UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

 WASHINGTON, D.C. 20460 

 

 oFFICE PREVENTION, 

 PESTICIDES AND TOXIC SUBSTANCES 

MEMORANDUM July 28, 2010

SUBJECT: Summary of Ecotoxicity Data and Risk Assessment of three 

Nitrophenolates (Sodium 5-Nitroguaiacolate, Sodium oNitrophenolate, Sodium p-Nitrophenolate) for the Registration Review 

Decision Document. 

EPA Reg No.: 64922-5 

Registration Review 

Case#: 6067 

CAS No.: 67233-85-6; 824-39-5; 824-78-2. 

PC Code: 129075; 129076; 129077. 

FROM: Miachel Rexrode, Ph.D., Senior Biologist /s/ 07/28/2010 

Biochemical Pesticides Branch 

Biopesticide & Pollution Prevention Division (7511P) 

TO: Driss Benmhend, Regulatory Action Leader 

Biochemical Pesticides Branch 

Biopesticide & Pollution Prevention Division (7511P) 

THE FOLLOWING CONTAINS CONFIDENTIAL BUSINESS INFORMATION 

ACTION REQUESTED 

The following is a preliminary ecotoxicity assessment for the Nitrophenolates, Sodium 5-

Nitroguaiacolate, Sodium o-Nitrophenolate, and Sodium p-Nitrophenolate in support of 

the Registration Review Work Plan for Atonik PGR. 

1
 

 

 

RECOMMENDATIONS AND CONCLUSIONS 

Executive Summary

Based on the available information for Atonik PGR, the Agency does not foresee the 

need for additional ecotoxicity data for a new risk assessment. All Tier I data 

requirements per 40 CFR 158.2060 have been fulfilled for the three active ingredients. 

Hazard and exposure data on these chemicals were evaluated against current standards 

established by the Agency’s scientific policies and regulations. The unique characteristics 

of this product, its non-toxic mode of action, low use volumes (< 20g/A), and 

biodegradability (low to no persistence) should minimize the risks to all non-targets. The 

Agency has reviewed the available ecotoxicity data and completed a risk assessment 

using the maximum application of Atonik to an agricultural crop. Atonik is relatively 

nontoxic to honey bees and exposure of this product to non-target terrestrial and aquatic 

species should not pose toxic risk. Since, Atonik is intended for use as a plant growth 

enhancer and will be aerially applied to rice, soybean, and cotton crops; there is a 

possibility of drift to adjacent vegetative areas. The Agency, however, has evaluated the 

potential for indirect exposure to plants and concludes that this exposure will be minimal 

and not efficacious resulting in residue levels that are 2-3 orders of magnitude below field 

levels that were found to not be effective (Bynum et al., 2007). The Agency concludes 

that exposure of Atonik to fish and wildlife and to listed/threatened species and their 

supporting habitat will result in a No Effect (NE). 

I. Background 

Atonik is a plant growth regulator (PGR), and is composed of three active ingredients, 

Sodium p-Nitrophenolate (0.3%); Sodium o- Nitrophenolate (0.2%); Sodium 5-

Nitroguaiacolate. The three active ingredients are similar to each other in structure, 

function and toxicity and appear to enhance fertilizer uptake, crop growth and yield. 

Currently, there are five products that are registered containing the biochemicals. One 

product is an end-use product (EP) that contains all three PGRs (EPA Reg. No.: 64922-1) 

as its active ingredients. Four products are manufacturing-use products (MPs); one 

contains Sodium 5-Nitroguaiacolate (EPA Reg. No.: 64922-2) as its active ingredient, 

one contains Sodium p-Nitrophenolate (EPA Reg. No.: 64922-3) as its active ingredient, 

one contains Sodium o-Nitrophenolate (EPA Reg. No.: 64922-4) as its active ingredient, 

and the last contains all three active ingredients (EPA Reg. No.: 64922-5). The EP is used 

on cotton, rice and soybean plants. 

