### UNITED STATES ENVIRONMENTAL PROTECTIONAGENCY WASHINGTON, D.C.20460

OFFICE OF CHEMICAL SAFETY AND POLLUTION PREYENTION



### MEMORANDUM PC Code: 392201 DP Barcode: 384525 

### DE~ 5

## rotJ 

### : 

### 4-06 

### 300 Subject: (Revised) EFED Environmental Risk Assessment for the Proposed Uses of Spirotetrarnat on the Production of Cotton, Soybean, Legume Vegetables, Tropical Fruit, Pistachio, Okra, and Dried Prunes, Review of Risk to Pollinators, and GroundwaterLabel Requirement Revision.
To: Rita Kumar, Risk Manager Reviewer John Hebert, Risk Manager,

### Rrn 07 Meredith Laws, Branch Chief Insecticide-Rodenticide Branch Registration Division (7505P)
From: JosephDecant,Ecologist, Ecological Effects Reviewer ChristinadeMariano,Biologist, Ecological Effects 

## b / JosC 

### L. MelCndez, Chemist Environmental Risk Branch V Environmental Fate and Effects Division (7507P) Through: Mah 

### T. Shamim,Ph.D., Branch Chief 

# @p?!- /a / ?/lo Environmental Risk Branch V 

## 1 EnvironmentalFate and Effects Division (7507P)
This revised memo addresses a series of requests made 

### by Bayer Cropscience (BCS) related to the use of spirotetramat. The revisions include the addition of information related to the potential hazard to bees and appropriate label language or additional data needed to address this hazard. Therevised memo also updates the data requirements remaining for spirotetramat.
Similar to the original memo, this revised memo assesses the state of science regarding pollinators and the results of submitted studies as they pertainto bee label language and the field study requirement. It also deals with the groundwater label revision request proposed by the registrant. Finally, it addresses the risk to terrestrial and aquatic non-target species associated with new use registrations that are currently being requested for spirotetramat products for the following crops: cotton, soybean, legume vegetables, tropical fruit, pistachio, okra, and dried prunes (see

### Table 1below for the proposed rates). 1 -The major conclusions related to pollinators and the available information are as follows. The Environmental Fate and Effects Division (EFED) does not concur with the request of Bayer Cropsciencein their white paper entitled, "Position Paper on Toxicity of Spirotetramat to Honey Bees" (MRID 47576401), to remove the label language restricting the spraying before and during bloom on cucurbits and citrus nor the removal ofthe label language stating, "Exposure of adult bees to direct treatment or residues on blooming crops can lead to effects on honey bee larvae. See the "Directions for Use" section of this label for specific crop application instructions that minimize risk to honey bee larvae." Nor does the EFED concur with the request to consider fulfilled the condition ofregistration for MoventoTM for field testing with pollinators by the submission ofthe previous field studies and the additional data contained in the submitted datapackage (D357547). While two more field studies have been submitted, MRID7s 48159801 and 48159802, these studies have not yet been evaluated. At present, the data gap therefore remains for Guideline 850.3040; Field Testing for Pollinators. The EFED has developed crop specific label language that can be used to eliminate exposure to pollinators for some crops, but not all crops. For tree fruits and tree nuts, as well as citrus. the EFED believes that additional data on translocated residues is needed to better characterize exposure. A field studythat satisfies the Guideline 850.3040 will be held in reserve pending the outcome of residue characterization in the field. Regarding the groundwater label amendment, based on the laboratory and field studies, it appears that spirotetramat, spirotetramat-en01 and spirotetramat-ketohydroxy do not leach or persist substantially. Therefore, the EFED concurs with the registrant's label amendment request. The groundwater label advisory isnot required. Finally, based on its review of the new studies and the proposed new uses, the EFED concludes that the risk picture for all proposed new uses is not substantially altered from the most recent assessment covering the currently registered uses of spirotetramat. While new studies have been recently submitted to fulfill OPPTS Guideline 850.1075 (Freshwater Fish Toxicity with Fathead Minnows) and OPPTS Guideline 850.21 00 (Avian Oral Toxicity Study with a Passerine Species), these studies are still in review. No additional data has been submitted on OPPTS Guideline 850.2300, Avian Reproduction Study with the Mallard Duck (Anas platyrhvnchos). The ecological risk assessment findings under that review (~345278') therefore pertain to this request. Please rely onthe prior assessment and the additional information presented here for the evaluation of the ecological risk conclusions for the proposed new uses. The current statusofthe outstanding data requirements based on the previous risk assessment and new pollinator strategy are as follows: 850.1075 Freshwater Fish Toxicity with Fathead Minnows: in review 850.1350 Aquatic invertebrate life-cycle EstuarineIMarine: in reserve 850.2100Avian Oral Toxicity Study with a Passerine Species: in review 850.2300 Avian Reproduction Study with the Mallard Duck (Anas platvrhvnchos): No datasubmitted 

## ' Appendices can be found at H:\EFED-Chem_Files\392201\Sec 3\D345278. 3 

### - -

### 850.3040 Field Testing for Pollinators: in 

### reserve Non-guideline Study for Systemic Field Residueswith Tree Crops:

### No 

### data submitted.
The following discussion in this memo updates the previous memo (D362953, 363765, 358761) regarding the pollinator and groundwater label discussion, new use risk assessment and data requirements. 

### Evaluation of Spirotetramatand Pollinators Request from Bayer CropScience
New studies on the fate and toxicity of the spirotetramat parent compound and the major degradate.~ as they relate to pollinators have been submitted to the EFED since the last risk assessment2. Bayer CropScience submitted a document entitled "Position Paper on Toxicity of Spirotetramatto Honey Bees" (MRID47576401),which states their rationalebehind their threefold request as outlinedbelow:
1.

### The condition of registration for MoventoTM for field testing with pollinatorsbe considered klfilled with the previous submission of two field studies and the additional data includedin this data package. 

