UNITED
STATES
ENVIRONMENTAL
PROTECTION
AGENCY
WASHINGTON,
D.
C.
20460
OFFICE
OF
PREVENTION,
PESTICIDES,
AND
TOXIC
SUBSTANCES
DP
Barcode:
D288451
PCCode:
056801
Date:
March
18,
2003
MEMORANDUM:

SUBJECT:
Revised
EFED
Risk
Assessment
of
Carbaryl
in
Support
of
the
Reregistration
Eligibility
Decision
(
RED)

To:
Anthony
Britten,
PM
Team
Reviewer
Michael
Goodis,
Product
Manager
53
Special
Review
and
Reregistration
Division
(
7508C)

FROM:
R.
David
Jones,
Ph.
D.,
Senior
Agronomist
Thomas
Steeger,
Ph.
D.,
Senior
Biologist
Environmental
Risk
Branch
IV
Environmental
Fate
and
Effects
Division
(
7507C)

THRU:
Elizabeth
Behl,
Chief
Environmental
Risk
Branch
IV/
Environmental
Fate
and
Effects
Division
(
7507C)

The
Environmental
Fate
and
Effects
Division
has
revised
the
Environmental
Fate
and
Ecological
Risk
Assessment
chapter
in
support
of
the
reregistration
eligibility
decision
on
carbaryl.
The
chapter
has
been
revised
to
incorporate
recently
received
fate
and
effects
data
and
to
reflect
comments
received
during
the
public
comment
phase
of
the
review
process.
The
revised
chapter
is
attached
and
contains
more
detailed
information
on
drinking
water
monitoring
studies
and
specialized
uses
of
carbaryl,
i.
e.,
Section
24c
use
of
carbaryl
to
control
burrowing
shrimp
and
the
use
of
carbaryl
for
the
U.
S.
Department
of
Agriculture
Animal
and
Plant
Health
Inspection
Service's
grasshopper
and
Mormon
cricket
suppression
program.

In
general,
carbaryl
is
not
likely
to
persist
in
the
environmental;
however
owing
to
its
mobility
and
it
extensive
use,
the
chemical
is
frequently
detected
in
surface
water
and
to
a
much
lesser
extent
in
groundwater.
Urban
use
of
carbaryl
appears
to
serve
as
a
primary
source
of
carbaryl
residues
in
surface
water.
Carbaryl's
primary
degradate,
1­
naphthol,
is
expected
to
degrade
more
rapidly
and
be
less
mobile
than
the
parent.
Since
1­
naphthol
has
many
natural
and
anthropogenic
sources
other
than
carbaryl
degradation,
the
presence
of
this
compound
cannot
be
used
as
a
measure
of
carbaryl
use.
Furthermore,
the
Agency
does
not
have
soil
photolysis
(
Guideline
§
161­
3)
data
and
recommends
the
study
be
submitted.
The
registrant
voluntarily
expended
considerable
effort
to
conduct
drinking
water
monitoring
studies
independent
of
the
Agency;
however,
EFED's
review
of
the
studies
indicated
that
the
sampling
sites
could
not
be
considered
representative
of
highly
vulnerable
current
use
sites
for
carbaryl
and
the
sampling
interval
(
one
week)
is
not
likely
to
adequately
capture
peak
concentrations.
While
the
studies
provide
useful
information
on
spatial­
temporal
trends
in
carbaryl
residues
in
drinking
water,
the
residues
cannot
be
considered
high­
end
values.
Therefore,
distributions
of
modeled
drinking
water
concentrations
were
developed
for
use
in
estimating
drinking
water
concentrations
for
the
purposes
of
human
risk
assessment.

Although
carbaryl
is
not
expected
to
persist,
its
mobility
coupled
with
high
use
is
likely
to
result
in
residues
in
both
terrestrial
and
aquatic
habitats.
Carbaryl
is
not
likely
to
represent
a
risk
of
acute
mortality
to
birds;
however,
on
the
majority
of
uses
modeled,
the
chronic
risk
level
of
concern
is
exceeded.
Based
on
estimated
environmental
concentrations,
over
75%
of
the
registered
uses
modeled
are
likely
to
represent
a
risk
of
acute
mortality
and
chronic
growth/
reproductive
effects
in
mammals.
As
with
most
chemicals,
smaller­
sized
animals
that
consume
a
larger
percentage
of
their
body
weight
are
more
vulnerable
than
larger­
sized
animals.
Carbaryl
is
also
very
highly
toxic
to
bees
and
at
current
application
rates
these
beneficial
insects
will
likely
succumb
to
acute
mortality
if
they
come
in
direct
contact
with
the
chemical
in
the
immediate
treatment
areas.

No
acute
risk
LOCs
are
exceeded
for
estuarine/
marine
fish
and
carbaryl
use
on
citrus
alone
exceeds
the
acute
risk
LOC
for
freshwater
fish.
The
acute
endangered
species
LOC
is
minimally
exceeded
for
all
freshwater
fish
as
the
magnitude
of
the
risk
quotients
is
low,
i.
e.
<
0.70).
Consistent
with
carbaryl's
classification
as
being
very
highly
toxic
to
aquatic
invertebrates,
both
acute
mortality
and
chronic
reproductive/
growth
effects
are
likely
for
freshwater
invertebrates
in
static
bodies
of
water.
In
some
cases
though,
like
the
use
of
carbaryl
to
control
burrowing
shrimp,
large
influxes
of
water
can
significantly
reduce
chemical
residues
in
nontargeted
areas.

While
controlled
studies
of
carbaryl's
affects
on
plants
do
not
indicate
that
the
chemical
is
phytotoxic,
field
incidents
suggest
otherwise.
It
is
possible
that
the
carbaryl
degradate
1­
naphthol,
a
plant
auxin,
is
impacting
the
plants
rather
than
the
parent
compound.
Additionally,
carbaryl's
toxicity
to
aquatic
invertebrates
may
reduce
the
potential
for
zooplankton
grazing
and
result
in
conditions
that
may
actually
favor
the
growth
(
survival)
of
phytoplankton.

Carbaryl
is
sufficiently
volatile
to
result
in
aerial
transport
of
the
chemical.
Consideration
should
be
given
to
reducing
the
extent
of
aerial
applications.
Given
carbaryl's
potential
to
degrade
rapidly,
mitigation
options
may
include
spraydrift
and
vegetated
runoff
buffers
to
slow
the
chemical's
movement
and
facilitate
degradation.
Additionally,
more
protracted
reapplication
intervals
would
reduce
chemical
residues.
Where
possible,
delaying
application
by
several
weeks
could
reduce
estimated
environmental
concentrations
by
roughly
30
to
40%.

Uncertainties
Although
carbaryl
is
practically
nontoxic
to
birds
on
an
acute
oral
and
subacute
dietary
exposure
basis,
there
is
some
uncertainty
regarding
the
sensitivity
of
smaller­
sized
passerine
species.
Open
literature
and
weakly
supported
field
incident
data
suggest
that
carbaryl
may
be
more
toxic
to
smaller
birds.
Aquatic
and
terrestrial
plant
testing
with
carbaryl
was
conducted
over
a
limited
range
of
species.
Given
the
field
incidents
reported
where
both
residential
and
commercial
use
of
carbaryl
has
resulted
in
plant
damage,
EFED
is
uncertain
regarding
the
extent
to
which
carbaryl
use
may
impact
nontarget
plants.
EFED
recommends
that
both
aquatic
(
Guideline
§
122­
2)
plant
growth
and
terrestrial
seedling
emergence
and
vegetative
vigor
(
Tier
2;
Guideline
§
123­
1)
testing
be
conducted
on
the
full
range
of
species.

Although
EFED
does
not
have
data
to
support
concerns
that
the
Section
24c
use
of
carbaryl
to
control
burrowing
shrimp
in
Willapa
Bay/
Grays
Harbor,
Washington,
represents
an
unreasonable
risk
to
nontarget
areas,
it
is
clear
that
carbaryl
has
to
potential
to
drift
from
its
application
area
due
to
tidal
flow.
The
extent
of
this
drift
has
been
and
continues
to
be
monitored.
EFED
encourages
stakeholders
in
the
area
to
work
together
toward
limiting
potential
drift
issues
by
continuing
studies
to
examine
alternatives.
Additionally,
consideration
should
be
given
to
treating
smaller
areas
of
contiguous
acres
to
limit
total
pesticide
loading
during
any
particular
treatment
cycle.

Given
carbaryl's
rapid
degradation
potential
under
most
conditions,
it
is
not
likely
to
represent
a
risk
to
of
chronic
exposure
in
estuarine/
marine
species.
However,
there
are
conditions,
i.
e.,
acidic
and/
or
anaerobic
environments,
where
carbaryl
can
persist.
Since
no
data
have
been
provided
on
the
chronic
effects
of
carbaryl
on
estuarine/
marine
fish
and
invertebrates,
EFED
recommends
that
Guideline
§
74­
4
studies
on
estuarine/
marine
fish
and
invertebrates
be
conducted.

Endangered
Species
The
U.
S.
Fish
and
Wildlife
Service
rendered
a
draft
biological
opinion
on
the
use
of
carbaryl
in
1989.
Since
that
time
new
uses
have
been
added
and
additional
species
have
been
listed.
Consultations
with
the
Fish
and
Wildlife
Service
and
the
National
Marine
Fisheries
Service
are
either
in
process
or
are
being
planned
to
afford
endangered
species
protection
to
the
extent
possible
under
the
Endangered
Species
Act.
Environmental
Fate
and
Ecological
Risk
Assessment
for
the
Re­
registration
of
Carbaryl
1­
Naphthyl
methylcarbamate
1­
naphthyl
N­
methylcarbamine
CAS
Registry
Number
63­
25­
2
PC
Code
056801
Prepared
by:

R.
David
Jones,
Ph.
D.
Thomas
M.
Steeger,
Ph.
D.
Elizabeth
Behl,
Branch
Chief
U.
S.
Environmental
Protection
Agency
Office
of
Pesticide
Programs
Environmental
Fate
and
Effects
Division
Environmental
Risk
Branch
IV
401
M
Street,
SW
Mail
Code
7507C
Washington,
DC
20460
Reviewed
by:
Elizabeth
Behl,
Branch
Chief
ii
EXECUTIVE
SUMMARY
Carbaryl
is
a
carbamate
insecticide
registered
for
control
of
a
wide
range
of
insect
and
other
arthropod
pests
on
over
100
agricultural
and
noncrop
use
sites,
including
home
and
garden
uses.
The
pesticide
is
a
cholinesterase
inhibitor
that
acts
on
contact
on
ingestion.
Carbaryl
dissipates
in
the
soil
environment
by
abiotic
and
microbially­
mediated
degradation.
The
major
degradation
product
is
1­
naphthol,
which
is
further
degraded
to
CO2.
Abiotic
routes
of
degradataion
include
relatively
rapid
hydrolysis
under
alkaline
conditions
and
photolysis
in
water.
Under
aerobic
conditions,
the
compound
degrades
rapidly
by
microbial
metabolism
with
half­
lives
of
4
to
5
days
in
soil
and
aquatic
environments.
Carbaryl
dissipates
rapidly
from
foliage
and
is
mobile
in
the
environment;
however,
the
compound
will
increasingly
partition
to
sediment
as
organic
carbon
content
increases.
Both
urban
and
agricultural
use
have
been
associated
with
detections
in
all
environmental
compartments.
Carbaryl
is
not
expected
to
bioaccumulate.

Fate
data
on
the
primary
degradate,
is
limited;
however,
1­
naphthol
appears
to
be
somewhat
mobile
but
is
not
likely
to
persist
due
to
fairly
rapid
degradation.
Since
1­
naphthol
can
occur
from
a
variety
of
natural
and
anthropogenic
processes,
its
presence
cannot
be
considered
indicative
of
carbaryl
use.

Carbaryl
has
been
frequently
detected
in
surface
water
monitoring
studies
and
although
infrequent,
in
ground
water
monitoring
studies
as
well.
Based
on
these
data,
residential
use
of
carbaryl
is
more
frequently
associated
with
surface
water
contamination.
A
drinking
water
monitoring
study
was
submitted
for
review;
however,
estimates
of
carbaryl
concentrations
in
surface
water­
derived
drinking
water
and
used
in
aquatic
exposure
assessment
were
based
on
deterministic
models
and
estimates
for
groundwater­
derived
drinking
water
were
based
on
an
empirical
model.
While
the
drinking
water
monitoring
study
provided
information
on
spatial
and
temporal
trends
in
carbaryl
residues,
the
study
was
viewed
as
not
having
included
what
could
be
considered
representative
of
highly
vulnerable
sites
in
current
carbaryl
use
areas.
Although
carbaryl
is
frequently
detected
in
surface
water
monitoring
studies,
particularly
on
urban
watersheds,
and
these
data
suggest
that
carbaryl
is
persistent,
the
frequent
detections
are
more
likely
an
index
of
the
volume
of
carbaryl
being
used
rather
than
on
the
chemical's
persistence.

The
demonstrated
mobility
of
carbaryl
and
its
likelihood
to
reach
both
terrestrial
and
aquatic
habitats
has
raised
concerns
regarding
its
affects
on
nontarget
animals.
Carbaryl
is
practically
nontoxic
to
birds,
moderately
toxic
to
mammals
and
fish,
and
very
highly
toxic
to
bees
and
aquatic
invertebrates
on
an
acute
exposure
basis.
The
carbaryl
hydrolysis
degradate
1­
naphthol
ranges
in
toxicity
from
moderately
to
highly
toxic
to
aquatic
organisms.
Since
carbaryl
is
practically
nontoxic
to
birds
on
both
an
acute
exposure
basis,
there
is
a
low
likelihood
that
current
registered
uses
of
carbaryl
will
impact
birds
in
terms
of
acute
effects.
However,
based
on
a
deterministic
"
risk
quotient
(
RQ)"
assessment,
i.
e.,
ratio
of
exposure
to
toxic
effect
endpoints,
the
chronic
risk
level
of
concern
(
LOC)
is
exceeded
(
RQ
$
1)
for
birds
on
over
50%
of
the
70
uses
modeled
at
maximum
label
rates.
At
"
average"
use
rates,
roughly
49%
of
the
modeled
uses
exceeded
the
chronic
risk
LOC.
Although
incident
data
exist
for
carbaryl,
they
only
weakly
support
the
potential
for
carbaryl
adversely
affecting
birds.

Acute
risk
LOCs
are
exceeded
for
mammals
on
over
75%
of
the
uses
modeled
for
small
and
intermediate­
sized
animals
using
both
maximum
label
and
"
average"
application
rates.
Although
large
mammals
appear
to
be
less
vulnerable
to
carbaryl
in
terms
of
exposure,
acute
risk
LOCs
are
exceeded
for
40%
of
the
uses.
The
chronic
risk
LOC
is
exceeded
on
all
uses
at
maximum
label
rates
and
for
89%
of
the
uses
at
"
average"
rates.
Granular/
bait
formulations
exceeded
acute
risk
LOCs
for
all
40
registered
uses.
iii
Although
two
incidents
involving
mammals
(
one
squirrel
and
one
mole)
have
been
reported
for
carbaryl,
neither
could
be
associated
with
a
specific
use
of
the
pesticide.

Carbaryl
is
highly
toxic
to
beneficial
insects
and
bees
are
likely
to
be
impacted
if
they
are
located
in
the
application
site.
Bee
kill
incidents
have
been
reported;
however,
except
for
a
single
use
of
carbaryl
on
asparagus,
a
specific
use
could
not
be
implicated.
While
concern
has
been
raised
regarding
the
use
of
carbaryl
to
thin
fruit
in
orchards,
a
field
study
of
this
use
indicated
that
carbaryl
did
not
impact
bee
mortality
and/
or
behavior.

Consistent
with
carbaryl's
moderate
toxicity
to
freshwater
fish,
the
acute
risk
LOC
is
exceeded
for
citrus
use
alone;
however,
acute
endangered
species
LOC
(
RQ
$
0.05)
is
exceeded
for
the
majority
of
uses
modeled.
None
of
the
modeled
uses
exceeded
the
chronic
LOC.
While
estuarine/
marine
fish
are
equally
sensitive
to
carbaryl,
no
acute
risk
LOC
was
exceeded
for
this
group.
No
data
were
available
to
assess
chronic
risk
to
estuarine/
marine
fish.

Freshwater
and
estuarine/
marine
invertebrates
are
particularly
vulnerable
to
carbaryl
and
acute
risk
LOCs
are
exceeded
for
all
of
the
uses
modeled
at
maximum
label,
"
average"
and
maximum
reported
application
rates.
No
data
were
available
to
assess
chronic
risk
to
estuarine/
marine
invertebrates.

Two
specific
uses
of
carbaryl
were
explored
in
greater
detail,
these
included
the
Section
24c
use
of
carbaryl
to
control
burrowing
shrimp
in
Willapa
Bay
and
Grays
Harbor,
Washington,
and
the
use
of
carbaryl
to
control
grasshoppers
and
Mormon
crickets
on
rangeland
in
the
Midwest.
On
the
use
of
carbaryl
to
control
burrowing
shrimp,
the
available
data
indicate
that
acute
mortality
will
likely
be
near
100%
for
animals
trapped
on
mudflats
in
the
immediate
application
area
and
that
carbaryl
will
likely
drift
off­
site
with
the
tide.
However,
a
combination
of
the
rapid
degradation
of
carbaryl
due
to
both
biotic
and
abiotic
factors
and
dilution
by
a
relatively
large
influx
of
water
together
render
potential
acute
and
chronic
effects
remote.
While
concern
has
been
expressed
for
birds
feeding
opportunistically
on
carbaryl­
immobilized
prey
items,
no
data
have
been
submitted
to
substantiate
these
concerns.
Additionally,
as
stated
above,
laboratory
data
indicate
that
on
both
an
acute
oral
and
subacute
dietary
exposure
basis,
carbaryl
is
practically
nontoxic
to
birds.

With
respect
to
the
use
of
carbaryl
to
control
grasshoppers
and
Mormon
crickets
on
rangeland,
acute
and
chronic
risk
LOCs
are
exceeded
for
smaller­
sized
mammals
when
0.5
lbs/
Acre
is
applied;
however,
at
0.25
lbs/
A
the
acute
endangered
species
LOC
alone
is
exceeded
for
smaller
animals.
Additionally,
assuming
5%
spray
drift
at
edge­
of­
field,
acute
restricted
use
and
endangered
species
LOCs
are
exceeded
for
freshwater
invertebrates.
If
95%
spraydrift
(
direct
overflight
of
aquatic
habitat)
occurrs,
then
the
acute
endangered
species
LOC
is
exceeded
for
fish,
and
acute
and
chronic
risk
LOCs
are
exceeded
for
aquatic
invertebrates.

Based
on
the
potential
for
both
acute
and
chronic
effects
to
terrestrial
(
primarily
mammals)
and
aquatic
animals
(
primarily
invertebrates),
plans
are
underway
to
consult
with
the
U.
S.
Fish
and
Wildilfe
Service
and
the
National
Marine
Fisheries
Service
to
assure
that
endangered
species
are
protected
to
the
extent
possible.
Section
7
consultations
on
the
use
of
carbaryl
on
rangelands
to
control
grasshoppers/
crickets
are
ongoing.

Although
laboratory
studies
of
aquatic
and
terrestrial
plants
suggest
that
carbaryl
exposure
is
not
likely
to
represent
a
risk,
these
data
were
collected
over
a
limited
range
of
species.
However,
the
largest
number
of
field
incidents
reported
for
carbaryl
have
been
associated
with
phytotoxicity.
While
the
majority
of
these
incidents
have
involved
homeowner
use,
several
were
associated
with
orchards.
The
discrepancy
iv
between
the
controlled
toxicity
testing
results
and
the
field
incident
data
represents
an
uncertainty
that
should
be
addressed
by
additional
studies.
v
Acknowledgment
This
Environmental
Fate
and
Effects
Assessment
chapter
in
support
of
the
reregistration
eligibility
decision
(
RED)
for
carbaryl
has
undergone
many
revisions
and
has
benefitted
from
the
insights
of
various
reviewers
over
the
years.
The
most
current
authors
would
like
to
take
this
opportunity
to
acknowledge
the
contributions
of
the
previous
lead
authors
Dr.
Angel
Chiri
and
Dr.
Laurence
Libelo
and
the
former
Risk
Assessment
Process
Leader,
Mr.
Dana
Spatz.
vi
TABLE
OF
CONTENTS
EXECUTIVE
SUMMARY
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ii
ENVIRONMENTAL
FATE
ASSESSMENT
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1
Exposure
Characterization
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1
Hydrolysis
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1
Aqueous
photolysis
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4
Microbially­
mediated
processes
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4
Mobility
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5
Batch
Adsorption/
Desorption
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5
Column
Leaching
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5
Field
Dissipation
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6
Terrestrial
Field
Dissipation
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6
Forestry
Field
Dissipation
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7
Aquatic
Field
Dissipation
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7
Foliar
Dissipation/
Foliar
Washoff
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8
Bioaccumulation
in
Fish
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8
Aerial
Transport
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9
1­
naphthol
Fate
and
Transport
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9
WATER
RESOURCES
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11
Monitoring:
Ground
Water
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11
Pesticides
in
Ground
Water
Database
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11
STORET
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11
NAWQA
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12
Monitoring:
Surface
Water
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12
NAWQA
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12
STORET
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13
Pilot
Reservoir
Monitoring
Study
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13
Registrant
Drinking
Water
Monitoring
Study
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14
Ground
water
modeling
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16
Surface
water
modeling
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16
AQUATIC
EXPOSURE
ASSESSMENT
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21
Drinking
Water
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21
Effects
of
Drinking
Water
Treatment
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23
Drinking
Water
Monitoring
Study
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23
TERRESTRIAL
EXPOSURE
ASSESSMENT
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23
ECOLOGICAL
EFFECTS
ASSESSMENT
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25
Effects
Assessment
for
Terrestrial
Organisms
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26
Birds
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26
Mammals
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27
vii
Insects
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27
Hazard
Assessment
for
Aquatic
Organisms
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28
Freshwater
Fish
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28
Amphibians
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29
Freshwater
Invertebrates
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30
Estuarine/
Marine
Fish
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31
Estuarine/
Marine
Invertebrates
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31
Aquatic
Plants
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31
ECOLOGICAL
HAZARD
ASSESSMENT
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.
33
Nontarget
Terrestrial
Animals
.
.
.
.
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.
33
Birds
.
.
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.
33
Mammals
.
.
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.
35
Acute
Risk
.
.
.
.
.
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.
35
Chronic
Risk
.
.
.
.
.
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.
.
.
.
.
.
.
.
39
Risks
from
Granular
Products
.
.
.
.
.
.
.
.
.
.
.
.
.
.
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.
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.
.
.
.
.
40
Hazard
to
Terrestrial
Plants
.
.
.
.
.
.
.
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.
.
.
.
.
40
Hazard
to
Nontarget
Aquatic
Animals
.
.
.
.
.
.
.
.
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.
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.
.
.
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.
.
.
.
.
.
.
40
Freshwater
Fish
.
.
.
.
.
.
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.
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.
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.
.
.
40
Freshwater
Invertebrates
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
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.
.
.
.
.
42
Estuarine/
Maine
Fish
.
.
.
.
.
.
.
.
.
.
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.
.
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.
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.
.
.
.
.
.
43
Estuarine/
Marine
Invertebrates
.
.
.
.
.
.
.
.
.
.
.
.
.
.
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.
.
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.
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.
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.
.
.
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.
.
.
43
Aquatic
Plants
.
.
.
.
.
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.
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.
.
44
ECOLOGICAL
RISK
CHARACTERIZATION
.
.
.
.
.
.
.
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.
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.
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.
.
.
.
.
45
Risk
to
Terrestrial
Animals
.
.
.
.
.
.
.
.
.
.
.
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.
.
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.
.
.
.
.
46
Risks
to
Aquatic
Animals
.
.
.
.
.
.
.
.
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.
.
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.
.
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.
.
.
.
47
Risks
to
Plants
.
.
.
.
.
.
.
.
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.
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.
.
48
Grasshopper
and
Mormon
Cricket
Control
on
Rangeland
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
48
Section
24c
Use
of
Carbaryl
to
Control
Burrowing
Shrimp
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
49
Endocrine
Disruption
Concerns
.
.
.
.
.
.
.
.
.
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.
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.
.
.
49
Endangered
Species
.
.
.
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.
50
Avian
.
.
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.
50
Mammals
.
.
.
.
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.
.
50
Aquatic
Animals
.
.
.
.
.
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.
51
REFERENCES
.
.
.
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.
53
APPENDIX
A1.
DRINKING
WATER
MEMO
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
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.
.
.
.
.
58
APPENDIX
A2.
INPUT
FILES
FOR
ESTIMATING
DRINKING
WATER
EXPOSURE
FOR
TOTAL
CARBARYL
RESIDUES
.
.
.
.
.
.
.
.
.
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.
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.
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.
.
.
.
.
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.
.
.
.
.
70
APPENDIX
B1.
REVIEW
OF
DRINKING
WATER
MONITORING
STUDY
.
.
.
.
.
.
.
.
.
.
.
71
viii
APPENDIX
B2.
SUPPLEMENTAL
TABLES
IN
SUPPORT
OF
DRINKING
WATER
MONITORING
STUDY
ANALYSES
.
.
.
.
.
.
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.
.
.
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.
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.
.
.
.
.
.
.
89
APPENDIX
C.
SPREADSHEET­
BASED
TERRESTRIAL
EXPOSURE
VALUES
.
.
.
.
.
.
.
.
94
Terrestrial
Exposure
Model
Output
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
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.
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.
.
.
.
.
.
95
APPENDIX
D1:
ECOLOGICAL
EFFECTS
ASSESSMENT
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
97
Toxicity
to
Terrestrial
Animals
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
97
Birds,
Acute
and
Subacute
Toxicity
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
97
Incidents
Involving
Birds
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
99
Birds,
Chronic
Toxicity
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
99
Mammals,
Acute
and
Chronic
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
100
Incidents
Involving
Mammals
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
100
Insect
Toxicity
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
101
Incidents
Involving
Bees
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
102
Earthworms
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
103
Toxicity
to
Freshwater
Aquatic
Animals
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
103
Freshwater
Fish,
Acute
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
103
Incidents
Involving
Freshwater
Fish
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
104
Freshwater
Fish,
Chronic
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
105
Amphibians
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
106
Freshwater
Invertebrates,
Acute
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
107
Freshwater
Invertebrate,
Chronic
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
109
Toxicity
to
Estuarine
and
Marine
Animals
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
110
Estuarine/
Marine
Fish,
Acute
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
110
Estuarine
and
Marine
Fish,
Chronic
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
110
Estuarine
and
Marine
Invertebrates,
Acute
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
110
Estuarine
and
Marine
Invertebrate,
Chronic
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
112
1­
Naphthol
Toxicity
to
Aquatic
Organisms
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
112
Acute
Toxicity
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
112
Chronic
Toxicity
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
113
Terrestrial
Plants
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
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114
Incidents
Involving
Terrestrial
Plants
.
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114
Aquatic
Plants
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115
APPENDIX
D2.
REVIEW
OF
LITERATURE
ON
EFFECTS
OF
CARBARYL
ON
AMPHIBIANS
.
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117
APPENDIX
D3.
REVIEW
OF
RELYEA
AND
MILLS
PAPER
.
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122
Attachment
1.
Excerpt
on
Amphibians
from
the
Initial
Draft
Environmental
Fate
and
Ecological
Risk
Assessment
for
the
Reregistration
of
Carbaryl
Chapter
.
.
.
.
.
126
APPENDIX
E1.
SECTION
24c
USE
OF
CARBARYL
TO
CONTROL
BURROWING
SHRIMP
.
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127
ix
APPENDIX
E2.
REVIEW
OF
DATA
SUBMITTED
ON
SECTION
24c
USE
OF
CARBARYL
TO
CONTROL
BURROWING
SHRIMP
.
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132
APPENDIX
E3.
REVIEW
OF
LITERATURE
SUBMITTED
TO
REBUT
THE
USE
OF
CARBARYL
TO
CONTROL
BURROWING
SHRIMP
IN
WILLAPA
BAY/
GRAYS
HARBOR
.
.
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140
APPENDIX
F.
ECOLOGICAL
RISK
ASSESSMENT
.
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143
Exposure
and
Risk
to
Nontarget
Terrestrial
Animals
.
.
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.
146
Avian
Acute
and
Chronic
Risk
.
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147
Risk
from
Exposure
to
Nongranular
Products
.
.
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.
147
Risk
from
Exposure
to
Granular
Products
.
.
.
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.
150
Mammalian
Acute
and
Chronic
Risk
.
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.
151
Risk
from
Exposure
to
Nongranular
Products
.
.
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.
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151
short
grass
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151
Broadleaf/
forage
plants
and
small
insects
.
.
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.
151
Fruit,
pods,
seeds,
and
large
insects
.
.
.
.
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.
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.
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.
151
Risk
to
Granular
Products
.
.
.
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158
Insects
.
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159
Terrestrial
Plants
.
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.
159
Exposure
and
Risk
to
Nontarget
Aquatic
Animals
.
.
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.
159
Freshwater
Animals
.
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.
160
Fish
.
.
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.
160
Invertebrates
.
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.
161
Estuarine
and
Marine
Animals
.
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.
162
Fish
.
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.
162
Invertebrates
.
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.
162
Aquatic
Plants
.
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163
APPENDIX
G.
GRASSHOPPER
AND
MORMON
CRICKET
SUPPRESSION
PROGRAM
.
.
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.
165
Risk
to
Terrestrial
Animals
.
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.
165
Risk
to
Aquatic
Animals
.
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.
165
1
Figure
1.
Generalized
carbaryl
degradation
pathway
ENVIRONMENTAL
FATE
ASSESSMENT
Exposure
Characterization
Using
acceptable
and
supplemental
environmental
fate
studies
submitted
by
the
registrant,
along
with
published
scientific
literature,
a
profile
of
the
fate
and
transport
of
carbaryl
in
the
environment
has
been
compiled.
This
information
is
sufficiently
complete
to
allow
the
evaluation
of
the
movement
and
fate
of
the
compound.
A
study
for
soil
photolysis
was
submitted
by
did
not
provide
usable
data.
However,
existing
data
gaps
in
and
degradate
fate
and
mobility
need
to
be
addressed
by
the
registrant.

Carbaryl
dissipates
in
the
soil
environment
by
abiotic
and
microbially
mediated
degradation.
The
major
degradation
products
are
CO2
and
1­
naphthol,
which
is
further
degraded
to
CO2
(
Figure
1).
Carbaryl
is
stable
to
hydrolysis
in
acidic
conditions,
but
hydrolyzes
rapidly
in
alkaline
environments.
Carbaryl
is
degraded
by
photolysis
in
water,
with
a
half­
life
of
21
days.
Under
aerobic
conditions
the
compound
degrades
rapidly
by
microbial
metabolism
with
half­
lives
of
4
to
5
days
in
soil
and
aquatic
environments.
In
anaerobic
environments
metabolism
is
much
slower
with
half­
lives
on
the
order
of
two
to
three
months.
Carbaryl
is
mobile
in
the
environment
(
Kf
=
1.7
to
3.5).
Sorption
onto
soils
is
positively
correlated
with
soil
organic
content,
increasing
with
higher
soil
organic
content
(
R2
=
0.94).
Table
1
summarizes
the
environmental
fate
characteristics
of
carbaryl.
Capsule
descriptions
of
the
different
routes
of
dissipation
are
described
below.

Hydrolysis
Carbaryl
hydrolysis
is
strongly
pH
dependent.
The
compound
is
stable
under
acidic
conditions
and
degrades
in
neutral
and
alkaline
systems
with
measured
half­
lives
of
12
days
(
pH
7)
and
3.2
hours
(
pH
9).
Only
one
major
degradate
was
identified,
1­
naphthol
(
MRID
44759301).
Chapman
and
Cole
(
1982)
measured
half­
lives
of
2.0
weeks
(
pH
=
7.0)
and
0.07
weeks
(
pH
=
8).
Wolfe
et
al.
(
1978)
reported
half­
life
values
in
natural
pond
waters
at
pH
6.7
of
30
days
and
at
pH
7.2
of
12
days.
They
also
estimated
minimum
hydrolysis
half­
life
in
acidic
conditions
of
1600
days.
2
Armbrust
and
Crosby
(
1991)
reported
hydrolysis
half­
lives
in
filtered
seawater
of
24
hours
at
pH
7.9
and
23
hours
at
pH
8.3.
The
major
degradation
product
was
1­
naphthol
which
was
stable
to
further
hydrolysis.
The
registrant
submitted
hydrolysis
was
used
to
generate
the
model
input
parameters.

Table
1.
Summary
of
Environmental
Chemistry
and
Fate
Parameters
For
Carbaryl
(
See
Text
for
Analysis)

Parameter
Value
Reference
Selected
Physical/
Chemical
Parameters
Molecular
Weight
201.22
Water
Solubility
32
mg/
L
(
ppm)
at
20o
C
Suntio,
et
al.,
1988
Vapor
pressure
1.36
10­
7
mm
Hg
(
25o
C)
Ferrira
and
Seiber,
1981
Henry's
Law
Constant
1.28
x
10­
8
atm
m3
mol­
1
Suntio,
et
al.,
1988
Octanol/
Water
Partition
Kow
=
229
Windholz
et
al.,
1976
Persistence
Hydrolysis
t1/
2
pH
5
pH
7
pH
9
stable
12
days
3.2
hours
MRID
00163847,
44759301
Photolysis
t
½
aqueous
21
days
MRID
41982603
Soil
photolysis
assumed
stable
No
valid
data
submitted
Soil
metabolism
T
½
Aerobic
4
days
in
one
sandy
loam
soil
MRID
42785101
Anaerobic
t1/
2
=
72
days
Satisfied
by
162­
3
Aquatic
metabolism
Aerobic
t1/
2
=
4.9
days
MRID
43143401
Anaerobic
t1/
2
=
72
days
MRID
42785102
Parameter
Value
Reference
3
Major
Transformation
Products
Identified
in
the
Fate
Studies:

1­
naphthol,
CO2
Minor
Transformation
Products
Identified
in
the
Fate
Studies:

5­
hydroxy­
l­
naphthyl
methylcarbamate
(
aerobic
soil
metabolism,
anaerobic
aquatic
)
1­
naphthyl(
hydroxymethyl)
carbamate
(
aerobic
soil
metabolism,
anaerobic
aquatic)
1,4­
naphthoquinone
(
aerobic
aquatic
metabolism,
anaerobic
aquatic)
(
hydroxy)
naphthoquinones
(
degradates
of
1­
naphthol)
4­
hydroxy­
1­
naphthyl
methylcarbamate
(
anaerobic
aquatic)
1,5­
naphthalenediol
(
anaerobic
aquatic)
1,4­
naphthalenediol
(
anaerobic
aquatic)

Mobility/
Adsorption­
Desorption
Batch
Equilibrium
Kf
(
Koc)
=
1.74
(
207)
­
sandy
loam
2.04
(
249)
­
clay
loam
sediment
3.00
(
211)
­
silt
loam
3.52
(
177)
­
silty
clay
loam
1/
n
values
ranged
from
0.78­
0.84
MRID
43259301
Column
Leaching
slightly
mobile
in
columns
(
30­
cm
length)
of
sandy
loam,
silty
clay
loam,
silt
loam,
and
loamy
sand
soils
MRID
433207­
01
Field
Dissipation
Terrestrial
Dissipation
Submitted
study
not
acceptable
MRID
419826­
05
Forestry
Dissipation
Foliar
t1/
2
=
21
days
Leaf
Litter
t1/
2
=
75
days
Soil
t1/
2
=
65
days
MRID
43439801
Aquatic
Submitted
study
not
acceptable
MRID
4326001
Foliar
Dissipation
30
days
Default
value
Bioaccumulation
Accumulation
in
Fish
not
expected
due
to
low
Kow
4
Aqueous
photolysis
In
an
aqueous
photolysis
study,
carbaryl,
with
an
initial
concentration
of
10.1
mg/
L,
degraded
in
a
pH
5
solution
with
a
half­
life
of
21
days
after
correction
for
dark
controls
(
MRID
41982603).
The
only
degradate
identified
was
1­
naphthol.
Wolfe
et
al.
(
1978)
reported
a
photolysis
half­
life
in
distilled
water
at
pH
5.5
of
45
hours.
In
filtered
seawater
carbaryl
degraded
rapidly
to
1­
naphthol
under
artificial
sunlight
(
290­
360
nm)
with
a
half­
life
of
5
hours.
The
degradation
product,
1­
naphthol,
was
degraded
very
rapidly
with
half­
life
of
less
than
1
hour
(
Armbrust
and
Crosby,
1991).
The
data
from
the
study
submitted
by
the
registrant
(
MRID
41982603)
was
used
to
generate
the
model
input
parameters.

Microbially­
mediated
processes
Carbaryl
degrades
fairly
rapidly
by
microbial
processes
under
aerobic
conditions
and
more
slowly
under
anaerobic
conditions.
In
a
guideline
study
of
aerobic
soil
metabolism
carbaryl,
with
an
initial
concentration
of
11.2
mg/
kg,
degraded
with
a
half­
life
of
4.0
days
in
sandy
loam
soil
incubated
in
the
dark
at
25BC
(
MRID
42785101).
The
major
degradate
was
1­
naphthol
which
further
degraded
rapidly
to
non­
detectable
levels
within
14
days.
In
an
aerobic
aquatic
metabolism
study
carbaryl,
with
an
initial
concentration
of
9.97
mg/
L,
degraded
with
a
half­
life
of
4.9
days
in
flooded
clay
loam
sediment
in
the
dark
at
25
°
C
(
MRID
43143401).
1­
Naphthol
was
identified
as
a
major
non­
volatile
degradate.
Carbaryl
degraded
with
a
half­
life
of
72.2
days
in
anaerobic
aquatic
sediment
with
an
initial
carbaryl
concentration
of
about
10
mg/
L;
1­
naphthol
was
the
major
degradate.
Minor
degradates
included
5­
hydroxy­
1­
naphthyl
methylcarbamate,
4­
hydroxy­
1­
naphthyl
methylcarbamate,
1,5­
naphthalenediol,
1,4­
naphthalenediol,
1­
naphthyl(
hydroxymethyl)­
carbamate,
and
1,4­
naphthoquinone.

Liu,
et
al.
(
1981)
studied
carbaryl
degradation
in
anaerobic
and
aerobic
fermenters
spiked
with
a
mixture
of
lake
sediment,
silt
loam
and
domestic
activated
sludge
and
buffered
to
pH
6.8.
They
reported
abiotic
degradation
half­
lives
of
8.3
(
aerobic)
and
15.3
(
anaerobic)
days.
After
correcting
for
abiotic
controls,
when
carbaryl
was
used
as
the
sole
carbon
source
they
found
aerobic
and
anaerobic
metabolism
half­
lives
of
54
and
11.6
days,
respectively.
When
glucose
and
peptone
were
added
co­
metabolism
aerobic
and
anaerobic
metabolism,
half­
lives
were
7.6
and
6.1
days
respectively.

A
number
of
soil
microorganisms
have
been
identified
which
can
degrade
carbaryl
including
Pseudomonas
sp
(
Chapalmadugu
and
Chaudhry,
1991;
Larken
and
Day,
1986),
Rhodoccus
sp.
(
Larkken
and
Day,
1986),
Bacillus
sp.
(
Rajagopal.
et
al.,
1984),
Arthrobacter
sp.
(
Hayatsu
et
al.,
1999),
and
Achromobacter
sp
(
Karns
et
al.,
1986).
Some
bacteria
are
capable
of
complete
degradation
to
CO2
(
Chapalamadugu
and
Chaudhry,
1991)
while
some
stop
at
1­
naphthol.
In
soils
it
appears
that
consortia
of
bacteria
are
able
to
degrade
parent
and
1­
naphthol
completely
to
CO2.
Proposed
degradation
pathways
proceed
by
using
the
methylcarbarmate
side
chain
as
a
carbon
source,
converting
the
parent
to
1­
naphthol.
1­
naphthol
is
then
degraded
through
intermediates
salicylaldehyde,
salicylic
acid,
catechol,
and
gentisate
to
CO2
and
water
(
Chapalamadugu
and
Chaudhry,
1991;
Hayatsu
et
al.,
1999).
Several
studies
have
shown
that
bacteria
isolated
from
soil
exposed
to
carbofuran
can
degrade
carbaryl
indicating
cross
adaption
by
microorganisms
allowing
5
degradation
of
compounds
with
similar
structure
(
Karns
et
al.,
1986:
Chaudhry,
et
al.,
1988).
Carbaryl
degradation
utilizes
enzyme
systems
which
may
or
may
not
degrade
other
carbamate
compounds
(
Chapalamadugu
and
Chaudhry,
1991).

Mobility
Carbaryl
is
considered
to
be
moderately
mobile
in
soils.
Based
on
batch
sorption/
desorption
studies,
the
compound
has
Freundlich
Kf
values
of
<
3.52.
Sorption
is
dependant
on
the
soil
organic
matter
content
and
increased
with
increasing
Koc.

Batch
Adsorption/
Desorption
Based
on
batch
equilibrium
experiments
(
MRID
43259301)
carbaryl
was
determined
to
be
mobile
in
soils.
In
silty
clay
loam,
sandy
loam,
loamy
sand,
and
silt
loam
soils
and
clay
loam
sediment,
mobility
decreased
with
increasing
soil
organic
matter
content.
Kf
values
were
1.74
for
the
sandy
loam
soil,
2.04
for
the
clay
loam
sediment,
3.00
for
the
silt
loam
soil,
and
3.52
for
the
silty
clay
loam
soil.
An
adsorption
Koc
of
144
was
estimated
when
an
regression
with
a
y­
intercept
was
used.
When
this
model
is
used,
there
is
a
residual
adsorption
of
0.7
L
kg­
1
when
there
is
no
organic
matter
present.
This
implies
carbaryl
has
some
ability
to
sorb
to
the
clay
directly.
This
model
has
R2
of
0.94
and
is
significant
at
p
<
0.05.
A
model
with
no­
intercept
was
also
fit,
and
Koc
calculated
this
was
is
195,
however,
the
R2
is
only
0.81
and
p
=
0.069.
1/
n
values
ranged
from
0.78­
0.84.
Sorption
showed
significant
hystereses
with
Freundlich
desorption
constants
(
Kf(
des))
values
of
6.72
for
sandy
loam
soil,
6.78
for
clay
loam
sediment,
6.89
for
silt
loam
soil,
and
7.66
for
silty
clay
loam
soil.
1/
n
values
ranged
from
0.86­
1.02.
Literature
data
confirms
that
carbaryl
is
mobile.
Nkedi­
Kizza
and
Brown
(
1998)
reported
Kf
of
4.72
(
1/
n
=
0.80)
for
soil
with
an
organic
content
of
590
mg/
Kg.
They
found
that
sorption
was
lower
on
subsoils
and
attributed
this
to
a
lower
organic
content.
The
Koc
estimated
using
the
no­
intercept
was
used
for
modeling
as
this
is
how
Koc
is
handled
internally
in
both
PRZM
and
EXAMS.

Column
Leaching
In
column
leaching
experiments
(
MRID
43320701),
carbaryl
residues
were
determined
to
be
slightly
mobile
in
columns
(
30­
cm
length)
of
sandy
loam,
silty
clay
loam,
silt
loam,
and
loamy
sand
soils
treated
with
aged
carbaryl
residues.
This
disparity
with
the
batch
experiments
may
possibly
be
explained
by
the
relatively
poor
extraction
recovery,
by
slow
desorption
kinetics
and
by
degradation
during
the
aging
period.
Unextracted
[
14C]
labeled
residues
in
the
soils
prior
to
leaching
ranged
from
19.0%
of
the
recovered
in
the
loamy
sand
soil
to
39.7%
in
the
silty
clay
loam
soil.
The
study
author
believed
that
50%
of
the
carbaryl
applied
to
the
soil
had
degraded
prior
to
leaching.
6
Field
Dissipation
Studies
of
carbaryl
dissipation
in
terrestrial,
aquatic
and
forest
environments
have
been
submitted
by
the
registrant.
In
forest
environments
carbaryl
was
found
to
be
moderately
persistent
in
soil
(
half­
live
=
65
days)
and
leaf
litter
(
half­
live
=
75
days).
The
submitted
field
and
aquatic
dissipation
studies
were
determined
to
be
unacceptable,
and
did
not
provide
useful
information
on
movement
and
dissipation
of
carbaryl
or
its
degradation
products.

Field
dissipation
studies
conducted
in
the
1960s
and
1970s
in
terrestrial
(
Fiche/
Master
ID
000108961
and
00159337),
aquatic
(
Fiche/
Master
ID
001439080,
0124378,
00159337,
00159338,
00159339)
and
forestry
(
Fiche/
Master
ID
00029738,
00159340,
00159341)
environments
and
submitted
in
the
1980'
s
have
been
reexamined.
When
they
were
initially
reviewed
they
were
not
considered
acceptable
for
a
number
of
reasons
including:
sampling
frequency
was
not
sufficient
to
allow
calculation
of
dissipation
rates,
degradates
were
not
identified
or
quantified,
soil,
sediment
and
water
were
not
sufficiently
characterized,
problems
with
analytical
method
specificity
and
validity,
insufficient
sampling
frequency
and
sampling
depth,
lack
of
data
on
irrigation
practices
measures.
These
studies
do
not
meet
current
levels
of
scientific
validity
required
to
be
considered
acceptable
and
do
not
provide
useful
information
on
field
dissipation
of
carbaryl
and
its
degradates.

Terrestrial
Field
Dissipation
Results
of
two
field
dissipation
studies
conducted
in
California
and
North
Carolina
were
submitted
(
MRID
41982605).
These
studies
are
considered
supplemental
and
can
be
upgraded
to
fully
acceptable
with
submission
of
additional
storage
stability
data
and
information
on
the
pH
of
the
irrigation
water.

A
freezer
stability
study
was
reportedly
conducted
but
the
results
past
90
days
were
not
submitted.
There
was
apparently
significant
degradation
within
90
days.
Study
samples
were
analyzed
as
long
as
8
months
after
collection,
making
the
quality
of
the
data
highly
questionable.
Degradates
were
not
analyzed
in
either
study.
In
the
California
study
>
80%
of
the
applied
carbaryl
apparently
dissipated
from
the
surface
15
cm
between
the
final
carbaryl
application
and
the
next
sampling
interval
(
7
days
after
the
final
application).
In
the
NC
study
>
90
%
apparently
dissipated
from
the
surface
15
cm
between
application
and
the
next
sampling
event
(
7
days).
However,
in
both
studies
dissipation
after
7
days
suggested
a
half­
life
on
the
order
of
weeks.
In
both
studies
rainfall
and
irrigation
were
less
than
evapotranspiration
so
the
data
can
not
be
used
to
assess
the
potential
for
carbaryl
to
leach
into
the
subsurface.
In
the
California
study,
irrigation
with
water
with
a
pH
of
8.0
was
applied
1­
3
days
after
each
pesticide
application.
Because
carbaryl
hydrolysis
is
highly
pH
dependant
(
T1/
2
at
pH
9
=
3.2
hours)
this
may
have
resulted
in
an
increase
in
the
degradation
rate,
but
higher
pH
irrigation
waters
are
not
uncommon
in
the
western
United
States.
Carbaryl
was
not
detected
below
the
0.90­
m
soil
depth.

California
site:
Carbaryl
dissipated
with
an
observed
initial
half­
life
of
<
4
days
from
the
upper
0.15
m
of
a
plot
of
Sorrento
silt
loam
soil
planted
to
broccoli
in
California
following
five
applications
at
2.24
kg
ai/
ha/
application
(
total
11.2
kg
ai/
ha)
of
carbaryl;
the
applications,
at
6­
10
day
intervals,
7
were
made
in
March
and
April
1990.
In
the
0­
to
0.15­
m
soil
depth,
carbaryl
was
0.673­
1.25
ug/
g
immediately
following
the
first
application,
1.51­
2.38
ug/
g
following
the
second,
2.03­
2.21
ug/
g
following
the
third,
1.42­
1.73
ug/
g
following
the
fourth,
and
0.603­
1.06
ug/
g
following
the
fifth
(
Tables
2­
11
of
Appendix
2).
Carbaryl
was
0.065­
0.212
ug/
g
at
4
and
7
days
after
the
final
treatment,
0.068­
0.097
ug/
g
at
15
days,
and
<
0.052
ug/
g
at
33
and
61
days.
In
the
0.15­
to
0.30­
m
soil
depth,
carbaryl
was
<
0.05
ug/
g
immediately
after
the
second,
fourth,
and
fifth
applications
and
<
0.374
ug/
g
immediately
after
the
third
application;
carbaryl
was
<
0.015
ug/
g
at
all
other
sampling
intervals.
In
the
0.30­
to
0.45­
m
soil
depth,
carbaryl
was
<
0.038
ug/
g
after
each
application,
and
<
0.010
ug/
g
at
all
other
sampling
intervals.
In
the
0.45­
to
0.90­
m
soil
depths,
carbaryl
was
sporadically
detected
at
<
0.026
ug/
g
throughout
the
application
period,
and
was
<
0.010
ug/
g
at
all
other
sampling
intervals.
The
formation
and
decline
of
carbaryl
degradates
were
not
investigated.

North
Carolina
site:
Carbaryl
dissipated
with
an
observed
initial
half­
life
of
<
7
days
from
the
upper
0.15
m
of
a
plot
of
Norfolk
sandy
loam
soil
planted
to
sweet
corn
in
North
Carolina,
following
one
application
at
7.11
kg
ai/
ha
of
carbaryl
on
May
1,
1990.
In
the
0­
to
0.15­
m
soil
depth,
carbaryl
was
3.72­
7.30
ug/
g
immediately
after
treatment,
0.145­
0.379
ug/
g
at
7
days,
0.036­
0.105
ug/
g
at
16
days,
0.017­
0.043
ug/
g
at
30
days,
and
<
0.013
ug/
g
at
62
days
(
Tables
13­
17
of
Appendix
2).
Carbaryl
was
sporadically
detected
at
<
0.015
ug/
g
in
the
0.15­
to
0.60­
m
soil
depths,
except
carbaryl
was
O.
D6
ug/
g
in
one
of
four
samples
from
the
0.30­
to
0.45­
m
depth
at
7
days.
Carbaryl
was
not
detected
in
the
0.60­
to
0.90­
m
soil
depths
at
any
sampling
interval.
The
formation
and
decline
of
carbaryl
degradates
were
not
investigated.
Rainfall
plus
irrigation
totaled
53.1
mm
through
7
days
posttreatment
(
May
1­
May
8,
1990),
and
174
mm
throughout
the
remainder
of
the
study
(
May
I­
July
2).
Throughout
the
study,
air
temperatures
were
8­
35
C,
and
soil
temperatures
at
0.1
and
0.2
m
were
16.7­
36.7
and
18.3­
30.6
C,
respectively.
The
slope
of
the
test
plot
was
<
1%
to
the
south,
and
the
depth
to
the
water
table
was
3­
5
m.

Forestry
Field
Dissipation
In
a
supplemental
forestry
field
dissipation
study
(
MRID
43439801)
carbaryl
was
applied
on
a
pine
forest
site
in
Oregon.
Carbaryl
half­
lives
were
found
to
be
21
days
on
foliage,
75
days
in
leaf
litter
and
65
days
in
soil.
At
the
time
of
treatment,
the
trees
of
primary
interest
(
pine)
were
3­
8
feet
tall.
Carbaryl
concentration
was
a
maximum
of
264
ppm
in
the
pine
foliage
at
2
days
posttreatment
28.7
ppm
in
the
leaf
litter
at
92
days,
0.16
ppm
in
the
upper
15
cm
of
litter­
covered
soil
at
62
days,
and
1.14
ppm
in
the
upper
15
cm
of
exposed
soil
at
2
days.
Carbaryl
was
detected
in
the
leaf
litter
up
to
365
days
after
treatment,
and
in
the
litter­
covered
soil
up
to
302
days
after
treatment.
Carbaryl
was
<
0.003
ppm
in
water
and
sediment
from
a
pond
and
stream
located
approximately
50
feet
from
the
treated
area.

Aquatic
Field
Dissipation
Results
of
aquatic
field
dissipation
studies
conducted
on
rice
in
Texas
and
Mississippi
were
submitted
(
MRID
43263001).
The
studies
were
evaluated
and
found
to
provide
supporting
data
and
could
be
upgraded
to
fully
acceptable
with
additional
information
on
storage
stability.
Frozen
storage
stability
data
were
provided
for
only
6
months,
although
the
water
samples
were
stored
for
8
up
to
14
months
and
the
soil
samples
were
stored
for
up
to
17.5
months
prior
to
analysis.
In
the
six
months
of
storage
carbaryl
degraded
an
average
of
34
%
in
Texas
water
and
39%
in
from
Mississippi.
1­
naphthol
degraded
50%
in
water
from
Texas
and
69%
from
Mississippi.
Degradation
did
not
appear
linear,
and
it
is
not
possible
to
extrapolate
out
to
14
months.

Carbaryl
(
1­
naphthyl
N­
methylcarbamate)
dissipated
with
observed
half­
lives
of
approximately
<
1.5
days
from
the
floodwater
of
plots
of
loam/
sandy
loam
and
clay
loam/
loam
soils
in
Texas
and
Mississippi
which
had
been
planted
to
rice,
flooded,
and
then
treated
twice,
at
5­
day
intervals,
at
1.65­
1.81
kg
ai/
ha/
application
with
carbaryl
(
Sevin
XLR
Plus,
42.38%
ai
FlC)
in
June
and
July
1992.
The
plots
were
maintained
with
a
0.5­
to
4.75­
inch
layer
of
irrigation
water
through
approximately
1
month
after
the
second
application,
according
to
normal
cultural
practices
for
rice
growing.
Carbaryl
did
not
appear
to
leach
below
the
7.5­
cm
soil
depth
during
the
study.
In
the
floodwater,
the
degradate
1­
naphthol
dissipated
to
non­
detectable
concentrations
within
7­
14
days
after
the
second
application;
in
the
soil,
1­
naphthol
was
not
detected
at
any
soil
depth
at
any
sampling
interval.

Foliar
Dissipation/
Foliar
Washoff
In
the
preliminary
assessment
of
carbaryl,
a
half­
life
of
35
days
was
used
as
a
default
value
to
represent
the
degradation
of
carbaryl
on
leaf
surfaces.
In
submitted
comments
on
that
draft,
the
registrant
submitted
a
review
of
data
that
was
relevant
to
the
degradation
of
carbaryl
and
leaf
surfaces.
That
document
(
Holmsen
,
2003)
and
the
supporting
studies
and
data
have
been
reviewed
(
See
Appendix
C)
and
the
foliar
degradation
half­
life
has
been
revised
accordingly.
Based
on
thirty
acceptable
studies,
the
mean
foliar
half­
life
of
carbaryl
was
determined
to
be
3.2
d.
These
studies
were
predominantly
magnitude
of
residue
studies
used
to
support
the
setting
of
tolerances
for
food
as
well
as
some
other
data
from
the
open
literature.
A
set
of
criterion
(
described
in
detail
in
Appendix
C)
for
data
quality
and
study
appropriateness
were
established
to
select
those
studies
which
were
appropriate
for
making
the
estimate.
A
value
of
3.7
d
was
used
for
foliar
degradation
in
estimating
for
both
terrestrial,
aquatic
and
drinking
water
exposure
estimates.
This
value
is
the
upper
90%
confidence
bound
on
the
mean
value.
Upper
confidence
bounds
values
are
used
as
input
parameters
for
other
input
parameters
which
are
based
on
metabolic
degradation
processes.

While
not
specifically
addressed
in
the
comments
from
the
registrant,
two
studies
(
Willis
et
al,
1988,
Willis
et
al,
1996)
were
submitted
by
the
registrant
which
could
be
used
to
estimate
the
foliar
washoff
rate
which
is
a
input
parameter
for
PRZM.
In
the
absence
of
data,
this
parameter
is
usually
set
to
0.5.
Washoff
coefficients
estimated
from
these
two
studies
were
0.83
and
0.98
respectively
with
a
mean
of
0.91.
In
both
these
cases,
the
washoff
coefficient
was
estimated
from
only
two
points,
so
no
error
could
be
estimated.
The
mean
of
0.91
was
used
in
the
modeling.

Bioaccumulation
in
Fish
Because
of
the
low
octanol/
water
partition
coefficient
carbaryl
is
not
expected
to
significantly
bioaccumulate.
Reported
Kow
values
range
from
65
to
229
(
Bracha,
and
O'Brian,
1966;
Mount
and
Oehme,
1981;
Windholz
et
al.,
1976).
A
fish
bioaccumulation
study
reviewed
in
1988
(
Chib,
1986,
Fiche/
Master
ID
00159342)
suggested
that
bioaccumulation
factors
were
14x
in
edible
9
tissue,
75x
in
visceral
tissue
and
45x
in
whole
fish.
Though
the
study
does
not
meet
current
acceptable
standards
it
does
support
the
conclusion
that
significant
bioaccumulation
is
not
expected.
No
additional
data
on
bioaccumulation
is
required
at
this
time.

Aerial
Transport
Carbaryl
has
been
shown
to
be
transported
and
deposited
aerially
(
Waite,
et
al.,
1995;
Foreman,
et
al.,
2000;
Sanusi
et
al.,
2000).
As
with
all
chemicals
applied
by
aerial
or
ground
spray,
spray
drift
can
cause
exposure
to
non­
target
organisms
downwind.
Beyer
et
al.,
(
1995)
studied
spray
drift
from
aerial
application
to
rangeland
near
the
Little
Missouri
River
in
North
Dakota.
In
1991
carbaryl
was
applied
to
35,130
ha
at
560
g/
ha
(
0.62
lb)
A.
I.
A
152­
m
no­
spray
buffer
zone
was
maintained.
River
water
samples
collected
1
hour
after
completion
of
spraying
had
a
mean
concentration
of
85.1
:
g/
l.
Concentration
decreased
over
time,
and
96
hours
after
application
the
mean
was
0.1
:
g/
l.
In
1993
a
similar
application
resulted
in
a
maximum
concentration
1
hour
after
spraying
of
12.6
:
g/
l
decreasing
to
5.14
:
g/
L
after
96
hours.
The
researchers
found
that
invertebrates
in
the
river
were
minimally
effected
while
fish
brain
acetylcholinesterase
activity
was
not
effected.

Vapor
phase
transport
and
particulate
transport
may
carry
the
compound
far
from
the
area
of
application.
In
the
atmosphere,
partitioning
between
particulate
and
gas
phase
is
a
function
of
temperature
and
changes
from
about
30%
vapor
phase
to
about
90%
when
temperature
increases
from
283
to
303oK
(
10
­
30oC)
(
Sanusi
et
al.,
1999).
This
suggests
that
aerial
transport
distance
and
deposition
are
a
function
of
temperature.

Carbaryl
has
been
detected
in
air
in
urban
and
suburban
areas
with
limited
influence
from
agricultural
spraying.
It
is
detected
more
frequently
and
generally
at
higher
concentrations
at
sampling
locations
in
urban
areas
than
in
agricultural
areas
(
Foreman
et
al.,
2000).
Pesticide
concentrations
in
fog
formed
in
the
vicinity
of
applications
often
are
higher
than
those
observed
in
rain
water
or
surface
water
and
may
represent
a
significant,
though
generally
overlooked,
route
of
exposure.
Schomburg
et
al.
(
1991)
reported
carbaryl
concentrations
in
fog
ranging
from
0.069
to
4.0
:
g/
L.
In
general
though,
given
carbaryl's
relatively
rapid
degradation,
its
potential
for
longrange
atmospheric
transport
is
very
limited.

1­
naphthol
Fate
and
Transport
Limited
information
is
available
for
the
environmental
fate
and
transport
of
the
major
carbaryl
degradate
1­
naphthol.
1­
naphthol
was
formed
in
laboratory
degradation
studies
and
represented
a
major
portion
of
the
applied
mass
(
maximum
of
22
%
in
aerobic
aquatic
metabolism,
58%
in
aerobic
soil
metabolism
and
67%
in
photolysis).
1­
naphthol
was
not
persistent
in
the
studies
and
appears
to
have
degraded
more
rapidly
then
the
parent.

1­
Naphthol
a
natural
product
and
is
also
formed
as
a
degradation
product
of
naphthalene
and
other
polycyclic
aromatic
hydrocarbons.
It
appears
to
degraded
more
rapidly
then
the
parent
in
the
10
submitted
studies
but
there
is
not
sufficient
information
the
develop
a
detailed
fate
profile.
While
guideline
studies
were
not
submitted
specifically
for
the
degradate,
literature
information
suggests
that
it
is
less
persistent
and
less
mobile
than
parent
carbaryl.
Armbrust
and
Crosby
(
1991)
reported
that
1­
Naphthol
was
stable
to
hydrolysis
in
filtered
seawater
at
pH
7.9
and
8.3.
Hydrolytic
degradation
of
1­
naphthol
is
reported
to
be
due
to
reaction
with
dissolved
O2
and
is
highly
pH
dependant
(
Karthikeyan
and
Chorover,
2000).
Oxidation
increases
with
pH
and
ionic
strength.
Below
pH
7
oxidation
is
minimal
and
reaches
a
maximum
at
about
pH
9.
Oxidation
of
1­
naphthol
reportedly
results
in
production
of
(
hydroxy)
naphthoquinones
and
dimer
coupled
reaction
products,
though
the
reaction
rates
for
1­
naphthol
degradation
is
not
well
known
(
Karthikeya
and
Chorover,
2000).
In
filtered
seawater
carbaryl
degraded
rapidly
to
1­
naphthol
under
artificial
sunlight
(
290­
360
nm),
with
half­
life
of
5
hours.
The
degradation
product,
1­
naphthol,
was
degraded
very
rapidly
with
half­
life
of
less
than
1
hour
(
Armbrust
and
Crosby,
1991).

1­
naphthol
is
degraded
rapidly
by
microbial
processes
in
aerobic
systems.
In
an
aerobic
soil
metabolism
study
(
MRID
42785101)
1­
naphthol
degraded
rapidly
to
non­
detectable
levels
within
14
days.
Armbrust
and
Crosby
(
1991)
reported
that
1­
naphthol
degraded
in
unfiltered
seawater
to
below
detectable
level
within
94
hours.
Burgos
et
al.
(
1999)
found
that
greater
than
90%
of
aqueous
1­
naphthol
was
degraded
to
CO
2
within
10
days.
However,
they
found
that
sorption
to
soil
greatly
reduced
the
degradation
rate;
when
sorbed
degradation
was
greatly
slowed
to
25­
40%
degradation
in
90
days.

No
guideline
information
was
submitted
on
1­
naphthol
sorption.
Literature
information
suggests
that
it
is
not
strongly
sorbed.
Sorption
to
poorly
crystalline
aluminum
hydroxide
was
pH
dependant
and
appeared
to
occur
only
after
oxidation
(
Karthikeyan
et
al.,
1999).
Hassett
et
al.
(
1981)
reported
an
average
1­
naphthol
Koc
of
431
(
±
40)
for
10
of
the
16
soils
tested.
They
also
found
that
in
other
soils
with
very
low
organic
carbon
to
clay
ratios
clay
surfaces
controlled
sorption.
Additional
data
on
1­
naphthol
sorption
is
required
to
fully
characterize
mobility.
11
WATER
RESOURCES
Due
to
its
mobility,
carbaryl
is
expected
to
reach
surface
water
resources
by
spray
drift
and
runoff
and
it
has
a
limited
ability
to
reach
ground
water
through
leaching.
Carbaryl
is
not
persistent
in
most
cases
and
would
not
be
expected
to
be
found
frequently
in
neutral
and
alkaline
conditions;
however,
under
acid
conditions
with
low
biological
activity,
the
pesticide
is
likely
to
persist.
Carbaryl
was
found
in
about
1.5%
of
wells
in
the
NAWQA
program.
In
groundwater
carbaryl
is
detected
less
often
and
at
lower
levels
(
generally
less
than
0.01
:/
L).
Carbaryl
is
the
second
most
commonly
found
insecticide
(
after
diazinon)
in
surface
water
with
21%
of
samples
having
detectable,
but
usually
sub­:
g
L­
1
level
concentrations
and
the
maximum
reported
value
is
less
than
10
:
g/
L.
Detections
are
more
frequent
in
urban
than
agricultural
watersheds.

Both
modeling
and
monitoring
data
were
used
to
assess
the
concentrations
of
carbaryl
in
water
resources.
Monitoring
data
from
the
United
States
Geological
Survey,
EPA's
STORET
database
and
Pesticides
in
Ground
Water
Database,
and
a
registrant
study
are
described
below.
Modeling
of
ground
water
was
performed
with
SCIGROW.
A
drinking
water
exposure
assessment
was
carried
out
with
the
Pesticide
Root
Zone
Model
coupled
with
the
Exposure
Assessment
Model
System
(
PRZM/
EXAMS)
using
the
Index
Reservoir
scenario.
Aquatic
EEC's
were
estimated
with
PRZM/
EXAMS
and
the
standard
pond.
The
monitoring
studies
are
summarized
first,
followed
by
the
modeling.

Monitoring:
Ground
Water
Available
evidence
from
valid
scientific
studies
show
that
carbaryl
has
a
limited
potential
to
leach
to
ground
water.

Pesticides
in
Ground
Water
Database
As
a
result
of
normal
agricultural
use,
detections
of
carbaryl
residues
have
been
reported
in
groundwater
from
several
states.
As
reported
in
the
U.
S.
EPA.
Pesticides
in
Groundwater
Database
(
Jacoby
et
al.,
1992),
carbaryl
was
detected
in
0.4%
of
wells
sampled.
Carbaryl
was
detected
in
California
(
2
out
of
1433
wells),
Missouri
(
11
out
of
325
wells),
New
York
(
69
out
of
21027
wells)
Rhode
Island
(
13
out
of
830
wells)
and
Virginia
(
11
out
of
138
wells).
The
maximum
concentration
detected
was
610
:
g
L­
1
in
NY,
though
typically
the
measured
concentrations
were
orders
of
magnitude
lower.

STORET
The
EPA
Storage
and
Retrieval
(
STORET)
water
quality
database
was
queried
on
May
12,
1999
for
reports
of
measurements
of
carbaryl
in
groundwater.
The
database
contained
9,389
records
indicating
that
analysis
was
done
for
carbaryl.
Out
of
these,
only
4
reported
concentrations
above
the
detection
limits.
These
analyses
were
all
from
one
well
in
Cleveland,
OK
in
1988.
The
4
reported
concentrations
were
between
0.8
and
1
ppb.
12
NAWQA
Carbaryl
was
detected
at
greater
than
the
detection
limit
(
0.003
µ
g/
L)
in
1.1
%
of
groundwater
samples
from
1,034
sites
across
the
country
by
U.
S.
Geological
Survey's
(
USGS)
National
Water
Quality
Assessment
(
NAWQA)
program.
The
maximum
observed
concentration
was
0.021
µ
g/
L.
Detections
were
mainly
from
three
use
sites:
wheat
(
5.8
%
of
well
samples
from
wheat
land
use
),
orchards
and
vineyards
(
1.7
%
of
well
samples
from
orchard
and
vineyard
land
use),
and
urban
(
1.8%
of
urban
groundwater
samples).
Data
on
pesticides
in
groundwater
were
reviewed
by
Kolpin
et
al.
(
1998)
and
updated
information
is
available
at:
http://
water.
wr.
usgs.
gov/
pnsp/
pestgw/.

Monitoring:
Surface
Water
Carbaryl
is
widely
detected
in
non­
targeted
and
targeted
monitoring
studies.
Observed
concentrations
are
generally
low
with
fifty
percent
of
the
samples
below
minimum
detection
limits
and
ninety
five
percent
of
the
samples
less
than
0.065
:
g/
L.
Carbaryl
is
not
very
persistent
in
most
surface
water
conditions
suggesting
that
the
wide
spread
occurrence
is
a
result
of
its
extensive
use
in
a
variety
of
applications.
Because
of
limitation
in
the
analytical
methods
used
there
is
some
uncertainty
in
the
quantitative
accuracy
of
carbaryl
analysis.
Additionally,
non­
targeted
monitoring
may
not
coincide
with
vulnerable
application
areas
and
times
and
typically
not
include
low­
order
streams
or
lentic
(
e.
g.
ponds
and
wetlands)
environments.
Specific
data
sets
are
discussed
below:

NAWQA
Carbaryl
is
the
second
most
widely
detected
insecticide
in
surface
water
after
diazinon
in
the
NAWQA
program
(
http://
water.
usgs.
gov/
nawqa/
nawqa_
home.
html).
Carbaryl
was
detected
in
46%
of
36
NAWQA
study
units
between
1991
and
1998.
The
reported
concentrations
are
believed
to
be
reliable
detections
but
have
greater
than
average
uncertainty
in
quantification.
The
data
in
the
NAWQA
database
are
amended
with
an
"
E"
qualifier
to
indicate
the
variability
found
in
the
analysis.
This
suggests
that
the
reported
values
may
not
represent
the
maximum
concentrations
that
exist.

