 

Protection Agency, Pesticides Reg- ulation Div., Agricultural Research Center, Animal Biology 

Labo- ratory, unpublished report.) 

121-1 Phytotoxicity

MRID Citation Reference

5548 Uniroyal Chemical (1977) Vitavax-25 DB--Phytotoxicity. (Unpublished study received Feb 28, 

1978 under 400-115; prepared in cooperation with Univ. of Idaho, Experiment Station; 

CDL:238076-D) 
76

PC Code 011107 Disodium octaborate, anhydrous (B8Na2O13) ECO Effects 

Bibliography

850.1300 Daphnid chronic toxicity test

MRID Citation Reference

48507004 Hooftman, R.; Van Drongelen-Sevenhuijsen, D.; de Haan, H. (2000) Semi-Static Reproduction 

Test with Boric Acid, Manufacturing Grade and Daphnia magna. Project Number: 

IMW/99/9047/10. Unpublished study prepared by TNO Nutrition and Food. 37 p.

850.2300 Avian reproduction test

MRID Citation Reference

49009801 Stafford, J. (2012) Boric Acid Reproductive Toxicity Test with the Mallard (Anas platyrhynchos). 

Project Number: 14018/4103. Unpublished study prepared by Smithers Viscient. 342p.

49185901 Stafford, J. (2013) Boric Acid: Reproductive Toxicity Test with the Northern Bobwhite (Colinus 

virginianus). Project Number: 14018/4102. Unpublished study prepared by Smithers Viscient. 

375p.

850.5400 Algal toxicity, Tiers 1 and II

MRID Citation Reference

48507003 Hanstvelt, A.; Oldersma, H. (2000) Determination of the Effect of Boric Acid, Manufacturing 

Grade on the Growth of Fresh Water Green Alga, Selenastrum capriconutum. Project Number: 

IMW/99/9047/05. Unpublished study prepared by TNO Nutrition and Food. 31 p.

PC Code 011110 Disodium tetraborate pentahydrate (B4Na2O7•5H2O) ECO 

Effects Bibliography

Contains no additional ecotoxicity data

PC Code 011111 Sodium borate pentahydrate (H3BO3Na+•5H2O) ECO 

Effects Bibliography

Contains no additional ecotoxicity data

PC Code 011112 Boron sodium oxide (B4Na2O7) ECO Effects Bibliography

Contains no additional ecotoxicity data
77

Appendix F GENEEC Modeling Summary for Boric acid and 

Sodium Borate Salts.

From previous assessment for use in screening.

Assumptions: Application rate of 0.07 lb/acre by ground spray, high boom, fine spray, no wet-in, no spray 

drift buffer, no incorporation, stable to all degradation processes, solubility 59,300 ppm. Either one 

application (Run #1) or 52 weekly applications (Run #2).

 RUN No. 1 FOR borax ON any * INPUT VALUES * 

 --------------------------------------------------------------------

 RATE (#/AC) No.APPS & SOIL SOLUBIL APPL TYPE NO-SPRAY INCORP

 ONE(MULT) INTERVAL Kd (PPM ) (%DRIFT) ZONE(FT) (IN)

 --------------------------------------------------------------------

 .070( .070) 1 1 .159300.0 GRHIFI( 6.6) .0 .0

 FIELD AND STANDARD POND HALFLIFE VALUES (DAYS) 

 --------------------------------------------------------------------

 METABOLIC DAYS UNTIL HYDROLYSIS PHOTOLYSIS METABOLIC COMBINED

 (FIELD) RAIN/RUNOFF (POND) (POND-EFF) (POND) (POND) 

 --------------------------------------------------------------------

 .00 2 N/A .00- .00 .00 .00

 GENERIC EECs (IN MICROGRAMS/LITER (PPB)) Version 2.0 Aug 1, 2001

 --------------------------------------------------------------------

 PEAK MAX 4 DAY MAX 21 DAY MAX 60 DAY MAX 90 DAY

 GEEC AVG GEEC AVG GEEC AVG GEEC AVG GEEC

 --------------------------------------------------------------------

 4.10 4.10 4.09 4.09 4.09

 RUN No. 2 FOR borax ON any * INPUT VALUES * 

 --------------------------------------------------------------------

 RATE (#/AC) No.APPS & SOIL SOLUBIL APPL TYPE NO-SPRAY INCORP

 ONE(MULT) INTERVAL Kd (PPM ) (%DRIFT) ZONE(FT) (IN)

 --------------------------------------------------------------------

 .070( 3.640) 52 7 .159300.0 GRHIFI( 6.6) .0 .0

 FIELD AND STANDARD POND HALFLIFE VALUES (DAYS) 

 --------------------------------------------------------------------

 METABOLIC DAYS UNTIL HYDROLYSIS PHOTOLYSIS METABOLIC COMBINED

 (FIELD) RAIN/RUNOFF (POND) (POND-EFF) (POND) (POND) 

 --------------------------------------------------------------------

 .00 2 N/A .00- .00 .00 .00

 GENERIC EECs (IN MICROGRAMS/LITER (PPB)) Version 2.0 Aug 1, 2001

 --------------------------------------------------------------------

 PEAK MAX 4 DAY MAX 21 DAY MAX 60 DAY MAX 90 DAY

 GEEC AVG GEEC AVG GEEC AVG GEEC AVG GEEC

 --------------------------------------------------------------------

 212.99 212.97 212.90 212.74 212.62
78

Appendix G T-REX Model Input and Output

Weekly Spray Applications:

TREX MODEL INPUTS

These values will be used in the calculation of exposure estimates for foliar, 

granular, liquid and/or 

seed applications of pesticides.

Chemical Identity and Application Information

Chemical Name: Boric Acid Application Rate (lb 

ai/acre)

Seed Treatment? (Check if yes)

FALSE Seeding Rate 

(lbs/acre)

 Use:

Product name and form:

% A.I. (leading zero must be entered for 

formulations <1% a.i.):

Application Rate (lb ai/acre) 0.0625

Half-life (days): 35

Application Interval (days): 7

Number of Applications: 52

Are you assessing applications with variable 

rates or intervals? no

You MUST specify application day in Columns F and G - you may enter up to 30 applications

Assessed Species Inputs (optional, use defaults for RQs for national level 

assessments)

What body weight range is assessed 

(grams)? Birds Mammals

Small 20 15

Medium 100 35

Large 1000 1000
79

Endpoints

Avian

Endpoint Toxicity value

Indicate test species

below

LD50 (mg/kg-bw)

1625.00 1

LC50 (mg/kg-diet)

5620.00 1

NOAEL (mg/kg-bw)

2

NOAEC (mg/kgdiet) 249.00 2

Enter the Mineau et al. Scaling Factor 1.15

Mammalian

Acute Study Chronic Study

Size (g) of mammal used in toxicity study

Default rat body weight is 350 grams 350 20

Endpoint Toxicity value

Reference 

(MRID)

LD50 (mg/kg-bw) 450.00

LC50 (mg/kg-diet)

Reported Chronic 

Endpoint 150.00

1

Is dietary 

concentration 

(mg/kg-diet) 

reported from the 

available chronic 

mammal study? 

(yes or no)

yes

Enter dietary 

concentration 

(mg/kg-diet)

1000.00

Application Type:

1

2

Enter data below:

Is application rate given in lbs 

a.i./Acre? yes

Application rate, lbs a.i./Acre, 

from B10 0.0625

Do not use this input

Do not use this input

Do not use this input

% incorporated 0.00%
80

Summary of Risk Quotient Calculations Based on Upper Bound Kenaga EECs

Table X. Upper Bound Kenaga, Acute Avian Dose-Based Risk Quotients

Size 

Class

(grams)

Adjusted

LD50

EECs and RQs

Short Grass Tall Grass Broadleaf Plants Fruits/Pods/Seeds Arthropods Granivore

EEC RQ EEC RQ EEC RQ EEC RQ EEC RQ EEC RQ

20 1170.70 131.87 0.11 60.44 0.05 74.18 0.06 8.24 0.01 51.65 0.04 1.83 0.00

100 1490.36 75.20 0.05 34.47 0.02 42.30 0.03 4.70 0.00 29.45 0.02 1.04 0.00

1000 2105.19 33.67 0.02 15.43 0.01 18.94 0.01 2.10 0.00 13.19 0.01 0.47 0.00

Table X. Upper Bound Kenaga, Subacute Avian Dietary Based Risk Quotients

LC50

EECs and RQs

Short Grass Tall Grass Broadleaf 

Plants Fruits/Pods/Seeds Arthropods

EEC RQ EEC RQ EEC RQ EEC RQ EEC RQ

5620 115.79 0.02 53.07 0.01 65.13 0.01 7.24 0.00 45.35 0.01

Size class not used for dietary risk quotients 

Table X. Upper Bound Kenaga, Chronic Avian Dietary Based Risk Quotients

NOAEC 

(ppm)

EECs and RQs

Short Grass Tall Grass Broadleaf 

Plants Fruits/Pods/Seeds Arthropods

EEC RQ EEC RQ EEC RQ EEC RQ EEC RQ

249 115.79 0.47 53.07 0.21 65.13 0.26 7.24 0.03 45.35 0.18

Size class not used for dietary risk quotients

Table X. Upper Bound Kenaga, Acute Mammalian Dose-Based Risk Quotients 

Size 

Class

(grams)

Adjusted

LD50

EECs and RQs

Short Grass Tall Grass Broadleaf Plants Fruits/Pods/Seeds Arthropods Granivore

EEC RQ EEC RQ EEC RQ EEC RQ EEC RQ EEC RQ

15 989.02 110.40 0.11 50.60 0.05 62.10 0.06 6.90 0.01 43.2386 0.0437 1.5333 0.0016

35 800.23 76.30 0.10 34.97 0.04 42.92 0.05 4.77 0.01 29.8837 0.0373 1.0597 0.0013

1000 346.12 17.69 0.05 8.11 0.02 9.95 0.03 1.11 0.00 6.92864 0.02 0.2457 0.0007

Table X. Upper Bound Kenaga, Acute Mammalian Dietary Based Risk Quotients

LC50 

(ppm)

EECs and RQs

Short Grass Tall Grass Broadleaf 

Plants Fruits/Pods/Seeds Arthropods

EEC RQ EEC RQ EEC RQ EEC RQ EEC RQ

0 115.79 #DIV/0! 53.07 #DIV/0! 65.13 #DIV/0! 7.24 #DIV/0! 45.35 #DIV/0!

Size class not used for dietary risk quotients

Table X. Upper Bound Kenaga, Chronic Mammalian Dietary Based Risk Quotients

NOAEC 

(ppm)

EECs and RQs

Short Grass Tall Grass Broadleaf 

Plants

Fruits/Pods/Seeds/Large 

Insects Arthropods

EEC RQ EEC RQ EEC RQ EEC RQ EEC RQ

1000 115.79 0.12 53.07 0.05 65.13 0.07 7.24 0.01 45.35 0.05

Size class not used for dietary risk quotients 

Table X. Upper Bound Kenaga, Chronic Mammalian Dose-Based Risk Quotients

Size 

Class

(grams)

Adjusted 

NOAEL

EECs and RQs

Short Grass Tall Grass Broadleaf Plants Fruits/Pods/Seeds Arthropods Granivore

EEC RQ EEC RQ EEC RQ EEC RQ EEC RQ EEC RQ

15 161.19 110.40 0.68 50.60 0.31 62.10 0.39 6.90 0.04 43.24 0.27 1.53 0.01

35 130.42 76.30 0.59 34.97 0.27 42.92 0.33 4.77 0.04 29.88 0.23 1.06 0.01

1000 56.41 17.69 0.31 8.11 0.14 9.95 0.18 1.11 0.02 6.93 0.12 0.25 0.00
81

Single Spray Application:

TREX MODEL INPUTS

These values will be used in the calculation of exposure estimates for foliar, granular, liquid and/or seed 

applications of pesticides.

Chemical Identity and Application Information

Chemical Name: Boric Acid

Seed Treatment? (Check if yes)

FALSE

 Use:

Product name and form:

% A.I. (leading zero must be entered for 

formulations <1% a.i.): 100.00%

Application Rate (lb ai/acre) 0.07

Half-life (days): 35

Application Interval (days):

Number of Applications: 1

Are you assessing applications with 

variable rates or intervals? no
82

Summary of Risk Quotient Calculations Based on Upper Bound Kenaga EECs

Table X. Upper Bound Kenaga, Acute Avian Dose-Based Risk Quotients

Size 

Class

(grams)

Adjusted

LD50

EECs and RQs

Short Grass Tall Grass Broadleaf Plants Fruits/Pods/Seeds Arthropods Granivore

EEC RQ EEC RQ EEC RQ EEC RQ EEC RQ EEC RQ

20 1170.70 19.13 0.02 8.77 0.01 10.76 0.01 1.20 0.00 7.49 0.01 0.27 0.00

100 1490.36 10.91 0.01 5.00 0.00 6.14 0.00 0.68 0.00 4.27 0.00 0.15 0.00

1000 2105.19 4.88 0.00 2.24 0.00 2.75 0.00 0.31 0.00 1.91 0.00 0.07 0.00

Table X. Upper Bound Kenaga, Subacute Avian Dietary Based Risk Quotients

LC50

EECs and RQs

Short Grass Tall Grass Broadleaf 

Plants Fruits/Pods/Seeds Arthropods

EEC RQ EEC RQ EEC RQ EEC RQ EEC RQ

5620 16.80 0.00 7.70 0.00 9.45 0.00 1.05 0.00 6.58 0.00

Size class not used for dietary risk quotients 

Table X. Upper Bound Kenaga, Chronic Avian Dietary Based Risk Quotients

NOAEC 

(ppm)

EECs and RQs

Short Grass Tall Grass Broadleaf 

Plants Fruits/Pods/Seeds Arthropods

EEC RQ EEC RQ EEC RQ EEC RQ EEC RQ

249 16.80 0.07 7.70 0.03 9.45 0.04 1.05 0.00 6.58 0.03

Size class not used for dietary risk quotients

Table X. Upper Bound Kenaga, Acute Mammalian Dose-Based Risk Quotients 

Size 

Class

(grams)

Adjusted

LD50

EECs and RQs

Short Grass Tall Grass Broadleaf Plants Fruits/Pods/Seeds Arthropods Granivore

EEC RQ EEC RQ EEC RQ EEC RQ EEC RQ EEC RQ

15 989.02 16.02 0.02 7.34 0.01 9.01 0.01 1.00 0.00 6.27353 0.0063 0.2225 0.0002

35 800.23 11.07 0.01 5.07 0.01 6.23 0.01 0.69 0.00 4.33585 0.0054 0.1538 0.0002

1000 346.12 2.57 0.01 1.18 0.00 1.44 0.00 0.16 0.00 1.00528 0.0029 0.0356 0.0001

Table X. Upper Bound Kenaga, Acute Mammalian Dietary Based Risk Quotients

LC50 

(ppm)

EECs and RQs

Short Grass Tall Grass Broadleaf 

Plants Fruits/Pods/Seeds Arthropods

EEC RQ EEC RQ EEC RQ EEC RQ EEC RQ

0 16.80 #DIV/0! 7.70 #DIV/0! 9.45 #DIV/0! 1.05 #DIV/0! 6.58 #DIV/0!

Size class not used for dietary risk quotients

Table X. Upper Bound Kenaga, Chronic Mammalian Dietary Based Risk Quotients

NOAEC 

(ppm)

EECs and RQs

Short Grass Tall Grass Broadleaf 

Plants

Fruits/Pods/Seeds/Large 

Insects Arthropods

EEC RQ EEC RQ EEC RQ EEC RQ EEC RQ

1000 16.80 0.02 7.70 0.01 9.45 0.01 1.05 0.00 6.58 0.01

Size class not used for dietary risk quotients 

Table X. Upper Bound Kenaga, Chronic Mammalian Dose-Based Risk Quotients

Size 

Class

(grams)

Adjusted 

NOAEL

EECs and RQs

Short Grass Tall Grass Broadleaf Plants Fruits/Pods/Seeds Arthropods Granivore

EEC RQ EEC RQ EEC RQ EEC RQ EEC RQ EEC RQ

15 161.19 16.02 0.10 7.34 0.05 9.01 0.06 1.00 0.01 6.27 0.04 0.22 0.00

35 130.42 11.07 0.08 5.07 0.04 6.23 0.05 0.69 0.01 4.34 0.03 0.15 0.00

1000 56.41 2.57 0.05 1.18 0.02 1.44 0.03 0.16 0.00 1.01 0.02 0.04 0.00
83

Using Canary Data:

Endpoints

Avian

Endpoint Toxicity value

Indicate 

test 

species 

below

Optional 

Test 

Organism 

Body 

weight (g)

Optional 

Test 

Species 

Name

LD50 (mg/kg-bw)

1625.00 1

LC50 (mg/kg-diet)

11000.00 3 23.70 Canary

NOAEL (mg/kg-bw)

2

NOAEC (mg/kg-diet)

249.00 2

Enter the Mineau et al. Scaling Factor 1.15

Table X. Upper Bound Kenaga, Subacute Avian Dietary Based Risk Quotients

LC50

EECs and RQs

Short Grass Tall Grass Broadleaf 

Plants Fruits/Pods/Seeds Arthropods

EEC RQ EEC RQ EEC RQ EEC RQ EEC RQ

11000 129.68 0.01 59.44 0.01 72.95 0.01 8.11 0.00 50.79 0.00

Size class not used for dietary risk quotients 
84

Granular Applications:

TREX MODEL INPUTS

These values will be used in the calculation of exposure estimates for foliar, granular, liquid 

and/or seed applications of pesticides.