### 2. The environmental hazard statement should be amended as follows. Remove, "Exposure of adult bees to direct treatment or residues on blooming crops can lead to effects on honey bee larvae. See the "Directions for Use" section of this label for specific crop application instructions that minimize risk to honey bee larvae." and replace with "No effects on the bee brood have been observed in field testing with Movento". 3.The restriction on cucurbits and citrus to avoid spraying before and during bloom is not necessary and should be removed. The statement, "Do not apply until after petal fall7' should also be removed. This is redundant with the statement in the "Application Information" section of the label which will remain on the label and states, "Sufficient leaf tissue must be present for uptake and translocation of this product; due to this requirement, do not apply prior to petal-fall on pome fruits, stone fruits, and tree nut crops." Bayer CropScience proposes that their products containing spirotetramat are safe for pollinators as evidencedby field and semi-field trials with

### Apis mellifera. These studiesrange from residue studies in pollen, nectar, and blossoms to semi-field trials with spirotetramat spiked pollen to field trials using melon and citrus crops. Previous laboratory studies have illustrated the ability of spirotetramat to adversely affect bee brood (MRID 469044-70, 769044-58). These studies subjected honeybees to sugar solutions containing 0.0144% spirotetramat (equivalent to 144ppmin the bee food), and they found that spirotetramat has the ability to substantially affect bee brood development. Bayer subsequently

MRID ~Abers 47576401,47563302,47563303,47563304,47563305,47563306,47563307,47563308, 47563309,47563310,4756331 1,47563312. 3
-sponsored a tunnel study to further evaluate the possible effects of spirotetramat to bee brood (MRID 472769-Ol), which also demonstrated the potential for spirotetramat to affect bee brood development. In response to these studies, Bayer CropScience countered that these studies represent unrealistic exposure scenarios. The laboratory studies, they contend, exposed the bees to unrealistically high concentrations that will not be found in the environment. Similarly, the bees exposed in the tunnel study were forced to forage on the contaminated crop, and therefore represent unrealistic worst-case exposure conditions. They therefore conducted two studies, a semi-field (MRID 469044-59) test with oilseed rape and a field test (MRID 469044-62) with flowering lacy phacelia. In both studies, no adverse effects occurred in honey bee adults orbrood. Despite these studies the EFED continued to state that risk to honey bee brood from spirotetramat could not be precluded. The 

### EFED countered with the rationale that the tunnel study that showed effects to the bee brood exhibited effects lower than the maximum labeled application rate. The tunnel study by Bayer, which did not show effects, was conducted with application rates of approximately one-halfthe maximum labeled application rate. Similarly, in the field study conducted by Bayer not only were the highest single application rates approximately equal to half the maximum single proposed label application rate, but the overall total application rates were approximately half the maximum proposed label seasonal application rate. The conclusion of the EFED related to honey bee brood and development were based on a couple ofreasons. The rationale was partly based onthe nature of spirotetramat as an insecticide that has exhibited effects to bee brood under less than maximum application rates. The other part of the rationale was that two other related chemicals (spiromesifen and spirodiclofen) showed the potential for chronic effects to bee brood and development while displaying low acute toxicity.



### Review of Previously Submitted Studies
The new studies submitted by Bayer CropScience are in response to the request for a field study that assesses the toxicity and exposure of spirotetramat to bees under field conditions. A total of 11 studies were submitted for review to fulfill the Field Testing for Pollinators requirement inthe conditional registration. A total of six studies were submitted that examined the residues of spirotetramat, which address the exposure of spirotetramat to pollinators. Two studies explore the toxic effects of spirotetramat over a range of concentrations in spiked pollen samples when given to bees in a tunnel design. Finally, three studies explore the toxicity of spirotetramat when bees are exposed under field conditions. The results ofeach study will be presented below along with the limitations of the studies that affect their ability to adequately assess the risk of spirotetramat to honey bee brood.

### 47563302 Assessment ofeffectsofSpirotetramat

### OD150 on honeybee (Apismellifera) coloniesunder arealistic field scenarioin a melon crop in 2007 (non-GLP).
Class2Jication: This field study is invalid due to the statistically signzjcant differences between treatment groupsfor average larval abundance and number of dead pupae before thejrst application asweN asthe inability toconfirm exposure affer the 

### 2nd application. This study assessed the effects of total spirotetramat residues on honey bee colonies in a field study design at application rates of 72 g a.i.ka applied four times and 

### 88 g a.i./ha applied four times. A 

### review of the study revealed significant differences between the control plot and the both treatment groups for average larval abundance by a greater than 34% reduction in both groups compared to the control before the first application. For the average number of dead pupae, there was a reviewer-estimated effect on the number of dead pupae in the 72 and 88 g a.i./ha treatment group before the first treatment was applied. In addition, there were events of pupae expulsion from the hives in both treatment groups on different days after the first treatment. For the endpoint of number of dead worker bees per hive, the variability within groups was extremely high. The averagenumber of dead worker bees was 4 times as high and 3 times ashigh in the 72 and 

### 88 g a.i.katreatment groups as compared to the control, respectively. ~urthermore, there was significantly higher mortality in the treatment groups before application ofthe test material. In summary, many of the endpoints exhibitedhigh variability or significant differences between groups even before the first application, which does not allow for meaningful comparisonsbetween treatment groups.
A 

### number of other limitations arose in the study. The study authors reported that a flower density equivalent to approximately 200 melon blossoms/100 m is sufficient to provide an attractive.food source for honeybees. However, the crop fell below this threshold after the 2nd application. The study authors did not provide a reference for this critical threshold. The study authors also stated that a positive proof of the absence of effects could only be provided for the study period up to the T1 assessment, because they were uncertain about exposure in the period after the 2ndapplication. The plots were located only three kilometers apart from each other, which is within the foraging range of a honeybee (Beekman and Ratneiks, 2000). The study showed high variability in the controls. Melon plants on almost all of the plots were heavily infested with Bemisia sp., so thiacloprid and deltarnethrin were used to control the infestation. Finally, the study authors did not confirm foraging through pollen identification or exposure throughpollednectar analysis.



### 47563303 Assessment of effects of Spirotetramat OD 

### 150 to honey bee (Apis mellifera) coloniesunder arealisticwdscenarioin a meloncrop. Classzjcation: This study is supplemental because itprovides information about the effects of spirotetramat on bees in a Jield scenario; however, the study did not conjrmforaging or exposure through pollen identification or pollen/nectar analysis, showed reduced foraging potential after thefourth application ofthe test material, and did not quantijjforaging on the crop. 5 -The study authors examined the effects oftotal spirotetramat residues onhoney bee colonies in a field study setting with a melon crop. The study was conducted at three rates: 0 for the control, 75 g a.i./ha applied four times, and 

### 88 g a.i./ha applied twice. There was no evidence of any treatment related effects in any ofthe endpoints measured.
There were a number of aspects related to this study that limit the inferences that can be drawn from it. All of the treatments exhibited high variability, which may either have masked the effects from the test material or may have reflected natural variability in bee colonies. After the fourth application of the test material, there was an observed decrease in blossom density. This decrease was reported as being normal due to the crop being cultivated later than is done regionally that resulted in a shortened flowering period. The plots were again only 3km apart. The study authors did not confirm foraging through pollen identification or exposure through pollenJnectar analysis. Finally, the study author stated that they obtained visual verification of exposure by observing bees ontheblossoms, but this conclusion was not quantified.



