December
11,
2003
MEMORANDUM
SUBJECT:
Preliminary
Ecological
Risk
Assessment
for
Thiram
FROM:
Jim
Carleton
and
Fred
Jenkins
Environmental
Risk
Branch
II
Environmental
Fate
and
Effects
Division
7507C
THROUGH:
Tom
Bailey,
Chief
Environmental
Risk
Branch
II
Environmental
Fate
and
Effects
Division
7507C
TO:
Craig
Doty
Special
Review
and
Reregistration
Division
(
7508C)

Attached
to
this
memo
is
the
revised
EFED
risk
assessment
for
thiram.
Thiram's
usage
on
apples,
peaches,
strawberries,
and
non­
residential
turf
is
expected
to
present
risk
to
numerous
organisms.
However,
the
potential
chronic
risk
to
birds
and
mammals
are
of
greatest
concern.
Although
thiram
has
low
acute
toxicity
to
birds
and
mammals,
there
are
LOC
exceedences
for
acute
risk.
One
major
uncertainty
in
this
assessment
is
the
effectiveness
of
thiram
as
a
registered
repellent.
Repellency
may
prevent
wildlife
from
consuming
a
lethal
dose.
Further
investigation
into
this
area
is
warranted.
Exposure
to
thiram
can
cause
reproductive
effects
in
avian
species
and
growth
effects
in
mammals.
The
risk
quotients
for
the
foliar,
turf,
and
seed
treatment
uses
greatly
exceed
the
levels
of
concern
for
chronic
risk
to
birds
and
mammals.
Again,
since
thiram
is
an
animal
repellent,
there
is
uncertainty
surrounding
the
exposure
component
of
the
risk
assessment.
Further
refinements
in
this
area,
including
predictions
on
whether
non­
target
animals
would
ingest
enough
thiram­
contaminated
food
to
induce
chronic
effects,
will
be
pursued.
N
C
S
S
C
N
CH3
CH3
CH3
CH3
*
*
S
S
*
*
Environmental
Fate
and
Ecological
Risk
Assessment
for
the
Reregistration
of
Thiram
Prepared
by:

James
Carleton
Fred
Jenkins
United
States
Environmental
Protection
Agency
Office
of
Pesticide
Programs
Environmental
Fate
and
Effects
Division
Environmental
Risk
Branch
II
1200
Pennsylvania
Ave.
NW
Mail
Code
7507C
Washington,
DC
20460
Reviewed
by:

Thomas
A.
Bailey,
Ph.
D.
i
TABLE
OF
CONTENTS
Page
ENVIRONMENTAL
RISK
CONCLUSIONS
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1
INTRODUCTION
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2
Use
Characterization
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2
Formulation
Type
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2
Method,
Rate,
and
Timing
of
Application
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3
INTEGRATED
ENVIRONMENTAL
RISK
CHARACTERIZATION
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3
ENVIRONMENTAL
FATE
ASSESSMENT
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5
Physical/
Chemical
Properties
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5
Persistence
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6
Mobility
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7
Monitoring
Data
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8
AQUATIC
EXPOSURE
AND
RISK
ASSESSMENT
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8
Hazard
Assessment
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8
Aquatic
Exposure
Summary
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8
Aquatic
Risk
Assessment
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10
DRINKING
WATER
ASSESSMENT
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13
Surface
Water
EECs
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13
Groundwater
EECs
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15
Monitoring
Data
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15
TERRESTRIAL
EXPOSURE
AND
RISK
ASSESSMENT
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16
Hazard
Assessment
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16
Terrestrial
Exposure
Summary
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16
Quantitative
Risk
Assessment
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17
APPENDIX
A:
Ecotoxicity
Data
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19
APPENDIX
B:
Tier
I
Model
Limitations
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26
APPENDIX
C:
Assumptions
Used
in
the
LFATE
Spreadsheet
Program
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27
APPENDIX
D:
Terrestrial
(
Bird
and
Mammal)
Risk
Quotient
Calculations
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29
APPENDIX
E:
Environmental
Fate
Study
Bibliography
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35
APPENDIX
F:
Environmental
Fate
Data
Requirements
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36
APPENDIX
G:
Ecological
Effects
Data
Requirements
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37
APPENDIX
H:
Chemical
Names
and
Structures
of
Thiram
and
Degradates
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38
APPENDIX
I:
Descriptions
of
PRZM/
EXAMS
Scenarios
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39
ii
Page
LIST
OF
TABLES
EECs
for
Use
in
the
Human
Health
Risk
Assessment
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2
PRZM/
EXAMS
Input
Parameters
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9
Tier
II
Surface
water
EECs
(
Farm
Pond)
for
Thiram
(
µ
g/
L)
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10
Acute
Risk
Quotients
for
Freshwater
Fish
Based
on
a
Bluegill
Sunfish
(
Leopmis
macrochirus)
LC50
of
42
ppb.
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11
Acute
Risk
Quotients
for
Freshwater
Invertebrates
Based
on
a
Water
Flea
(
Daphnia
magna)
LC50
of
210
ppb.
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11
Acute
Risk
Quotients
for
Estuarine
and
Marine
Fish
Based
on
a
Sheepshead
Minnow
(
Cyprinodon
variegatus)
LC50
of
540
ppb.
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12
Acute
Risk
Quotients
for
Estuarine/
Marine
Aquatic
Invertebrates
Based
on
a
Mysid
Shrimp
(
Americamysis
bahia)
LC50
of
3.6
ppb.
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12
Acute
Risk
Quotients
for
Aquatic
plants
Based
on
a
Selenastrum
Capricornutum
EC50
of
140
ppb.
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13
PRZM/
EXAMS
Input
Parameters
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13
Tier
II
Surface
water
EECs
(
Index
Reservoir)
for
Thiram
(
µ
g/
L)
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15
Ground
Water
Exposure
Inputs
for
SCIGROW
for
Thiram
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15
Ground
Water
EECs
for
Thiram
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15
Expected
Environmental
Concentrations
for
Exposure
to
Terrestrial
Wildlife
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16
1
I.
ENVIRONMENTAL
RISK
CONCLUSIONS
Thiram
(
tetramethylthiram
disulfide)
is
a
fungicide
used
to
control
plant
diseases
in
the
field.
Although
numerous
uses
are
listed
in
REFS,
currently
thiram
is
only
registered
for
foliar
application
on
apples,
peaches,
strawberries,
and
non­
residential
turf.
Thiram
is
also
used
as
an
animal
repellant
and
as
a
seed
protectant,
which
together
account
for
the
majority
of
the
registered
uses.
Some
of
these
uses
are
not
currently
supported
by
any
registrant
(
K.
Rothwell,
personal
communication
1/
24/
2000),
and
are
not
included
on
any
current
labels.
This
risk
assessment
is
based
only
on
currently
labeled
uses.
This
risk
assessment
focuses
primarily
on
the
four
foliar
uses
mentioned
above,
because
these
uses
involve
substantially
higher
application
rates
than
the
seed
and
animal
repellant
uses.
Several
studies
are
lacking,
but
based
on
the
available
data,
EFED
concludes
the
following
concerning
the
environmental
risk
of
the
usage
of
thiram.