 

II. Toxicity Profile 

Avian Toxicity Studies 

An acute oral toxicity study using the technical grade of the active ingredient (TGAI) is 

required to establish the toxicity of the plant stimulant, Atonik PGR (sodium 5-

nitroguaiacolate; Sodium o-nitrophenolate; Sodium p-Nitrophenolate) to birds. The 

2
 

 

 

preferred test species is either mallard duck (Anas platyrhynchos; a waterfowl) or 

Bobwhite quail (Colinus virginianus; an upland game bird). Results of these studies are 

summarized below in Table 1.0. Atonik PGR has been shown to be practically non-toxic 

to avian species as noted in the Bobwhite quail acute and dietary studies where toxicity 

ranges from LD50 > 2,000 mg/kg to LC50 = 5,620 ppm. One exception was Sodium oNitrophenolate that is considered slightly toxic at LD50 = 1,046 mg/kg. The results of 

these studies suggest that Atonik PGR should not cause any adverse effects to avian 

wildlife. 

Table 1.0 Summary of Avian Toxicity for Atonik PGR

Species Sodium 5-

Nitroguaiacolate 

Sodium oNitrophenolate Sodium pNitrophenolate MRID No. 

850.2100 

Acute Oral 

Bobwhite quail 

(Colinus 

virginianus)

LD50>2,000 mg/kg 

Practically nontoxic 

LD50 = 1,046 mg/kg 

Slightly toxic 

LD50 = 2,000 mg/kg 

Practically nontoxic 

41852201 

41854802 

41868505 

850.2200 

Acute Dietary 

Bobwhite quail 

(Colinus 

virginianus)

LC50>5,620 ppm 

Practically nontoxic 

LC50>5,620 ppm 

Practically nontoxic 

LC50>5,620 ppm 

Practically nontoxic 

41868506 

41854803 

41852202 

Mammal Studies 

Summaries of the most sensitive toxicity values (acute) for mammals are shown in Table 

2.0. The acute oral toxicity was found to ranged from LD50 = 345.5 – 960.1 mg/kg 

suggesting slight toxicity. Exposure to these compounds should not result in acute 

dermal effects (2,000 mg/kg) or significant acute inhalation effects (>1.2-2.3 mg/L). 

Studies on prenatal development showed maternal NOEL and LOEL at 300 and 600 

mg/kg/day and developmental NOEL = 600 mg/kg (no toxicity). The results of these 

studies suggest that Atonik PGR should not cause any adverse effects to mammalian 

wildlife 

Table 2.0 Summary of Mammalian Toxicity Studies for Atonik PGR 

Test Sodium 5-

Nitroguaiacolate 

Sodium oNitrophenolate Sodium pNitrophenolate MRID 

No. 

870.1100 

Acute Oral Toxicity 

 

LD50 = 716 mg/kg 

Tox Cat 

III 

LD50 = 960.1 mg/kg 

Tox Cat 

III 

LD50 = 345.5 mg/kg 

Tox Cat 

II 

41897901 

41868401 

41868501 

870.1200 

Acute Dermal 

> 2,000 mg/kg 

Tox Cat 

III 

> 2,000 mg/kg 

Tox Cat 

III 

> 2,000 mg/kg 

Tox Cat 

III 

41868602 

41868402 

41868502 

870.1300 

Acute Inhalation 

>2.3 mg/L 

Tox Cat 

IV 

>1.24 mg/l 

Tox Cat 

III 

>1.2 mg/L 

 Tox Cat 

 III 

43070307 

43072007 

43071907 

870.3700 

Prenatal 

Developmental 

Maternal NOEL 

=300 mg/kg/day; 

Maternal LOEL=600 

Maternal NOEL 

=300 mg/kg/day; 

Maternal LOEL=600 

Maternal NOEL 

=300 mg/kg/day; 

Maternal LOEL=600 

43070203 

43070203 

43070203 

3
 

 

 

Test Sodium 5-

Nitroguaiacolate 

Sodium oNitrophenolate Sodium p- MRID 

Nitrophenolate No. 

mg/kg/day; 

Developmental 

NOEL = 600 

mg/kg/day (no 

toxicity ) 

mg/kg/day; 

Developmental 

NOEL = 600 

mg/kg/day (no 

toxicity ) 

mg/kg/day; 

Developmental 

NOEL = 600 

mg/kg/day (no 

toxicity ) 

Honey Bee Toxicity 

Atonik PGR appears to be nontoxic to honey bees as noted in acute contact studies with 

LD50 = 100 – 111 ug/bee (Table 3.0). The results of these studies suggest that Atonik 

PGR should not cause any adverse effects to beneficial insects. 