### 47563304 Assessment of Side Effects of Spirotetramat OD 150 on the Honey Bee (Apis mellifera

### L.)Applied to Citrus in the Field in Spain. ClassiJication: This study is su~~lemental because it shows the effects of spirotetramat on bee brood in afield setting, but it also shows high variability in the endpoints and that little citrus pollen was foraged by bees in the treatment group suggesting limited exposure to the chemical.
This study assessed the effects of total spirotetramat residues to honey bee colonies in citrus crops in Spain. The chemical was applied at a rate of 192.0 g a.i./ha, which was applied at two different times and separated by three weeks. The treated and the control orchards were appropriately far away from each other (15km). There was no evidence of any treatment related effects in any ofthe endpoints measured. This study using citrus crops showed that total spirotetramat residues would not result in any adverse effects to honey bee colonies. Yet, the study also showed some results that question the usefulness ofthe study. High variability in the endpoints was apparent in both of the treatments in the study. A review ofthe study revealed that on a day to day basis, the control and treatment orchards would exhibit increased mortality or decreased foraging as compared to one another. But the effects were minimized when considering the entire post-application period due to the high daily variability. Thepollen and nectar analysis showed the accumulation of small amounts of spirotetramat in the pollen, but not the nectar, inside the hives of the bee colonies (<0.01 to 0.03 mg/kg of spirotetramat and <0.01 to 0.15 mg/kg of BYI08330-enol). The study authors identified the pollen in the hives and remarked that the bees in the control group foraged on a variety of crops including citrus (from 8.7% on day 26 after the second application to 23.7% on day 14 after the second application) whereas in the treated orchard little citrus pollen was collected (from 1.O% on day 26 after the second application to 2.7% on day 7 after the second application). This data shows that bees were foraging on other crops besides citrus and may imply that spirotetramat has repellent properties. Furthermore, the residues of spirotetramat 6
-

### found inside the hive could not be compared to the citrus residue study 

### (MRID 47563312) that could not verify the chemical concentrations in the pollen. This comparison would have confirmed if the concentration found in this study could be realistic or simply an artifact ofa lack of foraging onthe treated crop.


### 47563305 Determination of Effects of Spirotetramat in Spiked Pollen to Honeybee Brood under Semi-Field Conditions(Trial2008). ClassiJication: This study is supplemental as it illustrates the impact ofspirotetramat in a food source over a range of concentrations, but it also revealed several limitations such as high variability in the endpoints inall treatment groups, a decrease in larval and pupal abundance in all treatment groups until the bees were allowed to forage, and the lack of pollen storage inside the hive. The purpose of this study was to assess the effects of pollen spiked with total spirotetramat residues on honey bee colonies and their brood. The study authors reported no effects on brood or brood development after feeding small honeybee colonies for 21 days with the spiked pollen with nominal concentrations covering a range of 0, 2, 10, and 20 mglkg. In addition, there appeared to be no adverse effects on comb development, hive weight development, honey and pollen storage behavior, and foraging activity. After exposure the bees were allowed to forage outside of the tunnels. The study provided an assessment of total spirotetramat residue toxicity to honey bee brood in a tunnel design. This design ensured that the only food source for the hives would be the food provided by the study authors, which were the spiked pollen and spirotetrarnat free honey. The study showed no adverse effects to any endpoint, however the data also showed some results that question the applicability of the study. First, the honeybees in all of the treatments did not store pollen in the hives until they could forage outside of the tunnel, yet they stored honey from a feeder outside the hive over the course of the whole study. The study authors state that the bees did not store pollen because they considered the pollen in the petri dish inside the hive to be a part of the comb. This rationale should be a part of future research into this method given the propensity of honey bee behavior to store pollen and nectar in the hives. Second, all of the treatments, including the controls, showed a decrease in larval and pupal abundance over the course of the study until the bees were allowed to forage outside of the tunnel, at which point both parameters increased in the various treatments. Finally, the different treatments showed high variability in the endpoints with only three replicates per treatment, which may be a result ofnatural honey bee colony variability or may mask any treatment level effects. 

### 47563306 Determination of Effects ofBY108330 inSpiked Pollen toHoneybeeBrood under Semi-Field Conditions(Trial 2006). Classification: This study is supplemental because it provides useful information about the effects ofspirotetramat on bees ina tunnel design, but it also has deficiencies such as the lack of pollen collection inside the hive and the study design lacked replication. 7
-This study examined the effects of pollen spiked with a range of concentrations of total spirotetramat residues. The concentrations were 0, 0.05, 0.2, 0.5, 2, and 10 mglkg. The bees were exposed for 22 days to spiked pollen through a feeder placed outside the hive and one placed inside the hive. After exposure the bees were allowed to forage outside of the tunnels. The study authors concluded that a slight transient effect to larval abundance in the highest treatment group could not be excluded. They also reported that there were no adverse effects to other brood-related endpoints, comb development, hive weight development, honey and pollen storage behavior, foraging activity and mortality by foraging on and consumption of pollen containing up to lOmg BY108330 and BYI08330-enollkg pollen. After a review ofthe results however, egg deposition appeared to decrease at all levels, including the controls.
While the study employs a tunnel design to ensure exposure, the study has a number of deficiencies that render it of little use in risk assessment to pollinators. The study authors did not conduct statistical analyses onthe data for each endpoint. The mortality data are presented as the number of dead bees found,but the exact number ofbees in eachtreatment level attest initiation is not known so that percent mortality could not be determined. The honey was placed in a feeder outside of the hives, whereas spiked pollen was placed in two feeding dishes- inside the tunnel, one inside the hive and one outside the hive. The bees collected honey and stored the honey inside the hives; however they did not store pollen in the combs. The study authors state that the bees did not store pollen because they considered the pollen in the petri dish inside the hive to be a part ofthe comb. This rationale should be a part of future research into this method given the propensity of honey bee behavior to store pollen and nectar in the hives. The most important deficiency is the lack of replicates in the study, which places the results in question because statistical analyses cannot be performed on the data and severely limits the usefulness of the study.