Thiram's
usage
on
apples,
peaches,
strawberries,
and
non­
residential
turf
is
expected
to
present
risk
to
numerous
organisms.
Acute
risk
to
aquatic
animals
(
including
endangered
species)
is
expected.
The
chronic
toxicity
data
requirements
for
aquatic
animals
have
not
yet
been
fulfilled.
However,
EFED
assumes
that
there
will
be
adverse
chronic
risk
to
aquatic
animals
because
of:
1)
the
adverse
acute
risk
to
aquatic
animals,
2)
predicted
water
exposures,
and
3)
studies
on
mammals
and
birds
indicating
that
the
reproductive
physiology
of
fish
may
be
affected.
Although
the
acute
risk
to
birds
and
mammals
is
uncertain,
the
chronic
risk
to
mammals
and
birds
(
including
endangered
species)
is
expected
to
be
high.

Acceptable
guideline
studies
on
hydrolysis
and
adsorption/
desorption
are
required.
Based
in
part
on
supplemental
fate
data,
thiram
may
be
sufficiently
mobile
and
persistent
to
reach
surface
waters
in
concentrations
high
enough
to
impact
aquatic
life,
following
foliar
applications
of
the
chemical.

The
Tier
I
Estimated
Environmental
Concentrations
(
EECs)
for
Thiram
were
calculated
using
SCIGROW
(
ground
water)
for
turf,
apples
and
cotton
seed.
Tier
II
surface
water
EECs
for
Thiram
were
calculated
using
PRZM/
EXAMS
for
apples,
non­
residential
turf,
and
cotton
seed.
Surface
water
EECs
were
not
calculated
for
the
strawberry
use
because
of
the
absence
of
an
official
PRZM/
EXAMS
scenario.
However,
given
the
commonplace
use
of
plastic
mulch
in
the
cultivation
of
strawberries,
and
the
large
number
of
potential
seasonal
applications,
runoff
loadings
and
associated
aquatic
concentrations
of
Thiram
are
likely
to
be
high.
PRZM/
EXAMS
scenarios
were
run
using
the
standard
farm
pond
environment
to
generate
ecological
EECs,
and
the
Index
Reservoir
to
generate
drinking
water
EECs.
Resulting
EECs
to
be
used
for
human
drinking
water
exposure
assessment
are
summarized
in
the
following
table.

Table
1.
EECs
for
use
in
the
human
health
risk
assessment
2
Crop
Annual
App
Rate
(
lbs
ai/
acre/
yr)
SCIGROW
concentration
(
ppb)
PRZM/
EXAM
S*
Acute
EEC
(
ppb)
PRZM/
EXAMS*
non­
cancer
chronic
EEC
(
ppb)
PRZM/
EXAMS*
cancer
chronic
EEC
(
ppb)

Turf
farm
146.6
0.84
47.8
2.5
2.2
Golf
course
146.6
0.84
14.8
0.78
0.67
Apples
22.5
0.13
16.3
1.2
1.1
Cotton
seed
0.01
0.00006
0.006
0.0002
0.00007
*
Index
Reservoir
environment
II.
INTRODUCTION
Use
Characterization
Thiram
is
a
broad
spectrum
fungicide
used
to
control
plant
diseases
in
the
field.
Thiram
is
currently
registered
for
foliar
application
on
apples,
peaches,
strawberries,
and
non­
residential
turf.
Thiram
is
also
used
as
an
animal
repellant
and
as
a
seed
protectant.
Thiram
is
available
in
dust,
flowable,
wettable
powder,
water
dispersible
granules,
and
water
suspension
formulations.
Thiram
is
also
formulated
in
mixtures
with
other
fungicides.
The
majority
of
thiram
use
is
as
a
seed
treatment.
According
to
UCB
Chemicals
Corp.,
the
only
registrant
which
makes
thiram
products
for
foliar
and
turf
uses,
139,000
pounds
of
active
ingredient
were
sold
in
1998
for
foliar
and
turf
uses,
while
840,000
pounds
were
sold
for
seed
treatment.
According
to
the
QUA
report
(
9/
9/
99,
F.
Hernandez),
the
seed
treatment
with
the
greatest
thiram
usage
is
cotton,
and
about
29
million
acres,
or
16%
of
overall
acreage
planted
in
the
U.
S.
is
planted
with
seeds
that
have
been
treated
with
thiram.
According
to
information
provided
by
the
USGS
(
available
at
http://
water.
wr.
usgs.
gov/
pnsp/
use92/),
and
based
on
state­
level
estimates
of
pesticide
use
rates
for
individual
crops,
compiled
by
the
National
Center
for
Food
and
Agricultural
Policy
(
NCFAP)
for
1991­
1993
and
1995,
and
on
county­
based
crop
acreage
data
from
the
1992
Census
of
Agriculture),
the
geographical
areas
with
the
greatest
thiram
usage
include
areas
in
the
northeast
(
especially
in
Pennsylvania,
Delaware
and
Connecticut),
the
southeast
(
especially
in
North
Carolina,
Virginia,
and
Florida),
the
Pacific
northwest,
and
California.

Formulation
Type
The
formulations
of
Thiram
registered
for
foliar
application
are
as
follows:

$
Thiram
65J:
a
wettable
powder
product
composed
of
65%
Thiram
and
35%
inert
ingredients.

$
Thiram
GranufloJ:
a
water
dispersable
granule
product
composed
of
75%
Thiram
and
25%
inert
ingredients.
3
Method,
Rate,
and
Timing
of
Application
The
recommended
application
methods
for
foliar
treatments
of
Thiram
65J
wettable
powder
and
Thiram
GranufloJ
water
dispersible
granule
are
groundboom
and
aerial
broadcast.
For
strawberries,
the
labels
recommend
applying
up
to
five
individual
applications
of
up
to
3.3
lb
a.
i./
acre
per
crop
cycle
(
there
are
three
crop
cycles
per
year
in
Florida),
at
ten­
day
intervals,
for
a
maximum
total
of
49.5
lbs.
a.
i./
acre
per
year.
According
to
the
registrant,
the
use
of
this
number
of
applications
on
strawberries
in
Florida
is
standard
practice.
For
apples,
the
labels
recommend
individual
applications
as
needed
of
4.5
lb
a.
i./
acre,
to
be
applied
at
pre­
bloom,
calyx,
early
cover,
and
late
cover.
For
peaches,
the
labels
recommend
applications
of
3.8
lb
a.
i./
acre
each
as
needed.
For
non­
residential
turf,
the
labels
recommend
applications
of
up
to
98
lb
a.
i./
acre
each
as
needed.