Chemical Identity and Application Information

Chemical Name: Boric Acid

Seed Treatment? (Check if yes) Granular Apps

FALSE

 Use:

Product name and form:

% A.I. (leading zero must be entered 

for formulations <1% a.i.): 100.00%

Application Rate (lb ai/acre) 1310

Half-life (days): 35

Application Interval (days): 90

Number of Applications: 2

Are you assessing applications 

with variable rates or intervals? no

LD50 ft-2

Application Type:

1

Make sure to 

enter an

1

application rate 

above

% incorporated 0.00%

Chemical: Boric Acid

LD50 ft-2

INPUTS Do not overwrite these numbers.

Application Rate: 1310 lbs / acre

% A.I.: 100.00%

Avian LD50 (20g): 1170.70 mg/kg bw

(100g) 1490.36

(1000g) 2105.19

Mammalian LD50 (15g): 989.02 mg/kg bw

(35g) 800.23

(1000g) 346.12

Row Spacing: 0 inches

Bandwidth: 0 inches

Unincorporation: 100%

Row/Band/In-furrow applications

Granular N/A

Intermediate Calculations Intermediate Calculations

# rows acre-1: N/A mg a.i./1000 ft row: N/A

row length (ft): N/A bandwidth: N/A
85

lb ai/1000 ft row: N/A mg a.i./ft2: N/A

bandwidth (ft): N/A exposed mg a.i./ft2: N/A

mg ai/ft2: N/A

exposed mg ai/ft2: N/A

LD50 ft-2 N/A

wgt class 

(grams)

wgt class 

(grams)

Avian 20 N/A Avian 20 N/A

100 N/A 100 N/A

1000 N/A 1000 N/A

Mammal 15 N/A

Mamma

l 15 N/A

35 N/A 35 N/A

1000 N/A 1000 N/A

Broadcast applications

Granular

Intermediate Calculations

mg ai/ft2: 13641.02

LD50 ft-2

wgt class (grams)

Avian 20 582.60

100 91.53

1000 6.48

Mammal 15 919.49

35 487.04

1000 39.41
86

Appendix H TERRPLANT Input and Output

TerrPlant v. 1.2.2

Green values signify user inputs (Tables 1, 2 and 4). 

Input and output guidance is in popups indicated by red arrows.

Table 1. Chemical Identity.

Chemical Name Sodium Tetraborate Decahydrate

PC code 11002

Use Ornamentals, Fruits, Soybeans, Etc. 

Application Method Ground

Application Form Spray 

Solubility in Water 

(ppm)

55600 (rapidly hydrates to boric acid, this is boric acid 

sol)

Table 2. Input parameters used to derive EECs.

Input Parameter Symbol Value Units

Application Rate A 0.0625 y

Incorporation I 1 none

Runoff Fraction R 0.05 none

Drift Fraction D 0.01 none

Table 3. EECs for Sodium Tetraborate Decahydrate. Units in y.

Description Equation EEC

Runoff to dry areas (A/I)*R 0.003125

Runoff to semi-aquatic areas (A/I)*R*10 0.03125

Spray drift A*D 0.000625

Total for dry areas ((A/I)*R)+(A*D) 0.00375

Total for semi-aquatic areas ((A/I)*R*10)+(A*D) 0.031875

Table 4. Plant survival and growth data used for RQ derivation. Units are in y.

Seedling Emergence Vegetative Vigor

Plant type EC251 NOAEC EC251 NOAEC 

Monocot >5 5 >0.2 0.2

Dicot >5 0.65 >0.2 0.2

1Toxicity values used were non-definitive (>) due to low toxicity and no effects in highest treatment. RQs 

calculated from these (below) are upper-bound values used for screening.

Table 5. RQ values for plants in dry and semi-aquatic areas exposed to Sodium Tetraborate 

Decahydrate through runoff and/or spray drift.*

Plant Type Listed Status Dry Semi-Aquatic Spray Drift

Monocot non-listed <0.1 <0.1 <0.1

Monocot listed <0.1 <0.1 <0.1

Dicot non-listed <0.1 <0.1 <0.1

Dicot listed <0.1 <0.1 <0.1

*If RQ > 1.0, the LOC is exceeded, resulting in potential for risk to that plant group.
87

Appendix I Ecotoxicity of Boric Acid and Sodium Borate 

Salts

There are a number of active ingredients under this Boric Acid and Sodium Borate Salts Case 

(Case). Toxicity data submitted to the Agency to support these active ingredients or available from 

Agency test laboratory files were either expressed in terms of the active ingredients themselves (e.g., 

boric acid, borax, etc.) or in terms of boron. Additionally, toxicity data in the open literature was 

sometimes expressed as the actual test substance (e.g., boric acid, borax, etc.) or in terms of boron. All of 

the active ingredients in this Case form primarily the mononuclear species, undissociated boric acid 

[B(OH)3] and borate ion [B(OH)4

-

], at low aqueous boron concentrations (e.g., <25 mmole B/kg or 270 

mg B/L) with polynuclear borate species forming at higher concentrations (Zeebe et al. 2001). The mode 

of action for each of these active ingredients in non-target organisms is unknown and may be due to the 

undissociated boric acid formed or due to a combination of the mononuclear and polynuclear species 

present. To compare toxicity results and to be able to bridge between these active ingredients, test results 

of all the active ingredients covered in this case need to be expressed in the same units. The Agency has 

selected to express results for use in this assessment in both terms of boric acid equivalents (a.e.) and 

boron equivalents (B). This allows the Agency to use results in those models predicting boric acid 

exposure concentrations and those predicting boron exposure concentrations. Most environmental 

monitoring results (soil, air, water, biological tissues) are measured and reported as B, which 

encompasses all forms of boron present. Also, National Ambient Water Quality Criteria are expressed in 

terms of B. The National Ambient Water Quality Value of 750 μg B/L is for protection of long-term 

irrigation of crops, there are no national criteria for protection of aquatic life15. The States of Illinois and 

Minnesota are working to develop state aquatic life criterion for boron (USEPA, 2010a).

Boron is an essential nutrient for plants, including aquatic plants, in small quantities. There is 

also some evidence that it is essential for some lower and higher order animals including humans (Nielsen 

2008; USEPA 2008). This means if the boron content in soil is too low plants may not thrive or if it is 

too low in water aquatic plants, fish, and invertebrates may not thrive. Nielson (2008) reviewed literature 

on effects of boron deficient conditions for a number of higher level organisms, he noted that deprivation 

of boron in food of adult frogs has been shown to impair reproduction and impair embryogenesis; and that 

zebrafish fed low boron food and exposed to low boron content waters (1.1 μg B/L) embryogenesis was 

impaired. Rowe et al. (1998) observed a U-shape concentration response for trout and zebrafish. 

Toxicity to Aquatic Organisms

There are no data gaps for freshwater fish and invertebrate toxicity data or for aquatic plant 

toxicity data. There is acute toxicity data for nonnative estuarine/marine fish and an invertebrate. There 

is no acute or chronic toxicity data for native estuarine/marine fish, shrimp, or mollusks. Because of the 

qualitative risk assessment approach taken, the data on acute freshwater mollusks, and the information on 

nonnative estuarine/marine shrimp and fish species the lack of this estuarine/marine toxicity data is not 

identified as a data gap for this assessment. The data summarized in this section consists of studies 

submitted by registrants to support boric acid and sodium borate salts; agency conducted studies with 

boric acid or sodium borate salts; and studies from the public literature, identified using ECOTOX, for 

missing taxonomic groups (e.g., estuarine/marine species) or for studies with a more sensitive endpoint 

than in the agency files (e.g., acute toxicity data E118810 for Ceriodaphnia dubia). Appendix J

 

15 http://water.epa.gov/scitech/swguidance/standards/criteria/current/index.cfm accessed 6/23/2015
88

summarizes the results of the ECOTOX literature search that was conducted and the basis for excluding 

and including public literature for this toxicity profile.

a. Aquatic Animals

Aquatic Invertebrates, Acute – Technical Grade Active Ingredient

For the combination of boric acid and sodium borate salts use patterns acute toxicity tests for a 

freshwater aquatic invertebrate, an estuarine/marine mollusk, and an estuarine/marine shrimp species 

using the TGAI (technical-grade active ingredient) are typically required to establish the toxicity of an 

active ingredient to aquatic invertebrates. The preferred test species is Daphnia magna for the freshwater 

invertebrate toxicity test and a species from either the Mysidae or Penaeidae family for the 

estuarine/marine shrimp toxicity test. The acute estuarine/marine mollusk test consists of either a shell 

deposition toxicity test with the Eastern oyster or an embryo/larval toxicity test with Eastern oysters, 

Pacific oysters, Blue mussels, or Quahogs. Toxicity tests using estuarine/marine species were not

identified as data requirements for this assessment due to the assumption that marine organisms are 

adapted to high levels of naturally-occurring boron in seawater (see the problem formulation document, 

USEPA, 2009a).

Results of acute toxicity studies from: studies submitted to the agency to support product 

registrations; agency test data; and results from the ECOTOX literature search with more sensitive values 

or for missing taxonomic groups are tabulated in Table I1 for the boric acid and sodium borate salts case. 

From the ECOTOX literature search two studies were added to the agency’s acute aquatic invertebrate 

profile: data from Dethloff (2009, ECOTOX ID E118810) for a freshwater cladoceran, Ceriodaphnia 

dubia, which was more acutely sensitive than data contained in the agency’s files for freshwater 

invertebrates; and data for the estuarine/marine penaeid taxon (Li, et al., 2008, ECOTOX ID E111738) 

for which the agency had no data. Acute toxicity data for technical grade boric acid is available for two 

freshwater cladocerans or waterfleas (D. magna and C. dubia), three freshwater mollusks (Fatmucket, 

Washboard, and Black sandshell), and an estuarine/marine penaeid shrimp, the whiteleg shrimp 

Litopenaeus vannamei. There was no acute toxicity data specifically with the TGAI for any of the 

sodium borate salts in this case. However, because these other actives are expected to rapidly release 

boric acid upon dissolution in aqueous media and the concentrations tested are below solubility limits 

these boric acid results are considered to be bridgeable for the TGAI of the other active ingredients in this 

case when their concentrations are expressed as either boric acid equivalents or as boron equivalents. 

Since the acute toxicity endpoints (48-h EC50 values for cladocerans, and 96-h LC50 values for other 

aquatic invertebrates) fall in the range 260 to >3169 mg a.e./L (45.5 to >544 mg B/L; Table I1), boric 

acid is classified as practically nontoxic to aquatic invertebrates on an acute basis and slightly toxic to 

practically nontoxic based on B equivalents. The most acutely sensitive freshwater species is C. dubia

with an acute 48-h EC50 of 260 mg a.e./L (45.5 mg B/L); this endpoint is selected for the use in risk 

estimates for this assessment (
89

Table 4.1).

No studies on estuarine/marine species were submitted by registrants and were not required as 

part of the work plan for this case. However, estuarine/marine data was found in the ECOTOX literature 

search and the most acutely toxic result, which was with the nonnative whiteleg shrimp, L. vannamei (Li, 

et al., 2008) was added to the toxicity profile. The estuarine/marine penaeid shrimp data is for a species 

not native to the coastal United States or its territories. However, it is a Pacific species and ranges from 

the Mexican state of Sonora to Peru. Given its taxonomic group, range, habitat and biology16, toxicity 

data for this species is considered representative for native penaeid species. The whiteleg shrimp, L. 

vannamei, was more acutely sensitive to boric acid than freshwater species with a 96-h LC50 of 30.1 mg 

a.e./L (14.0 mg B/L).

Table I1. Acute Aquatic Invertebrate Toxicity Data for Technical Grade Boric Acid and Sodium 

Borate Salts Active Ingredients.

Species, Age 

or size

% 

Purity

Exposure Conditions Acute Endpoints

Toxicity 

Category

Study 

Classification/

Source/

Comments

Exposure Type

pH

Water 

Hardness as mg 

CaCO3/L

Temperature

48-h EC50

or

96-h LC50

(95% CI)

mg a.e./L

48-h EC50

or

96-h LC50

(95% CI)

mg B/L

Probit 

Slope

Freshwater Invertebrate Species

Daphnid

Ceriodaphnia 

dubia

<24 h old

Boric 

Acid

% N.R.

S 8.1 96 20 oC 48-h EC50 = 

260

(193-316)

48-h EC50 = 

45.5

(33.7-55.2)

NR Practically 

non-toxic on 

a.e. basis; 

Slightly toxic 

on B basis

SupplementalQuantitative/ 

ECOTOX ID 

E118810 (Dethloff, 

2009)

N.R. 168 20 oC 48-h EC50 = 

289

(256-324)

48-h EC50 = 

50.6

(44.7-56.7)

NR

Daphnid

C. dubia, <24 h 

old

Boric 

acid 

>99.5%

F 7.77 136 25 +

1

oC

48-h EC50 = 

440

Measured(1)

48-h EC50 = 

76.9

Measured

Practically 

non-toxic on 

a.e. basis; 

Slightly toxic 

on B basis

Acceptable/

EPA, 2010a,b

Water flea 

(Daphnia 

magna), <24 h 

old

Boric 

acid 

Tech%

SR 8.1 

+0.1

148 +7 20 oC 48-h EC50 = 

761

(658-875) 

Nominal(2)

48-h EC50 = 

133

(115-153)

Nominal

NR Practically 

non-toxic on 

both a.e. and 

B basis

SupplementalQuantitative/

Gersich 1984(3)/

Water flea (D. 

magna), <24 h 

old

Boric 

acid 

Analytical 

Grade

S 7.1-

8.7

166 18-21 

oC

48-h EC50 = 

1293

(1144-1407)

Nominal

48-h EC50 = 

226

(200-246)

Nominal

NR Practically 

non-toxic on 

both a.e. and 

B basis

SupplementalQuantitative/

Lewis and 

Valentine 1981(3)/

The no kill 

concentration was 

<200 mg B/L

 

16 Food and Agriculture Organization (FAO) of the United Nations Cultured aquatic species information 

programme: Penaeus vannanmei http://www.fao.org/fishery/culturedspecies/Penaeus_vannamei/en accessed July 

30, 2015.
90

Species, Age 

or size

% 

Purity

Exposure Conditions Acute Endpoints

Toxicity 

Category

Study 

Classification/

Source/

Comments

Exposure Type

pH

Water 

Hardness as mg 

CaCO3/L

Temperature

48-h EC50

or

96-h LC50

(95% CI)

mg a.e./L

48-h EC50

or

96-h LC50

(95% CI)

mg B/L

Probit 

Slope

Water flea (D. 

magna), <24 h 

old

Boric 

acid 

99.9%

S 7.48 180 17 oC 48-h EC50 = 

777

(648-932)

Nominal

48-h EC50 = 

136

(113-163)

Nominal

NR Practically 

non-toxic on 

both a.e. and 

B basis

Acceptable/

U.S. Animal 

Biology

Laboratory, 1982—

TN 2750 

(TN2862)(4)/

Temperature was 

not recorded on 

data sheets, but the 

protocol used called 

for 17 oC

Fatmucket 

clam

(Lampsilis 

siliquoidea), 

<5 day old 

juveniles

Boric 

acid 

99.6%

S 8.0-

8.1

86-90 19.8-

20.2

96-h EC50 = 

784

Measured

96-h EC50 = 

137

Measured

NA Practically 

non-toxic on 

both a.e. and 

B basis

Acceptable/

EPA, 2010a,b/

INHS, Control av 

0.6 mg B/L

Washboard 

mussel

(Megalonaias 

nervosa), <5 

day old 

juveniles

Boric 

acid 

99.6%

S 7.7-

8.2

86-90 20.3-

21.0

96-h LC50

>3169

Measured

96-h LC50

>544

Measured

NA Practically 

non-toxic on 

both a.e. and 

B basis

Acceptable/

EPA, 2010a,b/

INHS, control 

<0.02 mg B/L

Black sandshell 

mussel 

(Ligumia 

recta), <5 day 

old juveniles

Boric 

acid 

99.6%

S 7.9-

8.1

90-92 19.0-

20.5

96-h = 841

Measured

96-h =147

Measured

NA Practically 

non-toxic on 

both a.e. and 

B basis

Acceptable/

EPA, 2010a,b/

Control <0.02 mg 

B/L

Estuarine/Marine Invertebrate Species

Whiteleg 

shrimp,

Litopenaeus 

vannamei

Boric 

Acid

Unkno

wn %

SR 8.3± 

0.2

[Salinity 20.0 

‰]

27.6–

29.1 

°C

96-hr LC50 = 

80.1

96-h LC50 = 

14.0

-- Slightly Toxic

on both a.e. 

and B basis

Supplemental/ 

Quantitative/

ECOTOX ID 

E111738 (Li, et al., 

2008)

a.e.: boric acid equivalent; B: boron equivalent; NR: not reported; NA: not applicable (i.e., probit method not a good fit); S: 

static; SR: static-renewal; TN: test number; NG: non-guideline.