### 47563307 Residues ofSpirotetramat and its metabolites in blossom samples ofmelons after spray application in Spain. Classification: 

### This study is supplemental as it provides useful information related to the accumulation of spirotetramat in melon blossoms, but it was not conducted according to any established guideline.
This study assessed the magnitude ofresidues of spirotetramat in melon blossoms attwo rates of 72 and 288 g a.i./ha. The study concluded that total residues can persist as long as 10 days after application. Total residue concentrations were 1.463mglkg after three hours post application in the 72 g a.i./ha treatment and 4.690 mglkg after three hours post application in the 288 g a.i./ha treatment. This study showed that residues persisted in melon blossoms after both application rates.



### 47563308 Residues ofSpirotetramat and its metabolites in nectar and pollen samples of melons after spray application (tunneltesl)in Spain. 8
-

### Classzfication: This study is supplemental as it provides useful information related to the accumulation ofspirotetramat in honey bee nectar and pollen after foraging on melon blossoms, but itwas not conducted according toany established guideline. The study authors assessed the magnitude of total residues of spirotetramat in nectar and pollen collected by honeybees (Apismellifera)from melon crops in a tunnel design. Spirotetramat was applied at two rates: 96 and 288 g a.i./ha. The nectar and pollen were collected from inside the hive. Two different application times provided a comparison oftotal residues when applications were made five days before flowering or at full flowering. The maximum concentrations based onthe sampling design inside the hives were 0.306 mgkg after an application of 288 g a.i./ha at 

### 17 days after treatment and 0.213 mglkg after an application of 96 

### g a.i./ha at 11 days after treatment. The study addresses the accumulation of spirotetramat in honeybee nectar and pollen stores, but it did not include control plots. More importantly, the sampling showed increasing concentrations of spirotetramat inthe hives over time. Yet the sampling did not capture the point at which concentrations remained constant or decreased, which suggests that the study may not have captured the maximum concentrations inside the hives.

4

### 7563309 Residues ofSpirotetramat and its metabolitesin citrus blossoms after spray application in Spain. Classification: This study is supplemental as it provides useful information related to the accumulation of spirotetramat in citrus blossoms, but it was not conducted according to any establishedguideline. This study examined the concentrations of spirotetramat in citrus blossoms with a total application rate of 112.5g a.i./ha applied two times. The upper bound of reported total residues reached 0.742mg/kg, with a mean value of 0.591mglkg. The study showed that total residues of spirotetramat will accumulate in citrus blossoms. The study was limited in that it failed to use the maximum labeled rates, but in fact used a rate approximately one-half ofboth the maximum application rate and the maximum seasonal application amount.


### 47563310 Residues of Spirotetramat andits metabolites in nectar and pollen of phacelia after spray application in Germany. Classfication: This study is supplemental as it provides useful information related to the accumulation ofspirotetramat in phacelia nectar and pollen collected from inside bee hives, but itwas not conducted according any established guideline, they did not describe their methods for analyzing the honeybee toxicity endpoints or condition ofthe bees, and the study did not have a control treatment.
The focus of this study was on the total residues of spirotetramat in nectar and pollen collected by bees (A.

### mellifera). The chemical was applied at a rate of 100 g 

### a.i./ha over phacelia, and 9
-residues in pollen and nectar were collected from inside the hive. Analysis showed that total spirotetramat residues in pollen accumulated to a maximum of 6.35 mglkg at 4 days after application. In addition, concentrations tended to remain high where the upper bound of total residues was 4.51 mglkg at 10 days after application. However, total residues in nectar showed much lower concentrations with a maximum of 0.33 mg/kg at 4 days after application and an upper bound of 0.23 mglkg at 10 days after application. The study found no effects to any measured endpoint in the honeybee colony. The study showed that total spirotetramat residues can accumulate in the pollen and nectar of honeybee hives after foraging on treated phacelia and persist for at least ten days. However, the study had 

### a number of limitations. The authors did not describe their methods for analyzing the honeybee toxicity endpoints, and the source, health, and age of the bees ofthe honeybee colony were not reported, and most importantly the study did not have a control treatment.



### 4 756331 

### 1Residues ofSpirotetramat and its metabolites in nectar and pollen ofsummer oilseedrape after spray application in Germany. Classz~cation: This study is supplemental as it provides useful information related to the accumulation ofspirotetramat in nectar and pollen from summer oilseed rape collectedfrom inside bee hives, but it was not conducted according to any established guideline, they did not describe their methods for analyzing the honeybee toxicity endpoints or condition of the bees, and the study did not have a control treatment.
Similar to the study on phacelia nectar and pollen, this study focused on the total residues of spirotetramat in nectar and pollen collected by bees (A.

### mellfera). The chemical was applied at a rate of 100 g a.i./ha over oilseed rape, and residues in pollen and nectar were collected from inside the hive. Analysis showed that total spirotetramat residues in pollen exhibited a maximum of 8.31 mglkg at 6 days after application. In addition, concentrations tended to remain high where the upper bound on total residues was 7.14 mglkg at 7 days after application. However, total residues in nectar showed much lower concentrations with a maximum of 0.06 mglkg at 4 days after application and an upper bound of 0.04 mglkg at 7 days after application. The study found no effects to any measured endpoint in the honeybee colony. The study showed that total spirotetramat residues can accumulate in the pollen and nectar from honeybee hives after foraging on treated oilseed rape and persist for at least ten days. However, the study had a number of limitations. The authors did not describe their methods for analyzing the honeybee toxicity endpoints, and the source, health, and age of the bees of the honeybee colony were not reported, and most importantly the study did not have a control treatment.



### 47563312 Residues ofSpirotetramat and its metabolites in nectar and pollen ofcitrus after spray application in Spain.

### ClassiJication: This study is supplemental as it provides useful information related to the accumulation ofspirotetramat in citrus nectar andpollen collected from inside bee hives, but it was not conducted according to any established guideline nor did it assess the accumulation of spirotetramat in pollen stores in the hive. This study focused on the total residues of spirotetramat in nectar and pollen collected by bees (A. 

### mellifera) in a crop of citrus. The chemical was applied twice at 

### a rate of 75 g a.i.kalm canopy height over citrus, and residues in nectar were collected from inside the hive. Analysis showed that total spirotetramat residues in nectar did not accumulate to quantifiable concentrations throughout the entire study. The study failedto assess the accumulationpotential of spirotetramat residues in pollen because there was not enough pollen to sample. In addition, the application rate was approximately one-half of both the maximum application rate and the seasonal application rate.