Table 3.0 Summary of Honey Bee Toxicity for Atonik PGR

Test Species Sodium 5-

Nitroguaiacolate 

Sodium oNitrophenolate Sodium pNitrophenolate MRID No. 

880.4350 

Honey bee 

(Aphis 

LD50 = 100 ug/bee 

Nontoxic 

LD50 = 100 ug/bee 

Nontoxic 

LD50 = 111 ug/bee 

Nontoxic 

41868509 

41852205 

41854805 

Non target Plant Testing 

Plant testing of biological pest control agents is conditionally required if incidents have 

occurred or if there is published information that the compound is toxic to plants. 

Therefore, to the best of our knowledge none of these compounds are known to be 

phytotoxic. 

Aquatic Toxicity Studies 

The Agency has summarized available acute aquatic studies and concluded that Atonik 

PGR is slightly toxic to fish with LC50 = 25.0 – 69.0 mg/L and slightly toxic to aquatic 

invertebrates with 48 hr EC50 = 27.7 – 84.5 mg/L (Table 4.0). 

 

Table 4.0 Summary of Aquatic Toxicity Studies for Atonik PGR 

Species Sodium 5-

Nitroguaiacolate 

Sodium oNitrophenolate Sodium pNitrophenolate MRID No. 

Fish

850.1075 

Rainbow trout 

(Oncorhynchus 

mykiss) 

96 hr LC50 = 37.4 

mg/L 

Slightly toxic 

96 hr LC50 = 

69.0 mg/L 

Slightly toxic 

96 hr LC50 = 

25.0 mg/L 

Slightly toxic 

41944701 

41852203 

41868507 

Aquatic Invertebrates

850.1010 

Daphnia magna

48 hr EC50 84.5 

mg/L 

Slightly toxic 

48 hr EC50 68.8 

mg/L 

Slightly toxic 

48 hr EC50 27.7 

mg/L 

Slightly toxic 

41854804 

41852204 

41868508 

4
 

 

 

Species Sodium 5-

Nitroguaiacolate 

Sodium o- Sodium p- MRID No. Nitrophenolate Nitrophenolate 

Ecological Assessment 

Ecotoxicity Risk 

Aquatic 

Atonik (nitrophenolates) is used as a plant growth regulator to enhance fertilizer uptake 

and crop yield on soybeans, rice, and cotton. The three nitrophenolates compounds that 

make-up Atonik are applied at a total rate of 20 g ai/A per application and are rapidly 

absorbed and converted to compounds that are naturally found in plants. In order to 

assess potential risk to aquatic ecosystems the Agency has estimated environmental 

concentrations (EECs) of Atonik from runoff after applications to terrestrial crops. Using 

the GENeric Estimated Environmental Concentration model (GENEEC; EPA, 2001) the 

Agency assumed 2 maximum applications of end product at 0.004lbs ai/A (4g ai/A) at 7 

day intervals, assume a one day aquatic half-life, a one day photodegradation half-life in 

water, and a one day half-life in aerobic soil. The peak aquatic EEC was calculated at a 

about 0.000031 ppm which declined to about 0.000005 ppm after 21 days (Table 5.0). 

Since the LC50 values for fish and aquatic invertebrates is 37.4mg/L and 84.5mg/L this 

would result in Risk Quotients (RQs) of 0.00 and 0.00, respectively, well below the 

Agency’s Levels of Concern (LOCs = 1.0 - 0.5), suggesting no risk concerns for 

aquatic species.

Table 5.0 Generic Estimated Environmental Concentrations (EECs) of Atonik in Aquatic 

Sites using the GENEEC Model, ver 2.0 (EPA, 2001) in Parts Per Trillion (pptr)

Table Peak EEC Max 4 Day 

Avg EEC 

Max 21 Day 

Avg EEC 

Max 60 Day 

Avg EEC 

Max 90 Day 

Avg EEC 

31.22 20.64 4.97 1.74 1.16 

Terrestrial 

In order to evaluate risk of Atonik (nitrophenolates) exposure to terrestrial species, the 

Agency has estimated RQ values using the Terrestrial Residue Exposure Model (T-REX) 

Version 1.4.1. A terrestrial risk assessment includes calculated expected residues, as well 

as, numerous calculations of dietary exposure for multiple weight class animals 

(Appendix B). Expected residues were calculated for avian and mammalian food items 

along with dissipation rate of a chemical applied to foliar surfaces (single or multiple 

applications) in order to estimate worst case acute RQs relative to weight class for 

various sized birds and mammals. These calculations showed upper bound Kenega values 

and that exposure to Atonik (0.004lbs ai/A) has a low potential for toxic impact to birds 

(RQ = 0.00) and mammals (RQ= 0.00) that may be feeding in the area of application as 

noted in Appendix B. The unique characteristics of this product, the non-toxic mode of 

action, biodegradability and low potential for exposure will result in no risk to all nontarget terrestrial organisms.