(1) measured: endpoint value(s) based on measured concentrations. Analytical method would measure boron, which would then 

be also considered measured for boric acid equivalents.

(2) nominal: endpoint value(s) based on nominal concentrations.

(3) Per the US EPA Boric Acid/Sodium Metaborate RED (USEPA 1993) these unvalidated public literature studies were 

submitted by registrants to support reregistration but were not assigned MRID numbers at the time of submittal by the Agency. 

The studies were conducted using acceptable protocols albeit the lack of submitted raw data and GLP compliance verification. 

The Agency classified these studies as supplemental data but usable quantitatively.

(4) Study was conducted at the Agency’s Animal Biology Laboratory following Agency test guidance. Raw data is available and 

study is acceptable.

Aquatic Invertebrates, Acute – Boric acid and Sodium Borate Salts Formulations

Toxicity data with typical end-use products are required when it is known or there is concern for 

the potential for an ingredient or ingredients within the formulation to enhance the toxicity of the active 
91

ingredient. Information may also be used for labeling purposes. While no specific concern was 

expressed for enhanced toxicity of boric acid or any of the sodium borate salts, information was available 

from agency laboratory testing and from studies submitted to support registrations. The toxicity data 

from aquatic invertebrate studies using formulations are presented in Table I2. One of the formulated 

products no longer has an active registration nor are there other active end-use products for which it could 

act as a typical end-use product and it is therefore not applicable to this assessment. The wood 

preservative end-use product, Wolsin FL-35, is highly toxic and has a higher toxicity than accounted for 

by boric acid alone (classified as practically nontoxic to D. magna) or in combination with the other two 

active ingredients, fenpropimorph and propiconazole) which are both moderately toxic to D. magna (48-h 

EC50 of 2.38 mg/L and 4.8 mg/L, respectively [MRIDs 45857207 and 00067925, respectively]). This 

indicates there are inert ingredients that add to or enhance the toxicity of the actives in the end-use 

product.

Table I2. Acute Aquatic Invertebrate Toxicity Data for Boric Acid and Sodium Borate Salts Active 

Ingredient Formulations.

Species,

Age or size % Purity

Exposure Conditions Acute Endpoints

Toxicity 

Category of 

Test 

Substance

Study 

Classification/

Source/

Comments

Exposure Type

pH

Water 

Hardness as mg 

CaCO3/L

Temperature

x-h IC50

(95% CI)

mg t.s./L

x-h IC50

(95% CI)

mg a.e./L(1)

x-h IC50

(95% CI)

mg B/L(2)

Freshwater Invertebrate Species

Water flea (D. 

magna), <24 h 

old

Prev-Am Ultra(3)

Disodium 

tetraborate 

decahydrate

0.99%

S 7.4 

+0.5

122 20.2 

oC

48-h EC50 = 

22.3

(18.8-26.3)

NOAEC = 

9.33

Nominal

48-h EC50 = 

0.143

(0.121 –

0.169)

NOAEC = 

0.060

48-h EC50 = 

0.0250

(0.0211 –

0.0295)

NOAEC = 

0.0105

Slightly 

Toxic

/

MRID 

46955801/

Water flea (D. 

magna), <24 h 

old

Wolsin FL-35(4)

Boric acid

9.00%

S 8.0 250 21.0 

oC

48-h EC50 = 

0.30

(0.26-0.36)

Nominal

48-h EC50 = 

0.027

(0.023 –

0.032)

48-h EC50 = 

0.0047

(0.0040 –

0.0056)

Highly 

Toxic

Acceptable/

46074204

Water flea (D. 

magna)

Grotan HD II(5)

Sodium tetraborate 

decahydrate 

(Borax)

41%

S -- -- -- 48-h EC50 = 

22.8

(21.3-24.4)

Nominal

End-use product is no 

longer registered

Slightly 

toxic

Acceptable/

MRID 

00060199/

a.e.: boric acid equivalent; B: boron equivalent; NA: not applicable (i.e., probit method not a good fit); S: static; TN: test number

(1) This conversion assumes all the toxicity is attributable to the equivalents of boric acid in the formulation. Comparison of 

toxicity in terms of the actives and toxicity data based on each technical grade active ingredient in the test substance is needed

to determine if the toxicity of boric acid was enhanced.

(2) This conversion assumes all the toxicity is attributable to total boron in the formulation. Comparison of toxicity in terms of the 

actives and toxicity data based on each technical grade active ingredient in the test substance is needed to determine if the 

toxicity of boron was enhanced.

(3) EPA Reg #72662-3, sodium tetraborate decahydrate 0.99%; 99.01% inert ingredients -- Foliar treatment for a number of crops.

(4) EPA Reg # 71406-4, manufactured by Dr. Wolman GMBH—wood preservative uses. Fenpropimorph 5.41%; propiconazole 

2.70%; boric acid 9.00%; inert ingredients 82.9%

(5) EPA Reg # 10000-3, manufactured by Hellemite Lehn & Fink Products Company. Sodium tetraborate decahydrate (Borax) 

41%; potassium iodide 0.39%; 2-chloro-N-(hydroxymethyl)acetamide 39%; inert ingredients 19.61%.

Aquatic Invertebrates, Chronic – Technical Grade Active Ingredient
92

A chronic freshwater invertebrate study with the TGAI is required to support the combined use 

patterns. The preferred freshwater species is the most sensitive of the acute freshwater invertebrates 

tested with boric acid or the sodium borate salts, when this is not achievable a chronic test for a species 

for which there is acute data, conducted under the same environmental conditions is required to allow for 

calculation of an acute-to-chronic ratio (ACR) for use in estimating the chronic value for the most 

sensitive species. Boric acid toxicity data for one freshwater species, D. magna, from three studies 

submitted by registrants are summarized in Table I3. No data for the most acutely sensitive freshwater 

species. C. daphnia (Table I1) was submitted or found in the ECOTOX literature search. The NOAEC 

for D. magna ranged from 34 to 57 mg a.e./L (6.0 to 10 mg B/L; Table I3). Two of the literature studies 

in addition to conducting chronic 21 day studies with D. magna also conducted concurrent acute tests for 

D. magna which provides more accurate ACRs, these are listed in Table I4. Using the most sensitive 

Ceriodaphnia dubia acute data from Table I1, along with the mean ACR from the D. magna data (see 

Table I3), a NOAEC for the more acute sensitive C. dubia species was estimated to be 8.9 mg a.e./L (1.6 

mg B/L)17. There was no acute toxicity data specifically with the TGAI of any of the sodium borate salts 

in this case. However, because these other actives are expected to rapidly release boric acid upon 

dissolution in aqueous media and the concentrations tested are below solubility limits these boric acid 

results are considered to be bridgeable for the TGAI of the other active ingredients in this case when their 

concentrations are expressed as either boric acid equivalents or as boron equivalents.

Table I3. Chronic Aquatic Invertebrate Toxicity Data for Technical Grade Boric Acid and Sodium 

Borate Salts Active Ingredients.

Species, 

Age or size

% 

Purity

Exposure Conditions Chronic Endpoint

Study Classification/

Source/

Comments

Exposure 

Type

pH

Water 

Hardness as 

mg CaCO3/L

Temperature

NOAEC /

LOAEC

mg a.e./L

NOAEC /

LOAEC

mg B/L

Freshwater Invertebrate Species

Water flea (D. 

magna), 1st

instar

Boric acid 

99.9%

SR 7.2 –

8.0

212 19.3 –

20.9 oC

21-d

57 / 103

21-d

10 / 18

Measured

Supplemental/

MRID 48507004/

Most sensitive endpoint was number of 

young produced per surviving female; 

adult survival was significantly 

reduced @ 320 mg a.e./L (56 mg B/L)

Time to first brood release and growth 

of young were not assessed in the 

study.

Water flea (D. 

magna), 

neonates

Boric acid 

Analytical

Grade

SR 7.1-

8.7

166 

(135-

217)

18-

21 oC

21-d

34 / 74(4)

21-d

6.0 / 13(4)

Measured

Supplemental-Quantitative/

Lewis and Valentine 1981(3)/

Most sensitive endpoint was brood size 

and total number of young produced.

 

17 NOEC = Acute endpoint/ACR = (45.5 mg B/L)/29.2 = 1.56 mg B/L
93

Species, 

Age or size

% 

Purity

Exposure Conditions Chronic Endpoint

Study Classification/

Source/

Comments

Exposure 

Type

pH

Water 

Hardness as 

mg CaCO3/L

Temperature

NOAEC /

LOAEC

mg a.e./L

NOAEC /

LOAEC

mg B/L

Water flea (D. 

magna), <24 hr 

old

Boric acid 

Tech Grade

SR 8.1 

+0.1

148 +7 19.5 –

20.5 oC

21-d

37 / 77.8

21-d

6.4 / 13.6

Measured

Supplemental-Quantitative/

Gersich 1984(3)/

Sensitive measurement endpoints 

included: mean number of broods per 

daphnid, mean total young per daphnid, 

mean brood size per daphnid and mean 

size (length)

No adults survived to reproductive age 

in the highest treatment concentration 

(105 mg B/L) but was significantly 

reduced at 59.3 mg B/L

Time to first reproduction was not 

affected at or below 59.3 mg B/L.

Estuarine/marine Invertebrate Species

---------------------------------------------- No data available ----------------------------------------------

a.e.: boric acid equivalent; B: boron equivalent; N.A.: not applicable (i.e., probit method not a good fit); S: static; SR: staticrenewal; TN: test number

(1) measured: endpoint value(s) based on measured concentrations. Analytical method would measure boron, which would then 

be also considered measured for boric acid equivalents.

(2) nominal: endpoint value(s) based on nominal concentrations.

(3) Per the US EPA Boric Acid/Sodium Metaborate RED (USEPA 1993) these unvalidated literature studies were submitted by 

registrants to support reregistration but were not assigned MRID numbers at the time of submittal by the Agency. The studies

were conducted using acceptable protocols albeit the lack of submitted raw data and GLP compliance verification. The 

Agency classified these studies as supplemental data but usable quantitatively.

(4) Corrected for 0.17 mg B/L in the dilution water.

Table I4. Freshwater Invertebrate Acute-to-Chronic Ratio (ACR) Values for Boron Data.

Test Species

Source Acute Endpoint Chronic Endpoint Acute-to-chronic ratio (ACR)

D. magna

Lewis and Valentine 1981 226 mg B/L 6.0 mg B/L 37.7

D. magna

Gersich 1992 133 mg B/L 6.4 mg B/L 20.8

Mean 29.2

Chronic estuarine/marine invertebrate data was not required as part of the work plan for boric 

acid and sodium borate salts case. No data was found in the ECOTOX literature search. The use of the 

freshwater invertebrate ACR is not appropriate for boric acid and sodium borate salts. There are 

differences in how freshwater and saltwater species osmoregulate, in addition to other differences that can 

sometimes result in differences in ACRs between freshwater and saltwater invertebrates and this is likely 

the case for boric acid and sodium borate salts. Use of the mean freshwater invertebrate ACR of 29.2 

(Table I4) with the acute value for the whiteleg shrimp (Table I1) results in an erroneous chronic NOEC 

estimate of 0.47 mg B/L—this value is over 10 times below the background boron level for seawater of 
94

5.0 mg B/L. The lack of an estuarine/marine invertebrate chronic value is not considered a data gap at 

this time based on the risk assessment approach taken.

Fish, Acute – Technical Grade Active Ingredient Purity

For the combination of boric acid and sodium borate salts use patterns acute toxicity tests for two 

freshwater fish species, one a cold water species and one a warm water species, and an estuarine/marine 

species using the TGAI (technical-grade active ingredient) are typically required to establish the toxicity 

of an active ingredient to freshwater and estuarine/marine fish. The preferred test species are the rainbow 

trout (Oncorhynchus mykiss) for the coldwater species, the bluegill sunfish (Lepomis macrochirus) for the 

warmwater species, and one of three silverside species (Menidia sp.) for the estuarine/marine fish. 

Toxicity tests using estuarine/marine species were not identified as data requirements for this assessment 

due to the assumption that marine organisms are adapted to high levels of naturally-occurring boron in 

seawater (see the problem formulation document, USEPA, 2009a).

Results of acute toxicity studies from: studies submitted to the agency to support product 

registrations; agency test data; and results from the ECOTOX literature search with more sensitive values 

or for missing taxonomic groups are tabulated in Table I5 for the boric acid and sodium borate salts case. 

From the ECOTOX literature search two studies were added to the agency’s acute fish profile: data from 

Rowe (1998, ECOTOX ID E105984) for the zebrafish, Danio rerio, which appeared initially to be more 

sensitive than data contained in the agency’s files for freshwater fish; and data for estuarine/marine fish 

(Furuta et al., 2007: ECOTOX ID E166696) for which the agency had no data. Acute toxicity data for 

technical grade boric acid is available for three warmwater species (Fathead minnow, Bluegill sunfish, 

and the Zebrafish), one coldwater species (rainbow trout), and two estuarine/marine species (Red sea 

bream and Japanese flounder). There was no acute toxicity data specifically with the TGAI for any of the 

sodium borate salts in this case. However, because these other actives are expected to rapidly release 

boric acid upon dissolution in aqueous media and the concentrations tested are below solubility limits 

these boric acid results are considered to be bridgeable for the TGAI of the other active ingredients in this 

case when their concentrations are expressed as either boric acid equivalents or as boron equivalents.

For freshwater fish species, the 96-h LC50 for boric acid ranged from 404 mg a.e./L to > 1100 mg 

a.e./L (70.6 mg B/L to > 192 mg B/L) (Table I5); boric acid is classified as practically non-toxic to 

freshwater fish on an acute basis and slightly toxic to practically nontoxic based on B equivalents. The 

zebrafish is not native to the United States or its territories. The data included for this species in the table 

was found to be a greater than value and therefore the 96-h LC50 for this species is unknown. Other data 

within the acute fish profile have either definitive values or were tested to at least the OCSPP guideline 

standard of >100 mg a.i./L for a limit test for this soluble of a compound. This information was therefore 

not included in the toxicity range.

No studies on estuarine/marine species were submitted by registrants and were not required as 

part of the work plan for this case. However, estuarine/marine fish acute data was found in the ECOTOX 

literature search and data for the two most sensitive species (Red sea bream and Japanese flounder) were 

reviewed and added to the profile. Both the Red sea bream (Pagrus major) and Japanese flounder 

(Paralichthys olivaceus) are not native species to the United States. The Red sea bream is distributed in 

the northwest Pacific from the east coast of China, Taiwan, and southern Japan to Indonesia and the 

Philippines. The Japanese flounder has a similar but more limited range as that of the Red sea bream. 

Both species have similar counterparts that occur in the coastal waters of the United States and its 

territories with similar habitat and biology, therefore toxicity data for these species is considered 

representative for native estuarine/marine fish species. These sensitive saltwater species with 96-h LC50

values ranging from 555 to 618 mg a.e./L (97 to 108 mg B/L) had similar sensitivity to that of the most 

sensitive freshwater fish species (Table I5).
95

Table I5. Acute Fish Toxicity Data for Technical Grade Boric Acid and Sodium Borate Salts Active 

Ingredients.