### EFED Response In summary, these studies show that total spirotetramat residues will accumulate in the blossoms ofvarious crops up to a maximum of 4.69 mglkg after a treatment of 288 g a.i./ha in melon and 0.591 mglkg after a treatment of 112.5 g a.i./ha applied twice in citrus. The residues accumulate in the pollen stores of a hive based on specified application and sampling times at 0.306 mglkg after a treatment of 288 g a.i./ha in melon, 6.35 mglkg after a treatment of 100 g a.i./ha in phacelia, and 8.3 1mglkg after a treatmentof 100 g a.i./hain oilseedrape. These studies also show that in a tunnel study design where honey bees are forced to forage on pollen spiked with spirotetramat and its metabolites the results can be mixed. The tunnel study in 2006 (47563306) showed slight transient effects at 10mglkg. The 

### NOAEC would therefore be 

### 2 mglkgbased on this study. However, a similar study in 2008 (47563305) showedno effects at any treatment level up to 20 mg/kg. Both of the field studies (47563303, 47563304) showed no advers.eeffects to any endpoints.
It would appear that spirotetramat exposure to the brood, which is conclusive based on the residue analyses ofthe pollen and nectar stores inside the hives in the tunnel studies,will not be toxic to honeybees at the application rates tested in the field studies. Furthermore, the tunnel studies with spiked pollen show that adverse effects would not occur at concentrations up to 

### 2 mglkgbased upon the 2006 tunnel study (47563306). Yet, as previously reviewed, these studies have some substantial limitations in addressing the potential toxicity of spirotetramat to honey bee colonies. The deficiencies range from high variability and few replicates (47563305, 47563303, and 47563304), questionable hive performancegiven differencesbetween treatments even before chemical application (47563302), questionsof exposurerelated to a 

### decrease in blossom density or the lack ofpollen identification analysis (47563302,47563303), application rates lower than the maximum labeled use rate and maximum seasonal rate (47563309,47563312), a lack of method reporting for toxicity endpoints (47563310, 4756331

### I), a sampling design that may not have captured the maximum exposure 

### 11level (47563308), to a complete lack of replicates (47563306). Also, concentrations in citrus pollen stored inside the hives were not assessed in the field residue study (47563304) even though one of the requested actions is to remove the restriction of applying spirotetrarnat to blooming citrus.
An additional limitation ofthe studies arises from the nature of the risk posed by spirotetramat. Previous laboratory studies showed effects to the brood. The current studies show that spirotetramat may affect larval abundance (47563306). They also show that spirotetramat residues will accumulate and persist inthe hives of honey bee colonies. In fact, even though the NOAEC as established in the 2006 tunnel study (47563306) is questionable given the high variability in the control treatment endpoints, concentrations in the semi-field residue studies for phacelia and oilseed rape were greater than this value. Both of these aspects of toxicity and exposure, together with the results of the previous laboratory studies, suggest that chronic risk needs to be the assessment goal in the field study. However, the maximum length of time that these studies assessed the honey bee colonies was approximately 1.5 months (47563303, and 47563304).
The EFED does not concur with the requested label changes as requested by Bayer CropSciences. An application to blooming citrus or cucurbits could increase the exposure to adult bees, which would then allow the adult foragers to return and expose the hive to these higher pesticide loads. The removal of protective labeling language related to the effects to honey bee broods isinappropriate considering that aspreviously discussed therecently submitted studies have deficiencies that do not allow for a sufficient analysis of exposure and potential chronic effects to the brood of honey bee colonies. These deficiencies do not provide sufficient evidence to alter the EFED's assessment of the risk of spirotetramat to pollinators and beneficial insects as outlined in the attached previousrisk assessment. Finally, given these deficiencies and the need to assess chronic risk, the most recently submitted studies do not satisfy the requirements of a field study. Previous responses and comments by 

### RD and the EFED recommended submitting a proposed study design and working with the EFED to establish a testing protocol before the study would be implemented. However, the EFED believes that crop specific labeling could eliminate exposure for most crops, which may also affect the need for a pollinator field study. The EFED has further assessed those crops for which specific label lan~uage should be applied. For more information see the revised memo regarding crop specific labeling (D379926). Specificallv relatedto the new uses, the label language, "Do not apply until after petal fall" is appropriate for the following crops:
1. Stone Fruits: dried prune 2. Tree Nuts:pistachio Minor crops and/or crops which may be attractiveto bees under some conditions,but do not warrant crop-specific labeling:3. 

### Others: Soybean, legume vegetables, tropical fruit, okra 

### Potential hazard from exposure which cannot be mitigatedby labeling: Cotton: Because cotton has extrafloral nectaries which produce nectar throughout the growing season, bees are attracted to the crop even after actual bloom has ceased. Thus, bee precautions based on bloom do not mitigate the hazard. The following websites discuss the nature of extrafloral nectaries in cotton:

The crops included in the currentlyproposed new uses are also included in the revised memo on crop specific labeling (D379926). The EFED identified uncertaintiesin exposure for citrus and tree fmits and tree nuts based on the protective label language. The EFED therefore developed a strategy to address any remaining uncertainties in exposure. A previous memo (D380617) established the current strategyofEFED related to spirotetramat regarding pollinators as follows:
"The Environmental Fate and Effects Division (EFED) identifies that the period of concern for spirotetramat applications, given its systemic nature, is the period before bloom, during bloom, and until petal fall is complete. Therefore, EFED believes that the label statement, "Do not apply until after petal fall", will be sufficiently protective for most crops. Given the systemic nature of spirotetramat, however, there is uncertainty regarding the potential for carry-over of residues from one growing season to the next for tree crops. Thus, studies shouldbe conducted to determine whether residues will remain in tree crops following post petal-fall application of spirotetramat in the previous season at the maximum application rate. Bayer Cropscience 