III.
INTEGRATED
ENVIRONMENTAL
RISK
CHARACTERIZATION
This
risk
characterization
includes
an
integration
of
both
the
environmental
fate
characteristics
of
thiram
and
the
expected
ecological
effects
of
thiram.
The
primary
concerns
of
the
risk
characterization
are
acute
and
chronic
risks
to
aquatic
organisms,
and
chronic
risk
to
mammals
and
birds
due
to
foliar
and
turf
uses
of
thiram.

The
environmental
fate
database
for
thiram
is
incomplete.
However,
based
in
part
on
supplemental
fate
data,
thiram
that
is
applied
foliarly
is
expected
to
be
sufficiently
mobile
and
persistent
in
some
cases
to
reach
surface
waters
in
concentrations
high
enough
to
impact
aquatic
life.
Thiram
appears
to
be
hydrolytically
labile
under
alkaline
conditions,
but
relatively
stable
under
acidic
conditions
(
half­
life
>
68
days
at
pH
5).
Aqueous
photolysis
data
indicate
a
very
short
half­
life
(<
1
day)
for
thiram,
suggesting
that
in
clear
waters
thiram
may
not
persist.
Thiram
may
thus
be
most
potentially
persistent
in
acidic
waters
with
high
turbidity
or
color,
such
as
in
peat
bogs,
or
acidified,
eutrophic
lakes.
Under
both
aerobic
and
anaerobic
conditions
in
soil,
data
indicate
that
microbial
metabolism
of
thiram
is
substantially
biphasic,
with
rapid
initial
degradation
for
about
the
first
week,
followed
by
a
period
of
much
slower
degradation.
Aerobic
aquatic
data
indicate
rapid
degradation
in
water.
However,
this
may
be
offset
by
use
patterns
involving
multiple,
repeated
applications
which
cause
repeated
pulse
loadings
to
water
bodies
over
the
course
of
an
application
season.

Although
the
major
agricultural
use
of
thiram
is
as
a
seed
treatment,
it
is
the
orchard
and
turf
uses
which
present
the
most
significant
risks
to
endangered
and
non­
endangered
aquatic
organisms
(
freshwater
and
marine/
estuarine
fish,
invertebrates,
plants
and
algae)
on
an
acute
basis
(
See
Part
V.
Sec
C.).
This
is
in
part
because
the
application
rate
of
the
pesticide
to
the
environment
(
in
terms
of
lbs./
acre)
is
substantially
higher
than
that
for
treated
seed.
In
addition
to
the
higher
application
rate,
the
orchard
and
turf
uses
typically
entail
multiple
applications,
unlike
seed,
which
is
only
"
applied"
to
the
environment
at
planting.
A
higher
application
rate
means
higher
thiram
concentrations
in
receiving
waters
such
as
low­
order
streams
draining
agricultural
areas.
This
explains
the
level
of
concern
exceedances
for
acute
risk
to
aquatic
organisms
from
thiram
usage
on
apples
and
turf
(
See
Aquatic
Risk
Assessment
Tables
6­
10).
Currently
there
is
4
no
modeling
scenario
to
predict
estimated
exposure
concentrations
for
pesticides
used
on
strawberries.
However,
typical
agricultural
practices
for
growing
strawberries
treated
with
thiram
may
increase
the
risk
of
thiram
entering
adjacent
aquatic
organism
habitats.
These
typical
practices
include
using
multiple
applications
(
15
applications
at
3.3
lbs.
ai/
acre),
and
growing
strawberries
in
plastic­
mulch
beds.
Risk
of
aquatic
habitat
contamination
exist
from
these
specific
practices
because
the
plastic
surface
underlying
the
mulch
beds
will
decrease
rain
infiltration
and
increase
runoff
from
the
site
of
application.
Multiple
seasonal
applications
also
increase
the
probability
that
thiram
will
enter
water
bodies
at
concentrations
high
enough
to
cause
adverse
effects
to
aquatic
organisms.

The
chronic
toxicity
data
requirements
for
aquatic
organisms
have
not
yet
been
fulfilled.
However,
since
thiram
is
moderately
to
very
highly
toxic
to
aquatic
organisms
on
an
acute
basis,
has
adverse
reproductive
effects
on
other
organisms,
and
is
expected
to
reach
surface
waters
and
persist,
EFED
assumes
thiram
may
pose
an
adverse
chronic
risk
to
aquatic
organisms.

Although
the
acute
risk
quotients
indicate
that
thiram
presents
an
acute
risk
to
birds
and
mammals
for
the
foliar
uses
and
an
acute
restricted
use
to
birds
and
mammals
for
the
seed
uses,
EFED
concludes
that
the
acute
risk
to
birds
and
mammals
is
uncertain.
This
conclusion
is
based
on
the
fact
that
lab
studies
indicate
low
toxicity
to
avian
and
mammal
species,
and
that
thiram
is
marketed
as
an
animal
repellant
to
protect
treated
seeds
or
foliage
against
birds
and
mammals.
This
repellency
may
prevent
wildlife
from
oral
consumption
of
concentrations
high
enough
to
warrant
a
concern
for
acute
risk,
if
multiple
seed
ingestions
are
required
for
a
lethal
acute
dose.
However,
EFED
has
no
efficacy
data
on
the
effectiveness
of
thiram
as
an
animal
repellent.
Therefore,
EFED
is
not
certain
of
the
acute
risk
of
thiram
to
birds
and
mammals.

Although
EFED
is
uncertain
of
the
acute
risk
to
birds
and
mammals,
EFED
has
concerns
for
the
chronic
risk
of
thiram
to
birds
and
mammals.
Even
though
thiram
is
used
as
an
animal
repellant,
birds
and
mammals
could
ingest
enough
of
this
chemical
to
pose
chronic
risks.
The
risk
quotients
for
the
foliar,
turf,
and
seed
treatments
greatly
exceed
the
level
of
concern
for
chronic
risk
to
birds
and
mammals
(
Mammal
Risk
Quotients
range
2762­
3.94;
Bird
Risk
Quotients
range
546­
25;
See
Appendices
C
and
D).
Therefore,
EFED
predicts
that
there
will
be
chronic
risk
to
birds
and
mammals.
These
chronic
risks
include
endangered
species
of
mammals
and
birds.