Species, 

Age or size % Purity

Exposure Conditions Endpoint

Toxicity 

Category

Study 

Classification/

Source/

Comments

Exposure Type

pH

Water Hardness as 

mg CaCO3/L

Temperature

96-h LC50

(95% CI)

mg a.e./L

96-h LC50

(95% CI)

mg B/L

Probit 

Slope

Freshwater Species

Fathead minnow

(P. promelas)

Boric acid 

99.9%

6.75

7.75

8.75

-- -- 404

784

761

70.6

137

133

Slightly 

toxic on B 

basis and 

Practically 

non-toxic 

on a.e. 

basis

Acceptable/

EPA, 2010a,b/

Fathead minnow

(Pimephales 

promelas), 0.12 

g, 19.8 mm

Boric acid 

99.9%

S 7.54-

8.18

132-

168

24.6-

25.1

578 101

Measured

Practically 

non-toxic 

on both a.e. 

and B basis

Acceptable/

EPA, 2010a,b/

GLEC,

Bluegill sunfish 

(Lepomis 

macrochirus), 

Average 0.77 g, 

TL 40 mm

Boric acid 

100%

S 7.4 52 20.5

+0.5 

oC

1021

(907-1310)

178

(158-229)

Measured(1)

NA Practically 

non-toxic 

on both a.e. 

and B basis

Acceptable/

MRID 

40594602/

Rainbow trout 

(Oncorhynchus 

mykiss), 1.06 g

Boric acid 

100%

S 7.2 52 12.5

+0.5 

oC

>1100

0% mortality 

(0/20 fish)

>192

Measured

NA Practically 

non-toxic

on both a.e. 

and B basis

Acceptable/

MRID 

40594601/

Rainbow trout 

(O. mykiss), 

Average 2.32 g, 

58.6 mm

Boric acid 

99.9%

S 7.7 36 9 oC >800

0% mortality 

(0/10 fish)

Nominal(2)

>140 NA Practically 

non-toxic 

on both a.e. 

and B basis

Supplemental/

Nolen, 1982 TN 

2751 (TN 

2860)/

Zebrafish

Danio rerio

Embryo to larval 

stage

Boric Acid

99.5%

SR 7.2-

7.4

0-200 12.5°C >74.4

(96-h mortality 

NOAEC >

74.4)

>13.0

(96-h 

mortality 

NOAEC >

13.0)

NR At most 

Slightly 

toxic on 

both a.e. 

and B 

basis.

Supplemental/ 

Quantitative/

ECOTOX ID 

E105984: 

Rowe, 1998

Does not meet 

standard for a 

limit test by 

OCSPP 

guidelines.
96

Species, 

Age or size % Purity

Exposure Conditions Endpoint

Toxicity 

Category

Study 

Classification/

Source/

Comments

Exposure Type

pH

Water Hardness as 

mg CaCO3/L

Temperature

96-h LC50

(95% CI)

mg a.e./L

96-h LC50

(95% CI)

mg B/L

Probit 

Slope

Estuarine/Marine Species

Red sea bream, 

Pagrus major

0.4g (tested up to 

20.3g, but lowest 

wt. most 

sensitive)

Boric Acid 

Unknown 

%

SS 8.1-

8.2

[salinity 

35‰]

25°C 555 97

Measured(1)

5.2 Slightly 

toxic on B 

basis and 

Practically 

non-toxic 

on a.e. 

basis

Supplemental/ 

Quantitative/

ECOTOX ID 

E166696: 

Furuta, et al., 

2007

Japanese flounder

Paralichthys 

olivaceus

0.05g (tested up 

to 70g, but lowest 

wt. most 

sensitive)

Boric Acid 

Unknown 

%

SS 8.1-

8.2

[salinity 35 

‰]

20°C 618 108

Measured(1)

12.65 Slightly 

toxic on B 

basis and 

Practically 

non-toxic 

on a.e. 

basis

Supplemental/ 

Quantitative/

ECOTOX ID 

E166696: 

Furuta, et al., 

2007

‰: parts per thousand; a.e.: boric acid equivalent; B: boron equivalent; NA: not applicable (i.e., probit method not a good fit); 

NR: not reported; S: static; SS: semi-static; TN: test number

(1) measured: endpoint value(s) based on measured concentrations.

(2) nominal: endpoint value(s) based on nominal concentrations.

Fish, Acute – Boric acid and Sodium Borate Salts Formulations

Toxicity data with typical end-use products (TEPs) are required when it is known or there is 

concern for the potential for an ingredient or ingredients within the formulation to enhance the toxicity of 

the active ingredient. Information may also be used for labeling purposes. While no specific concern was 

expressed for enhanced toxicity of boric acid or any of the sodium borate salts, information was available 

from agency laboratory testing and from studies submitted to support registrations. The toxicity data 

from acute fish studies using formulations are presented in Table I7. A number of studies conducted 

with formulations are not applicable to this assessment because they are no longer registered and also do 

not have an active end-use product for which they could act as a typical end-use product. The end-use 

product New Improved Ureabor was cancelled but there are active end-use products for which it a 

representative typical end-use product formulation result. No adequate studies using a TEP were 

available to assess adjuvant effects. The only acceptable study (MRID 46074203) used a product 

containing 9% boric acid, 5.4% fenpropimorph, and 2.7% propiconazole 2.7%; this product was several 

orders of magnitude more toxic than technical boric acid alone to rainbow trout (practically nontoxic). It 

also has a higher toxicity than accounted for by boric acid in combination with the other two active 

ingredients, fenpropimorph and propiconazole which are both moderately toxic to rainbow trout (96-h 

LC50 of 3.46 mg/L and 0.85 mg/L, respectively [MRIDs 45857206 and 00067923, respectively]). This 

indicates there are inert ingredients that add to or enhance the toxicity of the actives in the end-use 

product. 
97

Table I7. Acute Fish Toxicity Data for Boric Acid and Sodium Borate Salts Active Ingredient 

Formulations.

Species, Age or 

size

Test 

Substance

% Purity

Exposure Conditions Endpoint

Toxicity 

Category of 

Test 

Substance

Study 

Classification/

Source/

Comments

Exposure Type

pH

Water 

Hardness as 

mg CaCO3/L Temperature

96-h LC50

(95% CI)

mg t.s./L

96-h LC50

(95% CI)

mg a.e./L(1)

96-h LC50

(95% CI)

mg B/L(2)

Rainbow trout 

(Oncorhynchus 

mykiss), 1.01 +

0.34 g, 4.68 +

0.55 cm

Wolsin FL-35

(Sinesto PFB

(3)

)

Boric acid 9%

SR 7.6-

8.1

250 15-

16 

oC

0.63

(0.38-2.0)

Measured

0.069

(0.040-0.092)

Nominal

0.012

(0.007-

0.016)

Nominal

Highly toxic Acceptable/

MRID 46074203

Test was conducted 

at 1-2 oC higher 

than standard 

guidance

Rainbow trout 

(O. mykiss), 

Average 2.32 g, 

58.6 mm

Perma-Dust

PT 240(4)

Boric acid 

20%

S 8.3 36 9.0 

oC

<100

100% mortality 

(10/10 fish)

Nominal

<20.0 <3.50 Insufficient 

information

Supplemental/

Nolen, 1982—TN 

2749 (TN2861)/ 

10% mortality @ 

25 ppm t.s.

Rainbow trout 

(O. mykiss), 

Average 0.5998 

g, 39.7 mm

New 

Improved 

Ureabor(5)

Sodium 

metaborate 

tetrahydrate 

66.5%

S 7.0 51.3 12.8 

oC

(55 

oF)

>180

10% mortality 

(1/10 fish)

Nominal

>112 >20 Practically 

nontoxic

Supplemental/

MRID 24964 

(McCann, 1972—

TN 0457)/

Rainbow trout 

(O. mykiss)

Prev-Am

Ultra(6)

Disodium 

tetraborate 

decahydrate 

0.99%

S 7.4 

+1

122 15.4 

oC

47.9

(40.8-56.1)

NOAEC = 15.6

Nominal

0.308

(0.262 –

0.360)

NOAEC = 

0.100

0.0538

(0.0458 –

0.0630)

NOAEC = 

0.0175

Slightly 

toxic

/

MRID 46955801/

Bluegill sunfish 

(L. 

macrochirus), 

Average 0.62 g, 

34.6 mm

New 

Improved 

Ureabor(5)

Sodium 

metaborate 

tetrahydrate 

66.5%

S 7.0 51.3 18.3 

oC

(65 

oF)

>100 ppm

0% mortality 

(0/10 fish)

Nominal

>62.5 >10.9 Practically 

nontoxic

Supplemental/

MRID 24967 

(McCann, 1972 TN 

0447)/

Zebra fish, NR Protectol CX 

Type A 

[Wolmanit 

CX-LP 

15172]

(7)

Boric acid 5%

S 8.0 

–

8.3

250 20 

oC

0.90

(0.56 – 1.8)

NOAEC = 

0.56

0.045

(0.028 – 0.09)

NOAEC = 

0.028

0.0079

(0.0049 –

0.0157)

NOAEC = 

0.0049

Highly 

toxic

Acceptable/

47069401 & 

47069404

Rainbow trout 

(O. mykiss), 

Average 0.60 g, 

39.7 mm

Steri-Soil(8) S 7.0 51.3 12.8 

oC

(55 

oF)

>180

0% mortality 

(0/10 fish)

Nominal

End-use product is no 

longer registered

Practically 

nontoxic

Supplemental/

MRID 00090307 

(McCann, 1972—

TN 0456)/
98

Species, Age or 

size

Test 

Substance

% Purity

Exposure Conditions Endpoint

Toxicity 

Category of 

Test 

Substance

Study 

Classification/

Source/

Comments

Exposure Type

pH

Water 

Hardness as 

mg CaCO3/L Temperature

96-h LC50

(95% CI)

mg t.s./L

96-h LC50

(95% CI)

mg a.e./L

(1)

96-h LC50

(95% CI)

mg B/L(2)

Rainbow trout 

(O. mykiss), 

Average 0.62 g, 

40.3 mm

Riverside 

Weedgard 

G(9)

Sodium 

metaborate 

tetrahydrate 

66.5%

S 7.0 51.3 12 

oC

>180

30% mortality 

(3/10 fish)

Nominal

End-use product is no 

longer registered

Practically 

nontoxic

Supplemental/

MRID 24967 

(McCann, 1974—

TN 0773)/

Rainbow trout 

(O. mykiss)

Grotan HD 

II(10)

Sodium 

tetraborate 

decahydrate 

(Borax)

41%

S -- -- -- 134

(127-141)

Nominal

End-use product is no 

longer registered

Practically 

nontoxic

Acceptable/

MRID 00067968/

Rainbow trout 

(O. mykiss), 

Average 1.519 g, 

51.8 mm

Permatox 100 

Liquid 

Fungicide 

Concentrate(11

)

Sodium 

metaborate 

octahydrate 

13.66%

S 7.0 51.3 12.8 

oC

(55 

oF)

48-h LC50 = 

0.47

(0.43-0.51)

End-use product is no 

longer registered

Highly 

toxic

Supplemental/

MRID 74975 

(McCann, 1970—

TN 0267/

No control data

Rainbow trout 

(O. mykiss);

Mean 0.75 g, 42 

mm

Permatox 100 

Liquid 

Fungicide 

Concentrate(11

)

Sodium 

metaborate 

octahydrate 

13.66%

S 6.7 

–

7.3

-- 13 

oC

+

0.5 

oC

0.15

(0.11-0.21)

End-use product is no 

longer registered

Highly 

toxic

/

MRID 110816/

Trout succumbing 

to the test material 

exhibited 

darkening of 

coloration, 

hyperactivity, loss 

of equilibrium, and 

then settling to the 

bottom.

Bluegill sunfish 

(L. 

macrochirus), 

Average 0.58 g, 

34.5 mm

Steri-Soil(8) S 7.0 41.04 18.3 

oC 

(65 

oF)

>100

0% mortality 

(0/10 fish)

Nominal

End-use product is no 

longer registered

Practically 

nontoxic

Supplemental/

MRID 00090308 

(McCann, 1972—

TN 0444)/

Bluegill sunfish 

(L. 

macrochirus), 

Average 0.883 g, 

40.85 mm

Riverside 

Weedgard 

G(9)

Sodium 

metaborate 

tetrahydrate 

66.5%

S 7.0 51.3 18.3 

oC

(65 

oF)

>180

10% mortality

(1/10 fish)

Nominal

End-use product is no 

longer registered

Practically 

nontoxic

Supplemental/

McCann, 1973—

TN 0643/

Bluegill sunfish 

(L. macrochirus)

Grotan HD 

II(10)

Sodium 

tetraborate 

decahydrate 

41%

S 280

(259-301)

Nominal

End-use product is no 

longer registered

Practically 

nontoxic

Acceptable/

MRID 00067968/
99

Species, Age or 

size

Test 

Substance

% Purity

Exposure Conditions Endpoint

Toxicity 

Category of 

Test 

Substance

Study 

Classification/

Source/

Comments

Exposure Type

pH

Water 

Hardness as 

mg CaCO3/L Temperature

96-h LC50

(95% CI)

mg t.s./L

96-h LC50

(95% CI)

mg a.e./L

(1)

96-h LC50

(95% CI)

mg B/L(2)

Bluegill sunfish 

(L. 

macrochirus);

Mean 1.2 g, 42 

mm

Permatox 100 

Liquid 

Fungicide 

Concentrate(8)

Sodium 

metaborate 

octahydrate 

13.66%

S 6.8 

–

7.3

-- 18 

oC 

+

0.5 

oC

0.33

(0.23 – 0.45)

End-use product is no 

longer registered

Highly 

toxic

/

MRID 110816/

Bluegill 

succumbing to the 

test material 

exhibited 

darkening of 

coloration, erratic 

swimming and 

hyperactivity, loss 

of equilibrium, and 

then settling to the 

bottom.

Fathead minnow 

(P. promelas), 

Average 1.581 g, 

56.85 mm

Permatox 100 

Liquid 

Fungicide 

Concentrate(11

)

Sodium 

metaborate 

octahydrate 

13.66%

S 7.0 51.3 18.3 

oC

(65 

oF)

-- End-use product is no 

longer registered

-- Unacceptable/

MRID 107146 

(McCann, 1971—

TN 0381/

No control data

a.e.: boric acid equivalent; B: boron equivalent; N.A.: not applicable (i.e., probit method not a good fit); S: static; TN: test 

number

(1) This conversion assumes all the toxicity is attributable to the equivalents of boric acid in the formulation. Comparison of 

toxicity in terms of the actives and toxicity data based on each technical grade active ingredient in the test substance is needed 

to determine if the toxicity of boric acid was enhanced.

(2) This conversion assumes all the toxicity is attributable to total boron in the formulation. Comparison of toxicity in terms of the 

actives and toxicity data based on each technical grade active ingredient in the test substance is needed to determine if the

toxicity of boron was enhanced.

(3) EPA Reg # 71406-4 manufactured by BASF Wolman GMBH, wood preservative uses—Boric acid 9%; fenpropimorph 5.4%; 

propiconazole 2.7%; inert ingredients 82.9% 

(4) EPA Reg # 499-220, Boric acid 20%; and inert ingredients 80% this specific end-use product is no longer active but it is 

typical for another active end-use product Perma-Dust PT 240 (EPA Reg # 499-384) that contains 35.5% boric acid and 64.55 

inert ingredients (Use sites are nonfood/nonfeed residential, commercial, institutional, industrial food processing plants, and 

transportation premises).

(5) USDA Reg # 97428, 1624-90, manufactured by U.S. Borax and Chemical Corporation Sodium metaborate tetrahydrate 66.5% 

(Boron Trioxide equivalent 22.6%); sodium chlorate 30.0%; bromacil 1.5%; inert ingredients 2.0%. While this specific enduse product is not active it is a typical end-use product for Ureabor (alternate names Barespot Ureabor or Bareground Ultra) 

(EPA Reg # 33560-47 which contains less sodium metaborate tetrahydrate (49.0%). (Soil and foliar treatment noncrop areas 

such as drainage areas, vacant fields, roadways, rights-of-way, industrial, commercial, and institutional grounds and area etc.).

(6) EPA Reg #72662-3, sodium tetraborate decahydrate 0.99%; 99.01% inert ingredients. (Foliar treatment for a number of crops.)

(7) EPA Reg #71406-2, copper carbonate, basic 16.3%; bis-(N-Cyclohexyldiazeniumdioxy)-copper) 3.5%; boric acid 5%; and 

75.2% inert ingredients.

(8) USDA Reg # 5-1. Manufactured by Empire Laboratories, Atlanta, Georgia—77% sodium chlorate and sodium borate (sodium 

tetraborate decahydrate); 23% inert ingredients. 