### (BCS) should consult with EPA in developmentofthe protocols for these studies.
For citrus, EFED suggests that the original label statement, "Do not apply this product within 10 days prior to bloom, during bloom, or until petal fall is complete", may be used. Data shouldbe submitted to EPA to confirm and quantify levels of residues in citrus leaves, pollen, and nectar after applications at different times before bloom. Thepurpose ofthe study is to evaluateresidue levels at 10 days before bloom and prior to 10 days before bloom in order to better evaluate exposureto bees, and, if necessary, to revise the appropriate pre-bloom "window" necessary to protect pollinators. Again, studyprotocols should be developed through consultation with EPA.
The previous requirement for a pollinator field studywith spirotetramatwill be placed in reserve, pending the outcome of the residue studies. Should the residue studies indicate potential for pollinator exposure in spiteofthe application restrictions, field studiesmay be required.
BCS has submitted a letter to EPA regarding amended bee label safety language that EPA has proposed for spirotetramat labels. BCS states that the languageproposed by EPA for tree crops, "Do not apply until after petal fall", is not appropriate for citrus, as it is unclear, is inconsistent with a recent memo from EFED, and does not provide enough detail to specify a definite 

### 11application window. In addition, BCS states that this label statement is scientifically unacceptable based on the extensive existing dataset, and it renders impractical the uses for melon and citrus. According to BCS, two studies on citrus are in the process ofbeing prepared for submission to EPA, which show that spirotetramat does not pose any risk to bees at realistic application rates to citrus. BCS therefore proposes the original label language for citrus: "Do not apply this product within 10 days prior to bloom, during bloom, or until petal fall is complete."
EFED has reviewed this position statement by BCS. EFED stated in the previous memo that for certain crops, the potential hazard to bees could be "mitigated by current labeling," which is the proposed label language of "Do not apply until after petal fall". EFED believes that this label language will be sufficient for the majority of crops, due to the application window defined by leaf fall or harvest. However, EFED agrees with BCS that this label language, "Do not apply until after petal fall", is unclear for citrus, because citrus produces new growth year-round with no clear endpoint to the treatment season. Thus, the original label statement, "Do not apply this product within 10 days prior to bloom, during bloom, or until petal fall is complete", is appropriate for citrus, unless data from citrus residue studies indicate that a longer pre-bloom restriction is needed." In summary, the previous field studies to date have been found to be insufficient to address the hazard of spirotetramat to bee brood and hive survival. Protective label language has been identified for most crop uses. Uncertainties in exposure remain for citrus, tree fruits, and tree nuts given the systemic nature of spirotetramat. Therefore, the EFED is requesting nonguideline studies to be conducted that address the systemic residues in these crops while a field study onthe toxicity of spirotetramat (850.3040) is being placed in reserve pending the outcome of the residue studies. If the residue studies show that bees will continue to be exposed to spirotetramat residues despite the protective label language, then a field study may be requested to satisfy Guideline 850.3040. 

### Groundwater Label Requirement Revision Request from Bayer Cropscience
BCS also requested to amend the labels of Spirotetramat Technical and its three end use products.3 The registrant proposed to remove the following advisories from the labels: Technical Label: "This chemical has properties and characteristics associated with.chemicals detected in ground water. The use of this chemical in areas where soils are permeable, particularly where the water table is shallow, may result in ground water contamination."

Letter from L. Hodges to R. Kumar, Identified as EPA Correspondence No. 09-03S, dated Feb. 5,2009, Re: Application to Amend the Registration of ~Spirotetramat Technical (EPA Reg. No. 264-1049); ~Movento (EPA Reg. No. 264-1050); .BY1 8330 150OD Insecticide (EPA Reg. No. 264-1051); 0ULTOR (EPA Reg. No. 264- 1065). 14 -

### End Use Products Labels: "This chemical has properties and characteristics associated with chemicals detected in ground water. This chemical may leach into ground water if used in areas where soils are permeable, particularly where the water table is shallow." The registrant cited two submissions in support of their request, a photolysis on soil study, using a sterile soil (MRID# 47576502), which was accompanied by a position paper (MRID# 47576501), related to the nature of the non-extractable residues (NER). The Agency has reviewed.thesoil photolysis study (supplemental). Moreover, BCS has indicated that: Mobility and persistence: The Kd3sare 4.1, 16.8 and 1.0 mL/g for spirotetramat, spirotetramat-en01and spirotetramat-ketohydroxy, respectively, but they degrade rapidly. Degradation: The mean half-lives are 0.21, 0.10 and 6.9 days, respectively. The half-life for the combined residues of spirotetramat-enol, spirotetramat-ketohydroxy and spirotetramat-MA-amide from the spirotetramat-en01study was a mean of 16.8 days. The Non-Extracted Residues (NER) should not be considered as relevant residues or in half-life calculations and should not be considered mobile. The results of the terrestrial field dissipation confirmed the rapid degradation and low mobility of spirotetramat residues. The DTSOs for the combined residues of spirotetramat, spirotetramat-en01and spirotetramat-ketohydroxy was 9.5 days for the four sites, with residues remaining inthe top soil layers. The results obtained from the tier 

### 1 groundwater model SCI-GROW were less than 0.4 ppt, indicating a low potential for groundwater contamination.



### EFED Response
EFED concurs with BCS' request, and BCS should request to amend the labels accordingly. According to the Label Review Manual 

### (http://www.epa.~ov/oppfeadl/labelin~/ld ), 

### "The need for a ground water label advisory is based on the environmental fate properties of the chemical andordetections ofthe chemical in ground water." According to the manual, there are two criteea to be used. First,the mobility ofthe chemicals shouldbe evaluated: e.g.,if

### Kdis less than 5 or the field dissipation results indicate that the chemical leaches. Second, the chemical's persistence is examined; e.g., the hydrolysis half-life is greater than 30 days at any 

### pH or the aerobic soil metabolism half-life is greater than 2 weeks.
The 

### Kdfor spirotetramat ranges from 3.58 - 

### 5.52 mL/g, for spirotetramat-enol, it is 10.86mL/g, and for spirotetramat-ketohydroxy,it is 12.28mL/g. These values suggest high mobility for all the three compounds. Nonetheless, in terrestrial field dissipation studies, conducted in 

### NY, CA and WA,.including both, cropped and bareground plots (a total of 5 trials), the test substances were confined in the upper 0-15 cm soil depth. In the study conducted in FL, all three test substances were also observed in the 15-30cm soil depth at 1andor 7 days (but not at 3 days), but they were not detected in the 15-30 cm soil depth above the LOQ after the 7 days test interval. Despite their low Kd 

### values, the field dissipation studies suggest that these test substancesdonot leach substantially under field condition.For spirotetramat, the hydrolysis half-lives are 32.5-47.6 days (pH 4); 8.6-13.1 days (pH 7); and 0.32 days (pH 

