Risk Assessment of the Fungicide Luna Privilege with the Active Substance Fluopyram
Authors: Sverdrup Line Emilie , Bjørge Christine , Eklo Ole Martin , Grung Merete , Källqvist Torsten , Klingen Ingeborg , Låg Marit , Ropstad Erik , Rivedal Edgar 
Published: August 2022

Luna Privilege is a new fungicide for use in apples, pears, outdoor and indoor strawberries, outdoor and indoor lettuces, peas, beans and indoor tomatoes, and contains the new active substance fluopyram.
VKM was requested by the Norwegian Food Safety Authority to consider the possible health risk for operators related to the properties of Luna Privilege and fluopyram; in particular to evaluate the potential for bioaccumulation, reproductive and neurotoxic effects, and discuss possible mechanisms involved in liver and thyroid tumor formation observed in rats, and the establishment of NOAELs and reference values.
VKM was also asked to evaluate the fate and behaviour of fluopyram in the environment, and the ecotoxicological effects and risks related to its use, in particular the potential for groundwater contamination, safety margins and possible effects on birds and aquatic organisms.
The assessment was finalized in a meeting on December 13. 2013 by VKM’s Panel on Plant Protection Products.
VKM’s conclusions are as follows:
Health:
It is the opinion of VKM that:

The active ingredient fluopyram has low potential for bioaccumulation, and the data do not suggest a sex-specific excretion.

An in vivo Comet Assay in rat liver could help to further elucidate the genotoxic potential of fluopyram.

It can not be excluded that the reported incidence of “gall bladder absent” is treatment related.

NOAEL for the 90-day feeding study in rats should be set to 3.06 mg/kg bw/day, resulting in an AOEL of 0.03 mg/kg bw/day.

The “dumb-bell or incomplete ossification and/or bipartite/normal cartilage” should be considered as a malformation and regarded as treatment related.

The time points used for neurotoxic measurements are not optimal to detect neurotoxic effects from acute exposure, since the time window between the first and second measurements is too long.

The studies where effects of fluopyram and phenobarbital are compared can not be used to exclude human relevance of the tumor-inducing effect of fluopyram in the liver of female rats.

The results from the mechanistic studies are insufficient to support the proposed mode of action for the induction of thyroid follicular cell tumors in male mice, and thus the induction of thyroid tumors in male mice could be relevant for humans.

VKM proposes:

NOAEL of 1.2 mg/kg bw/day based on a 2 year feeding study in rats.

ADI: 0.012 mg/kg bw/day

AOEL: 0.03 mg/kg bw/day

ARfD: 0.25 mg/kg bw/day

Risk calculations for field use of Luna Privilege show minimal risk if personal protective equipment is used. The AOEL of fluopyram for greenhouse use is not exceeded, even without protective equipment. Re-entry and bystander exposure is calculated to be well below the AOEL.
Environment:
It is the opinion of VKM that:

Worst case degradation rates from laboratory studies should preferably be used to calculate PECsoil values for fluopyram.
Both fluopyram and fluopyram-7-hydroxy have a high potential for groundwater contamination.

The efficacy of buffer zones needs to be considered on a case-by-case basis, and further validation of values for efficacy from the model simulation is necessary.

It is further the opinion of VKM that all the refinements used in the risk assessment for birds are relevant. Since the TER values estimated for all crops except for orchards are below the trigger following refinements, it is the view of VKM that the data indicate medium risk for strawberries and pulses, and high risk for lettuce in open field.

The use of LC50 values for fluopyram in the TER calculations with a TER trigger value of 100 is overly conservative, and a reduction of the acute trigger for both invertebrates and fish from 100 to 10 for such calculations are suggested.

The trigger for acute toxicity is not exceeded for any of the crops. For chronic toxicity, VKM concludes that there is a moderate risk for effects on fish when Luna Privilege is applied to beans/strawberries without the use of a vegetated mitigation buffer-strip.