(9) EPA Reg. # 9779-209 Manufactured by Riverside Chemical Company, Memphis, Tennessee. Sodium metaborate tetrahydrate 

66.5% (Boron Trioxide equivalent 22.6%); sodium chlorate 30.0%; bromacil 1.5%; inert ingredients 2.0%.

(10) EPA Reg # 10000-3, manufactured by Hellemite Lehn & Fink Products Company. Sodium tetraborate decahydrate (Borax) 

41%; potassium iodide 0.39%; 2-chloro-N-(hydroxymethyl)acetamide 39%; inert ingredients 19.61%. (Transferred to EPA 

Reg #365-77).
100

(11) USDA Reg #1022-354, manufactured by Chapman Chemical Company. As reported in the studies the active ingredient and 

inert ingredient contents of this formulation were: sodium tetrachlorophenate 16.40%; sodium salts other chlorinate phenols 

4.43%; sodium metaborate octahydrate 13.66%; phenylmercuric lactate 0.40; and inert ingredients 65.11%.

(12) EPA Reg #83933-1, sodium fluoride 22.5%; boric acid 40.8%; and 36.7% inert ingredients.

Fish, Chronic

A chronic fish study with the TGAI is required to support the combined use patterns. The 

preferred species is the most sensitive of the acute freshwater or estuarine/marine fish species tested with 

boric acid or the sodium borate salts, when this is not achievable a chronic test for a species for which 

there is acute data, conducted under the same environmental conditions is required to allow for 

calculation of an acute-to-chronic ratio (ACR) for use in estimating the chronic value for the most 

sensitive species. The most acutely sensitive freshwater fish species was the fathead minnow with 96-hr 

LC50 values ranging from 70.6 mg B/L to 137 mg B/L (Table I6). The acute sensitivity of the two 

estuarine/marine fish species were within this same range, 97-108 mg B/L. There was an acceptable fish 

early life study with the most sensitive freshwater species, the fathead minnow, and the results are 

summarized in Table I8. The NOAEC for the fathead minnow was found to be 42 mg a.e./L (7.4 mg 

B/L; MRID 43914601) based on total length (Table I9).

The results of the D. magna life cycle data indicates that boron is potentially a reproductive 

toxicant for aquatic animals (most sensitive endpoints are brood size and number of young produced for 

D. magna). Therefore, there is some uncertainty in the use of just a fish early life stage test to assess 

chronic risk as it does not specifically measure effects on reproductive endpoints and may result in 

underestimation of chronic risk to fish. Boron is also a reproductive toxicant in mammals.

Table I8. Chronic Fish Toxicity Data for Technical Grade Boric Acid and Sodium Borate Salts 

Active Ingredients.

Species, 

Age or size

% 

Purity

Exposure 

Conditions Endpoint

Study Classification/

Source/

Comments

Exposure Type

pH

Water Hardness 

as mg CaCO3/L

Temperature

NOAEC /

LOAEC

mg a.e./L

NOAEC /

LOAEC

mg B/L

Fathead minnow 

(Pimephales 

promelas), 7 

hour postfertilized eggs

Boric 

acid 

99.7%

F 6.5 

-7.8

60 -

76

24 –

25 oC

32-d

42 / 

74

Measured(1)

32-d

7.4 /

13

Acceptable/

MRID 48914601(2) /

Most sensitive endpoint 

was total length; posthatch survival and dry 

weight was significantly 

reduced @ 140 mg a.e./L 

(28 mg B/L)
101

Species, 

Age or size

% 

Purity

Exposure 

Conditions Endpoint

Study Classification/

Source/

Comments

Exposure Type

pH

Water Hardness 

as mg CaCO3/L

Temperature

NOAEC /

LOAEC

mg a.e./L

NOAEC /

LOAEC

mg B/L

Fathead minnow 

(P. promelas), 

<24 h old 

fertilized 

embryos

Boric 

acid 

99.7%

F -- -- -- -- -- Unacceptable/

EPA, 2010a,b/

Control mortality 

exceeded acceptable 

levels, and was attributed 

to handling issues and 

two of the control 

replicates were not 

included in the statistical 

analysis. If there were 

handling issues with the 

controls, effects in other 

treatments may also be 

impacted and not 

separable from treatment 

related impacts. Source 

of water was 

dechlorinated (carbon 

filtered) Traverse, MI tap 

water, GLEC, 60-90% 

control mortality in 2 

replicates

a.e.: boric acid equivalent; B: boron equivalent; F: flowthrough; N.A.: not applicable (i.e., probit method not appropriate in this 

case)

(1) measured: endpoint value(s) based on measured concentrations. 

(2) Note: 48914601 is a fish early life stage test. D. magna life cycle data indicates that boron is potentially a reproductive 

toxicant for aquatic animals (most sensitive endpoints are brood size and number of young produced). In avian reproduction 

study there was no effect on number of eggs laid per pair. The most sensitive endpoints were number of hatchlings per eggs set, 

and number of 14 d hatchlings per eggs set. Use of fish early life stage test may underestimate risks to fish. 

 

Other Aquatic Animal Data

A study on boric acid toxicity to toad eggs (Takeuchi, 1958, Acc. 05015376) was submitted but 

not useable due to insufficient information, including missing pages, lack of supporting data and lack of 

information on controls. Two studies using tadpoles were submitted but not determined to be useable. In 

one (Ziof and Stephen, 1949, Acc. 05018639), solutions of various sugar alcohols (e.g., mannitol) were 

prepared with an unknown quantity of boric acid. Authors determined that tadpoles died more rapidly in

those solutions with the greater number of hydrogen ions but the submission contained insufficient 

information (including not providing the number of tadpoles involved). In the other (Du Bois, et al., 

1957, Acc. 05019853) the effect of boric acid solutions on the regeneration of amputated tadpole tails was 

studied. This study was determined to lack pertinence to regulatory assessments. 

A submitted study (Linden, et al., 1979, Acc. 05020076) using a brackish water fish, the bleak 

(Alburnus alburnus), and a crustacean, the harpacticoid (Nitocra spinipes) received an abbreviated review 
102

because it contained insufficient information and was done with a formulation that contained an 

additional active ingredient. 

Table I6. Other Fish Toxicity Information for Technical Grade Boric Acid and Sodium Borate Salts 

Active Ingredients.

Species, 

Age or size % Purity

Exposure Conditions Endpoint

Toxicity 

Category

Study 

Classification/

Source/

Comments

Exposure Type

pH

Water Hardness as 

mg CaCO3/L

Temperature

96-h LC50

(95% CI)

mg a.e./L

96-h LC50

(95% CI)

mg B/L

Probit 

Slope

Freshwater Species

Zebrafish

D. rerio

Age/Size N.R.

N.R. N.R. N.R. N.R. N.R. Developmental 

EC50(1) = 0.656

Development

al EC50(3) = 

3.75

N.R. N.A. Supplemental/ 

Qualitative/

ECOTOX ID 

E161191/

Padilla, 2011

‰: parts per thousand; a.e.: boric acid equivalent; B: boron equivalent; N.A.: not applicable (i.e., probit method not a good fit);

N.R.: not reported; S: static; SS: semi-static; TN: test number

(1) This is not an LC50 but a type of EC50 (median effects concentration) that authors refer to as a developmental effect index, a 

half-maximal activity concentration (AC50). 

a. Aquatic Plants

Testing with Technical Grade Active Ingredient

For the combination of boric acid and sodium borate salts use patterns toxicity tests using 

technical grade active ingredient for four species of algae (a green algae, a freshwater diatom, a saltwater 

diatom and a cyanobacteria or blue-green algae), and a duckweed are typically required to establish the 

toxicity of an active ingredient to aquatic plants. For the antimicrobial use patterns, a seedling emergence 

test with rice is triggered if the aquatic toxicity of the algae or duckweed is 1 mg/L of less. Aquatic plant 

toxicity studies for boric acid were recently reviewed and the endpoints presented below (Table I12). 

No data gaps were identified as data for all four algal species and a duckweed species was available, and 

the results did not indicate that seedling emergence testing with rice was needed.

Table I12. Aquatic Plant Toxicity Data for Technical Grade Boric Acid and Sodium Borate Salts 

Active Ingredients.

Species % Purity

Exposure Conditions Endpoints

Study Classification/

Source/

Comments

Exposure Type

pH

Water 

Hardness as 

mg CaCO3/L

Temperature

x-h IC50

(95% CI)

NOAEC/ 

LOAEC

mg a.e./L

x-h IC50

(95% CI)

NOAEC/ 

LOAED

mg B/L

Duckweed (Lemna 

gibba G3), 

inoculum culture 

was 2 days old

Boric acid

99.7%

SR 7.4-

8.9

20X AAP 

Medium(1)

23-25 

oC

7-d

163

(139-191)

7-d

28.5

(24.3-33.4)

Acceptable/

48820802

Most sensitive endpoint was 

biomass based on dry weight.
103

Species % Purity

Exposure Conditions Endpoints

Study Classification/

Source/

Comments

Exposure Type

pH

Water 

Hardness as 

mg CaCO3/L

Temperature

x-h IC50

(95% CI)

NOAEC/ 

LOAEC

mg a.e./L

x-h IC50

(95% CI)

NOAEC/ 

LOAED

mg B/L

60 /

130

11 /

22

Measured

Green algae 

(Pseudokirchneriel

la subcapitata)

Boric acid 

99.9%

S 7.5-

8.3

AAP 

Medium(2)

24.2

23+2 

oC

74.5-hr

230

(180-320)

100 /

181

74.5-hr

40.2

(31.5-55.9)

17.5 /

31.6

Nominal but 

confirmed with 

selected 

measurements

Supplemental-Quantitative/

MRID 48507003/ 

Standard test is a 96 hour 

exposure study. Therefore 

results from this study may 

potentially underestimate 

toxicity as compared to results 

from a standard study. Also raw 

data was not provided so an 

independent evaluation of results 

was not possible. Estimate can 

be used as an upper bound of 

toxicity since 96-hour endpoints 

would be expected to be equal or 

lower. Also, study redone 

(48820804). The most sensitive 

endpoint was area under the 

growth curve. 

Green algae (P. 

subcapitata), 

inoculum culture 

was 3 days old

Boric acid 

99.7%

S 6.6-

9.3

AAP 

Medium(2)

24.2

23-25 

oC

96-hr

124

(87.2-177)

66 /

150

96-hr

21.7

(15.2-30.9)

11.5 /

26.2

Measured

Acceptable/

MRID 48820804/

Most sensitive endpoint was cell 

density and area under the 

growth curve. An 

algistatic/algicidal ancillary 

investigation documented that 

boric acid has an algistatic, 

rather than algicidal effect (at 

test termination cells from 1000 

mg a.e./L were exposed to 66 

mg a.e./L for 4 days—961 fold 

increase)

Blue-green algae 

(Anabaena flosaquae), inoculum 

culture was 3 days 

old

Boric acid 

99.7%

S 7.1-

7.4

AAP 

Medium(2)

24.2

24-25 

oC

96-hr

81.3

(58.2-113)

9.2 /

20

96-hr

14.2

(10.2-19.8)

1.6 /

3.5

Measured

Acceptable/

MRID 48820801/

Most sensitive endpoint was area 

under the growth curve. An 

algistatic/algicidal ancillary 

investigation documented that 

boric acid has an algistatic, 

rather than algicidal effect (at 

test termination cells from 160 

mg a.e./L were exposed to 10 

mg a.e./L for 4 days—81 fold 

increase).

Freshwater diatom 

(Navicula 

pelliculosa), 

inoculum culture 

was 3 days old

Boric acid 

99.7%

S 6.8-

7.6

AAP 

Medium(2)

24.2

23-24 

oC

96-hr

585

(488-703)

260 /

540

96-hr

102

(85.3-123)

45.4 /

94.3

Acceptable/

MRID 48851201/ 

Most sensitive endpoint was 

biomass. An algistatic/ algicidal 

ancillary investigation 

documented that boric acid has 

an algistatic, rather than algicidal 
104

Species % Purity

Exposure Conditions Endpoints

Study Classification/

Source/

Comments

Exposure Type

pH

Water 

Hardness as 

mg CaCO3/L

Temperature

x-h IC50

(95% CI)

NOAEC/ 

LOAEC

mg a.e./L

x-h IC50

(95% CI)

NOAEC/ 

LOAED

mg B/L

Measured effect (at test termination cells 

from 1000 mg a.e./L were 

exposed to 63 mg a.e./L for 4 

days—77 fold increase).

Marine diatom 

(Skeletonema 

costatum), 

inoculum culture 

was 8 days old

Boric acid 

99.7%

S 7.1-

8.7

AES 

Medium(3)

Salinity 30 

+ 2 g/L

21-22 

oC

96-hr

388

(343-435)

270 /

510

96-hr

67.8

(60.0-76.0)

47.1 /

89.1

Measured

Supplemental-Quantitative/

MRID 48820803/

Most sensitive endpoint was area 

under the growth curve. The 

final control density was slightly 

below test standards so 

uncertainty exists as to whether 

the cells were in optimum 

logarithmic growth phase. An 

algistatic/algicidal ancillary 

investigation documented that 

boric acid has an algistatic, 

rather than algicidal effect (at 

test termination cells from 1000 

mg a.e./L were exposed to 250 

mg a.e./L for 9 days—6.16 fold 

increase).

AAP: algal assay procedure; AES: artificially enriched seawater

(1) For this test the 20X AAP medium recipe was amended to not include the boric acid ingredient (final concentration of 3.7 mg 

a.e./L or 0.65 mg B/L), which is a nutrient for duckweed. This means controls were missing required nutrient levels of boron.

(2) The AAP medium recipe contains 0.1855 mg boric acid/L. This level is required for nutrition of these algae species and is 

negligible relative to the added boric acid additions for exposure treatment concentrations.

(3) For this test the AES medium recipe was amended to not include the boric acid ingredient (final concentration of 2.10 mg 

a.e./L or 0.37 mg B/L), which is a nutrient for this algal species. This means controls were missing required nutrient levels of 

boron.

The 96-hour IC50 for aquatic non-vascular plants (algae) from boric acid exposure ranged from 

81.3 (58.2 to 113) mg a.e./L for the freshwater blue-green algae, Anabaena flosaquae (MRID 48820801, 

based on AUC, area under the curve), to 592 (533 to 657) mg a.e./L for the freshwater diatom, Navicula 

pelliculosa (MRID 48851201, based on biomass); respective NOAECs were 9.2 and 260 mg a.e./L 

(Table I12). Anabaena is a bluegreen algae, which are not typically the most sensitive group – this is 

likely due, at least in part, to the protection from environmental stressors by their mucilaginous sheath. 

One possible explanation is the corrosive nature of boric acid that may damage the mucilaginous sheath. 

The second most sensitive algae tested had somewhat similar sensitivity with an IC50 approximately fifty 

percent greater; the freshwater green algae, Pseudokirchneriella subcapitata, had a 96-hour IC50 of 125 

(94 to 166) mg a.e./L and an NOAEC of 66, based on AUC. 

The IC50 for aquatic vascular plants from boric acid exposure was 163 (139 to 191) mg a.e./L for 

duckweed, Lemna gibba (MRID 48820802, based on final biomass) with an NOAEC of 60 mg a.e./L 

(Table I12). 

Testing with Formulations
105

Toxicity data with typical end-use products (TEPs) are required when it is known or there is 

concern for the potential for an ingredient or ingredients within the formulation to enhance the toxicity of 

the active ingredient. Information may also be used for labeling purposes. While no specific concern was 

expressed for enhanced toxicity of boric acid or any of the sodium borate salts, information was available 

from agency laboratory testing and from studies submitted to support registrations. Toxicity data with 

formulations are given in Table I13 below.

Table I13. Aquatic Plant Toxicity Data for Boric Acid and Sodium Borate Salts Active Ingredient 

Formulations.

Species,

Age or size % Purity

Exposure Conditions Endpoint

Study 

Classification/

Source/

Comments

Exposure Type

pH

Water 

Hardness as mg 

CaCO3/L

Temperature

x-h IC50

(95% CI)

mg t.s./L

x-h IC50

(95% CI)

mg a.e./L(1)

x-h IC50

(95% CI)

mg B/L(2)

Duckweed 

(Lemna

EP, Impralit KDS(3)

Boric acid 8%

-- -- -- -- -- -- -- /

46522304

Freshwater green 

algae, S. 

capricornutum)

Protectol CX Type A

[aka Wolmanit CXLP 15172]

(4)

Boric acid 5%

S 7.52 

– 8.7

OECD 

medium

21.2 –

23.0 

oC

0.15

(N.R.)