### 9). Spirotetramat-en01was stable to hydrolysis at a pH range of 4 to 

### 9 and 50°C for 5 days. Finally, for 

### spirotetramat-ketohydroxy, there is no hydrolysis study, but the aerobic aquatic metabolism study suggests that it could be persistent to hydrolysis. Despite the hydrolysis half-lives are >30 days in some instances, the aerobic soil metabolism is very rapid. For spirotetramat, it is 10.30days (four soils), for spirotetramat-en01it is 10.16days (four soils), and for 

### spirotetramat-ketohydroxy, it is 1.5-5.1 days for three soils, and 16.7 days for one soil. These aerobic soil metabolism half-lives suggest that spirotetrarnat, spirotetrarnat-en01 and 

### spirotetramat-ketohydroxyare not persistent. This is substantiatedby the results ofthe terrestrial field dissipation studies, where the half-lives for the total residues of spirotetramat, spirotetramat-en01and spirotetramat-ketohydroxy, in six trials conducted in FL, CA and WA (cropped and bareground plots) were in the rage of 5.0 - 10.2 days. For a field study conducted in

### NY (bareground plot), the half-life was slightly higher, 23.4 days.
Based on the laboratory and field studies, it appears that spirotetramat, spirotetramat-en01 and spirotetramat-ketohydroxy do not leach or persist substantially. Therefore, the EFED believes that the groundwater label advisory is not required.
The issue of the NER has been deferred and will be considered at a later time since no exceedances of the levels of concern were observed for the total spirotetramat residues (see also D358765+).


### RiskAssessment
Based on the maximum exposure scenario allowed under these new uses, exposure modeling was conducted with the EFED's PRZMIEXAMS,T-REX (T-REX, Version 1.3.1,dated December 7, 2006), and TerrPlant (v1.2.2) models to estimate exposure to aquatic organisms (Tables 2 and 

### 3), terrestrial animals (Table 

### 4), and upland and wetland plants (Table 

### 5), respectively. Based on the results of T-REX and TerrPlant, the estimated environmental concentrations (EECs) were less than the highest EECs estimated in the previously conducted risk assessment, "Environmental Fate and Ecological Risk Assessment for the Section 3 Registration of the New Chemical Spirotetramat (DP Barcode 345278; Dated May 30, 2008)" (based on the more conservative total residues approach discussed in the assessment). Only EECs for terrestrial and aquatic organisms are presented below to demonstrate that exposure, and therefore risk, for the proposed new uses will be lower than for the currently registered uses. Based on its review, the EFED concludes that the risk picture for all proposed new uses is not substantially altered from the previously mentioned assessment covering the currently, registered uses of spirotetramat. The ecological risk assessment findings under that review therefore pertain to this request (copy attached4). Please rely on the prior assessment and the additional information presented here for the evaluation ofthe ecological risk conclusions for the proposed new uses. Data requirements can be found in Tables 

### 6 and 7.

4 Appendices can be found at H:\EFED-Chem-Files\392201\Sec 3\D345278. 16 -me Fruit (Crop Group 11,and winter type squash like acorn squash,calabaza and others), and

Fruiting Vegetables (Crop Group 8 plus including eggplant, groundcheny, okra, pepinos, peppervarious kinds, tomatillo and tomato) Leafy Vegetables (Crop Group4 including amaranth-various kinds, arugula-roquette, cardoon, celery, celtuce, chervil, Chinese celery, chrysanthemum,corn salad,garden cress, cress-various kinds, dandelion, sorrel dock, endive, Florence fennel, lettuce-head and leaf, orach, parsley, garden and winter purslane, radicchio-red chicory, rhubarb, spinach-various kinds, Swiss chard) 0.08

0.08 2

2 0.16

0.16 7

7 (3,A, Chemigation

G, A. Chemigation 1

3Table 1. 'Summaryuse information for spirotetramat, basedon BY18330 150ODInsecticide(oil



## .No. 264-1051) and MOVENTOTM (suspension concentrate) labels (Reg. No. 264-1050).

Proposed New usesd (FL avocado aerial/ 

# 1 4.89 

# 1 4.84 

# 1 4.78 

# 1 0.0074 

# 1 0.0089 Currently Registered Uses (NC apples aerial; 0.4; 3; 7)

0.12+0.12+0.14/ 31 14) 

## I * The representative modeled exposure scenario for spray applications of spirotetramatto agricultural crops resultingin the highest EECs. ~p~lication rate in lb &./A and intervalbetween applications in days. Highest calculated acute RQs are for fkeshwater invertebrates. Toxicity values arebased on studies with midges (Chironomus riparius) for freshwater invertebrates (ECSo =660 pg a.i./L). All RQs fromthe previous assessment and for theproposed new uses arebelow the Agency's acute risk (0.5), acute restricted use (0.I), and acute endangered species (0.05)LOCs. 'Highest calculated chronic RQs are for freshwater fish.Chronic toxicity values are based on studies with fathead minnows (Pimephalespromelas)for freshwater fish (NOAEC =534 pg a.i./L). The chronic risk LOC is 1. Therefore, all chronic RQs fromthe previous assessment and for the proposed new uses are below the Agency's chronic LOC.

Includes non-extracted residues in the EECs. INTERVAL BETWEEN APPS. (days) 7

7 USE Brassica(Cole) Leafy Vegetables (Crop Group 5 including broccoliraab, Brussels sprouts,cabbage, cauliflower, cavalo broccolo, Chinese broccoli,Chinese cabbage, Chinesemustard cabbage, collards,kale, kohlrabi,mizuna, mustard greens, mustard spinach, rape greens, turnip greens) Potato and Other Tuberousand CormVegetables (Crop Subgroup IC including arracacha,arrowroot, artichokeChineseand Jerusalem, edible canna,bitter and sweet cassava, chayote-root, chufa, dasheen-taro, ginger,leren,potato, sweetpotato,tanier,turmeric,yam bean, true yam)

11.4 NUMBER OFAPPS. 2

2 SINGLE APP. RATE (Ibs. a.i./A) 0.08

0.08 APP. METHOD

G,A, Chemigation

G,A, Chemigation SEASONAL APP. RATE

(I.aA)

0.16

0.16

11.1 PHI (days)

1

7

10.8 0.0173 0.02020.12+0.12+0.14/ 31 14)

a The representative modeled exposure scenario for spray applications of spirotetramat to agricultural crops resulting Currently Registered Uses (NC apples aerial; 0.4; 3;7) Proposed New Usesc (FL avocado aerial1

. -- in the highest EECs. ~pplication rate in 1ba.i./A andinterval between applications in days: - Toxicity values arebased on studies with duckweed (Lemnagibba)for vascular plants (ECS0 =4620 pg a.i./L; NOAEC=1540 pg a.i./L)and marine diatoms (Skeletonema costatum) for non-vascular plants (EC5, = 360 pg a.i./L; NOAEC=124 pg a.i./L). ECSo values are used to derive RQs for non-endangered species while NOAEC values are used to determine RQs for endangered species. All ofthe highest calculated RQs fiom the previous assessment and for the proposed new uses are below the acute LOC (1)for aquatic plants. Therefore, all RQs for both vascular and non-vascular aquatic plants for all uses arebelow the Agency's LOCs.