EPA
is
required
under
the
FFDCA,
as
amended
by
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
5
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,
thiram
may
be
subjected
to
additional
screening
and
or
testing
to
better
characterize
effects
related
to
endocrine
disruption.

Based
on
the
weight
of
the
evidence,
the
following
effects
noted
in
Avian
Reproduction
studies
on
thiram
(
MRID
43612501,
43612502)
suggest
possible
endocrine
system
related
action:
abnormal
egg
production,
reductions
in
eggs
laid,
abnormal
embryos
of
eggs
set,
and
abnormal
hatchlings
of
eggs
set.

IV.
ENVIRONMENTAL
FATE
ASSESSMENT
The
environmental
fate
database
is
incomplete
because
acceptable
guideline
studies
on
hydrolysis
and
adsorption/
desorption
have
not
been
submitted.
The
registrants
are
required
to
submit
acceptable
studies
to
fulfill
these
guideline
requirements.
Although
these
guideline
study
requirements
have
not
been
fulfilled
at
this
time,
the
Agency
has
supplemental
data
for
all
of
these
studies,
which
can
be
used
in
conjunction
with
the
acceptable
guideline
study
data
to
qualitatively
assess
the
environmental
fate
of
the
chemical.

A.
Physical/
Chemical
Properties
Common
Name:
Thiram
Chemical
Name:
Tetramethylthiuram
disulfide
PC
code:
079801
CAS
Number:
137­
26­
8
Chemical
Class:
Dimethyl
dithiocarbamate
Formulations:
Dust,
Flowable,
Wettable
Powder,
Water
Dispersable
Granule,
Water
Suspension
Molecular
weight:
240.44
g/
mol
Aqueous
solubility:
30
ppm
(
25

C)
Vapor
pressure:
Negligible
at
25

C
6
B.
Persistence
Hydrolysis,
photodegradation,
and
aerobic
soil
metabolism
are
the
main
degradative
processes
for
thiram.
Observed
half­
lives
are
generally
less
than
18
days
under
the
nominal
or
expected
use
conditions,
producing
the
volatile
degradates
COS
and
CS
2
from
hydrolysis
and
photodegradation,
and
CO
2
from
aerobic
metabolism.
Non­
volatile
degradates
are
formed
at
less
than
10%
of
the
applied.

In
a
study
classified
as
supplemental,
the
hydrolysis
half­
life
for
thiram
(
MRID
41840601)
was
68.5
days
in
pH
5
buffer,
3.5
days
in
pH
7
buffer,
and
6.9
hours
in
pH
9
buffer.
In
another
hydrolysis
study
(
MRID
45714101),
thiram
was
stable
(
half­
life=
169
days)
in
pH
5
buffer
solution,
while
half­
lives
in
pH
7
and
pH
9
buffer
were
17.9
and
6.9
days,
respectively.
The
pH
5
portion
of
the
study
was
classified
as
acceptable,
while
the
pH
7
and
pH
9
portions
were
classified
as
supplemental.

In
a
supplemental
aqueous
photolysis
study
(
MRID
41753801),
the
half­
life
of
thiram
was
10.4
hours
in
pH
5
buffer,
while
in
a
study
classified
as
acceptable
(
MRID
45651201),
the
photolytic
half­
life
was
7.2
hours
in
pH
5
buffer.
No
degradation
was
observed
in
dark
controls
in
either
study.
In
an
acceptable
soil
photolysis
study
(
MRID
45724501),
thiram
degraded
with
a
half­
life
of
17.3
hours
on
a
sandy
loam
soil
at
pH
6.6
(
the
half­
life
was
43.2
hours
in
the
dark
controls).

In
an
aerobic
soil
(
pH=
6.7)
laboratory
study
(
MRID
43734901),
thiram
degraded
with
an
overall
half­
life
of
17.2
days
(
r2
=
0.74)
in
sandy
loam
soil,
over
a
period
of
205
days
(
the
reviewer­
calculated
overall
half­
life
was
2.09
days
by
non­
linear
regression).
The
minor
degradate
1,1,3,3­
tetramethyl­
2­
thiourea
(
TMTU)
was
a
maximum
of
0.3%
(
0.069
ppm)
of
the
applied
radioactivity
at
14
days
posttreatment.
The
minor
degradates
1,1,3,3­
tetramethylurea
(
TMU)
and
tetramethylthiuram
monosulfide
(
TMTM)
were
each
<
0.1%
(
0.001­
0.006
ppm)
of
the
applied
radioactivity.
The
minor
volatile
degradate
14CS
2
was
<
3%
of
the
applied
radioactivity
from
0
to
4
days
posttreatment.
Based
on
TLC
analysis,
the
minor
degradate
dimethylcarbamo
(
thioperoxic)
acid
(
M6.5)
was
a
maximum
of
8.7%
(
1.8
ppm)
of
the
applied
radioactivity
at
4
days
posttreatment.
Evolved
14CO
2
accounted
for
9.0%
of
the
applied
radioactivity
at
2
days
posttreatment
and
increased
to
a
maximum
of
74.9%
by
205
days.
The
DT50,
DT75,
and
DT90
for
thiram
were
approximately
1.7,
4.8,
and
9.8
days,
respectively.

The
aerobic
aquatic
metabolism
of
thiram
was
studied
(
MRID
45243401)
in
flooded
loamy
sand
and
loam
sediments
(
water:
soil
ratio
approximately
3:
1)
that
were
treated
at
a
rate
equivalent
to
3.2
kg
ai/
ha
and
incubated
in
the
dark
at
20
±
2

C
for
up
to
101
days.
During
incubation,
air
was
blown
across
the
water
surface
without
disturbing
the
sediment
layer;
redox
potentials
in
the
water
and
sediment
ranged
from
65
to
220
mV
and
­
46
to
­
390
mV,
respectively.
Thiram
degraded
with
reviewer­
calculated
half­
lives
of
1.5
and
2.1
days
for
pond
and
river
water
systems,
respectively.
Thiram
was
found
only
in
the
floodwater
throughout
the
study.
Three
degradates,
each
present
at
<
5.5%
of
the
applied,
were
identified
using
HPLC:
7
°
DMDTC­
ME
(
dimethyldithiocarbamic
acid
methyl
ester);
°
TMTM
(
tetramethylthiuram
monosulphide);
and
°
DMDTC
(
dimethyldithiocarbamic
acid
sodium
salt
dihydrate).