NOAEC = 

N.R. for 

biomass

0.0075 0.0013 Supplemental/

47210203

Control growth 

rate did not meet 

standards;

Biomass was 

most sensitive 

endpoint;

Effect was 

identified to be 

algicidal.

Freshwater green 

algae, S. 

capricornutum

Prev-Am Ultra(5)

Disodium tetraborate 

decahydrate 0.99%

S 7.4 

+1

155 22.8 

oC

72-h IC50 = 

40.4

NOAEC = 

11.9

Nominal

-- -- /

MRID 46955801/

Freshwater 

cyanobacteria, 

Anabaena flosaquae

Protectol CX Type A

[aka Wolmanit CXLP 15172]

(4)

 

Boric acid 5%

S 7.43 

–

8.09

OECD 

medium

22.1 –

24.0 

oC

0.10

NOAEC = 

N.R. for 

biomass

0.005 0.000874 Supplemental/

47210203 & 

47537801

Biomass was 

most sensitive 

endpoint;

Effect was 

identified to be 

algicidal.

Diatom, 

Navicula 

pelliculosa

Protectol CX Type A

[aka Wolmanit CXLP 15172]

(4)

Boric acid 5%

S 7.54 

–

7.82

-- 22.8 –

24.9 

oC

-- -- -- Acceptable/

47355201 & 

47537801

a.e.: boric acid equivalent; B: boron equivalent; N.A.: not applicable (i.e., probit method not a good fit); S: static; TN: test 

number

(1) This conversion assumes all the toxicity is attributable to the equivalents of boric acid in the formulation. Comparison of 

toxicity in terms of the actives and toxicity data based on each technical grade active ingredient in the test substance is needed

to determine if the toxicity of boric acid was enhanced.
106

(2) This conversion assumes all the toxicity is attributable to total boron in the formulation. Comparison of toxicity in terms of the 

actives and toxicity data based on each technical grade active ingredient in the test substance is needed to determine if the 

toxicity of boron was enhanced.

(3) EPA Reg #75269-2, 12.47% copper carbonate, basic; 8% boric acid; 5.96% N-decyl-1-Decanamine, polymer with boric acid, 

oxirane and 1,2-propanediol; and 73.57% inert ingredients. (Wood preservative uses.)

(4) EPA Reg #71406-2, copper carbonate, basic 16.3%; bis-(N-Cyclohexyldiazeniumdioxy)-copper) 3.5%; boric acid 5%; and 

75.2% inert ingredients.

(5) EPA Reg #72662-3, disodium tetraborate decahydrate 0.99%; 99.01% inert ingredients. (Foliar treatment for a number of 

crops.)

Toxicity to Terrestrial Organisms

a. Terrestrial Animals

Birds, Acute and Subacute – Technical Grade Active Ingredient

Acute oral toxicity data with TGAI is required to establish the toxicity for each active ingredient. 

Data is required for a passerine (songbird) species and either a waterfowl or upland game species. For the 

passerine study, regurgitation problems with using an oral dosing strategy resulted in a modified dietary 

passerine study (see footnote 2 to Table I15, below). The preferred waterfowl species is the mallard duck 

and the preferred upland gamebird species is the bobwhite quail. Avian acute toxicity data was available 

for three of the nine active ingredients in this case; results of these tests are tabulated below (Table I14). 

Boric acid data was tested above 2000 mg a.e./kg-bw, which is the cut-off between practically non-toxic 

and slightly toxic designation and therefore boric acid is considered practically nontoxic (Table I14). 

The other two active ingredients on a technical basis were also tested over 2000 mg t.s./kg-bw and are 

also considered practically nontoxic test substances on an acute oral basis. Because none of the tests 

exposed birds to boron in the diet at over 2000 mg/L and the results are not definitive tests, boron may at 

most be considered moderately toxic (Table I14). While no definitive comparison between acute oral 

toxicity can be made between all active ingredients in this Case given the available data, the agency does 

believe given the similarity between the chemicals in this case that the information on a boric acid 

equivalent basis and boron equivalent basis can be considered representative for the other active 

ingredients not tested.

Table I14. Acute Avian Oral Toxicity Data for Technical Grade Boric Acid and Sodium Borate 

Salts Active Ingredients.

Species, Age or 

size

Test 

Substance 

(ts)

% Purity

Design

Exposure 

Type

Endpoint

Toxicity 

Category

Study 

Classification/

Source/

Comments

mg a.e./kg mg B/kg

Mallard duck 

(Anas 

platyrhynchos)

Boric acid 

(H3BO)

99.9%

Oral, single 

dose

LD50

>2,150 

LD50 >376 B at most 

moderately toxic

(ts Practically 

non-toxic)

Acceptable/

ACC 254367/

No mortalities 

observed

Bobwhite quail 

(Colinus 

virginianus), 5 

months

Sodium 

Tetraborate 

Decahydrate

(Na2B4O7

•10H20)

100%

Oral, single 

dose

14-d LD50

>1,626 (a)

14-d LD50

>285 (a)

Practically 

nontoxic on a ts 

basis but 

Acceptable/

MRID 00100657/

No mortalities 

observed (10 

birds/tmnt)
107

Species, Age or 

size

Test 

Substance 

(ts)

% Purity

Design

Exposure 

Type

Endpoint

Toxicity 

Category

Study 

Classification/

Source/

Comments

mg a.e./kg mg B/kg

Bobwhite quail

(Colinus 

virginianus), 5 

months

Disodium 

Octaborate 

Tetrahydrate

(Na2B8O3

•4H20)

99.4%

Oral, single 

dose

14-d LD50

>1,625 (a)

14-d LD50

>284 (a)

Practically 

nontoxic on a ts 

basis but

Acceptable/

MRID 00107904

No mortalities 

observed (10 

birds/tmnt)

a.e.: boric acid equivalent; B: boron equivalent; mg/kg-bw: milligrams per kilogram of body weight; N.R.: not reported

(a) 14-d LD50 > 2,510 mg ts/kg-bw

Two subacute dietary studies one with a waterfowl and the other a gamebird species using TGAI 

are required to establish the subacute dietary toxicity to birds. The preferred test species are mallard duck 

for the waterfowl species and bobwhite quail for the upland game bird. Results of these tests are 

tabulated below (Table I15). Subacute data for a waterfowl and upland game bird species was available 

for two active ingredients in this case, boric acid and DOT; data for boric acid was also available for a 

passerine species. On a boric acid equivalent basis all results indicate these chemicals are practically 

nontoxic on a subacute dietary basis. While no definitive comparison between subacute dietary toxicity 

can be made between all active ingredients in this Case given the available data, the agency does believe 

given the similarity between the chemicals in this case that the information on a boric acid equivalent 

basis and boron equivalent basis can be considered representative for the other active ingredients not 

tested.

Table I15. Avian Subacute Dietary Toxicity Data for Technical Grade Boric Acid and Sodium 

Borate Salts Active Ingredients.

Species, Age or size

Test 

Substance (ts)

% Purity

Design

Exposure Type

Endpoint

Toxicity Category

Study Classification/

Source/

Comments mg a.e./kgdiet

mg B/kgdiet

Mallard duck (A. 

platyrhynchos), 1 day 

old

Boric acid 

(H3BO)

99.9%

Sub-Acute 

Dietary

8-d LC50

>5,620 

8-d LC50

>982 

B at most slightly 

toxic

(ts practically nontoxic)

Acceptable/

MRID 00141771

(ACC 254367), 

Beavers 1984/

No mortalities 

observed. 10 

subjects/group.

Mallard duck (A. 

platyrhynchos), 14 

days old

Disodium 

Octaborate 

Tetrahydrate

(Na2B8O13

•4H20)

99.4% 

Sub-Acute 

Dietary

8-d LC50

>12,000 (a)

8-d LC50

>2,100 (1)

Practically nontoxicAcceptable/

MRID 100636/

No mortalities 

observed. 10 

subjects/group

Bobwhite quail 

(Colinus 

virginianus), 11 days 

old

Boric acid 

(H3BO)

99.9%

Sub-Acute 

Dietary

8-d LC50

>5,620 

8-d LC50

>982 

B at most slightly 

toxic

(ts practically nontoxic)

Acceptable/

MRID 00141770

(ACC 254367),

Beavers 1984/ 

No mortalities 

observed. 10 

subjects/group. 
108

Species, Age or size

Test 

Substance (ts)

% Purity

Design

Exposure Type

Endpoint

Toxicity Category

Study Classification/

Source/

Comments mg a.e./kgdiet

mg B/kgdiet

Bobwhite quail 

(Colinus 

virginianus), N.R.

Disodium 

Octaborate 

Tetrahydrate

(Na2B8O13

•4H20)

99.4%

Sub-Acute 

Dietary

8-d LC50

>12,000 (a)

8-d LC50

>2,100 (a)

Practically nontoxicAcceptable/

MRID 100637/

No mortalities 

observed. 10 

subjects/group

Canary (Serinus 

canaria), 11-15 

months old

Boric acid 

(H3BO)

100%

Sub-Acute 

Dietary(2)

8-d LD50

>11,025

NOAEC/ 

LOAEC

1,869 / 4568 

(body wt 

gain-day 0-5)

8-d LD50

>1,929

NOAEC/ 

LOAEC

327 / 798 

(body wt 

gain-day 0-

5)

Measured

Practically nontoxicSupplemental/

MRID 48851202/

No mortalities 

observed out of 10 

birds/group

a.e.: boric acid equivalent; B: boron equivalent; mg/kg-bw: milligrams per kilogram of body weight; N.R.: not reported

(1) 8-d LC50 > 10,000 mg ts/kg-bw

(2) This study design is an acceptable alternative to the standard oral acute toxicity test which administers a single dose of test 

substance. The alteration was made because preliminary work by the study authors showed that canaries quickly regurgitated the

single dosage of boric acid. The primary study endpoint was survival. Observations were also made on body weight, food 

consumption, and changes in behavior.

3Based on 5-day weight gain.

Birds, Acute and Subacute – Boric Acid and Sodium Borate Salts Formulations

Toxicity data with formulations from the agency’s files are given in Table I16 below. None of 

these formulations have active registrations nor are they a typical end-use product for any active 

registrations and therefore are not useable in characterizing risk or hazards for this Case.
109

Table I16. Avian Oral and Subacute Dietary Toxicity Data for Boric Acid and Sodium Borate Salts 

Formulations.

Species, Age or size

Test Substance 

(ts)

% Purity

Design

Exposure Type

Endpoint Expressed As:

Toxicity 

Category

Study 

Classification/

Source/

Comments

ts a.e. B

Bobwhite quail (C. 

virginianus)

Grotan HD-II(a)

Sodium 

tetraborate 

decahydrate 

41%

Oral, single 

dose

LD50 = 317 

mg ts/kgbw

No longer registered Moderately 

toxic

Acceptable/

MRID 00060198/

Mallard duck (A. 

platyrhynchos)

Grotan HD-II

Sodium 

tetraborate 

decahydrate 

41%

Sub-Acute 

Dietary

8-d LC50 = 

13,100 ppm

(12,373-

13,827)

No longer registered Practically 

non-toxic

Acceptable/

MRID 00067969/

Bobwhite quail (C. 

virginianus)

Grotan HD-II(a)

Sodium 

tetraborate 

decahydrate 

41%

Sub-Acute 

Dietary

8-d LC50 = 

8,200 ppm

(7,354-

9,046)

No longer registered Practically 

non-toxic

Acceptable/

MRID 00067969/

a.e.: boric acid equivalent; B: boron equivalent; mg/kg-bw: milligrams per kilogram of body weight; N.R.: not reported

(a) EPA Reg # 10000-3, manufactured by Hellemite Lehn & Fink Products Company. Sodium tetraborate decahydrate (Borax) 

41%; potassium iodide 0.39%; 2-chloro-N-(hydroxymethyl)acetamide 39%; inert ingredients 19.61%

Birds, Chronic – Technical Grade Active Ingredient

Avian reproduction studies using the TGAI are required for birds as they may be subject to 

repeated or continuous exposure to the active ingredients due to the persistence, especially preceding or 

during the breeding season. The preferred test species are mallard duck and bobwhite quail. Data for 

boric acid was submitted for both a mallard duck and the bobwhite quail (Table I17). The mallard duck 

was more sensitive than the bobwhite quail. The mallard duck NOAEL for boric acid was 249 mg 

a.e./kg-diet (43.6 mg B/kg-diet) based on reproductive effects. 

Table I17. Avian Reproductive Toxicity Data for Technical Grade Boric Acid and Sodium Borate 

Salts Active Ingredients.

Species, Age or size

Test Substance 

(ts)

% Purity

Design

Exposure Type

Endpoint Study Classification/

Source/

mg a.e./kg Comments -diet mg B/kg-diet

Mallard duck (A. 

platyrhynchos), 27 

weeks old

Boric acid 

(H3BO)

100%

Reproduction NOAEL = 249(1) 

LOAEL = 743

NOAEL = 43.6

LOAEL = 130

Acceptable/

MRID 49009801/

16 pairs per level.

Based on percent 

hatchlings/live embryos.

Bobwhite quail (C. 

virginianus), 20 weeks 

4 days

Boric acid 

(H3BO)

100%

Reproduction NOAEL = 490 

LOAEL = 971 

NOAEL = 85.7 

LOAEL = 170 

Supplemental/ 

Quantitative/

49185901

16 pairs per level.

Based on percent 

hatchlings/live embryos 

and male weight gain.

a.e.: boric acid equivalent; B: boron equivalent; mg/kg-bw: milligrams per kilogram of body weight; N.R.: not reported; ts: test 

substance

(1) 21.2 mg/kg-bw estimated daily dose.
110

In addition to the submitted data, two avian reproduction studies testing borax have been 

identified in the available literature. They include a 28-day dietary exposure study in broiler chickens 

(Rossi et al. 1993) and a 6 week reproduction study testing mallard ducks (Smith and Anders 1989) .The 

results of Rossi et al. showed decreased hatchability in offspring of chickens exposed to 250 ppm B. In 

male chickens exposed to borax (250 ppm B), an increase in the number of damaged spermatozoa was 

observed (p = 0.051) (Rossi et al. 1993). Only one concentration of borax was tested in this study; thus, 

the NOAEL is <250 ppm B and the LOAEL is 250 ppm B. The results of Smith and Anders reported 

decreased hatching, post-hatching growth and survival in the 1000 ppm B treatment group (NOAEL = 

300 ppm B; LOAEL = 1000 ppm B). There was no effect of treatment on adult survival or egg fertility 

and no evidence of male reproductive toxicity was observed (NOAEL >1000 ppm B). The agency is 

assuming that on a boric acid equivalent basis and boron equivalent basis the boric acid results are 

representative of the toxicity for the other active ingredients not tested.

Birds, Other Data

Table I18. Other Avian Effects Data for Boric Acid and Sodium Borate Salts.

Species, Age or size

Test 

Substance (ts)

% Purity

Design

Exposure Type Endpoint Toxicity Category

Study Classification/

Source/

Comments

American Kestrel 

(Falco sparverius)

EP (sodium 

fluoride (98%)

+ boric acid)

Reproduction N/A -- /

47054802/ 

Sample sizes did not

permit adequate 

statistical analysis of 

the reproductive data.

Chicken Boric acid

(H3BO)

100%

Litter treated 

with boric acid

14-d LC50 > 

7.257 kg a.e./ 

ft2

14-d LC50 > 

1.270 kg B/ 

ft2

-- /

41017501 & 

41086601/ No 

mortalities, 20 

bird/group. 

(14-d LC50 > 16lb 

ts/ft2)

Turkey Boric acid

(H3BO)

100%

Litter treated 

with boric acid

14-d LC50 > 

7.257 kg a.e./ 

ft2

14-d LC50 > 

1.270 kg B/ 

ft2

-- /

41017501 & 

41086601/ No 

mortalities, 20 

bird/group. 

(14-d LC50 > 16lb 

ts/ft2)

a.e.: boric acid equivalent; B: boron equivalent; mg/kg-bw: milligrams per kilogram of body weight; N.R.: not reported; ts: test 

substance

Mammals, Acute and Chronic – Technical Grade Active Ingredient

Wild mammal testing is recommended on a case-by-case basis, depending on the results of lower 

tier laboratory mammalian studies, intended use pattern and pertinent environmental fate characteristics. 