Out
of
5,198
surface
water
samples
analyzed
1,067
(
21%)
were
reported
as
having
detections
greater
than
the
minimum
detectable
limit.
The
maximum
reported
concentration
was
5.5
µ
g/
L
across
all
sites..
For
samples
with
positive
detections
the
mean
concentration
was
0.11
:
g/
L,
with
a
standard
deviation
of
0.43
:
g/
L.
In
a
summary
of
pesticide
occurrence
and
concentrations
for
40
NAWQA
stream
sites
with
primarily
agricultural
basins,
carbaryl
was
detected
in
11%
of
the
samples
(
N
=
1,001)
with
a
maximum
concentration
of
1.5
µ
g/
L.
A
significant
portion
of
the
total
carbaryl
applied
was
transported
to
streams.
In
areas
with
high
agricultural
use
the
load
measured
in
surface
waters
was
relatively
consistent
across
the
country
at
about
0.1
percent
of
the
amount
used
in
the
basins
(
Larson
et
al.,
1999)
http://
water.
wr.
usgs.
gov/
pnsp/
rep/
wrir984222/
load.
html.
The
estimated
carbaryl
use
in
agricultural
applications
is
about
2.5
million
pounds
suggesting
that
2,500
pounds
are
delivered
to
the
nations
streams
draining
agricultural
areas.
13
Streams
draining
urban
areas
showed
more
frequent
detections
and
higher
concentrations
than
streams
draining
agricultural
or
mixed
land
use
areas.
For
example,
in
a
study
of
11
stream
sites
(
N
=
327)
with
primarily
urban
basins,
carbaryl
was
detected
in
45%
of
the
samples
with
a
maximum
concentration
of
3.2
µ
g/
L
(
http://
water.
wr.
usgs.
gov/
pnsp/
rep/
wrir984222/
load.
html).
Additionally,
Kimbrough
and
Litke
(
1996)
reported
that,
in
the
South
Platte
River
Basin
Study
Unit,
between
April
and
December
of
1993,
carbaryl
was
detected
in
14
urban
drainage
samples
and
6
agricultural
drainage
samples.
Carbaryl
had
the
highest
concentration
of
the
four
insecticides
analyzed
with
a
maximum
concentration
of
2.5
:
g/
L
in
the
urban
basin
and
1.5
:
g/
L
in
the
agricultural
basin
(
http://
webserver.
cr.
usgs.
gov/
nawqa/
splt/
meetings/
KIMB1.
html).
In
the
South­
Central
Texas
Study
Unit
carbaryl
was
detected
in
12%
of
streams
draining
agricultural
areas
and
52
%
draining
urban
areas
(
Bush
et
al.,
2000)
http://
water.
usgs.
gov/
pubs/
circ/
circ1212/.

STORET
The
EPA
STORET
database
(
was
queried
on
May
12,
1999
for
reports
of
measurements
of
carbaryl
in
surface
water.
The
database
contained
8048
records
indicating
that
analysis
was
done
for
carbaryl.
Out
of
these
432
reported
concentrations
above
the
detection
limits.
The
maximum
value
reported
was
5.5
µ
g/
L.
Of
the
reported
detections
18
were
above
1
ppb.
The
data
is
the
STORET
database
is
used
to
give
a
general
indication
of
the
occurrence
pattern
only.
Lack
of
QA/
QC
and
analytical
methodology
limitations
limit
the
usefulness
of
the
STORET
data.
However,
reported
detections
of
carbaryl
suggest
that
the
compound
is
infrequently
detected
in
surface
water
and
at
low
levels.

Pilot
Reservoir
Monitoring
Study
This
study
was
conducted
by
the
USGS
and
EPA
to
gain
better
understanding
of
pesticide
behavior
in
reservoirs.
Twelve
reservoirs
were
sampled
across
the
country
with
an
emphasis
on
watersheds
that
were
expected
to
be
vulnerable
to
pesticide
contamination,
but
with
no
particular
emphasis
on
any
particular
pesticide.
Samples
were
collected
at
the
drinking
water
intake
(
312
total
samples),
the
reservoir
outflow
(
73
samples)
and
finished
water
from
the
water
supply
(
225
samples).
Not
all
sites
had
samples
collected
at
the
reservoir
outflow.
Carbaryl
was
detected
at
5
sites
(
Table
2),
4
at
the
intake,
2
at
the
outflow,
and
two
in
finished.
In
addition,
3
samples,
all
from
intakes,
contained
1­
naphthol.
The
highest
carbaryl
concentration
detected
was
0.043
:
g
L­
1
at
Blue
Marsh
Reservoir
in
Pennsylvania
while
the
carbaryl
degradate,
1­
naphthol,
was
found
at
0.228
:
g
L­
1
at
Higginsville,
Missouri.
It
is
worth
noting
that
1­
naphthol
has
other
sources
in
the
environment,
including
some
which
are
natural.
It
is
also
worth
noting
that,
as
with
the
NAWQA
data
which
uses
similar
analytical
protocols,
all
detections
of
carbaryl
were
qualified
due
to
high
background
variability
of
the
measurements.
These
data
are
consistent
withe
other
data
which
show
widespread
low­
level
contamination
of
carbaryl
in
surface
water.
14
Table
2.
Summary
of
carbaryl
detections
in
the
Pilot
Reservoir
Monitoring
Study.
(
Blomquist
et
al.
2001)

Location
Number
of
Samples
Number
of
Detections
Maximum
Concentration
(:
g
L­
1)

Drinking
water
Intakes
Higginsville
Lake,
Higginsville,
MO
40
1
0.008
Tar
River
Reservoir,
Rocky
Mount,
NC
10
1
0.004
East
Fork
Lake,
Batavia,
OH
21
1
0.012
Blue
Marsh
Reservoir,
Reading,
PA
23
4
0.047
Reservoir
Outflow
Blue
Marsh
Reservoir,
Reading,
PA
24
1
0.005
Lake
Mitchell,
Mitchell,
SD
9
1
0.001
Finished
Water
Higginsville
Lake,
Higginsville,
MO
25
1
0.004
Blue
Marsh
Reservoir,
Reading,
PA
23
1
0.003
1­
Naphthol
Higginsville
Lake,
Higginsville,
MO
38
1
0.228
Blue
Marsh
Reservoir,
Reading,
PA
24
1
0.006
South
Pacolet
Reservoir,
Spartanburg,
SC
44
1
0.008
Registrant
Drinking
Water
Monitoring
Study
EFED
reviewed
in
detail
the
final
report
from
a
study
voluntarily
conducted
by
Aventis
for
carbaryl.
The
study
was
designed
and
implemented
voluntarily
by
Rhone­
Poulenc
Agricultural
Company
(
RPAC),
with
the
purpose
of
providing
the
Agency
data
useful
in
refining
the
drinking
water
exposure
estimates
for
carbaryl.
The
main
study
goal
is
in
line
with
data
needed
by
the
Agency
to
refine
the
drinking
water
risk.
However,
the
implementation
of
the
study
(
especially
site
selection)
was
not
consistent
with
the
study
goal.
Despite
these
drawbacks,
the
study
design
was
one
of
the
better
surface­
water
monitoring
studies
submitted
to
the
Agency
over
the
past
several
years.
The
analytical
methodology
and
method
sensitivity,
quality
assurance
procedures,
study
duration,
and
aspects
of
their
approach
to
site
selection
were
sound.
This
study
provides
useful
information
on
measured
concentrations
of
carbaryl
in
selected
surface
waters
of
the
United
States.
These
data
will
be
used
in
conjunction
with
other
monitoring
data,
to
characterize
surface
water
modeling
estimates
of
carbaryl
exposure
from
surface­
water
source
drinking
water.

A
detailed
critique
of
the
monitoring
data
identified
several
major
drawbacks
to
the
quantitative
use
of
these
data
to
represent
drinking
water
exposure:
15
°
With
only
16
sites
to
represent
vulnerable
surface
water
bodies
for
selected
agricultural
uses
(
really
15,
as
the
LA
site
was
selected
to
represent
population
exposure
not
because
source
waters
were
vulnerable)
and
four
suburban
sites,
this
study
is
not
likely
to
provide
comprehensive
coverage
of
all
carbaryl
usage
sites,
given
the
great
geographic
diversity
of
carbaryl
use
areas
and
carbaryl
uses.
Because
little
supporting
data
were
provided
on
nonagricultural
sales
and
national­
scale
non­
agricultural
carbaryl
usage,
the
relative
vulnerability
of
the
systems
selected
to
represent
"
home
and
garden"
usage
effects
could
not
be
determined
°
We
do
not
concur
that
sites
sampled
represent
the
"
the
highest
probable
risk
of
human
exposure
to
carbaryl
in
surface
water
in
each
state",
based
on
our
analysis
of
carbaryl
usage
and
vulnerability
characteristics
of
CWS
watersheds
selected.

°
The
monitoring
interval
(
one
week
to
two
weeks)
is
unlikely
to
capture
peak
concentrations
necessary
for
estimating
acute
dietary
risk,
given
the
variable
nature
of
the
exposure.

Results
of
this
study
indicate
that
carbaryl
was
found
in
source
drinking
water
(
raw
water)
at
low
concentrations
in
the
majority
of
sites
(
13
of
16
sites)
selected
to
represent
impacts
from
agricultural
uses,
despite
the
relative
lack
of
vulnerability
of
these
sites.
Concentrations
measured
at
these
sites
were
low
(
roughly
2
to
31
ppt)
in
raw
water
and
generally
lower
in
treated
drinking
water;
however,
the
highest
concentrations
were
found
in
finished,
not
raw,
drinking
water
(
181
ppt).
Where
residues
were
detected,
frequency
of
detection
in
raw
water
samples
ranged
from
a
few
percent
of
total
samples
(
1­
6
%)
at
9
of
the
13
sites
to
about
20%
of
total
samples
(
14
­
21%)
at
4
sites.
At
several
agricultural
sites,
low­
level
concentrations
were
measured
over
3­
4
week
periods
in
weekly
samples.
Given
the
environmental
fate
characteristics
of
this
compound,
this
is
most
likely
the
result
of
the
volume
of
usage
rather
than
the
persistence
of
the
compound.

Carbaryl
was
reported
in
raw
water
of
all
four
CWS
selected
to
represent
impacts
from
home
and
garden
uses.
Concentrations
measured
in
raw
water
at
these
sites
were
low
(
roughly
2
to
44
ppt)
and
detection
frequencies
ranged
from
approximately
1
to
20
%.
How
representative
these
systems
are
of
the
home
and
garden
use
of
carbaryl
cannot
be
determined
from
the
data
provided.
However,
the
lowest
detection
frequency
occurred
at
the
CWS
with
the
largest
watershed
size
(
exceeding
the
70th
percentile
nationally).
At
one
site,
concentrations
were
reported
in
sequential
weekly
samples
for
a
period
of
several
months,
likely
due
to
the
volume
of
usage.

Because
raw
and
finished
samples
were
not
temporally
paired,
we
cannot
make
quantitative
statements
about
the
impact
of
treatment
processes
in
removing
carbaryl
from
source
water.
In
fact,
in
several
instances
the
treated
water
concentrations
were
higher
than
the
raw
water
concentration
in
the
"
pair",
including
the
highest
reported
concentrations
Modeling.

Because
of
the
relatively
limited
persistence
of
the
compound
in
the
environment
it
is
unlikely
that
non­
targeted
monitoring
studies
will
detect
the
maximum
concentrations
that
occur.
Because
of
the
limited
amount
of
data
available
and
because
of
potential
problems
with
extant
data,
16
monitoring
data
are
of
limited
utility
in
developing
estimated
environmental
concentrations
(
EEC's)
for
ecological
and
human
health
risk
assessment.
Therefore,
EFED
used
computer
modeling
to
estimate
surface
water
and
groundwater
concentrations
that
could
be
expected
from
normal
agricultural
use.
For
developing
surface
water
EEC's
EFED
used
EPA
PRZM
3.12
and
EXAMS
2.98
programs
to
estimate
the
concentration
of
carbaryl
in
surface
water.
For
ecological
risk
assessment
the
standard
pond
scenario
was
used.
For
human
health
risk
assessment
index
reservoir
scenario
was
used.
For
ground
water,
the
Screening
Concentrations
in
Ground
Water
(
SCI­
GROW)
model
was
used.

Ground
water
modeling
The
concentration
of
carbaryl
that
might
be
found
in
vulnerable
ground
water
used
as
drinking
water
was
derived
using
SCI­
GROW
(
EFED,
2002).
SCI­
GROW
is
a
regression
model
which
relates
simple
environmental
fate
parameters
with
concentrations
which
have
been
seen
in
prospective
ground
water
studies
(
PGW).
These
studies
are
generally
done
on
sites
prone
to
leaching
with
shallow
ground
water
and
are
thus
highly
vulnerable.
Estimated
groundwater
concentrations
derived
using
SCI­
GROW
are
for
both
acute
and
chronic
human
health
assessment.
The
SCI­
GROW
EEC
for
carbaryl
is
0.08
µ
g/
L.
It
must
be
noted
that
carbaryl
has
an
aerobic
metabolism
half­
life
(
4
days)
which
is
outside
the
range
of
values
for
which
SCI­
GROW
was
developed
(
17­
1000
days).
The
OPP
currently
does
not
have
more
advanced
groundwater
models
and
targeted
studies
specifically
designed
to
evaluate
the
potential
for
carbaryl
to
move
to
groundwater
are
not
available.

Surface
water
modeling
Tier
2
modeling
was
used
to
calculate
EEC's
for
both
aquatic
and
drinking
water.
The
calculation
of
drinking
water
EEC's
are
described
in
detail
in
APPENDIX
A
and
the
aquatic
EEC's
in
APPENDIX
B.
For
both
sets
of
EEC's,
five
crops
were
modeled:
citrus
in
Florida,
sweet
corn
and
field
corn
in
Ohio,
apples
in
Pennsylvania
and
sugar
beets
in
Minnesota.
Application
rates
and
intervals
for
the
selected
uses
are
presented
in
Table
3.

Table
3.
Maximum
use
patterns
for
carbaryl
application
on
selected
crops
based
on
the
EPA
label
Crop
Single
app.
Rate
(
lb
acre­
1)
Number
of
Applications
Application
Interval
Application
Method
Date
of
First
Application
Apples
2
5
3
days
aerial
June
1
Citrus
5
4
14
days
aerial
April
1
Field
Corn
2
4
14
days
aerial
June
1
Sweet
Corn
2
8
14
days
aerial
May
1
Sugar
Beets
1.5
2
14
days
aerial
June
1
1
"
Average"
is
the
average
rate
as
determined
by
OPP/
BEAD
and
reported
in
the
a
memo
titled
Quantitative
Usage
Analysis
for
Carbaryl,
prepared
July
21,
1998
by
Frank
Hernandez,
OPP/
BEAD.

2
Maximum
used
is
the
highest
rate
of
application
that
is
actually
reported
to
be
used
based
on
OPP/
BEAD
analysis
of
DoaneS
survey
data
by
Donald
Atwood,
Personal
communication,
January
31,
2001.

17
Several
application
rates
were
used
in
modeling:
the
maximum
allowed
for
the
specific
crop,
an
"
average"
rate1,
and
the
maximum
rate
reported
to
actually
be
used2.
The
maximum
rate
was
taken
from
the
carbaryl
labels
(
Table
3).
"
Average"
and
maximum
reported
rates
(
Table
4
and
5)
were
determined
by
EPA's
Biological
and
Economic
Assessment
Division
(
BEAD)
based
on
data
collected
by
Doane's
surveys
and
registrant
market
analysis.
EEC's
varied
greatly
depending
on
the
geographic
location,
crop,
and
application
rate.
Modeling
"
average"
and
maximum
reported
use
rates
yielded
EEC
values
generally
40­
60%
lower
than
maximum.
EFED
normally
uses
the
maximum
allowed
application
rates
in
modeling.
In
this
assessment
other,
"
less
than
maximum",
rates
were
modeled
in
order
to
evaluate
how
conservative
maximum
label
rate
modeling
estimates
are.
The
average
and
maximum
rates
may
or
may
not
be
representative
of
actual
use
rates
and
are
of
limited
certainty
due
to
the
quality
and
extent
of
the
data
available
to
calculate
them.
As
described
in
the
BEAD
chapter,
the
average
application
rates
were
derived
by
dividing
total
pounds
used
by
the
overall
use
area.
The
resulting
average
does
not
represent
the
actual
average
applied
to
any
specific
area.
The
maximum
reported
rate
was
determined
from
Doane's
survey
results.
These
data,
while
the
best
available,
are
very
limited.
The
number
of
farmers
surveyed
is
small,
often
only
one
or
two
per
state,
and
the
statistical
validity
of
the
results
are
not
known
but
it
is
highly
unlikely
that
the
survey
identified
the
actual
maximum
value.
There
are
some
notable
unexplained
discrepancies
in
the
data.
In
particular,
the
average
and
maximum
reported
use
rates
of
carbaryl
on
sweet
corn
are
higher
than
the
maximum
label
rate.
The
reason
for
the
discrepancy
could
has
not
been
determined.

Table
4.
Maximum
reported
use
patterns
for
carbaryl
application
on
selected
crops
Crop
Single
app.
Rate
(
lb
acre­
1)
Number
of
Applications
Application
Interval
Application
Method
Date
of
First
Application
Apples
1.6
2
14
days
aerial
June
1
Citrus
4.26
3
14
days
aerial
April
30
Field
Corn
1.5
2
14
days
aerial
June
1
Sweet
Corn
3*
1
­­­
aerial
June
1
Sugar
Beets
1.2
1
­­­
aerial
June
1
*
The
maximum
reported
rate
is
greater
than
the
maximum
label
rate.
The
seasonal
maximum
rate
is
not
exceeded,
however.
18
Table
5.
`
Average'
use
patterns
for
carbaryl
application
on
selected
crops
Crop
Single
app.
Rate
(
lb
acre­
1)
Number
of
Applications
Application
Interval
Application
Method
Date
of
First
Application
Apples
1.2
2
14
days
air
blast
June
1
Citrus
3.4
2
14
days
aerial
April
30
Field
Corn
1
2
14
days
aerial
June
1
Sweet
Corn
3.4
2
14
days
aerial
June
1
Sugar
Beets
1.5
1
­­­
aerial
June
1
*
The
maximum
reported
rate
is
greater
than
the
maximum
label
rate.
The
seasonal
maximum
rate
is
not
exceeded,
however.
**
The
`
average'
rate
is
greater
than
maximum
reported
rate.
The
reason
for
this
discrepancy
is
not
known.

The
chemical
parameters
used
in
the
simulations
are
in
Table
6.
Detailed
descriptions
of
the
development
of
these
parameters
and
the
data
quality
characterizations
are
in
APPENDIX
A.
Generally
parameters
estimates
from
multiple
reproducible
studies
are
characterized
as
very
good,
parameters
from
limited
numbers
of
studies
are
good
with
less
reproducibility
are
good
or
fair,
and
parameters
estimated
from
surrogate
data
are
poor.

Table
6.
Chemical
input
parameters
for
carbaryl
Parameter
Value
Quality
Molecular
weight
201.22
g
mol­
1
excellent
Solubility
32
mg
L­
1
good
Henry's
Law
Constant
1.28
x
10
­
8
atm­
m­
3
mol­
1
fair
Koc
196
L
kg­
1
good
Aerobic
soil
metabolism
half­
life
12
d
fair
Aerobic
aquatic
metabolism
half­
life
29.6
d
fair
Anaerobic
aquatic
metabolism
half­
life
216.6
d
fair
Hydrolysis
half­
life
pH
5
­
assumed
stable
pH
7
­
12
d
pH
9
­
0.133
d
very
good
Aqueous
photolysis
21
d
very
good
Foliar
Degradation
Rate
3.71
d
excellent
Foliar
Washoff
Coefficient
0.91
fair
Drinking
water
EEC's
for
these
crops
and
use
patterns
are
in
Table
7.
The
EEC's
for
citrus
were
recommended
for
single
point
estimation
of
drinking
water
exposure.
EEC's
for
citrus,
apples,
and
sugar
beets
were
calculated
with
the
percent
crop
area
(
PCA)
of
0.87
which
represents
the
largest
amount
of
agricultural
land
in
any
basin
in
the
United
States
represented
with
an
8­
digit
hydrologic
unit
code
(
Seaber
et
al.,
1987),
or
HUC.
Sweet
corn
and
field
corn
used
a
PCA
value
of
0.46
which
is
the
largest
proportion
of
corn
in
any
8­
digit
HUC.
19
Table
7.
Drinking
Water
EEC's
for
carbaryl
based
maximum,
`'
average''
and
maximum
reported
use
patterns.

Crop
Usage
Rate
Number
of
Applications
per
Year
Pounds
A.
I.
per
application
Surface
Water
Acute
(
ppb)
(
1
in
10
year
peak
single
day
concentration)
Surface
Water
Chronic
(
ppb)
(
1
in
10
year
annual
average
concentration)

Sweet
Corn
(
OH)
(
PCA
=
0.46)
Maximum1
8
2
57.3
5.53
Average2
2
3.4
49.8
2.31
Maximum3
Reported
3
1
25.6
1.26
Field
Corn
(
OH)
(
PCA
=
0.46)
Maximum1
4
2
51.3
2.72
Average2
2
1
14.6
0.68
Maximum3
Reported
2
1.5
21.9
1.02
Apples
(
PA)
(
PCA
=
0.87)
Maximum1
5
2
62.9
2.20
Average2
2
1.2
23.4
0.63
Maximum3
Reported
2
1.6
34.4
1.04
Sugar
Beats
(
MN)
(
PCA
=
0.87)
Maximum1
2
1.5
48.2
2.16
Average2
1
1.5
13.6
0.73
Maximum3
Reported
1
1.2
10.8
0.58
Citrus
(
FL)
(
PCA
=
0.87)
Maximum1
4
5
316
14.2
Average2
2
3.4
203
7.33
Maximum3
Reported
3
4.26
272
10.0
1
Maximum
application
rate
on
label
2
Average
application
rate
from
Quantitative
Usage
Analysis
for
Carbaryl,
prepared
July
21,
1998
by
Frank
Hernandez,
OPP/
BEAD
3
Maximum
rate
of
application
reported
in
Doanes
survey
data
Aquatic
EEC's
for
the
maximum
label
use
rate
are
in
Table
8.
The
EEC's
for
`
average
use
rates
are
in
Table
9,
and
the
those
for
maximum
reported
use
patterns
are
in
Table
10.

Table
8.
Aquatic
EEC's
for
the
`
maximum'
use
patterns
for
carbaryl
on
selected
agricultural
crops.

Crop
Peak
4
Day
Mean
21
Day
Mean
60
Day
Mean
­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­
:
g
L­
1
carbaryl
­­­­­­­­­­­­­­­­­­­­­­­­­­­­­

Apples
(
PA)
30.6
25.6
14.8
6.55
Citrus
(
FL)
152.6
135.7
82.0
41.0
Sweet
Corn
52.7
48.8
30.2
19.2
Field
Corn
46.9
41.9
24.9
14.4
Sugar
beets
23.3
20.6
12.8
6.2
20
Table
9.
Aquatic
EEC's
for
the
`
average'
use
patterns
for
carbaryl
on
selected
agricultural
crops.

Crop
Peak
4
Day
Mean
21
Day
Mean
60
Day
Mean
­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­
:
g
L­
1
carbaryl
­­­­­­­­­­­­­­­­­­­­­­­­­­­­­

Apples
(
PA)
11.8
9.911.3
4.6
2.0
Citrus
(
FL)
99.9
89.3
51.3
22.7
Sweet
Corn
45.84
40.6
24.9
12.7
Field
Corn
13.4
11.9
7.3
3.7
Sugar
beets
6.5
5.8
3.4
2.1
Table
10.
Aquatic
EEC's
for
the
`
maximum
reported'
use
patterns
for
carbaryl
on
selected
agricultural
crops.

Crop
Peak
4
Day
Mean
21
Day
Mean
60
Day
Mean
­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­
:
g
L­
1
carbaryl
­­­­­­­­­­­­­­­­­­­­­­­­­­­­­

Apples
(
PA)
15.8
13.2
6.2
1.7
Citrus
(
FL)
130.6
115.7
68.5
30.7
Sweet
Corn
23.5
20.9
11.6
6.8
Field
Corn
20.8
17.9
11.0
6.6
Sugar
beets
5.2
4.6
2.7
1.7
21
AQUATIC
EXPOSURE
ASSESSMENT
For
aquatic
exposure,
the
scenario
uses
a
10­
ha
water
shed
feeding
into
a
1­
ha
standard
pond,
2­
meters
deep
with
no
outlet.
The
standard
pond
serves
not
only
to
protect
ponds
and
small
lakes
but
also
is
intended
as
a
surrogate
for
a
variety
of
small
water
bodies
at
the
top
of
watersheds.
These
include
prairie
potholes,
vernal
pools,
playa
lakes,
bogs,
swamps,
and
other
wetlands,
and
first­
order
streams.
Shallower
static
water
bodies
will
tend
to
have
higher
concentrations
as
will
first­
order
streams,
although
peak
concentrations
in
streams
tends
to
be
of
much
shorter
duration.
Because
these
water
bodies
are
at
the
top
of
the
watershed,
the
assumption
of
100%
cropping
for
the
watershed,
essentially
one
farm
field,
is
reasonable.
Water
bodies
further
downstream
will
have
lower
concentrations
due
to
dilution
with
waters
coming
rom
land
which
was
not
treated.
Some
watersheds
may
have
greater
treated
surface­
area­
to­
pond
volume
ratios
which
will
increase
the
loading
of
pesticide
to
the
pond;
however,
this
effect
is
limited
because
larger
watersheds
are
less
likely
to
be
cropped
to
a
single
crop
all
treated
with
a
single
pesticide,
and
the
associated
increase
in
the
volume
of
runoff
water
makes
it
more
likely
that
there
will
be
pesticide
transported
out
of
the
pond
when
the
pond
overflows.
(
Pond
overflow
is
currently
not
simulated
in
these
assessments.)

Drinking
Water
For
drinking
water
exposure,
the
standard
scenario
uses
the
index
reservoir.
The
index
reservoir
geometry
is
based
on
a
small
reservoir
in
Illinois.
The
watershed
is
172.8
ha
and
feeds
a
2.74­
m
deep
reservoir
that
is
640­
m
long
by
82­
m
wide
with
an
area
of
5.2
ha.
As
opposed
to
the
standard
static
pond,
water
flows
through
reservoir
and
the
rate
is
set
for
each
location
depending
upon
the
total
amount
of
runoff
entering
the
reservoir.
As
with
the
standard
pond,
the
index
reservoir
watershed
geometry
is
combined
with
local
weather
and
soils
to
create
scenarios
for
a
specific
crop
in
a
specific
location
(
APPENDICES
A1
and
A2).

While
the
aquatic
EEC's
are
a
good
estimate
of
what
is
expected
to
be
in
waters
in
certain
waterbodies
which
are
vulnerable
to
pesticide
contamination,
EEC's
for
drinking
water
tend
to
exceed
those
seen
at
drinking
water
facilities.
These
values
are
greater
than
those
that
would
be
expected
to
be
found
in
the
environment
primarily
for
three
reasons.
First,
we
have
used
the
default
PCA
of
0.87,
as
the
PCA
for
citrus
in
Florida.
The
default
PCA
is
the
maximum
proportion
of
agricultural
land
found
in
any
basin
in
the
country,
In
fact,
the
actual
PCA
in
Florida
is
probably
closer
to
one­
third
this
value,
although
a
precise
estimate
is
not
available
at
this
time.
Secondly,
the
percent
crop
treated
has
been
assumed
to
be
100%.
In
fact,
according
to
BEAD
(
Hernandez,
2002),
the
percent
crop
treated
for
different
citrus
crops
ranges
for
1.5
to
6%,
depending
on
the
crop.
Thirdly,
since
the
labels
have
not
specified
maximum
number
of
applications,
the
maximum
practice
modeled
is
substantially
greater
than
that
which
is
usually
used
in
practice.
In
particular,
the
rate
per
acre,
and
the
number
of
treatments
per
season
is
often
less
than
that
allowed
on
the
label.
In
addition,
the
interval
between
applications,
when
there
is
more
than
one
is
usually
longer
than
has
been
simulated
for
the
maximum
use
pattern.
This
third
factor
has
been
addressed
in
this
assessment,
and
is
reflected
in
the
EEC's
from
the
`
average'
and
maximum
reported
use
patterns
from
Table
9
and
10.
Three
additional
simulations
were
done
for
citrus
in
order
to
better
characterize
the
exposure
in
this
scenario.
In
the
first
simulation,
the
application
date
for
the
first
application
was
changed
22
from
April
30
to
August
31,
otherwise
using
the
maximum
application
practice.
The
second
simulation
also
changed
the
first
application
date
but
with
`
average'
application
practice.
While
there
are
pests
which
could
be
of
concern
on
citrus
as
early
as
April,
monitoring
data
from
the
area
indicates
that
most
of
the
usage
actually
occurs
in
the
late
summer.
The
1­
in­
10
year
peak
EEC
for
the
April
application
and
maximum
label
practice
is
316
:
g
L­
1
while
for
September
the
value
is
220
:
g
L­
1.
For
`
average'
application
practice,
the
respective
EEC's
are
203
and
125
:
g
L­
1.
Another
run
was
done
where
best
estimates
for
all
the
metabolism
values
were
used
as
inputs
(
4
day
half­
life
for
aerobic
soil
metabolism,
a
9.6
day
half­
life
for
aerobic
aquatic
metabolism,
72.2
days
for
anaerobic
aquatic
metabolism,
and
3.2
days
for
foliar
degradation)
combined
with
`'
average''
application
practice
in
September
to
give
a
`
best'
estimate
of
the
EEC
for
this
site.
The
1­
in­
10
year
peak
in
this
case
was
78.9
:
g
L­
1.

In
addition
to
the
point
estimate
EEC's
for
drinking
water
exposure
described
above.
We
have
provided
the
time
series
of
concentrations
for
the
entire
duration
of
the
simulation
for
the
different
citrus
scenarios.
These
series
of
estimates
are
intended
for
use
in
a
more
full
of
the
whole
range
dietary
exposure
for
carbaryl
and
are
being
combined
with
pesticide
residues
in
food
using
the
Dietary
Exposure
Estimation
Model
(
DEEM).
Making
wider
use
of
the
whole
time
series
for
drinking
water
exposure
is
expected
to
improve
the
description
of
the
dietary
risk.
However,
using
the
time
series
for
water
in
combination
with
the
distribution
of
food
residues
and
consumption
patterns
normally
used
in
DEEM
substantially
alters
the
interpretation
of
the
risk
represented
by
the
output
of
the
model.
This
is
because
the
drinking
water
component
introduces
a
time
component
which
is
not
present
in
the
food
and
consumption
data
and
any
time
component
in
the
data
is
ignored
by
DEEM.
Technically,
the
food
and
consumption
distributions
are
assumed
to
be
`
stationary'
with
respect
to
time
and
location,
i.
e.,
the
distributions
are
always
the
same
at
any
point
in
time
and
any
location
in
the
United
States.
This
is
a
reasonable
assumption
for
food
residues
and
consumption,
but
not
a
reasonable
one
for
pesticide
residues
in
drinking
water
which
are
expected
to
vary
by
orders
of
magnitude
with
both
time
and
location.
The
difference
in
interpretation
can
be
best
illustrated
by
describing
how
the
interpretation
differs
when
the
different
exposure
components
dominate
the
exposure
profile.
When
food
(
other
than
water
dominates
the
exposure
and
the
drinking
water
contribution
is
negligible,
an
exceedance
of
the
99.9%
threshold
implies
that
one
person
in
1000
across
the
whole
U.
S.
population
is
above
the
threshold
each
day.
If
drinking
water
dominates
and
food
contributions
are
negligible,
an
exceedance
of
the
99.9%
means
that
the
entire
population
provided
drinking
water
from
a
facility
represented
by
scenario,
are
expected
to
exceed
the
risk
once
every
1000
days,
a
little
less
that
once
every
three
years.
When
both
water
and
food
sources
make
significant
contributions
to
exposure,
a
more
detailed
analysis
of
the
structure
of
the
data
is
necessary
to
determine
the
nature
of
the
risk.
Depending
on
the
structure
of
the
risk,
regulating
on
the
99.9
percentile
in
a
manner
similar
to
that
used
previously
may
not
provide
a
intended
level
of
safety
similar
to
that
which
is
provided
by
using
DEEM
with
food
only
and
the
drinking
water
level
of
concern
(
DWLOC)
approach
with
water.
23
Effects
of
Drinking
Water
Treatment
There
is
some
evidence
that
conventional
drinking
water
treatment,
that
is
coagulation,
flocculation
and
settling,
is
expected
to
reduce
carbaryl
concentration
by
43%
of
the
concentration
prior
to
treatment
(
US
EPA,
1989).
This
is
based
on
a
study
of
wastewater
containing
carbaryl
treated
with
alum
at
100
mg
L­
1
and
1
mg
L­
1
of
anionic
polymer
(
Whittaker
et
al.
1982).
In
addition,
ozone
has
been
shown
to
be
99%
effective
at
removing
carbaryl
from
water
(
Shevchenko
et
al.,
1982)
and
removes
it
from
water
at
a
rate
too
fast
to
measure
(
Mason
et
al.
1990).
Evidence
suggests
that
chlorine
and
hypochlorite
may
be
ineffective
at
degrading
carbaryl
(
ibid.).
At
this
point
in
time,
ozonation
is
only
infrequently
used
for
disinfection
of
public
drinking
water
in
the
United
States.
Based
on
the
hydrolysis
data,
softening
would
be
expected
to
substantially
reduce
carbaryl
concentrations
(
via
alkaline
hydrolysis)
as
softening
raises
the
pH
of
the
water
as
high
as
11.
Softening
is
used
on
`
hard'
water
that
is
high
in
calcium
and
magnesium
and
decreases
the
concentrations
of
these
cations.
The
Office
of
Pesticide
Programs
currently
does
not
have
sufficient
information
to
account
for
locations
where
water
softening
processes
are
utilized
at
public
drinking
water
treatment
facilities,
and
thus
cannot
systematically
use
this
information
in
estimating
EEC's.

Drinking
Water
Monitoring
Study
Aventis
voluntarily
conducted
a
study
entitled
"
Surface
Water
Monitoring
for
Residue
of
Carbaryl
in
High
Use
Areas
in
the
United
States:
Final
Report".
The
study
provided
useful
information
on
measured
concentrations
of
carbaryl
in
selected
surface
waters
of
the
United
States.
Based
on
an
analysis
of
sites
selected,
it
was
determined
that
the
results
of
the
study
could
not
be
used
directly
in
the
dietary
risk
assessment
to
represent
exposure
to
carbaryl
in
surface
water
source
drinking
water
(
APPENDICES
B1
and
B2).
The
information
from
this
study
provided
some
good
quality
data
that
could
be
used
in
association
with
other
monitoring
data
sets
in
conjunction
with
surface
water
modeling
to
characterize
carbaryl
exposure
from
surface­
water
source
drinking
water
TERRESTRIAL
EXPOSURE
ASSESSMENT
Terrestrial
exposure
was
evaluated
using
estimated
environmental
concentrations
generated
from
a
spreadsheet­
based
model
(
EL­
FATE)
that
calculates
the
decay
of
a
chemical
applied
to
foliar
surfaces
for
single
or
multiple
applications
(
APPENDIX
C).
The
model
uses
the
same
principle
as
the
batch
code
models
FATE
and
TERREEC
for
calculation
of
terrestrial
estimated
exposure
concentrations
(
TEEC)
on
plant
surfaces
following
application.
Further
explanation
of
the
model
is
presented
in
Appendix
D.

The
terrestrial
exposure
assessment
is
based
on
the
methods
of
Hoerger
and
Kenaga
(
1972)
as
modified
by
Fletcher
et
al.
(
1994).
Terrestrial
estimated
environmental
concentrations
(
EECs)
for
nongranular
and
granular
formulations
(
Table
11)
were
derived
for
major
crops
using
current
application
rates
and
intervals
between
applications.
Uncertainties
in
the
terrestrial
EECs
are
primarily
associated
with
a
lack
of
data
on
interception
and
subsequent
dissipation
from
foliar
surfaces.
However,
the
registrant
submitted
foliar
dissipation
studies
from
which
a
90th
percent
confidence
interval
value
for
the
mean
(
8.07
days)
was
used
as
a
foliar
dissipation
rate
for
modeling
purposes.
24
For
pesticides
applied
as
a
nongranular
product
(
e.
g.,
liquid,
dust),
the
estimated
environmental
concentrations
(
EECs)
on
food
items
following
product
application
are
compared
to
LC50
values
to
assess
risk.
The
predicted
0­
day
maximum
and
56­
day
mean
residues
of
a
pesticide
that
may
be
expected
to
occur
on
selected
avian
or
mammalian
food
items
immediately
following
a
direct
single
application
at
1
lb
ai/
A
and
3
lbs
ai/
A
are
presented
in
Table
8.

Table
11.
Estimated
environmental
concentrations
on
avian
and
mammalian
food
items
(
ppm)
following
single
applications
at
1
lb
ai/
A.

Application
Rate
Food
Items
EEC
(
ppm)
Predicted
Maximum
Residue1
EEC
(
ppm)
56
Day
Mean1
1
lb
a.
i./
A
Short
grass
240
27
Tall
grass
110
10
Broadleaf/
forage
plants
and
small
insects
135
11
Fruits,
pods,
seeds,
and
large
insects
15
1
1
Predicted
maximum
and
mean
residues
are
for
a
1
lb
ai/
a
application
rate
and
are
based
on
Hoerger
and
Kenaga
(
1972)
as
modified
by
Fletcher
et
al.
(
1994).
25
ECOLOGICAL
EFFECTS
ASSESSMENT
APPENDIX
D1
summarizes
the
105­
plus
ecological
toxicity
studies
considered
in
this
evaluation.
Information
on
acute
and
chronic
effects
is
drawn
from
both
guideline
and
nonguideline
studies.
Toxicity
testing
reported
in
this
section
does
not
represent
all
species
of
bird,
mammal,
or
aquatic
organism.
Only
a
few
surrogate
species
for
both
freshwater
fish
and
birds
are
used
to
represent
all
freshwater
fish
(
2000+)
and
bird
(
680+)
species
in
the
United
States.
For
mammals,
acute
studies
are
usually
limited
to
Norway
rat
or
the
house
mouse.
Estuarine/
marine
testing
is
usually
limited
to
a
crustacean,
a
mollusk,
and
a
fish.
Also,
neither
reptiles
nor
amphibians
are
tested.
The
assessment
of
risk
or
hazard
makes
the
assumption
that
avian
and
reptilian
toxicities
are
similar.
The
same
assumption
is
used
for
fish
and
amphibians.

Carbaryl
is
practically
nontoxic
to
birds,
moderately
toxic
to
mammals
and
fish,
and
very
highly
toxic
to
bees
and
aquatic
invertebrates
on
an
acute
exposure
basis.
Table
12
provides
a
summary
of
the
most
sensitive
ecological
toxicity
endpoints
used
in
the
hazard
assessment
of
terrestrial
animals
and
Table
13
summarizes
the
most
sensitive
endpoints
used
in
the
hazard
assessment
of
aquatic
animals.
A
more
detailed
discussion
of
the
ecological
toxicity
studies
that
went
into
this
assessment
can
be
found
in
APPENDIX
D1.
Additionally,
data
indicate
that
the
carbaryl
hydrolysis
degradate
1­
naphthol
ranges
in
toxicity
from
moderately
to
highly
toxic
to
aquatic
organisms.

Table
12.
Summary
of
acute
and
chronic
toxicity
data
for
terrestrial
organisms
exposed
to
carbaryl.

Species
Acute
Toxicity
Chronic
Toxicity
LD50
(
ppm)
Acute
Oral
Toxicity
(
MRID)
5­
day
LC50
(
ppm)
Subacute
Dietary
Toxicity
(
MRID)
NOEC/
LOEC
(
ppm)
(
MRID)
Affected
Endpoints
Mallard
duck
Anas
platyrhynchos
>
2000
practically
nontoxic
(
458206­
01)
>
5000
practically
nontoxic
(
00022923)
300
/
600
(
ACC263701)
decreased
number
of
eggs;
eggs
cracked
Honey
bee
Apis
meliferus
0.0011
very
highly
toxic
(
05004151)
­­
­­
­­
­­

Laboratory
rat
Rattus
norvegicus
301
moderately
toxic
(
00148500)
­­
­­
75
/
300
(
447329­
01)
decreased
pup
survival
26
Table
13.
Summary
of
acute
and
chronic
aquatic
toxicity
estimates
using
technical
grade
carbaryl.

Species
Acute
Toxicity
Chronic
Toxicity
96­
hr
LC50
(
mg/
L)
48­
hr
EC50
(
mg/
L)
Acute
Toxicity
(
MRID)
NOEC
/
LOEC
(
mg/
L)
Affected
Endpoints
(
MRID)

Atlantic
Salmon
Salmo
salar
0.250
­­
very
highly
toxic
(
40098001)
­­
­­

Fathead
Minnow
Pimephales
promelas
­­
­­
0.21
/
0.68
reduced
growth
(
TOUCAR05)

Stonefly
Chloroperla
grammatica
0.0051
very
highly
toxic
(
458206­
02)

Water
flea
Daphnia
magna
­­
­­
­­
0.0015
/
0.0033
reproduction
(
00150901)

Sheepshead
minnow
Cyprinodon
variegatus
2.6
­­
moderately
toxic
(
423728­
01)
­­
­­

Mysid
shrimp
Mysidopsis
bahia
0.45
0.0057
very
highly
toxic
(
423434­
01)
­­
­­

Effects
Assessment
for
Terrestrial
Organisms
Birds
Carbaryl
is
practically
nontoxic
to
birds
on
both
an
acute
exposure
(
LD50
>
2,000
mg/
Kg)
and
subacute
dietary
exposure
basis
(
LC50
>
5,000
mg/
Kg
of
diet).
Acute
toxicity
estimates
as
low
as
16
mg/
Kg
and
56
mg/
Kg
have
been
reported
for
starlings
(
Sturnus
vulgaris)
and
red­
winged
black
birds
(
Agelaius
phoeniceus),
respectively
(
Schafer
et
al.
1983)
and
it
is
uncertain
whether
smaller
passerine
species
may
be
more
sensitive
to
the
effects
of
carbaryl.
EFED
recommends
that
acute
toxicity
testing
be
conducted
with
passerine
species
to
address
this
uncertainty.

Exposure
to
carbaryl
on
a
chronic
exposure
basis
resulted
in
adverse
reproductive
effects
including
decreased
number
of
eggs
produced,
increased
number
of
eggs
cracked
and
decreased
fertility
(
NOEC
=
300
mg/
Kg
of
diet).

A
total
of
five
incidents
(
APPENDIX
D1)
involving
birds
have
been
reported
under
6(
a)
2
in
the
Ecological
Incident
Information
System
(
EIIS)
database.
However,
only
two
of
the
five
appear
to
clearly
attributed
to
carbaryl
and
only
one
of
those
two
could
be
linked
to
a
specific
registered
use.
The
remaining
incidents
appear
to
have
been
associated
with
either
intentional
poisoning
or
the
co­
occurrence
of
much
more
toxic
pesticides.
In
one
incident
(
I012817­
001)
a
single
morning
dove
(
Zenaida
macroura)
was
discovered
dead;
the
animal
exhibited
reduced
acetylcholinesterase
activity
and
had
2.4
mg/
Kg
of
carbaryl
in
its
stomach
contents.
The
report
suggests
that
birdseed
around
a
feeder
had
become
contaminated
after
carbaryl
was
applied
to
the
property
owner's
lawn.
In
a
second
incident
(
I000802­
001),
five
blackbirds
were
discovered
dead.
No
residue
analysis
was
conducted
on
the
birds
but
carbaryl
residues
were
detected
in
dead
squirrel
found
in
the
vicinity;
acetylcholinesterase
activity
was
not
reduced
in
the
squirrel.
While
these
incidents
do
not
provide
substantial
evidence
that
carbaryl
is
impacting
birds
in
the
wild,
they
do
27
emphasize
the
need
to
address
the
uncertainty
regarding
the
sensitivity
of
passerine
species
to
carbaryl.

Mammals
Carbaryl
is
moderately
toxic
(
LD50
=
301
mg/
Kg)
to
mammals
on
an
acute
exposure
basis.
Chronic
exposure
to
carbaryl
resulted
in
decreased
second­
generation
pup
survival
(
NOEC
=
75
mg/
kg
of
diet).

A
total
of
two
incidents
were
reported,
one
(
I000802­
001)
involving
a
gray
squirrel
(
Sciurus
carolinensin)
and
a
second
involving
a
hairytail
mole
(
Parascalops
breweri).
In
neither
case
was
information
provided
on
the
use
of
carbaryl
that
may
have
resulted
in
the
deaths
of
these
animals.

Insects
Carbaryl
is
highly
toxic
to
honey
bees
(
Apis
mellifera)
on
an
acute
contact
basis
(
LD50
=
0.0011
mg/
bee);
however,
acute
contact
toxicity
testing
of
Carbaryl
SC
indicates
bees
are
less
sensitive
to
the
formulated
product
(
LD50
=
0.0040
mg/
bee).
Acute
oral
toxicity
studies
with
carbaryl
reveal
that
technical
grade
carbaryl
(
LC50
=
0.0001
mg/
bee)
is
roughly
ten
times
more
toxic
than
the
formulated
soluble
concentrate
(
Carbaryl
SC
LC50
=
0.0016
mg/
bee).
Carbaryl
ranged
from
being
moderately
to
highly
toxic
to
predacious
insects,
mites
and
spiders.

In
a
field
study
to
examine
the
effects
of
carbaryl
on
bees
when
the
chemical
is
used
to
thin
fruit,
Carbaryl
SC
applications
to
apple
orchards
at
a
rate
of
0.8
lbs
a.
i./
Acre
did
not
have
a
significant
(
P
>
0.05)
affect
on
bee
mortality
and/
or
behavior.

A
total
of
5
incidents
related
to
carbaryl
are
reported
in
the
EIIS
database.
Two
of
the
reports
(
I005855­
001
and
B0000­
300­
03)
do
not
contain
any
data
but
rather
reflect
general
concerns
expressed
by
the
American
Beekeeper
Federation
and
the
Honey
Industry
Council
on
the
role
pesticides
in
bee
kills.
The
Honey
Industry
Council
sited
the
specific
use
of
carbaryl
on
alfalfa
during
the
day.
In
North
Carolina
(
incident
#
I003826­
021),
a
bee
mortality
was
associated
with
0.8
ppm
carbaryl
residues;
however,
in
a
second
incident
(#
I003826­
0090
in
North
Carolina,
bee
mortality
was
more
likely
attributed
to
methyl
parathion
than
carbaryl.
Only
in
one
incident
(
I001611­
002)
though,
was
the
use
of
carbaryl
on
a
specific
crop,
i.
e.,
asparagus
in
Washington,
clearly
associated
with
carbaryl
residues
in
dead
bees.
28
0
10
20
30
40
50
60
70
80
90
100
0
5
10
15
20
25
Carbaryl
(
mg/
L)
Percent
of
Total
Species
Atlantic
Salmon
Black
Crappie
Lake
Trout
Cutthroat
Trout
Rainbow
Trout
Longnose
killifish
Chinook
Salmon
Coho
Salmon
Yellow
Perch
Brook
Trout
Common
Carp
Brown
Trout
Largemouth
Bass
Fathead
Minnow
Channel
Catfish
Bluegill
Green
Sunfish
Black
Bullhead
Moderately
toxic
Figure
2..
Cumulative
percent
distribution
of
96­
hour
acute
LC50
values
in
mg/
L
(
ppm)
for
freshwater
fish
exposed
to
technical
grade
carbaryl.
Vertical
dashed
lines
indicate
range
of
LC50
values
classified
as
moderately
toxic.
LC50
values
10
­
100
mg/
L
are
considered
slightly
toxic.
Hazard
Assessment
for
Aquatic
Organisms
Freshwater
Fish
On
an
acute
exposure
basis,
technical
grade
(
purity
>
90%)
carbaryl
ranged
in
toxicity
from
highly
to
slightly
toxic
(
LC50
=
0.25
­
20
mg/
L)
to
freshwater
fish
and
to
fish
that
spend
a
portion
of
their
life
cycle
in
fresh
water,
such
as
the
Atlantic
salmon
(
Salmo
salar).
Figure
2
shows
a
cumulative
percent
frequency
distribution
of
96­
hour
LC50
values
for
freshwater
fish
and
demonstrates
that
for
the
majority
(
78%)
of
fish
tested,
carbaryl
was
moderately
toxic
(
LC50
range:
1
­
10
mg/
L).
In
general,
coldwater
species,
e.
g.
salmonids,
appear
to
be
more
sensitive
to
carbaryl
than
warm
water
species
(
e.
g.,
centrarchid
sunfish
and
bass).
Although
Atlantic
salmon
(
Salmo
salar)
are
used
as
the
most
sensitive
species
(
96­
hr
LC50
=
0.250
mg/
L),
they
represent
an
extreme
in
the
range
of
sensitivities
among
freshwater
fish;
assuming
a
log­
normal
distribution
for
the
LC50
values,
the
mean
is
1.28
mg/
L
and
the
lower
5%
confidence
interval
is
1.23
mg/
L.
LC50
values
for
the
typical
end
use
products
(
purity
range:
5
to
82%)
from
1.4
to
290
mg/
L,
falling
in
the
moderately
to
practically
nontoxic
categories.
Acute
toxicity
testing
of
carbaryl's
hydrolysis
degradate
1­
naphthol
in
fish
shows
that
the
compound
ranged
from
being
moderately
to
highly
toxic
(
LC50
range
0.75
­
1.6
mg/
L).
29
Chronic
exposure
of
fathead
minnows
(
Pimephales
promelas)
to
carbaryl
resulted
in
reduced
survival
and
reproductive
effects
(
NOEC
=
0.210
mg/
L)
including
reduced
number
of
eggs
per
female
and
reduced
number
of
eggs
spawned.
Chronic
exposure
of
fathead
minnows
to
1­
naphthol
reduced
larval
growth
and
survival
(
NOEC
=
0.1
mg/
L);
at
the.

Although
a
total
of
three
fish­
kill
incidents
were
reported
for
carbaryl
(
APPENDIX
D1),
only
one
report
(#
B0000­
501­
92)
could
be
credibly
associated
with
a
specific
carbaryl
use,
i.
e.,
to
control
gypsy
moth
in
New
Jersey.

Amphibians
The
majority
of
data
available
on
amphibians
focused
on
the
juvenile
tadpole
stage
of
frogs.
Carbaryl
ranged
from
moderately
toxic
(
96­
hr
LC50
=
8.4
mg/
L)
to
Southern
leopard
frogs
(
Rana
sphenocephalia)
to
slightly
toxic
(
96­
hr
LC50
=
12.2
mg/
L)
to
boreal
toads
(
Bufo
boreas)
on
an
acute
exposure
basis
(
APPENDICES
D2
and
D23).
In
toxicity
testing
with
formulated
product
(
purity
=
50%
carbaryl
was
practically
nontoxic
to
bullfrogs
(
Rana
catesbeiana)
with
an
LD50
greater
than
4,000
mg/
kg
(
MRID
00160000).
The
sensitivity
of
tadpoles
to
carbaryl
exhibited
considerable
intraand
interspecies
variability.
Depending
on
the
stage
of
development,
the
conditions
of
exposure,
and
which
frog
populations
were
sampled,
frog
susceptibility
to
carbaryl
varied.
For
example,
the
96­
hr
LC50
for
green
frogs
(
Rana
clamitans)
roughly
doubled
when
temperature
dropped
from
27oC
(
LC50
=
11.3
mg/
L)
to
17oC
(
LC50
=
22
mg/
L).

Information
on
the
sublethal
effects
of
carbaryl
on
amphibians
indicated
that
a
single
acute
exposure
of
plains
leopard
frog
tadpoles
(
Rana
blairi)
to
carbaryl
concentrations
ranging
from
3.5
­
7.2
mg/
L
resulted
in
a
90%
reduction
in
swimming
activity
(
including
sprint
speed
and
sprint
distance)
with
activity
completely
ceasing
at
7.2
mg/
L
(
Bridges
1997).
Slower
swimming
speeds,
altered
activity
patterns
and
prolonged
juvenile
stages
have
been
suggested
as
increasing
the
vulnerability
of
frogs
to
predation
(
Bridges
1997;
Bridges
1999;
Relyea
and
Mills
2001)
and/
or
that
the
threat
of
predation
renders
the
animals
more
susceptible
to
the
direct
toxicity
of
carbaryl
(
Relyea
and
Mills
2001).
While
the
Relyea
and
Mills
paper
indicates
that
carbaryl
was
2
to
4
times
more
lethal
to
gray
treefrogs
(
Hyla
versicolor)
in
the
presence
of
a
predator,
the
study
is
confounded
by
the
potential
effects
of
water
quality
on
mortality
(
APPENDIX
D3).

On
a
chronic
exposure
basis,
carbaryl
has
been
shown
to
have
the
potential
to
adversely
affect
amphibians.
Southern
leopard
frog
tadpoles
exposed
to
carbaryl
during
development
exhibited
some
type
of
developmental
deformity,
including
both
visceral
and
limb
malformations,
compared
to
less
than
1%
in
control
tadpoles
(
Bridges,
2000).
Although
the
length
of
the
larval
period
was
the
same
for
all
experimental
groups,
tadpoles
exposed
throughout
the
egg
stage
were
smaller
than
their
corresponding
controls.
However,
in
some
cases,
it
is
unclear
whether
the
effects
of
carbaryl
on
amphibians
has
been
entirely
adverse.
For
example,
Southern
leopard
frogs
exposed
to
carbaryl
at
5
mg/
L
exhibited
a
20%
increase
in
weight
at
metamorphosis(
Bridges
and
Boone
2003)
and
that
at
concentrations
as
high
as
7
mg/
L,
Woodhouse's
toad
(
Bufo
woodhousii)
survival
was
roughly
30%
higher
than
controls
(
Boone
and
Semlitsch
2002).
30
0
20
40
60
80
100
0
5
10
15
20
25
30
Carbaryl
(
ug/
L)
Percent
of
Total
Species
Pteronarcella
Pteronarcella
Isogenus
Classenia
Gammarus
Figure
3.
Cumulative
percent
distribution
of
acute
96­
hr
EC50
values
in
µ
g/
L
(
ppb)
for
freshwater
invertebrates
exposed
to
carbaryl.
Freshwater
Invertebrates
Technical
grade
carbaryl
is
very
highly
toxic
to
aquatic
invertebrates
with
EC50
values
ranging
from
0.0017
­
0.026
mg/
L
on
an
acute
exposure
basis.
Figure
3
shows
a
cumulative
percent
distribution
of
96­
hr
EC50
values
for
freshwater
invertebrates;
roughly
80%
of
the
species
tested
had
EC50
values
between
0.002
and
0.006
mg/
L.
In
general,
freshwater
invertebrates
exhibited
the
same
sensitivity
(
EC50
range:
0.007
­
0.013
mg/
L)
to
formulated
end
products
(
purity
range:
44
­
81%).
In
studies
examining
the
toxicity
of
carbaryl
to
aquatic
invertebrates
in
the
presence
of
sediment,
toxicity
values
were
more
widely
distributed
(
EC50
range
0.005
to
>
2.5
mg/
L)
suggesting
that
tendency
of
carbaryl
and
its
hydrolysis
degradate
1­
naphthol
to
partition
to
sediment
may
limit
their
bioavailability
and
hence
lower
toxicity
under
more
natural
exposure
conditions.
Additionally,
in
an
acute
1­
hr
"
pulse"
exposure,
50%
of
the
stonefly
larvae
(
Chloroperla
grammatica)
were
immobilized
by
0.028
mg/
L;
however,
the
affected
animals
recovered
completely
after
removal
to
freshwater.
The
ability
of
invertebrates
to
fully
recover
is
uncertain
though
as
one
study
(
Mora
et
al.
2000)
showed
that
following
a
72
­
hr
exposure
to
carbaryl
at
0.0032
mg/
L
snail,
acetylcholine
esterase
activity
did
not
return
to
pre­
exposure
levels.
Studies
have
indicated
that
acute
exposure
to
carbaryl
impacts
predator
avoidance
mechanisms
in
invertebrates
(
Hanazato
1995),
reduces
overall
zooplankton
abundance
(
Havens
1995;
Hanazato
1989),
and
may
actually
promote
phytoplankton
growth
through
reduced
predation
by
zooplankton
(
Bridges
and
Boone
2003).

Exposure
of
freshwater
invertebrates
to
1­
naphthol
indicated
the
degradate
ranged
from
being
moderately
to
highly
toxic
(
EC50
range:
0.2
­
3.3
mg/
L).
31
On
a
chronic
exposure
basis,
carbaryl
affected
reproduction
(
NOEC
=
0.0015
mg/
L)
in
water
fleas
(
Daphnia
magna).
Following
a
28­
day
static
exposure
study
of
midge
larvae
(
Chironomous
riparius)
with
sediment,
reduced
emergence
and
developmental
rates
were
the
most
sensitive
endpoints;
however,
the
midge
was
considerably
less
sensitive
(
NOEC
=
0.5
mg/
L).
It
is
unclear
from
the
results
of
this
study
what
the
actual
exposure
conditions
were
however;
midge
larvae
are
benthic
macroinvertebrates
and
exposure
may
have
been
better
characterized
had
it
been
based
on
sediment
pore
water
concentrations
as
opposed
to
carbaryl
concentrations
in
overlying
water.
This
study
did
indicate
though
that
both
carbaryl
and
its
1­
naphthol
degradate
were
below
detection
limits
by
Day
7
of
exposure.

Estuarine/
Marine
Fish
Considerably
less
data
were
available
on
carbaryl's
affect
on
estuarine/
marine
fish;
on
average
though,
carbaryl
is
moderately
toxic
(
LC50
=
2.2
mg/
L)
to
Sheepshead
minnow
(
Cyprinodon
variegatus)
on
an
acute
exposure
basis..
In
sublethal
effect
tests,
exposure
to
a
single
dose
of
carbaryl
at
0.10mg/
L
adversely
affected
schooling
behavior
in
the
silverside
(
Weis
and
Weis,
1974).
Additionally,
exposure
to
carbaryl
at
0.01
mg/
L
caused
retardation
of
fin
regeneration
during
the
first
week
of
the
study
in
the
killifish
(
Fundulus
heteroclitus)
(
Weis
and
Weis
1975).
Field
exposure
to
a
maximum
carbaryl
water
concentration
of
1.2
mg/
L
affected
burying
behavior
in
caged
English
sole
young
(
Pozorycki,
1999).

At
present
there
are
no
data
with
which
to
evaluate
the
chronic
toxicity
of
carbaryl
for
marine/
estuarine;
therefore,
EFED
is
recommending
that
chronic
toxicity
testing
be
conducted
using
estuarine/
marine
fish.
Guideline
testing
requirement
72­
4(
a)
is
not
fulfilled.

Estuarine/
Marine
Invertebrates
Technical
grade
carbaryl
ranged
from
being
moderately
to
very
highly
toxic
estuarine/
marine
invertebrates
on
an
acute
basis
(
48­
hr
EC50
range
0.0015
to
2.7
mg/
L).
A
cumulative
percent
distribution
of
48­
hr
EC50
values
(
Figure
4)
shows
that
for
75%
of
shrimp
species
tested,
carbaryl
is
very
highly
toxic,
i.
e.,
EC50
<
0.1
mg/
L
while
oysters
were
relatively
insensitive
to
the
effects
of
carbaryl
(
EC50
=
2.7
mg/
L).
Similarly,
formulated
end
products
(
purity
range:
43
­
82%)
were
very
highly
toxic
to
mysid
shrimp
(
Mysidopsis
bahia)
while
slightly
toxic
to
Eastern
oysters
(
Crassostrea
virginica)
with
EC50
values
of
0.009
mg/
L
and
23.6
mg/
L,
respectively.

No
data
were
available
to
assess
the
chronic
risk
of
carbaryl
to
estuarine/
marine
invertebrates
and
EFED
recommends
that
such
studies
be
undertaken.

Aquatic
Plants
Only
two
studies
of
the
filamentous
green
algae
Pseudokirchneriella
subcaptitata
were
available
to
assess
the
toxicity
of
carbaryl
to
aquatic
plants.
With
technical
grade
carbaryl
the
concentration
inhibiting
plant
growth
(
in
terms
of
number
of
algal
cells)
by
50%
(
IC50
=
1.27
mg/
L)
32
0
20
40
60
80
100
0
500
1000
1500
2000
2500
3000
Carbaryl
(
ug/
L)
Percent
of
Total
Species
Moderately
Toxic
Highly
Toxic
Brown
shrimp
Glass
shrimp
Pink
shrimp
Fairy
shrimp
Blue
crab
Eastern
oyster
Figure
4.
Cumulative
percent
distribution
of
acute
48­
hr
EC50
values
in
µ
g/
L
(
ppb)
for
estuarine/
marine
invertebrates
exposed
to
carbaryl.
The
area
between
the
vertical
dashed
lines
represent
EC50
values
classified
as
highly
toxic;
to
the
right
of
the
dashed
vertical
line
where
EC50
values
lie
between
1000
and
10,000
:
g/
L
is
classified
as
moderately
toxic.
was
roughly
similar
to
the
endpoint
for
formulated
end
product
(
IC50
=
3.2
mg/
L).
In
neither
study
were
abnormalities
in
cell
morphology
or
signs
of
phytotoxic
effects
observed.
As
reported
earlier,
carbaryl
use
has
been
associated
with
increases
in
phytoplankton
numbers.
Whether
this
is
due
to
reduced
predation
by
zooplankton
as
a
result
of
their
greater
susceptibility
to
carbaryl
and/
or
a
response
to
1­
naphthol
being
a
plant
auxin
is
unclear.
EFED
recommends
that
additional
aquatic
plant
studies
be
undertaken
with
the
following
species:
duckweed
(
Lemna
gibba),
freshwater
bluegreen
algae
(
Anabaena
flos­
aquae),
the
freshwater
diatom
(
Navicula
pelliculosa)
and
the
marine
diatom
(
Skeletonema
costatum).
33
ECOLOGICAL
HAZARD
ASSESSMENT
To
evaluate
the
potential
risk
to
nontarget
organisms
from
the
use
of
carbaryl
products,
risk
quotients
(
RQs)
are
calculated
from
the
ratio
of
estimated
environmental
concentrations
(
EECs)
to
ecotoxicity
values.
RQs
are
then
compared
to
levels
of
concern
(
LOCs)
used
by
OPP
to
indicate
potential
risk
to
nontarget
organisms
and
the
need
to
consider
regulatory
action
(
see
APPENDIX
F
for
more
discussion).

Nontarget
Terrestrial
Animals
The
estimated
environmental
concentration
(
EEC)
values
used
for
terrestrial
exposure
are
derived
from
the
Kenaga
nomograph,
as
modified
by
Fletcher
et
al.
(
1994),
based
on
a
large
set
of
actual
field
residue
data.
The
upper
limit
values
from
the
nomograph
represent
the
95th
percentile
of
residue
values
from
actual
field
measurements
(
Hoerger
and
Kenega,
1972).
The
Fletcher
et
al.
(
1994)
modifications
to
the
Kenaga
nomograph
are
based
on
measured
field
residues
from
249
published
research
papers,
including
information
on
118
species
of
plants,
121
pesticides,
and
17
chemical
classes.
These
modifications
represent
the
95th
percentile
of
the
expanded
data
set.
Risk
quotients
are
based
on
the
most
sensitive
LC50
and
NOAEC
for
birds
(
in
this
instance,
mallard
ducks)
and
LD50
for
mammals
(
based
on
lab
rat
studies).

Birds
Since
carbaryl
is
practically
nontoxic
to
birds
on
both
an
acute
and
subacute
dietary
exposure
basis,
no
acute
RQ
values
have
been
calculated
and
acute
risk
to
birds
is
assumed
to
lie
below
the
established
level
of
concern,
i.
e.,
RQ
<
0.1.
Chronic
risk
quotients
(
APPENDIX
F)
based
on
an
mallard
duck
NOEC
of
300
mg/
Kg
of
diet
(
ppm)
for
birds
feeding
on
four
categories
of
food,
i.
e.,
short
grasses,
tall
grasses,
broadleaf
plants/
small
insects,
and
fruit/
seeds/
large
insects,
are
depicted
in
Figure
5.
For
birds
feeding
on
short
grasses,
the
chronic
risk
LOC
(
RQ
=
1)
is
exceeded
for
all
nongranular
uses.
For
birds
feeding
on
tall
grasses
and
broadleaf
plants/
small
insects,
55%
and
60%
of
the
modeled
use
categories
exceed
the
chronic
LOC,
respectively.
None
of
the
modeled
uses
exceeded
the
chronic
LOC
for
birds
feeding
on
fruit/
seeds/
large
insects.
Generally,
crops
groupings
receiving
multiple
applications
of
greater
than
3
lbs/
Acre
per
application
(
citrus,
olives,
pome
fruits,
stone
fruits,
tree
nuts
and
turf)
or
crop
groupings
receiving
four
or
more
applications
of
2
lbs/
acre
with
short
(#
7days)
reapplication
intervals
(
sweet
corn,
asparagus,
solanaceous
crops,
small
fruits
and
berries)
are
likely
to
result
in
risk
of
chronic
reproductive
effects
in
birds
feeding
on
three
out
of
the
four
food
categories
(
short
grasses,
tall
grasses
and
broadleaf
plants/
small
insects).

In
addition
to
maximum
label
use
rates,
avian
RQs
were
also
calculated
for
nongranular
carbaryl
based
on
quantitative
use
assessment
(
QUA)
rates
for
70
crops.
Furthermore,
chronic
RQ
values
were
calculated
based
on
maximum
reported
use
rates
derived
from
Doane
Report
data
on
42
crops.
For
both
use
rates,
risk
quotients
were
only
calculated
for
birds
feeding
on
short
grasses
since
this
food
sources
represents
the
highest
exposure
potential.
When
RQ
values
are
based
on
QUA
average
use
rates,
the
chronic
LOC
is
exceeded
for
49%
of
the
uses
(
APPENDIX
F
Table
5b).
When
RQ
values
are
based
on
maximum
reported
use
rates,
the
chronic
LOC
is
met
34
0
1
2
3
4
5
6
7
8
9
Citrus
O
lives
Pom
e
Stone
Tre
e
N
uts
Cor
n
Rice
Sugar
Beets
Asparagus
Vegetables
Cuc
u
r
b
its
Sola
na
c
ous
Legum
es
Sm
a
ll
Fruits
Alfalfa
Rangeland
Forest
Turf
Crop
C
ategory
Chronic
RQ
S
h
ort
Ta
l
l
B
road
Fru
i
t
Avian
Chronic
Risk
Quotients
at
Maximum
Label
Rates
Chronic
LOC
Figure
5.
Chronic
risk
quotients
(
RQ)
in
selected
crop
categories
for
birds
feeding
on
short
grasses,
tall
grasses,
broadleaf
plants/
small
insects
and
fruits/
seeds/
large
insects
at
maximum
label
application
rates.
The
chronic
level
of
concern
(
LOC)
is
exceeded
at
RQ
$
1.

or
exceeded
for
81%
of
the
uses
(
APPENDIX
F
Table
5c).
Typically,
single
average
application
rates
of
more
than
1.3
lbs/
Acre
or
multiple
rates
of
greater
than
1
lbs/
Acre
are
likely
to
exceed
the
chronic
risk
LOC.
At
maximum
reported
application
rates,
the
only
crops
where
the
chronic
risk
LOC
was
not
exceeded
(
canola,
carrots,
cauliflower,
cucumbers,
lettuce,
sorghum,
sunflower
and
wheat)
all
had
single
application
rates
of
less
than
1
lb/
Acre.