5
 

 

 

Endangered Species Risk Assessment 

Terrestrial and Aquatic Animals 

The unique characteristics of this product, Atonik PGR, its non-toxic mode of action, low 

use volumes (< 20g/A), and biodegradability (low to no persistence) should minimize the 

risks to all non-targets, including threatened and endangered aquatic and terrestrial 

animal species. Due to the non-toxic mode of action and/or lack of exposure to nontargets by this product, and Risk Quotient (RQ) calculated at 0.00 for terrestrial and 

aquatic non-target species toxic risk and/or exposure to listed and endangered/threatened 

species will be at or near zero. The Agency’s Individual Effects Chance Model Version 

1.1 (Table 6 and 7) was used to further estimate the chance of risk to endangered/ 

threatened avian and aquatic species from exposure to Atonik. These values (avian risk at 

1 in 294,000 and aquatic risk at 1 in 418,000,000) show that Atonik will not cause toxic 

risk to these endangered/threatened species. The mode of action of Atonik is to enhance 

plant growth, however, calculated residues from an expected drift scenario shows that 

these levels will be minimal and non efficacious (refer to Plant section) and will not 

cause an indirect effect in terrestrial and aquatic habitat. The Agency concludes that 

Atonik exposure is a No Effect (NE) for terrestrial and aquatic species. 

Table 6.0 Individual Effects Chance Model Version 1.1 

(Terrestrial Species) 

Enter LC50 or LD50 2000

Enter desired threshold 0.1

Enter slope of dose-response 4.5

z score result -4.5

Probability associated with z 3.40E-06

Chance of individual effect, ~1 in . . . 2.94E+05

Table 7.0 Individual Effects Chance Model Version 1.1 

(Aquatic Species) 

Enter LC50 or LD50 27.7

Enter desired threshold 0.05

Enter slope of dose-response 4.5

z score result -5.85463498

Probability associated with z 2.39E-09

Chance of individual effect, ~1 in . . . 4.18E+08

Plants 

Plant testing of biological pest control agents is conditionally required if incidents have 

occurred or if there is published information that the compound is toxic to plants. 

Therefore, to the best of our knowledge Atonik is not known to be phytotoxic. 

Positive effects, however, are problematic when it comes to measurement or observation 

in the field and thresholds will be different for various plant species relative to 

environmental conditions. Since Atonik is intended for use as a plant growth enhancer 

6
 

 

 

and will be aerially applied to rice, soybean, and cotton crops, there is a possibility of 

drift to adjacent vegetative areas. This indirect exposure, however, is minimal and not 

efficacious. The Agency has made this conclusion by noting that the direct application 

scenario for target plants can result in expected residues of 0.02 – 1.1 g ai/A (T-REX). 

Bynum et al., (2007) found that the use of nitrophenolates (Chaperone) on cotton 

increased yield after application of 0.69 g ai/A, but was not efficacious at 0.17 – 0.34 g 

ai/A. In evaluating Atonik aerial application to a crop the Agency has assumed a worst 

case scenario of about 5% drift from the target site onto adjacent areas that can result in 

expected residues ranging from 0.001 – 0.06 g ai/A with significant decreases farther 

from the target site. These values are about 2 -3 orders of magnitude below the non 

efficacious levels found by Bynum et al., (2007) and illustrates that indirect exposure of 

Atonik to non-target plants (listed threatened or endangered plant species or any 

designated critical habitat) will result in No Effect (NE). 