In
addition,
CS
2
(
carbon
disulfide)
and
CO
2
were
identified
in
the
floodwater
and
volatile
traps,
and
comprised
>
60%
of
the
applied
at
101
days.

In
an
anaerobic
aquatic
study
(
MRID
43628501),
thiram
degraded
with
an
overall
half­
life
of
43.1
days
(
0­
168
days
data;
r2
=
0.45)
in
flooded
clay
loam
sediment,
over
a
period
of
252
days.
The
major
degradate
under
anaerobic
conditions
was
CS
2,
comprising
approximately
17%
of
the
applied
after
7
days
of
anaerobic
incubation;
no
other
anaerobic
degradates
were
present
at
>
10%
during
the
incubation.
In
both
studies,
degradation
appeared
to
be
biphasic,
with
faster
degradation
initially
following
application,
followed
by
a
slower
degradation
until
the
end
of
the
study.
The
DT50,
DT75,
and
DT90
were
approximately
4.2,
8.1,
and
20.6
days,
respectively.

In
terrestrial
field
studies
conducted
in
California
(
MRID
44724501),
Thiram
(
Spotrete
J
75
WDG),
broadcast
applied
eight
times
as
a
spray,
at
a
nominal
application
rate
of
10.3
lbs
a.
i./
A/
application,
dissipated
with
half­
lives
of
27.4
days
(
r2
=
0.09;
0­
1
month
data)
and
14.4
days
(
r2
=
0.13;
0­
14
day
data)
for
bareground
and
turf
plots
of
sandy
loam
soil
(
pH
8.2
to
9.6),
respectively,
using
first­
order
linear
regression.
Dissipation
was
again
biphasic
in
both
plots.
In
terrestrial
field
studies
conducted
in
North
Carolina
(
MRID
44724502),
Thiram
(
Spotrete
®
75WDG),
broadcast
applied
eight
times
as
a
spray
at
a
nominal
application
rate
of
10.3
lb
a.
i./
A/
application,
dissipated
with
half­
lives
of
36
days
(
r2
=
0.79;
0­
60
day
data)
and
62.5
days
(
r2
=
0.84;
0­
90
day
data)
following
the
last
of
eight
applications
onto
a
bareground
plot
of
sand
soil
(
pH
4.1
to
4.7)
and
a
turf
plot
of
loamy
sand
soil
(
pH
4.4
to
4.5),
respectively.

Volatilization
is
not
expected
to
be
a
major
route
of
dissipation
due
to
thiram's
low
vapor
pressure
(
2.3
mPa
at
25

C,
or
1.77
x
10­
7
Torr).
The
major
thiram
degradates
are
volatile,
and
so
are
not
expected
to
persist
in
soil
or
water.

C.
Mobility
Thiram
residues
appear
to
have
low
mobility
in
the
environment.
In
a
supplemental
laboratory
study
(
MRID
43787501),
Thiram,
at
concentrations
of
0.01,
0.04,
0.20,
and
1.07
mg/
L,
was
determined
to
be
essentially
immobile
in
sandy
loam
and
silt
loam
soils,
and
to
have
low
mobility
in
loam
and
loamy
sand
soils
that
were
equilibrated
for
4
hours
at
20
oC
(
a
4
hour
equilibration
period
was
first
determined
to
be
adequate).
Freundlich
K
ads
values
were
54
for
the
sandy
loam
soil
(
pH=
6.7),
150
for
the
loamy
sand
soil
(
pH=
4.8),
67
for
the
silt
loam
soil
(
pH=
6.7),
and
263
for
the
loam
soil
(
pH=
7.3);
corresponding
K
oc
values
were
2245,
24526,
6359,
and
12899
mL/
g.
Respective
1/
N
values
were
1.04,
1.15,
1.10,
and
1.13
for
adsorption.
The
degree
of
sorption
of
thiram
to
these
soils
was
found
not
to
be
a
function
of
the
amount
of
organic
matter
present.
8
D.
Monitoring
data
At
this
time,
there
are
limited
monitoring
data
available
for
thiram
in
either
ground
or
surface
water,
with
no
reported
detections.
The
Pesticides
in
Ground
Water
Database
(
1991)
contains
no
records
for
thiram;
STORET
contains
no
detections
of
thiram.
No
detections
of
thiram
have
been
reported
to
the
Agency
under
6(
a)
2.
The
US
Geological
Survey
National
Water
Quality
Assessment
program
(
NAWQA)
is
not
currently
analyzing
for
thiram
in
their
samples,
and
they
do
not
have
analytical
methods
in
place
for
this
chemical.

V.
AQUATIC
EXPOSURE
AND
RISK
ASSESSMENT
A.
Hazard
Assessment
Thiram
is
moderately
to
very
highly
toxic
to
freshwater
and
estuarine
fish
on
an
acute
basis
(
96­
hour
LC
50'
s
42
to
7
ppb)
(
see
Appendix
A,
Tables
1
and
3).
In
addition,
thiram
on
an
acute
basis
is
highly
toxic
to
freshwater
invertebrates
(
EC
50:
210
ppb)
and
very
highly
toxic
to
marine/
estuarine
invertebrates
(
EC
50:
3.6
ppb).

EFED
has
required
that
chronic
toxicity
testing
be
conducted
for
freshwater
and
marine/
estuarine
fish
and
invertebrates
(
Memos:
D260206
&
D252135).
This
chronic
toxicity
data
has
not
yet
been
submitted.
Therefore,
EFED
cannot
determine
the
chronic
toxicity
to
aquatic
organisms.

B.
Aquatic
Exposure
Summary
Tier
II
models
PRZM
and
EXAMS
were
used
to
determine
estimated
concentrations
of
Thiram
in
surface
waters
for
use
on
non­
residential
turf,
apples,
and
cotton
seed.
Model
input
parameters
are
presented
in
the
following
table.
9
Table
2.
PRZM/
EXAMS
Input
Parameters
Parameter
Input
Source/
Rationale
Solubility
(
ppm)
16
Registrant­
provided
Aerobic
soil
t1/
2
(
days)
6.27
3
×
single
value
available;
MRID
43734901
Hydrolysis
t1/
2
(
days),
pH=
5
169
MRID
45714101
Hydrolysis
t1/
2
(
days),
pH=
7
18
MRID
45714101
Hydrolysis
t1/
2
(
days),
pH=
9
6.9
MRID
45714101
Aerobic
aquatic
t1/
2
(
days)
3.2
From
90%
C.
L.
on
mean
k
(
2
observations),
adjusted
to
account
for
hydrolysis
at
pH
7;
MRID
45243401
Aqueous
photolysis
t1/
2
(
days)
0.3
MRID
45651201
CAM
parameter
2
Reflects
application
to
turf
`
foliage'