As
noted
earlier,
although
carbaryl
is
characterized
as
being
practically
nontoxic
to
birds,
there
is
uncertainty
whether
small
birds
may
be
more
sensitive.
Open
literature
suggests
that
carbaryl
may
be
moderately
toxic
to
small
birds.
Additionally,
the
only
two
field
incidents
that
could
be
associated
with
carbaryl
use
affected
smaller­
sized
birds.
Further
study
should
be
directed
toward
addressing
this
uncertainty.
35
Mammals
Similar
to
exposure
estimates
for
birds,
residues
on
mammalian
food
items
are
determined
using
Hoerger
and
Kenaga
(
1972)
as
modified
by
Fletcher
et
al.
(
1994).
A
description
of
the
method
used
in
deriving
mammalian
RQs
can
be
found
in
APPENDIX
F.

Acute
Risk
Figures
6,
7
and
8
depict
acute
risk
quotients
for
small,
intermediate
and
large­
sized
mammals,
respectively,
feeding
on
short
grasses,
broadleaf/
forage
plants/
small
insects,
fruit/
pods/
seeds
and
large
insects
and
seeds
on
nongranular
carbaryl
uses
at
maximum
label
rates.
The
acute
risk
LOC
(
RQ
$
0.5)
is
exceeded
for
all
small
(
Figure
6;
RQ
range
0.76
to
12)
and
intermediate­
sized
(
Figure
7;
RQ
range:
0.53
­
8.4)
mammals
feeding
on
short
grasses.
For
largesized
mammals,
the
acute
risk
LOC
is
exceeded
for
40%
of
the
use
categories
(
Figure
8).
The
acute
endangered
species
LOC
(
RQ
$
0.1)
is
exceeded
for
all­
sized
mammals
feeding
on
short
grasses.

For
mammals
feeding
on
broadleaf/
forage
plants
and
small
insects,
the
acute
risk
LOC
is
exceeded
on
all
uses
except
rangeland
for
small­
sized
mammals
(
Figure
6).
For
intermediate­
sized
animals
(
Figure
7),
75%
of
the
use
categories
exceed
the
acute
high
risk
LOC
(
RQ
range:
0.56
­
4.74).
For
large­
sized
animals
(
Figure
8),
the
acute
risk
LOC
is
reached
or
exceeded
for
olives
(
RQ
=
0.54)
and
turfgrass
(
RQ
=
0.68).
RQ
values
equal
or
exceed
the
acute
restricted
use
or
the
endangered
species
LOCs
for
most
uses
except
cucurbits,
trees,
ornamentals,
rangeland
and
forested
areas.

For
mammals
feeding
on
fruits,
pods,
seeds
and
large
insects,
the
acute
risk
LOC
is
only
exceeded
on
citrus
for
small­
sized
mammals
(
Figure
6;
RQ
=
0.76).
For
large­
sized
mammals
(
Figure
8),
the
acute
risk
LOC
is
not
exceeded
on
any
use.
The
acute
endangered
species
LOC
is
exceeded
in
citrus
(
RQ
=
0.12).

Although
neither
acute
risk
nor
acute
restricted
use
LOC
is
exceeded
for
granivores
for
any
of
the
nongranular
uses,
the
acute
endangered
species
LOC
is
reached
or
exceeded
for
citrus
(
RQ
=
0.17)
and
turfgrass
(
RQ
=
0.11)
and
for
citrus
alone
(
RQ
=
0.12)
for
small
(
Figure
6)
and
intermediate­
sized
(
Figure
7)
granivores,
respectively.
No
acute
LOC
is
exceeded
for
large­
sized
granivores
(
Figure
8).

When
RQ
values
are
based
on
QUA
average
use
rates,
the
acute
risk
LOC
is
exceeded
(
RQ
range:
0.53
­
4.0)
on
89%
of
the
uses
(
APPENDIX
F
Table
9a)
and
the
acute
restricted
use
LOC
is
exceeded
for
99%
(
all
but
Chinese
cabbage)
of
the
uses.
The
acute
endangered
species
LOC
however,
is
exceed
on
all
uses
(
RQ
range:
0.15
­
4.0).
When
RQ
values
are
based
on
maximum
reported
(
Doane)
use
rates
(
APPENDIX
F
Table
9b),
the
acute
risk
LOC
is
exceeded
on
95%
of
the
uses
(
RQ
range:
0.60
­
11).
The
acute
restricted
use
and
endangered
species
LOCs
are
exceeded
on
all
of
the
uses
(
RQ
range:
0.38
­
11).
36
0
2
4
6
8
10
12
14
Crop
C
ategory
Acute
RQ
S
h
ort
Forage
/
Sm
al
l
In
s
e
cts
Larg
e
In
s
e
cts
S
e
e
ds
Acute
Risk
Quotients
at
Maximum
Label
Rates
for
Small­
sized
Mammals
Acute
LOC
Figure
6.
Acute
risk
quotients
(
RQ)
in
selected
crop
categories
for
small­
sized
mammals
feeding
on
short
grasses,
forage/
small
insects,
large
insects
and
seeds
at
maximum
label
application
rates.
The
acute
risk
level
of
concern
(
LOC)
is
exceeded
at
RQ
$
0.5
.
37
0
1
2
3
4
5
6
7
8
9
Crop
C
ategory
Acute
RQ
S
h
ort
Forag
e
/
Sm
al
l
In
s
e
cts
Larg
e
In
s
e
cts
S
e
e
ds
Acute
Risk
Quotients
at
Maximum
Label
Rates
for
Intermediate­
sized
Mammals
Acute
LOC
Figure
7.
Acute
risk
quotients
(
RQ)
in
selected
crop
categories
for
intermediate­
sized
mammals
feeding
on
short
grasses,
forage/
small
insects,
large
insects
and
seeds
at
maximum
label
application
rates.
The
acute
risk
level
of
concern
(
LOC)
is
exceeded
at
RQ
$
0.5
.
38
0
1
2
3
Crop
C
ategory
Acute
RQ
S
h
ort
Fo
ra
g
e
/
Sm
a
l
l
In
s
e
cts
La
rg
e
In
s
e
cts
S
e
e
ds
Acute
Risk
Quotients
at
Maximum
Label
Rates
for
Large­
sized
Mammals
Acute
LOC
Figure
8.
Acute
risk
quotients
(
RQ)
in
selected
crop
categories
for
large­
sized
mammals
feeding
on
short
grasses,
forage/
small
insects,
large
insects
and
seeds
at
maximum
label
application
rates.
The
acute
risk
level
of
concern
(
LOC)
is
exceeded
at
RQ
$
0.5
.
39
0
10
20
30
40
50
Crop
C
ategory
Chronic
RQ
S
h
ort
Forage
/
Sm
al
l
In
s
e
cts
Larg
e
In
s
e
cts
S
e
e
ds
Chronic
Risk
Quotients
at
Maximum
Label
Rates
for
Mammals
Chronic
LOC
Figure
9.
Chronic
risk
quotients
(
RQ)
in
selected
crop
categories
for
mammals
feeding
on
short
grasses,
forage/
small
insects,
large
insects
and
seeds
at
maximum
label
application
rates.
The
chronic
risk
level
of
concern
(
LOC)
is
exceeded
at
RQ
$
1.0
.
Chronic
Risk
As
reported
in
APPENDIX
F
Table
8
and
depicted
in
Figure
9,
the
mammalian
chronic
risk
LOC
(
RQ
$
1)
is
exceeded
on
all
registered
uses
for
mammals
feeding
on
short
grasses
(
RQ
range:
3
­
51),
forage/
small
insects
(
RQ
range:
1.4
­
24)
and
fruit/
seeds/
large
insects
(
RQ
range:
1.7
­
29).
For
granivores,
the
chronic
risk
LOC
is
exceeded
on
five
uses:
citrus,
olives,
stone
fruit,
tree
nuts
and
turf
grass
(
RQ
range:
1.1
­
3.2).
40
Risks
from
Granular
Products
Mammals
may
also
be
exposed
to
granular/
bait
pesticides
through
ingestion
or
by
walking
on
exposed
granules.
APPENDIX
F
provides
a
description
of
how
risk
quotients
are
derived
for
this
exposure.
Based
on
this
analysis,
acute
LOCs
are
exceeded
for
all
40
registered
granular
uses
(
APPENDIX
F
Table
10)
for
small­
and
intermediate­
sized
mammals
(
RQ
range
0.99
­
21).
For
large
mammals,
acute
restricted
use
and
endangered
species
LOCs
are
exceeded
on
applications
to
trees/
ornamentals,
turfgrass,
and
for
tick
control
(
RQ
=
0.32).

Hazard
to
Terrestrial
Plants
Terrestrial
and
semi­
aquatic
plants
may
be
exposed
to
pesticides
from
runoff,
spray
drift
or
volatilization.
Semi­
aquatic
plants
are
those
that
inhabit
low­
laying
wet
areas
that
may
be
dry
at
certain
times
of
the
year.
Ecological
effects
testing
on
a
range
of
terrestrial
and
semi­
aquatic
plants
revealed
that
the
detrimental
effects
for
all
the
test
endpoints
were
less
than
25%
when
compared
with
the
controls
(
APPENDIX
D1).
As
a
result,
the
EC25
was
greater
than
0.083
lb
a.
i./
Acre.
Therefore,
RQ
values
have
not
been
calculated
for
terrestrial
and
semi­
aquatic
plants
and
it
is
assumed
that
at
application
rates
less
than
or
equal
to
0.083
lbs/
Acre,
carbaryl
use
does
not
represent
a
risk
to
plants.
As
noted
earlier
though,
terrestrial
plant
testing
was
limited
in
the
scope
of
plants
tested
and
EFED
recommends
that
a
more
comprehensive
Tier
I
and,
if
necessary,
Tier
II
Seed
Germination
and
Seedling
Emergence
and
Vegetative
Vigor
studies.
Additionally,
since
1­
naphthol
is
a
plant
auxin,
the
effects
of
this
carbaryl
degradate
should
also
be
evaluated.

Hazard
to
Nontarget
Aquatic
Animals
Estimated
environmental
concentrations
for
determining
risk
to
aquatic
organisms
are
derived
using
the
Pesticide
Root
Zone
Model
coupled
with
the
Exposure
Analysis
Model
System
(
PRZM/
EXAMS).
A
more
detailed
description
of
how
aquatic
RQ
values
are
determined
can
be
found
in
APPENDIX
F.

Freshwater
Fish
Figure
10
shows
acute
risk
quotients
for
freshwater
fish
based
on
maximum
label
rates;
the
acute
risk
LOC
(
RQ
$
0.5)
is
exceeded
on
citrus
alone.
Endangered
species
LOC
is
met
or
exceeded
on
all
of
the
crops
modeled.
RQ's
based
on
QUA
average
and
reported
average
rates
(
APPENDIX
F
Table
12)
exceeded
the
acute
risk
LOC
for
citrus
while
the
endangered
species
was
exceeded
on
all
crops
for
both
use
rates
except
on
sugar
beets;
at
average
and
maximum
reported
rates,
sugar
beets
did
not
exceed
any
acute
LOC.
41
0
0.2
0.4
0.6
0.8
1
Sweet
Corn
Fi
e
l
d
C
o
rn
Apples
S
ugar
B
e
e
ts
Citrus
Crop
C
ategory
Acute
RQ
Acute
Risk
Quotients
at
Maximum
Label
Rates
for
Freshwater
Fish
Acute
Risk
LOC
Acute
Restricted
Use
LOC
Acute
Endangered
Species
LOC
Figure
10.
Acute
risk
quotients
(
RQ)
in
selected
crop
categories
for
freshwater
fish
at
maximum
label
application
rates.
Acute
risk
level
of
concern
(
LOC)
is
exceeded
at
RQ
$
0.5;
acute
restricted
use
LOC
is
exceeded
at
RQ
$
0.1
and
acute
endangered
species
LOC
is
exceeded
at
RQ
$
0.05
.
42
0
10
20
30
40
Sweet
C
orn
Fi
e
l
d
C
o
rn
A
ppl
e
s
S
ugar
B
e
e
ts
Citrus
Crop
C
ategory
Acute
RQ
Acute
Risk
Quotients
at
Maximum
Label
Rates
for
Freshwater
Invertebrates
Acute
Risk
LOC
Figure
11.
Acute
risk
quotients
(
RQ)
in
selected
crop
categories
for
freshwater
invertebrates
at
maximum
label
application
rates.
Acute
risk
level
of
concern
(
LOC)
is
exceeded
at
RQ
$
0.5;
acute
restricted
use
LOC
is
exceeded
at
RQ
$
0.1
and
acute
endangered
species
LOC
is
exceeded
at
RQ
$
0.05
.
Freshwater
Invertebrates
Acute
risk
quotients
(
RQ
range:
4.5
­
30)
for
freshwater
invertebrates
at
maximum
label
rates
(
Figure
11),
QUA
average
rates
(
RQ
range:
1.4
­
20)
and
Doane
maximum
reported
rates
(
RQ
range:
1.0
­
26)
all
exceed
acute
risk
levels
of
concern
(
APPENDIX
F
Table
13).

Chronic
risk
quotients
for
freshwater
invertebrates
exceed
the
chronic
LOC
for
maximum
label
rates
(
RQ
range:
8.7
­
55),
QUA
average
rates
(
RQ
range:
2
­
34)
and
Doane
maximum
reported
rates
(
RQ
range:
2
­
45)
(
APPENDIX
F
Table
13).
43
0
10
20
30
40
Sweet
Corn
Fi
e
l
d
C
o
rn
Apple
s
Sugar
Beets
Citrus
Crop
C
ategory
Acute
RQ
Acute
Risk
Quotients
at
Maximum
Label
Rates
for
Estuarine/
Marine
Invertebrates
Acute
Risk
LOC
Figure
12.
Acute
risk
quotients
(
RQ)
in
selected
crop
categories
for
estuarine/
marine
invertebrates
at
maximum
label
application
rates.
Acute
risk
level
of
concern
(
LOC)
is
exceeded
at
RQ
$
0.5;
acute
restricted
use
LOC
is
exceeded
at
RQ
$
0.1
and
acute
endangered
species
LOC
is
exceeded
at
RQ
$
0.05
.
Estuarine/
Maine
Fish
None
of
the
uses
modeled
exceeded
acute
risk
or
restricted
use
LOCs
at
maximum
label
rates,
QUA
average
rates
or
maximum
(
Doane)
reported
rates
(
APPENDIX
F
Table
14).
The
endangered
species
LOC
was
minimally
exceeded
for
maximum
label
and
maximum
reported
rate
rates
on
citrus
(
RQ
=
0.06).

Estuarine/
Marine
Invertebrates
The
acute
risk
LOC
for
estuarine/
marine
invertebrates
is
exceeded
for
all
five
carbaryl
uses
modeled
at
maximum
label
rates
(
Figure
12)
(
RQ
range:
4
­
27),
QUA
average
rates
(
RQ
range:
1.2
­
18)
and
Doane
maximum
reported
rates
(
RQ
range:
0.9
­
23)
(
APPENDIX
F
Table
15).
44
Aquatic
Plants
Based
on
a
single
core
aquatic
plant
toxicity
study
available,
neither
the
acute
risk
nor
the
endangered
species
LOC
(
RQ
$
1)
is
exceeded
for
any
of
the
five
use
scenarios
modeled,
at
maximum
label
(
RQ
range:
0.11
­
0.66),
QUA
average
(
RQ
range:
0.05
­
0.43),
and
maximum
reported
use
rates
(
RQ
range:
0.01
­
0.56)
(
APPENDIX
F
Table
16).
However,
to
fully
assess
carbaryl
risk
to
aquatic
plants,
it
is
recommended
that
toxicity
studies
with
Lemna
gibba,
Anabaena
flos­
aquae,
Skeletonema
costatum,
and
a
freshwater
diatom
be
submitted.
45
ECOLOGICAL
RISK
CHARACTERIZATION
Carbaryl
is
a
carbamate
insecticide
registered
for
control
of
a
wide
range
of
insect
and
other
arthropod
pests
on
over
100
crop
and
noncrop
use
sites,
including
home
and
garden
uses.
The
pesticide
is
a
cholinesterase
inhibitor
that
acts
on
contact
or
ingestion
by
competing
for
binding
sites
on
the
enzyme
acetyl
cholinesterase,
thus
preventing
the
breakdown
of
acetyl
choline.

Carbaryl
is
not
very
persistent
and
dissipates
in
the
soil
environment
by
abiotic
and
microbially­
mediated
degradation
and
is
not
likely
to
persist.
The
major
degradation
products
are
CO2
and
1­
naphthol,
which
is
further
degraded
to
CO2.
Carbaryl
is
stable
to
hydrolysis
in
acidic
conditions,
but
hydrolyzes
rapidly
in
alkaline
environments.
The
compound
is
degraded
by
photolysis
in
water,
with
a
half­
life
of
21
days.
Under
aerobic
conditions
the
compound
degrades
rapidly
by
microbial
metabolism
with
half­
lives
of
4
to
5
days
in
soil
and
aquatic
environments.
In
anaerobic
environments
metabolism
is
much
slower
with
half­
lives
on
the
order
of
two
to
three
months.
Carbaryl
is
mobile
in
the
environment
(
Kf
=
1.7
to
3.5)
and
has
been
detected
in
all
environmental
compartments;
it
dissipates
rapidly
from
foliage
with
a
mean
half­
life
of
3.2
d,
but
is
easily
washed
off
leaf
surfaces,
with
91%
removal
with
1
cm
of
rain.
Sorption
onto
soils
is
positively
correlated
with
soil
organic
content,
increasing
with
higher
soil
organic
content
(
R2
=
0.94.)
Carbaryl
is
not
expected
to
bioaccumulate
(
BCF
=
45X).

In
field
studies,
carbaryl
dissipated
from
terrestrial
field
dissipation
studies
with
DT50
of
4
(
California)
and
7
(
North
Carolina)
days.
No
leaching
was
observed
in
either
study.
but
recharge
may
not
have
been
sufficient
to
cause
downward
movement.
In
a
forestry
dissipation
study,
time
to
fifty
percent
removal
was
21
days
on
foliage,
75
days
on
leaf
litter,
and
65
days
on
soil.
In
two
aquatic
(
rice
paddy)
dissipation
studies
in
Texas
and
Mississippi,
DT50'
s
at
both
sites
were
less
than
two
days.

Fate
data
on
the
primary
degradate,
is
limited;
however,
1­
naphthol
appears
to
be
somewhat
mobile
but
is
not
likely
to
persist
due
to
fairly
rapid
degradation.
Since
1­
naphthol
can
occur
from
a
variety
of
natural
and
anthropogenic
processes,
its
presence
cannot
be
considered
indicative
of
carbaryl
use.

Carbaryl
is
widely
detected
in
non­
targeted
and
targeted
monitoring
studies.
Observed
concentrations
are
generally
low
with
fifty
percent
of
the
samples
below
minimum
detection
limits
and
ninety
five
percent
of
the
samples
less
than
0.065
:
g/
L.
Carbaryl
is
not
very
persistent
in
most
surface
water
conditions
suggesting
that
the
wide
spread
occurrence
is
a
result
of
its
extensive
use
in
a
variety
of
applications.

As
noted
above,
carbaryl
is
expected
to
be
mobile,
but
degrade
rapidly
in
the
environment
in
most
cases.
However,
there
are
circumstances,
i.
e.,
under
acidic
conditions
with
low
biological
activity
and/
or
in
reducing
(
anaerobic)
conditions,
where
carbaryl
is
likely
to
persist.
Available
field
data
are
in
general
agreement
with
the
laboratory
data,
with
the
forestry
dissipation
study
indicates
somewhat
longer
persistence
than
the
other
studies,
but
not
so
far
as
to
be
an
outlier.
The
fate
and
transport
data
has
a
relatively
complete
coverage
of
the
expected
routes
of
fate
and
transport,
but
is
limited
in
the
amount
of
data
for
any
particular
study.
In
particular,
there
is
only
one
available
46
guideline
metabolism
study
for
each
route
of
metabolism.
Given
the
high
variability
typically
associated
with
these
studies,
there
is
some
uncertainty
in
these
rates.
Since
this
uncertainty
is
factored
into
the
aquatic
and
drinking
water
exposure
estimates,
an
increase
in
the
number
of
metabolism
studies
could
potentially
decrease
current
exposure
estimates.

Additionally,
there
are
a
number
of
factors
inherent
in
the
modeling
that
can
affect
the
accuracy
and
precision
of
this
analysis
including
the
selection
of
the
high
exposure
scenarios,
the
quality
of
the
input
data,
the
ability
of
the
models
to
represent
the
real
world,
and
the
number
of
years
that
were
modeled.
The
EEC's
in
this
analysis
are
accurate
only
to
the
extent
that
the
site
represents
this
hypothetical
high
exposure
site.

Although
carbaryl
is
not
expected
to
be
persistent,
on
low
organic
carbon
content
soils
and
following
high
rain
events
the
pesticide
is
likely
to
be
mobile.
Laboratory
studies
of
terrestrial
and
aquatic
animals
indicates
that
carbaryl
is
practically
nontoxic
to
birds,
moderately
toxic
to
mammals
and
fish,
and
very
highly
toxic
to
bees
and
aquatic
invertebrates
on
an
acute
exposure
basis.
Additionally,
data
indicate
that
the
carbaryl
hydrolysis
degradate
1­
naphthol
ranges
in
toxicity
from
moderately
to
highly
toxic
to
aquatic
organisms.

Risk
to
Terrestrial
Animals
Given
that
carbaryl
is
practically
nontoxic
to
birds
on
both
an
acute
oral
exposure
and
a
subacute
dietary
exposure
basis,
the
threat
of
adverse
effects
to
birds
resulting
from
acute
exposure
to
carbaryl
is
considered
low.
On
an
chronic
exposure
basis
however,
the
chronic
risk
level
of
concern
(
RQ
=
1)
is
exceeded
on
over
50%
of
the
crops
modeled
for
birds
feeding
on
short
grasses
(
100%),
tall
grasses
(
55%)
and
broadleaf
plants/
small
insects
(
66%)
for
nongranular
product
at
maximum
label
rates.
In
general,
crops
receiving
multiple
applications
of
nongranular
products
greater
than
3
lbs
a.
i./
acre
with
short
(#
7
day)
reapplication
intervals
were
likely
to
represent
a
risk
of
chronic
effects
in
birds.
At
"
average"
application
rates
modeled
for
short
grasses
the
number
of
exceedances
was
reduced
from
100%
to
49%
of
the
crops.

Although
bird
incidents
(
5)
have
been
reported
for
carbaryl,
only
two
could
be
clearly
attributed
to
the
chemical
and
only
one
could
be
linked
to
a
specific
registered
use.
The
one
incident
reported
a
single
morning
dove
(
Zenaida
macroura)
dying
following
application
to
a
homeowner's
lawn
in
the
vicinity
of
a
bird
feeder.

Even
though
carbaryl
has
been
classified
as
practically
nontoxic
to
birds
on
an
acute
exposure
basis,
there
is
uncertainty
regarding
the
sensitivity
of
smaller,
passerine
birds.
Open
literature
on
smaller
birds
and
incidents
involving
blackbirds
and
starlings
suggest
that
perching
birds
may
be
more
sensitive.

Consistent
with
carbaryl's
moderate
acute
toxicity
to
mammals,
the
acute
risk
level
of
concern
(
RQ
$
0.5),
acute
restricted
use
(
RQ
$
0.2)
and
acute
endangered
species
(
RQ
$
0.1)
are
exceeded
for
majority
(>
75%)
of
the
uses
modeled
for
small
(
15
g)
and
intermediate­
sized
(
35
g)
animals
feeding
on
short
grasses
and
broadleaf/
forage
plants.
For
large­
sized
mammals
(
1000
g),
acute
risk
LOCs
are
exceeded
on
40%
of
the
uses
modeled
for
animals
feeding
on
short
grasses
and
47
for
over
50%
of
the
uses
modeled
for
large
animals
feeding
on
broadleaf/
forage
plants.
For
mammals
feeding
on
fruits/
pods/
seeds/
large
insects,
the
acute
risk
LOC
is
exceeded
for
small­
sized
animals
and
the
acute
endangered
species
LOC
is
exceeded
for
large­
sized
mammals
following
application
to
citrus.
For
granivores,
acute
endangered
species
LOCs
are
minimally
exceeded
for
small
(
RQ
=
0.17)
and
intermediate­
sized
mammals
(
RQ
=
0.12)
following
application
to
citrus
and
for
small­
sized
mammals
alone
(
RQ
=
0.11)
following
application
to
turfgrass.
The
mammalian
chronic
risk
LOC
is
exceeded
for
all
registered
uses
for
animals
feeding
on
short
grasses,
forage/
small
insects,
and
fruits/
large
insects
(
RQ
range:
1.1
­
31).
For
mammals
feeding
on
seed
fruit,
the
chronic
LOC
is
exceeded
on
citrus,
olives,
stone
fruit,
tree
nuts
and
turf
(
RQ
range:
1.1
­
3.2).
Even
when
looking
at
average
application
rates,
acute
risk
LOCs
are
exceeded
on
89%
of
the
uses
while
the
chronic
risk
LOC
is
exceeded
on
all
uses
except
Chinese
cabbage.

Mammals
may
also
be
exposed
to
granular/
bait
formulations
of
carbaryl
through
ingestion
and/
or
walking
on
exposed
granules.
The
acute
risk
LOC
for
small
and
intermediate­
sized
mammals
is
exceeded
(
RQ
range:
0.99
­
21)
for
all
40
registered
granular
uses.
For
large­
sized
mammals,
acute
restricted
use
and
endangered
species
LOCs
are
exceeded
following
application
for
trees
and
ornamentals,
turfgrass,
and
tick
control.

Although
2
incidents
have
attributed
to
carbaryl,
one
involving
a
gray
squirrel
(
Sciurus
carolinensin)
and
the
second
involving
a
hairytail
mole
(
Parascalops
breweri),
neither
could
be
associated
with
a
specific
use
of
carbaryl.
However,
based
on
the
risk
quotients
for
small
and
intermediate
sized
animals,
estimated
acute
environmental
concentrations
are
sufficiently
high
to
result
in
mortality.

Carbaryl
is
highly
toxic
to
beneficial
insects
on
an
acute
exposure
basis.
Bee­
kill
incidents
have
been
reported;
however,
all
but
one
involving
the
use
of
carbaryl
on
asparagus
in
Washington,
contained
sufficient
information
to
implicate
a
specific
use
of
carbaryl.
Although
the
bee
industry
has
expressed
its
concerns
regarding
the
toxicity
of
carbaryl
to
bees,
it
has
not
provided
sufficient
data
to
support
its
concerns.

The
risk
to
bees
from
the
use
of
carbaryl
to
thin
orchard
fruit
has
recently
been
evaluated.
Under
the
conditions
tested
in
the
German
apple
orchards,
carbaryl
SC
applications
to
thin
fruit
did
not
have
a
significant
(
P
>
0.05)
effect
on
bee
mortality
and/
or
behavior.

Risks
to
Aquatic
Animals
In
general,
carbaryl
is
moderately
toxic
to
freshwater
fish
and
the
acute
risk
LOC
is
exceeded
for
citrus
alone
(
RQ
=
0.61);
acute
endangered
species
LOCs
are
exceeded
(
RQ
range:
0.06
­
0.61)
on
all
crops
modeled
except
sugar
beets.
None
of
the
uses
modeled
exceeded
the
chronic
risk
LOC.
Although
three
fish
kill
incidents
hare
been
reported
for
carbaryl,
there
appears
to
be
only
one
credible
report
where
carbaryl
used
to
control
gypsy
moth
(
Lymantria
dispar)
could
be
directly
associated
with
a
fish
kill.

Carbaryl
ranged
from
being
slightly
to
moderately
toxic
to
amphibians
on
an
acute
exposure
basis.
Intra
and
inter­
species
variability
contributed
to
the
range
of
responses
to
carbaryl.
While
48
much
of
the
current
research
focuses
on
direct
acute
effects
of
carbaryl
on
tadpoles/
frogs,
the
indirect
effects
of
carbaryl
on
impairing
predator
avoidance
is
frequently
raised
as
a
concern.
Additionally,
carbaryl
exposure
has
been
associated
with
skeletal
deformities
in
frogs.

Consistent
with
carbaryl's
classification
as
being
very
highly
toxic
to
freshwater
invertebrates,
acute
risk
LOCs
are
exceeded
(
RQ
range
1
­
30)
for
all
uses
modeled
at
maximum
label
rates,
average
rates
and
maximum
reported
rates.
Similarly,
the
chronic
risk
LOC
is
exceeded
(
RQ
range:
2
­
55)
for
all
uses
at
all
rates.
Interestingly,
carbaryl's
toxicity
to
aquatic
macroinvertebrates
has
been
associated
with
phytoplankton
blooms
where
it
is
hypothesized
that
selective
mortality
on
zooplankton
reduced
grazing
on
phytoplankton
to
a
sufficient
extent
to
favor/
promote
phytoplankton
abundance.
Increased
growth
rates
in
tadpoles
exposed
to
carbaryl
has
been
theorized
as
a
response
of
the
amphibians
to
increased
phytoplankton
food
supplies.

Similar
to
freshwater
fish,
carbaryl
is
moderately
toxic
to
estuarine/
marine
fish;
however,
none
of
the
estimated
environmental
concentrations
exceeded
acute
risk
LOCs.
The
acute
endangered
species
LOC
was
minimally
exceeded
(
RQ
=
0.06)
for
citrus.

Carbaryl
is
very
highly
toxic
to
estuarine/
marine
invertebrates
and
the
acute
risk
LOC
is
exceeded
on
all
uses
modeled
at
maximum
label,
average
and
maximum
reported
application
rates
(
RQ
range:
0.9
­
27).

Risks
to
Plants
For
both
aquatic
and
terrestrial
plants,
the
likelihood
of
adverse
effects
from
maximum
label
use
rates
appears
to
be
low;
however,
there
were
limited
data
on
which
to
evaluate
the
effects
of
carbaryl
on
a
range
of
plants.
Studies
over
a
broader
range
of
terrestrial
and
aquatic
plants
should
be
submitted
to
address
this
uncertainty.
Although,
toxicity
data
suggest
that
carbaryl
is
relatively
innocuous
to
plants,
the
greatest
number
of
incidents
(
11)
for
carbaryl
have
involved
terrestrial
plants
(
APPENDIX
D1).
While
the
majority
of
these
reports
have
been
associated
with
homeowner
use
of
the
product,
some
agricultural
crops,
e.
g.,
quince
and
olive,
have
reported
losses
resulting
from
spotting,
low
fruit
set
and
malformations
in
fruit
shape.
Reconciling
the
phytotoxicity
reported
in
field
incidents
with
the
laboratory
data
represents
an
uncertainty.

Additional
Concerns
Grasshopper
and
Mormon
Cricket
Control
on
Rangeland
With
respect
to
U.
S.
Department
of
Agriculture's
Animal
and
Plant
Health
Inspection
Service
(
USDA
APHIS)
Grasshopper
and
Mormon
Cricket
Suppression
Program
use
of
carbaryl
to
control
grasshoppers
and
Mormon
crickets,
acute
and
chronic
risk
LOCs
are
exceeded
for
smaller­
sized
mammals
when
0.5
lbs/
Acre
is
applied;
however,
at
0.25
lbs/
A
the
acute
endangered
species
LOC
alone
is
exceeded
for
smaller
animals
(
APPENDIX
G).
Additionally,
assuming
5%
spray
drift,
acute
restricted
use
and
endangered
species
LOCs
are
exceeded
for
freshwater
invertebrates.
If
95%
spraydrift
(
direct
overflight
of
aquatic
habitat),
then
acute
endangered
species
LOC
is
exceeded
for
fish
and
acute
and
chronic
risk
LOCs
are
exceeded
for
aquatic
invertebrates.
49
Based
on
the
potential
for
both
acute
and
chronic
effects
to
terrestrial
(
primarily
mammals)
and
aquatic
animals
(
primarily
invertebrates),
plans
are
underway
for
USDA
APHIS
to
consult
with
the
U.
S.
Fish
and
Wildlife
Service
and
the
National
Marine
Fisheries
Service
to
assure
that
endangered
species
are
protected
to
the
extent
possible.
Section
7
consultations
on
the
use
of
carbaryl
on
rangelands
to
control
grasshoppers/
crickets
are
ongoing.

Section
24c
Use
of
Carbaryl
to
Control
Burrowing
Shrimp
For
several
decades,
carbaryl
has
been
used
to
control
burrowing
shrimp
on
tidal
mudflats
in
Willapa
Bay
and
Grays
Harbor,
Washington
(
APPENDICES
E1
to
E3)
.
Although
concern
has
been
raised
regarding
this
use
and
its
potential
impact
to
nontarget
animals
outside
of
treated
areas,
very
little
data
have
been
provided
to
substantiate
these
concerns.
The
available
data
indicate
that
acute
mortality
will
likely
be
near
100%
for
animals
trapped
on
mudflats
in
the
immediate
application
area
and
that
carbaryl
will
likely
drift
off­
site
with
the
tide.
However,
a
combination
of
the
rapid
degradation
of
carbaryl
due
to
both
biotic
and
abiotic
factors
and
dilution
by
a
relatively
large
influx
of
water
together
render
potential
acute
and
chronic
effects
remote.
Additionally,
as
part
of
a
memorandum
of
agreement
between
the
Washington
Stage
government
representatives
and
various
stakeholders,
the
oystergrowers
have
agreed
to
developed
an
integrated
pest
management
program
to
look
at
alternatives
to
carbaryl
and
to
conduct
studies
to
determine
the
extent
to
which
carbaryl
impacts
areas
adjacent
to
treated
sites.
Through
this
cooperative
approach
it
may
be
possible
to
better
document
by
monitoring
of
surface
waters
and
sediments
the
extent
to
which
carbaryl
drifts.
Studies
are
also
planned
to
determine
to
what
extent
salmonids
may
be
impacted.
However,
at
this
time,
given
the
limited
number
of
acres
treated
and
the
combination
of
chemical
degradation
and
potential
dilution
by
successive
tides,
there
is
insufficient
data
to
warrant
concern
that
nontarget
animals
are
at
risk
throughout
the
Willapa
Bay/
Grays
Harbor
area.

Endocrine
Disruption
Concerns
There
are
data
indicating
that
carbaryl
exposure
may
impact
endocrine­
mediated
processes
in
both
aquatic
and
terrestrial
animals.
Serum
and
pituitary
levels
of
gonadotropic
hormone
and
gonadotropin­
releasing
hormone
(
GnRH)
in
the
freshwater
snakehead
fish
(
Channa
punctatus)
are
reduced
by
exposure
to
1.66
­
3.73
ppm
of
carbaryl
in
laboratory
and
paddy
field
tests
(
Ghosh
et
al.,
1990).
The
decrease
in
GnRH
levels
could
be
explained
by
exposure
to
high
estrogen
levels,
acting
through
a
negative
feedback
pathway
to
inhibit
GnRH
release,
and
thus
the
release
of
gonadotropins
(
Klotz
et
al.,
1997).
Plasma
and
ovarian
estrogen
levels
in
freshwater
perch
(
Anabas
testudineus)
exposed
to
1.66
ppm
of
carbaryl
for
90
days
increase
until
day
15
and
then
decline,
relative
to
control
fish,
indicating
that
long­
term
exposure
to
this
chemical
may
cause
an
inhibitory
effect
on
fish
reproduction
(
Choudhury
et
al.,
1993).

In
addition,
chronic
exposure
of
fathead
minnows
(
Pimephales
promelas)
to
carbaryl
resulted
in
reduced
survival
and
reproductive
effects
(
LOEC
=
0.680
ppm)
including
reduced
number
of
eggs
per
female
and
reduced
number
of
eggs
spawned.
Chronic
studies
with
aquatic
macroinvertebrates
resulted
in
reduced
emergence
and
developmental
rates
in
midges,
Chironomous
riparius,
and
reproductive
effects
in
Daphnia
magna.
In
avian
reproduction
studies
of
the
mallard
duck
(
Anas
50
platyrhynchos)
carbaryl
exposure
resulted
in
reduced
number
of
eggs
produced
and
increased
number
of
eggs
cracked.

These
chronic
toxicity
measurement
endpoints
are
considered
consistent
with
a
chemical
that
acts
on
endocrine­
medicated
pathways.
When
considered
in
concert
with
open
literature,
there
is
uncertainty
regarding
the
endocrine
disrupting
potential
of
carbaryl
and
its
1­
naphthol
degradate.

EPA
is
required
under
the
Federal
Food,
Drugs,
and
Cosmetics
Act
(
FFDCA),
as
amended
by
Food
Quality
Protection
Act
(
FQPA),
to
develop
a
screening
program
to
determine
whether
certain
substances
(
including
all
pesticide
active
and
other
ingredients)
"
may
have
an
effect
in
humans
that
is
similar
to
an
effect
produced
by
a
naturally­
occurring
estrogen,
or
other
such
endocrine
effects
as
the
Administrator
may
designate."
Following
the
recommendations
of
its
Endocrine
Disruptor
Screening
and
Testing
Advisory
Committee
(
EDSTAC),
EPA
determined
that
there
was
scientific
basis
for
including,
as
part
of
the
program,
the
androgen­
and
thyroid
hormone
systems,
in
addition
to
the
estrogen
hormone
system.
EPA
also
adopted
EDSTAC's
recommendation
that
the
Program
include
evaluations
of
potential
effects
in
wildlife.
For
pesticide
chemicals,
EPA
will
use
FIFRA
and,
to
the
extent
that
effects
in
wildlife
may
help
determine
whether
a
substance
may
have
an
effect
in
humans,
FFDCA
authority
to
require
the
wildlife
evaluations.
As
the
science
develops
and
resources
allow,
screening
of
additional
hormone
systems
may
be
added
to
the
Endocrine
Disruptor
Screening
Program
(
EDSP).

When
the
appropriate
screening
and
or
testing
protocols
being
considered
under
the
Agency's
Endocrine
Disruptor
Screening
Program
have
been
developed,
it
is
recommended
that
carbaryl
be
subjected
to
additional
screening
and
or
testing
to
better
characterize
effects
related
to
endocrine
disruption.

Endangered
Species
Avian
Chronic
LOCs
are
exceeded
for
birds
feeding
on
short
grasses
for
all
uses
modeled
except
rangeland.
For
birds
feeding
on
tall
grasses,
the
avian
chronic
LOC
is
exceeded
for
55%
of
the
modeled
uses
and
for
birds
feeding
on
broadleaf/
forage
plants
and
small
insects,
the
chronic
LOC
is
exceeded
for
60%
of
the
uses
modeled.
When
RQs
were
based
on
average
use
rates,
49%
of
the
uses
exceeded
chronic
LOCs.
When
RQs
were
based
on
maximum
reported
use
rates,
81%
of
the
uses
exceeded
the
chronic
LOC.

Mammals
For
mammals,
all
uses
modeled
exceeded
the
acute
endangered
species
LOC
for
herbivores.
For
mammals
foraging
on
broadleaf
plants
and
small
insects,
the
endangered
species
LOC
is
exceeded
for
all
uses
except
cucurbits,
trees,
ornamentals,
rangeland
and
forested
areas.
For
mammals
feeding
on
large
insects,
roughly
70%
and
45%
of
the
use
categories
modeled
exceeded
the
acute
endangered
species
LOC
small
(
15
g)
and
intermediate­
sized
(
35
g)
mammals,
51
respectively.
Only
one
use,
i.
e.,
citrus,
exceeded
the
LOC
for
large­
sized
animals
(
1,000
g).
For
granivores,
the
acute
endangered
species
LOC
is
exceeded
for
small­
sized
animals
feeding
in
citrus
and
turfgrass
areas
and
for
intermediate­
sized
mammals
feeding
in
citrus
areas.
Chronic
LOCs
are
exceeded
for
all
modeled
uses
for
mammals
feeding
on
all
food
items
except
seeds/
fruits
and
large
insects.
For
granivores,
the
chronic
LOC
is
exceeded
for
citrus,
olives,
stone
fruits,
tree
nuts
and
turf
grass.
When
RQ
were
based
on
average
rates
or
maximum
reported
rates,
acute
and
chronic
endangered
species
LOCs
are
exceeded
for
all
of
the
modeled
uses.
Additionally,
granular
products
represented
an
acute
risk
to
both
small
and
intermediate­
sized
mammals
all
on
of
the
uses
modeled.
Granules
were
only
a
risk
to
large­
sized
mammals
for
trees,
ornamental,
turfgrass
and
tick
control
uses.

Aquatic
Animals
For
freshwater
fish
the
endangered
species
LOC
is
exceeded
for
all
of
the
crops
modeled
for
all
three
use
rates
except
for
sugar
beets.
The
LOC
for
endangered
species
was
not
exceeded
on
for
sugar
beets
at
the
maximum
reported
use
rate.
For
freshwater
invertebrates,
the
both
acute
and
chronic
endangered
species
LOCs
are
exceeded
for
all
of
the
uses
modeled.
For
estuarine/
marine
fish,
only
use
on
citrus
exceeded
the
acute
LOC
for
all
three
use
rates.
For
estuarine/
marine
invertebrates,
the
acute
endangered
species
LOC
is
exceeded
for
all
of
the
use
and
rates
modeled;
however,
there
currently
are
no
federally
listed
estuarine
invertebrates.
At
the
current
application
rates,
carbaryl
use
is
likely
to
result
in
both
acute
and
chronic
risks
to
endangered/
threatened
species
of
animals.

In
1989
the
U.
S.
Fish
and
Wildlife
Service
(
USFWS)
issued
a
biological
opinion
(
USFWS
1989)
on
carbaryl
in
response
to
the
U.
S.
Environmental
Protection
Agency's
request
for
consultation.
In
issuing
its
opinion
the
USFWS
considered
the
following
factors:
(
1)
potential
for
exposure
of
the
listed
species
to
the
pesticide;
(
2)
information
on
the
chemical
toxicity
relative
to
estimated
environmental
concentrations;
(
3)
potential
for
secondary
impacts;
and
(
4)
special
concerns
not
specifically
addressed
in
the
preceding
factors
or
unique
to
the
situation
being
evaluated.
Given
the
evaluation
criteria,
a
total
127
species
(
6
amphibians,
77
fish,
32
mussels,
9
crustaceans,
1
insect,
and
2
bird
species)
were
considered
potentially
affected
by
the
use
of
carbaryl.
Of
those
organisms
potentially
affected,
the
USFWS
listed
85
aquatic
species
as
jeopardized,
of
which
the
majority
(
51%)
were
endangered/
threatened
species
of
freshwater
fish.
One
terrestrial
(
avian)
species
was
also
classified
as
being
in
jeopardy.
The
remaining
potentially
affected
organisms
were
listed
either
as
having
no
potential
for
exposure
or
as
not
being
in
jeopardy.
For
all
of
the
species
listed
as
jeopardized
the
USFWS
lists
reasonable
and
prudent
alternatives
(
RPA)
to
mitigate
the
effects
of
carbaryl
use.
For
some
of
the
species
listed
as
not
jeopardized,
the
USFWS
lists
reasonable
and
prudent
measures
(
RPM)
and
incidental
take
(
IT)
to
mitigate
effects.
For
details
on
the
RPA
and
RPM
recommendations,
the
reader
is
referred
to
USFWS
1989
publication.
Many
additional
species,
especially
aquatic
species,
have
been
federally
listed
as
endangered/
threatened
since
the
biological
opinion
of
1989
was
written,
and
determination
of
jeopardy
to
these
species
has
not
been
assessed
for
carbaryl.

EPA's
current
assessment
of
ecological
risks
uses
both
more
refined
methods
to
define
ecological
risks
of
pesticides
and
new
data,
such
as
that
for
spray
drift.
Therefore,
the
Reasonable
52
and
Prudent
Alternatives
and
Reasonable
and
Prudent
Measures
in
the
Biological
Opinion
may
need
to
be
reassessed
and
modified
based
on
these
new
approaches.

The
Agency
is
currently
engaged
in
developing
a
consultation
package
for
transmittal
to
National
Marine
Fisheries
Service
(
NMFS)
on
April
1,
2003,
to
address
listed
Pacific
salmon
and
steelhead.
EPA
is
committed
to
look
at
other
species
beyond
those
discussed
in
this
consultation
package;
additional
consultations
with
both
USFWS
and
NMFS
are
expected
to
cover
other
terrestrial
and
aquatic
species.

The
Agency
is
also
engaged
in
a
Proactive
Conservation
Review
with
USFWS
and
the
National
Marine
Fisheries
Service
under
section
7(
a)(
1)
of
the
Endangered
Species
Act.
The
objective
of
this
review
is
to
clarify
and
develop
consistent
processes
for
endangered
species
risk
assessments
and
consultations.
Subsequent
to
the
completion
of
this
process,
the
Agency
will
reassess
the
potential
effects
of
carbaryl
use
to
federally
listed
threatened
and
endangered
species.
At
that
time
the
Agency
will
also
consider
any
regulatory
changes
recommended
in
the
IRED
that
are
being
implemented.
Until
such
time
as
this
analysis
is
completed,
the
overall
environmental
effects
mitigation
strategy
articulated
in
this
document
and
any
County
Specific
Pamphlets
described
in
Section
IV
which
address
carbaryl,
will
serve
as
interim
protection
measures
to
reduce
the
likelihood
that
endangered
and
threatened
species
may
be
exposed
to
carbaryl
at
levels
of
concern.

The
Agency
has
developed
the
Endangered
Species
Protection
Program
to
identify
pesticides
whose
use
may
cause
adverse
impacts
on
endangered
and
threatened
species,
and
to
implement
mitigation
measures
that
address
these
impacts.
The
Endangered
Species
Act
requires
federal
agencies
to
ensure
that
their
actions
are
not
likely
to
jeopardize
listed
species
or
adversely
modify
designated
critical
habitat.
To
analyze
the
potential
of
registered
pesticide
uses
to
affect
any
particular
species,
EPA
puts
basic
toxicity
and
exposure
data
developed
for
REDs
into
context
for
individual
listed
species
and
their
locations
by
evaluating
important
ecological
parameters,
pesticide
use
information,
the
geographic
relationship
between
specific
pesticide
uses
and
species
locations,
and
biological
requirements
and
behavioral
aspects
of
the
particular
species.
This
analysis
will
take
into
consideration
any
regulatory
changes
recommended
in
this
RED
that
are
being
implemented
at
this
time.
A
determination
that
there
is
a
likelihood
of
potential
impact
to
a
listed
species
may
result
in
limitations
on
use
of
the
pesticide,
other
measures
to
mitigate
any
potential
impact,
or
consultations
with
the
Fish
and
Wildlife
Service
and/
or
the
National
Marine
Fisheries
Service
as
necessary.

The
Endangered
Species
Protection
Program
as
described
in
a
Federal
Register
notice
(
54
FR
27984­
28008,
July
3,
1989)
is
currently
being
implemented
on
an
interim
basis.
As
part
of
the
interim
program,
the
Agency
has
developed
County
Specific
Pamphlets
that
articulate
many
of
the
specific
measures
outlined
in
the
Biological
Opinions
issued
to
date.
The
Pamphlets
are
available
for
voluntary
use
by
pesticide
applicators
on
EPA's
website
at
www.
epa.
gov/
espp.
A
final
Endangered
Species
Protection
Program,
which
may
be
altered
from
the
interim
program,
was
proposed
for
public
comment
in
the
Federal
Register
in
December
2,
2002.
53
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58
APPENDIX
A1.
DRINKING
WATER
MEMO
UNITED
STATES
ENVIRONMENTAL
PROTECTION
AGENCY
WASHINGTON,
D.
C.
20460
OFFICE
OF
PREVENTION,
PESTICIDES
AND
TOXIC
SUBSTANCES
MEMORANDUM
March
12,
2003
SUBJECT:
Final
Report
of
Carbaryl
EEC's
for
Drinking
Water
DB
Barcode:
D288455
PC
Code:
056801
TO:
Anthony
Britten,
Chemical
Review
Manager,
Reregistration
Branch
3
Special
Review
and
Reregistration
Division
FROM:
R.
David
Jones,
Ph.
D.,
Senior
Agronomist
Environmental
Risk
Branch
4
THROUGH:
Elizabeth
Behl,
Chief
Environmental
Risk
Branch
4
Environmental
Fate
and
Effects
Division
This
is
the
final
report
for
revised
estimated
environmental
concentrations
(
EEC's)
in
surface
water
for
the
use
of
carbaryl
on
selected
crops.
These
EEC's
are
intended
to
replace
those
in
the
Environmental
Fate
and
Ecological
Risk
Assessment
for
the
Reregistration
of
Carbaryl
(
Libelo
et
al.,
2002).
Since
the
issuance
of
that
document,
new
information
has
been
received
by
the
Agency
in
response
to
a
request
for
public
comments
on
the
draft
assessment
(
particularly
on
foliar
degradation
rates)
that
warranted
a
re­
evaluation
of
the
aquatic
exposure.
We
have
also
taken
the
opportunity
to
make
some
other
changes
that
improve
the
general
quality
and
reliability
of
the
estimates.

The
EEC's
in
Table
1
represent
the
90
percentile
exposure
value
for
carbaryl
use
on
representative
crops.
These
EEC's
are
based
on
the
maximum
use
patterns
allowed
on
each
label
as
described
below.
Because
we
estimate
that
the
highest
carbaryl
concentrations
will
59
result
from
the
use
of
carbaryl
on
citrus,
those
values
are
used
as
a
screen
in
estimating
potential
drinking
water
exposure
nationally.
It
should
be
noted
that
concentrations
estimated
to
result
from
carbaryl
use
on
other
crops
are
substantially
lower
than
for
the
citrus
use(
see
table
1).
In
addition
to
the
point
estimates,
we
have
also
provided
the
time
series
of
carbaryl
concentrations
for
the
entire
duration
of
the
simulation
for
the
different
citrus
scenarios.
These
estimates
are
intended
for
use
in
a
more
refined
estimate
of
dietary
exposure
for
carbaryl
and
are
being
combined
with
carbaryl
residues
in
food
using
the
DEEM
model.

The
following
changes
were
made
in
the
selection
of
input
parameters
used
in
this
assessment
relative
to
those
used
in
the
original
set
of
estimates:

C
The
foliar
half­
life
was
changed
from
35
to
3.71
days,
to
reflect
relevant
data
submitted
by
the
registrant.
C
The
foliar
washoff
coefficient
was
also
changed
from
a
default
value
of
0.5
to
0.91
based
on
estimates
made
from
two
literature
studies
submitted
by
the
registrant.
C
The
site
for
used
to
represent
a
vulnerable
site
for
apples
was
changed
from
Oregon
to
Pennsylvania,
which
better
reflects
a
vulnerable
use
site
for
apples
across
the
whole
country
and
is
more
consistent
with
EFED's
policy
on
Tier
2
site
selection.
C
In
the
original
assessment,
measured
soil­
water
partition
coefficient's
(
Kd's)
were
used
based
on
the
texture
of
a
measured
soil.
This
was
changed
to
using
a
single
Koc
of
196
L
kg­
1
based
on
the
texture
in
the
soil
represented
in
the
model
scenario,
which
better
reflects
current
policy.
C
The
value
used
to
represent
microbial
degradation
in
the
pond
sediment
was
changed
from
72.2
to
216
days
in
keeping
with
current
policy
of
parameter
selection
which
indicates
single
metabolism
values
should
be
multiplied
by
three.

Table
1.
EEC's
for
the
`
maximum'
use
patterns
for
carbaryl
on
selected
agricultural
crops
Crop
Acute
EEC
Chronic
EEC
­­­­­­­­­­­­­­­­­­­­­
:
g
L­
1
carbaryl
equivalents
­­­­­­­­­­­­­­­­­­­­

Apples
62.9
2.20
Citrus
316
14.2
Field
Corn
51.3
2.72
Sweet
Corn
57.3
5.53
Sugar
Beets
48.2
2.16
C
The
value
originally
used
for
aerobic
aquatic
metabolism,
12
days,
unintentionally
resulted
in
double
counting
of
hydrolysis.
A
revised
value
of
29.6
days
avoids
doubling
the
hydrolysis
rate.
C
The
application
date
on
some
sites
was
changed
to
better
reflect
the
actual
use
practice.
60
A
more
complete
description
of
rationale
and
effects
of
these
changes
is
provided
below.
The
revised
EEC's
for
the
maximum
use
pattern
are
in
Table
1.
A
complete
list
of
EEC's
for
all
use
patterns
is
in
Table
6.

Models
These
estimates
were
calculated
using
PRZM
version
3.12
dated
May
24,
2001
and
EXAMS
version
2.98.04
dated
July
18,
2002.
These
models
were
run
in
the
EFED
PRZM
EXAMS
shell,
PE3
version
1.2,
dated
October
15,
2002.
The
shell
also
processed
the
output
from
EXAMS
to
estimate
the
1
in
10
year
return
values
reported
here.
In
addition,
time
series
of
daily
values
for
thirty
years
were
output
and
have
been
provided
for
use
in
more
refined
dietary
exposure
assessment.
A
list
of
the
input
files
used
to
generate
these
EEC's
is
in
the
APPENDIX
A2.

It
is
worth
noting
that
the
Office
of
Pesticide
Programs
is
aware
of
an
error
in
the
current
modeling
system
that
results
in
the
"
peak"
EEC's
reported
actually
representing
not
instantaneous
peak
concentrations,
but
24­
hour
mean
concentrations
on
the
day
the
peak
occurs.
The
OPP
is
currently
taking
corrective
action,
but
revisions
had
not
completed
QA
review
prior
to
initiation
of
this
analysis.
For
the
case
of
carbaryl,
this
likely
results
in
an
approximately
five
percent
underestimation
of
the
peak.
However,
this
error
is
certainly
covered
by
other
substantial
conservatisms
which
are
inherent
in
these
estimates.

Scenarios
EEC's
were
calculated
for
5
crops
which
include
those
which
are
the
major
use
sites
for
carbaryl.
These
sites
are:
apples,
citrus,
field
corn,
sweet
corn,
and
sugar
beets.
The
scenario
for
apples
is
in
Lancaster
County,
Pennsylvania
and
represents
a
Elioak
silt
loam
soil,
Hydrologic
Group
C
soil.
The
scenario
for
citrus
is
in
Collier
and
Hendry
Counties
Florida
and
represents
a
Wabasso
sand
soil.
The
scenario
for
field
corn
and
sweet
corn
is
in
Darke
and
Rickaway
Counties,
Ohio
and
represents
a
Cardington
silt
loam
soil
which
is
Hydrologic
Group
C.
The
scenario
for
sugar
beets
is
in
Polk
County,
Minnesota.
The
soil
there
is
an
Adair
clay
loam
in
Hydrologic
Group
C.

The
apple
scenario
used
in
previous
modeling
was
set
in
Oregon
rather
than
Pennsylvania.
The
site
was
switched
to
Pennsylvania
as
this
site
is
thought
to
better
represent
a
vulnerable
site
among
all
apple
orchards
across
the
United
States.
The
Oregon
site
may
not
be
protective
of
drinking
water
facilities
downstream
from
apple
orchards
in
the
eastern
United
States
as
that
geographic
region
receives
lower
rainfall
and
runoff
during
the
growing
season
than
the
site
in
the
East.
61
Use
Patterns
The
use
patterns
for
each
crop
were
adapted
from
the
carbaryl
labels
to
represent
the
maximum
use
patterns.
The
input
parameters
used
to
represent
these
use
patterns
are
in
Table
2.
These
values
are
essentially
the
same
as
in
for
the
previous
set
of
EEC's
except
that
the
date
of
first
application
was
changed
for
some
crops
to
better
represent
the
use
pattern.
For
citrus,
simulations
for
two
different
initial
application
dates
were
done,
April
1
and
August
31.
The
April
1
date
appears
to
be
plausible
for
Florida
given
the
pests
carbaryl
is
intended
to
control,
but
monitoring
data
in
Florida
citrus
watersheds
indicate
that
there
is
use
during
August
and
September
(
D285826).
The
results
for
the
citrus
scenario
are
discussed
in
the
characterization
section
below.
In
cases
where
a
minimum
re­
application
interval
was
specified
on
the
label
this
value
was
used
in
the
maximum
application
pattern.
In
cases
when
no
minimum
interval
is
specified,
a
interval
of
3
days
was
used.
The
OPP
current
has
no
written
guidance
for
this
subject.
However,
three
days
is
a
reasonable
minimum
retreatment
interval,
given
that
scouting
and
evaluation
of
efficacy
would
have
to
occur
before
another
treatment
is
undertaken.
This
minimum
value
has
been
used
by
OPP
for
Tier
2
modeling
in
the
absence
of
guidance
for
10
years.
Metadata
for
each
scenario
is
described
in
EFED,
2002b.

Table
2.
Maximum
use
patterns
for
carbaryl
application
on
selected
crops
based
on
the
EPA
label.

Crop
Single
app.
Rate
(
lb
acre­
1)
Number
of
Applications
Applicatio
n
Interval
Application
Method
Date
of
First
Application
Apples
2
5
3
days
aerial
June
1
Citrus
5
4
14
days
aerial
April
1
Field
Corn
2
4
14
days
aerial
June
1
Sweet
Corn
2
8
14
days
aerial
May
1
Sugar
Beets
1.5
2
14
days
aerial
June
1
62
Table
3.
Maximum
reported
use
patterns
for
carbaryl
application
on
selected
crops
Crop
Single
app.
Rate
(
lb
acre­
1)
Number
of
Applications
Application
Interval
Application
Method
Date
of
First
Application
Apples
1.6
2
14
days
aerial
June
1
Citrus
4.26
3
14
days
aerial
April
30
Field
Corn
1.5
2
14
days
aerial
June
1
Sweet
Corn
3*
1
­­­
aerial
June
1
Sugar
Beets
1.2
1
­­­
aerial
June
1
*
The
maximum
reported
rate
is
greater
than
the
maximum
label
rate.
The
seasonal
maximum
rate
is
not
exceeded,
however.

Table
3
contains
maximum
reported
use
patterns
(
application
rate
and
number
of
applications),
and
represents
the
high
end
of
actual
carbaryl
use
patterns
for
these
crops
as
determined
from
survey
usage
data
available
from
the
Doane's
Agricultural
Services.
Table
4
contains
"
average"
use
patterns,
developed
from
estimates
of
the
mean
(
50
percentile??)
number
of
applications
application
rate,
the
total
number
of
acres
receiving
an
application
and
total
applied
to
each
acre
for
each
crop.
(
Hernandez,
2002).
For
the
"
average"
use
pattern,
the
number
of
applications
more
closely
reflects
those
that
are
reported
by
BEAD
in
the
QUA
(
Hernandez,
2002).

Table
3.
`
Average'
use
patterns
for
carbaryl
application
on
selected
crops
Crop
Single
app.
Rate
(
lb
acre­
1)
Number
of
Applications
Application
Interval
Application
Method
Date
of
First
Application
Apples
1.2
2
14
days
air
blast
June
1
Citrus
3.4
2
14
days
aerial
April
30
Field
Corn
1
2
14
days
aerial
June
1
Sweet
Corn
3.4
2
14
days
aerial
June
1
Sugar
Beets
1.5
1
­­­
aerial
June
1
*
The
maximum
reported
rate
is
greater
than
the
maximum
label
rate.
The
seasonal
maximum
rate
is
not
exceeded,
however.
**
The
`
average'
rate
is
greater
than
maximum
reported
rate.
The
reason
for
this
discrepancy
is
not
known.

In
all
cases,
an
aerial
application
was
used
for
the
maximum
use
pattern
and
the
maximum
reported
use
pattern
as
this
is
the
application
practice
on
the
label
which
results
in
63
the
most
drift.
In
practice,
the
orchard
crops
would
most
often
receive
an
application
by
air
blast
equipment,
therefore
air
blast
was
simulated
for
average
uses.
Aerial
application
is
represented
by
using
a
spray
drift
efficiency
of
0.16
and
an
application
efficiency
of
0.95
while
air
blast
is
represented
by
values
of
0.064
and
0.99
for
these
parameters
respectively.

Chemical
Parameters
The
input
parameters
used
to
describe
the
chemical
properties
of
carbaryl
are
in
Table
5.
In
most
cases
these
parameters
were
selected
in
accordance
with
guidance
(
Environmental
Fate
and
Effects
Division,
2002).
Data
quality
descriptions
for
each
parameter
were
derived
as
follows.
`
Excellent'
was
used
to
describe
parameters
which
very
well
know
and
had
little
or
no
error
associated
with
them
(
e.
g.
molecular
weight)
or
when
there
is
an
abundance
of
high
quality
data
available.
`
Very
good'
is
used
to
describe
parameters
from
high
quality
studies
and
the
study
is
generally
reproducible
(
e.
g.
hydrolysis)
,
or
when
there
is
substantial
background
variability
(
e.
g.
aerobic
soil
metabolism)
there
are
multiple
high
quality
studies
used
to
develop
the
input
parameter.
Good
is
used
to
describe
abiotic
process
data
where
there
the
data
is
expected
to
be
reproducible,
but
is
more
uncertain
than
normal,
or
metabolism
parameters
base
on
two
high
quality,
or
multiple
studies
which
are
usable
but
not
high
quality.
Fair
is
used
to
describe
metabolism
parameters
based
on
a
single
study,
or
significantly
flawed
by
usable
data
for
describing
abiotic
processes.
Poor
is
used
describe
input
parameters
based
on
surrogate
data
.
In
the
previous
drinking
water
modeling,
soil
water
partitioning
was
represented
by
Kd
values
which
were
keyed
to
the
soil
texture
in
studies
where
Kd's
were
measured.
Since
texture
is
usually
only
a
factor
of
secondary
importance,
this
does
not
always
result
in
great
accuracy.
In
this
assessment,
a
Koc
was
estimated
by
regressing
the
Kd's
values
against
the
organic
carbon
content.
The
Koc
value
estimated
using
a
regression
model
with
both
a
slope
and
an
intercept
is
significant
at
p
=
0.05.
However,
the
Koc
model
used
in
both
PRZM
and
EXAMS
assumes
that
the
binding
at
zero
organic
carbon
content
is
zero
(
no
y­
intercept).
The
regression
to
this
model
is
significant
at
p
=
0.1
but
not
0.05
and
results
in
a
Koc
estimate
of
196
kg
L­
1.
This
will
result
in
some
underestimation
of
the
binding
(
and
overestimation
of
carbaryl
mobility)
in
soils
with
low
organic
carbon
content,
but
greater
accuracy
over
all
scenarios.

Metabolism
half­
lives
were
estimated
from
single
studies
available
for
each
of
the
following
three
studies:
aerobic
soil
metabolism,
aerobic
aquatic
metabolism,
and
anaerobic
aquatic
metabolism.
The
aerobic
soil
and
anaerobic
aquatic
metabolism
half­
lives
were
consequently
multiplied
by
three
in
keeping
with
current
policy
to
account
for
the
uncertainty
caused
by
the
high
background
variability
in
these
parameters.
The
anaerobic
aquatic
metabolism
values
in
the
previous
modeling
assessment
was
not
adjusted
by
three.
In
the
previous
assessment,
the
aerobic
aquatic
metabolism
half
life
input
parameter
was
14.7
days,
or
three
times
the
single
estimate.
However,
this
value
was
not
adjusted
to
account
for
hydrolysis,
resulting
in
the
effect
of
hydrolysis
being
double
counted
in
the
previous
assessment.
This
assessment
corrected
that
error;
the
expected
hydrolysis
rate
(
9.3
days)
at
the
study
pH
(
7.1)
was
subtracted
from
the
rate
constant
for
the
measurement
from
the
aerobic
aquatic
metabolism
64
study.
The
resulting
value,
9.87
days,
which
is
the
half­
life
in
the
aerobic
aquatic
metabolism
study
due
to
metabolism
alone,
was
multiplied
by
three
for
an
input
parameter
of
29.6
days.

In
the
original
assessment,
the
foliar
degradation
rate
was
set
to
35
days,
the
default
value
based
on
current
OPP
policy
for
terrestrial
exposure
assessments
which
is
not
the
same
as
the
current
guidance
for
aquatic
modeling.
Current
guidance
for
setting
the
foliar
degradation
rate
for
PRZM
(
the
PLDKRT
parameter)
recommends,
in
the
absence
of
data
to
set
the
parameter
to
zero
(
no
degradation)
or
no
degradation
is
this
correct.
The
primary
registrant,
Bayer
CropScience,
provided
data
(
MRID
45860501)
in
their
comments
on
the
draft
Carbaryl
EFED
chapter
(
Libelo
et
al,
2002)
demonstrating
that
carbaryl
degrades
on
foliage
at
a
substantially
faster
rate
than
35
days.
The
data
submitted
with
the
report
was
reviewed
and
analyzed
(
D288376).
Based
on
this
assessment,
a
new
value
of
3.71
days
was
used
as
the
foliar
degradation
half­
life.
This
represents
an
upper
90%
confidence
bound
on
the
mean
from
30
studies
from
which
foliar
dissipation
of
carbaryl
could
be
estimated.

Table
5.
Chemical
input
parameters
for
carbaryl.

Parameter
Value
Quality
Molecular
weight
201.22
g
mol­
1
excellent
Solubility
32
mg
L­
1
good
Henry's
Law
Constant
1.28
x
10
­
8
atm­
m­
3
mol­
1
fair
Koc
196
L
kg­
1
good
Aerobic
soil
metabolism
half­
life
12
d
fair
Aerobic
aquatic
metabolism
half­
life
29.6
d
fair
Anaerobic
aquatic
metabolism
half­
life
216.6
d
fair
Hydrolysis
half­
life
pH
5
­
assumed
stable
pH
7
­
12
d
pH
9
­
0.133
d
very
good
Aqueous
photolysis
21
d
very
good
Foliar
Degradation
Rate
3.71
d
excellent
Foliar
Washoff
Coefficient
0.91
fair
As
part
of
the
data
submitted
for
consideration
in
estimating
the
foliar
degradation
rate,
the
registrant
also
submitted
data
which
supported
a
revised
estimate
of
the
foliar
washoff
coefficient.
In
the
absence
of
data,
current
EFED
policy
recommends
value
of
0.5
which
represents
the
fraction
of
chemical
that
washes
off
with
each
1
cm
of
rainfall.
An
analysis
of
two
relevant
studies
indicates
that
carbaryl
washoff
is
greater;
a
washoff
coefficient
of
0.91
is
more
appropriate
based
on
the
data
reviewed.
However,
the
estimates
for
both
studies
were
based
on
two
data
point,
so
no
error
term
or
determination
of
variability
in
the
data
could
be
made.
A
more
complete
description
of
how
the
studies
were
assessed
is
in
OPP
review
D288376.
65
Effects
of
Drinking
Water
Treatment
There
is
some
evidence
that
conventional
drinking
water
treatment,
that
is
coagulation,
flocculation
and
settling,
is
expected
to
reduce
carbaryl
concentration
by
43%
of
the
concentration
prior
to
treatment
(
US
EPA,
1989).
This
is
based
on
a
study
of
wastewater
containing
carbaryl
treated
with
alum
at
100
mg
L­
1
and
1
mg
L­
1
of
anionic
polymer
(
Whittaker
et
al.
1982).
In
addition,
ozone
has
been
shown
to
be
99%
effective
at
removing
carbaryl
from
water
(
Shevchenko
et
al.,
1982)
and
removes
it
from
water
at
a
rate
too
fast
to
measure
(
Mason
et
al.
1990).
Evidence
suggests
that
chlorine
and
hypochlorite
may
be
ineffective
at
degrading
carbaryl
(
ibid.).
At
this
point
in
time,
ozonation
is
only
infrequently
used
for
disinfection
of
public
drinking
water
in
the
United
States.
Based
on
the
hydrolysis
data,
softening
would
be
expected
to
substantially
reduce
carbaryl
concentrations
(
via
alkaline
hydrolysis)
as
softening
raises
the
pH
of
the
water
as
high
as
11.
Softening
is
used
on
`
hard'
water
that
is
high
in
calcium
and
magnesium
and
decreases
the
concentrations
of
these
cations.
The
Office
of
Pesticide
Programs
currently
does
not
have
sufficient
information
to
account
for
locations
where
water
softening
processes
are
utilized
at
public
drinking
water
treatment
facilities,
and
thus
cannot
systematically
use
this
information
in
estimating
EEC's.