Ecological Effects Summary 

The Agency has reviewed the available ecotoxicity data and completed a risk assessment 

using the maximum application of Atonik to an agricultural crop. Atonik is relatively 

nontoxic to honey bees and exposure of this product to terrestrial and aquatic animal 

species (non-target or listed/threatened species) should not pose a toxic risk. Since, 

Atonik is intended for use as a plant growth enhancer and will be aerially applied to rice, 

soybean, and cotton crops; there is a possibility of drift to adjacent vegetative areas. The 

Agency, however, has evaluated the potential for indirect exposure to plants and 

concludes that this exposure will be minimal and not efficacious resulting in residue 

levels that are 2-3 orders of magnitude below field levels that were found to not be 

effective (Bynum et al., 2007). The Agency concludes that exposure of Atonik to fish and 

wildlife and to listed/threatened species and their supporting habitat will result in a No 

Effect (NE). 

III. References 

Bynum, J.B., Cothren, J.T., Lemon, R.G., Fromm, D.D., Boman, R.K. 2007. Field 

evaluation of nitrophenolate plant growth regulator (Chaperone) for the effect on cotton 

lint yield. J. Cotton Sci. 11: 20-25. 

Parker, R.D., R.D. Jones and H.P. Nelson., 1995. GENEEC: A Screening Model for 

Pesticide Environmental Exposure Assessment., in Proceedings of the International 

Exposure Symposium on Water Quality Modeling; American Society of Agricultural 

Engineers, pp. 485-490; Orlando, Florida. 

U.S. EPA Fact Sheet for Sodium 5-Nitroguaiacolate (129075), Sodium o-Nitrophenolate 

(129076), Sodium p-Nitrophenolate (129077). Issued August, 2001.

7
 

 

 

U.S. EPA. Federal Register: October 26, 2007 (Volume 72, Number 207) Page 61008-

61011. 

U.S. EPA. 1998. Guidance for Ecological Risk Assessment. Risk Assessment Forum. 

EPA/630/R-95/002F, April 1998. 

U.S.EPA 2004. Individual Effects Chance Model Version 1.1. EFED/OPP/USEPA. 

U.S.EPA 2008. Terrestrial Residue Exposure Model (T-REX) Version 1.4.1. 

EFED/OPP/USEPA. 

8
 

 

 

Appendix A 

GENEEC Model Output for Atonik Application to Soybeans 

 ATONIK SOYBEANS * INPUT VALUES * 

 -------------------------------------------------------------------- 

 RATE (#/AC) No.APPS & SOIL SOLUBIL APPL TYPE NO-SPRAY INCORP 

 ONE(MULT) INTERVAL Kd (PPM ) (%DRIFT) ZONE(FT) (IN) 

 ------------------------------------------------------------------------------------------------------- 

 .004( .004) 2 7 100.0 100.0 ERL_B( 13.0) .0 .0 

 FIELD AND STANDARD POND HALFLIFE VALUES (DAYS) 

 -------------------------------------------------------------------- 

 METABOLIC DAYS UNTIL HYDROLYSIS PHOTOLYSIS METABOLIC COMBINED 

(FIELD) RAIN/RUNOFF (POND) (POND-EFF) (POND) (POND) 

 -------------------------------------------------------------------------------------------------------------------- 

 1.00 0 N/A 1.00- 124.00 1.00 .99 

 GENERIC EECs (IN NANOGRAMS/LITER (PPTr)) 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 

 --------------------------------------------------------------------------------------------------------- 

 31.22 20.64 4.97 1.74 1.16 

9
 

 

 

Appendix B TREX Output for Terrestrial Exposure and Risk from Atonik 

Application to Soybeans

Avian Results

Avian Body Ingestion (Fdry) Ingestion (Fwet) % body wgt FI

Class Weight (g) (g bw/day) (g/day) consumed (kg-diet/day)

Small 20 5 23 114 2.28E-02

Mid 100 13 65 65 6.49E-02

Large 1000 58 291 29 2.91E-01

Avian Body Adjusted LD50

Weight (g) (mg/kg-bw)

20 1038.45

100 1322.00

1000 1867.37

small mid large

20 g 100 g 1000 g

Short Grass 1.10 0.63 0.28

Tall Grass 0.51 0.29 0.13

Broadleaf plants/sm Insects 0.62 0.35 0.16

Fruits/pods/seeds/lg insects 0.07 0.04 0.02

20 g 100 g 1000 g

Short Grass 0.00 0.00 0.00

Tall Grass 0.00 0.00 0.00

Broadleaf plants/sm insects 0.00 0.00 0.00

Fruits/pods/seeds/lg insects 0.00 0.00 0.00

Acute Chronic

Short Grass 0.00 #DIV/0!