In most cases, rat or mouse toxicity values obtained from the Agency's Health Effects Division (HED) 

substitute for wild mammal testing. These data are not included in this appendix.
111

Terrestrial Invertebrates – Technical Grade Active Ingredient

A honey bee acute contact study using the TGAI was previously recommended for boric acid 

because its proposed uses may result in honey bee exposure. Results of this test are tabulated below 

(Table I19). Additional pollinator studies more recently requested are also included, though incomplete 

at this time. The contact LD50 for the honey bee was >363 μg a.e./bee. More information is needed to 

assess risk to pollinators.

Table I19. Nontarget Insect Acute Toxicity.

Species

Guideline

Test Substance

Purity, % a.e.

LD50

(ug/bee) Study 

Classification MRID Expressed as μg 

a.e./bee

Expressed as μg 

B/bee

Honey Bee

Apis mellifera

850.30201

Acute Contact

TGAI (20 Mule Team Boric 

Acid)

100%

>363

(NOAEC 363)

>63.5

(NOAEC 63.5) Acceptable 402692012

Honey Bee

A. mellifera

OECD Guideline No. 213/EU 

method C.16.

Acute Oral Toxicity

Test Substance was OA-01NL

Unknown boric acid or boron.

NA NA

Not Reviewed; 

Review Pending 

Receipt of Active 

Ingredient 

information.

46955803

Honey Bee

A. mellifera

OECD Guideline No. 214/EU 

method C.17.

Acute Contact

Test Substance was OA-01NL

Unknown boric acid or boron.

NA NA

Not Reviewed; 

Review Pending 

Receipt of Active 

Ingredient 

information.

46955804

TGAI = technical-grade active ingredient; NA = information not available; 

1Formerly Guideline 141-1.

2Most of this information is also covered on pages 3-8 of a 1975 document (Atkins et al.). 

Table I20. Other Terrestrial Invertebrate Studies.

Species

Guideline

Test Substance

Purity, % a.e.

LC50

(ug/kg-diet) Study 

Classification

MRID/Other 

Expressed as mg Citation

a.e./Kg

Expressed as mg 

B/kg

Multiple Species1 Field Study NA NA

Not Reviewed;1

Supplemental 

Information

000060632/ 

Johansen, 1967

Dipteran

Anastrepha 

suspensa

NG - Acute 

Dietary

Sodium Tetraborate

Purity not given

48-h LC50 for 10d old 

males = 11800 (3320-

14500) mg boric 

acid/kg-diet

Slope 6.13 ± 1.96

48-h LC50 for 10d old 

males = 2060 (580-

2540) mg B/kg-diet

Slope 6.13 ± 1.96

Supplemental 

Quantitative 45356601

NG – non-guideline study; NA = information not available.

1Available copy illegible for the most part; appears to involve leaf-cutting bee, alkali bee, harvester ants, a beetle, a fly parasite 

and possibly other species.

A study of the effects of herbicides and foliar fertilizers on bees (Ostrovskil, 1955) was submitted 

for boric acid but not reviewed due to insufficient information. Another submitted study (Cherkasova,

1958) addressed the influence of boron on gas metabolism of the mulberry silkworm and was not 

reviewed due to unclear applicability in risk assessment for non-target species.
112

a. Terrestrial Plants

Table I21. Summary of Most Sensitive Terrestrial Plant Toxicity Endpoints – Tiers I and II.

Species Tested

Guideline

Test Substance

Purity, % a.e.

Toxicity Value

Study 

Classification

MRID

Expressed as lb a.e./A Expressed as lb B/A

Most sensitive monocot 

and dicot: Could not be 

determined

Species tested: monocot 

(corn, Zea mays; onion, 

Allium cepa; ryegrass, 

Lolium perenne; and oat, 

Avena sativa) and dicot 

(common bean, Phaseolus 

vulgaris; cucumber, 

Cucumis sativus; oilseed 

rape, Brassica napus; radish, 

Raphanus sativus; soybean, 

Glycine max; and tomato, 

Lycopersicon esculentum)

Seedling Emergence

850.4100

TGAI1 99.7%

Monocot:

IC25: >5.0 lb a.e./A (95% 

C.I.: N/A)

NOEC: >5.0 lb a.e./A

Dicot:

IC50: >5.0 lb a.e./A (95% 

C.I.: N/A)

IC25: >5.0 lb a.e./A (95% 

C.I.: N/A)

NOEC: 0.65 lb a.e./A; 

LOEC: 1.4 lb a.e./A, based 

on 9.9% in reduction in 

shoot length.

Monocot:

IC25: >0.874 lb B/A (95% 

C.I.: N/A)

NOEC: >0.874 lb B/A

Dicot:

IC50: >0.874 lb B/A (95% 

C.I.: N/A)

IC25: >5.0 lb B/A (95% 

C.I.: N/A)

NOEC: 0.114 lb B/A; 

LOEC: 0.245 lb B/A, 

based on 9.9% in 

reduction in shoot length.

Supplemental/ 

Quantitative 48885402

Vegetative Vigor

850.4150

TGAI1

99.7%

Monocot and Dicot:

IC25: >0.2 lb a.e./A (95% 

C.I.: N/A)

NOEC: >0.2 lb a.e./A

Slope: N/A

Monocot and Dicot:

IC25: >0.035 lb B/A (95% 

C.I.: N/A)

NOEC: >0.035 lb B/A

Slope: N/A

Supplemental/ 

Quantitative 48885401

1This study was conducted with TGAI (technical grade active ingredient) rather than the recommended TEP (typical enduseproduct) and since plants may be exposed directly to the whole product, some uncertainty exists as to potential effects from 

adjuvants in formulated products.

Tables of Plant Study Data Showing Details from 48885401 and 48885402:

48885402 Seed Emergence (Tier II):

Table I22a. Summary of seedling emergence data by species comparing control to highest 

treatment (5.0 lb a.e./A).

Species

Parameter

Survival**

Control Treatment % Difference

Bean 100 100 0

Corn 100 100 0

Cucumber 100 100 0

Oat 100 100 0

Oilseed Rape 100 100 0

Onion 100 100 0

Radish 100 100 0

Ryegrass 100 100 0

Soybean 100 100 0

Tomato 100 100 0

** For survival, the author said no mortalities, but a reviewer also counted lack of emergence as mortality – the conclusions were 

the same either way.
113

Table I22b. Summary of seedling emergence data by species comparing control to highest 

treatment (5.0 lb a.e./A).

Species Emergence

Control Treatment % Difference

Bean 87 70 19

Corn1 87 70 191

Cucumber2 93 77 182

Oat 81 81 0

Oilseed Rape 97 83 14

Onion 81 88 -8

Radish 77 93 -22

Ryegrass 84 69 19

Soybean 77 77 0

Tomato 80 73 8

1 There was a significant reduction of 27% at the 0.31, 1.3 and 2.5 lb a.e./A test level. However, the response was not dosedependent or consistent across other endpoints and/or other treatment levels and was determined by visual inspection not to be 

treatment related.

2 There was a significant reduction of 21% at the 1.2 and 2.5 lb a.e./A test level. However, the response was not dose-dependent 

or consistent across other endpoints and/or other treatment levels and was determined by visual inspection not to be treatment 

related.

Table I22c. Shoot length and dry weight data.

Species Shoot length (cm) Dry weight (mg)

Control Treatment % Difference Control Treatment % Difference

Bean 4.2 (1.3) 4.2 (2.5) 2 0.248 (0.065) 0.303 (0.213) -22

Corn 24.7 (7.7) 27.7 (7.1) -12 0.104 (0.040) 0.110 (0.051) -6

Cucumber 3.3 (0.8) 4.2 (1.5) -25 0.0361 (0.0128) 0.0684 (0.0281) -89

Oat 19.7 (2.8) 17.4 (2.0) 12 0.0267 (0.0034) 0.0257 (0.0081) 4

Oilseed Rapea 6.6 (1.0) 5.9 (0.4) 12*a 0.0755 (0.0146) 0.0805 (0.0127) -7

Onionb,c 7.7 (0.6) 7.4 (0.3) 3

b 0.0026 (0.0005) 0.0023 (0.0004) 13c

Radish 1.8 (0.3) 2.0 (0.3) 8 0.0427 (0.0153) 0.0456 (0.0135) -7

Ryegrass 11.8 (1.4) 11.9 (2.0) -1 0.0038 (0.0007) 0.0038 (0.0013) 1

Soybeand 6.6 (4.3) 5.9 (2.7) 10d 0.269 (0.060) 0.241 (0.044) 10

Tomatoe 3.2 (0.4) 3.1 (0.5) 2

e 0.0160 (0.0034) 0.0163 (0.0034) -2

* Significantly different from control (p≤0.05).

a There was a significant reduction of up to 10-14% at the three highest test levels; the response appeared to be dose dependent 

(Williams test, p<0.05).

bThere was a significant reduction of 10% at the 0.65 lb a.e./A test level. However, the response was not dose-dependent or 

consistent across other endpoints and/or other treatments and was determined by visual inspection not to be treatment related.

c There was a significant reduction of 19% at the 2.4 lb a.e./A test level. However, the response was not dose-dependent or 

consistent across other endpoints and/or other treatments and was determined by visual inspection not to be treatment related.

d There was a significant reduction of up to 51% at the 0.30 lb a.e./A test level and the direction of the response was inverted, 

with greater inhibition at lower doses. High inhibitions were due to variation in growth of this species; the response was not dosedependent and was not consistent across other endpoints and/or other treatment levels; ICx values were uncalculable.

e There was a significant reduction of 20% at the 0.65 lb a.e./A test level. However, the response was not dose-dependent or 

consistent across other endpoints and/or other treatments and was determined by visual inspection not to be treatment related.

Most sensitive monocot: Could not be determined 

IC50: >5.0 lb a.e./A 95% C.I.: N/A

IC25: >5.0 lb a.e./A 95% C.I.: N/A

NOEC: 5.0

Most sensitive dicot: Oilseed rape, based on height

IC50: >5.0 lb a.e./A 95% C.I.: N/A

IC25: >5.0 lb a.e./A 95% C.I.: N/A
114

NOEC: 0.65 lb a.e./A

LOEC: 1.4 lb a.e./A, based on 9.9% in reduction in shoot length.

Note: Due to slight differences in treatments, the NOEC for soybean and cucumber was 4.5 lb a.e./A, for 

all others except oilseed rape the NOEC was 5.0 lb a.e./A.

48885401 Vegetative Vigor (Tier II):

Table I23a. Summary of most sensitive parameters by species comparing control to highest 

treatment (0.20 mg a.e./A).

Species Survival

Control Highest % Difference

Bean 100 100 0

Corn 100 100 0

Cucumber 100 100 0

Oat 100 100 0

Oilseed Rape 100 100 0

Onion 100 100 0

Radish 100 100 0

Ryegrass 100 100 0

Soybean 100 100 0

Tomato 100 100 0

Table I23b. Shoot length and dry weight data.

Species Shoot length (cm) Dry weight (mg)

Control Treatment % Difference Control Treatment % Difference

Bean 29.6 (3.4) 28.9 (2.1) 2 1.70 (0.38) 1.87 (0.50) -10

Corn 68.1 (9.0) 66.9 (4.7) 2 0.669 (0.165) 0.793 (0.126) -19

Cucumber 13.2 (2.9) 11.8 (2.5) 11 0.580 (0.273) 0.582 (0.312) 0

Oat 54.9 (3.2) 52.2 (3.9) 5 0.253 (0.036) 0.272 (0.051) -8

Oilseed Rape 7.1 (0.6) 7.0 (0.8) 1 0.720 (0.058) 0.691 (0.053) 4

Onion 18.8 (1.3) 18.2 (1.8) 3 0.0252 (0.0052) 0.0222 (0.0061) 12

Radish 3.4 (0.2) 3.6 (0.4) -7 0.317 (0.013) 0.325 (0.036) -3

Ryegrass 34.3 (2.2) 35.5 (1.7) -3 0.0822 (0.0135) 0.0871 (0.0218) -6

Soybean 25.7 (2.0) 23.9 (3.4) 7 1.481 (0.394) 1.637 (0.393) -10

Tomato 14.0 (2.5) 14.1 (1.3) 0 0.263 (0.061) 0.260 (0.058) 1

Table I23c. Summary of endpoints.

Species Endpoint NOEC EC05 EC25 EC50

Bean None ≥0.2 >0.2 >0.2 >0.2

Corn* Dry Weight ≥0.2 162 1.25 0.0428

Cucumber None ≥0.2 >0.2 >0.2 >0.2

Oat None ≥0.2 >0.2 >0.2 >0.2

Oilseed Rape None ≥0.2 >0.2 >0.2 >0.2

Onion* Height ≥0.2 0.0968 1.28 >0.2

Ryegrass None ≥0.2 >0.2 >0.2 >0.2

Radish None ≥0.2 >0.2 >0.2 >0.2

Soybean None ≥0.2 >0.2 >0.2 >0.2

Tomato None ≥0.2 >0.2 >0.2 >0.2

* The response was not dose-dependent and was not consistent across other endpoints and/or other treatment levels; 

NOEC and/or ECx values are unreliable.
115

Most sensitive monocot: Could not be determined

IC50: >0.2 lb a.e./A 95% C.I.: N/A

IC25: >0.2 lb a.e./A 95% C.I.: N/A

NOEC: 0.2 lb a.e./A

Most sensitive dicot: Could not be determined

IC50: >0.2 lb a.e./A 95% C.I.: N/A

IC25: >0.2 lb a.e./A 95% C.I.: N/A

NOEC: 0.2 lb a.e./A

Species Tested: bean, corn, cucumber, oat, oilseed rape, onion, ryegrass, radish, soybean and tomato.

References for Appendix I: Ecotoxicity of Boric Acid and Sodium Borate Salts

Atkins, E.L., E.A. Greywood and R.L. Macdonald. 1975. Toxicity of Pesticides and Other Agricultural 

Chemicals to Honey Bees: Laboratory Studies, University of California, Division of Agricultural 

Sciences, LEAFLET 2287, 38 pp.

Beavers, J.B. 1982a. “Eight-day dietary LC50 – Mallard duck – Polybor. Final Report. TX-82-4.” 

Prepared by Wildlife International, St. Michaels, MD. Also referenced as 1984, so assume was 

resubmitted.

Beavers, J.B. 1982b. “Eight-day dietary LC50 – Bobwhite Quail – Polybor. Final Report. TX-82-3.” 

Prepared by Wildlife International, St. Michaels, MD. Also referenced as 1984, so assume was 

resubmitted. 

Beavers. J.B. 1984a. "A Dietary Study in the Mallard with Boric Acid. Final Report.” Project No. 176-

103. Prepared by Wildlife International Inc., St. Michaels. MD.

Beavers. J.B. 1984b. "A Dietary Study in the Bobwhite with Boric Acid. Final Report.” Project No. 176-

102a. Prepared by Wildlife International Inc., St. Michaels. MD.

Cherkasova, E.V. 1958. The influence of boron on gas metabolism of mulberry silkworm. Bulletin of 

the Academy of Sciences of the Turkmen SSR. (3):107-109.

Dethloff, G.M., W.A. Stubblefield, C.E. Schlekat. 2009. Effects of Water Quality Parameters on Boron 

Toxicity to Ceriodaphnia dubia. Arch Environ Contam Toxicol (2009) 57:60–67. ECOTOX ID: 

E118810.

Du Bois, A.M., G. Turian and A. Gonet. 1957. Effects of boric acid on growth; investigations on Allium 

cepa and tadpole. Archives des Sciences 10;466-470.

Johansen, C., Eves, J. 1967. Bee Research Investigations, 1967: Report No. 21866. (Unpublished study 

received Mar 27, 1974 under 4F1485; prepared by Washington State Univ., submitted by 

Chemagro Corp., Kansas City, Mo.; CDL:092011-M).

Fink, R. 1982. Acute Oral LD50 for Bobwhite Quail; Project No. 135-106; Prepared By Wildlife 

International LTD for U.S. Borax, Anaheim, California 92801.
116

Furuta, T., N. Iwata and K. Kikuchi. 2008. Effects of Fish Size and Water Temperature on the Acute 

Toxicity of Boron for Japanese Flounder, Paralichthys olivaceus, and Red Sea Bream, Pagrus 

major. Fisheries Science. Volume 73, Issue 2, pages 1444-2906, April 11, 2007.

Gerish, F.M. 1984. Evaluation of a Static Renewal Chronic Toxicity Test Method for Daphnia magna

Straus Using Boric Acid. Environmental Toxicology and Chemistry. 3(1):89-94.

Lewis, M.A. and L.C. Valentine. 1981. Acute and chronic Toxicities of Boric Acid to Daphnia magna

Straus. Bulletin of Environmental Contamination Toxicology 27:309-315.