Results
and
Characterization
EEC's
were
calculated
as
described
above
and
then
adjusted
for
percent
cropped
area
(
PCA),
based
on
OPP
guidance
(
OPP,
2000).
For
apples,
citrus,
and
sugar
beets,
the
default
PCA
for
all
agricultural
land
of
0.87
was
used.
The
individual
PCA
for
corn
of
0.46
was
used
for
field
corn
and
sweet
corn.
These
adjusted
EEC's
were
reported
in
Table
1
at
the
front
of
the
document,
and
the
full
distribution
of
EEC's
were
made
available
for
use
in
dietary
exposure
estimation.
The
citrus
scenario
is
recommended
in
estimating
EEC's
for
Tier
II
drinking
water
assessment.
A
Tier
II
EEC
uses
a
single
site
which
represents
a
high
exposure
scenario
for
the
use
of
the
pesticide
on
a
particular
crop
or
non­
crop
use
site.
The
weather
and
agricultural
practice
are
simulated
at
the
site
over
multiple
(
in
this
case,
30)
years
so
that
the
probability
of
an
EEC
occurring
at
that
site
can
be
estimated.
Sites
are
selected
to
represent
a
site
which
is
more
vulnerable
than
90%
of
the
sites
which
are
used
for
growing
the
crop
on
a
nationwide
basis.
Sites
are
currently
selected
to
meet
this
standard
by
best
professional
judgement.
For
each
simulation,
the
exposure
of
interest,
either
the
annual
peak
or
mean,
is
identified
for
each
year.
These
30
values
are
sorted
and
the
single
point
estimate
is
selected
by
identifying
the
value
that
would
be
expected
to
recur
once
every
10
years.
For
these
simulations,
this
specific
value
is
linearly
interpolated
from
between
the
third
and
fourth
highest
annual
values.

These
values
are
greater
than
those
that
would
be
expected
to
be
found
in
the
environment
primarily
for
three
reasons.
First,
we
have
used
the
default
PCA
of
0.87,
as
the
PCA
for
citrus
in
Florida.
The
default
PCA
is
the
maximum
proportion
of
agricultural
land
found
in
any
basin
in
the
country,
In
fact,
the
actual
PCA
in
Florida
is
probably
closer
to
one­
third
this
value,
although
a
precise
estimate
is
not
available
at
this
time.
Secondly,
the
percent
crop
treated
has
been
assumed
to
be
100%.
In
fact,
according
to
BEAD
(
Hernandez,
2002),
the
percent
crop
treated
for
different
citrus
crops
ranges
for
1.5
to
6%,
depending
on
the
crop.
Thirdly,
since
the
66
labels
have
not
specified
maximum
number
of
applications,
the
maximum
practice
modeled
is
substantially
greater
than
that
which
is
usually
used
in
practice.

Table
6.
Drinking
Water
EEC's
for
carbaryl
based
maximum,
`'
average''
and
maximum
reported
use
patterns.

Crop
Number
of
Applications
per
Year
Pounds
A.
I.
per
application
Surface
Water
Acute
(
ppb)
(
1
in
10
year
peak
single
day
concentration)
Surface
Water
Chronic
(
ppb)
(
1
in
10
year
annual
average
concentration)

Sweet
Corn
(
OH)
(
PCA
=
0.46)
Maximum1
8
2
57.3
5.53
Average2
2
3.4
49.8
2.31
Maximum3
Reported
3
1
25.6
1.26
Field
Corn
(
OH)
(
PCA
=
0.46)
Maximum1
4
2
51.3
2.72
Average2
2
1
14.6
0.68
Maximum3
Reported
2
1.5
21.9
1.02
Apples
(
PA)
(
PCA
=
0.87)
Maximum1
5
2
62.9
2.20
Average2
2
1.2
23.4
0.63
Maximum3
Reported
2
1.6
34.4
1.04
Sugar
Beats
(
MN)
(
PCA
=
0.87)
Maximum1
2
1.5
48.2
2.16
Average2
1
1.5
13.6
0.73
Maximum3
Reported
1
1.2
10.8
0.58
Citrus
(
FL)
(
PCA
=
0.87)
Maximum1
4
5
316
14.2
Average2
2
3.4
203
7.33
Maximum3
Reported
3
4.26
272
10.0
1
Maximum
application
rate
on
label
2
Average
application
rate
from
Quantitative
Usage
Analysis
for
Carbaryl,
prepared
July
21,
1998
by
Frank
Hernandez,
OPP/
BEAD
3
Maximum
rate
of
application
reported
in
Doanes
survey
data
In
particular,
the
rate
per
acre,
and
the
number
of
treatments
per
season
is
often
less
than
that
allowed
on
the
label.
In
addition,
the
interval
between
applications,
when
there
is
more
than
one
is
usually
longer
than
has
been
simulated
for
the
maximum
use
pattern.
This
third
factor
has
been
addressed
in
this
assessment,
and
is
reflected
in
the
EEC's
from
the
`
average'
and
maximum
reported
use
patterns
from
Table
3
and
4.

Three
additional
simulations
were
done
for
citrus
in
order
to
better
characterize
the
exposure
in
this
scenario.
In
the
first
simulation,
the
application
date
for
the
first
application
was
changed
from
April
30
to
August
31,
otherwise
using
the
maximum
application
practice.
The
second
simulation
also
changed
the
first
application
date
but
with
`
average'
application
practice.
While
there
are
pests
which
could
be
of
concern
on
citrus
as
early
as
April,
monitoring
data
from
67
the
area
indicates
that
most
of
the
usage
actually
occurs
in
the
late
summer.
The
1­
in­
10
year
peak
EEC
for
the
April
application
and
maximum
label
practice
is
316
while
for
September
the
value
is
220
:
g
L­
1.
For
`
average'
application
practice,
the
respective
EEC's
are
203
and
125
:
g
L­
1.
Another
run
was
done
where
best
estimates
for
all
the
metabolism
values
were
used
as
inputs
(
4
day
half­
life
for
aerobic
soil
metabolism,
a
9.6
day
half­
life
for
aerobic
aquatic
metabolism,
72.2
days
for
anaerobic
aquatic
metabolism,
and
3.2
days
for
foliar
degradation)
combined
with
`'
average''
application
practice
in
September
to
give
a
`
best'
estimate
of
the
EEC
for
this
site.
The
1­
in­
10
year
peak
in
this
case
was
78.9
:
g
L­
1.

In
addition
to
the
point
estimate
EEC's
for
drinking
water
exposure
described
above.
We
have
provided
the
time
series
of
concentrations
for
the
entire
duration
of
the
simulation
for
the
different
citrus
scenarios.
These
series
of
estimates
are
intended
for
use
in
a
more
full
of
the
whole
range
dietary
exposure
for
carbaryl
and
are
being
combined
with
pesticide
residues
in
food
using
the
DEEM
model.
While
making
fuller
use
of
the
whole
time
series
for
drinking
water
exposure
is
expected
to
improve
the
description
of
the
dietary
risk,
using
the
time
series
for
water
in
combination
with
the
distribution
of
food
residues
and
consumption
patterns
normally
used
in
DEEM
substantially
alters
the
interpretation
of
the
risk
represented
by
the
output
of
the
model
because
the
drinking
water
component
introduces
a
time
component
which
is
not
present
in
the
food
and
consumption
data
­
any
time
component
in
the
data
is
ignored
by
DEEM.
Technically,
the
food
and
consumption
distributions
are
assumed
to
be
`
stationary'
with
respect
to
time
and
location,
that
is
the
distributions
are
always
the
same
at
any
point
in
time
and
any
location
in
the
United
States.
This
is
a
reasonable
assumption
for
food
residues
and
consumption,
but
not
a
reasonable
one
for
pesticide
residues
in
drinking
water
which
are
expected
to
vary
by
orders
of
magnitude
with
both
time
and
location.
The
difference
in
interpretation
can
be
best
illustrated
by
describing
how
the
interpretation
differs
when
the
different
exposure
components
dominate
the
exposure
profile.
When
food
(
other
than
water
dominates
the
exposure
and
the
drinking
water
contribution
is
negligible,
an
exceedance
of
the
99.9%
threshold
implies
that
one
person
in
1000
across
the
whole
U.
S.
population
is
above
the
threshold
each
day.
If
drinking
water
dominates
and
food
contributions
are
negligible,
an
exceedance
of
the
99.9%
means
that
the
entire
population
provided
drinking
water
from
a
facility
represented
by
scenario,
are
expected
to
exceed
the
risk
once
every
1000
days,
a
little
less
that
once
every
three
years.
When
both
water
and
food
sources
make
significant
contributions
to
exposure,
a
more
detailed
analysis
of
the
structure
of
the
data
is
necessary
to
determine
the
nature
of
the
risk.
Depending
on
the
structure
of
the
risk,
regulating
on
the
99.9
percentile
in
a
manner
similar
to
that
used
previously
may
not
provide
a
intended
level
of
safety
similar
to
that
which
is
provided
by
using
DEEM
with
food
only
and
the
DWLOC
approach
with
water.

Beyond
the
three
major
factors
which
are
described
above,
there
are
a
number
of
other
factors
inherent
in
the
modeling
can
affect
the
accuracy
and
precision
of
this
analysis
including
the
selection
of
the
high
exposure
scenarios,
the
quality
of
the
input
data,
the
ability
of
the
models
to
represent
the
real
world,
and
the
number
of
years
that
were
modeled.

Scenarios
that
are
selected
for
use
in
Tier
2
EEC
calculations
are
ones
that
are
likely
to
produce
large
concentrations
in
the
aquatic
environment.
It
should
represent
a
site
that
really
exists
and
would
be
likely
to
have
the
pesticide
in
question
applied
to
it.
It
should
be
extreme
68
enough
to
provide
conservative
estimates
of
the
EEC,
but
not
so
extreme
that
the
model
cannot
properly
simulate
the
fate
and
transport
processes
at
the
site.
Currently,
sites
are
chosen
by
best
professional
judgement
to
represent
sites
which
generally
produce
EEC's
larger
than
90%
of
all
sites
use
for
that
crop.
The
EEC's
in
this
analysis
are
accurate
only
to
the
extent
that
the
site
represents
this
hypothetical
high
exposure
site.

The
quality
of
the
analysis
is
directly
related
to
the
quality
of
the
input
parameters.
In
general,
the
fate
data
for
carbaryl
are
good.
The
paucity
of
soil
and
aquatic
metabolism
data
is
the
main
limitation
of
the
data
set.
Because
metabolism
values
are
set
to
the
upper
90%
confidence
limit
of
the
mean,
the
EEC's
will
be
conservative
to
the
extent
we
are
uncertain
of
the
true
central
tendency
of
the
metabolism
data.
Additional
metabolism
data
would
greatly
increase
our
confidence,
and
likely
reduce
our
EEC
estimates.
As
noted
above,
using
best
estimates
for
"
average"
application
practice
rather
than
the
standard
upper
bound
estimates
reduced
the
EEC
from
125
:
g
L­
1
to
78.9
:
g
L­
1.
This
indicates
that
the
quantity
and
quality
of
the
metabolism
data
can
substantially
effect
the
estimates.

The
models
themselves
represent
a
limitation
on
the
analysis
quality.
While
the
models
are
some
of
the
best
environmental
fate
estimation
tools
available,
they
have
significant
limitations
in
their
ability
to
represent
some
processes.
Spray
drift
is
estimated
as
a
straight
16%
of
the
application
rate
reaching
the
reservoir
for
each
application.
In
actuality,
this
value
should
vary
with
each
application
from
zero
when
the
wind
blows
away
from
the
reservoir
to
perhaps
as
high
as
20%.
A
second
major
limitation
of
the
models
is
the
lack
of
validation
at
the
field
level
for
pesticide
runoff.
While
several
of
the
algorithms
(
volume
of
runoff
water,
eroded
sediment
mass)
are
well
validated
and
well
understood,
there
is
less
confidence
that
PRZM
3.12
well
represents
the
amount
of
pesticide
transported
in
runoff
events.
Some
validation
efforts
undertaken
by
the
pesticide
industry
and
under
review
by
the
Agency
indicate
that
PRZM
gives
reasonable
estimates
of
pesticide
extraction
into
runoff,
but
validation
of
the
runoff
portion
of
PRZM
is
not
extensive.
Another
limitation
of
the
models
used
is
their
inability
to
handle
withinsite
variation
(
spatial
variability),
lack
of
crop
growth
algorithms,
and
an
overly
simple
soil
water
transport
algorithm
(
the
"
tipping
bucket"
method).
A
final
limitation
is
that
only
thirty
years
of
weather
data
were
available
for
modeling
at
each
site.
Consequently
there
is
approximately
a
1­
in­
20
chance
that
the
true
10%
exceedance
EEC's
are
larger
than
the
maximum
EEC
in
the
calculated
in
the
analysis.
If
the
number
of
years
of
weather
data
could
be
increased
it
would
increase
the
confidence
that
the
estimated
value
for
the
1­
in­
10
year
exceedance
EEC
was
close
to
the
true
value.

Literature
Citations
D285826.
Behl,
Elizabeth.
2003.
Review
of
"
Surface
Water
Monitoring
for
Residues
of
Carbaryl
in
High
Use
Areas
in
the
United
States."
EPA
Internal
Memorandum
to
Tony
Britten.

D288376.
Jones.
R.
David.
2003.
Review
of
"
Estimation
of
the
Foliar
Dissipation
Half­
life
of
Carbaryl"
and
Re­
analysis
of
the
Foliar
Degradation
Rate.
EPA
Internal
Memorandum
to
Tony
Britten.
69
MRID
45860501.
Holmsen,
Jeffrey
D.
Estimation
of
the
Foliar
Dissipation
Half­
life
of
Carbaryl.
Bayer
CropScience
Research
Triangle
Park,
NC
Study
ID
606YS.
Report
No.
B003798.

Environmental
Fate
and
Effects
Division.
2002.
Guidance
for
Selecting
Input
Parameters
in
Modeling
the
Environmental
Fate
and
Transport
of
Pesticides,
Version
II.
U.
S.
Environmental
Protection
Agency.
Washington,
D.
C.
http://
www.
epa.
gov/
oppefed1/
models
water/
input_
guidance2_
28_
02.
htm/

Environmental
Fate
and
Effects
Division.
2002b.
Pesticide
Root
Zone
Model
(
PRZM)
Field
and
Orchard
Crop
Scenarios:
Standard
Procedures
for
Conducting
Quality
Control
and
Quality
Assurance.
http://
www.
epa.
gov/
oppefed1/
models/
water/
qa_
qc_
documentation_
ver2.
htm/

Hernandez,
Frank.
March
18,
2002.
Quantitative
Usage
Analysis
for
Carbaryl.
Internal
EPA
Memorandum.

Libelo,
E.
Laurence,
Angel
Chiri,
and
Thomas
Steeger.
2001.
Environmental
Fate
and
Ecological
Risk
Assessment
for
the
Reregistration
of
Carbaryl.
Unites
States
Environmental
Protection
Agency/
Office
of
Pesticide
Programs.
http://
cascade.
epa.
gov/
RightSite/
getcontent/
Tempfile.
pdf?
DMW_
OBJECTID=
090007d4800cd83d&
DMW_
FORMAT=
pdf
Office
of
Pesticide
Programs.
2000.
Part
A.
Guidance
for
Use
of
the
Index
Reservoir
in
Drinking
Water
Assessments.
http://
www.
epa.
gov/
oppfead1/
trac/
science/
reservoir.
pdf
Shevchenko,
M.
A.,
P.
N.
Taran,
and
P.
V.
Marchenko.,
1982.
Modern
methods
for
purifying
water
from
pesticides.
Soviet
Journal
of
Water
Chemistry
and
Technology.
4(
4):
53­
71.

United
States
Environmental
Protection
Agency.
1989.
Lewis
Publishers.
Drinking
Water
Health
Advisory:
Pesticides.
Lewis
Publishers.
Chelsea,
Michigan.

Whittaker,
K.
F.,
J.
C.
Nye,
R.
F.
Wukasch,
R.
J.
Squires,
A.
C.
York,
H.
A.
Kazimier.
1982.
Collection
and
treatment
of
wastewater
generated
by
pesticide
application.
EPA
Report
No.
600/
2­
82­
028
70
APPENDIX
A2.
INPUT
FILES
FOR
ESTIMATING
DRINKING
WATER
EXPOSURE
FOR
TOTAL
CARBARYL
RESIDUES.

Table
C­
1.
Input
files
archived
for
azinphos
methyl
applied
to
pome
fruits.

File
Name
Date
Description
W12842.
dvf
July
3,
2002
weather
data
for
Florida
citrus
scenario
W14637.
dvf
July
3,
2002
weather
data
for
Pennsylvania
apple
scenario
W14914.
dvf
November
20,
2002
weather
data
for
Minnesota
sugar
beet
scenario.

W93815.
dvf
July
3,
2002
weather
data
for
Ohio
corn
scenario
Flcitrus.
txt
October
12,
2002
Florida
citrus
scenario
parameters
for
PRZM
&
EXAMS
MNsugarbeet.
txt
October
12,
2002
Minnesota
scenario
parameters
for
PRZM
&
EXAMS
OHcorn.
txt
October
12,
2002
Ohio
corn
scenario
parameters
for
PRZM
&
EXAMS
PAapple.
txt
October
12,
2002
Pennsylvania
apple
scenario
parameters
for
PRZM
&
EXAMS
Input
Data
Files
for
specific
simulations
(.
PZR
extension)

FLCits00
February
13,
2003
citrus,
maximum
use
pattern,
index
reservoir
FLCits01
February
13,
2003
citrus,
maximum
use
pattern,
Sept
application,
index
reservoir
FLCits02
February
13,
2003
citrus,
`
average'
use
pattern,
index
reservoir
FLCits03
February
13,
2003
citrus,
maximum
reported
use
pattern,
index
reservoir
FLCits04
February
13,
2003
citrus,
`
average'
use
pattern,
air
blast,
September
application,
best
estimate
metabolism
parameters.

FLCits10
March
7,
2003
citrus,
`
average'
use
pattern,
air
blast,
September
application
OHCorn00
February
13,
2003
field
corn,
maximum
use
pattern,
index
reservoir
OHCorn01
February
13,
2003
field
corn,
`
average'
use
pattern,
index
reservoir
OHCorn02
February
13,
2003
field
corn,
maximum
reported
use
pattern,
index
reservoir
OHCorn03
February
13,
2003
sweet
corn,
maximum
use
pattern,
index
reservoir
OHCorn04
February
13,
2003
sweet
corn,
`
average'
use
pattern,
index
reservoir
OHCorn05
February
13,
2003
sweet
corn,
maximum
reported
use
pattern,
index
reservoir
PAAppl00
February
13,
2003
apples,
maximum
use
,
index
reservoir
PAAppl01
February
13,
2003
apples,
`
average'
use,
index
reservoir
PAAppl02
February
13,
2003
apples,
maximum
reported
use,
index
reservoir
MNSbet00
February
13,
2003
sugar
beets,
maximum
use
pattern,
index
reservoir
MNSbet01
February
13,
2003
sugar
beets,
`
average'
use
pattern,
index
reservoir
MNSbet02
February
13,
2003
sugar
beets,
maximum
reported
use
pattern,
index
reservoir
cc:
Jeff
Dawson
Felicia
Fort
chemical
actions
71
APPENDIX
B1.
REVIEW
OF
DRINKING
WATER
MONITORING
STUDY.

UNITED
STATES
ENVIRONMENTAL
PROTECTION
AGENCY
WASHINGTON,
D.
C.
20460
PC
Code:
056801
DP
Bar
Code
D285826
DATE:
March
13,
2003
MEMORANDUM
SUBJECT:
Review
of
"
Surface
Water
Monitoring
for
Residue
of
Carbaryl
in
High
Use
Areas
in
the
United
States:
Final
Report"

FROM:
Elizabeth
Behl,
Chief
Environmental
Risk
Branch
IV
Environmental
Fate
and
Effects
Division
(
7507C)

THROUGH:
R.
David
Jones,
Sr.
Agronomist,
ERB4
Environmental
Fate
and
Effects
Division
(
7507C)

TO:
Anthony
Britten,
PM
Team
Reviewer
Branch
X
Michael
Goodis,
Acting
Chief
Special
Review
and
Reregistration
Division
(
7508C)

This
memo
presents
EFED's
review
of
the
final
report
from
a
study
voluntarily
conducted
by
Aventis
for
carbaryl.
Interim
results
from
this
study
were
reviewed
previously
by
the
Agency
(
DP
Bar
Code
D274824;
8/
7/
2001),
and
a
preliminary
review
of
the
study
and
data
from
the
interim
report
were
included
in
the
EFED
Risk
Assessment
of
Carbaryl
(
USEPA,
2002).
Aventis
provided
feedback
to
the
Agency
on
our
review
of
that
study,
which
the
Agency
responded
to
(
USEPA
2002a).
Aventis
provided
further
comment
(
largely
a
repetition
of
their
original
comments)
on
the
Agency's
review
of
this
monitoring
study
in
public
comments
submitted
to
the
electronic
docket
in
October
2002.

Conclusions
This
study
provides
useful
information
on
measured
concentrations
of
carbaryl
in
selected
surface
waters
of
the
United
States.
Based
on
our
analysis
of
sites
selected,
we
do
not
concur
that
these
results
can
be
used
directly
in
the
dietary
risk
assessment
to
represent
exposure
to
carbaryl
in
surface
water
source
drinking
water.
The
information
from
this
study
does
provide
some
good
quality
data
that
can
be
used
in
association
with
other
monitoring
data
sets
to
characterize
carbaryl
exposure.
72
These
data
will
be
used
in
conjunction
with
other
monitoring
data,
to
characterize
surface
water
modeling
estimates
of
carbaryl
exposure
from
surface­
water
source
drinking
water.

Involving
EFED/
OPP
in
the
scoping
and
planning
of
this
study,
developing
the
protocol
design,
and
during
site
selection
is
necessary
to
ensure
that
the
data
collection
effort
is
focused
on
adequately
addressing
the
specific
risk
assessment
questions.
The
main
study
goal
is
in
line
with
data
needed
by
the
Agency
to
refine
the
drinking
water
risk.
However,
the
implementation
of
the
study
(
especially
site
selection)
was
not
consistent
with
the
study
goal
and
the
data
can
be
used
only
qualitatively.

A
detailed
critique
of
the
monitoring
data
are
presented
in
the
body
of
this
review.
Several
major
drawbacks
to
the
quantitative
use
of
these
data
to
represent
drinking
water
exposure
are:

°
With
only
16
sites
to
represent
vulnerable
surface
water
bodies
for
selected
agricultural
uses
(
really
15,
as
the
LA
site
was
selected
to
represent
population
exposure
not
because
source
waters
were
vulnerable)
and
four
suburban
sites,
this
study
is
not
likely
to
provide
comprehensive
coverage
of
all
carbaryl
usage
sites,
given
the
great
geographic
diversity
of
carbaryl
use
areas
and
carbaryl
uses.

°
We
do
not
concur
that
sites
sampled
represent
the
"
the
highest
probable
risk
of
human
exposure
to
carbaryl
in
surface
water
in
each
state".
A
majority
of
the
agricultural
sites
monitored
do
not
have
"
high"
carbaryl
usage
in
the
county,
based
on
registrant
criteria.
The
size
of
watersheds
(
another
measure
of
site
vulnerability)
exceeded
the
70th
percentile
nationally
(
about
1000
aquare
kilometers)
for
all
but
five
agricultural
CWSs.
Overall,
the
majority
of
monitoring
sites
are
located
in
areas
where
carbaryl
usage
is
not
the
highest
nationally,
on
water
bodies
draining
large
watersheds,
or
on
systems
which
derive
their
water
from
large
lakes
or
rivers.
Although
there
is
some
carbaryl
usage
in
the
watersheds
of
these
CWS,
a
minority
of
monitoring
locations
appear
to
represent
CWS
which
are
most
vulnerability
to
contamination.

°
Because
little
supporting
data
were
provided
on
non­
agricultural
sales
and
national­
scale
nonagricultural
carbaryl
usage,
the
relative
vulnerability
of
the
systems
selected
to
represent
"
home
and
garden"
useage
effects
could
not
be
determined.
The
majority
of
those
systems
were
located
on
smaller
sized
waterbodies,
and
from
that
perspective
are
vulnerable
to
contamination.
Only
one
system
had
watershed
which
exceeded
the
70th
percentile
CWS
watershed
size
nationally
(
Blomquist,
2003).

°
The
monitoring
interval
(
one
week
to
two
weeks)
is
unlikely
to
capture
peak
concentrations
necessary
for
estimating
acute
dietary
risk,
given
the
variable
nature
of
the
exposure.

°
The
finished
water
data
are
difficult
to
interpret.
According
to
the
study
design
finished
water
samples
were
collected
before
raw
samples,
complicating
the
temporal
pairing
of
samples.
Also,
to
collect
temporally
paired
raw
and
finished
samples
(
and
to
interpret
the
resulting
data)
there
must
be
data
on
temporally
relevent
treatment
processes
in
place
at
each
sampling
point
during
the
sampling
period.
These
data
were
not
provided
or
discussed.
73
Despite
these
drawbacks,
the
study
design
was
one
of
the
better
surface­
water
monitoring
studies
submitted
to
the
Agency
over
the
past
several
years.
The
analytical
methodology
and
method
sensitivity,
quality
assurance
procedures,
study
duration,
and
aspects
of
their
approach
to
site
selection
were
sound.

Results
of
this
study
indicate
that
carbaryl
was
found
in
source
drinking
water
(
raw
water)
at
low
concentrations
in
the
majority
of
sites
(
13
of
16
sites)
selected
to
represent
impacts
from
agricultural
uses,
despite
the
relative
lack
of
vulnerability
of
these
sites.
Concentrations
measured
at
these
sites
were
low
(
roughly
2
to
31
ppt)
in
raw
water
and
generally
lower
in
treated
drinking
water;
however,
the
highest
concentrations
were
found
in
finished,
not
raw,
drinking
water
(
181
ppt).
Where
residues
were
detected,
frequency
of
detection
in
raw
water
samples
ranged
from
a
few
percent
of
total
samples
(
1­
6
%)
at
9
of
the
13
sites
to
about
20%
of
total
samples
(
14
­
21%)
at
4
sites.
Two
of
these
higher
detection
frequency
sites
are
on
the
Sacramento
River,
one
site
in
Florida,
and
one
site
in
Massachusetts
representing
impacts
from
use
on
cranberries.
There
is
some
correspondence
annually
with
the
timing
of
detections
at
each
site,
but
it
is
not
uniformly
strong.
At
several
sites,
low­
level
concentrations
were
measured
over
3­
4
week
periods
in
weekly
samples.
Given
the
environmental
fate
characteristics
of
this
compound,
this
is
most
likely
the
result
of
the
volume
of
usage
rather
than
the
persistence
of
the
compound.

Carbaryl
was
reported
in
raw
water
of
all
four
CWS
selected
to
represent
impacts
from
home
and
garden
uses.
Concentrations
measured
in
raw
water
at
these
sites
were
low
(
roughly
2
to
44
ppt)
and
detection
frequencies
ranged
from
approximately
1
to
20
%.
How
representative
these
systems
are
of
the
home
and
garden
use
of
carbaryl
cannot
be
determined
from
the
data
provided.
However,
the
lowest
detection
frequency
occurred
at
the
CWS
with
the
largest
watershed
size
(
exceeding
the
70th
percentile
nationally).
At
one
site,
concentrations
were
reported
in
sequential
weekly
samples
for
a
period
of
several
months,
likely
due
to
the
volume
of
usage.

Because
raw
and
finished
samples
were
not
temporally
paired,
we
cannot
make
quantitative
statements
about
the
impact
of
treatment
processes
in
removing
carbaryl
from
source
water.
In
fact,
in
several
instances
the
treated
water
concentrations
were
higher
than
the
raw
water
concentration
in
the
"
pair",
including
the
highest
reported
concentrations
Background:

This
study
was
voluntarily
conducted
by
the
registrant
of
carbaryl,
and
no
protocol
was
submitted
for
review
by
the
Agency
prior
to
it's
initiation.
Interim
results
from
this
study,
containing
data
covering
the
period
February
19,
1999
through
December
31,
2000,
were
reviewed
previously
by
the
Agency
(
USEPA,
2001).
At
the
time
the
Agency
concluded
that:

"
The
results
of
this
study
may
provide
useful,
though
limited,
information
on
the
level
of
carbaryl
contamination
in
raw
surface
water
used
for
drinking
water.
It
may
also
provides
limited
information
on
concentrations
present
in
finished
water.
It
is
hoped
that
the
results
of
this
study,
in
combination
with
data
from
other
sources,
will
increase
our
understanding
of
exposure
to
carbaryl
in
drinking
water.
Information
74
on
site
selection,
source
water,
carbaryl
use
and
how
the
sampled
water
supplies
relate
to
population
distribution
are
required
to
fully
evaluate
the
data
collected
in
this
study.

The
site
selection
was
subsequently
submitted
to
the
Agency
(
10/
1/
2002)
as
an
appendix
to
the
final
report.

OPP
uses
the
models
PRZM
and
EXAMS
to
estimate
concentrations
of
pesticides
that
can
occur
in
surface
water,
and
evaluates
available
monitoring
data
in
developing
pesticide
exposure
assessments.
For
chemicals
with
relatively
short
half­
lives
and
when
acute
exposure
is
of
key
concern,
model
estimates
provide
a
more
realistic
estimate
of
upper­
end
exposure
than
most
monitoring
data,
largely
due
to
the
prohibitive
costs
associated
with
very
frequent
sample
collection
and
analysis
of
large
numbers
of
samples.

Monitoring
data
do
provide
a
valuable
check
on
model
values,
which
are
intended
to
represent
the
upper
end
of
potential
exposure.
Comparison
of
model
and
monitoring
results
are
most
relevant
when
monitoring
sites
are
selected
to
be
similarly
representative
of
the
upper
end
of
potential
exposure.
In
general,
review
of
a
monitoring
study
will
focus
first
on
the
overall
design
of
the
monitoring
study
to
determine
if
the
study
design
is
consistent
with
the
study
purpose.
Second,
the
review
should
determine
if
the
implementation
of
the
study
is
consistent
with
the
study
design
(
and
the
study
purpose).
Finally,
the
results
of
the
study
are
evaluated
in
terms
of
data
quality
and
in
the
context
of
the
study
design.

Problem
Formulation
Problem
formulation
should
occur
prior
to
initiation
of
a
monitoring
program
and
should
involve
interaction
between
risk
assessors,
risk
managers
and
other
interested
parties.
The
interactive
nature
of
this
activity
is
critical
to
ensure
that
the
data
will
address
regulatory
questions.
Problem
formulation
prior
to
initiation
of
this
study
appears
to
have
been
done
primarily
by
Rhone­
Poulenc.

Study
Purpose
In
their
final
report,
Aventis
states
the
purpose
of
the
study
as
follows:

"
This
study
was
conducted
to
determine
the
potential
for
carbaryl
residues
to
reach
public
water
supplies
resulting
from
the
use
of
SEVIN
brand
insecticides.....
This
study
was
conducted
to
provide
an
assessment
of
the
potential
of
carbaryl
residues
in
surface
water
to
contribute
to
dietary
exposure
due
to
consumption
of
drinking
water."

Assessment
Endpoints
Bayer
does
not
explicitly
identify
assessment
endpoints
for
carbaryl.
Carbaryl
risk
from
drinking
75
water
sources
will
be
determined
by
the
Agency
in
association
with
other
dietary
components,
including
assessment
of
both
acute
and
chronic
endpoints.
Acute
endpoints
are
of
particular
interest
in
assessing
carbaryl
risk,
and
require
an
estimate
of
peak
carbaryl
concentrations
in
drinking
water.
Consideration
of
this
endpoint
is
not
evident
in
the
study
design.

Conceptual
Model
There
is
no
description
of
the
overall
system
and
conceptual
model
for
this
monitoring
study;
however,
one
can
be
interpreted
from
the
study
design
that
resulted.

°
Monitoring
points
selected
were
at
community
water
supply
facilities,
so
drinking
water
exposure
was
targeted.
All
community
water
supply
facilities
monitored
derived
their
water
from
surface
water
sources
and
treat
the
water
prior
to
distribution.
This
represents
the
majority
of
surface­
water
source
drinking
water
consumed
by
the
US
population
(
there
are
some
surface­
water
source
drinking
waters
that
are
not
treated
prior
to
consumption,
but
very
few).
Ground
water
sources
are
not
included
in
the
study
design.

°
Sites
were
selected
to
represent
locations
that
are
"
vulnerable"
to
carbaryl
exposure
largely
on
the
basis
of
pesticide
sales.

°
A
secondary
study
goal
is
to
represent
impacts
from
specific
uses
in
selecting
some
of
the
agricultural
monitoring
sites.

°
A
third
study
goal
is
to
incorporate
a
measure
of
potential
exposure
to
large
human
populations
(
rather
than
rather
than
system
vulnerability
to
contamination)

°
Aventis
collected
both
raw
and
finished
drinking
water
samples,
representing
the
finished
drinking
water
samples
collected
in
this
study
as
more
relevant
to
human
exposure
than
raw
water
samples.

Study
Design
(
Analysis
Plan)

The
following
sections
describe
study
design
components,
study
implementation,
and
results.

Number
of
sites
to
monitor.
RPAC
determined
that
16
sites
would
be
monitored
in
"
areas
of
high
agricultural
carbaryl
use";
and
four
in
"
large
suburban
areas
of
highest
regional
carbaryl
sales
for
non­
crop
use".
The
rationale
for
the
overall
number
of
monitoring
sites
(
20
sites)
is
not
provided
but
was
a
constraint
in
the
study
design,
most
likely
due
to
cost
considerations.
Because
carbaryl
is
widely
used
for
both
agricultural
and
home
and
garden
uses,
the
monitoring
sites
were
apportioned
to
represent
these
two
major
usage
categories.

No
summary
information
is
provided
describing
the
universe
of
carbaryl
use
nationally
("
agricultural"
and
"
home
and
garden")
for
reference
in
determining
the
number
of
sites
which
would
76
be
adequate
to
monitor
to
meet
the
study
goals.
Carbaryl
is
used
on
a
variety
of
crops
in
almost
every
State
in
the
U.
S.
(
based
on
Doane
usage
maps)
and
is
a
major
insecticide
for
home
and
garden
use
in
the
U.
S.
Given
the
diversity
of
uses
and
the
hydrologic
diversity
of
the
use
areas
it
is
difficult
to
adequately
represent
overall
carbaryl
impacts
on
surface
water
quality
with
this
small
number
of
monitoring
sites.

RPAC
also
indicated
that
they
tried
to
meet
a
secondary
study
goal,
to
represent
impacts
from
specific
uses
(
for
example,
from
cranberries),
in
selection
of
some
of
the
16
agricultural
sites.
This
second
goal
further
complicates
the
study
design
adding
an
additional
level
of
complexity.
For
example,
to
represent
a
range
of
potential
impacts
on
surface
water
quality
from
cranberry
uses
would
require
monitoring
at
several
sites
where
cranberries
agriculture
dominates
water
quality
impacts
or
alternatively
a
description
of
why
only
that
one
site
was
selected
to
represent
all
potential
cranberry
sites.
How
crop
type
would
play
into
site
selection
decisions
is
not
clear.

Bayer's
third
study
goal,
of
trying
to
include
sampling
of
sites
which
result
in
high
exposure,
would
result
in
a
very
different
set
of
site
selection
criteria.
These
criteria
are
not
presented,
not
is
there
a
description
for
why
the
one
site
selected
was
chosen
over
other
potential
sites.

Site
Selection.
Aventis
characterizes
the
sites
selected
for
monitoring
as:

"
The
source
water
for
all
selected
water
treatment
facilities
was
surface
waters
originating
in
watershed
areas
with
a
high
carbaryl
use
on
agricultural
crops
or
which
drain
suburban
areas
with
high
sales
of
carbaryl
for
home
and
garden
use."

Monitoring
sites
were
all
existing
Community
Water
Supply
facilities
(
CWS),
which
supply
drinking
water
to
the
local
population.
All
CWS
had
to
have
surface
water
as
their
primary
exclusive
source
(
not
ground
water,
not
a
blend
of
ground
and
surface
water,
not
fa
surface
water
source
used
as
a
backup
to
the
primary
supply).

With
the
exception
of
one
system,
RPAC
characterized
all
CWS
as
potentially
vulnerable
to
carbaryl
contamination,
primarily
on
the
basis
of
"
high"
carbaryl
sales
(
or
high
usage
in
California)
in
the
counties
where
the
watershed
of
the
CWS
is
located.
The
exception
was
a
CWS
located
in
Riverside
Co.,
CA
which
supplies
a
very
large
population
(
Los
Angeles,
CA)
and
was
selected
on
the
basis
of
potential
population
exposure
rather
than
vulnerability
to
contamination.
County­
level
sales
was
stated
to
be
the
prime
criterion
for
selection
of
the
other
15
agricultural
sites,
and
high
sales
in
the
"
sales
region"
was
the
prime
criterion
for
selection
of
the
four
urban
sites.
Sales
regions
typically
cover
many
states;
the
top
distribution
city
in
the
sales
region
was
assumed
to
have
the
highest
sales
(
and
resulting
usage).

Differences
between
usage
and
sales
are
recognized,
and
"
refinements"
are
described
to
better
represent
actual
carbaryl
usage
in
a
watershed.
Use
of
GIS
tools
is
described
for
refining
the
site
selection,
identifying
watersheds
boundaries
and
overlaying
sales
data.
Refinement
of
crop
location
was
also
to
be
done
by
consultation
with
local
experts
(
RPAC
sales
personnel
and
CWS
personnel)
77
familiar
with
the
specific
sales
area.
How
this
will
be
documented
is
not
clear.
Land
use
data
was
also
to
be
used
in
home
and
garden
site
selection
to
screen
out
agricultural
use
and
identify
large
suburban
areas
with
CWS
using
small
rivers
draining
only
urban
areas.
Suburban
land
use
was
identified
in
NLCD
data
coverages
and"
low
intensity
residential".
Specific
criteria
to
be
used
(
what
defines
a
small
river;
what
density
of
housing
defines
suburban
land;
what
percentage
of
the
watershed
in
suburban
land
use
made
it
qualify)
are
not
provided.

Study
design
criteria
state
that:

"
CWS
using
small
and
medium
sized
watersheds
will
be
selected,
although
large
watersheds
may
be
selected
if
the
primary
carbaryl
application
area
is
located
near
the
intake
location.
This
is
done
to
maximize
the
likelihood
of
detecting
carbaryl
residues"

No
definitions
are
provided
for
the
terms
"
small",
"
medium",
and
"
large"
watersheds
and
criteria
describing
the
size
of
the
water
body
being
sampled
are
also
not
quantified.
In
identifying
vulnerable
monitoring
sites
for
the
USGS­
EPA
Pilot
Reservoir
(
Blomquist
et
al,
2001)
monitoring
study
EPA
focused
on
identifying
reservoirs
with
high
potential
pesticide
use,
high
intensity
agriculture
in
a
watershed,
relatively
small
volume
reservoirs
(
120
 
92,600
acre
feet)
and
relatively
small
watershed
size
(
3.3
 
784
square
miles).
These
parameters
are
important
in
identifying
and
appropriately
characterizing
watersheds
as
vulnerable
for
site
selection.

Several
of
the
rejection
criteria
identified
in
the
study
design
are
reasonable
to
use
to
select
CWS
as
assessment
points
consistent
with
the
study
design
goals.
In
general,
for
example,
the
CWS
selected
must
be
in
a
watershed
that
has
significant
carbaryl
use,
derives
their
water
from
surface
water
sources,
and
represents
source
waters
that
are
most
likely
to
be
contaminated.
Consistent
with
these
design
goals,
CWS
were
rejected
if:

°
The
CWS
watershed
was
in
a
non­
agricultural
area
of
a
high
carbaryl
sales
county
°
Source
waters
were
either:
ground
water,
mixed
surface
and
ground
water,
or
surface
water
was
only
the
secondary
source.
°
Source
was
a
Great
Lake
(
based
on
concerns
about
the
size
of
the
watershed
and
storage)
°
Personnel
were
unwilling
to
participate
°
Source
water
is
pumped
from
high
elevation
reservoirs
which
are
outside
agricultural
areas
(
specifically
in
CA)
°
the
ratio
of
county­
level
sales
area
to
non­
sales
area
in
watershed
was
"
low"
(
low
is
not
defined)

Several
other
criteria
are
not
consistent
with
the
study
goal
of
identifying
vulnerable
sites
for
sampling,
for
example:

°
Retaining
CWS
for
county
with
a
low
county­
level
sales
area
to
non­
sales
area
in
watershed
when
the
high
sales
county
was
in
"
proximity"
to
the
CWS
intake.
The
relative
influence
of
the
carbaryl
use
area
in
comparison
to
the
impact
of
the
rest
of
the
watershed
may
or
may
not
78
be
significant,
and
must
be
documented.
If
potential
carbaryl
impacts
at
the
CWS
are
not
likely
to
occur,
these
systems
should
be
rejected
as
measurement
locations
which
are
not
be
consistent
with
study
design
goals.

°
Retaining
CWS
for
systems
with
large
watersheds
or
rivers
if
the
"
high"
sales
county
was
in
"
proximity"
to
the
CWS
intake.
Again,
the
relative
influence
of
the
carbaryl
use
area
in
comparison
to
the
impact
of
the
rest
of
the
watershed
may
or
may
not
be
significant,
and
must
be
documented
with
all
termed
defined.
If
potential
carbaryl
impacts
at
the
CWS
are
not
likely
to
occur,
these
systems
should
be
rejected,
as
they
would
not
be
consistent
with
study
design
goals.

°
Rejecting
CWS
in
California
which
draw
water
from
canals
or
aqueducts
(
because
of
difficulties
in
accounting
for
input
from
flood­
irrigated
fields
and
"
ground
water
sources").
The
rationale
for
this
rejection
criterion
is
unclear,
as
irrigated
fields
which
may
drain
into
canals
(
or
for
that
matter
rivers)
exist
and
affect
surface
water
quality
in
California.
Rejection
CWS
which
could
have
water
quality
affected
by
irrigation
return
flow
preferentially
removes
some
of
the
most
potentially
vulnerable
CWS
from
consideration.
This
is
not
consistent
with
the
study
design
goal.

Sampling
frequency,
interval,
and
study
duration.
According
to
the
study
design,
sampling
at
the
agricultural
sites
begins
two
weeks
prior
to
the
typical
carbaryl
application
period
with
samples
collected
weekly
during
the
application
period
and
at
least
one
month
afterward.
.
The
timing
is
based
on
local
expert
advice,
but
how
this
was
determined
was
not
described.
Samples
are
to
be
collected
monthly
for
the
remainder
of
the
year.
The
exception
to
this
is
at
the
Florida
site,
as
a
result
of
the
broad
use
season,
where
sampling
continued
on
a
weekly
basis
throughout
the
year.
For
the
"
home
and
garden"
sites,
sample
is
scheduled
to
begin
in
March
or
April,
and
continued
weekly
throughout
the
study.
The
study
protocol
was
amended
to
provide
a
total
of
three
years
of
sampling,
consistent
with
EFED
recommendations.

Targeting
sampling
frequency
to
the
application
period
is
a
reasonable
approach.
The
duration
of
the
study
is
consistent
with
EFED
study
design
recommendations,
and
should
be
adequate
to
meet
study
design
goals.
Weekly
sampling
is
not
likely
to
provide
an
adequate
estimate
of
peak
concentrations
for
use
in
acute
exposure
assessment,
a
key
design
goal.

Sample
matrix.
Samples
are
to
be
collected
from
raw
drinking
water
at
the
intake
and
finished
water
after
passing
through
the
treatment
plant.
Duplicates
of
both
raw
and
finished
are
to
be
collected,
with
the
duplicate
available
for
analysis
as
needed.
All
raw
water
samples
are
being
analyzed.
Finished
water
samples
are
being
analyzed
when
the
paired
raw
water
sample
has
detectable
concentrations
of
carbaryl.
This
procedure
is
consistent
with
EFED
guidance
for
reactive
sampling
design,
with
the
stipulation
that
the
drinking
water
treatment
train
is
well
know
at
each
sampling
interval
so
that
samples
can
be
considered
to
be
paired.
The
protocol
stipulated
that
finished
samples
be
collected
prior
to
raw
samples,
so
raw
and
finished
sample
"
pairs"
will
not
be
collected
in
a
time
frame
relative
to
the
treatment
train.
79
Current
OPP
guidance
(
OPP,
2000)
for
monitoring
surface­
water
source
drinking
water
indicates
that
to
represent
drinking
water
exposure,
raw
water
samples
should
be
sampled
because
of
added
complexities
and
uncertainties
introduced
into
estimates.
These
recommendations
were
made
for
two
reasons.
First,
to
minimize
spatial
and
temporal
variability
introduced
during
treatment.
Second,
to
enable
necessary
mitigation
to
be
targeted
to
sources
waters
of
concern.
The
purpose
of
collecting
temporally
paired
raw
and
finished
drinking
water
should
be
to
determine
the
effect
of
treatment
on
exposure.
Mixing
the
raw
and
finished
water
results
combines
two
separate
sample
populations
and
makes
interpretation
difficult.

Ancillary
data
collection.
A
substantial
amount
of
information
is
provided
for
each
treatment
facility
and
watershed
area
including
watershed
delineation
and
GIS
characterization.
Although
the
information
is
better
than
what
is
presented
in
the
vast
majority
of
monitoring
studies,
it
is
difficult
to
determine
a
number
of
important
factors
about
the
facilities
which
control
their
vulnerability.
For
example,
it
is
difficult
to
determine
the
location
of
treated
areas
within
the
watershed
or
the
location
of
crops
treated,
from
the
information
provided.
Relatively
little
information
is
submitted
on
the
source
water
(
volume
of
reservoir
or
lake,
or
average
monthly
flowrate).
Information
on
treatment
processes
used
at
each
facility
is
provided,
but
not
in
a
way
that
can
be
used
quantitatively
to
estimate
removal
or
to
evaluate
the
timing
required
to
adequately
pair
raw
and
treated
samples.
The
nearest
NOAA
station
is
identified
as
a
source
of
precipitation
data.
Soils
information
is
also
provided
for
the
watershed.

Sample
collection
and
handling:
For
the
most
part
sample
collection
and
handling
procedures
as
described
in
the
protocol
will
meet
the
study
design
guidelines.
Sample
collection,
handling
and
shipment
procedures
according
to
Stone
Environmental
SOP's.
Samples
will
be
shipped
on
the
day
of
collection
with
ice
packs
(
described
in
SOP's)
and
samples
frozen
upon
receipt
at
the
lab
until
analysis.
Samples
will
be
stored
for
a
maximum
of
99
days
(
from
receipt
to
analysis)
Handling
procedures
will
depend
on
the
pH
of
the
water.
Since
carbaryl
is
unstable
in
alkaline
water
at
room
temperature,
0.5
ml
of
formic
acid
is
added
to
stabilize
potential
carbaryl
residues.

Analytical
Method
The
analytical
method
described
in
the
protocol,
including
the
method
detection
limit,
are
adequate
to
meet
the
study
goal.
LOD
is
2
ppt;
LOQ
is
30
ppt.
An
independent
laboratory
validation
(
ILV)
was
submitted
for
the
method.
Residues
detected
between
LOD
and
LOQ
were
estimated.
No
degradates
of
carbaryl
will
be
analyzed.
An
ILV
of
the
method
was
completed
prior
to
initiation
of
the
study.
Samples
are
extracted
prior
to
analysis
(
SPE
using
C18
SPE
cartridges).
Analysis
is
by
reverse
phase
HPLC,
quantified
by
MS/
MS.
The
protocol
indicates
that
the
control
test
matrix
in
quality
control
samples
(
i.
e.
matrix
spikes)
uses
"
Type
I"
water
The
source
of
this
water
is
not
clear,
and
should
be
described
in
detail.
The
effect
of
this
cannot
be
determined
from
the
data
provided.

QA/
QC.
Storage
stability
studies
were
conducted
for
field
and
lab
samples.
A
method
blank
and
a
field
spike
appear
to
be
included
with
each
sample
set
analysis,
but
the
description
is
confusing
and
the
overall
number
is
not
clear.
A
sample
set
appears
to
consist
of:
one
field
spike
at
30
ppt,
one
at
300
ppt
in
HPLC
grade
water,
one
control
blank,
and
some
number
of
field
samples.
.
Clarification
is
needed
to
confirm
that
this
is
the
case.
It
appears
that
each
sample
set
included
8
field
80
samples,
however
this
also
needs
confirmation.
Clarification
is
also
needed
regarding
the
use
of
field
blanks.

Storage
stability
was
tested
in
field
recovery
studies
at
5
locations
using
field
spikes:
duplicate
samples
of
raw
and
finished
water
(
200
ml)
were
spiked
at
300
ppt
and
30
ppt
of
carbaryl.
Storage
stability
studies
indicated
that
frozen
samples
were
stable
when
stored
for
total
of
4
months.

Summary
Aspects
of
the
study
design
are
consistent
with
Agency
guidance
and
the
primary
study
design
goals.
Useful
ancillary
data
is
collected
for
this
study
which
aids
in
analysis
of
the
study
design
and
implementation,
particularly
related
to
sample
QA,
analytical
results,
and
collection
and
handling
procedures.
Important
parameters
describing
CWS
vulnerability
(
reservoir
volume
or
stream
flowrate)
are
not
taken
into
consideration
in
site
selection,
a
significant
flaw
in
the
study
design.
Sampling
frequency
is
not
likely
to
be
adequate
to
meet
the
primary
study
design
goal.
Some
important
parameters
lack
adequate
definition.
Without
better
more
quantitative
definition
or
clear
decision
criteria
important
aspects
of
site
selection
are
subject
to
interpretation.
Adequate
information
is
not
provided
to
determine
if
the
number
of
sites
selected
to
monitor
such
a
complex
and
varied
use
area
is
adequate.
Not
enough
information
is
provided
to
determine
if
the
secondary
goal
of
representing
impacts
from
specific
crops
could
be
met
by
this
design.
OPP
guidance
on
the
use
of
finished
drinking
water
rather
than
raw
water
samples
to
estimate
pesticide
exposure
is
well
documented
(
OPP,
2000).
Because
of
the
protocol
for
collection
of
raw
and
finished
samples
it
will
be
difficult
to
draw
quantitative
conclusions
regarding
the
effect
of
treatment
on
carbaryl
residues.

Study
Implementation
Number
of
sites
to
monitor
It
appears
that
RPAC
identified
20
counties
in
certain
states
which
met
their
criteria
and
provided
this
information
to
a
contractor
to
finish
selection
of
individual
CWS
and
to
implement
the
study.

According
to
their
contractor:

"
The
goal
for
each
state
[
identified
by
RPAC]
was
to
establish
a
monitoring
program
using
the
CWSs
that
represented
the
highest
probable
risk
of
human
exposure
to
carbaryl
through
surface
drinking
water.
Highest
probable
risk
is
assumed
to
be
associated
with
those
watersheds
draining
the
highest
sales
counties
in
each
state."

RPAC
identified
20
municipal
water
treatment
facilities
which
derive
their
water
from
surface
water
sources.
RPAC
identified
sixteen
agricultural
sites
in:
California
(
5
sites);
Florida
(
1
site),
Michigan
(
2
sites),
New
York
(
2
sites),
Oregon
(
2
sites),
Texas
(
2
sites),
and
Washington
(
2
sites).
Sites
selected
for
potential
inclusion
as
"
large
suburban
areas
of
highest
regional
carbaryl
sales
for
noncrop
use"
were:
Dallas,
TX;
Atlanta,
GA;
Little
Rock,
AK,
and
Greensboro,
NC
Trying
to
meet
a
secondary
study
goal,
to
represent
impacts
from
specific
uses
(
for
example,
from
81
cranberries)
played
a
role
in
selection
of
some
of
the
16
agricultural
sites.
This
second
goal
complicates
the
study
purpose
adding
an
additional
level
of
complexity
to
the
conceptual
model.
However,
it
does
not
appear
that
additional
monitoring
sites
were
selected
to
meet
these
additional
criteria.
For
example,
to
represent
a
range
of
potential
impacts
on
surface
water
quality
from
cranberry
uses
would
likely
require
monitoring
at
more
than
one
site
where
cranberry
agriculture
dominates
water
quality
impacts.
At
the
very
least
a
description
of
why
this
one
site
was
selected
to
represent
all
potential
cranberry
sites
where
carbaryl
is
used
should
have
been
provided.

Bayer's
third
study
goal,
of
trying
to
include
sampling
of
sites
which
result
in
high
exposure,
would
result
in
a
very
different
set
of
site
selection
criteria.
These
criteria
are
not
presented,
not
is
there
a
description
for
why
the
one
site
selected
was
chosen
over
other
potential
sites.

Site
Selection
The
initial
scope
of
the
study
("
20
CWS
that
have
potential
risk
of
exposure
to
carbaryl")
was
determined
by
Rhone­
Poulenc
Agricultural
Company
(
RPAC)
based
on
sales
information,
location
of
CWS,
and
somehow
distributed
to
"
encompass
different
types
of
agricultural
use".
Sales
data
were
used
as
a
surrogate
for
determining
actual
agricultural
usage,
except
in
California
where
countylevel
use
data
was
available.
To
estimate
home
and
garden
use,
Aventis
relied
on
regional
sales
information
from
"
stores
such
as
Walmart,
Home
Depot,
and
Sam's
Club".
Although
the
site
selection
report
contains
a
table
(
see
Table
1
below)
of
major
carbaryl
use
crops,
how
this
information
was
used
to
systematically
select
sites
is
not
clear.

Table
1
Crop
Usage
(
as
presented
in
study
design)
and
monitoring
locations
selected
Crop
Usage
Agricultural
Monitoring
Site
Citrus
17%
Riverside,
CA,
Manatee
Co.

Vegetables
14%
Manatee
Co.,
Lenawee
Co.,
Marion
Co.

Tree
nuts
12%
W.
Sacramento,
Lodi,
CA
Wagoner
Co.
Calhoun
Co
Jefferson
Co.

Pastures
9%
Wagoner
Co.
Calhoun
Co
,
Jefferson
Co.

Stone
fruit
8%
W.
Sacramento,
Lodi,
CA
Pome
fruits
7%
Lenawee
Co.
Yates,
Co.
Chelan
Co.,
Franklin,
Co
Grains
6%

Grapes
5%
Chatauqua
Co.,
Yates,
Co.

Roots/
tubers
5%
Lenawee
Co.,
Franklin,
Co
Soybeans
4%
82
Other
7%
cranberry
­
Plymouth,
MA
rice­
Calhoun,
TX
Table
1
represents
major
use
crops
and
related
monitoring
sites,
according
to
Aventis.
From
this
table
it
appears
that
the
effort
to
distribute
sites
to
represent
the
variety
of
carbaryl
uses
played
a
relatively
major
role
in
site
selection
efforts.
Sites
do
represent
multiple
uses;
however
there
is
an
embedded
decision
to
select
sites
representing
some
relatively
minor
uses
rather
than
to
select
multiple
sites
representing
major
uses.
Also,
while
the
stated
use
may
occur
in
the
county,
it
is
not
clear
how
dominant
these
uses
(
or
home
and
garden
uses)
are
in
the
watersheds.

Agricultural
site
selection
This
section
describes
major
factors
considered
in
site
selection,
and
some
drawbacks
and
inconsistencies
in
applying
these
factors
which
resulted
in
selecting
a
number
of
sites
for
monitoring
which
were
not
particularly
vulnerable.
Information
is
presented
on
the
agricultural
sites
selected
in
Table
2.

Sales.
High
county­
level
sales,
the
primary
criterion
for
selection
of
the
agricultural
sites,
was
defined
by
RPAC
as
sales
greater
than
15,000
lb
a.
i.
The
intervals
used
to
map
county­
level
sales
(
in
lb.
a.
i.)
were:
0­
1,999;
"
low"
2,000­
4,999;
"
medium"
5,000­
14,999;
and
"
high"
15,000­
265,000.
Using
such
a
large
interval
to
represent
the
"
high
sales"
of
carbaryl
masked
several
of
the
higher
carbaryl
sales
counties
with
CWS
which
should
have
been
considered
in
site
selection.
According
to
the
site
selection
report
only
13
candidate
systems
were
found
in
the
high
sales
category
counties,
and
thus
additional
systems
were
selected
from
"
the
high
end
of
the
medium
sales
category"
(
not
defined).
Using
Doane
data
(
1999­
2­­
1)
we
identified
20
counties
nationally
with
surface
water
source
CWS
and
carbaryl
sales
over
15,000
pounds.
Five
of
these
counties
were
represented
in
the
final
set
of
monitoring
sites.
Several
of
the
CWS
selected
for
monitoring
in
this
study
were
in
counties
which
would
be
characterized
by
RPAC's
scale
as
"
low"
usage
(
less
than
5000
pounds),
for
example:
Calhoun
Co.,
900
pounds;
Lenawee
Co.,
1,500
pounds;
Wagoner
Co.,
1850
pounds;
Manatee
Co.,
3200
pounds;
Jefferson
Co.,
4,300
pounds.
Thus,
five
of
the
16
agricultural
sites
selected
did
not
meet
this
vulnerability
criterion.

Watershed
Size
and
Source
Volume.

In
selecting
sites
for
the
carbaryl
monitoring
program,
information
was
not
gathered
on
the
volume
of
the
reservoir
or
the
flow
rate
of
rivers,
and
these
parameters
were
not
considered
in
determining
the
vulnerability
of
sites.
The
importance
of
these
factors
(
and
a
third
factor,
watershed
size,
which
was
collected
as
ancillary
data
but
not
used
as
a
vulnerability
criterion),
on
site
vulnerability
was
recognized
in
study
design
rejection
criterion.
CWS
which
relied
on
the
Great
Lakes
as
their
water
source
were
rejected
due
to
the
large
size
of
their
watersheds
and
storage
of
the
lakes.
Information
was
not
provided
to
make
site
selection
determinations
based
on
the
size
or
volume
of
reservoirs
and
flowrate
of
rivers.
83
The
USGS­
EPA
Pilot
reservoir
monitoring
study
targeted
reservoirs
believed
to
be
vulnerable
to
pesticide
contamination
(
but
not
necessarily
the
most
vulnerable
in
any
given
region).
Reservoirs
selected
had
a
storage
capacity
of
between
120
and
92,600
acre­
feet
and
watershed
sizes
ranging
from
3.3
to
784
square
miles
(
8.6
­
2030
square
kilometers).
Reservoirs
vulnerable
to
pesticide
contamination
were
characterized
overall
as
small
reservoirs
in
high
pesticide­
use
areas
having
high
runoff
potential.

In
an
ongoing
project,
the
USGS
and
EPA
have
determined
the
size
of
watersheds
for
approximately
7,000
US
surface­
water
source
CWS
(
Blomquist,
2003).
The
75
percentile
watershed
size
is
approximately
1,000
square
kilometers;
the
95th
percentile
value
is
approximately
40,000
square
kilometers.
In
Table
2
are
estimates
of
watershed
size,
as
described
in
the
final
report
from
this
monitoring
study,
and
as
determined
by
the
USGS/
EPA
effort.
Only
five
of
the
CWS
monitored
in
this
study
had
watersheds
smaller
than
1,000
square
kilometers.
Two
of
these
five
watersheds
fell
into
the
"
low"
carbaryl
sales
category,
based
on
Doane
usage
estimates.
Of
the
remaining
three
CWS,
one
is
located
on
a
Keuka
Lake,
a
lake
with
a
large
storage
capacity.
Another,
the
Minton
Reservoir,
has
the
second
smallest
drinking
water
watershed
in
the
United
States.
And
the
third,
Silver
Lake,
represents
a
relatively
minor
use
of
carbaryl
(
cranberries).

In
general,
CWS
with
large
watersheds
are
located
on
very
large
bodies
of
water,
and
are
not
typically
considered
as
vulnerable.
The
watersheds
of
CWS
located
on
the
Columbia
River,
Washington;
the
Sacramento
River,
CA,
and
the
California
aqueduct
intake,
which
were
selected
for
monitoring
are
larger
than
the
95th
percentile
nationally
(
40,000
square
kilometers).
The
CWS
on
in
Pasco,
WA
is
downstream
of
the
confluence
of
the
Columbia
River
with
the
Snake
River,
where
two
of
the
West's
largest
rivers
merge.
The
CWS
site
on
the
Neches
River
(
Beaumont
TX)
is
also
larger
than
the
90th
percentile
CWS
watershed
size
nationally.

The
practice
of
inter­
basin
water
transfer
makes
site
selection
difficult
in
the
West.
The
Henry
J
Mills
water
treatment
plant
in
Riverside,
CA
is
one
of
five
facilities
supplying
water
to
the
Los
Angeles
metropolitan
area
and
treats
water
from
multiple
sources.
The
water
is
derived
from
a
system
of
rivers
and
reservoirs
located
in
the
high
Sierras,
flowing
through
the
Feather
River,
and
the
Sacramento
where
it
is
withdrawn
at
the
Harvey
Banks
Filtration
Plant
to
the
South
of
San
Francisco
and
transported
hundreds
of
miles
to
the
south
to
Los
Angeles.
Riverside
County,
listed
as
the
intake
location,
is
actually
the
location
of
the
treatment
facility
and
quality
is
unaffected
by
usage
there.
Lake
Mathews,
the
water
source
for
the
City
of
Corona,
is
the
Western
terminus
of
the
Colorado
River
Aqueduct,
whose
intake
is
on
the
Colorado
River
at
Lake
Havasu,
Arizona.
Therefore,
the
water
in
Lake
Mathews
would
not
be
expected
to
be
affected
by
carbaryl
use
in
the
watershed
immediately
surrounding
the
lake.

CWS
selected
for
this
study
were
located
on
several
large
lakes,
for
example
Lake
Chelan
is
55
miles
long
and
is
the
third
deepest
lake
in
the
US.
A
small
portion
of
the
watershed
of
this
lake
is
used
in
agriculture,
however,
the
majority
of
the
watershed
drains
pristine
forest
land.
The
overall
impact
of
this
agriculture
on
the
quality
of
the
drinking
water,
given
it's
large
storage
capacity
is
difficult
to
determine,
and
maybe
locally
important
to
determine.
However,
there
are
reasonable
questions
about
it's
overall
vulnerability
and
selection
as
one
of
16
locations
nationally
in
this
monitoring
84
study.
Similarly,
Keuka
Lake
is
a
mid­
sized
Finger
Lake
in
upstate
New
York.
Formed
during
the
last
glaciation,
the
lake
has
a
relatively
large
storage
capacity
and
an
estimated
residence
time
for
pollutants
of
6­
8
years.
It
is
not
as
vulnerable
as
smaller­
sized
systems
which
more
rapidly
respond
to
environmental
effects.
The
CWS
located
on
Canyon
Lake
did
not
function
as
a
treatment
system
for
the
majority
of
the
study
due
to
low
reservoir
levels
calling
into
question
the
degree
to
which
runoff
and
carbaryl
usage
affected
water
quality
at
that
location.

It
is
clear
that
in
most
cases
there
was
some
degree
of
carbaryl
usage
in
the
watershed
and
the
results
of
the
monitoring
are
useful;
however,
the
majority
of
sites
selected
in
implementation
of
this
study
are
not
consistent
with
the
study
design
purpose
as
stated.

Watershed
sales
and
usage
and
crop
type.
Crop
data
(
from
the
1992
Census
of
Agriculture
and
a
cranberry
bog
database)
was
used
by
RPAC
in
4
states
(
New
York,
Michigan,
Washington,
and
Massachusetts)
as
a
surrogate
for
carbaryl
use
to
refine
watersheds
of
interest.
In
other
states
refinements
were
made
on
the
basis
of
discussions
with
RPAC
field
personnel
or
CWS
personnel
which
were
largely
undocumented.
Also,
information
provided
to
make
determinations
about
the
ratio
or
cropped
versus
non­
cropped
area
in
a
watershed
is
anecdotal
at
best,
derived
from
observation
of
CWS
and
RPAC
sales
personnel
implementation.
For
example,
the
CWS
on
the
Neches
River
in
Beaumont
Texas
is
characterized
as
a
high
sales
site,
based
on
RPAC
sales
data,
but
this
could
not
be
confirmed
using
Doane
usage
data,
which
indicates
usage
in
Jefferson
County
is
low
(
4300
pounds).

Representing
a
variety
of
crops
was
a
secondary
criterion
in
site
selection;
however,
the
basis
for
the
carbaryl
use
within
the
watershed
and
the
spatial
extent
of
this
use
within
the
watershed
is
not
entirely
clear.
As
another
example,
crops
in
the
watershed
of
Canyon
Lake,
the
water
source
for
the
Elsinore
Valley
MWD,
are
identified
as
citrus,
vegetables,
and
olives.
Land
Cover
information
does
not
include
these
crops,
but
does
indicate
that
"
orchard/
vineyard/
other"
constitute
0.04%
of
the
watershed;
"
row
crops"
14.2%,
"
residential
and
commercial"
7.2
%,
and
"
small
grains
2.4%.
The
USGS­
EPA
pilot
reservoir
monitoring
program
characterized
dominate
pesticide
usage
in
this
same
watershed
as
urban,
with
row
crops
dominated
by
alfalfa
and
wheat.
Actual
crops
to
which
carbaryl
is
applied
and
their
dominance
on
water
quality
in
this
watershed
is
unclear.

The
rationale
for
selection
of
sites
representing
what
appear
to
be
a
relatively
minor
percentage
of
the
overall
carbaryl
usage
(
cranberries)
is
not
clear.
The
decision
to
select
a
monitoring
site
to
characterize
exposure
from
this
use
appears
to
be
driven
more
by
the
desire
to
represent
a
broad
array
of
carbaryl
uses
than
the
high
carbaryl
sales
county
selection
criteria.
The
way
in
which
the
study
design
is
implemented
calls
into
question
the
ability
f
the
results
to
adequately
address
the
conceptual
model.
The
pasture
and
pecan
use
in
Wagoner
County,
OK
also
appears
to
have
played
a
dominant
role
in
selecting
that
site
despite
the
very
low
sales
in
that
county.
The
site
selection
report
indicates
that
a
site
was
sought
in
Oklahoma
after
a
second
site
could
not
be
identified
in
Oregon;
however
the
rationale
for
focusing
on
a
site
in
Oklahoma
is
not
provided.
There
are
other
geographic
locations
in
the
carbaryl
use
area
with
higher
sales
where
no
monitoring
site
was
selected
85
"
Home
and
Garden"
Sites:

No
analysis
has
been
done
of
the
relative
vulnerability
of
drinking
water
systems
resulting
from
the
home
and
garden
use
of
carbaryl,
because
sales
or
usage
data
for
these
sites
is
not
presented
to
enable
the
relative
vulnerability
of
these
sites
to
be
determined.
Sites
were
selected
in
different
locations
form
those
originally
identified.
Characteristics
are
presented
in
Table
3.
In
terms
of
watershed
size,
these
are
roughly
the
70th
percentile
or
slightly
higher,
according
to
the
USGS
data
(
Blomquist,
2003)

Sampling
frequency,
interval,
and
study
duration.

Some
sampling
periods
were
missed,
overall
the
implementation
of
this
design
feature
was
reasonable.
However,
the
adequacy
of
weekly
sampling
in
collecting
quality
data
to
represent
peak
exposure
values
is
unlikely
and
data
produced
have
high
uncertainty
in
representing
values
useful
for
acute
exposure
assessment.
The
study
duration
was
three
years,
as
indicated
in
the
study
design.

Sample
matrix
Samples
are
being
collected
from
raw
drinking
water
at
the
intake
and
finished
water
after
passing
through
the
treatment
plant.
All
raw
water
samples
are
being
analyzed.
Finished
water
samples
are
analyzed
when
raw
water
collected
at
the
same
time
show
detectable
concentrations
of
carbaryl.
This
design
component
was
implemented
in
reverse.
Raw
water
should
have
been
sampled
first
and
after
some
time
lag
linked
to
the
treatment
train
at
each
CWS,
the
finished
water
sampled.
Samples
cannot
be
considered
temporally
paired
and
cannot
be
use
quantitatively
to
assess
removal
efficiency.

Ancillary
data
collection
Ancillary
data
was
collected
as
described
in
the
study
design.
The
design
provides
for
the
collection
of
a
substantial
amount
of
ancillary
data.
However,
data
are
not
collected
on
an
number
of
important
factors
controlling
site
variability.
The
treatment
train
is
not
described
in
enough
detail
to
allow
quantitative
determinations
regarding
effects
on
exposure
to
be
made.

Sample
Collection
Procedure
and
Handling
Procedures
are
adequate
for
the
most
part,
with
protocol
deviations
identified.
Studies
done
on
unfortified
samples
from
Lake
Manattee
indicate
carbaryl
is
stable
in
non­
acidified
water
(
pH
6
or
higher)
under
standard
sample
handling
and
storage
conditions
(
freezing
conditions).