Tall Grass 0.00 #DIV/0!

Broadleaf plants/sm Insects 0.00 #DIV/0!

Fruits/pods/seeds/lg insects 0.00 #DIV/0!

Dietary-based RQs RQs

(Dietary-based EEC/LC50 or 

NOAEC)

Avian Acute RQs Dose-based RQs 

(Dose-based EEC/adjusted LD50)

Avian Classes and Body Weights Dose-based EECs 

(mg/kg-bw) 

10
 

 

 

Mammalian Results

Mammalian Body Ingestion (Fdry) Ingestion (Fwet) % body wgt FI

Class Weight (g bwt/day) (g/day) consumed (kg-diet/day)

15 3 14 95 1.43E-02

Herbivores/ 35 5 23 66 2.31E-02

insectivores 1000 31 153 15 1.53E-01

15 3 3 21 3.18E-03

Grainvores 35 5 5 15 5.13E-03

1000 31 34 3 3.40E-02

Mammalian Body Adjusted Adjusted

Class Weight LD50 NOAEL

15 759.35 659.35

Herbivores/ 35 614.40 533.48

insectivores 1000 265.74 230.75

15 759.35 659.35

Grainvores 35 614.40 533.48

1000 265.74 230.75

15 g 35 g 1000 g 15 g 35 g 1000 g

Short Grass 0.92 0.64 0.15

Tall Grass 0.42 0.29 0.07

Broadleaf plants/sm Insects 0.52 0.36 0.08

Fruits/pods/seeds/lg insects 0.06 0.04 0.01 0.01 0.01 0.00

Acute Chronic Acute Chronic Acute Chronic

Short Grass 0.00 0.00 0.00 0.00 0.00 0.00

Tall Grass 0.00 0.00 0.00 0.00 0.00 0.00

Broadleaf plants/sm insects 0.00 0.00 0.00 0.00 0.00 0.00

Fruits/pods/lg insects 0.00 0.00 0.00 0.00 0.00 0.00

Seeds (granivore) 0.00 0.00 0.00 0.00 0.00 0.00

Acute Chronic

Short Grass #DIV/0! 0.00

Tall Grass #DIV/0! 0.00

Broadleaf plants/sm insects #DIV/0! 0.00

Fruits/pods/seeds/lg insects #DIV/0! 0.00

Dietary-based RQs 

(Dietary-based EEC/LC50 or 

NOAEC)

Mammal RQs

15 g mammal 35 g mammal 1000 g mammal Dose-based RQs 

(Dose-based EEC/LD50 or NOAEL)

Granivores

Mammalian Classes and Body weight

Dose-Based EECs 

(mg/kg-bw)

Herbivores/ insectivores

11
 

 

 

Appendix C Risk Conclusions for Listed Threatened/Endangered Species 

Table C-1. Summary of risk conclusions for listed threatened and endangered species that may be 

exposed to Atonik 

Species Risk Conclusion Presumptions 

Aquatic Animal Species No Effect 

Occurs in habitat that may be 

affected by application. Toxicity 

values indicate no potential direct 

(acute and chronic effects) or 

indirect (changes in water quality 

parameters; loss of cover/food) 

effects. Residue levels are not 

efficacious. 

Terrestrial Animal Species No Effect 

Occurs in habitat that may be 

affected by application. Toxicity 

values indicate no potential direct 

(acute and chronic effects) or 

indirect (changes in water quality 

parameters; loss of cover/food) 

effects. Residue levels are not 

efficacious. 

Terrestrial Animal Species No Effect 

Occurs in habitat that may be 

affected by application. Toxicity 

values indicate no potential direct 

(acute and chronic effects) or 

indirect (changes in water quality 

parameters; loss of cover/food) 

effects. Residue levels are not 

efficacious. 

Terrestrial Plants No Effect 

Occurs in habitat that may be 

affected by application. Toxicity 

values indicate no potential direct 

(acute and chronic) effects. 

Indirect effects from drift are not 

expected because residues are 2-3 

orders of magnitude below levels 

that were found to not be 

efficacious. 

Aquatic Plants 

No Effect 

Occurs in habitat that may be 

affected by application. Toxicity 

values indicate no potential direct 

(acute and chronic) effects. 

Indirect effects from drift are not 

expected because residues are 2-3 

orders of magnitude below levels 

that were found to not be 

efficacious. 

12