Koc
(
mL/
g)
11507
Mean
value;
MRID
43787501
Application
rate,
turf
(
lb/
Acre)
10.18
From
label
Reg.
No.
45728­
1
Application
rate,
apples
(
lb/
Acre)
4.49
From
use
closure
memo,
K.
Rothwell,
2/
22/
2000
Application
rate,
cotton
seed
(
lb/
Acre)
0.01
From
label
Reg.
No.
7501­
80:
(
0.001
lb
ai/
lb
seed)
×
(
10
lb
seed/
acre)

Number
of
Applications,
turf
8
Max.
seasonal
(
not
annual)
number;
from
use
closure
memo,
K.
Rothwell,
2/
22/
2000
Number
of
Applications,
apples
5
Max.
seasonal
number;
from
use
closure
memo,
K.
Rothwell,
2/
22/
2000
Number
of
Applications,
cotton
seed
1
`
Application'
only
at
planting
Interval
between
applications,
turf
(
days)
7
Min.
interval;
from
use
closure
memo,
K.
Rothwell,
2/
22/
2000
Interval
between
applications,
apples
(
days)
7
Assumed:
value
not
specified
on
label,
or
in
use
closure
memo,
K.
Rothwell,
2/
22/
2000
Date
of
first
application,
turf
June
1
Reflects
summer
application
season
Date
of
first
application,
apples
March
22
Reflects
spring
application
season
Using
PRZM/
EXAMS
and
available
environmental
fate
data
for
thiram,
EFED
calculated
Tier
II
EECs
for
thiram
in
surface
water
for
the
uses
with
the
maximum
foliar
and
seed
acreages
(
apples
and
cotton,
respectively).
Detailed
descriptions
of
these
scenarios
are
given
in
Appendix
I.
10
Table
3.
Tier
II
Surface
Water
EECs
(
farm
pond)
for
thiram
(
µ
g/
L).

Use
site
Maximum
4
Day
21
Day
60
Day
90
Day
365
Day
FL
Turf,
nonresidential
44.5
25.0
15.3
13.1
9.7
3.4
OR
apples
20.0
12.5
8.9
5.8
4.4
1.6
MS
cotton
seed
0.29
0.02
0.007
0.0035
0.0027
0.001
Ecological
EEC
Summary:
Peak
Acute
estimated
surface
water
concentrations
of
Thiram
applied
at
maximum
label
rates
are
44.5
µ
g/
L
(
turf),
20.0
µ
g/
L
(
apples),
and
0.029
µ
g/
L
(
cotton).
Chronic
(
21
day)
estimated
surface
water
concentrations
are
15.3
µ
g/
L
(
turf),
8.9
µ
g/
L
(
apples),
and
0.007
µ
g/
L
(
cotton).

C.
Aquatic
Risk
Assessment
Below
is
a
summary
of
the
exceedances
of
the
level
of
concern
for
acute
risks
to
aquatic
organisms
(
freshwater
and
estuarine/
marine
fish,
invertebrates,
plants
and
algae)
for
thiram
usage.
This
summary
is
based
on
calculated
risk
quotients
and
only
applies
to
thiram
usage
on
nonresidential
turf,
apples,
and
cotton.
Currently
EFED
does
not
have
a
modeling
scenario
for
estimating
aquatic
concentrations
of
pesticides
used
on
strawberries.
Although
there
is
reason
to
believe
these
concentrations
may
be
high,
EFED
is
unable
to
quantitatively
determine
risk
quotients
for
thiram
used
on
strawberries
(
See
Sec
III
Integrated
Risk
Characterization).

EFED
has
required
the
chronic
studies,
Fish
Full
Life
Cycle
Test
(
Guideline
72­
5),
and
the
aquatic
invertebrate
life­
cycle
test
(
guideline
72­
4)
using
the
TGAI
of
thiram.
These
studies
have
not
yet
been
submitted.
However
because
of
the
adverse
acute
risk
expected
for
aquatic
organisms,
and
of
the
chronic
adverse
effects
to
mammals
and
birds,
EFED
assumes
high
potential
chronic
risk
to
aquatic
organisms
(
including
endangered
species).

Summary
of
acute
risks
to
aquatic
organisms
Freshwater
fish
risk:

$
acute
risk
for
non­
residential
turf
and
apple
uses
(
risk
includes
endangered
species).

Freshwater
invertebrate
risk:

$
acute
risk
for
non­
residential
turf
and
apple
uses
(
risk
includes
endangered
species).

Marine/
Estuarine
fish
risk:

$
acute
risk
to
non­
residential
turf
uses
(
risk
includes
endangered
species).

Marine/
Estuarine
Invertebrate
risk:
11
$
acute
risk
for
non­
residential
turf
and
apple
uses
(
risk
includes
endangered
species).

Risk
quotients
are
tabulated
below.

Freshwater
Fish
The
acute
freshwater
fish
risk
quotients
are
calculated
below.

Table
4.
Acute
Risk
Quotients
for
Freshwater
Fish
Based
on
a
Bluegill
Sunfish
(
Leopmis
macrochirus)
LC50
of
42
ppb.

Site/
Application
Method
LC50
(
ppb)
EEC
Initial/
Peak
(
ppb)
Acute
RQ
(
EEC/
LC50)

Turf/
ground
42
44.5
A
1.05
B
Apples/
aerial
foliar
application
42
20.0
A
0.47
B
Cotton/
seed
application
42
0.029
A
<
0.05
C
A
Tier
II
Surface
Water
EECs
for
thiram
(
µ
g/
L).
B
Exceeds
the
level
of
concern
of
acute
risk
to
freshwater
fish
(
including
endangered
species).
C
Does
not
exceed
the
level
concern.

Freshwater
Invertebrates
The
freshwater
invertebrates
acute
risk
quotients
are
tabulated
below.

Table
5.
Acute
Risk
Quotients
for
Freshwater
Invertebrates
Based
on
a
Water
Flea
(
Daphnia
Magna)
LC50
of
210
ppb.

Site/
Application
Method
LC50
(
ppb)
EEC
Initial/
Peak
(
ppb)
Acute
RQ
(
EEC/
LC50)

Turf/
ground
210
44.5
A
0.21
B
Apples/
aerial
foliar
application
210
20.0
A
0.10
B
Cotton/
seed
application
210
0.029
A
<
0.05
C
A
Tier
II
Surface
Water
EECs
for
thiram
(
µ
g/
L).
B
Exceeds
the
level
of
concern
of
acute
risk
to
freshwater
fish
(
including
endangered
species).
C
Does
not
exceed
the
level
concern.
12
Estuarine
and
Marine
Fish
The
estuarine
and
marine
fish
acute
risk
quotients
are
tabulated
below.