Fished
water
collected
prior
to
treated
water
sample
(
backwards).
There
is
no
description
of
the
timing
of
the
treatment
train.
It
may
still
be
possible
to
look
in
general
at
the
overall
data
and
make
observations
about
trends
in
levels
of
carbaryl
in
finished
versus
raw
water
based
on
these
data.
86
Chemical
Analysis
Samples
were
analyzed
before
the
maximum
allowed
time
of
99
days
with
the
exception
of
two
samples.
Deviations
from
the
protocol
were
identified;
none
significantly
affected
analytical
results.
When
a
sample
and
it's
duplicate
were
analyzed,
average
values
were
reported.
In
some
tables,
results
for
finished
water
samples
were
substituted
for
raw
samples.
Careful
interpretation
of
the
results
from
these
two
separate
water
sample
populations
(
finished
and
raw)
is
necessary.

Quality
Assurance
and
Quality
Control
The
laboratory
QA
samples
appear
to
be
adequate
for
the
purposes
of
the
study.
Clarification
is
needed
on
the
size
and
make
up
of
the
sample
set.
°
method
performance
indicated
recoveries
of
spiked
samples
101+/­
12
%.
°
All
but
one
control
were
negative.
°
Field
recovery:
72­
145
%
when
analyzed
within
6
days
of
fortification
(
field
spikes)
°
storage
stability:
non­
acidified
and
acidified
samples
showed
no
decline
in
frozen
raw
or
finished
water
up
to
14
weeks
(
98
days).

Summary:
Implementation
of
the
study
design
compromised
the
study
goal.
The
majority
of
the
agricultural
sites
monitored
do
not
appear
to
be
vulnerable
to
carbaryl
impacts,
based
on
the
sales
and
watershed
characteristics
evaluated.
Carbaryl
usage
is
likely
to
occur
in
the
watersheds
of
most
of
these
systems
and
results
can
be
evaluated
in
that
context;
however,
the
overall
vulnerability
of
these
systems
is
not
as
stated
in
the
conceptual
model
of
this
study.

Results
Monitoring
results
presented
in
Table
4
indicate
that
carbaryl
was
found
in
source
drinking
water
(
raw
water)
at
low
concentrations
in
the
majority
of
sites
(
13
of
16
sites)
selected
to
represent
impacts
from
agricultural
uses,
despite
the
relative
lack
of
vulnerability
of
these
sites.
Concentrations
measured
at
these
sites
were
low
(
roughly
2
to
31
ppt)
in
raw
water
and
generally
lower
in
treated
drinking
water.
However,
the
highest
concentrations
were
found
in
finished,
not
raw,
drinking
water
(
181
ppt).
Only
three
agricultural
sites
had
quantified
detections
(
at
levels
greater
than
the
LOQ):
Lodi,
CA
(
31
ppt,
raw);
Brockton,
MA
(
31
ppt,
raw),
and
Deerfield,
MI
(
160
ppt,
finished).
These
levels
were
observed
in
a
single
sampling
interval
(
weekly
sampling),
and
concentrations
were
lower
in
preceding
and
succeeding
samples
collected
at
those
sites.

Where
residues
were
detected,
frequency
of
detection
in
raw
water
samples
ranged
from
a
few
percent
of
total
samples
(
1­
6
%)
at
9
of
the
13
sites
to
about
20%
of
total
samples
(
14
­
21%)
at
4
sites.
Two
of
these
sites
are
on
the
Sacramento
River,
one
site
in
Florida,
and
one
site
in
Massachusetts
representing
impacts
from
use
on
cranberries.
There
is
some
correspondence
annually
with
the
timing
of
detections
at
each
site
(
that
is
they
appear
to
occur
in
the
same
season),
but
it
is
not
strong.
At
several
sites,
low­
level
concentrations
were
measured
in
weekly
samples
collected
87
over
3­
4
week
periods.
Measured
levels
are
variable
due
in
part
to
the
nature
of
the
fate
and
transport
of
carbaryl
and
in
part
to
the
noise
in
analytical
measurements
at
these
low
concentrations.
Because
treated
water
sampling
was
reactive,
frequencies
of
detection
were
not
determined.

No
carbaryl
residues
were
detected
in
raw
water
at
three
locations:
Corona
CA,
(
Lake
Mathews);
Beaumont
TX
(
Neches
River);
Manson,
WA
(
Lake
Chelan).
Lake
Mathews
actually
derives
it's
water
from
inter­
basin
transfer,
serving
as
the
western
terminus
of
the
Colorado
River
Aqueduct.
Carbaryl
usage
in
the
Colorado
River
watershed
and
Lake
Havasu,
AZ
area
(
the
aqueduct
withdrawal
point)
are
not
described,
but
expected
vulnerability
is
low.
Although
carbaryl
usage
occurs
in
the
other
two
systems,
there
are
questions
about
the
characterization
of
the
vulnerability
of
the
systems
due
to
watershed
size
and
storage.

Carbaryl
was
reported
in
raw
water
of
all
four
CWS
selected
to
represent
impacts
from
Home
and
Garden
uses.
Concentrations
measured
in
raw
water
at
these
sites
were
low
(
roughly
2
to
44
ppt)
and
detection
frequencies
ranged
from
1
­
about
20
%.
In
the
Birmngham,
AL
CWS,
concentrations
were
measured
at
levels
greater
than
the
LOQ
at
four
times
(
with
a
raw
and
finished
"
pair"
both
exceeding
the
LOQ):
(
35
ppt,
raw;
38
ppt,
raw;
32
ppt,
finished;
40
ppt,
raw;
40
ppt
raw).
At
this
site,
concentrations
of
carbaryl
were
detected
in
sequential
weekly
samples
for
several
months
in
one
year
(
out
of
three
years)
of
monitoring.
The
pattern
of
detections
was
not
as
strong
in
other
years.
How
representative
these
systems
are
of
the
home
and
garden
use
of
carbaryl
cannot
be
determined
from
the
data
provided.
The
lowest
detection
frequency
occurred
at
the
CWS
with
the
largest
watershed
size
(
exceeding
the
70th
percentile
nationally).

The
data
do
not
give
any
indication
of
the
effectiveness
of
treatment
in
removing
carbaryl.
Because
the
samples
were
collected
at
the
same
time
the
water
exiting
the
treatment
plant
was
temporally
different
than
the
water
sampled
at
the
intake.
In
several
cases
finished
water
had
higher
concentrations
then
raw
water,
and
finished
water
had
detectable
carbaryl
when
the
raw
water
did
not.
The
highest
concentration
measured
was
in
finished
water
(
0.18
ppb).
Raw
water
sampled
at
the
same
time
had
much
lower
concentration
(
0.011).
This
illustrates
that
carbaryl
contamination
is
transient,
and
that
it
is
unlikely
that
weekly
or
monthly
sampling
are
adequate
to
capture
actual
peak
concentrations
REFERENCES
USEPA,
2000,
Consultation:
National
Drinking
Water
Survey
Design
for
Assessing
Chronic
Exposure.
6/
6­
9/
2000,
http://
www.
epa.
gov/
scipoly/
sap/
2000/
june/
drinkingwatersurvey.
pdf
USEPA
2002a,
"
Response
to
Registrant's
30­
day
Error
Correction
Comments
on
the
EFED
Risk
Assessment
Chapter
in
Support
of
the
Reregistration
Eligibility
Decision
(
RED)
on
Carbaryl",
D276945,
dated
4/
8/
2002.

USEPA,
2002b,
"
Revised
EFED
Risk
Assessment
of
Carbaryl
in
Support
of
the
Reregistration
Eligibility
Decision
(
RED)"
Dated
8/
17/
2002.
EPA
document
ID:
OPP­
2002­
0138­
0012.
88
http://
www.
epa.
gov/
oppsrrd1/
reregistration/
carbaryl/,
accessed
01/
03/
03
Bayer
CropScience,
2002,
"
Review
of
the
Draft
Environmental
Fate
and
Ecological
Risk
Assessment
for
the
Registration
of
Carbaryl.
dated
October
2002.
Submitted
to
the
docket
OPP­
2002­
0138
during
public
comment
period.

USEPA,
2001,
review
of:
"
Surface
Water
Monitoring
for
Residue
of
Carbaryl
in
High
Use
Areas
in
the
United
States:
Interim
Study
Results",
D274824,
dated
August
7,
2001,
Internal
Memorandum
to
Betty
Shackleford,
SRRD.

Blomquist
J.
D.
et.
al.,
2001,
Pesticides
in
Selected
Water­
Supply
Reservoirs
and
Finished
Drinking
Water,
1999­
2000:
Summary
of
Results
from
a
Pilot
Monitoring
Program,
USGS
Open
File
Report
01­
456,
http://
md.
water.
usgs.
gov/
nawqa/
accessed
3/
1/
03
J.
D.
Blomquist,
2003,
personal
communication
regarding
national
distribution
of
community
water
supply
system
watershed
size.
89
APPENDIX
B2.
SUPPLEMENTAL
TABLES
IN
SUPPORT
OF
DRINKING
WATER
MONITORING
STUDY
ANALYSES.

Table
2:
Characteristics
of
Agricultural
Monitoring
Sites
selected
for
Carbaryl
Monitoring
Study.

intake
location
(
city
and
state)
system
name
watershed
location
(
SEI
#)
carbaryl
use
crop
carbaryl
sales
(
RPAC)
carbaryl
use
(
lbs
per
county),

based
on
Doane
source
water
volume
of
waterbody
watershed
size
Aventis
(
acres)
EFED
(
square
km)

Lake
Elsinore,

CA
Elsinore
Valley
MWD
Riverside
Co
(
CA­
12­
LE­
CB)

San
Jacinto
river?
citrus
vegetables
olives
(
urban;
alfalfa)
high
47833
Railroad
Canyon
Reservoir
(
Canyon
Lake)
11,867
acre­
ft
Small
445,551
1720
(
Oak
Ridge)

Corona,
CA
City
of
Corona
Riverside
Co
(
CA­
16­
CO­
CB)

(
actually,
Colorado
River)
citrus
vegetables
olives
high
47833
Lake
Mathews
(
Colorado
River
aquaduct)
182,000
acre
ft
Small
16,350s
inter­
basin
transfer
watershed
is
Colorado
River
upstream
from
Lake
Havasu
Lodi,
CA
Little
Potato
Slough
Mutual
San
Joachin,
Co
(
CA­
25­
ST­
CB)
tree
nuts,

stone
fruit
high
23896
Little
Potato
Slough
­­­
Medium
1,319,214
5341
(
Aventis)

West
Sacramento,

CA
City
of
West
Sacramento
Yolo,
Co
(
CA­
37­
WS­
CB)
tree
nuts,

stone
fruit
(
orchard:

2.7%
watershed)
high
13065
Sacramento
River
­­­
Medium
14,301,323
57,895
(
Aventis)

Sacramento,

CA
(
aka
Riverside,

CA
CA
aquaduct
Harvy
O
Banks
Filtration
Plant
(
State
Water
Project)
multiple
counties
from
Lake
Shasta
to
Sacramento
Delta
tree
nuts,

stone
fruit
high
cannot
be
estimated
Origin
in
high
Sierras,
Feather
River,
Sacramento
River
and
Delta.
2,700,000
acre­
ft
storage
in
Oroville
dam.
California
aquaduct
capacity:

2
billion
gallons
per
day
Very
large
27,826,575
112,651
(
Aventis)

Bradenton,
FL
Manatee
Co.

Water
Treatment
Plant
Manatee
Co.

(
FL­
2­
BR­
CB)
citrus,
vegetables
medium
3200
Lake
Manatee
(
impoundment
of
Little
Manattee
R)
32,500
acre­
ft
(
est)
Small
90,609
300
(
Oak
Ridge)

Brockton,
MA
Brockton
Water
Treatment
Plant
Plymouth,
MA
(
MA­
7­
BR­
CB)
cranberries
medium
8318
Silver
Lake
1100
acre
ft
(
est.)
Small
2,620
10.6
(
Aventis)
intake
location
(
city
and
state)
system
name
watershed
location
(
SEI
#)
carbaryl
use
crop
carbaryl
sales
(
RPAC)
carbaryl
use
(
lbs
per
county),

based
on
Doane
source
water
volume
of
waterbody
watershed
size
Aventis
(
acres)
EFED
(
square
km)

90
Deerfield,
MI
Village
of
Deerfield
Lenawee
Co.

(
MI­
4­
DE­
CB)
potatoes,

apples,
vegetables,

corn
medium
1500
River
Raisin
­­­
Medium
453,648
1,575
(
Oak
Ridge)

Westfield,
NY
Village
of
Westfield
Chatauqua
Co.

(
NY­
13­
WE­
CB)
grapes
high
29,901
Minton
Reservoir
(
90%)
10.7
acre­
ft
Small
502
0.005
(
Oak
Ridge)

Aventis
400
times
Oak
Ridge
Penn
Yan,
NY
Penn
Yan
Village
Yates,
Co.

(
NY­
3­
PY­
CB)
grapes,

apples
medium
9553
Keuka
Lake
1,162,157
acre­
ft
(
1)
Medium:

123,536
438
(
Oak
Ridge)

Coweta,
OK
Wagoner
Rural
Water
District
#
5
Wagoner
Co.

(
OK­
11­
WR­
CB)
Pecans,

pasture
high
1850
Verdigris
River
oxbow
of
Verdegris
R
large
(
tributary
to
Arkansas
river)
small
31800
medium
5,162,475
129
20,900
(
Aventis)

Jefferson,
OR
City
of
Jefferson
Marion
Co.

(
OR­
3­
JE­
CB)
vegetables
high
16718
Santiam
River
(
Willamette
Valley)
Medium:
1,140,819
4,620
(
Oak
Ridge)

Point
Comfort,

TX
City
of
Point
Comfort
Calhoun
Co.

(
TX­
2­
PC­
CB)
rice,
pasture,

tree
nuts
high
900
Lake
Texana
(
Navidad
River
impoundment)
165,900
acre­
ft
Medium:

886,462
3,345
(
Oak
Ridge)

Beaumont,
TX
City
of
Beaumont
Water
Utility
Department
Jefferson
Co.

(
TX­
3­
BE­
CB)
rice,
pasture,

tree
nuts
(
largely
undevelope
d)
high
4300
Neches
River
­­­
Medium:
5,819,700
25,178
(
Oak
Ridge)

Manson,
WA
Lake
Chelan
reclaimation
District
Chelan
Co.

(
WA­
13­
LC­
CB)
apples
high
16898
Lake
Chelan
15,800,000
acre­
ft
Medium:

558,885
2,384
(
Aventis)
intake
location
(
city
and
state)
system
name
watershed
location
(
SEI
#)
carbaryl
use
crop
carbaryl
sales
(
RPAC)
carbaryl
use
(
lbs
per
county),

based
on
Doane
source
water
volume
of
waterbody
watershed
size
Aventis
(
acres)
EFED
(
square
km)

91
Pasco,
WA
City
of
Pasco
Franklin,
Co
(
WA­
7­
PA­
CB)
apples,
potatoes
high
13122
Columbia
River
(
downstream
of
confluence
w/
Snake
R)
large
65,994,684
267,168
(
Aventis)

(
1)
from
NY
state
Depart
of
Environmental
Conservation,
2001,
Finger
Lakes
Synoptic
Water
Quality
Study,
http://
www.
dec.
state.
ny.
us/
website/
dow/
fingerlakes/
chapter2.
pdf,
accessed
3/
13/
03.

Table
3:
Characteristics
of
Home
and
Garden
Monitoring
Sites
selected
for
Carbaryl
Monitoring
Study.

intake
location
(
city
and
state)
system
name
watershed
location
(
SEI
#)
source
watershed
size
home
and
garden
sales
(
RPAC)
county
ag
sales
in
pounds
(
Doane)

Aventis
(
Acres)
EFED
(
square
km)

Birmingham,
AL
Shades
Mt.
Filter
Plant
Jefferson
Co.

(
AL­
1­
B1­
CB)
Cahaba
River/

Lake
Purdy
Small
125,703
509
(
Aventis)
N/
A
45
East
Point,
GA
East
Point
Water
Treatment
Plant
Fulton
Co.

(
GA­
1­
EP­
CB)
Sweetwater
Creek
Small
170,007
682
(
Oak
Ridge)
N/
A
20
Cary,
NC
Town
of
Cary
Water
Treatment
Plant
Wake
Co.

(
NC­
3­­
CA­
CB)
Jordan
Lake
Reservoir
Medium:

188,618
3455
(
Oak
Ridge)
N/
A
2100
Oak
ridge
4
times
Aventis
Midlothian,
TX
City
of
Midlothian,
Ellis
Co.

(
TX­
30­
MI­
CB)
Joe
Pool
Lake
Small
147,667
313
(
Oak
Ridge)
N/
A
4600
Aventis
2
times
Oak
Ridge
92
Table
4.
Results
of
Sampling
at
all
Community
Water
Supply
System
Locations
(
Agricultural
and
Home
and
Garden)

Site
type
intake
location
(
city
and
state)
source
detection
frequesny
(
raw
only)
year
months
with
detections
(
1
=
January)
Raw
Water
Results
Finished
Water
Results
#
detects
raw
Conc.

(
ppt)
#
detects
finished
Conc.

(
ppt)

A
Lake
Elsinore,

CA
Railroad
Canyon
Reservoir
(
aka
Canyon
Lake)
3%
123
2
 
3
­
6
201
2
 
3
(?)

­
6
(?)
NA
­
ND
A
Corona,
CA
Lake
Mathews
(
Colorado
River)
not
detected
123
­­­
ND
A
Lodi,
CA
Little
Potato
Slough
21%
123
5
 
12
2
 
9
4
­
12
6
12
4
2.38
 
12.48
2.18
 
30.55
2.3
 
4.1
240
2.09
­
3.44
3.63
 
6.66
­

A
West
Sacramento,

CA
(
Yolo)
Sacramento
River
14%
123
6
­
8
4
­
12
3
­
8
284
2.33
 
3.22
2.54
 
24.44
2.09
 
14.4
132
2.86
8.34
 
9.91
2.19
 
9.32
A
Henry
O
Banks
Filtration
Plant,

Sacramento,
CA
(
aka
Riverside
CA)
State
Water
Project
CA
Aquaduct
Feather
and
Sacramento
Rivers
1%
123
­

2­
­

1­
­

8­
Not
detected
A
Bradenton,
FL
Lake
Manatee
14%
123
7­
10
8­
9
7­
10
72
13
2.48
­
8.95
2.15
 
2.73
2.04
 
24.58
209
6.12
 
10.54
­­
2.72
 
19.04
A
Brockton,
MA
Silver
Lake
17%
123
6,
7
8­
10
3,
4
572
2.12
 
31.4
2.2
 
26.6
2.67
 
4.64
010
­
3.37
­

A
Deerfield,
MI
River
Raisin
4%
123
697
111
8.01
 
12.26
3.7
21.94
201
4.31
 
180.7
­
4.43
A
Westfield,
NY
Minton
Reservoir
6%
123
6,
8
7­
32­
2.4
 
20.58
3.94
 
5.24
­
­

1­
­
8.64
­

A
Penn
Yan,
NY
Keuka
Lake
1%
123
­

1­
­

8­
­
22.82
­
Not
detected
A
Coweta,
OK
Verdigris
River
4%
123
9
 
12
2­
310
2.09
 
3.6
2.94
­
Not
detected
A
Jefferson,
OR
Santiam
River
12
­
8
­
1
­
9.99
Not
detected
93
2%
3
9
1
3.58
A
Point
Comfort,

TX
Lake
Texana
3%
123
­
1,12
1
­

21
­
4.54
 
17.51
3.05
­­­
Not
detected
A
Beaumont,
TX
Neches
River
Not
detected
123
­­­
Not
detected
A
Manson,
WA
Lake
Chelan
Not
detected
123
Not
detected
A
Pasco,
WA
Columbia
(
downstream
of
confluence
of
Snake
River)
3%
123
5,10
6­
21­
2.19
 
2.76
2.71
­
Not
detected
H&
G
Birmingham,
AL
Cahaba
River/
Lake
Purdy
19%
1234
5­
12
1­
11
4­
11
4
10
8
12
1
2.41­
23.25
3.01
­
35.48
2.85
­
44.41
3.03
0080
­­
2.85
­
31.99
­

H&
G
East
Point,
GA
Sweetwater
Creek
19%
123
5­
12
1­
12
1­
10
10
12
8
2.01
­
17.56
2.15
­
17.64
2.96
­
12.52
110
2.90
7.61
­

H&
G
Cary,
NC
Jordan
Lake
Reservoir
1%
123
10
­­
2­­
3.21
­
3.89
­­
Not
detected
H&
G
Midlothian,
TX
Joe
Pool
Lake
6%
123
4­
6­
8
1­
9
13.2
­
14.9
­
2.94
­
13.69
Not
detected
94
APPENDIX
C.
SPREADSHEET­
BASED
TERRESTRIAL
EXPOSURE
VALUES
A
first­
order
decay
assumption
is
used
to
determine
the
concentration
at
each
day
after
initial
application
based
on
the
concentration
resulting
from
the
initial
and
additional
applications.
The
decay
is
calculated
from
the
first
order
rate
equation:

CT
=
Cie­
kT
or
in
log­
transformed
form:
ln
(
CT/
Ci)
=
­
kT
Where:
CT
=
concentration
at
time
T
Ci
=
concentration
in
parts
per
million
(
ppm)
present
initially
(
on
day
zero)
on
the
surfaces.
Ci
is
calculated
based
on
Kenaga
and
Fletcher
by
multiplying
the
application
rate,
in
pounds
active
ingredient
per
acre,
by
240
for
short
grass,
110
for
tall
grass,
and
135
for
broad­
leaf
plants/
insects
and
15
for
seeds.
Additional
applications
are
converted
from
pounds
active
ingredient
per
acre
to
parts
per
million
(
PPM)
on
the
plant
surface
and
the
additional
mass
added
to
the
mass
of
the
chemical
still
present
on
the
surfaces
on
the
day
of
application.

k=
degradation
rate
constant
determined
from
studies
of
hydrolysis,
photolysis,
microbial
degradation,
etc.
Since
degradation
rate
is
generally
reported
in
terms
of
half­
life,
the
rate
constant
is
calculated
from
the
input
half­
life
(
k
=
ln
2/
t
½
)
instead
of
being
input
directly.
Choosing
which
process
controls
the
degradation
rate
and
which
half­
life
to
use
in
terrestrial
exposure
calculations
is
open
for
debate
and
should
be
done
by
a
qualified
scientist.

T=
time,
in
days,
since
the
start
of
the
simulation.
The
initial
application
is
on
day
0.
The
simulation
is
set
to
run
for
365
days.

The
program
calculates
concentration
on
each
type
of
surface
on
a
daily
interval
for
one
year.
The
maximum
concentration
during
the
year
and
the
average
concentration
during
the
first
56
days
are
calculated.
95
Chemical
Name:
Carbaryl
Use
Grasshoppers
Formulation
Inputs
Application
Rate
0.25
lbs
a.
i./
acre
Half­
life
3.708
days
Frequency
of
Application
days
Maximum
#
Apps./
Year
1
Outputs
Maximum
56
day
Average
Concentration
Concentration
(
PPM)
(
PPM)
Short
Grass
60.00
6.28
Tall
Grass
27.50
2.88
#
days
Broadleaf
plants/
Insects
33.75
3.53
Exceeded
Seeds
3.75
0.39
on
short
grass
(
in
first
56)
Avian
Acute
LC50
(
ppm)
5000
0
Chronic
NOAEC
(
ppm)
300
0
Max
Single
Application
which
does
NOT
exceed
Acute
RQ
Chronic
RQ
Avian
Acute
20.833
(
Max.
res.
mult.
apps.)
Avian
Chronic
1.250
(
lb
a.
i.)
Short
Grass
0.01
0.20
Tall
Grass
0.01
0.09
#
days
Mammalian
Acute
8.36
Broadleaf
plants/
Insects
0.01
0.11
Exceeded
Mammalian
Chronic
0.31
Seeds
0.00
0.01
on
short
grass
(
in
first
56)
Mammalian
Acute
LD50
(
mg/
kg)
301
0
Rat
Calculated
LC50
(
ppm)
6020
Chronic
NOAEL
(
mg/
kg)
75
0
15
g
mammal
35
g
mammal
1000
g
mammal
Rat
Acute
Rat
Chronic
Acute
RQ
Acute
RQ
Acute
RQ
Dietary
Dietary
(
mult.
apps)
(
mult.
apps)
(
mult.
apps)
RQ
RQ
Short
Grass
0.19
0.13
0.03
0.01
0.80
Broadleaf
plants/
insects
0.09
0.06
0.01
0.00
0.37
Large
Insects
0.11
0.07
0.02
0.01
0.45
Seeds
(
granivore)
0.00
0.00
0.00
0.00
0.05
Length
of
Simulation
1
year
Level
of
Concern
(
ppm)
Terresterial
Application
Residues
0
10
20
30
40
50
60
70
0
4
8
12
16
20
24
28
32
36
40
44
48
52
Days
Concentration
(
PPM)
Short
Grass
Tall
Grass
Broadleaf
plants/
Insect
s
Seeds
Terrestrial
Exposure
Model
Output
96
Chemical
Name:
Carbaryl
Use
Grasshoppers
Formulation
Inputs
Application
Rate
0.5
lbs
a.
i./
acre
Half­
life
3.708
days
Frequency
of
Application
days
Maximum
#
Apps./
Year
1
Outputs
Maximum
56
day
Average
Concentration
Concentration
(
PPM)
(
PPM)
Short
Grass
120.00
12.57
Tall
Grass
55.00
5.76
#
days
Broadleaf
plants/
Insects
67.50
7.07
Exceeded
Seeds
7.50
0.79
on
short
grass
(
in
first
56)
Avian
Acute
LC50
(
ppm)
5000
0
Chronic
NOAEC
(
ppm)
300
0
Max
Single
Application
which
does
NOT
exceed
Acute
RQ
Chronic
RQ
Avian
Acute
20.833
(
Max.
res.
mult.
apps.)
Avian
Chronic
1.250
(
lb
a.
i.)
Short
Grass
0.02
0.40
Tall
Grass
0.01
0.18
#
days
Mammalian
Acute
8.36
Broadleaf
plants/
Insects
0.01
0.23
Exceeded
Mammalian
Chronic
0.31
Seeds
0.00
0.03
on
short
grass
(
in
first
56)
Mammalian
Acute
LD50
(
mg/
kg)
301
0
Rat
Calculated
LC50
(
ppm)
6020
Chronic
NOAEL
(
mg/
kg)
75
3
15
g
mammal
35
g
mammal
1000
g
mammal
Rat
Acute
Rat
Chronic
Acute
RQ
Acute
RQ
Acute
RQ
Dietary
Dietary
(
mult.
apps)
(
mult.
apps)
(
mult.
apps)
RQ
RQ
Short
Grass
0.38
0.26
0.06
0.02
1.60
Broadleaf
plants/
insects
0.17
0.12
0.03
0.01
0.73
Large
Insects
0.21
0.15
0.03
0.01
0.90
Seeds
(
granivore)
0.01
0.00
0.00
0.00
0.10
Length
of
Simulation
1
year
Terresterial
Application
Residues
0
20
40
60
80
100
120
140
0
4
8
12
16
20
24
28
32
36
40
44
48
52
Days
Concentration
(
PPM)
Short
Grass
Tall
Grass
Broadleaf
plants/
Insect
s
Seeds
97
APPENDIX
D1:
ECOLOGICAL
EFFECTS
ASSESSMENT
Toxicity
testing
reported
in
this
section
is
not
representative
of
the
wide
diversity
of
terrestrial
and
aquatic
organisms
in
the
United
States.
Two
surrogate
bird
species,
the
bobwhite
quail
and
the
mallard
duck,
are
used
to
represent
the
680+
species
of
birds
found
in
this
country.
For
mammals,
acute
studies
are
usually
limited
to
the
Norway
rat
or
the
house
mouse.
Reptiles
are
not
tested,
as
these
are
assumed
to
be
subject
to
similar
toxicological
effects
as
birds.
Of
approximately
100,000
species
of
insects,
spiders,
and
other
terrestrial
arthropods,
toxicity
tests
are
usually
required
only
for
the
honey
bee.
Only
two
surrogate
fish
species
(
rainbow
trout
and
bluegill
sunfish)
are
used
to
represent
the
over
2,000
species
of
freshwater
fish
found
in
this
country.
Amphibians
are
not
tested,
as
these
are
assumed
to
be
subject
to
similar
toxicological
effects
as
fish.
One
crustacean,
the
water
flea,
is
used
to
represent
all
freshwater
invertebrates.
Estuarine/
marine
animal
acute
toxicity
testing
is
usually
limited
to
a
crustacean,
a
mollusk,
and
a
fish.

Toxicity
to
Terrestrial
Animals
Birds,
Acute
and
Subacute
Toxicity
Based
on
two
core
studies
of
Mallard
ducks
(
Anas
platyrhynchos),
carbaryl
is
practically
nontoxic
(
LD50
>
2000
mg/
Kg)
to
birds
on
an
acute
exposure
basis
(
Table
1).
While
less
reliable
data
suggested
that
carbaryl
may
be
moderately
toxic
to
ring­
necked
pheasants
(
LD50
=
707
mg/
Kg)
and
red­
winged
blackbirds
(
LD50
=
56.2
mg/
Kg;
Schafer
et
al.,
1983)
and
highly
toxic
(
LD50
=
16.2
mg/
Kg)
to
starlings
(
Schafer
et
al.,
1983),
these
data
are
based
on
simple
screening
tests,
and
are
therefore
not
reliable
for
risk
assessment
purposes.
However,
these
data
do
suggest
that
passerine
birds
may
be
significantly
more
sensitive
to
carbaryl
exposure
than
non­
passerine
birds.
The
registrant
is
strongly
encouraged
to
submit
acute
oral
toxicity
tests
with
passerine
avian
species.
The
guideline
71­
1
is
fulfilled
(
MRID
00160000;
458206­
01).
98
Table
1.
Summary
of
avian
acute
oral
toxicity
in
mg/
kg
(
ppm)
of
technical
grade
carbaryl
Species
%
ai
LD50
(
mg/
kg)
Toxicity
Category
MRID
No.
Author/
Year
Study
Classification1
Mallard
Duck
(
Anas
platyrhynchos)
85
>
2,564
Practically
non­
toxic
00160000
Hudson
et
al.
(
1984)
Core
Mallard
Duck
99.1%
>
2,000
Practically
non­
toxic
458206­
01
Ensenbach
Core
Canada
Goose
Branta
canadensis
50
1,790
Slightly
toxic
00160000
Hudson
et
al.
(
1984)
Supplemental
Ring­
necked
Pheasant
male
(
Phasianus
colchicus)
95
>
2,000
Practically
non­
toxic
00160000
Hudson
et
al.
(
1984)
Supplemental
Ring­
necked
Pheasant
female
(
Phasianus
colchicus)
480g/
L
707
Moderately
toxic
00160000
Hudson
et
al.
(
1984)
Supplemental
Sharp­
tailed
grouse
Tympanuchus
phasianellus
85
<
1000
Slightly
toxic
00160000
Hudson
et
al.
(
1984)
Supplemental
California
quail
Lophortyx
californicus
480
g/
L
>
2000
Practically
non­
toxic
00160000
Hudson
et
al.
(
1984)
Supplemental
Rock
Dove
(
Columba
livia)
85
1,000
­
30002
Slightly
toxic
to
Practically
non­
toxic
00160000
Hudson
et
al.
(
1984)
Supplemental
1
Core
study
satisfies
guideline
requirements.
Supplemental
study
is
scientifically
sound,
but
does
not
satisfy
guidelines.

2
95%
confidence
interval
Two
subacute
dietary
studies
using
the
TGAI
are
required
to
establish
the
toxicity
of
carbaryl
to
birds.
The
preferred
test
species
are
mallard
duck
and
bobwhite
quail.
Results
of
these
tests
are
summarized
in
Table
2.
The
LC50
is
higher
than
5000
mg/
kg
(
ppm)
of
diet
for
both
species.
Therefore,
carbaryl
is
categorized
as
practically
nontoxic
to
avian
species
on
a
subacute
dietary
exposure
basis.
An
LC50
greater
than
10,000
ppm
has
been
reported
by
Hill
and
Camardese
(
1986),
confirming
that
carbaryl's
low
toxicity
to
birds
on
a
subacute,
dietary
basis.
The
guideline
71­
2
is
fulfilled
(
MRID
00028757,
00022923).

Table
2
:
Summary
of
avian
subacute
dietary
toxicity
in
mg/
Kg
of
diet
(
ppm)
for
technical
grade
carbaryl
Species
%
ai
5­
Day
LC50
(
ppm)
Toxicity
Category
MRID
No.
Author/
Year
Study
Classification
Ring­
necked
Pheasant
(
Phasianus
calchicus)
99.8
>
5,000
practically
non­
toxic
00028757
Hill
et
al.
(
1975)
Core
Northern
bobwhite
Quail
(
Colinus
virginianus)
99.8
>
5,000
Practically
non­
toxic
00028757
Hill
et
al.
(
1975)
Core
Japanese
Quail
(
Coturnix
japonica)
99.8.
>
5,000
Practically
non­
toxic
00022923
Hill
et
al.
(
1975)
Supplemental
Mallard
Duck
(
Anas
platyrhynchos)
99.8
>
5000
Practically
non­
toxic
00022923
Hill
et
al.
(
1975)
Core
99
Incidents
Involving
Birds
According
to
the
Ecological
Incident
Information
System
(
EIIS)
database
summarizing
6(
a)
2
incident
reports,
bird
kills
have
been
attributed
to
carbaryl
and
have
involved
"
blackbirds",
starlings,
grackles,
Mallard
ducks,
Canadian
geese
and
a
morning
dove
in
New
York,
South
Carolina,
Virginia,
Michigan
and
New
Jersey
(#
I002048­
001,
#
I000802­
001,
#
I007720­
020,
#
I004375­
004).
However,
two
of
the
incidents
appear
to
be
attributed
to
the
registered
use
of
carbaryl.
In
incident
#
I007720­
020
involving
10
Mallard
ducks
both
carbaryl
and
bendiocarb
were
detected
in
bird
stomach
contents;
bendiocarb
is
very
highly
toxic
(
LD50
=
3.1
mg/
Kg)
to
birds
an
is
more
likely
the
cause
of
this
incident.

In
incident
#
I004375­
004,
18
Canadian
Geese
(
Branta
canadensis)
were
reported
killed;
necropsy
of
4
birds
indicated
that
diazinon
was
present
in
the
highest
concentration
in
each
of
the
birds
with
minor
amounts
of
lindane
and
carbaryl.
Diazinon
is
very
highly
toxic
(
LD50
=
6.16
mg/
kg)
to
Canadian
geese
and
is
therefore
the
most
likely
cause
of
this
incident.

In
incident
I002048­
001,
one
common
grackle
and
five
European
starlings
(
Sturnus
vulgaris)
were
found
dead.
Pooled
stomach
contents
showed
carbaryl
at
17
ppm;
however,
brain
cholinesterase
levels
were
normal.
In
what
appears
to
be
a
follow­
up
report
(
I004169­
094),
corn
kernels
were
strewn
around
the
base
of
the
incident
site
suggesting
that
there
was
an
intentional
poisoning
of
the
birds.

Incident
I012817­
001
involved
a
single
morning
dove
(
Zenaida
macroura)
with
2.4
ppm
carbaryl
in
its
stomach
contents
and
acetylcholinesterase
activity
was
reduced.
The
report
suggests
that
the
birdseed
from
a
feeder
may
have
been
contaminated
when
carbaryl
was
applied
to
the
property
owner's
lawn.

In
incident
I000802­
001,
five
blackbirds
were
discovered
dead;
stomach
contents
from
a
single
squirrel
also
found
dead
on
the
farm
property
showed
carbaryl
residues;
however,
acetylcholine
esterase
activity
was
not
reduced.

Based
on
these
incident
reports,
only
two
appear
to
be
clearly
attributed
to
carbaryl
and
not
due
to
misuse
or
the
presence
of
some
other
chemical.
However,
only
one
incident
involving
the
morning
dove
is
attributed
to
a
particular
registered
use
or
carbaryl.
Additionally,
based
on
the
reported
carbaryl
residues,
it
is
unclear
how
the
chemical
could
have
inflicted
mortality
given
that
carbaryl
is
practically
nontoxic
to
birds
on
both
an
acute
and
subacute
exposure
basis.
These
incidents
however
underscore
the
uncertainty
whether
passerine
birds
are
more
sensitive
to
the
effects
of
carbaryl
than
current
surrogate
test
species
results
indicate.

Birds,
Chronic
Toxicity
Exposure
to
carbaryl
at
levels
equal
to
or
greater
than
300
mg/
kg
of
diet
(
ppm)
in
the
mallard
duck
results
in
adverse
reproductive
effects,
such
as
decreased
number
of
eggs
produced,
increased
number
100
of
cracked
eggs,
and
decreased
fertility
(
Table
3).
Guideline
71­
4
is
fulfilled
(
ACC263701;
MRID
00160044).

Table
3.
Summary
of
avian
reproduction
toxicity
in
mg/
Kg
of
diet
(
ppm)
for
technical
grade
carbaryl
Species
%
ai
NOAEC
(
ppm)
LOAC
Endpoints
MRID.
No.
Author/
Year
Study
Classification
Northern
bobwhite
Quail
(
Colinus
virginianus)
99.9
>
3,000
N/
A
00160044
Fletcher
(
1986)
Core
Mallard
Duck
(
Anas
platyrhynchos)
99.9
300
Number
of
eggs
produced
ACC263701
Fletcher
(
1986)
Core
Mammals,
Acute
and
Chronic
As
shown
in
Table
4,
carbaryl
is
categorized
as
moderately
toxic
to
small
mammals
on
an
acute
oral
basis
(
LD50
=
301
mg/
kg).
In
a
two­
generation
rat
reproduction
study
(
MRID
454481­
01)
the
LOAEL
for
reproductive
toxicity
could
not
be
established
because
no
effects
were
observed
at
any
does
level;
therefore
the
NOAEL
is
1500
ppm;
however,
the
LOAEL
for
offspring
toxicity
was
300
ppm
based
on
increased
number
of
second
generation
offspring
with
no
milk
in
the
stomach
and
decreased
pup
survival.
The
NOAEL
is
75
ppm.

Table
4.
Summary
of
mammalian
toxicity
for
technical
grade
carbaryl
Species
%
ai
Test
Type
Toxicity
Value
Affected
Endpoints
MRID
No.

Laboratory
Rat
(
Rattus
norvegicus)
99.0%
Acute
oral
LD50
=
301.0
mg/
kg
Morbidity
00148500
Laboratory
Rat
(
Rattus
norvegicus)
99.1%
2­
generation
Rate
Reproduction
NOAEC/
LOAEC
75
/
300
ppm
Decreased
pup
survival
44732901
Incidents
Involving
Mammals
Incidents
involving
small
mammal
kills
have
been
recorded
in
South
Carolina
and
Virginia.
In
incident
I000802­
001,
stomach
contents
from
a
gray
squirrel
(
Sciurus
carolinensin)
were
found
to
have
"
significant"
amount
of
carbaryl;
however,
brain
acetylcholine
activity
was
not
"
significantly
depressed.".

In
the
second
incident
involving
carbaryl,
a
hairytail
mole
(
Parascalops
breweri)
was
found
to
have
6
ppm
carbaryl
in
its
viscera.
No
information
was
provided
on
how
the
animal
may
have
come
in
contact
with
the
pesticide.

Based
on
these
incident
reports,
it
is
not
possible
to
determine
what
use
of
carbaryl
was
associated
with
these
deaths.
However,
carbaryl
is
moderately
toxic
to
mammals
(
LD50
=
301
mg/
Kg)
to
rodents
on
an
acute
exposure
basis.
101
Insect
Toxicity
Technical
carbaryl
is
categorized
as
highly
toxic
to
bees
on
an
acute
contact
basis
(
Table
5).
Guideline
141­
1
is
fulfilled
(
MRID
00036935,
05001991,
05004151).
More
recent
studies
with
technical
grade
carbaryl
(
purity
99.1%)
indicate
roughly
similar
acute
oral
toxicity
(
LC50
=
0.23
:
g/
bee).
Although
a
more
recent
contact
toxicity
study
of
technical
grade
carbaryl
was
undertaken
(
MRID
457854­
04),
the
study
was
classified
as
invalid
since
it
relied
on
dimethylsulfoxide
(
DMSO)
as
a
co­
solvent;
EPA
recommends
against
the
used
of
DMSO
as
a
solvent
due
to
the
extent
to
which
this
solvent
can
impact
cell
membranes
and
hence
the
uptake
and
distribution
of
chemicals.
Acute
oral
toxicity
testing
with
the
soluble
concentrate
(
Carbaryl
SC)
indicates
that
the
formulated
product
is
roughly
an
order
of
magnitude
less
toxic
(
LC50
=
1.57
:
g/
bee)
than
the
technical
grade.
Acute
contact
toxicity
with
the
soluble
concentrate
also
showed
reduced
toxicity
(
LD50
=
4.02
:
g/
bee)
compared
to
the
technical
grade.

Table
5.
Summary
of
honey
bee
acute
contact
(
LD50
in
:
g/
bee)
and
acute
oral
(
LC50
in
:
g/
bee)
toxicity
for
technical
grade
carbaryl
Species
%
ai
Contact
LD50
(
µ
g/
bee)
Oral
LC50
(
µ
g/
bee)
Toxicity
Category
MRID
No.
Author/
Year
Study
Classification
Honey
Bee
(
Apis
mellifera)
tech.
1.3
0.14
Highly
toxic
05001991
Stevenson
(
1978)
Core
Honey
Bee
(
Apis
mellifera)
tech
2.0
­­­
Highly
toxic
00036935
Atkins
et
al.
(
1975)
Core
Honey
Bee
(
Apis
mellifera)
tech
1.1
0.11
Highly
toxic
05004151
Stevenson
(
1968)
Core
Honey
Bee
(
Apis
mellifera)
99.1
­­
0.231
­­
457854­
03
Waltersdorfer
(
2002)
Supplemental
Honey
Bee
(
Apis
mellifera)
479
g/
L
­­
1.57
­­
457854­
06
Waltersdorfer
(
2002)
Supplemental
Honey
Bee
(
Apis
mellifera)
479
g/
L
4.02
­­
moderately
toxic
457854­
07
Waltersdorfer
(
2002)
Supplemental
The
topical
LD50
for
alfalfa
leaf­
cutter
bee
(
Megachile
pacifica
=
M.
rotundata)
=
262.4
µ
g/
g
(
05015678)
(
Lee
&
Brindley
1974).
However,
exposing
leaf­
cutter
bees
(
Megachilidae),
alkali
bees
(
Halictidae),
and
honey
bees
(
Apidae)
to
24­
hr
residues
from
80%
WP
carbaryl
applied
at
the
rate
of
1
lb/
acre
resulted,
respectively,
in
a
85%,
78%,
and
69%
mortality
rate
(
Johansen
1972)
(
ID
#
05000837).
Some
carbaryl
formulations
can
be
highly
toxic
to
bees
exposed
to
direct
application,
i.
e.,
when
bees
are
actively
visiting
blooming
crops
or
weeds.
Residual
toxicity
varies
with
the
crops
and
weather
conditions.

Carbaryl
can
also
range
from
moderately
to
highly
toxic
to
predaceous
arthropods.
These
include
lace
bugs
(
Nabidae)
(
MRID
#
05010807),
big
eyed
bugs
(
Geocoridae:
Geocoris)
(
MRID
#
05010807,
lady
beetles
(
Coccinellidae:
Coccinella,
Cryptolaemus,
Hippodamia,
Lindorus,
Rhodolia,
Stethorus)
(
MRID
#
05013372,
05003978,
05005640),
ground
beetles
(
Carabidae:
Scarites,
Pterostichus,
Bembidion,
Harpalus)
(
MRID
#
05008149),
hymenopterous
parasitoids
(
Aphytis,
Metaphycus,
102
Spalangia,
Leptomastix)
(
MRID
#
05003978,
05005640),
predaceous
mites
(
Amblyseius,
Typhlodromus)
(
MRID
#
05004148,
05013359,
05009346),
and
spiders
(
MRID
#
05010807).

In
a
7­
day
field
study
(
MRID
457854­
07)
designed
to
examine
the
effects
of
carbaryl
on
bees
when
the
chemical
is
used
to
thin
fruit,
carbaryl
SC
(
water
miscible
concentrate)
was
applied
by
mist
blower
at
a
rate
of
0.80
lbs
a.
i./
Acre
to
apple
orchards
in
Germany.
Bee
mortality
and
behavior
was
monitored
for
two
days
leading
up
to
application
and
for
7
days
following
application.
Under
the
conditions
tested
in
Germany,
carbaryl
SC
applications
to
apple
orchards
did
not
have
a
significant
(
P
>
0.05)
effect
on
bee
mortality
and/
or
behavior.
This
nonguideline
study
is
classified
as
supplemental.

Incidents
Involving
Bees
Bee
kill
incidents
have
been
reported
for
carbaryl.
In
incident
I001611­
002
Sevin
XLR
was
applied
to
200
acres
of
asparagus
in
Washington
and
carbaryl
residues
were
detected
in
the
bees.

In
incident
I003826­
009,
a
bee
keeper
in
North
Carolina
reported
a
bee
kill.
A
variety
of
pesticides
had
been
used
in
the
vicinity
and
residues
of
methyl
parathion
(
3.1
ppm),
chlorpyrifos
(
0.1
ppm),
dimethoate
(
1.7
ppm)
and
endosulfan
(
0.2
ppm)
were
detected.
Although
carbaryl
had
been
used
in
the
vicinity,
no
residues
were
detected
in
the
bees.
Given
that
bees
are
roughly
an
order
of
magnitude
more
sensitive
to
methyl
parathion
(
LD50
=
0.11
:
g/
bee)
and
that
residues
of
methyl
parathion
were
detected,
the
organophosphate
is
a
more
likely
culprit
in
this
bee
incident.

In
incident
I003826­
021,
a
bee
hive
owner
in
North
Carolina
reported
bee
mortality.
Although
a
number
of
pesticides
were
being
used
in
the
vicinity
of
the
apiary,
only
carbaryl
residues
(
0.08
ppm)
were
detected
in
the
bees.
The
bee
hive
owner
did
not
know
what
served
as
a
source
of
the
carbaryl.

In
incident
I005855­
001,
the
American
Beekeeper
Federation,
Inc.
submitted
a
report
dated
August
26,
1997,
about
the
ongoing
problem
of
bees
being
killed
by
pesticides
in
the
United
States.
The
report
lists
several
pesticides
(
carbofuran,
methyl
parathion,
parathion,
carbaryl,
naled)
associated
with
bee
kills
during
the
period
of
January
1
through
June
16,
1997.
No
data
were
provided
on
chemical
residues
or
on
the
pesticide
uses
associated
with
the
kills.

In
a
related
report
(
B0000­
300­
03),
the
Honey
Industry
Council
of
America
reported
that
farmers
spraying
alfalfa
crops
with
toxaphene,
parathion,
and
Sevin
in
the
middle
of
the
day
was
resulting
in
bee
kills
due
to
drift.
No
data
were
provided
to
support
these
concerns
though.

Other
than
the
use
of
carbaryl
on
asparagus
in
Washington,
none
of
the
other
reports
on
bee
kills
contain
sufficient
information
to
implicate
a
specific
use
of
carbaryl.
Although
the
bee
industry
has
expressed
its
concerns
regarding
the
toxicity
of
carbaryl
to
bees,
it
has
not
provided
sufficient
data
to
support
its
concerns.
103
Earthworms
An
acute
toxicity
study
of
the
carbaryl
degradate
1­
naphthol
was
conducted
using
earthworms
and
is
reported
in
greater
detail
in
the
1­
naphthol
toxicity
section
to
follow.

Toxicity
to
Freshwater
Aquatic
Animals
Freshwater
Fish,
Acute
Results
of
toxicity
tests
with
freshwater
fish
are
tabulated
in
Table
6.
Since
the
LC50
values
for
the
species
tested
are
in
the
0.25
­
20.0
mg/
L
(
ppm)
range,
carbaryl
can
therefore
range
from
highly
to
slightly
toxic
to
freshwater
fish
on
an
acute
exposure
basis.
Guidelines
72­
1(
a)
and
72­
1(
c)
are
fulfilled
(
MRID
40098001,
00043115).

Table
6.
Summary
of
freshwater
fish
acute
toxicity
in
mg/
L
(
ppm)
for
technical
grade
carbaryl
Species
%
ai
96­
hour
LC50
(
mg/
L)
(
nominal)
Toxicity
Category
MRID
No.
Author/
Year
Study
Classification
Rainbow
Trout
(
Onchorynchus
mykiss)
99.5
1.2
Moderately
Toxic
40098001
Mayer
&
Ellersieck
(
1986)
Core
Chinook
Salmon
(
Onchorynchus
tshawytacha)
99.5
2.4
Moderately
Toxic
40098001
Mayer
&
Ellersieck
(
1986)
Supplemental
Bluegill
Sunfish
(
Lepomis
macrochirus)
99.9
14.0
Slightly
Toxic
00043115
McCann
et
al
(
1969)
Core
Bluegill
Sunfish
(
Lepomis
macrochirus)
99.9
5.04
Moderately
Toxic
40098001
Mayer
&
Ellersieck
(
1986)
Core
Bluegill
Sunfish
(
Lepomis
macrochirus)
99.1
>
7.3*
Moderately
Toxic
457854­
01
Sowig
&
Gosch
(
2002)
Supplemental
Channel
Catfish
(
Ictalurus
punctatus)
99.9
7.79
Moderately
Toxic
40098001
Mayer
&
Ellersieck
(
1986)
Core
Fathead
Minnow
(
Pimephales
promelas)
99.5
7.7
Moderately
Toxic
40098001
Mayer
&
Ellersieck
(
1986)
Core
Black
Crappie
(
Pomoxis
nigromaculatus)
99.5
2.6
Moderately
Toxic
40094602
Johnson
&
Finley
(
1986)
Core
Atlantic
Salmon
(
Salmo
salar)
99.5
0.25
Highly
Toxic
40098001
Mayer
&
Ellersieck
(
1986)
Core
Brown
Trout
(
Salmo
trutta)
99.5
6.3
Moderately
Toxic
40098001
Mayer
&
Ellersieck
(
1986)
Core
Brook
Trout
(
Salvelinus
fontinalis)
99.5
3.0
Moderately
Toxic
40098001
Mayer
&
Ellersieck
(
1986)
Core
Lake
Trout
(
Salvelinus
namaycush)
99.5
0.69
Highly
Toxic
40098001
Mayer
&
Ellersieck
(
1986)
Core
Coho
Salmon
(
Onchorynchus
kisutch)
99.5
2.4
Moderately
Toxic
40098001
Mayer
&
Ellersieck
(
1986)
Core
Species
%
ai
96­
hour
LC50
(
mg/
L)
(
nominal)
Toxicity
Category
MRID
No.
Author/
Year
Study
Classification
104
Yellow
Perch
(
Perca
flavescens)
99.5
0.35
Highly
Toxic
40098001
Mayer
&
Ellersieck
(
1986)
Core
Cutthroat
Trout
(
Onchorynchus
clarkii)
99.5
0.97
Highly
Toxic
40098001
Mayer
&
Ellersieck
(
1986)
Core
Largemouth
Bass
(
Micropterus
salmoides)
99.5
6.4
Moderately
Toxic
40094602
Johnson
&
Finley
(
1980)
Core
Green
Sunfish
(
Lepomis
cyanellus)
99.5
9.5
Moderately
Toxic
40098001
Mayer
&
Ellersieck
(
1986)
Core
Black
Bullhead
(
Ictalurus
melas)
99.5
20.0
Slightly
Toxic
40098001
Mayer
&
Ellersieck
(
1986)
Core
Longnose
Killifish
(
Fundulus
similis)
99.7
1.6
Moderately
Toxic
40228401
Mayer
(
1986)
Supplemental
Carp
(
Cyprinus
carpio)
99.5
5.3
Moderately
Toxic
40098001
Mayer
&
Ellersieck
(
1986)
Core
*
mean­
measured
concentration
over
0
­
96
hours.

Toxicity
was
determined
for
the
typical
end­
use
product
as
well,
with
all
LC50
values,
except
one,
ranging
from
1.4
to
49
mg/
L
(
ppm),
which
indicates
that
carbaryl
can
be
classified
as
slightly
to
moderately
toxic
to
freshwater
fish
(
Table
7).
Guidelines
(
b)
and
72­
1(
d)
are
fulfilled
(
MRID
#
s
00059202,
00042381,
00151519,
00151417,
42397901,
00124383,
00124391).

Incidents
Involving
Freshwater
Fish
A
total
of
three
fish
kill
incidents
are
recorded
in
the
EIIS
database.
In
incident
B0000­
501­
92
carbaryl
was
associated
with
a
fish
kill
in
New
Jersey
(
1980)
following
the
application
of
carbaryl
to
control
gypsy
moth.
No
data
on
residues
were
provided.

In
a
second
incident
(
I000910­
001)
in
Louisiana,
a
fish
kill
was
reported
to
have
occurred
during
in
early
June
1992.
A
number
of
pesticides
(
carbaryl,
MSMA,
atrazine,
iprodione,
dimethylamine,
dicamba
with
2,4­
D,
and
chlorpyrifos)
had
been
applied
to
area
lawns
and
golf
courses
prior
to
the
incident
which
followed
a
high
rain
event.
No
chemical
residues
were
reported;
however,
carbaryl
had
not
been
applied
in
the
area
since
late
April
while
chlorpyrifos
(
bluegill
LC50
=
3
:
g/
L)
and
iprodione
(
LC50
=
3.1
mg/
L)
had
been
applied
less
than
a
week
before
the
incident.
It
is
unlikely
that
carbaryl
residues
would
have
been
sufficiently
high
to
result
in
a
fish
kill
if
the
chemical
had
been
applied
two
months
prior.
Both
chlorpyrifos
and
iprodione
are
more
likely
candidates
for
being
responsible
for
this
fish
kill.

In
a
third
incident
report
(
B0000­
246­
01)
a
number
of
pesticides
(
toxaphene,
carbaryl,
endrin,
methyl
parathion
and
DDT)
were
associated
with
a
fish
kill
in
Oklahoma
where
approximately
22,000
catfish
died.
No
residue
data
were
provided;
however,
given
that
toxaphene
and
endrin
are
both
classified
as
very
highly
toxic
to
catfish
with
LC50
values
of
2.7
:
g/
L
and
0.32
:
g/
L,
105
respectively,
it
is
likely
that
they
are
more
credible
candidates
for
having
caused
the
fish
kill
than
carbaryl.

Therefore,
based
on
the
incident
reports,
there
appears
to
be
only
one
credible
report
where
carbaryl
use
could
be
directly
associated
with
a
fish
kill.

Table
7.
Summary
of
freshwater
fish
acute
toxicity
in
mg/
L
(
ppm)
for
carbaryl
(
typical
end­
use
product)

Species
%
ai
96­
hr
LC50
(
mg/
L)
Toxicity
Category
MRID
No.
Author/
Year
Study
Classification
Rainbow
Trout
(
Onchorynchus
mykiss)
44
1.4
Moderately
Toxic
00151417
Sousa
(
1985)
Core
Rainbow
Trout
(
Onchorynchus
mykiss)
81.5
3.3
Moderately
Toxic
42397901
Lintott
(
1992)
Core
Rainbow
Trout
(
Onchorynchus
mykiss)
50
3.45
Moderately
Toxic
00124383
McCann
(
1971)
Core
Rainbow
Trout
(
Onchorynchus
mykiss)
50
4.5
Moderately
Toxic
00124383
McCann
(
1971)
Core
Bluegill
Sunfish
(
Lepomis
macrochirus)
30
49.0
Slightly
Toxic
00059202
Mc
Caan
(
1970)
Core
Bluegill
Sunfish
(
Lepomis
macrochirus)
5
290.0
Practically
Nontoxic
00042381
McCann
(
1968)
Core
Bluegill
Sunfish
(
Lepomis
macrochirus)
44
9.8
Moderately
Toxic
00151519
Sousa
(
1985)
Core
Bluegill
Sunfish
(
Lepomis
macrochirus)
50
22.0
Slightly
Toxic
00124391
McCann
(
1971)
Core
Freshwater
Fish,
Chronic
Results
of
the
required
early
life­
stage
with
fish
are
summarized
in
Table
8.
Exposure
to
680
:
g/
L
(
ppb)
reduced
survival
of
larvae,
reduced
number
of
eggs
per
female
and
reduced
number
of
eggs
spawned
(
TOUCARO5);
of
the
eggs
spawned
at
680
µ
g/
L,
none
hatched.

Table
8.
Summary
of
freshwater
fish
life­
cycle
toxicity
in
mg/
L
(
ppm)
under
flow­
through
conditions
for
technical
grade
carbaryl
Species
%
ai
NOAEC/
LOAC
(
mg/
L)
Endpoints
Affected
MRID
No.
Author/
Year
Study
Classification
Fathead
Minnow
(
Pimephales
promelas)
99
0.21/
0.68
Survival
and
Reproduction
TOUCARO5
Carlson
(
1972)
Core
106
Amphibians
According
to
a
supplemental
study
with
an
end­
use
product
containing
50%
carbaryl
(
MRID
00160000),
the
LD50
for,
the
bullfrog
(
Rana
catesbeiana)
is
greater
than
4,000
mg/
kg,
or
practically
nontoxic.

The
U.
S.
Geological
Survey
Biological
Resource
Division's
Columbia
Environmental
Research
Center
has
examined
the
effects
of
carbaryl
on
amphibians
(
APPENDIX
D2).
These
studies
have
shown
that
frogs
can
exhibit
considerable
intraspecies
(
Boone
and
Bridges
1998)
and
interspecies
(
Boone
and
Semlitsch
2002)
variability
in
their
response
to
carbaryl
exposure.
Genetic
factors
and
stage
of
development
during
which
exposure
took
place
can
impact
the
vulnerability
of
frogs.
For
example,
frogs
exposed
during
egg
stage
had
lower
weights
than
corresponding
control
animals
and
nearly
18%
of
leopard
frogs
exposed
to
carbaryl
during
development
exhibited
some
type
of
developmental
deformity
(
including
visceral
and
limb
malformations).
Additionally,
environmental
conditions
such
as
temperature
appear
to
impact
the
sensitivity
of
frogs
to
carbaryl.
In
a
96­
hr
acute
toxicity
study,
green
frogs
(
Rana
climitans)
had
an
LC50
of
22.0
mg/
L
at
17oC
but
at
27
oC
the
LC50
was
roughly
half
(
96­
hr
LC50
=
11.32
mg/
L)
(
Boone
and
Bridges
1998).

Furthermore,
in
studies
comparing
the
direct
toxicity
of
carbaryl
to
Southern
leopard
frogs
(
Rana
sphenocephala)
and
fish,
tadpoles
were
relatively
tolerant
(
96­
hr
LC50
=
8.4)
to
carbaryl
compared
to
bluegill
sunfish
(
96­
hr
LC50
=
6.2
mg/
L,
fathead
minnow
(
96­
hr
LC50
=
5.21
mg/
L)
and
rainbow
trout
(
LC50
=
1.88
mg/
L).
The
study
also
reports
the
96­
hr
LC50
(
12.31
mg/
L)
for
the
boreal
toad
(
Bufo
boreas);
these
data
suggest
that
the
surrogate
fish
species
used
to
evaluate
the
toxicity
to
carbaryl
are
protective
for
amphibians
(
Bridges
et
al.
2002).

Of
additional
concern
is
the
potential
for
secondary
effects.
Several
studies
have
suggested
that
carbaryl
exposure
impairs
predator
avoidance
behavior
in
frogs
(
Bridges
1997;
Bridges
1999),
affects
the
length
of
time
required
for
tadpoles
to
complete
metamorphosis
into
adults
(
Boone
and
Semlitsch
2002),
and
affected
the
weight
of
animals
undergoing
metamorphosis.
Carbaryl
concentrations
greater
than
3.5
mg/
L
significantly
affected
the
time
tadpoles
spent
being
active
where
control
animals
exhibited
greater
sprint
speeds
and
were
able
to
swim
greater
distances
(
Bridges
1997).
Slower
swimming
speeds,
altered
activity
patterns
and
prolonged
juvenile
stages
have
been
suggested
as
increasing
the
vulnerability
of
frogs
to
predation
(
Bridges
1997;
Bridges
1999;
Relyea
and
Mills
2001)
and/
or
that
the
threat
of
predation
renders
the
animals
more
susceptible
to
the
direct
toxicity
of
carbaryl
(
Relyea
and
Mills
2001).
While
the
Relyea
and
Mills
paper
indicates
that
carbaryl
was
2
to
4
times
more
lethal
to
gray
treefrogs
(
Hyla
versicolor)
in
the
presence
of
a
predator,
the
study
is
confounded
by
the
potential
effects
of
water
quality
on
mortality
(
APPENDIX
D3).
Additionally,
increased
vulnerability
to
predation
assumes
that
only
the
prey
are
incapacitated
by
carbaryl.
The
Bridges
(
1999)
study
indicates
however,
the
predators
may
also
be
impacted
and
that
gray
treefrogs
actually
spent
less
time
being
active,
but
that
the
active
times
were
primarily
spent
foraging.
However,
in
some
cases,
it
is
unclear
whether
the
effects
of
carbaryl
on
amphibians
has
been
entirely
adverse.
For
example,
Southern
leopard
frogs
exposed
to
carbaryl
at
5
mg/
L
exhibited
a
20%
increase
in
weight
at
metamorphosis(
Bridges
and
Boone
2003)
and
that
at
concentrations
as
high
as
107
7
mg/
L,
Woodhouse's
toad
(
Bufo
woodhousii)
survival
was
roughly
30%
higher
than
controls
(
Boone
and
Semlitsch
2002).

Freshwater
Invertebrates,
Acute
Since
the
EC50
falls
in
the
range
of
1.7
­
26
:
g/
L
(
ppb),
carbaryl
is
categorized
as
very
highly
toxic
to
aquatic
invertebrates
on
an
acute
exposure
basis
(
Table
9).
Toxicity
studies
with
the
typical
end­
use
product
show
that
carbaryl
is
very
highly
toxic
to
daphnids,
with
an
EC50
in
the
4.29
­
13.0
:
g/
L
range
(
Table
10).
Guideline
72­
2
is
fulfilled
(
MRID
#
s
400980­
01,
423979­
02,
423979­
03).

Acute
toxicity
studies
of
the
stonefly
larvae
Chloroperla
grammatica
with
technical
grade
carbaryl
using
a
96­
hr
exposure
period
(
MRID
458206­
02)
and
a
1­
hour
(
pulse)
exposure
period
(
MRID
458206­
03)
resulted
in
LC50
values
of
5.14
:
g/
L
and
28.1
:
g/
L
(
ppb),
respectively.
Following
the
1­
hour
"
pulse"
exposure,
treated
Mayflies
were
transferred
to
untreated
water
and
monitored
for
95
hours.
Although
50%
of
the
stonefly
larvae
were
immobilized
at
28
:
g/
L
after
a
1­
hour
exposure
period,
all
of
the
exposed
animals
appeared
to
be
completely
recovered
during
the
95
hour
post­
exposure
period
in
untreated
waters.

Table
9.
Summary
of
freshwater
invertebrate
acute
toxicity
in
:
g/
L
(
ppb)
for
technical
grade
carbaryl
Species/
Static
or
Flowthrough
%
ai
48­
hour
EC50
(:
g/
L)
(
nominal)
Toxicity
Category
MRID
No.
Author/
Year
Study
Classification
Water
flea
(
Daphnia
magna)
99.5
5.6
Very
Highly
Toxic
400980­
01
Mayer
&
Ellersieck
(
1986)
Core
Stonefly
(
Classenia
sabulosa)
99.5
96hr
LC50=
5.6
Very
Highly
Toxic
400980­
01
Mayer
&
Ellersieck
(
1986)
Supplemental
Stonefly
(
Isogenus
sp.)
99.5
96hr
LC50=
3.6
Very
Highly
Toxic
400980­
01
Mayer
&
Ellersieck
(
1986)
Supplemental
Stonefly
(
Pteronarcella
badia)
99.5
96hr
LC50=
1.7
Very
Highly
Toxic
400980­
01
Mayer
&
Ellersieck
(
1986)
Supplemental
Stonefly
(
Chloroperla
grammatica)
99.1
96­
hr
LC50
=
5.14*
Very
Highly
Toxic
458206­
02
Schäfers
(
2002)
Supplemental
Stonefly
(
Chloroperla
grammatica)
99.1
1­
hr
LC50
=
28.1*
:
g/
L
Very
Highly
Toxic
458206­
03
Schäfers
(
2002)
Supplemental
Scud
(
Gammarus
fasciatus)
99.5
96hr
EC50=
26
Very
Highly
Toxic
400980­
01
Mayer
&
Ellersieck
(
1986)
Core
*
Mean­
measured
concentrations
over
study
period.
108
Table
10.
Acute
carbaryl
toxicity
in
:
g/
L
(
ppb)
to
freshwater
invertebrates
using
technical
end­
product
(
TEP).

Species
%
ai
48­
hour
EC50
(:
g/
L)
Toxicity
category
MRID
No.
Author/
Year
Study
Classification
Water
flea
(
Daphnia
magna)
49.0%
7.1
Very
highly
toxic
00150538
Nicholson
and
Surprenant
(
1985)
Supplemental
Water
flea
(
Daphnia
magna)
43.9%
13.0
Very
highly
toxic
00150540
Nicholson
and
Surprenant
(
1985)
Supplemental
Water
flea
(
Daphnia
magna)
47.3%
4.29
Very
highly
toxic
42432401
Lintott
(
1992)
Supplemental
Water
flea
(
Daphnia
magna)
43.7%
6.66
Very
highly
toxic
42397902
Lintott
(
1992)
Core
Water
flea
(
Daphnia
magna)
81.5%
7.2
Very
highly
toxic
42397903
Lintott
(
1992)
Core
In
a
series
of
studies
(
Table
11)
to
simulate
the
presence
of
sediment,
technical
grade
carbaryl
was
evaluated
for
its
toxicity
to
freshwater
invertebrates
including
an
amphipod
(
Gammarus
fossarum),
two
cladocerans
(
Chydorus
sphaericus
and
Daphnia
magna),
a
clam
(
Sphaerium
corneum),
a
Mayfly
larvae
(
Ephemera
danica),
and
a
snail
(
Planobarius
corneus).
Exposure
was
based
on
mean­
measured
water
column
concentrations
over
the
length
of
each
study.
Carbaryl
was
moderately
toxic
to
both
the
clam
and
the
snail
(
96­
hr
EC50
>
2200
:
g/
L)
(
ppb)
while
it
was
very
highly
toxic
to
the
remainder
of
invertebrates
studied.(
48­
hr
EC50
range
5
­
15
:
g/
L).