Includes non-extracted residues in the EECs. 11.4

4.89 0.0317

0.0136 0.0025

0.001 0.0919

0.0394 0.0074

0.00320.16 lb &A "EECs arebased on the most conservative modeling scenario possible for spirotetramat. Specifically, it was assumed that spirotetramat was not ground incorporated, it was applied at the maximum single application rate with aerial application methods (driftfraction =0.05), and that the solubility is greater than 100mgL(solubility fraction=0.05).

Sheet runoff Channelized Runoff * For aerial applications the EEC = application rate x 0.05; for ground applications the EEC = application rate x 0.01.

EEC = Sheet Runoff +Drift EEC =Channelized Runoff+Drift 

### Data Requirement Tables 0.088 Unincorporated; 0.16 lb a.i./A Proposed New Uses

835.2120 Hydrolysis 46904405, Acceptable 46904426 no 0.016 0.008

835.2240

835.2410 0.08 Aerial Spray Application, Unincorporated;

835.2370 

# I Anaerobic Soil Metabolism 0.008

Photodegradation in Water Photodegradation on Soil

835.4100



# . I Acceptable 

# 1 46904410 Photodegradation in Air 46904406* 46904503,

Aerobic Soil Metabolism 47576502
No Data

835.4400

835.4300 Acceptable
Supplemental

46904408, 46904409, 46904428 no

Waived**

Anaerobic Aquatic Metabolism Aerobic Aquatic Metabolism no

no Acceptable no

46904411

469044 12 Acceptable
Acceptable no

noTestSubstantee

Av~an Reproduct~on

to BY108330 In

Leaching-Adsorption1

835 1410
835.8100
835.6100

835.6200

835.6300
850.1730
*An additional study with no MRID; **Waived based on low vapor pressure and Henry's law constant; ***Waived based on low octanollwater partition coefficient Laboratory Volatility Field Volatility
Terrestrial Field Dissipation

Aquatic Field Dissipation Forestry Dissipation
Accumulation in Fish 46904425, 46904432, 46904433
No Data
No Data
4690442 1, 46904422, 46904423, 46904424, 469044 17
No Data

No Data
No Data Waivedf*
Waived** Acceptable

NIA

N/A
Waived*** no

no

no

no

no

no81-1 Acute Mammalian 870.1 100 Oral LDSO TEP(OD 150) 46904576 TEP (SC 240) 46904585 Spirotetramat-ketohydroxy 46904593 Spirotetetramat-di-hyroxy 46904598

Mammalian 

## I TGAI 

## 1 46904546 

## 1 NO 

## I

Acute Freshwater Fish 72-1 l CrAl TGA1 TGAI

717- -- --- Acute Freshwater Fish Yes 850.1075

72-4 850.1400 

# 1 46904439 Dorgerloh,

2004b 

# 1 l CrAl TGA1 TGAI

Spirotetramat-ketohydroxy
Water-only exposure Methoxycyclohexylamino carboxylic

No data submitted 850.1075

72-4 850.1400 Lcso

Freshwater Fish Early Life-Stage 46904439 Dorgerloh,

2004b Lcso

Freshwater 1 Life-S TEP (OD 150) TEP (SC 240) Spirotetramat-en01

TGA1 Yes I I TI Spirotetramat-en01 46904460 46904468 46904475
46904442 No 

### 1 I 

### 1 I


### I 

### INodata submitted

Nodata submitted

No data submittedTGAI 46904449 144-1 Acute Honeybee TEP (SC 240) 46904469 No Contact and Oral TEP (OD 150) 46904461 850.3020 Toxicity Test

141-2 

# I Residues on Foliage Honev Bee Toxicity 

# I No data submitted 850.3030 Test 

### I I Spirotetramat-4-methoxy- Earthworm Sub- 47319101 No 850.6200 chronicToxicity cyclohexanone Earthworm Acute TGAI 46904455 Non-guideline 46904472 No Toxicity Spirotetramat-ketohydroxy Earthworm Growth Moser & and Reproductive Spirotetramat-enol Scheffczyk, No Non-guideline Toxicity 2005 48-hour Contact of Parasitoid Wasps with Waltersdorfer, TEP (OD 150) No Non-guideline Dried Residues on 2005a Treated Glass Plates

7-day Contact of Predatory Mite with TEP (OD 150) Waltersdorfer, 2005b No Nan-guideline Dried Residues on Treated Glass Plates 48-hour Contact of Parasitoid Wasp with Waltersdorfer, TEP (OD 150) No Non-guideline Dried Residues on 2006a Treated Barley Plants

7-day Contact of Predatory Mite with Waltersdorfer, TEP (OD 150) No ~on-~uidkline Dried Residues on 2005c Treated Bean Leaves

7-day Contact of Predatory Mite with Waltersdorfer, Dried Residues (acute TEP (OD 150) No 2006c Non-guideline and aged ontreated 

## I appleleaves) 

### I 1 Exvosure Until I 

### 1 upa at ion ofGreen 

### I



### acew win^ with Dried 

# I Residues on Treated 

# I TEP (OD 150) 

### I Bean Leaves ExposureUntil 

### 1 pupation Ladybird Beetle with Dried Non-guideline Residues on Treated Bean Leaves and TEP (OD 150) Roehlig, 2005 No

Waltersdorfer, 2006b No
Aph~ds 28-day Contact of Moser & Gamasld M~tes w~th Splrotetramat-en01 Scheffczyk, No Non-guldellne Contaminated So11 2005 Ter&IWStrrdies I I 1 46904462 1 TEP (OD 150) 47563302 Field Test for 850.3040 47563303 In Reserve Pollinators 47563304 Honey Bee Feeding TEP (OD 100) 46904458 Non-guideline 46904470 No Test TEP (SC 240)Brood Effects in

TEP (OD 150)