Linden, E., B.E. Bengtssop, O. Svanberg G. Sundstrom. 1979. The acute toxicity of 78 chemicals and 

pesticide formulations against two brackish water organisms, the bleak (Alburnus alburnus) and the 

harpacticoid (Nitocra spinipes). Chemosphere 8(11/12): 843-851. 

Ostrovskil, N.I. 1955. Toxic effect of herbicides and foliar fertilizers on honeybees. Proceedings of the 

All-Union Academy of Agricultural Sciences. 20(2):32-34.

Padilla, S., D. Corumb,1, B. Padnosa, D.L. Huntera, A. Beamb,2, K.A. Houckb, N. Sipesb, N. 

Kleinstreuerb, T. Knudsenb, D.J. Dixb, D.M. Reif. 2011. Zebrafish developmental screening of the 

ToxCastTM Phase I chemical library. Reproductive Toxicology. 33 (2012): 174-187. ECOTOX 

ID: 161191.

Rossi AF; Miles RD; Bootwalla SM; Wilson HR; Eldred AR. 1993. The effect of feeding two sources of 

boron on broiler breeder performance. Poultry Sci. 72: 1931-1934.

Rowe, R. I., C. Bouzan, S. Nabili, C. D. Eckhert. 1998. The Response of Trout and Zebrafish Embryos to 

Low and High Boron Concentrations Is U-Shaped. Biological Trace Element Research. Vol 66: 

261-270. ECOTOX ID: 105984.

Smith GJ; Anders VP. 1989. Toxic effects of boron on mallard reproduction. Environmental Toxicology 

and Chemistry. 8:943-950

Takeuchi, T. 1958. Effects of boric acid on the development of the eggs of the toad, Buto vulgaris

formosus.” Scientific Reports of the Tohoku University, Series 4: Biology 24(1):33-34.

United States Environmental Protection Agency (USEPA). 1982a. Report on the Toxicity of Boric Acid 

99.9% active ingredient to Daphnia magna. (U.S. EPA, Chemical and Biological Investigations 

Branch, Beltsville, Maryland, Static Jar, Test No. 2750, 3/1/82, unpublished report).

USEPA. 1982b. Report on the Toxicity of Boric Acid 99.9% active ingredient to rainbow trout. (U.S. 

EPA, Chemical and Biological Investigations Branch, Beltsville, Maryland, Static Jar, Test No. 

2751, 3/1/82, unpublished report).

USEPA. 1982c. Report on the Toxicity of Boric Acid (Perma-Dust PT 240 20.0%) to rainbow trout. 

(U.S. EPA, Chemical and Biological Investigations Branch, Beltsville, Maryland, Static Jar, Test 

No. 2749, 3/1/82, unpublished report).

USEPA. 1993. EFED Science Chapter for Boric Acid/Sodium Metaborate RED (Chemicals #011001, 

011103; Case #0024). Internal communication to the Special Review and Reregistration Division, 

June 1, 1993.
117

USEPA. 2010a. Final Report on Acute and Chronic Toxicity of Nitrate, Nitrite, Boron, Manganese, 

Fluoride, Chloride and Sulfate to Several Aquatic Animal Species. EPA 905-R-10-002. USEPA 

Region 5. 174 pp. 

http://www.epa.gov/region5/water/wqs5/pdfs/techdocs/FINAL%20Report%20EPA-905-R-10-

002.pdf

USEPA. 2010b. Final Report on Acute and Chronic Toxicity of Nitrate, Nitrite, Boron, Manganese, 

Fluoride, Chloride and Sulfate to Several Aquatic Animal Species. Boron Tests: Appendices 18-

26. EPA 905-R-10-002. USEPA Region 5. 416 pp. 

http://www.epa.gov/region5/water/wqs5/pdfs/techdocs/FINAL%20Report%20EPA-905-R-10-

002.pdf

Zeebe, R.E., A. Sanyal, J.D. Ortiz and D.A. Wolf-Gladrow. 2001. A theoretical study of the kinetics of 

the boric acid-borate complex in seawater. Marine Chemistry 73: 113-124.

Ziof, H.F. and G. Stephen. 1949. Toxic effects of boric acid and its products with aliphatic polyhydroxy 

compounds. Naunyn-Schmiedeheros Archiv fuer Experimentella Pathologie und Pharmakologie. 

207:55-66.
118

Appendix J ECOTOX

The agency performed a public literature search following OPP’s Evaluation Guidelines for Ecological 

Toxicity Data in the Open Literature18 (Open Lit Guideline). As identified in the Registration Review Ecological 

Risk Assessment Problem Formulation for: Boric Acid Salts (USEPA, 2009) and the Open Lit Guideline, open 

literature studies are identified through the agency’s ECOTOXicology database (ECOTOX)19. ECOTOX is a 

publically available knowledgebase, developed and maintained by the agency’s Office of Research and 

Development’s (ORD’s) National Health and Environmental Effects Research Laboratory (NHEERL), containing 

aquatic and terrestrial plant toxicity results from open literature studies where single chemical (i.e., not mixtures) 

exposures were tested. ORD/NHEERL performed a comprehensive literature search on boric acid and the sodium 

borate salts contained in this case20. For data from an open literature paper to be eligible for inclusion in ECOTOX 

it must meet six minimum data requirements: (1) exposures are to single chemicals; (2) the toxic effects are on a 

valid aquatic or terrestrial plant or animal species; (3) the test was conducted on live, whole organisms; (4) 

concurrent environmental chemical concentration/dose or application rate data with the observed effect; (5) there is 

an explicit duration of exposure; (6) the data is quantitative not qualitative20. In vitro, bacteria, yeast and virus 

exposures are not included in ECOTOX.

Papers that were located using the ECOTOX open literature search strategy but rejected for entry into the 

ECOTOX knowledgebase due to one or more of the six inclusion criteria not being met are listed in Section 1 of 

Attachment 1 to this document. There were 2,347 papers excluded. The reason for a specific paper being excluded 

is listed for that paper in the “Keywords:” line for the citation. The following table summarizes the specific 

exclusions for these papers. While abstracts that are available for these papers are provided to the agency to allow 

the risk assessor to determine if there is information that should be obtained for use in a weight of evidence 

approach, it was determined these papers were not useful for this assessment and none of these were required or 

reviewed further. 

Reason Papers in Section 1 of Attachment 1 on Boric Acid or Sodium Borate Salts were Excluded from 

ECOTOX

Keyword Codes21 Definition

Number 

of 

Excluded 

Papers

ABSTRACT Abstract only, not a full article—insufficient supporting documentation of study 10

BACTERIA Bacteria are the test organism, and data for bacteria are not included in ECOTOX. 30

BENEFICIAL EFFECT Study is on beneficial effects of the chemical, not toxic effects 11

CHEM METHODS No toxicity data, contains information only on a chemical method(s) 889

EFFLUENT Study reports effects associated with exposure to effluent, sewage, or polluted 

runoff and not to single chemical exposures. 19

FATE No toxicity data reported, contains fate information about the chemical in abiotic 

media. 143

FOOD Food study, no biological effects data for the chemical reported. 12

HUMAN HEALTH Human health effects; studies with human subjects or with animal subjects as 

surrogates for human health risk assessment. 90

 

18

http://www.epa.gov/pesticides/science/efed/policy_guidance/team_authors/endangered_species_reregistration_work

group/esa_evaluation_open_literature.htm

19 http://cfpub.epa.gov/ecotox/

20 http://cfpub.epa.gov/ecotox/help.cfm?help_id=OVERVIEW&help_type=define&help_back=1

21 Based on ECOTOX exclusion categories discussed in more detail in Attachment I-C at 

http://www.epa.gov/pesticides/science/efed/policy_guidance/team_authors/endangered_species_reregistration_work

group/esa_evaluation_open_literature.htm#att_2
119

Keyword Codes21 Definition

Number 

of 

Excluded 

Papers

IN VITRO The paper does not report a biological effect on live, whole organisms; in vitro 

data is not included in ECOTOX. 46

INCIDENT,SURVEY See INCIDENT and SURVEY 1

METHODS Methods paper with no usable toxicity test results. 5

MIXTURE Mixture study containing no data on single chemical exposure. 117

MIXTURE,NO CONC Mixture study containing no data on single chemical exposure and does not report 

concurrent exposure chemical concentrations/doses or application rates. 1

MODELING Paper reports models only, no new biological effects data. 9

NO CONC The paper does not report concurrent exposure chemical concentrations/doses or 

application rates with the effects. 2

NO DURATION The paper does not report an explicit duration of exposure. 1

NO DURATION,SURVEY A survey study measuring amounts of chemical present, but no usable 

quantification of exposure. Also lacks usable exposure duration information.

1

NO SOURCE Citation found but either no source given in the citation or source is no longer 

available (e.g., publication withdrawn). 2

NO SPECIES The paper does not report the species that was tested; or the species cannot be 

verified in a reliable source. 2

NO TOXICANT Not a toxicology study; no primary toxicity data presented in paper. 34

NON-ENGLISH The article is not published in the English language. 17

NUTRIENT Chemical is tested as a nutrient. 680

PUBL AS Author published data in multiple formats (e.g., thesis and peer reviewed journal); 

repeat of an already coded paper. 6

PUBL AS,REVIEW Author published data in multiple formats, this paper is a repeat of an already 

coded paper and it is not the primary source of biological effects data. 1

REVIEW The paper is not the primary source of biological effects data. 75

SURVEY A survey study measuring amounts of chemical present, but no usable 

quantification of exposure. Lacks either usable concentration or duration or both. 138

VIRUS A virus(es) is the test organism, and data for viruses are not included in 

ECOTOX. 2

YEAST Yeast is test organism, and data for yeasts are not included in ECOTOX. 3

An initial screen of the studies included in the ECOTOX database is conducted to eliminate those studies 

that have a low probability of usefulness in the risk assessment based on a set of standards the agency uses to 

evaluate the quality of studies and that can be readily screened against entries in ECOTOX data fields. ECOTOX 

papers that were eliminated as having a low probability of usefulness are listed in Section 2 of Attachment 1. 

There were 199 papers eliminated. The reason for a specific paper being eliminated is listed for that paper in the 

“Call Number:” line for the citation. The reasons for elimination include one or more of the following: bacteria was 

the test organism for the active ingredients in this case (NO BACTERIA); no control included in the study or control 

information not reported (NO CONTROL); biological effects not part of study (NO EFFECT); no biological effect 

endpoint reported in the study (NO ENDPOINT); all exposures were to mixtures of chemicals (NO MIXTURE); 

study was on nutritional aspect and not toxic biological effects (NO NUTRIENT); author published data in multiple 

formats, this paper contains a repeat of an already coded result (NO PUBL AS); test with the active ingredients was 

not with live, whole organisms (NO IN VITRO). Over 140 of the studies contained no biological effect endpoints, 

with over 160 containing no biological effect endpoint and/or no control data.

The bibliography of all ECOTOX studies not eliminated are presented in Section 3 of Attachment 1 and 

the results from these studies are summarized in tables in Attachment 2 as follows:
120

Aquatic Animal Studies

Table 1 for Aquatic Animal Studies (comparable species and endpoints) Boric Acid Case .........................................2

Table 2 for Aquatic Animal Studies (species not comparable) Boric Acid Case ........................................................38

Table 3 for Aquatic Animal Studies (endpoints not comparable) Boric Acid Case ....................................................43

Aquatic Plant Studies

Table 1 for Aquatic Plant Studies (comparable species and endpoints) Boric Acid Case ...........................................49

Table 2 for Aquatic Plant Studies (species not comparable) Boric Acid Case .........................................Not applicable

Table 3 for Aquatic Plant Studies (endpoints not comparable) Boric Acid Case ..............................None in ECOTOX

Terrestrial Animal Studies

Table 1 for Terrestrial Animal Studies (comparable species and endpoints) Boric Acid Case ...................................51

Table 2 for Terrestrial Animal Studies (species not comparable) Boric Acid Case ....................................................76

Table 3 for Terrestrial Animal Studies (endpoints not comparable) Boric Acid Case ................................................87

Terrestrial Plant Studies

Table 1 for Terrestrial Plant Studies (comparable species and endpoints) Boric Acid Case .....................................134

Table 2 for Terrestrial Plant Studies (species not comparable) Boric Acid Case ......................................................177

Table 3 for Terrestrial Plant Studies (endpoints not comparable) Boric Acid Case ..................................................178

The ECOTOX data is separated into a set of four major taxonomic groupings: aquatic animals, aquatic 

plants, terrestrial animals, and terrestrial plants. Except for the aquatic plants, the data summary tables for each 

taxonomic group is split into three tables. Table 1 for each taxonomic grouping contains results of studies that are 

comparable to the species and measurement endpoints from OCSPP guideline conducted studies submitted in 

support of registration or registration review actions. Table 2 for each taxonomic grouping contains results of 

studies that are from taxonomic groups not normally required in support of registration and registration review 

actions but the measurement endpoints are comparable to OCSPP guideline measurement endpoints. Table 3 for 

each taxonomic grouping contains biological effects measurement endpoints that are not comparable to those used in 

risk estimate calculations conducted in support of registration or registration review. Because all aquatic plant 

taxonomic groups are comparable species to those required to support registration and registration review actions, 

the aquatic plant taxonomic group data are only separated into two tables—Table 1 and Table 3. 

The agency examined these tables to determine if there was data for comparable species and measurement 

endpoints to those from OCSPP guideline conducted studies for which the agency had no data and to determine if 

the open literature contained any measurement endpoints with lower values than that contained within the agency’s 

files. A list of the lowest toxicity values for each taxonomic group and measurement endpoint type in the agency’s 

files used for the open literature analysis are provided in the proceeding table. The values listed in this table are on a 

boric acid equivalent basis. Values highlighted in red in the tables in Attachment 2 are lower than the respective 

taxonomic group and measurement endpoint type in this list of lowest toxicity values. However, it should be noted 

that the summary tables do not identify whether the results are reported as the test substance, boric acid equivalents, 

or boron equivalents. No attempt was made to go through each comment field to determine if a conversion to boric 

acid equivalents needed to be made on the results. However, a quick look at comment fields within the ECOTOX 

database indicated that a large portion were reported on either a boric acid or boron equivalents basis and therefore it 

was thought this would highlight values of concern. 

For freshwater fish there were acute 96-h LC50 values for six species of freshwater fish (bonytail, Colorado 

squawfish, flannelmouth sucker, razorback sucker, rainbow trout, and western mosquito fish) and a non-native 

amphibian (African-clawed frog). Definitive 96-h LC50 values ranged from 70 ppm B (429 ppm ae) for the red sea 

bream to 979 ppm B (5,600 ppm disodium tetraborate decahydrate or 3,362 ppm a.e.) for the western mosquito fish. 

The effect of age on toxicity to boric acid was studied with Colorado squawfish, bonytail and the razorback sucker, 

in general the younger fish (10-31 days old) were more sensitive than older fish (>133 days old). The 96-h LC50 for 

the African clawed frog ranged from 73.4 mg B/L (420 mg a.e./L) to 239 mg B/L (1,365 mg a.e./L). 
121

The results of this analysis of the ECOTOX open literature database consist of the following and are 

discussed in the boric acid and sodium borate salts ecotoxicity profile (Appendix I).

 More sensitive measurement endpoint values were identified for the following taxonomic groups and 

measurement endpoints resulting in the review of the following studies:

o Freshwater invertebrates, acute toxicity—Ceriodaphnia dubia study (ECOTOX ID E118810);

o Freshwater fish, acute toxicity—Zebrafish and

 Data for the following missing taxonomic groups and measurement endpoints were identified and the study 

with the lowest values reviewed:

o Estuarine/marine penaeid shrimp, acute toxicity—(ECOTOX ID E111738)

o Estuarine/marine fish, acute toxicity—(ECOTOX ID )
122

Appendix K Summary of Incident Information

EIIS Database:

Queries were done on PC Codes 011001, 011002, 011102, 011103, 011104, 011107, 011110, 

011111 and 011112 on July 7, 2015. PC Codes 011001, 011002, 011103, 011104, 011107, 011111 and 

011112did not yield any reported incidents. PC Codes 011102 and 011110 had a total of three reported 

incidents and the report summaries follow:
123
124
125
126

AIMS Database:

A query was done on PC Codes 011001, 011002, 011102, 011103, 011104, 011107, 011110, 

011111 and 011112 on July 7, 2015. No incidents were found.
127

IDS Aggregate Database:

A query was done on PC Codes 011001, 011002, 011102, 011103, 011104, 011107, 011110, 011111 and 

011112 on July 7, 2015. The report summaries follows; the first resulted from a query of wildlife, plant 

and non-target incidents, the second was for domestic animal incidents.
128

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