Table
11.
Acute
toxicity
of
carbaryl
in
:
g/
L
(
ppb)
to
freshwater
invertebrates
using
technical
grade
carbaryl
in
the
presence
of
sediment
Species
%
ai
48­
hour
EC50
(:
g/
L)
Toxicity
category
MRID
No.
Author/
Year
Study
Classification
Pulmonate
Snail
Planobarius
corneus
99.1%
96­
hr
EC50
>
2245
Moderately
Toxic
458609­
05
Schäfers
(
2002)
Supplemental
Freshwater
clam
Sphaerium
corneum
99.1%
96­
hr
EC50
>
2467
Moderately
Toxic
458609­
06
Schäfers
(
2002)
Supplemental
Cladoceran
Chydorus
sphaericus
99.1%
48­
hr
EC50
=
7.25
Very
Highly
Toxic
458609­
02
Schäfers
(
2002)
Supplemental
Amphipod
Gammarus
fossarum
99.1%
96­
hr
EC50
=
17.5
Very
Highly
Toxic
458609­
04
Schäfers
(
2002)
Supplemental
Cladoceran
Daphnia
magna
99.1%
48­
hr
EC50
=
15
Very
Highly
Toxic
457848­
01
Schäfers
(
2002)
Supplemental
Cladoceran
Daphnia
longispina
99.1%
48­
hr
EC50
=
4.9
Very
Highly
Toxic
4548609­
01
Schäfers
(
2002)
Supplemental
Mayfly
Ephemera
danica
99.1%
48­
hr
EC50
=
4.9
Very
Highly
Toxic
458609­
03
Schäfers
(
2002)
Supplemental
109
Field
studies
that
evaluated
populations
of
damselflies
(
Xanthocnemis
zealandica)
after
exposure
to
0.1
mg/
L
carbaryl
showed
a
90%
reduction
in
emergence
success
after
10­
12
days
exposure
(
Hardersen
and
Wratten,
1998).
Studying
natural
plankton
communities
in
enclosed
mesocosms,
Havens
(
1995)
reports
a
decline
in
total
zooplankton
biomass
and
numbers
of
individuals
up
to
0.100
mg/
L.
Furthermore,
at
carbaryl
concentrations
greater
than
0.02
mg/
L
Daphnia
was
no
longer
found
and
that
at
concentrations
above
0.050
mg/
L
all
cladocerans
were
eliminated,
resulting
in
an
increase
in
algal
biomass,
representing
a
repartitioning
of
biomass
from
zooplankton
to
phytoplankton.
Hanazato
(
1995)
exposed
Daphnia
ambigua
to
carbaryl
and
a
kairomone
released
by
the
predator
Chaoborus
(
phantom
midge)
simultaneously.
Daphnia
developed
helmets
in
response
to
the
kairomone,
but
not
in
response
to
carbaryl
at
0.001­
0.003
mg/
L.
However,
carbaryl
enhanced
the
development
of
high
helmets
and
prolonged
the
maintenance
period
of
the
helmets
in
the
presence
of
the
kairomone,
suggesting
that
at
low
concentrations
carbaryl
can
alter
predator­
prey
interactions
by
inducing
helmet
formation
and
vulnerability
to
predation
in
Daphnia.
In
related
mesocosms
studies,
exposure
to
carbaryl
at
1
mg/
L
killed
all
plankton
species,
including
Chaoborus
larvae
(
Hanazato,
1989).
However,
this
concentration
is
well
above
the
maximum
EECs
modeled
for
carbaryl,
and
is
unlikely
that
such
high
levels
of
this
chemical
would
be
found
under
field
conditions.
Mora
et
al.
(
2000)
studying
the
relationship
between
toxicokinetics
of
carbaryl
and
effects
on
acetylcholinesterase
(
ACHase)
activity
in
the
snail,
Pomaca
patula,
observed
increased
enzyme
inhibition,
along
with
the
bioconcentration
of
carbaryl,
after
72
hours
of
exposure
to
sublethal
levels
(
0.0032
mg/
L).
The
transfer
of
snails
to
carbaryl­
free
water
was
followed
by
rapid
monophasic
elimination
with
a
half­
life
of
1.0
hour,
although
ACHase
activity
levels
never
returned
to
control
values.

Freshwater
Invertebrate,
Chronic
A
21­
day
toxicity
study
preformed
with
the
water
flea
estimated
a
NOAEC
and
a
LOAEC
of
1.5
:
g/
L
and
3.3
:
g/
L
(
ppb),
respectively,
based
on
affected
reproduction
(
Table
12).
Guideline
72­
4(
b)
for
freshwater
invertebrates
is
fulfilled
(
MRID
00150901).

In
a
recent
28­
day
chronic
(
static)
toxicity
of
carbaryl
(
technical;
99.1%
purity)
to
the
midge
larvae
Chironomus
riparius
(
MRID
457848­
02
),
organisms
were
exposed
to
negative
control,
solvent
(
acetone)
control
and
test
chemical
at
a
single
dosing
of
nominal
concentration
of
0.0625,
0.125,
0.25,
0.50,
and
1.0
mg/
L.
Reduced
emergence
and
development
rates
were
the
most
sensitive
endpoints
(
NOEC
=
0.5
mg/
L;
LOEC
=
1.0
mg/
L)
(
ppm).
The
study
is
classified
as
supplemental
since
it
is
uncertain
whether
the
use
of
dechlorinated
tap
water
may
have
impacted
the
study's
ability
to
differentiate
treatment
effects;
however,
the
study
provides
information
on
the
effects
of
carbaryl
technical
(
99.1%
purity)
on
benthic
invertebrates
based
on
a
single
exposure
to
carbaryl
followed
by
a
28­
day
observation
period.
Analytical
analysis
of
overlying
water
revealed
that
carbaryl
and
its
primary
degradate,
1­
naphthol,
had
essentially
dissipated
by
day
7.
110
Table
12.
Summary
of
freshwater
aquatic
invertebrate
life­
cycle
toxicity
in
:
g/
L
(
ppb)
for
technical
grade
carbaryl
Species
%
ai
21­
day
NOAEC/
LOAEC
(:
g/
L)
Endpoints
Affected
MRID
No.
Author/
Year
Study
Classification
Water
flea
(
Daphnia
magna)
99.0%
1.5
/
3.3
Reproduction
00150901
Surprenant
(
1985)
Core
Midge
Chironomous
riparius
99.1%
500
/
1000
Emergence
/
developmental
rate
457848­
02
Ebeling
&
Radix
(
2002)
Supplemental
Toxicity
to
Estuarine
and
Marine
Animals
Estuarine/
Marine
Fish,
Acute
Since
the
minnow
LC50
is
2.6
mg/
L
(
ppm)
(
Table
13),
carbaryl
is
categorized
as
moderately
toxic
to
estuarine/
marine
fish
on
an
acute
basis.
The
guideline
72­
3(
a)
is
fulfilled
(
MRID
42372801).

Table
13.
Summary
of
estuarine/
marine
fish
acute
toxicity
for
technical
grade
carbaryl
Species/
Static
%
ai
96­
hour
LC50
mg/
L
(
nominal)
Toxicity
Category
MRID
No.
Author/
Year
Study
Classificati
on
Sheepshead
Minnow
(
Cyprinodon
variegatus)
99
2.2
Moderately
Toxic
00150539
Sousa
and
Surprenant
(
1985)
Supplemen
tal
Sheepshead
Minnow
(
Cyprinodon
variegatus)
99.7%
2.6
Moderately
Toxic
42372801
Lintott
(
1992)
Core
Estuarine
and
Marine
Fish,
Chronic
An
estuarine/
marine
fish
early
life­
stage
toxicity
test
using
the
TGAI
is
required
for
carbaryl
because
the
end­
use
product
is
expected
to
be
transported
to
this
environment
from
the
intended
use
site.
The
pesticide
uses
(
e.
g.
turf)
are
such
that
its
presence
in
water
is
likely
to
be
continuous
(
multiple
applications),
and
chronic
concerns
have
been
noted
for
freshwater
and
marine
fish.
At
this
point,
the
guideline
72­
4(
a)
for
estuarine/
marine
fish
is
not
fulfilled.

Estuarine
and
Marine
Invertebrates,
Acute
As
shown
in
Table
14,
the
96­
hour
mysid
shrimp
LC50
for
technical
carbaryl
falls
is
5.7
:
g/
L
(
ppb)
(
MRID
42343401).
Thus,
this
chemical
is
categorized
as
very
highly
toxic
to
estuarine/
marine
111
shrimp
species
on
an
acute
basis.
By
contrast,
carbaryl
is
moderately
toxicity
to
the
oyster
(
LC50
=
2.7
mg/
L
(
ppm;
MRID
00148221).
Guidelines
72­
3(
b)
and
72­
3(
c)
are
fulfilled.

Table
14.
Summary
of
estuarine/
marine
invertebrate
acute
toxicity
for
technical
grade
carbaryl
Species
%
ai.
48­
hour
LC50
:
g/
L
Toxicity
Category
MRID
No.
Author/
Year
Study
Classification
Brown
Shrimp
(
Penaeus
aztecus)
99.7
1.5
Very
Highly
Toxic
40228401
Mayer
(
1986)
Supplemental
Mysid
(
Mysidopsis
bahia)
99
96
hr
LC50
=
6.7
Very
Highly
Toxic
00150544
Hoberg
and
Surprenant
(
1985)
Supplemental
Mysid
(
Mysidopsis
bahia)
99.7
96
hr
LC50
=
5.7
Very
Highly
Toxic
42343401
Lintott
(
1992)
Core
Glass
Shrimp
(
Palaemonetes
kadiakensis)
99.5
5.6
Very
Highly
Toxic
40098001
Mayer
&
Ellersieck
(
1986)
Supplemental
Grass
Shrimp
(
Palaemonetes
pugio)
99.7
28
Very
Highly
Toxic
40228401
Mayer
(
1986)
Supplemental
Pink
Shrimp
(
Penaeus
duorarum)
99.7
32
Very
Highly
Toxic
40228401
Mayer
(
1986)
Supplemental
Eastern
Oyster
(
Crassostrea
virginica)
99.7
96
hr
LC50>
2
Very
Highly
Toxic
40228401
Mayer
(
1986)
Core
Eastern
Oyster
(
Crassostrea
virginica)
99
2700
Moderately
Toxic
00148221
Surprenant,
et
al.
(
1985)
Core
Blue
Crab
(
Callinectes
sapidus)
99.7
320
Highly
Toxic
40228401
Mayer
(
1986)
Supplemental
Fairy
Shrimp
95.3%
170
Highly
toxic
40094602
Mayer
(
1986)
Supplemental
Eastern
Oyster
(
Crassostria
virginica)
95.0%
>
1,000
Moderately
toxic
40228401
Mayer
(
1986)
Supplemental
Results
of
toxicity
testing
using
the
typical
end­
use
product
are
summarized
in
Table
15.
Carbaryl
TEPs
are
highly
toxic
to
mysids,
LC50
values
ranging
from
9.3
to
20.2
:
g/
L
(
ppb)
(
MRID
#
s
42397904,
42565601,
and
42343402),
and
slightly
toxic
to
oysters
(
LC50
=
23.6
mg/
L
(
ppm),
MRID
42597301).
Guidelines
72­
3(
e)
and
72­
3(
f)
are
fulfilled.
112
Table
15.
Summary
of
estuarine/
marine
invertebrate
acute
toxicity
for
TEP
Species
%
ai.
48­
hour
LC50
:
g/
L
Toxicity
Category
MRID
No.
Author/
Year
Study
Classification
Mysid
(
Mysidopsis
bahia)
81.5
9.6
Very
Highly
Toxic
42397904
Lintott
(
1992)
Core
Mysid
(
Mysidopsis
bahia)
81.5
9.3
Very
Highly
Toxic
42565601
McElwee
and
Lintott
(
1992)
Core
Mysid
(
Mysidopsis
bahia)
43.7%
96
hr
LC50
=
20.2
Very
Highly
Toxic
42343402
Lintott
(
1992)
Core
Eastern
Oyster
(
Crassostrea
virginica)
43.3%
96
hr
LC50
=
23,600
Slightly
Toxic
42597301
Lintott
(
1992)
Supplemental
Estuarine
and
Marine
Invertebrate,
Chronic
There
are
no
available
chronic
toxicity
data
for
estuarine/
marine
invertebrates.
The
guideline
72­
4(
b)
for
estuarine/
marine
invertebrates
is
no
fulfilled.

1­
Naphthol
Toxicity
to
Aquatic
Organisms
Acute
Toxicity
The
major
metabolite
of
carbaryl
degradation
by
abiotic
and
microbially
mediated
processes
is
1­
naphthol.
As
summarized
in
Table
16,
1­
naphthol
is
categorized
as
moderately
to
highly
toxic
to
aquatic
organisms
on
an
acute
exposure
basis.
LC50
values
ranged
from
0.75
to
1.6
mg/
L
for
freshwater
fish,
from
1.2
to
1.8
mg/
L
for
estuarine/
marine
fish,
from
0.70
to
3.25
mg/
L
for
freshwater
invertebrates,
and
from
0.21
to
2.5
mg/
L
for
estuarine/
marine
invertebrates.

Acute
toxicity
testing
of
1­
naphthol
was
also
conducted
using
earthworms
(
Eisenia
fetida).
In
a
14­
day
study,
the
LC50
was
441
mg/
kg
of
soil
(
MRID
457848­
06).
Although
the
study
was
conducted
for
14
days,
no
additional
mortality
was
observed
after
day
7
suggesting
that
naphthol
had
likely
degraded.
The
study
is
classified
as
supplemental
since
EPA
does
not
currently
require
earthworm
testing..
113
Table
16
Summary
of
aquatic
organisms
acute
toxicity
in
mg/
L
(
ppm)
for
the
carbaryl
degradate
1­
naphthol.

Species
96­
hour
LC50
(
mg/
L)
(
nominal)
Toxicity
Category
MRID
No.
Author/
Year
Study
Classification
Rainbow
Trout
(
Onchorynchus
mykiss)
1.4
Moderately
Toxic
40955204
Surprenant
(
1988)
Core
Rainbow
Trout
(
Onchorynchus
mykiss)
1.6
Moderately
Toxic
00164307
Surprenant
(
1986)
Supplemental
Bluegill
Sunfish
(
Lepomis
macrochirus)
0.76
Highly
Toxic
40955203
Surprenant
(
1988)
Core
Bluegill
Sunfish
(
Lepomis
macrochirus)
0.75
Highly
Toxic
00164305
Surprenant
(
1986)
Supplemental
Sheepshead
Minnow
(
Cyprinodon
variegatus)
1.2
Moderately
Toxic
40955201
Surprenant
(
1988)
Core
Sheepshead
Minnow
(
Cyprinodon
variegatus)
1.8
Moderately
Toxic
00164306
Surprenant
(
1986)
Supplemental
Waterflea
(
Daphnia
magna)
48
hr
EC50
=
0.73
Highly
Toxic
40955205
Surprenant
(
1988)
Core
Waterflea
(
Daphnia
magna)
48
hr
EC50
=
0.70
Highly
Toxic
00164310
Surprenant
(
1986)
Supplemental
Waterflea
(
Daphnia
magna)
48
hr
EC50
=
3.25
Moderately
toxic
457854­
05
Ebeling
&
Nguyen
(
2002)
Supplemental
Mysid
(
Mysidopsis
bahia)
0.21
Highly
Toxic
40955202
Surprenant
(
1988)
Core
Mysid
(
Mysidopsis
bahia)
0.20
Highly
Toxic
00164309
Surprenant
(
1986)
Supplemental
Eastern
Oyster
(
Crassostrea
virginica)
48
hr
LC50
=
2.1
Moderately
Toxic
00164308
Surprenant
(
1986)
Core
Chronic
Toxicity
Chronic
(
32­
day)
exposure
to
the
1­
naphthol
degradate
of
carbaryl
at
mean­
measured
concentrations
of
200
:
g/
L
resulted
in
reduced
larval
survival
and
reduced
body
weight
and
length
Table
17.
Approximately
75%
of
the
fish
exposed
to
the
200
µ
g/
L
exhibited
deformed
jaw,
i.
e.,
mouth
appeared
abnormally
small
and
the
lower
jaw
appeared
extended.
The
guideline
requirement
72­
4(
a)
for
freshwater
fish
using
1­
naphthol
is
fulfilled.

Table
17.
Chronic
toxicity
testing
of
the
carbaryl
degradate
1­
naphthol.

Species
%
ai
NOEC/
LOEC
(
mg/
L)
Endpoints
Affected
MRID
No.
Author/
Year
Study
Classification
Fathead
Minnow
(
Pimephales
promelas)
99
0.10
/
0.20
Larval
survival/
growth
457848­
04
Sousa
(
2002)
Core
114
Terrestrial
Plants
Toxicity
testing
of
terrestrial
plants
is
required
for
non­
herbicide
pesticides
when
the
label
warns
that
nontarget
plants
could
be
adversely
affected.
Carbaryl
can
be
used
as
a
fruit
thinning
agent
on
apples
and
pears.
However,
the
label
cautions
that
the
product
may
result
in
fruit
deformity
under
certain
environmental
conditions.
The
label
also
cautions
that
application
to
wet
foliage
or
during
periods
of
high
humidity
may
cause
injury
to
tender
foliage.
Label
language
indicates
that
carbaryl
should
not
be
used
on
Boston
ivy,
Virginia
creeper,
and
maidenhair
fern
due
to
potential
injury.
Incidents
have
also
been
recorded
for
vegetable
crops
(
tomatoes,
potatoes,
cabbage,
broccoli,
pumpkin,
squash,
cucumbers)
in
New
York
and
Pennsylvania
(#
1009262­
128;
#
1009305­
001).

Tier
1
terrestrial
plant
vegetative
vigor
testing
was
conducted
for
6
plant
species
(
4
dicots
and
2
monocots)
after
application
of
Sevin
®
XLR
Plus,
soluble
concentrate
(
Carbaryl,
44.35%
w/
w)
at
a
single
field
application
rate
of
900
g
a.
i./
ha
(
0.803
lbs
a.
i./
acre),
equivalent
to
the
TEP
of
4.059
g/
L
per
ha
(
0.014
lbs/
gal
per
acre).
Response
at
this
level
was
compared
to
response
in
a
negative
control
group.
Test
species
included
cabbage,
cucumber,
onion,
ryegrass,
soybean,
and
tomato.
No
species
were
sensitive
to
Sevin
®
XLR
Plus,
soluble
concentrate
(
Carbaryl,
44.35%
w/
w)
because
no
reductions
exceeded
25%.
The
study
(
MRID
457848­
07)
is
classified
as
supplemental
and
does
not
fulfill
the
guideline
requirements
for
a
Tier
I
vegetative
vigor
study
(
Subdivision
J,
§
122­
1b)
because
fewer
species
than
recommended
(
6
dicot
and
4
monocot
species)
were
tested
and
the
species
tested
did
not
include
corn
and
a
dicot
root
crop
species.
Furthermore,
plant
height
was
(
a
recommended
endpoint)
not
evaluated
Guideline
122­
1
is
not
fulfilled.

Incidents
Involving
Terrestrial
Plants
Of
all
of
the
incidents
associated
with
carbaryl,
the
greatest
number
(
11)
have
affected
terrestrial
plants.
In
Minnesota,
Sevin
XLR
Plus
damaged
all
15
acres
of
a
cucumber
crop
(
I012089­
008).
In
Florida,
Bug­
B­
Gon
Garden
dust
killed
two
tomato
plants
(
I010017­
016).
In
California,
the
use
of
Sevin
80W
(
9.3
lbs/
acre)
in
conjunction
with
SunSpray
6E
(
petroleum
distillate)
on
olives
resulted
in
pitting,
slight
burn
and
leaf
drop
(
I009846­
003).
In
North
Carolina,
the
use
of
Sevin
XLR
Plus
was
alleged
to
have
damaged
an
orchard;
however,
the
application
rate
and
crop
is
not
reported
(
I009412­
001).
In
Pennsylvania,
the
use
of
Garden
Tech
Ready­
to­
Use
bug
killer
to
control
flea
beetles
resulted
in
burning
of
vegetables
(
potatoes,
cabbage,
broccoli
and
tomatoes)
in
a
homeowner's
garden
(
I009305­
001).
In
New
York,
Bub­
B­
Gon
Dust
killed
tomatoes,
cucumbers,
pumpkins
and
squash
two
weeks
after
application
by
a
home
gardener
(
I009262­
128).
In
California,
application
of
two
different
formulations
of
carbaryl
(
Sevin
50W
and
Sevin
80
WSP)
over
4
consecutive
months
resulted
in
50%
of
a
43­
acre
quince
crop
being
spotted
(
I008034­
004
/
I008034­
003).
Also
in
California,
60%
of
the
fruit
from
8­
acre
quince
orchard
was
spotted
following
application
of
Sevin
50W
(
I008034­
002).
In
Oregon
where
two
orchards
applied
Sevin
XLR,
pear
harvest
was
reduced
by
low
fruit
set
and
malformations
in
fruit
shape
(
I002276­
002);
the
certainty
factor
was
classified
as
"
unlikely"
since
the
reviewer
felt
there
was
no
indication
that
carbaryl
had
damaged
plants
at
registered
use
rates.
In
California,
following
the
use
of
Greensweep,
a
homeowner's
lawn
was
damaged
(
I001556­
002);
the
certainty
factor
however,
was
classified
as
unlikely
since
the
reviewer
did
not
believe
carbaryl
had
ever
been
implicated
in
causing
plant
damage.
Finally,
in
Florida
use
of
Greesweep
Weed
damaged
a
homeowner's
lawn
(
I001358­
002);
the
certainty
factor
was
classified
115
as
unlikely
since
the
reviewer
felt
there
was
insufficient
information
contained
within
the
incident
report
to
link
carbaryl
directly
to
the
damage.

Based
on
the
available
incident
data
related
to
carbaryl
use,
it
appears
that
many
of
the
reports
were
generated
by
homeowner
use
of
the
pesticides.
Insufficient
detail
is
provided
to
determine
whether
the
homeowner
followed
label
instructions
for
the
application
of
carbaryl
on
plants.
The
large
scale
damage
inflicted
to
orchard
crops
is
a
greater
concern.
The
limited
terrestrial
plant
data
available
on
carbaryl
does
not
indicate
the
likelihood
of
phytotoxic
effects;
however,
the
incident
data
imply
that
phytotoxic
effects
are
possible.

Aquatic
Plants
Aquatic
plant
testing
is
recommended
for
all
pesticides
having
outdoor
uses
(
Keehner.
July
1999).
The
tests
are
performed
on
species
from
a
cross­
section
of
the
nontarget
aquatic
plant
population.
The
preferred
test
species
are
duckweed
(
Lemna
gibba),
marine
diatom
(
Skeletonema
costatum),
freshwater
blue­
green
algae
(
Anabaena
flos­
aquae),
freshwater
green
alga
(
Selenastrum
capricornutum),
and
a
freshwater
diatom.
Toxicity
testing
for
aquatic
plant
species
is
required
for
carbaryl
because
of
its
registered
forestry
uses.

To
date,
the
Agency
has
received
data
on
only
one
aquatic
plant
species,
i.
e.,
a
green
algae
Pseudokirchneria
subcapitata
(
formerly
Selenastrum
capricornutum).
I
n
one
study
of
green
algae
the
LC50
and
NOAEC
are
1.1
ppm
and
0.37
ppm,
respectively
(
MRID
#
42372802);
the
study
is
classified
as
core.

In
a
recent
96­
hour
acute
toxicity
study
(
MRID
457848­
03),
cultures
of
Pseudokirchneriella
subcapitata
were
exposed
to
carbaryl
at
nominal
concentrations
of
1.0,
1.8,
3.2,
5.6,
10,
and
18mg
a.
i/
L
under
static.
The
EC05
and
EC50/
IC50
values
based
on
cell
density
were
0.287
and
1.27
mg
a.
i/
L,
respectively.
The
percent
growth
inhibition
in
the
treated
algal
culture
as
compared
to
the
control
ranged
from
27
to
98%.
Other
than
inhibition
of
cell
growth
(
in
terms
of
numbers
of
cells),
there
were
no
compound
related
phytotoxic
effects.
This
toxicity
study
is
classified
as
supplemental
because
tap
water
was
used
as
a
source
of
dilution
water
and
the
levels
of
residual
chlorine
are
not
reported;
it
is
uncertain
whether
this
deficiency
may
have
impacted
the
ability
of
the
study
to
detect
treatment
effects.

In
a
similar
96­
hr
acute
toxicity
study
(
MRID
457848­
08
),
cultures
of
Pseudokirchneriella
subcapitata
were
exposed
to
SEVIN
XLR
PLUS
(
carbaryl
extra
long
residue
formulated
product)
at
nominal
concentrations
of
0,
1.0,
1.8,
3.2,
5.6,1
and
10
mg
a.
i/
L
under
static
conditions.
The
NOAEC
is
1.8
mg
a.
i./
L
and
EC50/
IC50
values
based
on
cell
count
was
3.2
mg
a.
i/
L.
The
percent
growth
inhibition
in
the
treated
algal
culture
as
compared
to
the
control
ranged
from
0
to
97%.
No
abnormalities
in
cell
morphology
were
observed
at
any
of
the
test
concentrations.
The
study
is
classified
as
scientifically
sound
and
is
suitable
for
use
in
estimating
the
risk
of
carbaryl
formulated
end­
product
to
aquatic
plants.
116
As
mentioned
earlier,
there
are
data
suggesting
that
amphibians
growth
has
actually
increased
in
carbaryl­
treated
waters
(
Bridges
and
Boone
2003).
In
this
study,
chlorophyll
a
concentrations
in
ponds
treated
with
carbaryl
at
5
mg/
L
increased
347%
compared
to
controls.
The
authors
suggest
that
the
increased
phytoplankton
productivity
may
have
been
due
to
reduced
grazing
by
zooplankton
sensitive
to
carbaryl.
It
is
also
possible
though
that
since
the
carbaryl
degradate
1­
naphthol
is
a
plant
auxin,
carbaryl
treatment
may
have
stimulated
the
growth
of
certain
algae.
Therefore,
EFED
is
uncertain
regarding
the
potential
effects
of
carbaryl
on
aquatic
plants.
Since
only
one
species
of
aquatic
plant
has
been
tested,
the
Guideline
122­
2
is
not
fulfilled.
117
APPENDIX
D2.
REVIEW
OF
LITERATURE
ON
EFFECTS
OF
CARBARYL
ON
AMPHIBIANS
Bridges,
C.
M.
1999.
Effects
of
a
Pesticide
on
Tadpole
Activity
and
Predator
Avoidance
Behavior.
Journal
of
Herpetology
33
(
2):
303
­
306
Gray
treefrog
(
Hyla
versicolor)
tadpoles
(
0.025
±
0.008
g)
at
stage
25
were
housed
with
redspotted
newts
(
Notophthalmus
viridescens)
and
exposed
to
carbaryl
at
either
1.25
or
2.50
mg/
L,
dilution
(
well
water)
water
control,
or
solvent
(
0.06
ml
acetone/
L)
control.
Three
replicates
of
eight
3.78­
L
glass
jars
filled
with
2
L
of
well
water
at
22oC
and
exposed
for
24
hours
under
static
conditions.
Testing
chambers
consisted
of
18­
L
plastic
tubs
(
45
x
25
x
15
cm)
willed
with
10
L
well
water.
A
small
plastic
plant
was
secured
15
cm
from
one
end.
At
the
other
end
was
a
1­
L
(
8
x
8
x
15
cm)
plastic
container
to
hold
the
newt.
The
containers
had
plastic
mesh
sides
to
facilitate
the
dissemination
of
visual,
tactile,
and
chemical
cues,
but
precluded
attack
by
the
newt.
Following
the
24­
hr
carbaryl
exposure,
each
group
of
three
tadpoles
was
placed
in
testing
chamber
containing
the
confined
newt.
After
a
5­
minute
acclimation,
tadpole
activity
(
swimming,
resting
and
feeding)
and
position
within
the
chamber
(
i.
e.,
in
refugia,
in
open,
near
edge)
were
recorded
every
3
minutes
for
1
hour.
Activity
of
all
three
tadpoles
was
pooled.

Tadpoles
exposed
to
carbaryl
at
2.5
mg/
L
were
active
an
average
of
45%
less
of
the
time
than
control
tadpoles.
The
responses
of
tadpoles
to
carbaryl
were
not
considered
adaptive
[
to
the
presence
of
predators].
Carbaryl­
exposed
tadpoles
spent
less
time
in
refugia
compared
to
controls
when
predators
were
present
and
also
spent
more
time
in
refugia
when
no
predator
was
present.

Both
in
the
presence
of
predators
and
carbaryl
exposure
significantly
reduced
the
amount
of
time
tadpoles
spent
active.
Tadpoles
spending
too
much
time
resting
may
not
acquire
adequate
resources
to
achieve
metamorphosis
or
to
outgrow
gape­
limited
predators.
Although
carbaryl­
exposed
tadpoles
spent
less
time
active
with
predators
were
present,
a
greater
proportion
of
that
active
time
was
spent
feeding,
thereby
minimizing
the
costs
associated
with
the
trade­
off
between
time
spent
foraging
and
predator
avoidance.
The
author
concludes
that
tadpoles
in
carbaryl
contaminated
sites
may
experience
longer
larval
periods
or
a
smaller
size
at
metamorphosis,
both
of
which
can
negatively
affect
adult
fitness.

Boone,
M.
D.
and
C.
M.
Bridges.
1998.
The
Effect
of
Temperature
on
the
Potency
of
Carbaryl
for
Survival
of
Tadpoles
of
the
Green
Frog
(
Rana
clamitans).
Environmental
Toxicology
and
Chemistry
18
(
7):
1482
­
1484.

Green
frog
(
Rana
clamitans)
tadpoles
weighing
an
average
of
80
mg
(
±
15
mg)
were
exposed
to
one
of
nine
chemical
treatments,
i.
e.,
water
control,
solvent
(
acetone
0.5
mL/
L),
3.5,
5.0,
7.2,
10.3,
14.7,
21.0
and
30.0
mg
carbaryl/
L,
and
to
one
of
three
temperature
treatments,
i.
e.,
17,
22,
or
27oC,
in
a
96­
hr
static
test.
The
tests
were
conducted
in
3.8­
L
glass
jars
containing
2
L
of
well
water
(
ph
7.8,
hardness
286
mg/
L
as
CaCO3).
Each
treatment
was
replicated
three
times.
Ten
tadpoles
were
randomly
assigned
to
each
glass
jar
and
the
percent
mortality
was
determined
at
12,
24,
48,
and
96
hours.
Tadpoles
were
not
fed
during
the
exposure.
118
Average
survival
was
significantly
different
at
each
temperature
treatment.
At
24
hours
survival
was
significantly
lower
at
27oC.
Lower
concentrations
(
3.5,
5.0,
7.2
and
10.3
mg/
L)
were
not
significantly
different
from
controls
(
survival
>
96%).
The
two
greatest
concentrations
(
21
and
30
mg/
L)
were
significantly
different
from
controls
at
all
times
and
had
an
average
survival
below
42%,
with
no
tadpoles
surviving
in
the
30
mg/
L
group
for
96
hours..
Tadpoles
at
17
and
22oC
had
greater
survival
at
higher
concentrations
than
tadpoles
at
27oC.
At
48
hours,
the
LC50
at
27oC
was
16.17
mg/
L
and
at
17oC
the
LC50
was
26.01
mg/
L.
By
96
hours,
the
LC50
at
27oC
(
11.32
mg/
L)
was
twice
as
large
as
at
17oC
(
22.02
mg/
L);
that
is,
a
smaller
amount
of
carbaryl
was
needed
to
induce
mortality
at
a
high
temperature.

Bridges,
C.
M.
and
R.
D.
Semlitsch.
2001.
Genetic
Variation
in
Insecticide
Tolerance
in
a
Population
of
Southern
Leopard
Frogs
(
Rana
sphenocephala):
Implications
for
Amphibian
Conservation.
Copeia
1:
7
­
13
In
a
study
investigating
the
amount
of
genetic
variability
in
tolerance
to
carbaryl
within
a
single
population
of
southern
leopard
frogs
(
Rana
sphenocephala),
time
to
death
was
measured
in
tadpoles
exposed
to
carbaryl
at
30
mg/
L.
Mortality
was
determined
at
3,
6,
9,
12,
18,
24,
36
and
48
hours
among
10
replicates
of
full­
and
half­
sibling
families.
Tadpoles
were
housed
in
250­
mL
glass
beakers
containing
200
mL.
Control,
solvent
(
acetone
0.5
mL/
L)
and
carbaryl
treated
solutions
were
prepared
using
well
water
(
pH
7.8,
hardness
286
mg/
L
as
CaCO3).
The
results
of
the
study
indicated
that
significant
differences
in
time
to
death
were
attributed
to
family
with
some
families
significantly
more
sensitive
than
others.
The
study
found
a
significant
amount
of
genetic
variation
for
tolerance
to
carbaryl
among
half­
sibling
famines
suggesting
that
this
population
may
have
the
ability
to
persist
in
the
presence
of
carbaryl
contamination.
The
data
also
indicated
that
smaller
tadpoles
were
more
tolerant
of
carbaryl
Boone,
M.
D.
and
R.
D.
Semlitsch.
2002.
Interactions
of
an
Insecticide
with
Competition
and
Pond
Drying
in
Amphibian
Communities.
Ecological
Applications
12
(
1):
307
­
316.

In
a
77­
day
mesocosm
study,
researchers
examined
the
effects
of
carbaryl
on
amphibians
in
terms
of
body
size,
length
of
larval
period,
and
survival
to
metamorphosis
when
exposed
to
carbaryl
early
in
the
larval
period.
The
study
units
consisted
of
fifty
1480­
L
polyethylene
ponds
(
1.85
m
in
diameter)
containing
1000
L
of
well
water
and
1
kg
of
leaf
litter.
The
study
manipulated
initial
larval
density,
i.
e.,
low
(
80)
and
high
(
240),
pond
hydroperiod,
(
constant
or
drying),
and
chemical
concentration
(
absent,
3.5
mg/
L,
5.0
mg/
L,
or
7.0
mg
carbaryl
/
L).
Frogs
species
included:
Southern
leopard
frog
(
Rana
sphenocephala),
plains
leopard
frog
(
R.
blairi),
and
the
Woodhouse
toad
(
Bufo
woodhousii).
The
results
suggest
that
for
Woodhouse
toads,
carbaryl
exposure
actually
increased
the
survival
of
the
frogs
by
roughly
30%
in
the
highest
treatment.
Toads
in
the
high­
density
ponds
showed
greater
survival
than
those
in
low­
density
ponds
at
the
highest
carbaryl
level.

For
Southern
and
plains
leopard
frogs,
carbaryl
treatment
did
not
have
a
significant
or
profound
influence
on
either
species.
For
green
frogs,
carbaryl
exposure
had
a
significant
effect
on
days
to
metamorphosis
with
tadpoles
in
the
chemical
treatments
generally
having
longer
larval
periods.
119
The
study
concluded
that
both
leopard
frog
species
may
be
less
affected
by
carbaryl
than
Woodhouse
`
s
toad..
Toads
show
a
dramatic
increase
in
survival
with
carbaryl
treatment.
The
authors
speculate
that
the
increase
in
survival
could
have
resulted
from
decreased
predation
by
newts
exposed
to
carbaryl,
or
more
likely,
a
competitive
release
from
zooplankton
in
the
presence
of
carbaryl.
In
general,
the
three
species
studied
showed
no
direct
negative
effect
when
exposed
to
carbaryl;
however,
poor
survival
in
the
control
ponds
may
have
confounded
the
test's
ability
to
detect
carbaryl
treatment
effects.
Additionally,
the
authors
speculate
that
since
the
test
animals
were
collected
from
agricultural
areas,
the
animals
may
have
been
more
tolerant
to
carbaryl.

Bridges,
C.
M.
2000.
Long­
term
Effects
of
Pesticide
Exposure
at
Various
Life
Stages
of
the
Southern
Leopard
Frog
(
Rana
sphenocephala).
Arch.
Environ.
Contam.
Toxicol.
39:
91
­
96.

In
a
study
to
determine
whether
chronic
exposure
of
tadpoles
to
carbaryl
affected
responses
at
metamorphosis
and
whether
the
effects
are
dependent
on
the
life
stage
at
which
individuals
are
exposed,
Southern
leopard
frogs
(
Rana
sphenocephala)
eggs,
embryos
and
tadpoles
were
exposed
to
control,
solvent
control
(
0.25
mL
acetone/
L),
0.16,
0.40
and
1.0
mg
carbaryl/
L.
Each
treatment
combination
was
replicated
10
times
(
total
n
=
250
tadpoles)
in
individual
1.5­
L
plastic
containers
filled
with
1
L
of
well
water
(
pH
7.8,
hardness
286
mg/
L
as
CaCO3;
temperature
21
±
1.5oC).
The
results
indicated
that
metamorphs
exposed
throughout
the
tadpole
stage
and
throughout
development
(
egg,
embryo,
tadpole)
experienced
significant
mortality
at
all
chemical
levels.
Additionally,
metamorphs
exposed
during
the
egg
stage
were
smaller
than
their
corresponding
controls.
Nearly
18%
of
individuals
exposed
to
carbaryl
during
development
exhibited
some
type
of
developmental
deformity
(
including
visceral
and
limb
malformations)
compared
to
less
than
1%
in
controls.

Bridges,
C.
M.,
F.
J.
Dwyer,
D.
K.
Hardesty,
and
D.
W.
Whites.
2002.
Comparative
Contaminant
Toxicity:
Are
Amphibian
Larvae
More
Sensitive
than
Fish?
Bull.
Enviorn.
Contam.
Toxicol.
69:
562
­
569.

In
a
study
designed
to
determine
the
LC50
of
Southern
leopard
frog
(
Rana
sphenocephala)
tadpoles
and
determine
whether
amphibians
are
more
sensitive
to
contaminants
than
fish,
three
replicates
(
containing
10
tadpoles
per
replicate)
for
each
of
six
test
concentrations
were
tested.
Tadpole
(
0.05
mg
±
0.008
mg)
mortality
was
recorded
after
6,
12,
24,
48,
72
and
96
hours.
The
96­
hr
LC50
was
then
compared
to
similar
values
on
rainbow
trout
(
Onchorynchus
mykiss),
fathead
minnow
(
Pimephales
promelas),
bluegill
sunfish
(
Lepomis
macrochirus)
and
boreal
toad
tadpoles
(
Bufo
boreas).
In
this
study,
tadpoles
(
96­
hr
LC50
=
8.4
mg/
L)
were
relatively
tolerant
to
carbaryl
compared
to
the
bluegill
sunfish
(
96­
hr
LC50
=
6.2
mg/
L),
fathead
minnow
((
96­
hr
LC50
=
5.21
mg/
L)
and
rainbow
trout
(
96­
hr
LC50
=
1.88
mg/
L).
The
only
species
that
was
less
sensitive
than
the
leopard
frog
was
the
Boreal
toad
(
96­
hr
LC50
=
12.31
mg/
L).
In
fact,
of
the
5
compounds
tested
(
4
nonylphenol,
carbaryl,
copper,
pentachlorophenol
and
permethrin)
only
copper
exhibited
enhanced
toxicity
to
the
leopard
frog.
For
the
remaining
organic
compounds,
the
toxicity
estimates
obtained
for
fish
proved
to
be
protective
for
amphibians.
The
report
notes
that
correlations
obtained
from
surrogate
species
and
leopard
frogs
suggest
that
rainbow
trout
may
be
the
most
appropriate
surrogate
fish
species
for
making
reference
to
anuran
tadpoles
as
their
LC50
values
for
many
contaminants
are
most
similar.
120
Bridges,
C.
M.
1997.
Tadpole
Swimming
Performance
and
Activity
Affected
by
Acute
Exposure
to
Sublethal
Levels
of
Carbaryl.
Environ.
Toxicol.
and
Chem.
16(
9):
1935
­
1939.

In
a
study
to
determine
the
effects
of
sublethal
concentrations
of
carbaryl
on
activity
level
and
swimming
performance
(
i.
e.,
sprint
speed
and
distance)
of
plains
leopard
frog
(
Rana
blairi)
tadpoles,
two
replicate
groups
of
five
3.8­
L
glass
jars
each
filled
with
2
L
of
well
water
were
used
to
test
single
tadpoles
(
approximately
20
mg)
to
control,
solvent
(
0.5
mL
acetone/
L),
3.5,
5.0
and
7.5
mg
carbaryl/
L.
Tadpoles
were
not
fed
24
hours
up
to
study
or
during
study.
Well
water
was
characterized
at
having
pH
of
7.8,
water
hardness
of
286
mg/
L
as
CaCO3
and
a
temperature
of
22
±
1oC.
Each
tadpole
was
observed
for
5
seconds
every
4
minutes
to
determine
swimming
activity
or
resting
activity
for
a
total
of
20
times
per
jar
initially.
Activity
was
also
examined
at
24,
48,
72
and
96
hours
after
which
time,
the
tadpoles
were
transferred
to
clean
water
and
their
activity
monitored
for
24­
and
48­
hr
post­
exposure.

Carbaryl
concentration
significantly
affected
the
time
tadpoles
spent
being
active.
At
48­
hrs
post
exposure,
activity
of
tadpoles
in
the
control
and
3.5
mg/
L
treatments
were
not
significantly
difference.
Some
recovery
of
tadpoles,
although
not
significant,
was
noted
in
all
treatments
except
the
7.2
mg/
L
group.
Additionally,
control
tadpoles
exhibited
greater
sprint
speed
than
carbaryltreated
tadpoles
and
the
controls
swam
greater
distances
than
their
carbaryl­
treated
counterparts.

Bridges,
C.
M.
and
M.
D.
Boone
2003.
The
Interactive
Effects
of
UV­
B
and
Insecticide
Exposure
on
Tadpole
Survival,
Growth
and
Development.
Biological
Conservation
In
Press.

In
a
study
of
the
Southern
leopard
frog
(
Rana
sphenocephala),
the
interaction
of
three
ultraviolet
B
(
UV­
B)
radiation
levels
and
carbaryl
exposure
was
explored.
Artificial
ponds
(
1480
L)
consisting
of
polyethylene
cattle
tanks
were
willed
with
1000
L
of
well
water
and
1
kg
of
leaf
litter
and
inoculated
with
algae
from
a
local
pond.
Ponds
were
allowed
to
equilibrate
for
45
days.
One
day
prior
to
the
start
of
the
study,
45
tadpoles
were
added
to
each
pond.
Dissolved
oxygen
(
range
2.5
­
4.9
mg/
L),
pH
(
range
6.9
­
7.1)
and
temperature
(
16.4
­
16.9oC)
were
monitored
the
day
of
Sevin
(
22.5%
carbaryl)
application;
the
nominal
carbaryl
concentration
was
5
mg/
L.
Differing
pond
lids
(
plastic
wrap,
Mylar
D
and
Polycarbonate)
served
as
filters
to
provide,
high
(
ambient),
medium
(
roughly
50%)
and
low
(
roughly10%)
UV­
B
exposure
intensities.
Control
ponds
were
uncovered
(
ambient
UV­
B).

UV­
B
intensity
significantly
increased
survival
to
metamorphosis.
The
presence
of
carbaryl
significantly
increased
the
mass
at
metamorphosis;
tadpoles
in
tanks
containing
carbaryl
were
20%
larger
than
those
in
tanks
without
carbaryl.
Chlorophyll
concentrations
in
ponds
with
carbaryl
was
347%
greater
than
in
control
ponds.
121
Bridges
C.
M.
and
R.
D.
Semlitsch.
1999.
Variation
in
Pesticide
Tolerance
of
Tadpoles
Among
and
Within
Species
of
Ranidae
and
Patterns
of
Amphibian
Decline.
Conservation
Biology14(
5):
1490
­
1499.

In
a
series
of
studies
designed
to
assess
the
degree
of
variation
in
response
to
carbaryl
among
and
within
species
of
frogs
in
the
family
Ranidae,
the
tolerance
to
carbaryl
was
tested
among
nine
species
and
among
Southern
leopard
frogs.
The
study
was
conducted
over
3
years
by
collecting
species
(
red­
legged
frog
(
Rana
aurora),
yellow­
legged
frog
(
R.
boylii),
spotted
frog
(
R.
pretiosa),
wood
frog
(
R.
sylvatica),
Pickeral
frog
(
R.
palustris),
plains
leopard
frog
(
R.
blairi),
northern
leopard
frog
(
R.
clamitans)
,
and
crayfish
frog
(
R.
areolata)
from
across
the
United
States.
At
least
three
egg
masses
from
each
species.
To
examine
variation
in
response
among
populations
of
southern
leopard
frogs
(
R.
sphenocephala),
10
populations
were
sampled.
Tadpoles
from
separate
egg
masses
from
each
population
were
tested
to
determine
the
within­
population,
i.
e.,
among­
family,
variation
on
all
but
two
(
Illinois
and
Texas)
collection
sites.
Time­
to­
death
assays
were
conducted
by
placing
individual
tadpoles
in
250­
mL
glass
beakers
containing
200
ml
of
30
mg/
L
carbaryl
in
well
water
with
0.1
ml
acetone
as
a
co­
solvent.
All
beakers
were
held
at
22
±
1oC
and
tadpoles
were
not
fed
during
exposure.
Each
family
was
replicated
10
times
except
in
three
cases.
Mortality
was
determined
at
3,
6,
9,
12,
18,
24,
36,
48
and
60
hours.
Activity
changes
were
also
tested
using
2.5
mg/
L
carbaryl.
Each
family
was
replicated
10
times
with
one
tadpole
per
replicate
except
in
three
cases
where
there
were
too
few
animals.
Activity
(
presence
or
absence
of
tail
movement)
was
monitored
after
24
hours
of
exposure.
Each
observation
was
made
for
5
seconds
and
a
total
of
20
observations
were
recorded
per
tadpole.

There
were
significant
differences
(
p
<
0.0001)
in
time
to
death
among
the
nine
ranid
species.
From
most
to
least
sensitive:
Rana
sylvatica
>
R.
areolata
>
R.
boyii
>
R.
clamitans
>
R.
blairi
>
R.
sphenocephala
>
R.
palustris
>
R.
pretiosa
>
R.
aurora.
Mean
time
to
death
varied
from
5
to
34
hours.
R.
sylvatica
was
significantly
more
sensitive
than
all
other
species.

There
were
significant
differences
among
species
with
respect
to
overall
activity
(
P
<
0.0002);
however,
there
was
no
significant
interaction
of
treatment
and
species;
the
lack
of
interaction
indicated
that
all
species
were
equally
sensitive
to
carbaryl
exposure.

Time
to
death
significantly
differed
among
southern
leopard
frog
populations
in
each
of
the
3
years.
Populations
in
Texas,
Mississippi,
South
Carolina,
and
one
from
Missouri
were
most
tolerant,
whereas
populations
from
Virginia
and
Illinois
and
three
from
Missouri
were
most
sensitive.
In
two
of
the
years
there
was
a
significant
population
by
treatment
interaction
indicating
that
populations
were
differentially
sensitive
to
carbaryl
exposure
122
APPENDIX
D3.
REVIEW
OF
RELYEA
AND
MILLS
PAPER
U.
S.
ENVIRONMENTAL
PROTECTION
AGENCY
WASHINGTON,
DC
20460
OFFICE
OF
PREVENTION,
PESTICIDES
AND
TOXIC
SUBSTANCES
MEMORANDUM
PC
Code
No.
129106
DP
Barcode
:
D283014
SUBJECT:
EFED
Review
of
Relyea
Paper
Entitled
"
Predator­
induced
stress
makes
the
pesticide
carbaryl
more
deadly
to
gray
treefrog
tadpoles
(
Hyla
versicolor)
"

TO:
Anthony
Britten,
Chemical
Review
Manager
Betty
Shackleford,
Product
Manager
Special
Review
and
Reregistration
Division
FROM:
Thomas
M.
Steeger,
Ph.
D.,
Senior
Biologist
Environmental
Risk
Branch
IV/
EFED
(
7507C)

Through:
Betsy
Behl,
Branch
Chief
Environmental
Risk
Branch
IV/
EFED
(
7507C)

The
Environmental
Fate
and
Effects
Division
(
EFED)
has
completed
its
review
of
the
research
article
entitled
"
Predator­
induced
stress
makes
the
pesticide
carbaryl
more
deadly
to
gray
treefrog
tadpoles
(
Hyla
versicolor)"
published
in
the
February
2001
issue
of
the
Proceedings
of
the
National
Academy
of
Science.
The
paper,
authored
by
Rick
Relyea
and
Nathan
Mills
(
Department
of
Biology,
University
of
Pittsburgh)
provides
data
demonstrating
that
prolonged
sub­
acute
exposure
of
gray
treefrog
tadpoles
to
carbaryl
at
3
to
4%
of
the
reported
LC50
(
2.5
­
20.6
mg/
L)
killed
10
to
60%
of
the
tadpoles.
Furthermore,
the
paper
claims
that
in
the
presence
of
"
predatory
cues"
carbaryl
was
2
to
4
times
more
lethal
to
tadpoles.
The
authors
conclude
that
"
under
more
realistic
conditions
of
increased
exposure
times
and
predatory
stress
[
simulated
in
their
study],
current
application
rates
for
carbaryl
can
potentially
devastate
gray
treefrog
populations"
and
that
given
the
common
mechanism
of
action,
i.
e.,
acetylcholinesterase
inhibition,
of
carbaryl
with
other
widely
used
pesticides
(
carbamates
and
organophosphates),
the
"
negative
impacts
may
be
widespread
in
nature."

While
EFED
concurs
that
biotic
and
abiotic
effects
do
impact
the
toxicity
of
chemicals,
we
do
not
concur
with
the
author's
contention
that
their
protocol
is
indicative
of
"
more
realistic
ecological
conditions"
than
EFED's
current
battery
of
acute
and
chronic
toxicity
tests;
all
of
these
studies
are
conducted
under
rigidly
controlled
laboratory
conditions
and
are
not
intended
to
be
representative
of
all
of
the
variables
that
may
affect
the
toxicity
of
a
compound
in
the
field.
Furthermore,
the
EFED
environmental
fate
and
ecological
risk
assessment
chapter
on
carbaryl
123
submitted
in
support
of
the
re­
registration
eligibility
decision
does
attempt
to
account
for
carbaryl's
risk
to
amphibians
and
is
to
some
extent
protective
to
amphibians
at
the
concentrations
discussed
in
the
Relyea
and
Mills
paper.
However,
while
the
authors
are
correct
that
a
cumulative
assessment
of
the
effects
of
all
chemicals
acting
through
a
similar
mode
of
action
may
be
more
realistic,
the
logistics
of
conducting
such
an
evaluation
would
require
additional
resources
than
are
currently
available
in
EFED.

The
EFED
environmental
fate
and
ecological
risk
assessment
chapter
on
carbaryl
contains
both
acute
and
chronic
amphibian
toxicity
data
(
see
Attachment
1
for
excerpt
on
amphibians
from
chapter).
Although
bullfrogs
(
Rana
catesbeiana)
are
relatively
inured
(
LD50
>
4,000
mg/
Kg)
to
carbaryl
on
an
acute
oral
exposure
basis,
leopard
frog
tadpoles
(
Rana
blairi)
exhibited
a
90%
reduction
in
swimming
activity
at
carbaryl
concentrations
in
the
3.5
­
7.2
mg/
L
range.
The
chapter
notes
that
such
an
impairment
would
likely
render
the
tadpoles
[
prey]
vulnerable
to
predation
provided
the
predators
were
not
similarly
impaired.
Furthermore,
the
chapter
notes
that
chronic
exposure
of
southern
leopard
frogs
(
Rana
sphenocephala)
to
carbaryl
led
to
developmental
and
growth
effects
and
that
the
long­
term
effects
of
short­
term
carbaryl
exposures
to
amphibians
during
critical
life
stages
was
uncertain
and
could
potentially
lead
to
population­
level
effects.
Therefore,
the
EFED
risk
assessment
does
discuss
qualitatively
the
potential
susceptibility
of
amphibians
following
both
acute
and
chronic
exposure
to
carbaryl.

EFED
does
not
typically
evaluate
risk
to
aquatic
animals
on
a
species­
by­
species
or
class­
byclass
basis
but
rather
relies
on
surrogate
species
as
representatives
of
broad
ranges
of
aquatic
organisms.
As
with
most
screening­
level
risk
assessments
conducted
by
EFED,
the
carbaryl
chapter
used
fish
toxicity
data
as
a
surrogate
for
amphibians.
Toxicity
values
for
freshwater
fish
ranged
from
0.25
to
20
mg/
L;
the
most
sensitive
species,
i.
e.,
Atlantic
salmon
(
Salmo
salar)
with
a
96­
hour
LC50
value
of
0.25
mg/
L,
was
selected
for
calculating
risk
quotient
(
RQ)
values
used
in
EFED's
assessment
of
ecological
risk
to
freshwater
vertebrates.
The
salmon
LC50
value
represents
roughly
10%
of
the
lower
LC50
range
(
2.5
to
20.6
mg/
L)
for
amphibians
reported
in
Relyea
and
Mills
paper.
Given
that
EFED's
levels
of
concern
(
LOC),
i.
e.,
the
ratio
of
expected
environmental
concentrations
(
EEC)
to
the
LC50
value,
for
endangered
is
0.05,
if
the
EEC
was
greater
than
0.01
mg/
L,
it
would
exceed
EFED's
LOC.
Therefore,
the
ecological
risk
assessment
for
aquatic
vertebrates
is
protective
for
species
with
96­
hour
LC50
values
greater
than
0.01
mg/
L.
(
0.04%
of
the
range
reported
by
Relyea
and
Mills).

EFED
concurs
with
the
study
authors
that
biotic
and
abiotic
effects
can
impact
the
toxicity
of
pesticides
and
that
it
is
difficult
to
account
for
these
effects
on
the
basis
of
the
limited
laboratory
tests
that
are
typically
available
for
evaluating
the
effects
of
pesticides.
EFED
also
concurs
with
the
authors
that
chemicals
with
similar
modes
of
action
may
have
additive
toxicities
and
that
commutative
assessments
may
better
account
for
toxicity;
however,
the
practicality
of
implementing
such
evaluations
is
limited
for
screening­
level
assessments.

EFED
is
uncertain
regarding
how
representative
the
Relyea
and
Mills
article
is
of
field
effects
though
or
of
the
direct
effects
of
carbaryl
and
predatory
cues.
The
experimental
design
included
10
tadpoles
in
10­
liter
polyethylene
tubs
containing
filtered
tapwater.
In
a
10­
day
static
renewal
study,
they
changed
water
on
days
3
and
7.
In
16­
day
static­
renewal
exposures,
they
changed
water
every
124
4
days.
Water
quality
parameters
(
dissolved
oxygen,
temperature,
pH
and
ammonia)
were
measured
midway
through
the
16­
day
exposure
studies.
Predator
treatments
consisted
of
a
larval
salamander
(
Ambystoma
maculatum)
housed
within
a
250­
ml
plastic
cup,
covered
with
a
fiberglass
window
screening,
in
each
of
the
exposure
tanks;
controls
consisted
of
the
plastic
cup
alone.
Nominal
carbaryl
concentrations
ranged
from
0.045
to
0.54
mg/
L;
both
negative
and
solvent
(
acetone)
controls
were
run
concurrently.
The
results
demonstrate
that
increased
ammonia
concentrations
were
associated
(
P<
0.0001,
range
of
means
=
0.21
­
0.99
mg/
L)
with
carbaryl
concentration,
an
effect
attributed
to
the
presence
of
dead
tadpoles
and
excess
unconsumed
food.
A
regression
analysis
of
survival
against
ammonia
was
significant
(
P
<
0.001,
but
not
particularly
predictive
(
R2
=
0.395).
Predators
had
no
effect
on
ammonia
(
P
>
0.1)
and
only
had
small
effects
on
oxygen
and
pH
(
9%
decrease
in
oxygen,
P
<
0.0001;
5%
decrease
in
pH,
P
=
0.019).
Given
that
water
quality
parameters
were
only
measured
midway
through
the
study
and
that
both
tadpoles
and
thus
feeding
rates
were
likely
increasing
throughout
the
study,
ammonia
levels
may
have
been
considerably
higher
toward
the
end
of
the
studies.
Thus
it
is
unclear
whether
ammonia,
pH
and
dissolved
oxygen
had
an
effect
on
the
toxicity
of
carbaryl
to
tadpoles.
It
is
noteworthy
that
the
Relyea
and
Mills
data
showed
precipitous
declines
in
tadpole
survival
after
5
days
of
exposure.

Although
it
is
difficult
to
design
a
study
that
can
accurately
reflect
field
conditions
and
particularly
predator­
prey
relationships,
EFED
is
not
convinced
that
the
Relyea
and
Mills
study
could
be
interpreted
as
more
representative
of
field
conditions.
Typically,
prey
demonstrate
predator
avoidance
behavior
in
the
presence
of
a
perceived
threat.
In
this
study,
tadpoles
were
unable
to
escape
their
perceived
threat;
predatory
cues,
i.
e.,
seeing
a
predator
(
visual
cues)
may
have
protracted
their
response
well
beyond
the
chemical
cues
released
following
the
salamander's
consumption
of
tadpoles.
It
is
questionable
whether
tadpoles
would
have
remained
in
view
of
a
potential
predator
under
more
realistic
conditions.

In
refined
ecological
assessments,
EFED
oftentimes
has
mesocosm
study
data
available
to
assess
the
risk
of
pesticides
under
"
field
conditions".
These
studies,
while
considerably
more
expensive
that
the
Relyea
and
Mills
protocol,
may
represent
the
most
accurate
reflection
of
controlled
field
studies.
It
is
interesting
to
note
though
that
while
mesocosm
studies
may
yield
LC50
values
similar
to
laboratory
studies,
they
rarely
provide
LC50
values
showing
enhanced
toxicity.
Test
species
within
these
studies
are
better
able
to
rely
on
compensatory
mechanism
to
shield
themselves
from
the
toxic
effects
of
chemicals.

In
addition,
the
environmental
fate
of
pesticides
is
often
different
under
field
conditions.
Under
alkaline
conditions,
i.
e.,
pH
>
7,
carbaryl
undergoes
hydrolysis
with
half­
lives
ranging
from
0.15
to
12
days.
While
Relyea
and
Mills
accurately
note
carbaryl's
susceptibility
to
hydrolysis,
they
fail
to
mention
that
under
aerobic
conditions,
carbaryl
is
also
microbially
degraded
in
the
aquatic
environment
with
a
half
life
of
approximately
5
days.
It
is
likely
that
gray
treefrogs
in
the
Relyea
and
Mills
study
were
exposed
to
carbaryl
concentrations
considerably
lower
than
nominal
after
3
to
4
days.
Thus
the
actual
exposure
regime
may
have
been
more
representative
of
pulsed
exposures
to
declining
concentrations
of
carbaryl
and
increasing
concentrations
of
ammonia.
While
it
is
clear
that
predators
had
an
effect
on
the
response
of
tadpoles
to
the
exposure
regime,
EFED
does
not
concur
that
the
test
results
are
representative
of
the
effects
of
predation
on
carbaryl
toxicity
alone.
125
EFED
concurs
with
Relyea
and
Mills
that
both
biotic
and
abiotic
factors
impact
the
toxicity
of
pesticides
and
that
current
screening
methods
do
not
account
for
the
full
range
of
these
effects
nor
do
screening
level
assessments
take
into
account
aggregate
effects
from
exposure
to
chemicals
with
similar
modes
of
action.
Screening­
level
assessments
attempt
to
identify
where
EFED's
LOCs
are
exceeded
and
where
EFED
has
uncertainties
regarding
risk.
With
respect
to
amphibians,
the
chapter
discusses
the
likelihood
of
acute
and
chronic
effects
from
current
uses
of
carbaryl.
126
Attachment
1.
Excerpt
on
Amphibians
from
the
Initial
Draft
Environmental
Fate
and
Ecological
Risk
Assessment
for
the
Reregistration
of
Carbaryl
Chapter
According
to
an
available
supplemental
study
with
a
50%
carbaryl
formulation,
the
LD50
for
the
bullfrog
(
Rana
catesbeiana)
is
greater
than
4,000
mg/
kg,
or
practically
nontoxic
(
MRID
00160000).
A
single
acute
exposure
of
plains
leopard
frog
tadpoles
(
Rana
blairi)
to
carbaryl
concentrations
in
the
3.5
­
7.2
mg/
L
range
led
to
a
90%
reduction
in
swimming
activity,
including
sprint
speed
and
sprint
distance,
activity
ceasing
completely
at
7.2
mg/
L
(
Bridges
1997).
This
reduction
in
activity
and
swimming
performance
may
result
in
increased
predation
rates
and,
because
activity
is
closely
associated
with
feeding,
may
result
in
slowed
growth
that
could
lead
to
failure
to
complete
metamorphosis.
Acute
exposure
to
low
carbaryl
levels
may
not
only
affect
immediate
survival
of
tadpoles
but
also
impact
critical
life
history
functions.

On
a
chronic
basis,
carbaryl
has
been
shown
to
have
the
potential
to
adversely
affect
amphibians.
In
a
recent
study,
nearly
18%
of
southern
leopard
frog
(
Rana
sphenocephala)
tadpoles
exposed
to
carbaryl
during
development
exhibited
some
type
of
developmental
deformity,
including
both
visceral
and
limb
malformations,
compared
to
a
single
deformed
(<
1%)
control
tadpole
demonstrating
that
carbaryl
exposure
can
result
in
amphibian
deformities
(
Bridges,
2000).
Although
the
length
of
the
larval
period
was
the
same
for
all
experimental
groups,
tadpoles
exposed
throughout
the
egg
stage
were
smaller
than
their
corresponding
controls.
Because
exposure
to
nonpersistent
chemicals
may
last
for
only
a
short
period
of
time,
it
is
important
to
examine
the
long­
term
effects
that
short­
term
exposure
has
on
larval
amphibians
and
the
existence
of
any
sensitive
life
stage.
Any
delay
in
metamorphosis
or
decrease
in
size
at
metamorphosis
can
impact
demographic
processes
of
the
population,
potentially
leading
to
declines
or
local
extinction.
127
APPENDIX
E1.
SECTION
24c
USE
OF
CARBARYL
TO
CONTROL
BURROWING
SHRIMP
Although
Texas
recently
applied
for
a
Section
24c
(
Supplemental
Label
of
the
Amended
Federal
Insecticide,
Fungicide
and
Rodenticide
Act)
for
use
of
carbaryl
in
shrimp
culture
ponds
which
drain
into
estuaries
along
the
Gulf
of
Mexico,
Washington
is
currently
the
only
state
sanctioning
the
use
of
carbaryl
in
estuarine/
marine
waters
for
control
of
burrowing
shrimp
on
mud
flats
used
for
oyster
culture.
The
use
of
carbaryl
to
control
burrowing
shrimp
has
generated
concern
regarding
the
effects
of
the
chemical
in
the
immediate
application
area
and
the
movement
(
drift)
and
potential
subsequent
effects
of
carbaryl
to
nontarget
sites.

The
commercial
oyster
fishery
in
Willapa
Bay
has
been
in
existence
since
the
1800'
s.
Originally
sustained
by
the
indigenous
Olympia
oyster,
Ostrea
lurida,
the
fishery
now
relies
on
the
Pacific
oyster
(
Crassostrea
gigas).
Over
the
years,
increasing
numbers
of
indigenous
burrowing
shrimp
(
ghost
shrimp,
Callianassa
sp.,
and
mud
shrimp
Upogebia
pugettensis)
have
rendered
tidal
mud
flats
in
the
bay
less
amenable
to
traditional
oyster
culture
methods.
The
activity
of
burrowing
shrimp
results
in
mud
too
soft
to
support
oysters
and
as
a
consequence
oysters
settle
into
the
mud
and
suffocate.
Since
1963
Washington
has
issued
permits
to
oyster
growers
to
apply
carbaryl
to
sheltered
tidal
areas
and
since
1994
carbaryl
has
been
sprayed
annually
on
600
acres
in
Willapa
Bay
and
200
acres
in
Grays
Harbor
at
a
rate
of
7.5
­
8
lbs/
acre.
Although
lower
application
rates
have
been
attempted,
they
were
not
effective
at
penetrating
tidal
muds
to
a
sufficient
depth
to
kill
burrowing
shrimp
and
thus
retreatment
was
required
in
subsequent
years.
Carbaryl
is
applied
as
a
wettable
powder
to
tidelands
at
low
low
[
Spring]
tide
primarily
by
helicopter;
however,
hand
spraying
is
used
in
some
instances.
The
label
restricts
aerial
applications
within
200
feet
of
a
channel
or
slough;
hand
spraying
is
prohibited
within
50
feet
of
a
channel
or
slough.

Willapa
Bay
is
located
on
the
Pacific
coast
of
Washington
State
and
encompasses
79,000
acres
at
mean
high
tide
representing
a
volume
of
56.6
million
ft3
of
water.
The
tidal
range
in
Willapa
Bay
is
from
14
to
16
feet
and
roughly
45%
(
25.4
million
ft3)
of
the
water
in
the
bay
is
exchanged
into
the
Pacific
Ocean
during
a
complete
tidal
cycle.
The
relatively
shallow
bay
has
more
than
50%
its
acreage
exposed
at
low
tide
with
much
of
the
remaining
surface
area,
except
for
channels,
covered
by
1
to
6
feet
of
water.
Channel
depths
range
from
30
to
50
feet
with
maximum
depths
75­
to
77­
ft
below
mean
low
water.
Willapa
Bay
opens
to
the
Pacific
Ocean
at
its
northwestern
corner
through
a
broad
shallow
pass
about
6
miles
wide
between
Cape
Shoalwater
and
Leadbetter
Point.
Major
tributaries
to
the
bay
include
the
Willapa
River
to
the
north
and
the
Naselle
River
to
the
south,
together
draining
an
area
of
461,280
acres
in
Pacific
County,
Washington
.
Rainfall
in
the
Willapa
Bay
area
ranges
from
85
­
100
inches
per
year
resulting
in
mean
annual
runoff
for
the
entire
basin
of
3.4
million
acre­
feet;
mean
maximum
discharge
at
the
mouth
of
Willapa
Bay
is
estimated
at
1.6
million
ft3/
second.
Mean
daily
runoff
is
estimated
to
be
about
0.004%
of
the
total
volume
of
the
bay
(
Hedgpeth,
J.
W.
and
S.
Obrebski
1981.
Willapa
Bay:
A
Historical
Perspective
and
a
Rationale
for
Research.
Coastal
Ecosystems
Project,
Office
of
Biological
Services,
U.
S.
Fish
and
Wildlife
Service
FWS/
OBS­
81/
03).

The
entrance
of
Willapa
Bay
is
approximately
28
miles
north
of
the
mouth
of
the
Columbia
River
and
approximately
11
miles
south
of
the
entrance
to
Grays
Harbor.
Flushing
rates
(
tidal
prism)
128
in
Willapa
Bay
are
influenced
by
conditions
in
the
ocean.
During
the
summer,
strong
northwesterly
winds
bring
upwelled
water
from
the
ocean
into
the
bay
and
promotes
rapid
turnover.
Strong
Pacific
storms
also
promote
mixing.
At
other
times
though,
freshwater
outflow
from
the
Columbia
River
acts
as
a
discrete
water
mass
moving
northward
along
the
Pacific
coast
and
may
prevent
mixing
from
occurring
in
the
bay
(
Hedgpeth
and
Obrebski
1981).

To
address
concerns
regarding
the
mobility/
persistence
of
carbaryl
and
it
effects
on
nontarget
animals,
a
series
of
studies
were
undertaken
as
a
requirement
of
the
permitting
process.
These
studies
have
been
reviewed
by
EFED
(
APPENDIX
E1).
Except
for
more
recent
studies
conducted
by
Washington
State
University
and
the
Washington
Department
of
Ecology,
much
of
the
older
(
pre­
1996)
data
had
procedural
problems
that
limited
the
utility
of
the
data.
The
more
recent
data
indicate
that
carbaryl
residues
in
the
water
column
were
generally
at
or
below
Washington
state's
projected
effect
threshold
of
0.1
µ
g/
L
Although
large
carbaryl
applications
can
affect
water
quality
in
areas
distant
from
spray
sites,
the
Washington
Department
of
Ecology
concluded
that
"
no
widespread
effects
from
carbaryl
would
be
expected
in
Willapa
Bay
after
the
end
of
the
[
carbaryl]
application
period.".

Additional
studies
have
also
been
submitted
examining
potential
drift
and
long­
term
effects
of
carbaryl
in
Willapa
Bay
(
APPENDIX
E2).
Studies
have
been
undertaken
to
examine
recovery
of
treated
sediments
(
Mazzone
and
McNamara);
however,
the
data
underscore
the
difficulty
in
conducting
well­
designed
field
studies
that
account
for
the
many
sources
of
variability
that
can
affect
a
study's
ability
to
establish
causality.
Insufficient
detail
is
provided
in
the
Mazzone
and
McNamare
study
to
suggest
though
that
carbaryl
applications
to
control
burrowing
shrimp
in
selected
sites
in
the
bay
are
likely
to
exhaust
aquatic
life
within
the
bay.
Given
that
the
reapplication
interval
is
roughly
six
years
and
the
current
study
at
best
demonstrates
that
after
two
years
a
similar
range
of
species
exist
in
treated
and
untreated
sites
(
that
may
or
may
not
be
comparable),
there
is
no
conclusive
evidence
to
support
concerns
that
carbaryl
treatments
are
reducing
the
overall
"
natural
productivity"
of
Willapa
Bay.
Although
a
report
by
Felsot
and
Ruppert
(
2002)
suggests
that
carbaryl
residues
may
partition
to
sediment,
persist
there
for
extended
periods
of
time,
and
serve
as
a
sink
for
carbaryl
reentering
the
water
column
for
as
much
as
year
post­
application,
these
data
are
not
consistent
with
previous
studies
in
Willapa
Bay
nor
the
environmental
fate
data
reported
in
this
document.
Therefore,
the
source
of
preapplication
carbaryl
residues
as
high
as
0.7
µ
g/
L
is
uncertain.
In
2002,
a
total
of
810.5
acres
and
186
acres
were
treated
in
Willapa
Bay
and
Grays
Harbor,
respectively.
As
part
of
the
National
Pollutant
Discharge
Elimination
System
(
NPDES)
permit
program,
established
under
Section
402
of
the
Clean
Water
Act
prohibiting
unauthorized
discharge
of
pollutants
from
point
sources,
monitoring
was
conducted
to
document
acute
and
chronic
exposure
potential.
Acute
samples
were
collected
at
the
first
falling
tide
at
least
24
hours
following
the
final
treatment
within
a
sample
area
and
samples
for
chronic
analysis
were
taken
at
the
first
falling
tide
at
least
30
days
after
final
treatments.
Acute
monitoring
data
revealed
carbaryl
concentration
as
high
as
5.3
µ
g/
L
while
3
out
of
22
(
14%)
of
the
chronic
monitoring
samples
had
carbaryl
levels
(
range
0.58
­
1.25
µ
g/
L)
exceeding
detection
limits
(
Booth
et
al.
2002).
Based
on
2002
monitoring
data
collected
by
the
Shoalwater
Bay
Environmental
Research
Laboratory
(
docket
number
OPP­
2002­
0138­
052),
carbaryl
residues
outside
of
application
areas
peaked
at
1.4
µ
g/
L
on
July
26
and
again
at
1.6
µ
g/
L
three
days
later
following
carbaryl
applications
on
July
25
and
July
27.
These
data
are
consistent
with
a
Washington
Department
of
Ecology
study
showing
that
carbaryl
is
frequently
129
0
20
40
60
80
100
0
500
1000
1500
2000
2500
3000
Carbaryl
(
ug/
L)
Percent
of
Total
Species
Brown
shrimp
Glass
shrimp
Pink
shrimp
Fairy
shrimp
Blue
crab
Eastern
oyster
Sheepshead
Minnow
24­
hour
acute
exposure
level
Figure
11.
Cumulative
percent
distribution
of
acute
LC50
values
in
µ
g/
L
(
ppb)
for
estuarine
marine
fish
and
invertebrate
exposed
to
carbaryl.
The
red
arrow
shows
point
along
curve
for
an
exposure
of
5
ug/
L.