Table
6.
Acute
Risk
Quotients
for
Estuarine
and
Marine
Fish
Based
on
a
Sheepshead
minnow
(
Cyprinodon
variegatus)
LC50
of
540
ppb.

Site/
Application
Method
LC50
(
ppb)
EEC
Initial/
Peak
(
ppb)
Acute
RQ
(
EEC/
LC50)

Turf/
ground
540
44.5
A
0.082
B
Apples/
aerial
foliar
application
540
22.0
A
<
0.05
C
Cotton/
seed
application
540
0.047
A
<
0.05
C
A
Tier
II
Surface
Water
EECs
for
thiram
(
µ
g/
L).
B
Exceeds
the
level
of
concern
of
acute
risk
to
freshwater
fish
(
including
endangered
species).
C
Does
not
exceed
the
level
of
concern.

Estuarine
and
Marine
Invertebrates
The
estuarine
and
marine
fish
acute
risk
quotients
are
tabulated
below.

Table
7.
Acute
Risk
Quotients
for
Estuarine/
Marine
Aquatic
Invertebrates
Based
on
a
Mysid
Shrimp
(
Americamysis
bahia)
LC50
of
3.6
ppb.

Site/
Application
Method
LC50
(
ppb)
EEC
Initial/
Peak
(
ppb)
Acute
RQ
(
EEC/
LC50)

Turf/
ground
3.6
44.5
A
12.36
B
Apples/
aerial
foliar
application
3.6
20.0
A
6.11
B
Cotton/
seed
application
3.6
0.029
A
<
0.05
C
A
Tier
II
Surface
Water
EECs
for
thiram
(
µ
g/
L).
B
Exceeds
the
level
of
concern
of
acute
risk
to
freshwater
fish
(
including
endangered
species).
C
Does
not
exceed
the
level
of
concern.

Aquatic
Plants
and
Algae
The
aquatic
plant
acute
risk
quotients
are
tabulated
below.
The
level
of
concern
for
risk
to
aquatic
plants
is
not
exceeded.
13
Table
8.
Acute
Risk
Quotients
for
Aquatic
plants
Based
on
a
Selena
strum
Capricornutum
EC50
of
140
ppb
and
a
Lemma
Gibba
EC
50
of
1600
ppb
Site/
Application
Method
EC50
(
ppb;
Selena
strum
Capricorn
utum)
EC50
(
ppb;
Lemma
Gibba)
EEC
Initial/
Peak
(
ppb)
Acute
RQ
(
EEC/
LC50)
Acute
RQ
(
Lemma
Gibba;
Aquatic
Vascular
Plants)

Turf/
ground
140
1600
44.5
A
<
1
C
<
1
C
Apples/
aerial
foliar
application
140
1600
20.0
A
<
1
C
<
1
C
Cotton/
seed
application
140
1600
0.029
A
<
1
C
<
1
C
A
Tier
II
Surface
Water
EECs
for
thiram
(
µ
g/
L).
B
Exceeds
the
level
of
concern
of
risk
.
C
Does
not
exceed
the
level
concern.

Endangered
Species
Assessment
(
Aquatic)

Both
the
non­
residential
turf
and
apples
uses
exceed
the
level
of
concern
for
risks
to
endangered
freshwater
fish,
freshwater
invertebrates,
estuarine/
marine
invertebrates.
There
is
an
exceedence
of
the
level
of
concern
risk
to
endangered
marine/
estuarine
fish
only
for
the
turf
use.

VI.
DRINKING
WATER
ASSESSMENT
Tier
II
models
PRZM
and
EXAMS
were
used
to
determine
estimated
concentrations
in
surface
waters
for
use
on
non­
residential
turf,
employing
the
Index
Reservoir
(
IR)
water
body
with
a
Percent
Crop
Area
(
PCA)
adjustment
for
the
turf
farm
use,
and
a
similar
areal
adjustment
for
the
golf
course
use
to
reflect
percent
coverage
in
tees
and
greens.
The
tier
I
screening
model
SCI­
GROW
was
used
to
estimate
concentrations
of
thiram
in
groundwater.

A.
Surface
Water
EECs
Tier
II
models
PRZM
and
EXAMS
were
used
to
determine
estimated
concentrations
of
Thiram
in
surface
waters
for
use
on
non­
residential
turf,
apples,
and
cotton
seed.
Model
input
parameters
are
presented
in
the
following
table.

Table
9.
PRZM/
EXAMS
Input
Parameters
Parameter
Input
Source/
Rationale
Solubility
(
ppm)
16
Registrant­
provided
Aerobic
soil
t1/
2
(
days)
6.27
3
×
single
value
available;
MRID
43734901
Hydrolysis
t1/
2
(
days),
pH=
5
169
MRID
45714101
Hydrolysis
t1/
2
(
days),
pH=
7
18
MRID
45714101
14
Hydrolysis
t1/
2
(
days),
pH=
9
6.9
MRID
45714101
Aerobic
aquatic
t1/
2
(
days)
3.2
From
90%
C.
L.
on
mean
k
(
2
observations),
adjusted
to
account
for
hydrolysis
at
pH
7;
MRID
45243401
Aqueous
photolysis
t1/
2
(
days)
0.3
MRID
45651201
CAM
parameter
2
Reflects
application
to
turf
`
foliage'

Koc
(
mL/
g)
11507
Mean
value;
MRID
43787501
Application
rate,
turf
(
lb/
Acre)
10.19
From
label
Reg.
No.
45728­
1
Application
rate,
apples
(
lb/
Acre)
4.49
From
use
closure
memo,
K.
Rothwell,
2/
22/
2000
Application
rate,
cotton
seed
(
lb/
Acre)
0.01
From
label
Reg.
No.
7501­
80:
(
0.001
lb
ai/
lb
seed)
×
(
10
lb
seed/
acre)