0
200000
400000
600000
800000
1000000
1200000
1400000
1600000
1965
1970
1975
1980
1985
1990
1995
2000
2005
Year
Total
Landings
(
Pounds)

Figure
12.
Total
landings
of
crab
in
pounds
harvested
by
year
from
Willapa
Bay,
Washington.
Source:
Washington
Department
of
Fish
and
Wildlife
2003.
detected
up
to
4
days
after
application
to
oyster
beds
and
that
carbaryl
is
transported
several
miles
from
the
site
of
application.

Based
on
a
cumulative
effects
distribution
of
acute
L
C
5
0
v
a
l
u
e
s
f
o
r
estuarine/
marine
species
(
Figure
11),
at
maximum
reported
peak
values
(
5.3
µ
g/
L)
after
24
hours,
less
than
28%
of
the
total
species
would
likely
be
affected
in
terms
of
acute
mortality.
Although
24­
hr
post­
application
mortality
is
expected
to
be
low
in
treatments
sites,
aquatic
a
n
i
m
a
l
s
(
f
i
s
h
a
n
d
invertebrates)
entrapped
in
shallow
pools
by
the
outgoing
tide
and
in
the
immediate
treatment
area
are
likely
to
experience
100%
mortality
the
day
of
treatment.
Observations
by
members
of
the
Shoalwater
Bay
Indian
Tribe
(
personal
communication
Gary
Burns,
Environmental
Programs
Director,
Shoalwater
Bay
Environmental
Research
Laboratory
2003)
on
the
day
of
treatment
report
extensive
mortality
of
crustaceans
and
in
particular
crabs,
which
constitute
a
subsistence­
level
fishery
for
the
Shoalwater
Bay
Indian
reservation
members.
These
observations
are
consistent
with
data
(
Stonic
1999)
indicating
that
Dungeness
crab
(
Cancer
magister)
larvae
would
be
particularly
sensitive
to
carbaryl
exposure
and
that
the
number
of
crabs
killed
by
carbaryl
in
treated
areas
has
increased
as
the
number
of
acres
treated
each
year
has
increased
(
Washington
Department
of
Ecology
1987).
Total
crab
landings
per
year
from
Willapa
Bay
(
Figure
12)
appear
to
fluctuate
on
a
10
to
15
year
cycle
and
have
ranged
from
169
thousand
pounds
to
1.4
million
pounds;
on
average,
515
thousand
pounds
are
harvested
annually.
Since
a
precipitous
(
83%)
decline
in
harvest
in
1997,
subsequent
years
have
yielded
a
steady
increase
in
annual
harvest.
Harvest
in
2002
(
976,870
lbs)
was
roughly
double
the
annual
130
average.
Given
that
carbaryl
application
to
the
bay
have
been
relatively
consistent
over
the
years,
the
information
on
crab
harvest
suggests
that
crab
recruitment
is
not
well
correlated
with
carbaryl
applications.

Furthermore,
age
0+
crabs
placed
on
mud
flats
24­
hrs
after
application
of
carbaryl
and
monitored
for
14
days
did
not
differ
in
mortality
rate
from
controls
(
Feldman
et
al.
2000);
the
study
indicated
that
young
crabs
were
capable
of
recolonizing
oyster
grounds
shortly
after
treatment.
The
risks
to
crabs
age
1+
and
2+
foraging
on
animals
immobilized
by
carbaryl
treatments
appeared
to
be
greatest
during
the
first
24
hours
then
declined
rapidly;
this
is
consistent
with
data
showing
carbaryl
residues
in
tissues
of
burrowing
shrimp
treated
with
carbaryl
declined
by
90%
after
24
hours.

In
general,
although
some
species
are
adversely
affected
by
carbaryl
treatments
on
a
shortterm
basis,
re­
colonization
by
bedload
transport
and
rapid
reproduction
is
viewed
as
largely
offsetting
impacts
resulting
from
carbaryl
application
(
Feldman
et
al.
2002).
Ironically,
the
productive
oyster
culture
in
the
bay
is
viewed
by
some
as
actually
improving
environmental
conditions
through
the
filter­
feeding
activity
of
these
animals,
the
refuge
that
the
oyster
shells
provide
for
attachment
of
epibionts
and
protection
for
juvenile
fish
and
invertebrates.
Juvenile
crab
densities
have
been
shown
to
be
significantly
higher
in
these
habitats
compared
to
areas
occupied
by
large
populations
of
burrowing
shrimp
(
Dumbauld
et
al.
1998).

With
an
application
rate
of
8
lbs
to
the
acre
and
assuming
that
the
tidal
flats
are
eventually
covered
by
6
feet
of
water
at
high
tide,
carbaryl
would
be
theoretically
diluted
in
1.96
x
106
gallons
of
water
corresponding
to
a
carbaryl
concentration
of
approximately
0.5
parts
per
million
(
0.5
mg/
L).
Based
on
the
environmental
fate
properties
of
carbaryl,
the
chemical
is
expected
to
undergo
relatively
rapid
hydrolysis
(
t
½
=
10
hrs
at
pH
8.4)
in
an
estuarine/
marine
environment
while
undergoing
considerable
dilution
from
successive
tides.
The
fact
that
on­
site
monitoring
24
hours
postapplication
indicates
carbaryl
concentrations
were
detected
at
a
maximum
of
5
parts
per
billion
(
0.005
mg/
L)
suggests
that
carbaryl
is
rapidly
dissipating
from
application
sites
and
that
its
potential
to
exert
ecological
effects
is
diminished.
While
EFED
recognizes
that
acute
mortality
in
the
immediate
application
site
may
be
near
100%
for
aquatic
animals
trapped
in
tide
pools
and/
or
living
in
benthic
sediments,
the
potential
for
off­
site
effects
and
overall
impact
to
Willapa
Bay
as
a
whole
appears
limited.
This
is
based
on
the
fact
that
roughly
1%
of
the
total
acres
(
79,000
acres)
of
the
bay
are
treated
during
any
given
year,
the
treatments
are
dispersed
over
several
months
depending
on
low
low
tide
schedules
and
that
during
a
complete
tidal
cycle
(
low
low
tide
to
high
high
tide),
as
much
as
25.4
million
ft3
of
water
(
up
to
45%
of
the
bay's
total
volume)
may
be
exchanged.
Thus,
the
opportunity
for
dilution
alone
is
significant.
Although
this
discussion
has
focused
primarily
on
Willapa
Bay,
it
is
believed
that
the
same
potential
for
dissipation
exists
for
Grays
Harbor
where
less
than
1%
of
the
total
acreage
is
treated.

Although
preliminary
research
(
personal
communication
Nat
Scholz,
National
Marine
Fisheries
Service
2002)
suggests
that
salmonid
fish
exposed
to
carbaryl
in
olfactory
perfusion
assays
are
not
able
to
detect
the
chemical,
i.
e.,
the
chemical
does
not
elicit
an
electrical
response
from
olfactory
cells,
the
relevancy
of
these
data
is
uncertain.
Concern
has
been
raised
though
that
the
animal's
inability
to
detect
carbaryl
would
render
the
fish
incapable
of
avoiding
a
chemical
plume;
however,
no
evidence
has
been
provided
that
for
fish
other
than
those
trapped
in
tide
pools
and
131
directly
in
a
chemical
treatment
site,
that
the
Section
24c
use
of
carbaryl
has
resulted
in
fish
kills.
Studies
have
been
proposed
though
(
personal
communication
Christian
Grue,
University
of
Washington
Cooperative
Fish
and
Wildlife
Unit,
2003)
that
are
designed
to
answer
whether
salmonids
frequent
active
carbaryl
application
sites,
the
extent
to
which
they
consume
prey
containing
carbaryl
residues
and
whether
the
residues
have
any
impact
on
brain
acetylcholinesterase
activity
in
the
fish.

Concern
has
also
been
raised
over
the
potential
effects
of
carbaryl
on
birds
feeding
opportunistically
on
immobilized
aquatic
animals
in
treated
areas;
however,
based
on
the
available
information,
carbaryl
is
practically
nontoxic
to
birds
on
an
acute
exposure
basis
(
LD50
>
2,000
mg/
Kg)
and
a
subacute
dietary
basis
(
LC50
>
5,000
mg/
kg
of
diet).
No
data
are
available
to
suggest
that
birds
are
adversely
affected
on
an
acute
exposure
basis
from
the
use
of
carbaryl
to
control
burrowing
shrimp.
Furthermore,
the
data
suggest
that
the
likelihood
of
chronic
exposure
to
birds
is
low.

As
part
of
a
memorandum
of
agreement
(
APPENDIX
E2)
between
the
oyster
growers
and
the
state
of
Washington,
an
integrated
pest
management
plan
has
been
developed
in
Willapa
Bay.
The
agreement
acknowledges
that
additional
data
on
the
environmental
fate
and
effects
of
carbaryl
are
necessary
and
that
alternative
methods
of
control
should
be
explored
to
mitigate
adverse
effects.
As
part
of
these
efforts,
the
shellfish
growers
are
actively
engaged
in
exploring
both
chemical,
biological
(
e.
g.,
parasites,
predation),
and
mechanical
(
e.
g.,
surface/
vertical
barriers,
compaction,
harrowing/
discing)
alternatives
along
with
different
methods
of
oyster
culture
(
e.
g.,
long­
lining).
Although
both
chemical
and
mechanical
methods
of
controlling
burrowing
shrimp
have
been
had
mixed
results,
an
effort
is
underway
to
reduce
the
potential
for
adverse
effects
from
carbaryl.
It
is
clear
from
the
data
that
considerable
variability
exists
in
estimates
on
the
extent
to
which
carbaryl
/
naphthol
residues
persist
in
both
the
water
column
and
treated
sediments
and
EFED
encourages
more
refined
studies
to
address
this
issue.
Proposals
have
been
submitted
to
study
the
fate
and
transport
of
carbaryl
in
Willapa
Bay
and
to
better
define
the
sediment
impact
zone.
Based
on
the
available
data,
acute
mortality
is
likely
for
animals
in
the
immediate
application
area;
however,
off­
site
acute
mortality
is
not
expected
to
be
significant.
Additionally,
the
potential
for
adverse
chronic
effects
is
not
expected
to
be
significant
due
to
a
combination
of
relatively
rapid
degradation
and
dilution
in
this
tidal
environment.

EFED
acknowledges
that
there
are
uncertainties
regarding
the
use
of
carbaryl
in
Willapa
Bay/
Grays
Harbor
and
its
potential
effect
on
nontarget
animals.
Maintaining
a
constructive
dialog
between
shellfish
growers,
Washington
state
representatives
and
other
stakeholders
within
the
Willapa
Bay/
Grays
Harbor
communities
can
only
serve
to
promote
the
necessary
research
to
address
various
concerns
and
uncertainties.
132
APPENDIX
E2.
REVIEW
OF
DATA
SUBMITTED
ON
SECTION
24c
USE
OF
CARBARYL
TO
CONTROL
BURROWING
SHRIMP
U.
S.
ENVIRONMENTAL
PROTECTION
AGENCY
WASHINGTON,
DC
20460
OFFICE
OF
PREVENTION,
PESTICIDES
AND
TOXIC
SUBSTANCES
MEMORANDUM
PC
Code
No.
129106
DP
Barcode:
D279109
SUBJECT:
EFED
Review
of
Documents
Relative
to
Section
24c
Special
Local
Needs
Registration
of
Carbaryl
for
Use
on
Oyster
Beds.

TO:
Anthony
Britten,
Chemical
Review
Manager
Betty
Shackleford,
Product
Manager
Special
Review
and
Reregistration
Division
FROM:
Thomas
M.
Steeger,
Ph.
D.,
Senior
Biologist
Environmental
Risk
Branch
IV/
EFED
(
7507C)

Through:
Betsy
Behl,
Branch
Chief
Environmental
Risk
Branch
IV/
EFED
(
7507C)

The
Environmental
Fate
and
Effects
Division
(
EFED)
has
completed
its
review
of
the
materials
submitted
relative
to
the
Section
24c
Special
Local
Needs
registration
of
carbaryl
for
use
on
oyster
beds
in
Willapa
Bay
and
Grays
Harbor,
Washington,
to
control
ghost
shrimp
(
Callianassa
californiensis)
and
mud
shrimp
(
Upogebia
pugettensis).
The
documents
included
1)
a
report
on
concentrations
of
carbaryl
and
its
degradate
(
1­
naphthol)
in
marine
sediments
from
sites
treated
with
or
adjacent
areas
treated
with
Sevin
(
Stonic
1999);
2)
a
fact
sheet
on
chemicals
of
special
concern
in
Washington
State;
3)
a
memo
from
the
State
of
Washington's
Department
of
Ecology's
review
of
data
relevant
to
the
environmental
effects
of
applying
Sevin
 
to
control
burrowing
shrimp
in
Willapa
Bay
and
Grays
Harbor
oyster
beds;
4)
a
copy
of
the
memorandum
of
agreement
between
the
Washington
State
Department
of
Ecology,
the
Willapa/
Grays
Harbor
Oyster
Growers'
Association
and
other
state
government
and
private
organizations;
and
5)
a
Washington
State
Department
of
Ecology
publication
entitled
Carbaryl
Concentrations
in
Willapa
Bay
and
Recommendations
for
Water
Quality
Guidelines
(
Johnson
2001).
Except
for
more
recent
studies
conducted
by
Washington
State
University
and
the
Washington
Department
of
Ecology,
much
of
the
older
(
pre­
1996)
data
had
procedural
problems
that
limited
the
utility
of
the
data.
The
more
recent
data
indicate
that
carbaryl
residues
in
the
water
column
were
generally
at
or
below
an
effect
threshold
of
0.1
ug/
L
Although
large
carbaryl
applications
can
affect
water
quality
in
areas
distant
from
spray
sites,
the
Washington
Department
of
Ecology
concluded
that
"
no
widespread
effects
from
carbaryl
would
be
expected
in
Willapa
Bay
after
the
end
of
the
[
carbaryl]
application
period."
133
Carbaryl
has
been
used
on
approximately
600
acres
of
Willapa
Bay
and
200
acres
of
Grays
Harbor
at
a
rate
of
7.5
to
10
lbs/
acre/
year
since
the
1960'
s.
Carbaryl
is
applied
as
a
wettable
powder
to
tidelands
at
low
low
[
Spring]
tide
primarily
by
helicopter;
however,
hand
spraying
is
used
in
some
instances.
The
label
restricts
aerial
applications
within
200
feet
of
a
channel
or
slough;
hand
spraying
is
prohibited
within
50
feet
of
a
channel
or
slough.

The
data
collected
and/
or
reviewed
by
the
Washington
Department
of
Ecology
indicate
that
carbaryl
residues
drop
below
the
level
of
quantitation
(<
0.004
ug/
L)
approximately
6
weeks
after
application.
While
concentrations
in
nontarget
areas
immediately
following
the
carbaryl
application
period
are
likely
to
inflict
mortality
to
aquatic
organisms,
no
data
are
provided
to
demonstrate
that
threatened
and/
or
endangered
species
(
e.
g.
salmonids)
are
adversely
affected
by
the
treatments
to
oyster
beds.

While
these
documents
provide
additional
information
on
the
environmental
fate
and
effects
of
carbaryl
in
estuarine/
marine
environments,
EFED's
review
of
Washington's
Section
24c
petition
was
based
on
the
required
guideline
fate
and
effects
data
provided
by
the
registrant
in
support
of
the
reregistration
of
carbaryl.
Although
the
EFED
reregistration
eligibility
document
(
RED)
for
carbaryl
does
not
estimate
environmental
concentrations
for
applications
directly
to
tidelands
for
control
of
burrowing
shrimp
in
oyster
culture,
it
does
discuss
the
use.
Data
submitted
in
support
of
reregistration
(
MRID
419826­
06)
indicate
that
estuarine/
marine
invertebrates
will
likely
be
impacted
by
this
route
of
exposure
and
that
certain
species,
e.
g.,
Dungeness
crab
(
Cancer
magister),
may
experience
100%
mortality
in
the
application
area.
However,
the
assessment
goes
on
to
note
that
effects
on
aquatic
invertebrates
will
likely
be
temporary
as
most
populations
show
signs
of
recovery
within
2
months.
Additionally,
the
chapter
suggests
that
carbaryl
applications
that
reduce
the
potential
for
drift
to
nontarget
sites,
such
as
direct
injection
of
carbaryl
into
the
sediment,
may
help
mitigate
nontarget
effects.

Review
of
Submitted
Literature
1)
Screening
Survey
of
Carbaryl
(
Sevin)
and
1­
naphthol
Concentrations
in
Willapa
Bay
Sediments
The
study
was
undertaken
to
determine
the
long­
term
persistence
of
carbaryl
and
1­
naphthol;
more
specifically,
the
study
objectives
were
to:

°
Determine
if
there
are
residues
of
carbaryl
and
its
degradate
1­
naphthol
in
the
marine
sediments
at
historically
sprayed
sites
and
unsprayed
adjacent
sites
°
Monitor
the
depletion
of
these
compounds
in
sediments
following
applications
of
Seven
 
.
°
Measure
concentrations
of
carbaryl
in
centrifuged
sediment
pore
water.
°
Determine
drift
potential.

The
study
was
divided
into
two
phases,
pre­
spray
and
post­
spray.
Sampling
was
conducted
in
Willapa
Bay
in
areas
deemed
to
be
conducive
to
carbaryl
persistence.
Thus,
areas
with
muddy
and/
or
fine
sediments
were
selected
since
they
were
believed
to
be
more
likely
to
retain
both
carbaryl
134
0
500
1000
1500
2000
2500
3000
3500
0
10
20
30
40
50
60
Days
after
Treatment
Carbaryl
(
ppb)

Figure
1
Average
carbaryl
concentrations
in
sediment
collected
from
Willapa
Bay
at
2,
30
and
60
days
after
treatment.
and
1­
naphthol.
Sandy
sediments
were
not
believed
to
provide
sufficient
clay
or
organic
material
with
which
carbaryl
and/
or
its
degradate
could
sorb.

Pre­
spray
samples
were
collected
from
areas
that
had
been
sprayed
in
previous
years
or
were
adjacent
to
areas
that
had
been
sprayed
in
previously.
A
reference
site,
Nemah
Oyster
Reserve,
was
sampled
as
an
area
that
had
never
been
sprayed.

Post­
spray
samples
were
collected
immediately
following
carbaryl
treatment
and
also
included
areas
adjacent
to
spray
sites.
Treated
sites
included
areas
that
had
been
sprayed
in
years
past
in
addition
to
the
recent
treatment.
Sampling
was
typically
conducted
2,
30
and
60
days
after
treatment
(
DAT).
Sediment
samples
were
collected
using
a
stainless
steel
17­
cm
diameter
device
that
allowed
sediment
samples
to
be
stratified
into
0
­
2
cm,
2
­
7.5
cm,
and
7.5
­
15
cm
depths.
Total
organic
carbon
(
TOC)
and
sediment
size
were
also
analyzed.
Carbaryl
and
1­
naphthol
residues
were
measured
both
in
whole
sediment
and
in
centrifuged
pore
water.
Quality
assurance
spiked
sediment
samples
suggest
considerable
amount
of
variability
in
recovery
of
standards.
The
results
may
be
negatively
biased.

Based
on
the
pre­
spray
study
results,
all
of
the
historically
sprayed
sites,
adjacent
unsprayed
sites
and
the
reference
site
showed
no
carbaryl
or
1­
naphthol
residues
above
the
detection
limit
range
of
21
to
58
ppb.
One
sample
representing
the
shallowest
area
adjacent
to
historically
sprayed
beds
had
trace
(
29
ppb)
residues
of
carbaryl.

Post­
spray
study
results
indicate
that
carbaryl
concentrations
at
sprayed
sites
ranged
from
2,000
to
3,400
ppb
by
2
DAT,
180
to
220
ppb
by
30
DAT,
and
86
­
120
ppb
by
60
DAT
(
Figure
1).
Although,
adjacent
sites
contained
as
much
as
2,000
ppb
2
DAT,
residues
in
sediment
at
all
adjacent
sites
at
60
DAT
were
close
to
detection
limits
and
ranged
from
27
to
32
ppb.

Residues
for
the
1­
naphthol
ranged
from
detection
limits
to
as
high
as
170
ppb
at
2
DAT
and
by
30
DAT
all
samples
had
dropped
to
detection
limits
(
22
to
33
ppb);
one
sample
at
60
DAT
contained
naphthol
at
34
ppb.
The
report
concluded
that
once
carbaryl
degrades
to
1­
naphthol,
the
degradate
appears
to
readily
leave
the
sediment.
It
did
not
however,
allow
for
the
fact
that
the
degradate
could
have
been
present
in
deeper
reaches
of
the
sediment.
At
adjacent
sites,
1
naphthol
ranged
as
high
as
120
ppb
2
DAT
and
then
dropped
to
below
detection
limits
for
the
remaining
sample
periods.

Carbaryl
residues
in
pore
water
were
only
detected
60
DAT
and
ranged
from
0.57
to
1.15
ppb.
It
is
difficult
to
understand
though
how
the
limit
of
detection
for
pore
water
was
so
much
lower
than
135
that
for
sediment.
Carbaryl
was
only
detected
in
one
sediment
pore
water
sample
collected
from
an
adjacent
site;
the
residue
was
close
to
the
limit
of
detection
at
0.05
ppb.

Analyses
of
sediment
grain
size
and
total
organic
carbon
revealed
that
the
clay­
silt
fraction
of
the
post
spray
sites
ranged
from
25%
to
73%
while
TOC
ranged
from
0.58%
to
2.07%.
Grain
size
and
TOC
were
strongly
correlated
(
Pearson
R2
range
0.89
­
0.96);
however,
there
was
no
correlation
between
carbaryl
residues
and
TOC.

The
study
concludes
that
carbaryl
is
clearly
persistent
in
treatment
areas
with
residues
being
detected
up
to
60
DAT.
Additionally,
residues
in
sites
adjacent
to
treated
areas
indicate
that
drift
does
occur.
Drift
to
nontarget
sites
was
attributed
to
wind,
depth
of
water
sampled,
and
both
surface
and
bottom
water
currents.
Additionally,
sediment
pore
water
concentrations
exceeded
the
National
Academy
of
Sciences
and
Engineering
water
quality
recommendation
for
carbaryl
of
0.06
ppb.
Additionally,
historic
sampling
revealed
that
water
column
concentrations
prior
to
application
ranged
as
high
as
9.2
ppb.
The
report
notes
that
QA/
QC
standards
suggested
that
actual
pore
water
concentrations
may
be
higher
than
those
reported.
It
is
uncertain
how
much
naphthol
was
present
in
the
water
column;
however,
given
that
naphthol
is
more
toxic
than
the
parent,
the
potential
affect
of
the
residues
on
aquatic
animals
is
a
legitimate
concern.

Finally
the
report
compares
the
sediment
residue
data
to
available
toxicity
data
on
carbaryl
and
concludes
that
Dungeness
crab
larvae
exposed
to
carbaryl
at
concentrations
ranging
from
0.1
to
10
ppb
for
25­
days
exhibited
both
molting
effects
and
mortality.
Although
no
formal
data
were
provided
on
the
numbers
of
organisms
affected;
the
author
reports
that
marine
fish
and
invertebrate
mortality
was
observed
2
DAT.
The
author
proposes
that
the
incidental
kills
could
serve
as
forage
for
other
fish
and
foraging
birds
that
would
then
bioaccumulate
carbaryl
in
their
tissues.
The
report
further
suggests
that
indirect
effects,
such
as
endocrine
disruption
and
mutagenicity,
are
not
sufficiently
characterized
and
that
coupled
with
direct
effects
and
the
potential
for
bioaccumulation
in
the
food
chain,
carbaryl
and
1­
naphthol
have
the
potential
to
impact
threatened
and/
or
endangered
salmon
stocks.

The
study
would
have
been
more
thorough
had
water
column
concentrations
of
carbaryl
been
measured.
Given
that
the
compound
was
applied
using
both
aerial
and
hand­
held
sprayers,
it
is
difficult
to
assess
the
affect
of
drift
relative
to
application
method.
It
would
have
also
been
helpful
to
know
how
representative
the
areas
sampled
were
of
the
total
areas
treated
in
terms
of
TOC
and
grain
size.
Additionally,
the
limit
of
detection
(
25
­
35
ppb)
was
not
sufficiently
low
to
document
residues
in
sediment
and
pore
water
that
may
have
been
sufficiently
high
to
effect
benthic
invertebrates.

2)
Chemicals
of
Special
Concern
in
Washington
State
Report
published
by
the
Washington
Department
of
Ecology
provides
a
brief
overview
of
the
environmental
fate
and
effects
of
carbaryl.
Although
the
overview
has
footnote
numbers,
no
references
were
provided;
therefore,
data
supporting
carbaryl's
characterization
could
not
be
verified.
The
report
implies
that
carbaryl
is
relatively
persistent
and
that
recoveries
of
aquatic
systems
exposed
136
to
carbaryl
have
taken
as
long
as
3
years.
According
to
the
overview,
carbaryl
is
teratogenic,
immunosuppressive,
and
degrades
to
carcinogenic
compounds.

3)
Washington
Department
of
Ecology
Review
of
Data
Relevant
to
the
Environmental
Effects
of
Applying
Carbaryl
to
Control
Burrowing
Shrimp
in
Willapa
Bay
and
Grays
Harbor
Oyster
Beds
(
1987).

The
object
of
the
Washington
Department
of
Ecology
review
was
to
answer
the
following
questions:

°
How
long
do
carbaryl
and
its
primary
hydrolysis
product
1­
naphthol
persist
in
the
water
column?
°
What
concentrations
of
carbaryl
and
1­
naphthol
in
water
are
toxic
to
marine
organisms?
°
How
long
do
carbaryl
and
1­
naphthol
persist
in
the
sediments?
°
What
concentrations
of
carbaryl
and
1­
naphthol
in
sediment
are
toxic
to
marine
organisms?
°
What
are
the
effects
on
abundance
and
diversity
of
infauna?
°
What
are
the
effects
on
abundance
and
diversity
of
epifauna?
°
What
mortality
is
experienced
by
Dungeness
crab
and
how
does
this
affect
the
fishery?
°
What
mortality
is
experienced
by
fish?
°
Are
birds
adversely
affected?
°
What
are
the
potential
ecological
impacts
of
Sevin
applications?

While
the
environmental
fate
studies
on
water
column
and
sediment
concentrations
during
and
after
application
of
carbaryl
showed
a
decline
in
carbaryl
and
1­
naphthol
concentrations,
much
of
the
data
were
discounted
due
to
poor
detection
limits
and
procedural
deficiencies.
Open
literature
reviews
of
ecological
effects
revealed
that
carbaryl
is
more
toxic
to
crustaceans
than
to
molluscs
or
fish;
however,
the
degradate
1­
naphthol
is
less
toxic
to
crustaceans
than
carbaryl
but
more
toxic
than
the
parent
to
molluscs
and
fish.
Subacute
effects
of
carbaryl
were
reported
at
concentrations
below
the
detection
limit
(
1
mg/
L)
of
most
of
the
monitoring
studies
reported;
the
report
states
that
circumstantial
evidence
suggests
the
potential
for
toxic
effects
at
or
below
0.1
mg/
L
in
sediment.
Sublethal
effects
included
reduced
development
of
oysters
and
delayed
molting
of
crab
larvae,
malformations
in
fish
eggs
and
adults.
Toxicity
of
carbaryl
is
reported
to
increase
with
temperature.

Although
the
report
fails
to
conclusively
resolve
whether
carbaryl
and
its
1­
naphthol
degradate
are
sufficiently
persistent
to
effect
aquatic
life,
it
notes
that
the
target
population
of
burrowing
shrimp
take
a
number
of
years
to
recover.
However,
failure
of
a
treated
area
to
recover
may
be
due
to
a
number
of
factors
and
may
not
result
exclusively
on
the
toxicity
of
carbaryl
or
its
degradate.
137
0
100
200
300
400
500
600
1976
1978
1980
1982
1984
1986
1988
Year
Acres
Treated
Figure
2.
Number
of
acres
treated
with
carbaryl
in
Willapa
Bay
over
years.

0
10000
20000
30000
40000
50000
60000
70000
0
100
200
300
400
500
600
Number
of
Acres
Treated
Number
of
Crabs
Killed
Figure
3.
Number
of
crabs
killed
versus
number
of
acres
treated
with
carbaryl
in
Willapa
Bay.
Fisheries
data
collected
on
Willapa
Bay
from
1977
to
1986
show
(
Figure
2)
that
the
number
of
acres
treated
with
carbaryl
increased
each
year.
And
that
the
number
of
crabs
killed
by
carbaryl
treatment
also
increased
(
Figure
3)
as
the
number
of
acres
treated
increased.
The
number
of
crabs
killed
was
significantly
correlated
(
Pearson
Correlation
coefficient
=
0.72;
p
>
rho
=
0.0187)
with
the
number
of
acres
treated.
Over
the
observation
period
an
average
of
53
crabs
(
standard
error
=
13)
were
killed
per
acre.
Followup
studies
by
the
University
of
Washington
that
[
Dungeness]
crab
in
treated
areas
are
impacted
but
that
further
studies
are
required
to
establish
population­
level
effects
in
Willapa
Bay.

Mortalities
to
fish
were
limited
to
small
specimens
which
were
entrapped
in
shallow
pools
by
the
outgoing
tide
and
directly
exposed
to
carbaryl
during
treatment;
however,
the
reviewed
literature
did
not
address
the
potential
for
indirect
mortality.

Although
no
studies
were
conducted,
the
report
concluded
that
likelihood
of
acute
or
chronic
effects
of
carbaryl
on
birds
was
remote.

Whether
there
are
broad
ecological
impacts
associated
with
the
use
of
carbaryl
to
control
burrowing
shrimp
in
Willapa
Bay
remains
an
uncertainty.
The
Environmental
Impact
Statement
concluded
that
the
use
of
carbaryl
by
the
commercial
oyster
industry
was
not
expected
to
cause
significant
impacts
on
the
estuarine
ecosystem
when
applied
at
current
levels.
It
based
this
conclusion
on
the
fact
that:

°
Carbaryl
is
not
accumulated
by
any
food
chain
component
or
transmitted
to
higher
levels
in
the
food
chain.
°
No
chemically
active
radical
group
remains
to
contaminate
the
estuarine
environment.
°
Only
a
small
percentage
of
the
total
intertidal
lands
are
treated
annually;
0.8%
in
Willapa
Bay
and
0.3%
in
Grays
Harbor.

The
report
recommends
though
that
further
work
be
conducted
to
evaluate
the
persistence
of
carbaryl
and
1­
naphthol
in
sediment
and
to
better
document
the
effects
of
nontarget
mortality.
138
4)
Burrowing
Shrimp
Integrated
Pest
Management
Memorandum
of
Agreement
The
memorandum
of
agreement
(
MOA)
was
established
between
the
Washington
State
Department
of
Ecology,
Washington
State
Department
of
Agriculture,
the
Washington
State
Commission
on
Pesticide
Registration,
the
Washington
Department
of
Fish
and
Wildlife,
the
Willapa/
Grays
Harbor
Oyster
Growers
Association,
the
Pacific
Coast
Shellfish
Growers
Association
and
the
Pacific
Shellfish
Institute.
The
agreement
acknowledges
that
while
carbaryl
and
its
1­
naphthol
degradate
affect
nontarget
species,
are
likely
transported
several
hundred
yards
offsite
by
tidal
action,
and
may
persist
for
several
weeks
in
the
water
column
and
sediments
within
Willapa
Bay/
Grays
Harbor,
treatment
for
burrowing
shrimp
is
necessary
if
economic
losses
due
to
diminished
oyster
harvests
are
to
be
avoided.
The
agreement
acknowledges
that
additional
data
on
the
environmental
fate
and
effects
of
carbaryl
are
necessary
and
that
alternative
methods
of
control
should
be
explored
to
mitigate
adverse
effects
especially
on
threatened/
endangered
salmonids.
The
MOA
establishes
a
process
and
time
for
the
development
of
a
"
sustainable
site­
specific,
environmentally
sound
and
ecologically
based
[
integrated]
pest
management
plan
for
the
control
of
burrowing."
The
MOA
outlines
criteria
to
be
met,
i.
e.,
demonstration
that
burrowing
shrimp
populations
have
reached
a
size
sufficient
to
inflict
economic
losses,
before
which
carbaryl
can
be
applied.

5)
Carbaryl
Concentrations
in
Willapa
Bay
and
Recommendations
for
Water
Quality
Guidelines.

In
the
summer
of
2000,
the
Washington
State
Department
of
Ecology
initiated
a
study
of
Willapa
Bay.
The
study
was
a
follow­
up
on
the
Stonic
(
1999)
study
from
1996
to
1997
and
concern
that
carbaryl
persisted
at
a
level
of
0.7
ug/
L.
The
objectives
of
the
study
were
to:

°
determine
if
there
is
a
carbaryl
background
that
persists
in
Willapa
Bay
water
outside
the
July
to
August
spray
period;
°
analyze
carbaryl
in
other
potential
sources
to
Willapa
Bay;
°
achieve
quantitation
limits
for
carbaryl
sufficiently
low
to
evaluate
the
potential
for
causing
toxicity
to
sensitive
marine
organisms;
°
review
the
literature
on
carbaryl's
effects
on
marine
organisms
and
evaluate
appropriate
water
quality
guidelines
for
carbaryl
in
Willapa
Bay.

Results
from
the
study
show
that
carbaryl
was
frequently
detected
in
Willapa
Bay
up
to
4
days
after
application
to
oyster
beds
and
that
carbaryl
was
transported
several
miles
from
the
site
of
application.
However,
the
study
showed
no
evidence
of
carbaryl
background
in
the
Willapa
Bay
water
column.
Additionally,
tributaries
and
cranberry
bog
drainages
were
not
significant
carbaryl
sources.
Carbaryl
had
dropped
to
levels
below
quantitation
(
0.004
ug/
L)
approximately
1
month
after
application
Based
on
a
review
of
toxicity
data
on
35
marine
species,
the
report
recommended
0.06
ug/
L
as
a
probable
safe
level
for
marine
organisms
and
a
range
of
0.1
to
0.7
ug/
L
as
a
potential
effects
threshold.
The
value
of
0.06
ug/
L
was
based
on
a
National
Academy
of
Science
approach
using
an
EC50
of
6
ug/
L
for
inhibiting
molting
in
Dungeness
crab
larvae
divided
by
a
100X
safety
factor.
The
139
data
collected
from
open
literature
suggests
that
carbaryl
is
more
toxic
to
crustaceans
and
echinoderms
than
to
fish,
molluscs,
or
polychaetes.
The
study
notes
that
while
similar
information
was
not
collected
on
the
1
naphthol
degradate,
one
study
has
shown
it
to
be
roughly
twice
as
toxic
to
fish
as
the
parent
compound
but
less
toxic
to
crustaceans.
Carbaryl
was
detected
at
concentrations
within
the
proposed
potential
effects
threshold
several
miles
from
treatment
areas
up
to
several
days
following
application.
The
report
recommended
that
future
water
quality
monitoring
focus
on
the
period
during
or
immediately
after
carbaryl
applications
and
that
data
are
collected
on
carbaryl's
1­
naphthol
transformation
product.
Additionally,
the
report
recommends
that
future
effects
testing
include
more
sensitive
test
species
and
indigenous
aquatic
species
that
serve
as
prey
for
endangered/
threatened
species
References
Stonic,
Cynthia.
1999.
Screening
Survey
of
Carbaryl
(
Sevin
 
)
and
1­
naphthol
Concentrations
in
Willapa
Bay
Sediments.
Washington
State
Department
of
Ecology.
Publication
No.
99­
323.

Johnson,
Art.
2001.
Carbaryl
Concentrations
in
Willapa
Bay
and
Recommendations
for
Water
Quality
Guidelines.
Washington
State
Department
of
Ecology.
Environmental
Assessment
Program.
Publication
No.
01­
03­
005.
140
APPENDIX
E3.
REVIEW
OF
LITERATURE
SUBMITTED
TO
REBUT
THE
USE
OF
CARBARYL
TO
CONTROL
BURROWING
SHRIMP
IN
WILLAPA
BAY/
GRAYS
HARBOR.

In
a
study
entitled
"
Benthic
Organisms
State
of
Regeneration
Two
Years
after
Carbaryl
Application
in
Willapa
Bay"
conducted
by
Scott
Mazzone
and
Michael
McNamara
(
no
date;
no
journal)
to
determine
whether
there
are
any
statistical
differences
between
regeneration
of
species
in
sprayed
sites
and
the
productivity
of
species
in
unsprayed
sites,
three
sampling
areas
(
A,
B,
C)
in
Willapa
Bay,
Washington,
were
selected.
At
each
site,
25
m
X
25
m
square
areas
were
identified
and
divided
into
0.5
m
square
intervals.
Twenty
random
sites
of
0.5­
m
square
were
selected
from
area
A
(
control)
and
10
sampling
sites
each
were
selected
from
areas
B
and
C
(
previously
sprayed
sites).
All
benthic
organisms
were
identified
and
counted
at
each
site.
Burrow
openings
were
also
counted
at
each
site
to
determine
the
relationship
between
the
openings
and
the
number
of
organisms
present.
Total
number
of
species
present
(
species
richness)
and
their
population
sizes
(
abundance)
were
compared.
A
Shannon­
Weiner
index
and
a
Species
Evenness
Index
were
also
calculated.
Results
were
compared
using
a
two­
tailed
t­
test.
Additionally,
the
depth
of
the
anoxic
layer
was
noted
at
each
site
by
collecting
10
measurements
at
each
site.
The
number
of
species
within
the
sprayed
areas
were
averaged
and
then
compared
to
the
control.

According
to
the
results
"
the
control
site
was
at
a
natural
state
of
productivity.
The
benthic
organisms
were
observed
as
having
high
levels
of
biodiversity
and
population.
Evidence
of
generational
succession
existed
in
the
control
site.
The
indicator
species
(
lugworms)
showed
a
sustainable
level
of
productivity,
while
littleneck
clams
(
Protothaca
staminea)
and
Orange
Nemertean
(
Tubulanus
polymorphus)
were
the
dominant
species.
.

Both
treated
areas
(
B
and
C)
"
contained
similar
biodiversity
to
that
of
site
A.
The
specific
species
populations
were
significantly
lower
with
no
evidence
of
generational
succession.
The
indicator
species
showed
a
non­
sustainable
level
of
production;
orange
Nemertean
were
[
sic]
the
dominant
species."
Species
found
in
the
control
site
were
consistently
more
abundant
than
that
of
the
sprayed
sites
and
there
did
not
appear
to
be
any
indication
that
the
burrow
openings
reflect
the
amount
of
organisms
for
at
each
sample
point.
The
Shannon­
Wiener
Index
for
treated
versus
control
sites
were
significantly
different
(
P
=
2.002
x
10­
7);
the
Species
Evenness
Index
for
the
two
sites
were
significantly
different
(
P=
0.00001),
and
the
depth
of
the
anoxic
layer
at
the
treated
versus
the
control
sites
was
significantly
different
(
P=
2.455
x
10­
15).
Based
on
the
study
results,
the
authors
conclude
that
the
rate
of
regeneration
of
the
areas
that
have
been
treated
"
does
not
support
the
current
belief
that
regeneration
of
the
affected
organisms
are
approaching
natural
levels
of
productivity"
and
that
"
relatively
low
populations
of
the
organisms
again
exposed
to
carbaryl
will
be
exhausted
throughout
Willapa
Bay.

In
reviewing
this
study,
it
is
unclear
whether
the
control
site
(
A)
was
similar
to
either
of
the
treated
sites.
The
authors
used
both
salinity
and
temperature
to
determine
the
similarity;
however,
given
that
the
study
is
examining
benthic
organisms,
a
more
likely
measure
of
comparability
may
have
been
sediment
type
and
morphology.
Based
on
the
map
that
was
provided,
the
reference
site
appears
to
be
facing
open
ocean
while
the
treated
sites
appear
to
be
on
a
sheltered
inlet
of
the
bay.
Furthermore,
the
distance
of
the
study
sites
from
the
shore
and
the
depth
of
water
over
each
site
is
141
not
reported.
Although
the
report
states
that
freshwater
inputs,
currents,
winds,
and
sediment
composition
were
also
noted
and
found
to
be
similar
between
sites,
no
data
are
provided
to
support
this
conclusion
statistically.

Additionally,
the
study
intends
to
compare
three
sites;
however,
the
authors
use
a
two­
sample
t­
test
to
compare
results.
Also,
it
is
not
clear
from
the
study
whether
the
authors
tested
to
see
whether
parametric
statistics
applied
and/
or
whether
it
was
appropriate
to
pool
data
from
the
treated
sites.
While
the
study
purports
to
measure
species
richness
and
abundance,
the
authors
make
conclusions
about
sustainable
levels
of
productivity
and
generational
succession
in
the
study
sites
and
conclude
that
repeated
applications
of
carbaryl
will
"
exhaust"
already
compromised
populations
in
the
Willapa
Bay
as
a
whole.

Although
the
authors
state
that
both
treated
areas
(
B
and
C)
"
contained
similar
biodiversity
to
that
of
site
A"
they
report
that
the
Shannon­
Wiener
Diversity
Index
was
significantly
different
between
the
sites.
According
to
the
report
figures,
5
different
groups
of
animals
(
clams,
ghost
shrimp,
lug
worms,
orange
Nemertean,
and
a
goby)
were
identified
in
the
control
area;
5
different
groups
of
animals
were
also
identified
in
the
combined
sites
B
and
C
(
clams,
ghost
shrimp,
lug
worms,
orange
Nemerteans
and
mud
shrimp).
The
apparent
difference
between
the
two
sites
appears
to
be
in
the
number
(
abundance)
of
each
organism.
Since
most
of
these
are
filter
feeding
organisms,
it
suggests
that
the
availability
of
food
(
primary
productivity)
may
have
been
a
critical
factor;
however,
the
authors
do
not
provide
any
information
on
plankton
counts
between
the
sampling
areas.

Carbaryl
had
not
been
applied
to
the
treated
sites
for
2
years
and
analyses
of
both
water
and
sediment
revealed
no
carbaryl
residues;
therefore,
it
cannot
be
concluded
that
repopulation
of
the
sites
was
affected
by
carbaryl
residues.
Since
insufficient
information
is
provided
to
demonstrate
the
similarity
of
the
sites
to
facilitate
comparing
treated
versus
untreated,
it
isn't
possible
to
conclude
that
the
reported
differences
in
species
diversity
and
abundance
are
a
result
of
carbaryl
treatment.
It
is
clear
though
that
based
on
the
carbaryl
reapplication
intervals
required
by
oyster
growers
in
the
bay,
it
requires
roughly
6
years
for
burrowing
shrimp
populations
to
fully
recover.
However,
this
is
not
to
say
that
carbaryl­
treated
areas
remain
a
biological
wasteland
over
those
years.
It
is
likely
that
recovery
occurs
in
stages
and
that
sere
progression
over
the
years
accounts
for
differences
in
species
diversity.

This
report
underscores
the
difficulty
in
conducting
well­
designed
field
studies
that
account
for
the
many
sources
of
variability
that
can
affect
a
study's
ability
to
establish
causality.
Insufficient
detail
is
provided
in
the
current
study
to
suggest
though
that
carbaryl
applications
to
control
burrowing
shrimp
in
selected
sites
in
the
bay
are
likely
to
exhaust
aquatic
life
within
the
bay.
Given
that
the
reapplication
interval
is
roughly
six
years
and
the
current
study
at
best
demonstrates
that
after
two
years
a
similar
range
of
species
exist
in
treated
and
untreated
sites
(
that
may
or
may
not
be
comparable),
there
is
no
conclusive
evidence
to
support
concerns
that
carbaryl
treatments
are
reducing
the
overall
"
natural
productivity"
of
Willapa
Bay.

In
a
second
study
entitled
"
Imidacloprid
Residues
in
Willapa
Bay
(
Washington
State)
Water
and
Sediment
Following
Application
for
Control
of
Burrowing
Shrimp"
by
A.
S.
Felsot
and
J.
R.
Ruppert
(
Journal
of
Agric.
food
Chem
2002,
50,
4417
­
4423),
imidacloprid
residues
were
monitored
142
after
application
to
mudflats
in
Willapa
Bay
and
sorption
studies
of
bay
sediments
were
conducted
to
test
the
hypothesis
that
fluctuations
in
water
volumes
associated
with
tidal
changes
dispersed
residues
to
levels
below
detection
limits.
The
residue
monitoring
was
part
of
an
efficacy
study
intended
to
compare
imidacloprid
(
0.28,
0.56,
1.12
kg
a.
i./
ha)
with
carbaryl
(
4.48
and
8.96
kg
a.
i./
ha)
after
spraying
with
different
rates
and
volumes
of
water
(
93.5
and
468
L/
ha)
applied
by
ground
handboom
sprayer.
The
study
utilized
a
stratified
random­
block
design
with
four
replications;
10
possible
insecticide
treatments
and
1
untreated
control
were
randomly
assigned
to
one
of
11
plots
(
6.1
m
x
6.1
m)
in
each
of
4
blocks.
Adjacent
plots
in
each
block
were
separated
from
one
another
by
an
untreated
6.1­
m
buffer..
The
four
experimental
blocks
were
arranged
in
a
line
that
ran
parallel
to
the
shoreline
approximately
m
offshore.
Tidal
flow
was
approximately
perpendicular
to
the
long
axis
of
the
blocks.
Water
(
collected
as
tide
was
coming
in)
and
sediment
(
collected
during
low
tide)
were
collected
immediately
after
application
and
days
14
and
28
post­
application
from
at
various
distances
(
0,
30,
61,
122
and
244
m)
along
a
westerly
transect
from
the
plots.
Sorption
studies
were
conducted
for
C14­
labeled
imidacloprid
alone.

According
to
the
paper,
on
the
day
following
application,
residues
of
both
pesticides
had
dropped
by
greater
than
96%.
Within
the
next
two
weeks,
both
pesticides
were
recovered
from
the
plots
with
levels
close
to
the
detection
limits.
Imidacloprid
was
still
detected
at
28
days
after
application,
but
carbaryl
residues
were
below
the
detection
limit.
Residues
on
neither
pesticide
were
detected
in
any
sediment
samples
collected
along
the
transect
away
from
the
plots
in
the
direction
of
tidal
flow.
Comparing
their
results
to
those
of
the
Department
of
Ecology
(
DOE)
study,
the
authors
note
that
the
DOE
had
documented
a
73%
decline
in
carbaryl
residues
after
2
days
and
carbaryl
residues
were
still
detectable
60
days
after
application
even
though
the
Felsot
and
Ruppert
studies
had
more
sensitive
detection
limits.

In
the
water
column,
carbaryl
residues
peaked
10
minutes
after
application
and
could
still
be
detected
at
concentrations
ranging
from
0.4
to
0.7
:
g/
L
28
days
post­
application.
The
report
states
however,
that
prior
to
application,
carbaryl
residues
in
the
water
were
at
0.7
:
g/
L
and
suggests
that
the
residues
may
have
persisted
from
spraying
in
the
previous
year.
Although
the
study
does
not
specifically
state
that
carbaryl
residues
persist
because
of
the
compound's
ability
to
sorb
to
sediment,
it
claims
that
imidacloprid
dissipates
rapidly
due
to
its
low
sorption
potential.
It
is
unclear
however,
that
if
carbaryl
residues
in
sediment
at
the
application
site
were
close
to
the
level
of
detection
2­
weeks
after
application
and
were
below
levels
of
detection
28­
days
post­
application,
what
exactly
is
serving
as
a
source
for
the
carbaryl.
The
report
notes
that
the
limit
of
detection
for
carbaryl
(
6
:
g/
Kg)
in
sediment
may
have
been
sufficiently
high
not
to
detect
a
potential
sink
for
the
compound;
however,
the
dissipation
half
life
of
carbaryl
in
water
and
soil,
based
on
laboratory
studies,
does
not
support
the
contention
that
carbaryl
residues
of
0.7
:
g/
L
in
the
water
column
were
a
result
of
the
previous
years
application.
Although,
the
carbaryl
residues
detected
in
the
water
are
an
order­
ofmagnitude
greater
than
reported
detection
limits
(
0.06
­
0.09
:
g/
L)
for
the
study,
the
source
of
the
carbaryl
remains
speculative.
In
reviewing
this
study,
it
is
unclear
why
carbaryl
residues
were
detected
in
the
treatment
area
prior
to
treatment.
The
results
of
this
study
are
inconsistent
with
the
results
of
the
DOE
study
(
2000)
showing
that
carbaryl
had
dropped
to
levels
below
quantitation
(
0.004
:
g/
L)
approximately
1
month
after
application.
Therefore,
it
is
uncertain
how
background
levels
of
carbaryl
reported
in
this
study
can
be
accounted
for.
143
APPENDIX
F.
ECOLOGICAL
RISK
ASSESSMENT
Risk
characterization
integrates
the
results
of
exposure
and
ecotoxicity
data
to
evaluate
the
likelihood
of
adverse
ecological
effects,
using
for
this
purpose
the
risk
quotient
(
RQ)
method.
RQs
are
calculated
by
dividing
estimated
environmental
concentrations
(
EECs)
of
the
pesticide
by
acute
and
chronic
toxicity
values.
Although
EECs
are
primarily
based
on
the
maximum
label
application
rates
for
that
pesticide,
EECs
based
on
a
Quantitative
Use
Assessment
(
QUA)
average
and
maximum
reported
(
Doane
data)
use
rates
were
also
considered
in
this
assessment.
The
74
carbaryl
registered
uses
and
application
specifications
(
methods,
maximum
label
use
rates,
number
of
applications,
and
interval
between
applications)
used
in
the
risk
assessment
for
terrestrial
organisms
are
summarized
in
Table
1.

The
ecotoxicity
test
values
(
i.
e.,
measurement
endpoints)
used
in
the
acute
and
chronic
risk
quotients
are
derived
from
the
results
of
required
studies.
Examples
of
ecotoxicity
values
derived
from
the
results
of
short­
term
laboratory
studies
that
assess
acute
effects
are:
(
1)
LC50
(
fish
and
birds)
(
2)
LD50
(
birds
and
mammals)
(
3)
EC50
(
aquatic
plants
and
aquatic
invertebrates)
and
(
4)
EC25
(
terrestrial
plants).
Examples
of
toxicity
test
effect
levels
derived
from
the
results
of
long­
term
laboratory
studies
that
assess
chronic
effects
are:
(
1)
NOEC
(
birds,
fish,
and
aquatic
invertebrates)
(
2)
NOEC
(
birds,
fish
and
aquatic
invertebrates)
and
(
3)
MATC
(
fish
and
aquatic
invertebrates).
For
birds,
mammals,
and
all
aquatic
organisms,
the
NOEC
is
the
ecotoxicity
test
value
used
in
assessing
chronic
risk.
Other
values
may
be
used
when
justified.
Table
2
lists
the
measurement
endpoints
used
for
assessing
the
risk
associated
with
the
use
of
carbaryl
to
terrestrial
and
aquatic
nontarget
organisms.
In
addition,
the
Agency
considers
any
incident
data
that
are
submitted
concerning
adverse
effects
on
nontarget
species
to
further
characterize
risk.

RQs
are
compared
to
levels
of
concern
(
LOC)
criteria
used
by
OPP
for
determining
potential
risk
to
nontarget
organisms
and
the
subsequent
need
for
possible
regulatory
action.
The
criteria
indicate
that
a
pesticide
used
as
directed
has
the
potential
to
cause
adverse
effects
on
nontarget
organisms.
Levels
of
concern
currently
address
the
following
risk
presumption
categories:
(
1)
acute,
i.
e.,
potential
for
acute
risk;
regulatory
action
may
be
warranted
in
addition
to
restricted
use
classification,
(
2)
acute
restricted
use,
i.
e.,
potential
for
acute
risk,
but
may
be
mitigated
through
restricted
use
classification;
(
3)
acute
endangered
species,
i.
e.,
potential
for
acute
risk
to
endangered
species;
regulatory
action
may
be
warranted;
(
4)
chronic
risk,
i.
e.,
the
potential
for
chronic
risk
is
high,
and
regulatory
action
may
be
warranted.
Currently,
EFED
does
not
perform
assessments
for
chronic
risk
to
plants,
acute
or
chronic
risks
to
nontarget
insects,
or
chronic
risk
from
granular/
bait
formulations
to
birds
or
mammals.
Risk
presumptions
and
the
corresponding
risk
quotients
and
levels
of
concern
are
summarized
in
Tables
3a
through
3c.
144
Table
1.
Uses,
application
rates,
and
application
intervals
used
in
the
risk
assessment
for
carbaryl1
Uses
Non­
granular
Formulations
Granular/
Bait
Use/
Crop
Appl
Rate
(
lb
ai/
A)
No.
Appl
Interval
(
days)
Max
lb/
year
Rate
(
lb
ai/
A)

Asparagus
2
5
3
10
2
Broccoli,
Brussels
sprouts,
cauliflower,
collards,
cabbage,
mustard
greens,
lettuce,
parsley,
spinach,
celery,
Swiss
chard,
(
beets,
carrots,
potato,
radish,
horseradish,
parsnip,
rutabaga,
salsify
2
3
7
6
2
Corn
(
field,
pop)
2
4
14
8
­­­­­

Sorghum
2
3
7
6
­­­­­

Rice
(
tadpole
shrimp)
1.5
2
7
4
­­­­­

Corn
(
sweet)
2
8
3
16
2
Flax,
millet,
wheat,
pasture,
grasses,
noncropland,
1.5
2
14
3
­­­­­

Cucurbits
(
melons,
cucumbers,
squash,
pumpkin)
1
6
7
6
­­­­­

Alfalfa,
clover
1.5
8
30
12
­­­­­

Rangeland
1
1
­­­­
1
­­­­­

Solanaceous
crops
(
tomato,
pepper,
eggplant),
tobacco
2
4
7
8
2
Legumes
(
beans,
peas,
lentils,
cowpeas,
soybean)
1.5
4
7
6
­­­­­

Peanuts,
sweet
potatoes
2
4
7
8
­­­­­

Sugar
beets
1.5
2
14
4
1.5
Small
fruits
&
berries
(
grape,
blueberry,
caneberry,
cranberry,
strawberry)
2
5
7
10
­­­­­

Strawberry
­­­­
­­­­
­­­­
­­­­­
2
Sunflower
1.5
2
7
3
­­­­­

Citrus
(
orange,
lemon,
grapefruit)
5,
16
4
14
20
­­­­­

Olives
7.5
2
14
15
­­­­­

Pome
fruits
(
apple,
pear)
3
5
14
15
­­­­­

Stone
fruits
(
peach,
apricot,
cherry,
nectarine,
plum/
prune)
4
3
14
14
­­­­­

Tree
nuts
(
almond,
chestnut,
filbert,
pecan,
pistachios,
walnut)
5
3
7
15
­­­­­

Forested
areas
(
non­
urban)
1
2
7
2
­­­­­

Trees
and
ornamentals
1
6
7
6
9.1
Turfgrass
8
2
7
16
9.1
Ticks
­­­­­
­­­­­
9.1
Oyster
beds
1
­­­­­
10
1
Aerial
and
ground
application
methods
for
all
uses
145
Table
2.
Terrestrial
and
aquatic
measurement
endpoints
used
in
determining
risk
of
carbaryl
to
nontarget
organisms.

Measurement
Endpoint
Toxicity
Value
Avian
acute
oral
LD50
No
assessment
done
since
carbaryl
is
practically
nontoxic
to
birds
on
an
acute
exposure
basis
Avian
subacute
dietary
LC50
No
assessment
done
since
carbaryl
is
practically
nontoxic
to
birds
on
a
subacute
dietary
exposure
basis
Avian
chronic
(
reproduction)
NOAEC
mallard
duck
=
300
ppm
Mammalian
acute
oral
LD50
rat
=
301
mg/
kg
Mammalian
chronic
(
reproduction)
NOAEC
rat
=
75
ppm
Freshwater
fish
acute
LC50
salmon
=
0.25
ppm
Freshwater
fish
acute
(
TEP)
LC50
trout
=
1.2
ppm
Freshwater
fish
chronic
NOAEC
minnow
=
0.21
ppm
Freshwater
invertebrate
acute
LC50
stonefly
=
5.1
ppb
Freshwater
invertebrate
chronic
NOAEC
waterflea
=
1.5
ppb
Estuarine/
marine
fish
acute
LC50
minnow
=
2.6
ppm
Estuarine/
marine
mollusc
acute
EC50
oyster
=
2.7
ppm
Estuarine/
marine
shrimp
EC50
mysid
=
5.7
ppb
Estuarine/
marine
fish
chronic
NOAEC
no
data
Estuarine/
marine
aquatic
invertebrate
chronic
NOAEC
no
data
Table
3a.
Risk
presumptions
for
terrestrial
animals
Risk
Presumption
Risk
Quotient
(
RQ)
Level
of
Concern
(
LOC)

Birds
Acute
Risk
EEC1/
LC50
or
LD50/
sqft2
or
LD50/
day3
0.5
Acute
Restricted
Use
EEC/
LC50
or
LD50/
sqft
or
LD50/
day
(
or
LD50
<
50
mg/
kg)
0.2
Acute
Endangered
Species
EEC/
LC50
or
LD50/
sqft
or
LD50/
day
0.1
Chronic
Risk
EEC/
NOAEC
1
Wild
Mammals
Acute
Risk
EEC/
LC50
or
LD50/
sqft
or
LD50/
day
0.5
Acute
Restricted
Use
EEC/
LC50
or
LD50/
sqft
or
LD50/
day
(
or
LD50
<
50
mg/
kg)
0.2
Acute
Endangered
Species
EEC/
LC50
or
LD50/
sqft
or
LD50/
day
0.1
Chronic
Risk
EEC/
NOAEC
1
1
abbreviation
for
Estimated
Environmental
Concentration
(
ppm)
on
avian/
mammalian
food
items
2
mg/
ft2
3
mg
of
toxicant
consumed/
day
LD50
*
wt.
of
bird
LD50
*
wt.
of
bird
146
Table
3b.
Risk
presumptions
for
aquatic
animals
Risk
Presumption
RQ
LOC
Acute
Risk
EEC1/
LC50
or
EC50
0.5
Acute
Restricted
Use
EEC/
LC50
or
EC50
0.1
Acute
Endangered
Species
EEC/
LC50
or
EC50
0.05
Chronic
Risk
EEC/
NOAEC
1
1
EEC
=
(
ppm
or
ppb)
in
water
Table
3c.
Risk
presumptions
for
plants
Risk
Presumption
RQ
LOC
Plant
Inhabiting
Terrestrial
and
Semi­
Aquatic
Areas
Acute
Risk
EEC1/
EC25
1
Acute
Endangered
Species
EEC/
EC05
or
NOAEC
1
Aquatic
Plants
Acute
Risk
EEC2/
EC50
1
Acute
Endangered
Species
EEC/
EC05
or
NOAEC
1
1
EEC
=
lbs
a.
i./
A
2
EEC
=
(
ppb
or
ppm)
in
water
Exposure
and
Risk
to
Nontarget
Terrestrial
Animals
For
nongranular
pesticide
applications
(
e.
g.,
liquid,
dust),
the
estimated
environmental
concentrations
(
EECs)
on
food
items
following
product
application
are
compared
to
LC50
values
to
assess
risk.
The
predicted
0­
day
maximum
and
mean
residues
of
a
pesticide
that
may
be
expected
to
occur
on
selected
avian
or
mammalian
food
items
immediately
following
a
direct
single
application
at
1
lb
a.
i./
A
are
tabulated
in
Table
4.

Table
4.
Estimated
environmental
concentrations
(
EECs)
on
avian
and
mammalian
food
items
(
ppm)
following
a
single
application
at
1
lb
a.
i./
A)

Food
Items
EEC
(
ppm)
Predicted
Maximum
Residue1
EEC
(
ppm)
Predicted
Mean
Residue1
Short
grass
240
85
Tall
grass
110
36
Broadleaf/
forage
plants
and
small
insects
135
45
Fruits,
pods,
seeds,
and
large
insects
15
7
1
Predicted
maximum
and
mean
residues
are
for
a
1
lb
a.
i./
a
application
rate
and
are
based
on
Hoerger
and
Kenaga
(
1972)
as
modified
by
Fletcher
et
al.
(
1994).
147
Avian
Acute
and
Chronic
Risk
Risk
from
Exposure
to
Nongranular
Products
Based
on
an
avian
subacute
dietary
LC50
of
greater
than
5,000
ppm
(
Appendix
D1),
with
zero
mortality
observed
at
this
concentration
for
the
four
avian
species
tested,
carbaryl
is
classified
as
practically
nontoxic
to
birds.
Since
the
acute
toxicity
measurement
endpoint
exceeded
the
highest
required
test
dose,
i.
e.,
5000
ppm,
acute
risk
quotient
values
have
not
been
calculated
and
acute
risk
to
birds
is
assumed
to
lie
below
the
established
level
of
concern,
i.
e.,
RQ
<
0.1.

Based
on
an
avian
NOAEC
of
300
ppm
and
maximum
label
application
rates,
for
birds
feeding
on
short
grasses
the
avian
chronic
risk
LOC
is
exceeded
for
all
nongranular
uses
(
Table
5a)
except
rangeland.
For
tall
grass
feeders,
the
avian
chronic
LOC
is
exceeded
for
55%
of
the
modeled
use
categories.
For
birds
feeding
on
broadleaf/
forage
plants
and
small
insects
the
avian
chronic
LOC
is
exceeded
for
60%
of
the
use
categories.
The
chronic
LOC
for
birds
feeding
on
fruits,
pods,
seeds,
and
large
insects
is
not
exceeded
for
any
of
the
carbaryl
uses.

In
addition
to
maximum
label
use
rates,
avian
chronic
RQs
were
also
calculated
for
nongranular
carbaryl
using
QUA
average
use
rates
(
Table
5b)
for
70
use
sites,
as
well
as
maximum
reported
(
Doane
data)
use
rates
for
42
use
sites
(
Table
5c).
When
RQs
are
based
on
average
application
rates,
the
chronic
risk
LOC
is
exceeded
for
34
of
70
(
49%)
uses.
For
RQs
based
on
maximum
reported
use
rates,
the
chronic
risk
LOC
is
met
or
exceeded
for
81%
of
the
uses.

Table
5a.
Avian
chronic
RQs
for
multiple
applications
of
nongranular
carbaryl
(
broadcast)
based
on
a
mallard
duck
NOAEC
of
300
ppm,
and
maximum
label
application
rates.

Uses
Appl.
Rate
No.
Appl.
Interval
Food
Items
Maximum
EEC
a
(
ppm)
NOAEC
(
ppm)
Chron.
RQ
(
EEC/
NOAEC)

Citrus
(
orange,
lemon,
grapefruit)
5
lb
ai/
A
4
appl
14
days
Short
grass
Tall
grass
Broadleaf
plants,
sm.
ins.
Fruit,
seeds,
lg.
insects
1294
593
728
81
300
4.31
b
1.98
b
2.42
b
0.27
Citrus
(
California)
16
lb
ai/
A
1
appl
Short
grass
Tall
grass
Broadleaf
plants,
sm.
ins.
Fruit,
seeds,
lg.
insects
3840
1760
2160
240
300
12.8
b
5.87
b
7.20
b
0.80
Olives
7.5
lb
ai/
A
2
appl
14
days
Short
grass
Tall
grass
Broadleaf
plants,
sm.
ins.
Fruit,
seeds,
lg.
insects
1931
885
1086
121
300
6.44
b
2.95
b
3.62
b
0.40
Pome
fruits
(
apple,
pear)
3
lb
ai/
A
5
appl
14
days
Short
grass
Tall
grass
Broadleaf
plants,
sm.
ins.
Fruit,
seeds,
lg.
insects
777
356
437
49
300
2.59
b
1.19
b
1.46
b
0.16
Stone
fruits
(
peaches,
apricot,
cherry,
nectarine,
plum/
prune)
4
lb
ai/
A
3
appl
14
days
Short
grass
Tall
grass
Broadleaf
plants,
sm.
ins.
Fruit,
seeds,
lg.
insects
1035
474
582
65
300
3.45
b
1.58
b
1.94
b
0.22
Uses
Appl.
Rate
No.
Appl.
Interval
Food
Items
Maximum
EEC
a
(
ppm)
NOAEC
(
ppm)
Chron.
RQ
(
EEC/
NOAEC)

148
Tree
nuts
(
almond,
chestnut,
filbert,
pecan,
pistachios,
walnut)
5
lb
ai/
A
3
appl
7
days
Short
grass
Tall
grass
Broadleaf
plants,
sm.
ins.
Fruit,
seeds,
lg.
insects
1612
739
907
101
300
5.37
b
2.46
b
3.02
b
0.34
Corn
(
field,
pop)
2
lb
ai/
A
4
appl
14
days
Short
grass
Tall
grass
Broadleaf
plants,
sm.
ins.
Fruit,
seeds,
lg.
insects
518
238
291
32
300
1.73
b
0.79
0.97
0.11
Corn
(
sweet)
2
lb
ai/
A
8
appl
3
days
Short
grass
Tall
grass
Broadleaf
plants,
sm.
ins.
Fruit,
seeds,
lg.
insects
1106
507
622
69
300
3.69
b
1.69
b
2.07
b
0.23
Rice,
sunflower
1.5
lb
ai/
A
2
appl
7
days
Short
grass
Tall
grass
Broadleaf
plants,
sm.
ins.
Fruit,
seeds,
lg.
insects
457
210
257
29
300
1.52
b
0.70
0.86
0.10
Sugar
beets,
wheat,
millet,
flax,
pasture,
grasses,
noncropland
1.5
lb
ai/
A
2
appl
14
days
Short
grass
Tall
grass
Broadleaf
plants,
sm.
ins.
Fruit,
seeds,
lg.
insects
386
177
217
24
300
1.29
b
0.59
0.72
0.08
Asparagus
2
lb
ai/
A
5
appl
3
days
Short
grass
Tall
grass
Broadleaf
plants,
sm.
ins.
Fruit,
seeds,
lg.
insects
1051
481
591
66
300
3.50
b
1.60
b
1.97
b
0.22
Broccoli,
Brussels
sprouts,
cabbage,
cauliflower,
collards,
mustard
greens,
celery,
lettuce,
parsley,
spinach,
beets,
potato,
carrot,
horseradish,
parsnip,
rutabaga,
salsify,
sorghum
2
lb
ai/
A
3
appl
7
days
Short
grass
Tall
grass
Broadleaf
plants,
sm.
ins.
Fruit,
seeds,
lg.
insects
645
296
363
40
300
2.15
b
0.99
1.21
b
0.13
Cucurbits
(
cucumbers,
melons,
squash,
pumpkin),
trees
and
ornamentals
1
lb
ai/
A
6
appl
7
days
Short
grass
Tall
grass
Broadleaf
plants,
sm.
ins.
Fruit,
seeds,
lg.
insects
329
151
185
21
300
1.10
b
0.50
0.62
0.07
Solanaceous
(
tomato,
pepper,
eggplant),
peanuts,
tobacco,
sweet
potato
2
lb
ai/
A
4
appl
7
days
Short
grass
Tall
grass
Broadleaf
plants,
sm.
ins.
Fruit,
seeds,
lg.
insects
654
300
368
41
300
2.18
b
1.00
b
1.23
b
0.14
Legumes
(
beans,
peas,
lentils,
cowpeas,
soybeans)
1.5
lb
ai/
A
4
appl
7
days
Short
grass
Tall
grass
Broadleaf
plants,
sm.
ins.
Fruit,
seeds,
lg.
insects
491
225
276
31
300
1.64
b
0.75
0.92
0.10
Small
fruits
&
berries
(
grapes,
blueberry,
caneberry,
cranberry,
strawberry)
2
lb
ai/
A
5
appl
7
days
Short
grass
Tall
grass
Broadleaf
plants,
sm.
ins.
Fruit,
seeds,
lg.
insects
657
301
369
41
300
2.19
b
1.00
b
1.23
b
0.14
Alfalfa,
clover
1.5
lb
ai/
A
8
appl
30
days
Short
grass
Tall
grass
Broadleaf
plants,
sm.
ins.
Fruit,
seeds,
lg.
insects
361
166
293
23
300
1.20
b
0.55
0.98
0.08
Rangeland
1
lb
ai/
A
1
appl
Short
grass
Tall
grass
Broadleaf
plants,
sm.
ins.
Fruit,
seeds,
lg.
insects
240
110
135
15
300
0.80
0.37
0.45
0.05
Uses
Appl.
Rate
No.
Appl.
Interval
Food
Items
Maximum
EEC
a
(
ppm)
NOAEC
(
ppm)
Chron.
RQ
(
EEC/
NOAEC)

149
Forested
areas
(
non­
urban)
1
lb
ai/
A
2
appl
7
days
Short
grass
Tall
grass
Broadleaf
plants,
sm.
ins.
Fruit,
seeds,
lg.
insects
305
140
171
19
300
1.02
b
0.47
0.57
0.06
Turfgrass
8
lb
ai/
A
2
appl
7
days
Short
grass
Tall
grass
Broadleaf
plants,
sm.
ins.
Fruit,
seeds,
lg.
insects
2439
1118
1372
152
300
8.13
b
3.73
b
4.57
b
0.51
a
Predicted
maximum
residues
are
for
a
1
lb
a.
i./
a
application
rate
and
are
based
on
Hoerger
and
Kenaga
(
1972)
as
modified
by
Fletcher
et
al.
(
1994).
b
Exceeds
chronic
level
of
concern
(
RQ
$
1.0)

Table
5b.
Avian
chronic
risk
quotientsa
for
multiple
applications
of
nongranular
carbaryl
based
on
a
mallard
duck
NOAEC
of
300
ppm
and
QUA
average
application
rates
for
70
uses
Use
site
(
Appl.
Rate
[
lb
ai/
A],
No.
Applications,
Interval)
Chronic
RQ
(
EEC/
NOAEC)
Use
Site
(
Appl.
Rate
[
lb
ai/
A],
No.
Applications,
Interval)
Chronic
RQ
(
EEC/
NOAEC)

Alfalfa
(
1.1,
1)
Almonds
(
2.1,
1)
Apples
(
1.2,
1)
Asparagus
(
0.9,
1)
Beans,
Dry
(
0.5,
1)
Beans,
Lima,
Fresh
(
0.9,
1)
Beans,
Snap,
Fresh
(
0.9,
2,
7)
Beans,
Snap,
Processed
(
0.7,
2,
7)
Beets
(
0.5,
1)
Blackberries
(
1.7,
1)
Blueberries
(
1.7,
1)
Broccoli
(
0.8,
1)
Brussels
Sprouts
(
0.9,
1)
Chinese
Cabbage
(
0.2,
1)
Fresh
Cabbage
(
1.0,
2,
7)
Cantaloupes
(
0.8,
1)
Carrots
(
0.9,
2,
7)
Cauliflower
(
1.1,
1)
Celery
(
1.0,
2,
7)
Cherries
(
1.9,
1)
Citrus,
other
(
1.8,
2,
14)
Corn,
Field
(
1.0,
1)
Cranberries
(
2.0,
1)
Cucumbers
(
1.1,
1)
Cucumbers,
Processed
(
0.6,
2,
7)
Eggplant
(
1.0,
2,
7)
Flax
(
1.1,
1)
Grapefruit
(
1.4,
2,
14)
Grapes
(
1.4,
2,
7)
Hay
(
0.8,
1)
Hazelnuts
(
2.5,
1)
Lemons
(
2.7,
1)
Lettuce
(
1.1,
1)
Lots/
Farmsteads
(
0.4,
2,
14)
Melons
(
0.7,
1)
0.89
1.68
b
0.96
0.72
0.40
0.72
0.91
0.71
0.40
1.36
b
1.36
b
0.64
0.72
0.16
1.02
b
0.64
0.91
0.88
1.02
b
1.52
b
1.55
b
0.80
1.60
b
0.88
0.61
1.02
b
0.88
1.20
b
1.42
b
0.64
2.00
b
2.16
b
0.88
0.68
0.56
Nectarines
(
3.8,
1)
Okra
(
1.9,
1)
Olives
(
5.3,
1)
Oranges
(
3.4,
1)
Pasture
(
0.9,
1)
Peaches
(
1.0,
3,
7)
Peanuts
(
0.8,
1)
Pears
(
1.0,
1,2
Pears,
Dry
(
1.0,
1)
Peas,
Green
(
1.5,
1)
Pecans
(
1.4,
2)
Peppers,
Bell
(
0.9,
2)
Peppers,
Sweet
(
1.3,
1)
Pistachios
(
3.6,
1)
Plums
(
3.8,
1)
Potatoes
(
0.8,
2)
Pumpkins
(
2.0,
2)
Raspberries
(
2.8,
1)
Rice
(
1.1,
1)
Sorghum
(
1.1,
1)
Soybeans
(
0.9,
1)
Squash
(
1.4,
1)
Strawberries
(
1.4,
2)
Sugar
Beets
(
1.3,
1)
Sunflower
(
0.7,
1)
Sweet
Corn,
Fresh
(
1.3,
3,
3)
Sweet
Potatoes
(
1.6,
1)
Tobacco
(
1.1,
2,7)
Tomatoes,
Fresh
(
0.7,
3,
7)
Tomatoes,
Processed
(
1.2,
1)
Walnuts
(
1.9,
1)
Watermelons
(
0.5,
1)
Wheat,
Spring
(
0.6,
1)
Wheat,
Winter
(
0.8,
1)
Woodland
(
0.7,
1)
3.04
b
1.52
b
4.24
b
2.72
b
0.72
1.07
b
0.64
0.80
0.80
1.20
b
2.10
b
1.35
b
1.04
b
2.88
b
3.04
b
1.20
b
2.99
b
2.24
b
0.88
0.88
0.72
1.12
b
2.10
b
1.04
b
0.32
1.97
b
1.28
b
1.12
b
0.75
0.96
1.52
b
0.40
0.48
0.64
0.32
aOnly
the
highest
RQs
­­
i.
e.
those
based
on
short
grass
EECs
­­
are
included
in
this
table.
b
Exceeds
chronic
level
of
concern
(
RQ
$
1.0)
150
Table
5c.
Avian
chronic
risk
quotients1
for
multiple
applications
of
nongranular
carbaryl
based
on
a
mallard
duck
NOAEC
of
300
ppm,
and
maximum
reported
use
rates
(
Doane
data)
for
42
use
sites
Use
site
[
appl.
rate
(
lb
ai/
A),
No.
appl]
Chronic
RQ
(
EEC/
NOAEC)
Use
Site
[
appl.
rate
(
lb
ai/
A)
No.
appl]
Chronic
RQ
(
EEC/
NOAEC)

Alfalfa
(
1.5,
1)
Almonds
(
4,
1)
Apples
(
3.2,
1)
Apricots
(
4,
1)
Asparagus
(
4,
1)
Beans,
Lima,
(
1.3,1)
Beans,
snap
(
1.6,1)
Cabbage
(
2,1)
Canola
(
0.5,
1)
Cantaloupe
(
1.2,
1)
Carrots
(
0.8,
1)
Cauliflower
(
1,
1)
Celery
(
2,
1)
Cherries
(
5,
1)
Corn,
Field
(
1.5,
2,
14)
Cucumbers
(
1,
1)
Grapefruit
(
12.8,
1)
Grapes
(
2.5,1)
Lemons
(
8,1)
Lettuce
(
1,
1)
Oranges
(
15,
1)
1.2
b
3.2
b
2.6
b
3.2
b
3.2
b
1.0
b
1.3
b
1.6
b
0.4
1.0
b
0.6
0.8
1.6
b
4.0
b
1.3
b
0.8
10.2
b
2.0
b
6.4
b
0.8
12.0
b
Peaches
(
5,1)
Peanuts
(
2,
1)
Pears
(
2,
1)
Pecans
(
3,
2,
7)
Peppers
(
2,
1)
Pistachios
(
5,
1)
Plums
(
4,
1)
Potatoes
(
1.5,
1)
Pumpkins
(
1.5,
1)
Rice
(
1.3,
1)
Sorghum
(
0.5,
1)
Squash
(
1.2,
1)
Sugar
Beets
(
1.2,
1)
Sunflower
(
1,
1)
Strawberries
(
2,1)
Sweet
Corn
(
1.5,
2,
3)
Tobacco
(
2,
1)
Tomatoes
(
2,1)
Walnuts
(
4,
1)
Watermelons
(
2,
1)
Wheat
(
1,1)
4.0
b
1.6
b
1.6
b
3.1
b
1.6
b
4.0
b
3.2
b
1.2
b
1.2
b
1.0
b
0.4
1.0
b
1.0
b
0.8
1.6
b
1.9
b
1.6
b
1.6
b
3.2
b
1.6
b
0.8
aOnly
the
highest
RQs
­­
i.
e.
those
based
on
short
grass
EECs
­­
are
included
in
this
table.
b
Exceeds
chronic
level
of
concern
(
RQ
$
1.0)

Risk
from
Exposure
to
Granular
Products
Birds
may
be
exposed
to
granular
pesticides
by
ingesting
granules
when
foraging
for
food
or
grit.
Birds
may
also
be
exposed
by
other
routes,
such
as
by
walking
on
exposed
granules
or
by
drinking
water
contaminated
with
granules.
The
number
of
lethal
doses
(
LD50)
that
are
available
within
one
square
foot
immediately
after
application
(
LD50/
ft2)
is
used
as
the
risk
quotient
for
granular/
bait
products.
Typically,
risk
quotients
are
calculated
for
birds
in
three
separate
weight
classes:
1000
g
(
e.
g.
waterfowl),
180
g
(
e.
g.
upland
gamebirds),
and
20
g
(
e.
g.,
songbirds).

Based
on
a
mallard
LD50
greater
than
2,000
mg/
kg,
technical
carbaryl
can
be
classified
as
slightly
to
practically
nontoxic
to
birds
on
an
acute
exposure
basis.
LD50
values
for
carbaryl
as
low
as
16.2
mg/
kg
and
56.2
mg/
kg
have
been
reported
for
the
starling
and
the
red­
winged
blackbird,
respectively
(
Schafer
et
al.,
1983).
Although
these
data
are
based
on
simple
screening
tests,
and
are
therefore
not
reliable
for
risk
assessment
purposes,
they
do
suggest
that
passerine
birds
may
be
significantly
more
sensitive
to
carbaryl
exposure
than
non­
passerine
birds.
The
registrant
is
strongly
encouraged
to
submit
acute
oral
toxicity
tests
with
passerine
avian
species.
Because
of
the
low
acute
oral
toxicity
of
carbaryl
to
mallard
ducks
though,
risk
from
exposure
to
granular
products
is
expected
to
be
minimal
(
RQ
<
0.1).
151
Mammalian
Acute
and
Chronic
Risk
Estimating
the
potential
for
adverse
effects
to
wild
mammals
is
based
upon
EFED's
draft
1995
SOP
of
mammalian
risk
assessments
and
methods
used
by
Hoerger
and
Kenaga
(
1972)
as
modified
by
Fletcher
et
al.
(
1994).
The
concentration
of
carbaryl
in
the
diet
that
is
expected
to
be
acutely
lethal
to
50%
of
the
test
population
(
LC50
)
is
determined
by
dividing
the
LD50
value
(
usually
rat
LD50)
by
the
%
(
decimal
of)
body
weight
consumed.
A
risk
quotient
is
then
determined
by
dividing
the
EEC
by
the
derived
LC50
value.
Risk
quotients
are
calculated
for
three
separate
weight
classes
of
mammals
(
15,
35,
and
1000
g),
each
presumed
to
consume
four
different
kinds
of
food
(
grass,
forage,
insects,
and
seeds).
The
acute
risk
quotients
for
broadcast
applications
of
nongranular
products
are
tabulated
below.

Risk
from
Exposure
to
Nongranular
Products
short
grass
The
mammalian
acute
risk
LOC
is
exceeded
for
all
registered
nongranular
carbaryl
uses,
at
maximum
label
application
rates,
for
short
grass
feeders
with
a
daily
food
consumption
equal
to
95%
and
66%
of
their
body
weight,
with
RQ
values
ranging
from
0.76
to
12
and
from
0.53
to
8.4,
respectively
(
Table
6).
The
acute
risk
LOC
for
herbivores
consuming
daily
15%
of
their
body
weight
are
exceeded
for
8
out
of
20
(
40%)
of
the
use
categories
(
RQs:
0.52
­
1.91).
The
acute
endangered
species
LOC
is
exceeded
for
all
herbivores.

Broadleaf/
forage
plants
and
small
insects
The
acute
risk
LOC
is
exceeded
for
all
nongranular
carbaryl
uses
except
rangeland
for
small
mammals
feeding
on
broadleaf/
forage
plants
and
small
insects,
with
RQs
in
the
0.54
­
6.82
range
for
mammals
with
a
daily
food
consumption
equal
to
95%
of
their
body
weights
(
Table
6).
Acute
risk
LOC
is
also
exceeded
for
75%
of
the
use
categories
for
mammals
consuming
66%
of
their
body
weights
(
RQs:
0.56
to
4.74).
For
mammals
consuming
15
%
of
their
body
weight,
the
acute
risk
LOC
is
reached
or
exceeded
for
olives
and
turfgrass
(
RQs:
0.54
­
0.68).
RQs
equal
or
exceed
the
acute
restricted
use
or
the
endangered
species
LOCs
for
most
other
uses
except
cucurbits,
trees,
ornamentals,
rangeland,
and
forested
areas.

Fruit,
pods,
seeds,
and
large
insects
The
acute
risk
LOC
is
only
exceeded
in
citrus
for
small
mammals
consuming
95%
(
RQ
=
0.76)
and
66%
(
RQ
=
0.53)
of
these
food
items.
For
mammals
that
consume
15%
of
their
body
weight,
the
acute
risk
LOC
is
not
exceeded
for
any
use;
however,
the
acute
endangered
species
LOC
is
exceeded
for
citrus.
152
Table
6.
Mammalian
(
herbivore/
insectivore)
acute
risk
quotients
for
multiple
applications
of
nongranular
carbaryl
(
broadcast)
based
on
a
rat
LD50
of
301
mg/
kg
and
maximum
label
use
rates.

Uses,
Application
Rate,
No.
Applications,
Interval
Body
Wt
(
g)
%
Body
Weight
Con_
sumed
LC50
(
LD50/%
Body
Wt
Con_
sumed
EEC:
Short
Grass
(
ppm)
EEC:
Forage
&
Small
Insects
(
ppm)
EEC:
Fruit,
Seeds,
Lg
Insects
(
ppm)
Acute
RQ:
Short
Grass
Acute
RQ:
Forage
&
Small
Insects
Acute
RQ:
Large
Insects
Citrus,
5
lb
ai/
A,
4
appl,
14
days
15
35
1000
95
66
15
316.84
456.06
2006.67
1294.49
728.15
80.91
4.08
a
2.83
a
0.65
a
2.29
a
1.60
a
0.36
b
0.26
b
0.18
c
0.04
Citrus
(
California),
16
lb
ai/
A,
1
appl
15
35
1000
95
66
15
316.84
456.06
2006.67
3840.00
2160.00
240.00
12.1
a
8.41
a
1.91
a
6.82
a
4.74
a
1.08
a
0.76
a
0.53
a
0.12
c
Olives,
7.5
lb
ai/
A
2
appl,
14
days
15
35
1000
95
66
15
316.84
456.06
2006.67
1931.43
1086.43
120.71
6.10
a
4.24
a
0.96
a
3.43
a
2.38
a
0.54
a
0.38
b
0.26
b
0.06
Pome
fruits
(
apples,
etc.),
3
lb
ai/
A,
5
appl,
14
days
15
35
1000
95
66
15
316.84
456.06
2006.67
776.71
436.90
48.54
2.45
a
1.70
a
0.39
b
1.38
a
0.96
a
0.22
b
0.15
c
0.11
c
0.02
Stone
fruits
(
peaches,
etc.),
4
lb
ai/
A,
3
appl,
14
days
15
35
1000
95
66
15
316.84
456.06
2006.67
1035.21
582.31
64.70
3.26
a
2.27
a
0.52
a
1.84
a
1.28
a
0.29
b
0.20
b
0.14
c
0.03
Tree
nuts
(
pistachios,
etc.),
5
lb
ai/
A,
3
appl,
7
days
15
35
1000
95
66
15
316.84
456.06
2006.67
1611.88
906.68
100.74
5.09
a
3.53
a
0.80
a
2.86
a
1.99
a
0.45
b
0.32
b
0.22
b
0.05
Corn,
field,
2
lb
ai/
A
4
appl,
14
days
15
35
1000
95
66
15
316.84
456.06
2006.67
517.79
291.26
32.36
1.63
a
1.14
a
0.26
b
0.92
a
0.64
a
0.15
c
0.10
c
0.07
0.02
Corn,
sweet,
2
lb
ai/
A
8
appl,
3
days
15
35
1000
95
66
15
316.84
456.06
2006.67
1105.64
621.93
69.10
3.49
a
2.42
a
0.55
a
1.96
a
1.36
a
0.31
b
0.22
b
0.15
c
0.03
Rice
(
tadpole
shrimp),
sunflower,
1.5
lb
ai/
A,
2
appl,
7
days
15
35
1000
95
66
15
316.84
456.06
2006.67
457.28
257.22
28.58
1.44
a
1.00
a
0.23
b
0.81
a
0.56
a
0.13
c
0.09
0.06
0.01
Sugar
beets,
wheat,
millet,
flax,
pasture,
grasses,
noncropland
1.5
lb
ai/
A,
2
appl,
14
days
15
35
1000
95
66
15
316.84
456.06
2006.67
386.29
217.29
24.14
1.22
a
0.84
a
0.19
c
0.69
a
0.48
b
0.11
c
0.08
0.05
0.01
Asparagus,
2
lb
ai/
A,
5
appl,
3
days
15
35
1000
95
66
15
316.84
456.06
2006.67
1050.51
590.91
65.66
3.32
a
2.30
a
0.52
a
1.87
a
1.30
a
0.29
b
0.21
b
0.14
c
0.03
Cucurbits
(
cucumbers
melons,
squash,
etc.),
trees
&
ornamentals,
1
lb
ai/
A,
6
appl,
7
days
15
35
1000
95
66
15
316.84
456.06
2006.67
328.74
184.91
20.55
1.04
a
0.72
a
0.16
c
0.58
a
0.41
b
0.09
0.06
0.05
0.01
Solanaceous
(
peppers,
tomatoes,
eggplant),
sweet
potatoes,
peanuts,
tobacco,
2
lb
ai/
A,
4
appl,
7
days
15
35
1000
95
66
15
316.84
456.06
2006.67
654.22
368.00
40.89
2.06
a
1.43
a
0.33
b
1.16
a
0.81
a
0.18
c
0.31
b
0.09
0.02
153
Leafy
veg
(
celery,
lettuce,
etc.),
Brassica
(
broccoli,
cabbage,
etc.),
roots
&
tubers
(
carrots,
potatoes,
etc.),
sorghum,
2
lb
ai/
A,
3
appl,
7
days
15
35
1000
95
66
15
316.84
456.06
2006.67
644.75
362.67
40.30
2.03
a
1.41
a
0.32
b
1.14
a
0.80
a
0.18
c
0.13
c
0.09
0.02
Legumes
(
beans,
peas,
lentils,
cowpeas),
1.5
lb
ai/
A,
4
appl,
7
days
15
35
1000
95
66
15
316.84
456.06
2006.67
490.67
276.00
30.67
1.55
a
1.08
a
0.24
b
0.87
a
0.61
a
0.14
c
0.10
c
0.07
0.02
Small
fruits
&
berries
(
grapes,
strawberries,
etc.),
2
lb
ai/
A,
5
appl
7
days
15
35
1000
95
66
15
316.84
456.06
2006.67
656.78
369.44
41.05
2.07
a
1.44
a
0.33
b
1.17
a
0.81
a
0.18
c
0.13
c
0.09
0.02
Alfalfa,
clover,
1.5
lb
ai/
A,
10
appl,
30
days
15
35
1000
95
66
15
316.84
456.06
2006.67
361.33
203.25
22.58
1.14
a
0.79
a
0.18
c
0.64
a
0.45
b
0.10
c
0.07
0.05
0.01
Rangeland,
1
lb
ai/
A,
1
appl
15
35
1000
95
66
15
316.84
456.06
2006.67
240.00
135.00
15.00
0.76
a
0.53
a
0.12
c
0.43
b
0.30
b
0.07
0.05
0.03
<
0.01
Forested
areas
(
non­
urban),
1
lb
ai/
A,
2
appl,
7
days
15
35
1000
95
66
15
316.84
456.06
2006.67
304.85
171.48
19.05
0.96
a
0.67
a
0.15
c
0.54
a
0.38
b
0.09
0.06
0.04
0.01
Turfgrass,
8
lb
ai/
A,
2
appl,
7
days
15
35
1000
95
66
15
316.84
456.06
2006.67
2438.82
1371.83
152.43
7.70
a
5.35
a
1.22
a
4.33
a
3.01
a
0.68
a
0.48
b
0.33
b
0.08
a
Exceeds
acute
high
risk
(
RQ
$
0.5),
restricted
use
(
RQ
$
0.2)
and
endangered
species
level
of
concern
(
RQ
$
0.1)
b
Exceeds
restricted
use
(
RQ
$
0.2)
and
endangered
species
level
of
concern
(
RQ
$
0.1)
c
Exceeds
endangered
species
level
of
concern
(
RQ
$
0.1)

Although
neither
the
acute
risk
nor
the
acute
restricted
use
LOC
is
exceeded
for
granivores
for
any
of
the
nongranular
carbaryl
uses,
the
acute
endangered
species
LOC
is
reached
or
exceeded
for
citrus
and
turfgrass
(
RQs:
0.11
­
0.17),
and
for
citrus
alone
(
RQs
=
0.12),
for
granivores
with
daily
food
consumption
equal
to
21%
and
15%
of
their
body
weight,
respectively
(
Table
7).
No
acute
LOCs
are
exceeded
for
granivores
which
consume
daily
3%
of
their
body
weight.

Table
7.
Mammalian
(
granivore)
acute
risk
quotients
for
multiple
applications
of
nongranular
carbaryl
(
broadcast)
based
on
a
rat
LD50
of
301
mg/
kg
and
maximum
label
use
rates.

Uses,
Application
Rate,
No.
Applications,
Interval
Body
Weight
(
g)
%
Body
Weight
Consumed
LC50
(
LD50
÷
%
Body
Weight
Consumed)
EEC:
Seeds
(
ppm)
Acute
RQ:
Seeds
Citrus,
5
lb
ai/
A,
4
appl,
14
days
15
35
1000
21
15
3
1433.33
2000.67
10033.33
80.91
0.06
0.04
0.01
Citrus
(
California),
16
lb
ai/
A,
1
appl
15
35
1000
21
15
3
1433.33
2000.67
10033.33
240.00
0.17
a
0.12
a
0.02
Olives,
7.5
lb
ai/
A,
2
appl,
14
days
15
35
1000
21
15
3
1433.33
2000.67
10033.33
120.71
0.08
0.06
0.01
154
Pome
fruits
(
apple,
pear,
etc.),
3
lb
ai/
A,
3
appl,
14
days
15
35
1000
21
15
3
1433.33
2000.67
10033.33
48.53
0.03
0.02
<
0.01
Stone
fruits
(
peach,
apricot,
etc.),
4
lb
ai/
A,
3
appl,
14
days
15
35
1000
21
15
3
1433.33
2000.67
10033.33
64.70
0.05
0.03
0.01
Tree
nuts
(
pistachios,
etc.),
5
lb
ai/
A,
3
appl,
7
days
15
35
1000
21
15
3
1433.33
2000.67
10033.33
80.88
0.06
0.04
0.01
Corn,
field,
2
lb
ai/
A,
4
appl,
14
days
15
35
1000
21
15
3
1433.33
2000.67
10033.33
32.36
0.02
0.02
<
0.01
Corn,
sweet,
2
lb
ai/
A,
8
appl,
3
days
15
35
1000
21
15
3
1433.33
2000.67
10033.33
69.10
0.05
0.03
0.01
Rice,
sunflower,
1.5
lb
ai/
A,
2
appl,
7
days
15
35
1000
21
15
3
1433.33
2000.67
10033.33
28.58
0.02
0.01
<
0.01
Sugar
beets,
wheat
&
millet,
flax,
pasture,
grasses,
noncropland,
1.5
lb
ai/
A,
2
appl,
14
days
15
35
1000
21
15
3
1433.33
2000.67
10033.33
21.14
0.02
0.01
<
0.01
Asparagus,
4
lb
ai/
A,
2
appl,
7
days
15
35
1000
21
15
3
1433.33
2000.67
10033.33
76.21
0.05
0.04
0.01
Brassica
crops
(
broccoli,
cabbage,
etc.),
leafy
veg
(
celery,
lettuce,
etc.),
Roots
&
tubers
(
beets,
carrot,
potato,
etc.),
sorghum,
2
lb
ai/
A,
3
appl,
7
days
15
35
1000
21
15
3
1433.33
2000.67
10033.33
40.30
0.03
0.02
<
0.01
Cucurbits
(
cucumbers,
melons,
squash,
etc.),
trees
and
ornamentals,
1
lb
ai/
A,
6
appl,
7
days
15
35
1000
21
15
3
1433.33
2000.67
10033.33
20.55
0.01
0.01
<
0.01
Solanaceous
(
pepper,
tomato,
eggplant),
sweet
potato,
peanuts,
tobacco,
2
lb
ai/
A,
4
appl,
7
days
15
35
1000
21
15
3
1433.33
2000.67
10033.33
40.89
0.03
0.02
<
0.01
Legumes
(
beans,
peas,
lentils,
cowpeas),
1.5
lb
ai/
A,
4
appl,
7
days
15
35
1000
21
15
3
1433.33
2000.67
10033.33
30.67
0.02
0.02
<
0.01
Small
fruits
&
berries
(
grapes,
strawberries,
etc.),
2
lb
ai/
A,
5
appl
7
days
15
35
1000
21
15
3
1433.33
2000.67
10033.33
41.05
0.03
0.02
<
0.01
Alfalfa,
clover,
1.5
lb
ai/
A,
10
appl,
30
days
15
35
1000
21
15
3
1433.33
2000.67
10033.33
22.58
0.02
0.01
<
0.01
Rangeland,
1
lb
ai/
A,
1
appl
15
35
1000
21
15
3
1433.33
2000.67
10033.33
15.0
0.01
0.01
<
0.01
Forested
areas
(
non­
urban),
1
lb
ai/
A,
2
appl,
7
days
15
35
1000
21
15
3
1433.33
2000.67
10033.33
19.05
0.01
0.01
<
0.01
Turfgrass,
8
lb
ai/
A,
2
appl,
7
days
15
35
1000
21
15
3
1433.33
2000.67
10033.33
152.43
0.11
a
0.08
0.02
155
a
Exceeds
acute
risk
to
endangered
species
level
of
concern
(
RQ
$
0.1)

As
summarized
in
Table
8,
at
maximum
label
application
rates,
the
mammalian
chronic
LOC
(
RQ
=
1)
is
exceeded
on
all
registered
uses
of
nongranular
carbaryl
for
animals
feeding
on
short
grasses
(
RQ
range:
3.0
­
51),
forage/
small
insects
(
RQ
range:
1.4
­
24),
and
fruits/
large
insects
(
RQ
range:
1.7
­
29).
The
mammalian
chronic
LOC
is
exceeded
for
granivores
on
following
uses:
citrus,
olives,
stone
fruits,
tree
nuts,
and
turfgrass
(
chronic
RQs
=
1.1
­
3.2).

Table
8.
Mammalian
chronic
risk
quotients
for
multiple
applications
of
nongranular
carbaryl
(
broadcast)
based
on
a
2­
generation
rat
reproductive
study
NOAEC
of
75
ppm
and
maximum
label
application
rates
Site,
Application
Rate,
Number
of
Applications,
Interval
Food
Items
Peak
Mean
EEC
(
ppm)
Chronic
RQ
(
EEC)/
NOAEC)

Citrus,
5
lb
ai/
A,
4
appl,
14
days
Short
Grass
Forage/
sm
insects
Fruit/
lg
insects
Seed
Fruit
1294.49
593.31
728.15
80.91
17.3
a
7.91
a
9.71
a
1.08
a
Citrus
(
California),
16
lb
ai/
A,
1
appl
Short
Grass
Forage/
sm
insects
Fruit/
lg
insects
Seed
Fruit
3840.00
1760.00
2160.00
240.00
51.2
a
23.5
a
28.8
a
3.20
a
Olives,
7.5
lb
ai/
A,
2
appl,
14
days
Short
Grass
Forage/
sm
insects
Fruit/
lg
insects
Seed
Fruit
1931.43
885.24
1086.43
120.71
25.8
a
11.8
a
14.5
a
1.61
a
Pome
fruits
(
apples,
etc.),
3
lb
ai/
A,
5
appl,
14
days
Short
Grass
Forage/
sm
insects
Fruit/
lg
insects
Seed
Fruit
776.71
355.99
436.90
48.54
10.4
a
4.75
a
5.83
a
0.65
Stone
fruits
(
peaches,
etc.),
4
lb
ai/
A,
3
appl,
14
days
Short
Grass
Forage/
sm
insects
Fruit/
lg
insects
Seed
Fruit
1035.21
474.47
582.31
64.70
13.8
a
6.33
a
7.76
a
6.86
a
Tree
nuts
(
pistachios,
etc.),
5
lb
ai/
A,
3
appl,
7
days
Short
Grass
Forage/
sm
insects
Fruit/
lg
insects
Seed
Fruit
1611.88
738.78
906.68
100.74
21.5
a
9.85
a
12.1
a
1.34
a
Corn,
field,
2
lb
ai/
A,
4
appl,
14
days
Short
Grass
Forage/
sm
insects
Fruit/
lg
insects
Seed
Fruit
517.79
237.32
291.26
32.36
6.90
a
3.16
a
3.88
a
0.43
Corn,
sweet,
2
lb
ai/
A,
8
appl,
3
days
Short
Grass
Forage/
sm
insects
Fruit/
lg
insects
Seed
Fruit
1105.64
506.75
621.93
69.10
14.7
a
6.76
a
8.29
a
0.92
Rice,
sunflower,
1.5
lb
ai/
A,
2
appl,
7
days
Short
Grass
Forage/
sm
insects
Fruit/
lg
insects
Seed
Fruit
457.28
209.59
257.22
28.58
6.10
a
2.79
a
3.43
a
0.38
Site,
Application
Rate,
Number
of
Applications,
Interval
Food
Items
Peak
Mean
EEC
(
ppm)
Chronic
RQ
(
EEC)/
NOAEC)

156
Asparagus,
2
lb
ai/
A,
5
appl,
3
days
Short
Grass
Forage/
sm
insects
Fruit/
lg
insects
Seed
Fruit
1050.51
481.48
590.91
65.66
14.0
a
6.42
a
7.88
a
0.88
Brassica
crops
(
broccoli,
cabbage,
etc.),
leafy
veg
(
celery,
lettuce,
etc.),
roots
&
tubers
(
beets,
carrots,
potatoes,
etc.),
sorghum,
2
lb
ai/
A,
3
appl,
7
days
Short
Grass
Forage/
sm
insects
Fruit/
lg
insects
Seed
Fruit
644.75
295.51
362.67
40.30
8.60
a
3.94
a
4.84
a
0.54
Cucurbits
(
cucumbers
melons,
squash,
etc.),
trees
and
ornamentals,
1
lb
ai/
A,
6
appl,
7
days
Short
Grass
Forage/
sm
insects
Fruit/
lg
insects
Seed
Fruit
328.74
150.67
184.91
20.55
4.11
a
1.88
a
2.31
a
0.26
Solanaceous
(
peppers,
tomatoes,
eggplant),
sweet
potatoes,
peanuts,
tobacco,
2
lb
ai/
A,
4
appl,
7
days
Short
Grass
Forage/
sm
insects
Fruit/
lg
insects
Seed
Fruit
654.22
299.85
368.00
40.89
8.18
a
3.75
a
4.60
a
0.51
Legumes
(
beans,
peas,
lentils,
cowpeas),
1.5
lb
ai/
A,
4
appl,
7
days
Short
Grass
Forage/
sm
insects
Fruit/
lg
insects
Seed
Fruit
490.67
224.89
276.00
30.67
6.13
a
2.81
a
3.45
a
0.38
Sugar
beets,
wheat,
millet,
flax,
pasture,
grasses,
noncropland
1.5
lb
ai/
A,
2
appl,
14
days
Short
Grass
Forage/
sm
insects
Fruit/
lg
insects
Seed
Fruit
386.29
177.05
217.29
24.14
4.83
a
2.21
a
2.72
a
0.30
Small
fruits
&
berries
(
grapes,
strawberries,
etc.),
2
lb
ai/
A,
5
appl,
7
days
Short
Grass
Forage/
sm
insects
Fruit/
lg
insects
Seed
Fruit
656.78
301.03
369.44
41.05
8.21
a
3.76
a
4.62
a
0.51
Alfalfa,
clover,
1.5
lb
ai/
A,
8
appl,
30
days
Short
Grass
Forage/
sm
insects
Fruit/
lg
insects
Seed
Fruit
361.33
165.61
203.25
22.58
4.52
a
2.07
a
2.54
a
0.28
Rangeland,
1
lb
ai/
A,
1
appl
Short
Grass
Forage/
sm
insects
Fruit/
lg
insects
Seed
Fruit
240.00
110.00
135.00
15.00
3.00
a
1.38
a
1.69
a
0.19
Forested
areas
(
non­
urban),
1
lb
ai/
A,
2
appl,
7
days
Short
Grass
Forage/
sm
insects
Fruit/
lg
insects
Seed
Fruit
304.85
139.72
171.48
19.05
3.81
a
1.75
a
2.14
a
0.24
Turfgrass,
8
lb
ai/
A,
2
appl,
7
days
Short
Grass
Forage/
sm
insects
Fruit/
lg
insects
Seed
Fruit
2438.82
1117.79
1371.83
152.43
30.5
a
14.0
a
17.2
a
1.91
a
a
Exceeds
chronic
risk
level
of
concern
(
RQ
$
1.0)

In
addition
to
maximum
label
use
rates,
mammalian
acute
and
chronic
RQs
were
also
calculated
for
nongranular
carbaryl
using
QUA
average
use
rates
data
available
for
70
uses
(
Table
9a)
and
maximum
reported
(
Doane
data)
use
rates
data
available
for
42
uses
(
Table
9b).
157
As
summarized
in
Table
9a,
when
RQs
are
based
on
QUA
average
rates,
the
acute
risk
LOC
is
exceeded
for
62
(
89%)
of
the
uses,
whereas
the
restricted
use
LOC
is
exceeded
for
69
uses
(
not
exceeded
only
for
Chinese
cabbage),
and
the
endangered
species
LOC
is
exceeded
for
all
70
uses.
The
chronic
risk
LOC
is
exceeded
for
69
uses
(
not
exceeded
only
for
Chinese
cabbage).

Table
9a.
Mammalian
(
herbivores)
highest
acute
and
chronic
risk
quotientsa
for
nongranular
carbaryl
based
on
a
rat
LD50
of
301
mg/
kg
ppm,
a
developmental
rat
NOAEC
of
75
ppm,
and
QUA
average
application
rates
for
70
uses
Use
site
Acute
RQ
(
EEC/
LC50)
Chronic
RQ
(
EEC/
NOAEC)
Use
Site
Acute
RQ
(
EEC/
LC50)
Chronic
RQ
(
EEC/
NOAEC)

Alfalfa
Almonds
Apples
Asparagus
Beans,
Dry
Beans,
Lima,
Fresh
Beans,
Snap,
Fresh
Beans,
Snap,
Processed
Beets
Blackberries
Blueberries
Broccoli
Brussels
Sprouts
Chinese
Cabbage
Fresh
Cabbage
Cantaloupes
Carrots
Cauliflower
Celery
Cherries
Citrus,
other
Corn,
Field
Cranberries
Cucumbers
Cucumbers,
Processed
Eggplant
Flax
Grapefruit
Grapes
Hay
Hazelnuts
Lemons
Lettuce
Lots/
Farmsteads
Melons
0.84
b
1.59
b
0.91
b
0.68
b
0.38
c
0.68
b
0.86
b
0.67
b
0.38
c
1.28
b
1.28
b
0.60
b
0.68
b
0.15
d
0.96
b
0.60
b
0.86
b
0.84
b
0.96
b
1.44
b
1.46
b
0.75
b
1.52
b
0.84
b
0.58
b
0.96
b
0.84
b
1.14
b
1.35
b
0.60
b
1.90
b
2.05
b
0.84
b
0.33
c
0.53
b
3.30
e
6.72
e
3.84
e
2.88
e
1.60
e
2.88
e
3.65
e
2.84
e
1.60
e
5.44
e
5.44
e
2.56
e
2.88
e
0.64
4.07
e
2.56
e
3.65
e
3.52
e
4.07
e
6.08
e
6.19
e
3.20
e
6.40
e
3.52
e
2.44
e
4.07
e
3.52
e
4.81
e
5.69
e
2.56
e
8.00
e
8.64
e
3.52
e
1.37
e
2.24
e
Nectarines
Okra
Olives
Oranges
Pasture
Peaches
Peanuts
Pears
Pears,
Dry
Peas,
Green
Pecans
Peppers,
Bell
Peppers,
Sweet
Pistachios
Plums
Potatoes
Pumpkins
Raspberries
Rice
Sorghum
Soybeans
Squash
Strawberries
Sugar
Beets
Sunflower
Sweet
Corn,
Fresh
Sweet
Potatoes
Tobacco
Tomatoes,
Fresh
Tomatoes,
Processed
Walnuts
Watermelons
Wheat,
Spring
Wheat,
Winter
Woodland
2.88
b
1.44
b
4.02
b
2.58
b
0.68
b
1.02
b
0.60
b
0.76
b
0.75
b
1.13
b
1.98
b
1.28
b
0.99
b
2.72
b
2.88
b
1.13
b
2.84
b
2.12
b
0.84
b
0.84
b
0.68
b
1.06
b
1.98
b
0.99
b
0.31
c
1.87
b
1.21
b
1.06
b
0.71
b
0.91
b
1.44
b
0.38
c
0.46
c
0.60
b
0.31
c
12.2
e
6.08
e
17.0
e
10.9
e
2.88
e
4.29
e
2.56
e
3.20
e
3.20
e
4.80
e
7.86
e
5.05
e
4.16
e
11.5
e
12.2
e
4.49
e
11.2
e
8.96
e
3.52
e
3.52
e
2.88
e
4.48
e
7.86
e
4.16
e
2.24
e
7.89
e
5.12
e
4.47
e
3.01
e
3.84
e
6.08
e
1.60
e
1.92
e
2.56
e
2.24
e
aOnly
the
highest
RQs
­­
i.
e.
those
corresponding
to
15
g
mammals
which
have
a
daily
food
consumption
equal
to
95%
of
their
body
weight
and
based
on
short
grass
EECs
­­
are
included
in
this
table.
b
Exceeds
acute
high
risk
(
RQ
$
0.5),
restricted
use
(
RQ
$
0.2)
and
endangered
species
level
of
concern
(
RQ
$
0.1)
c
Exceeds
acute
restricted
use
(
RQ
$
0.2)
and
endangered
species
level
of
concern
(
RQ
$
0.1)
d
Exceeds
acute
risk
to
endangered
species
level
of
concern
(
RQ
$
0.1)
e
Exceeds
chronic
risk
level
of
concern
(
RQ
$
1.0)

When
RQs
are
calculated
using
maximum
reported
application
rates,
the
acute
risk
LOC
is
exceeded
for
40
of
the
42
uses
(
RQs:
0.60
­
11).
The
acute
restricted
use
and
endangered
species
(
RQ
range
0.38
­
11)
and
chronic
(
RQs:
1.6
­
48)
risk
LOCs
are
exceeded
for
all
42
uses
(
Table
9b).
158
Table
9b.
Mammalian
(
herbivores)
highest
acute
and
chronic
risk
quotientsa
for
nongranular
carbaryl
based
on
a
rat
LD50
of
301
mg/
kg
ppm
and,
a
developmental
rat
NOAEC
of
75
ppm,
and
maximum
reported
use
rates
(
Doane
data)
for
42
uses
Use
site
[
appl.
rate
(
lb
ai/
A),
No.
appl]
Acute
RQ
(
EEC/
LC50)
Chronic
RQ
(
EEC/
NOAEC)
Use
Site
[
appl.
rate
(
lb
ai/
A)
No.
appl]
Acute
RQ
(
EEC/
LC50)
Chronic
RQ
(
EEC/
NOAEC)

Alfalfa
(
1.5,
1)
Almonds
(
4,
1)
Apples
(
3.2,
1)
Apricots
(
4,
1)
Asparagus
(
4,
1)
Beans,
Lima
(
1.3,1)
Beans,
snap
(
1.6,
1)
Cabbage
(
2,1)
Canola
(
0.5,
1)
Cantaloupe
(
1.2,
1)
Carrots
(
0.8,
1)
Cauliflower
(
1,
1)
Celery
(
2,
1)
Cherries
(
5,
1)
Corn,
Field
(
1.5,
2,
14)
Cucumbers
(
1,
1)
Grapefruit
(
12.8,
1)
Grapes
(
2.5,1)
Lemons
(
8,1)
Lettuce
(
1,
1)
Oranges
(
15,
1)
1.13
b
3.03
b
2.43
b
3.03
b
3.03
b
0.99
b
1.21
b
1.52
b
0.38
c
0.91
b
0.60
b
0.75
b
1.53
b
3.78
b
1.22
b
0.75
b
9.70
b
1.90
b
6.06
b
0.75
b
11.36
b
4.8
e
12.8
e
10.2
e
12.8
e
12.8
e
4.2
e
4.8
e
5.1
e
1.6
e
3.8
e
2.6
e
3.2
e
6.4
e
16.0
e
5.1
e
3.2
e
41.0
e
8.0
e
25.6
e
3.2
e
48.0
e
Peaches
(
5,
1)
Peanuts
(
2,
1)
Pears
(
2,
1)
Pecans
(
3,
2,
7)
Peppers
(
2,
1)
Pistachios
(
5,
1)
Plums
(
4,
1)
Potatoes
(
1.5,
1)
Pumpkins
(
1.5,
1)
Rice
(
1.3,
1)
Sorghum
(
0.5,
1)
Squash
(
1.2,
1)
Sugar
Beets
(
1.2,
1)
Sunflower
(
1,
1)
Strawberries
(
2,1)
Sweet
Corn
(
1.5,
2,
3)
Tobacco
(
2,
1)
Tomatoes
(
2,1)
Walnuts
(
4,
1)
Watermelons
(
2,
1)
Wheat
(
1,1)
3.78
b
1.52
b
1.52
b
2.89
b
1.52
b
3.78
b
3.03
b
1.13
b
1.13
b
0.99
b
0.38
c
0.91
b
0.91
b
0.75
b
1.52
b
1.78
b
1.52
b
1.52
b
3.03
b
1.52
b
0.75
b
16.0
e
6.4
e
6.4
e
12.2
e
6.4
e
16.0
e
12.8
e
4.8
e
4.8
e
4.2
e
1.6
e
3.8
e
3.8
e
3.2
e
6.4
e
7.5
e
6.4
e
6.4
e
12.8
e
6.4
e
3.2
e
a
Only
the
highest
RQs
­­
i.
e.
those
corresponding
to
15
g
mammals
which
have
a
daily
food
consumption
equal
to
95%
of
their
body
weight
and
based
on
short
grass
EECs
­­
are
included
in
this
table.
b
Exceeds
acute
high
risk
(
RQ
$
0.5),
restricted
use
(
RQ
$
0.2)
and
endangered
species
level
of
concern
(
RQ
$
0.1)
c
Exceeds
acute
restricted
use
(
RQ
$
0.2)
and
endangered
species
level
of
concern
(
RQ
$
0.1)
d
Exceeds
acute
risk
to
endangered
species
level
of
concern
(
RQ
$
0.1)
e
Exceeds
chronic
risk
level
of
concern
(
RQ
$
1.0)

Risk
to
Granular
Products
Mammals
also
may
be
exposed
to
granular/
bait
pesticides
through
ingestion
and
by
other
routes,
such
as
by
walking
on
exposed
granules
or
by
drinking
water
contaminated
with
granules.
The
number
of
lethal
doses
(
LD50)
that
are
available
within
one
square
foot
immediately
after
application
(
LD50/
ft2)
is
used
as
the
risk
quotient
for
granular/
bait
products.
Risk
quotients
are
calculated
for
small
mammals
in
three
weight
classes:
15
g,
35
g,
and
1000
g.

The
acute
level
of
concern
is
exceeded
for
mammals
in
the
15
g
and
35
g
categories
for
all
40
registered
granular
uses
(
Table
10).
For
1000
g
mammals,
the
restricted
use
and
endangered
species
LOCs
are
exceeded
for
applications
to
trees
and
ornamentals,
turfgrass,
and
tick
control.
159
Table
10.
Mammalian
acute
risk
quotientsa
for
granular
carbaryl
(
broadcast,
unincorporated)
based
on
a
rat
LD50
of
301
mg/
kg
Uses
Rate
in
lb
ai/
A
Body
Weight
(
g)
Acute
RQa
(
LD50/
ft2)

Asparagus,
Brassica
crops
(
broccoli,
cabbage,
cauliflower,
collards,
etc.),
corn
(
field,
sweet),
sorghum,
solanaceous
crops
(
tomato,
pepper,
eggplant),
leafy
vegetables
(
celery,
lettuce,
parsley,
spinach,
etc.),
roots
&
tubers
(
beets,
carrots,
radishes,
potatoes,
etc.),
strawberries
2
15
35
1000
4.61b
1.98b
0.07
Cucurbits
(
cucumber,
melon,
pumpkin,
squash)
1
15
35
1000
2.30b
0.99b
0.03
Legumes
(
beans,
peas,
lentils,
cowpeas,
southern
peas),
Wheat,
millet,
Sugar
beets
1.5
15
35
1000
3.45b
1.48b
0.05
Trees
and
ornamentals,
turfgrass,
tick
control
9.15
15
35
1000
21.10b
9.04b
0.32c
a
RQ
=
Appl.
rate
(
lb
ai/
a)
*
(
453,590
mg/
lb/
43,560
ft2/
a)
LD50
mg/
kg
*
weight
of
animal
(
kg)
b
Exceeds
acute
high
risk
(
RQ
$
0.5),
restricted
use
(
RQ
$
0.2)
and
endangered
species
level
of
concern
(
RQ
$
0.1)
c
Exceeds
acute
restricted
use
(
RQ
$
0.2)
and
endangered
species
level
of
concern
(
RQ
$
0.1)

Insects
Currently
EFED
does
not
assess
risk
to
nontarget
insects.
However,
data
from
acceptable
studies
are
used
to
recommend
appropriate
label
precautions.
Carbaryl,
is
highly
toxic
to
domestic
and
wild
bees
and
should
be
applied
only
under
the
conditions
specified
by
the
latest
pollinator
protection
label
language.
Carbaryl
has
also
been
shown
to
be
from
moderately
to
highly
toxic
to
predaceous
and
parasitic
arthropods,
including
lace
bugs,
big
eyed
bugs,
lady
beetles,
carabid
ground
beetles,
hymenopterous
parasitoids,
predaceous
mites,
and
spiders.

Terrestrial
Plants
Based
on
the
single
vegetative
vigor
study
of
Sevin
XLR
Plus
at
a
single
field
application
rate
(
0.803
lbs
a.
i./
Acre),
the
inhibitory
concentration
(
IC25)
exceeded
the
highest
dose
tested.
Therefore,
no
terrestrial
plant
risk
quotients
are
calculated.
However,
based
on
precautionary
label
language
about
potential
injury
to
several
crop
plants
and
the
limited
range
of
plants
tested
in
the
Tier
I
vegetative
vigor
study
(
MRID
457848­
07),
the
registrant
needs
to
submit
a
more
comprehensive
tier
I
and,
if
necessary,
tier
II
Seed
Germination
and
Seedling
Emergence
and
Vegetative
Vigor
studies.

Exposure
and
Risk
to
Nontarget
Aquatic
Animals
EFED
calculates
estimated
environmental
concentrations
(
EECs)
using
the
PRZM/
EXAMS
model.
The
EECs
are
used
for
assessing
acute
and
chronic
risks
to
aquatic
organisms.
Acute
risk
assessments
are
performed
using
peak
EEC
values
for
single
and
multiple
applications.
Chronic
risk
assessments
are
performed
using
the
21­
day
EECs
for
invertebrates
and
56­
day
EECs
for
fish.
160
The
PRZM/
EXAMS
program
uses
basic
environmental
fate
data
and
pesticide
label
application
information
to
estimate
the
expected
EECs
following
treatment
of
10
hectares.
The
model
calculates
the
concentration
(
EEC)
of
a
pesticide
in
a
one
hectare,
two
meter
deep
pond,
taking
into
account
the
following:
(
1)
adsorption
to
soil
or
sediment,
(
2)
soil
incorporation,
(
3)
degradation
in
soil
before
washoff
to
a
water
body,
and
(
4)
degradation
within
the
water
body.
The
model
also
accounts
for
direct
deposition
of
spray
drift
into
the
water
body
(
assumed
to
be
1%
and
5%
of
the
application
rate
for
ground
and
aerial
applications,
respectively).
The
environmental
fate
parameters
used
in
the
model
for
this
pesticide
are
contained
in
Table
6
of
the
preceding
main
environmental
fate
and
effects
chapter.
EECs
are
tabulated
below
in
Table
11.

Table
11.
Tier
II
surface
water
estimated
environmental
concentration
(
EEC)
values
derived
from
PRZM/
EXAMS
modeling
for
use
in
ecological
risk
assessment
(
Calculated
using
standard
pond.)

Use
Site,
Application
Method
Use
Rates
Number
of
Applications
Per
Year
Application
Rate
(
Pounds
A.
I.
per
Application)
Surface
Water
Acute
(
ppb)
(
1
in
10
year
peak
single
day
concentration)
21
day
(
ppb)
(
1
in
10
year)
60
day
(
ppb)
(
1
in
10
year)

Sweet
Corn
(
OH),
air/
ground
Maximum
"
Average"
Maximum
Reported
823
2
3.4
1
53
46
23
30
25
12
19
13
7
Field
Corn
(
OH),
air/
ground
Maximum
"
Average"
Maximum
Reported
422
21
1.5
47
13
20
25
7
11
14
47
Apples
(
PA),
air/
ground
Maximum
"
Average"
Maximum
Reported
522
2
1.2
1.6
31
12
16
15
56
722
Sugar
Beets
(
MN),
air/
ground
Maximum
"
Average"
Maximum
Reported
211
1.5
1.5
1.2
23
75
13
33
622
Citrus
(
FL),
air/
ground
Maximum
"
Average"
Maximum
Reported
423
5
3.4
4.3
153
100
131
82
51
68
41
23
31
Freshwater
Animals
Fish
Acute
and
chronic
risk
quotients
for
freshwater
fish,
based
on
maximum
label
(
Maximum),
QUA
average
("
Average"),
and
maximum
reported
(
Max
Rep;
Doane
data)
use
rates
are
tabulated
in
Table
12.
The
acute
risk
LOC
is
exceeded
only
for
the
citrus
scenario,
for
all
three
use
rates
modeled,
whereas
the
endangered
species
LOC
is
met
or
exceeded
for
all
of
the
crops
modeled
except
sugar
beets,
for
all
three
use
rates.
For
sugar
beets,
none
of
the
acute
risk
LOCs
is
exceeded
at
either
average
or
maximum
reported
application
rate.
The
chronic
risk
LOC
is
not
exceeded
for
any
uses
modeled,
at
any
of
the
use
rates.
161
Table
12.
Risk
quotients
for
freshwater
fish
based
on
an
Atlantic
salmon
LC50
of
250
ppb
and
a
fathead
minnow
NOAEC
of
210
ppb,
at
maximum
label
use
rates,
QUA
average
use
rates,
and
maximum
reported
use
rates
Site/
Appl.
Method
Use
Rates
LC50
(
ppb)
NOAEC
(
ppb)
EEC
Initial/
Peak
(
ppb)
EEC
60­
Day
Ave.
(
ppb)
Acute
RQ
(
EEC/
LC50)
Chronic
RQ
(
EEC/
NOAEC)

Sweet
Corn
(
OH),
air/
ground
Maximum
"
Average"
Max
Rep
250
210
53
46
23
19
13
7
0.21
b
0.18
b
0.09
c
0.09
0.06
0.03
Field
Corn
(
OH)
air/
ground
Maximum
"
Average"
Max
Rep
250
210
47
13
20
14
47
0.19
b
0.05
c
0.08
c
0.07
0.02
0.03
Apples
(
PA)
air/
ground
Maximum
"
Average"
Max
Rep
250
210
31
12
16
722
0.12
b
0.05
c
0.06
c
0.03
0.01
0.01
Sugar
Beets
(
MN)
air/
ground
Maximum
"
Average"
Max
Rep
250
210
23
75
622
0.09
c
0.03
0.02
0.03
0.01
0.01
Citrus
(
FL)
air/
ground
Maximum
"
Average"
Max
Rep
250
210
153
100
131
41
23
31
0.61
a
0.40
b
0.52
a
0.20
0.11
0.15
a
Exceeds
acute
high
risk
(
RQ
$
0.5),
restricted
use
(
RQ
$
0.1)
and
endangered
species
level
of
concern
(
RQ
$
0.05)
b
Exceeds
acute
restricted
use
(
RQ
$
0.1)
and
endangered
species
level
of
concern
(
RQ
$
0.05)
c
Exceeds
acute
risk
to
endangered
species
level
of
concern
(
RQ
$
0.05)

Invertebrates
The
risk
quotients
for
freshwater
invertebrates
exceed
both
the
acute
and
chronic
LOCs
for
all
five
uses
modeled,
at
maximum
label
use
rates,
QUA
average
rates,
and
maximum
reported
(
Doane
data)
use
rates
(
Table
13).

Table
13.
Risk
quotients
for
freshwater
invertebrates
based
on
a
stonefly
EC50
of
5.1
ppb
and
a
water
flea
NOAEC
of
1.5
ppb,
at
maximum
label
use
rates,
QUA
average
use
rates,
and
maximum
reported
use
rates
Site/
Appl.
Method
Use
Rates
EC50
(
ppb)
NOAEC
(
ppb)
EEC
Initial/
Peak
(
ppb)
EEC
21­
Day
Ave.
(
ppb)
Acute
RQ
(
EEC/
EC50)
Chronic
RQ
(
EEC/
NOAEC
)

Sweet
Corn
(
OH)
Maximum
"
Average"
Max
Rep
5.1
1.5
53
46
23
30
25
12
10.4
a
9.0
a
4.5
a
20
b
17
b
8
b
Field
Corn
(
OH)
Maximum
"
Average"
Max
Rep
5.1
1.5
47
13
20
25
7
11
9.2
a
2.5
a
3.9
a
17
b
4.7
b
7.3
b
Apples
(
PA)
Maximum
"
Average"
Max
Rep
5.1
1.5
31
12
16
15
56
6.1
a
2.4
a
3.1
a
10
b
3.3
b
4.0
b
Sugar
Beets
(
MN)
Maximum
"
Average"
Max
rep
5.1
1.5
23
75
13
33
4.5
a
1.4
a
1.0
a
8.7
b
2.0
b
2.0
b
Citrus
(
FL)
Maximum
"
Average"
Max
Rep
5.1
1.5
153
100
131
82
51
68
30
a
20
a
26
a
55
b
34
b
45
b
a
Exceeds
acute
high
risk
(
RQ
$
0.5),
restricted
use
(
RQ
$
0.1)
and
endangered
species
level
of
concern
(
RQ
$
0.05)
b
Exceeds
chronic
risk
level
of
concern
(
RQ
$
1.0)
162
Estuarine
and
Marine
Animals
Fish
The
acute
risk
LOC
is
not
exceeded
for
any
of
the
five
uses
modeled
using
maximum
label
use
rates,
QUA
average
rates,
and
maximum
reported
rates
(
Table
14).
The
acute
endangered
species
LOC
is
minimally
exceeded
at
maximum
label
and
maximum
reported
rates
on
citrus
alone.
Due
to
the
unavailability
of
core
chronic
toxicity
data,
it
is
not
possible
to
evaluate
chronic
risk
to
estuarine/
marine
fish
at
this
time.

Table
14.
Acute
risk
quotients
for
estuarine/
marine
fish
based
on
a
sheepshead
minnow
LC50
of
2.6
ppm
and
label
maximum
and
QUA
average
use
rates,
at
maximum
label
use
rates,
QUA
average
use
rates,
and
maximum
reported
use
rates
Site/
Appl.
Method
Use
Rates
LC50
(
ppb)
EEC
Initial/
Peak
(
ppb)
(
Max
Rates)
Acute
RQ
(
EEC/
EC50)

Sweet
Corn
(
OH)
Maximum
"
Average"
Max
Rep
2600
53
46
23
0.02
0.02
0.01
Field
Corn
(
OH)
Maximum
"
Average"
Max
Rep
2600
47
13
20
0.02
0.01
0.01
Apples
(
OR)
Maximum
"
Average"
Max
Rep
2600
31
12
16
0.01
<
0.01
0.01
Sugar
Beets
(
MN)
Maximum
"
Average"
Max
rep
2600
23
75
0.01
<
0.01
<
0.01
Citrus
(
FL)
Maximum
"
Average"
Max
Rep
2600
153
100
131
0.06a
0.04
0.06
a
a
Exceeds
acute
risk
to
endangered
species
level
of
concern
(
RQ
$
0.05)

Invertebrates
The
acute
risk
LOC
for
estuarine/
marine
invertebrates
is
exceeded
for
all
five
carbaryl
uses
modeled
at
maximum
label
use
rates,
QUA
average
rates,
and
maximum
reported
(
Doane
data)
rates
(
Table
15).
Due
to
the
unavailability
of
core
chronic
toxicity
data,
it
is
not
possible
to
evaluate
chronic
risk
to
estuarine/
marine
fish
or
invertebrates
at
this
time.
163
Table
15.
Acute
risk
quotients
for
estuarine/
marine
invertebrates
based
on
a
mysid
LC50
of
5.7
ppb
and
three
sets
of
use
rates,
at
maximum
label
use
rates,
QUA
average
use
rates,
and
maximum
reported
use
rates
Site/
Appl.
Method
Use
Rates
LC50
(
ppb)
EEC
Initial/
Peak
(
ppb)
(
Max
Rates)
Acute
RQ
(
EEC/
EC50)
(
Max
Rates)

Sweet
Corn
(
OH)
Maximum
"
Average"
Max
Rep
5.7
53
46
23
9.3
a
8.1
a
4.0
a
Field
Corn
(
OH)
Maximum
"
Average"
Max
Rep
5.7
47
13
20
8.2
a
2.3
a
3.5
a
Apples
(
OR)
Maximum
"
Average"
Max
Rep
5.7
31
12
16
5.4
a
2.1
a
2.8
a
Sugar
Beets
(
MN)
Maximum
"
Average"
Max
rep
5.7
23
75
4.0
a
1.2
a
0.9
a
Citrus
(
FL)
Maximum
"
Average"
Max
Rep
5.7
153
100
131
27
a
18
a
23
a
a
Exceeds
acute
high
risk
(
RQ
$
0.5),
restricted
use
(
RQ
$
0.1)
and
endangered
species
level
of
concern
(
RQ
$
0.05)

Aquatic
Plants
Exposure
to
nontarget
aquatic
plants
may
occur
through
runoff
or
spray
drift
from
adjacent
treated
sites
or
directly
from
such
uses
as
aquatic
weed
or
mosquito
larvae
control.
An
aquatic
plant
risk
assessment
for
acute
risk
is
usually
made
for
aquatic
vascular
plants
from
the
surrogate
duckweed
Lemna
gibba.
Non­
vascular
acute
risk
assessments
are
performed
using
either
algae
or
a
diatom,
whichever
is
the
most
sensitive
species.
An
aquatic
plant
risk
assessment
for
acuteendangered
species
is
usually
made
for
aquatic
vascular
plants
from
the
surrogate
duckweed
Lemna
gibba.
To
date,
there
are
no
known
non­
vascular
plant
species
on
the
endangered
species
list.
Runoff
and
drift
exposure
is
computed
from
PRZM/
EXAMS.
The
risk
quotient
is
determined
by
dividing
the
pesticide's
initial
or
peak
concentration
in
water
by
the
plant
EC50
value.

Based
on
a
single
core
aquatic
plant
toxicity
study
available,
neither
the
acute
risk
nor
the
endangered
species
LOC
is
exceeded
for
any
of
the
five
use
scenarios
modeled,
at
maximum
label,
QUA
average,
and
maximum
reported
use
rates
(
Table
16).
However,
to
fully
assess
carbaryl
risk
to
aquatic
plants,
it
is
recommended
that
toxicity
studies
with
Lemna
gibba,
Anabaena
flos­
aquae,
Skeletonema
costatum,
and
a
freshwater
diatom
be
submitted.
164
Table
17.
Risk
quotients
for
aquatic
plants
based
on
a
green
alga
(
Pseudokirchneriella
subcapitata)
EC50
of
1.3
ppm
and
a
NOAEC
of
0.29
ppm,
at
maximum
label
use
rates,
QUA
average
use
rates,
and
maximum
reported
use
rates.

Site/
Appl.
Method
Use
Rates
EC50
(
ppb)
NOAEC
(
ppb)
EEC
Initial/
Peak
(
ppb)
Acute
RQ
(
EEC/
EC50)
Acute
Endangered
Species
RQ
(
EEC/
NOAEC)

Sweet
Corn
(
OH)
Maximum
"
Average"
Max
Rep
1300
290
53
46
23
0.04
0.04
0.02
0.18
0.16
0.08
Field
Corn
(
OH)
Maximum
"
Average"
Max
Rep
1300
290
47
13
20
0.04
0.01
0.02
0.16
0.04
0.07
Apples
(
OR)
Maximum
"
Average"
Max
Rep
1300
290
31
12
16
0.02
0.01
0.01
0.11
0.04
0.06
Sugar
Beets
(
MN)
Maximum
"
Average"
Max
rep
1300
290
23
75
0.02
0.01
<
0.01
0.08
0.02
0.02
Citrus
(
FL)
Maximum
"
Average"
Max
Rep
1300
290
153
100
131
0.12
0.08
0.10
0.53
0.34
0.45
165
0
5
1
0
1
5
2
0
2
5
1
9
7
2
­
1
9
7
3
1
9
7
9
1
9
8
5
­
1
9
8
6
Ye
a
r
Figure
13.
Combined
acreage
of
private,
State,
and
Federal
rangeland
treated
to
suppress
grasshopper
outbreaks.
(
Source:
USDA
APHIS
2003)
APPENDIX
G.
GRASSHOPPER
AND
MORMON
CRICKET
SUPPRESSION
PROGRAM
Carbaryl
has
been
used
as
part
of
the
U.
S.
Department
of
Agriculture's
Animal
and
Plant
Health
Inspection
Service
(
USDA
APHIS)
Grasshopper
and
Mormon
Cricket
Suppression
Program.
According
to
the
USDA,
carbaryl
is
considered
unique
in
providing
satisfactory
results
under
cool,
wet
conditions.
It
is
also
more
persistent
than
other
chemical
alternatives,
e.
g.,
malathion
or
diflubenzuron,
in
the
program
and
it
is
more
effective
in
dense
vegetation
and
on
rough
terrain
(
Docket
Number
OPP­
2002­
0138­
0043).
A
single
application
of
carbaryl
is
applied
by
ultra
low
volume
sprayers
at
rates
ranging
from
0.25
to
0.50
lbs
a.
i./
A.
In
the
past,
the
entire
affected
area
has
been
treated;
however,
under
a
Reduced
Agent
Area
Treatment
(
RAAT)
approach
to
grasshopper
suppression,
carbaryl
will,
in
the
future,
be
applied
to
alternating
swaths.
The
number
of
acres
treated
in
the
past
has
increased
(
Figure
13)
by
roughly
a
factor
of
four.

Risk
to
Terrestrial
Animals
Based
on
estimated
environmental
concentrations
derived
using
EL­
FATE
model
(
APPENDIX
C)
at
the
maximum
single
application
rate
of
0.5
lbs
a.
i./
acre,
risk
quotients
do
not
exceed
either
acute
or
chronic
levels
of
concern
for
birds.
However,
for
small
and
intermediate­
sized
mammals
feeding
on
short
grasses
and
for
small
mammals
feeding
on
large
insects,
acute
restricted
use
and
endangered
species
LOCs
are
exceeded
(
RQ
range:
0.21
­
0.38).
For
small
and
intermediatesized
mammals
feeding
on
broadleaf
plants/
small
insects
and
for
intermediate­
sized
mammals
feeding
on
large
insects,
acute
endangered
species
LOCs
are
exceeded
(
RQ
range:
0.15
­
0.17).
No
acute
LOC
is
exceeded
for
large­
sized
mammals.
The
chronic
risk
LOC
is
exceeded
(
RQ
=
1.60)
for
animals
feeding
on
short
grasses
alone.
At
an
application
rate
of
0.25
lbs
a.
i./
A,
the
acute
endangered
species
LOC
is
exceeded
for
small
and
intermediate­
sized
mammals
feeding
on
short
grasses
and
for
small­
sized
mammals
feeding
on
large
insects;
the
chronic
risk
LOC
was
not
exceeded
at
the
lower
application
rate.

Risk
to
Aquatic
Animals
E
s
t
i
m
a
t
e
d
environmental
concentrations
for
determining
aquatic
exposure
were
derived
using
a
North
Dakota
166
wheat
scenario
with
PRZM/
EXAMS.
While
this
scenario
may
not
be
completely
representative
of
the
actual
use
area,
it
is
believed
to
provide
a
conservative
estimate
of
exposure.
Assuming
5%
drift,
peak,
21­
day
and
56­
day
average
concentrations
in
water
are
estimated
at
1.05,
0.55
and
0.32
µ
g/
L,
respectively.
At
these
concentrations,
acute
restricted
use
and
endangered
species
LOCs
are
exceeded
(
RQ
=
0.21)
for
freshwater
invertebrates
alone.
If
95%
spraydrift
is
assumed
for
direct
overspray
of
aquatic
environments,
peak,
21­
day
and
56­
day
average
concentrations
in
water
are
estimated
at
12.8,
6.5
and
2.8
µ
g/
L,
respectively.
Acute
endangered
species
LOC
is
exceed
(
RQ
=
0.05)
for
fish
while
the
acute
high
risk
LOC
(
RQ=
2.5)
and
chronic
risk
LOC
(
RQ=
4.3)
are
exceeded
for
freshwater
invertebrates
at
these
estimated
residue
levels.

The
Grasshopper
Suppression
Program
has
undergone
Section
7
consultation
with
the
U.
S.
Fish
and
Wildlife
Service
and
the
National
Marine
Fisheries
Service
and
a
Biological
Opinion
was
issued
in
1995.
It
was
concluded
that
APHIS
or
the
land
manager
will
consult
locally
with
the
USFWS
and/
or
NMFS
to
develop
protective
mitigations,
if
threatened
or
endangered
species
are
in
areas
targeted
for
treatment
(
Carl
Bausch,
Deputy
Director,
Environmental
Services,
USDA
Policy
and
Program
Development).