Number
of
Applications,
turf
8
Max.
seasonal
(
not
annual)
number;
from
use
closure
memo,
K.
Rothwell,
2/
22/
2000
Number
of
Applications,
apples
5
Max.
seasonal
number;
from
use
closure
memo,
K.
Rothwell,
2/
22/
2000
Number
of
Applications,
cotton
seed
1
`
Application'
only
at
planting
Interval
between
applications,
turf
(
days)
7
Min.
interval;
from
use
closure
memo,
K.
Rothwell,
2/
22/
2000
Interval
between
applications,
apples
(
days)
7
Assumed:
value
not
specified
on
label,
or
in
use
closure
memo,
K.
Rothwell,
2/
22/
2000
Date
of
first
application,
turf
June
1
Reflects
summer
application
season
Date
of
first
application,
apples
March
22
Reflects
spring
application
season
Percent
crop
area,
turf
farm
and
apples
0.87
Default
PCA
Percent
golf
course
in
greens
&
tees
0.27
Standard
assumption
for
golf
courses;
memo
2/
27/
2002
from
E.
Leovey
to
EFED
Using
PRZM/
EXAMS
and
available
environmental
fate
data
for
thiram,
EFED
calculated
Tier
II
EECs
for
thiram
using
Index
Reservoir
scenarios
for
the
uses
with
the
maximum
foliar
and
seed
acreages
(
apples
and
cotton,
respectively).
The
Index
Reservoir
is
intended
as
a
drop­
in
replacement
for
the
standard
pond
for
use
in
drinking
water
assessments.
It
is
used
in
a
manner
similar
to
the
standard
pond
except
that
flow
rates
are
calibrated
to
be
consistent
with
local
weather
conditions.
The
morphology
of
the
reservoir
and
its
watershed
are
designed
to
correspond
with
those
of
Shipman
City
Lake,
a
small
reservoir
in
Illinois
selected
to
represent
small
runoff­
vulnerable
drinking
water
surface
supplies
in
agricultural
areas.
As
with
the
standard
pond,
soils
are
selected
to
represent
the
regions
in
the
modeled
scenarios.
Detailed
descriptions
of
the
scenarios
used
in
this
assessment
are
presented
in
Appendix
I.
15
Table
10.
Tier
II
Surface
Drinking
Water
EECs
(
index
reservoir)
for
thiram
(
µ
g/
L).

Use
site
Acute
(
Max.
daily
average),
µ
g/
L
Chronic,
non­
cancer
(
µ
g/
L)
Chronic,
cancer
(
µ
g/
L)

Turf,
FL
(
Turf
farm)
47.8
2.5
2.2
Turf,
FL
(
Golf
course)
14.8
0.78
0.67
Apples,
OR
16.3
1.2
1.1
Cotton
seed,
MS
0.006
0.0002
0.00007
B.
Groundwater
EECs
EFED
used
the
Tier
I
screening
model
SCIGROW
to
estimate
concentrations
of
thiram
in
ground
water.
Model
input
parameters
and
EECs
are
presented
in
tables
12
and
13,
respectively.

Table
11.
Ground
Water
Exposure
Inputs
for
SCIGROW
for
Thiram.

Parameter
Input
Source/
Rationale
Aerobic
soil
t1/
2
(
days)
6.27
days
Single
available
value;
MRID
43734901
Koc
9629
Median
of
four
available
values;
MRID
43734901
Annual
application
rate
(
lb
a.
i./
acre/
yr)
146.6
Max.
annual
label
rate;
Reg.
No.
45728­
1;
from
use
closure
memo,
K.
Rothwell,
2/
22/
2000
Table
12.
Ground
Water
EECs
for
thiram
(
µ
g/
L)

Use
site
Acute
and
Chronic
conc.,
µ
g/
L
Turf,
FL
(
Turf
farm)
0.84
Apples,
OR
0.13
Cotton
seed,
MS
0.00006
C.
Monitoring
Data
At
this
time,
there
are
limited
monitoring
data
available
for
thiram
in
either
ground
or
surface
water,
with
no
reported
detections.
The
Pesticides
in
Ground
Water
Database
(
1991)
contains
no
records
for
thiram;
STORET
contains
no
detections
of
thiram.
No
detections
of
thiram
have
been
reported
to
the
Agency
under
6(
a)
2.
The
U.
S.
Geological
Survey
National
Water
Quality
Assessment
program
(
NAWQA)
is
not
currently
analyzing
for
thiram
in
their
samples,
and
they
do
not
have
analytical
methods
in
place
for
this
chemical.
16
VII.
TERRESTRIAL
EXPOSURE
AND
RISK
ASSESSMENT
A.
Hazard
Assessment
Since
the
LD50
falls
in
the
range
of
>
100
­>
2800
mg/
kg,
thiram
is
categorized
as
moderately
toxic
to
practically
nontoxic
to
avian
species
on
an
acute
oral
basis.
Because
the
LC50
falls
in
the
range
of
1000­>
5000
ppm,
thiram
is
categorized
as
slightly
toxic
to
practically
nontoxic
to
avian
species
on
a
subacute
dietary
basis
(
see
Appendix
A,
Table
5).

Study
results
indicate
that
thiram
is
practically
nontoxic
to
small
mammals
on
an
acute
oral
basis
(
Acute
oral
LC
50
2600
mg/
kg).
For
chronic
toxicity
effects
a
reduction
in
body
weight
of
mammals
was
observed
at
a
NOAEC
of
1.9
mg/
kg/
day.

Thiram
is
practically
nontoxic
to
the
honeybee
(
LD
50>
200

g/
bee).

B.
Terrestrial
Exposure
Summary
Foliar
and
turf
uses
The
terrestrial
EECs
were
calculated
using
the
spread
sheet
routine
entitled
"
LFATE".
(
See
Appendix
C.
for
the
assumptions).
The
peak
EECs
were
used
to
calculate
the
acute
and
chronic
risk
for
each
of
the
use
sites.
EFED
chose
the
peak
EEC
because
the
foliar
and
turf
uses
typically
entail
frequent
multiple
applications
(
applications
per
year
range
of
3.44
to
15
and
the
intervals
between
the
applications
range
from
7­
10
days).
Because
thiram's
use
involves
frequent
repeated
applications,
and
thiram
has
a
slow
rate
of
degradation,
the
EECs
for
foliar
and
turf
uses
are
expected
to
remain
at
or
near
peak
concentrations
throughout
the
growing
season.

Table
13.
Expected
Environmental
Concentrations
for
Exposure
to
Terrestrial
Wildlife.

Site,
Appl.
Method
Appl.
Rate
(
lbs
ai/
A)/#
of
Appl/
Frequency
of
Appl(
days)
Terrestrial
EEC
(
ppm)

Short
Grass
(
ppm)
max*
Tall
Grass
(
ppm)
max*
Broadleaf
Plants
&
Small
Insects
max*
Fruit
&
Large
Insects
max*

peaches
ground
application,
max.
per
season
rate
3.8/
8/
7
2666.4
1222.1
1499.8
166.7
apples
ground
application,
max.
per
season
rate
4.5/
5/
10
3586.2
1643.7
2017.2
224.13
strawberries
ground
application,
max.
per
season
rate
3.3/
15/
10
3719.11
1704.59
2092
232.44
Turf,
ground
application,
max
per
season
rate
13.5/
8/
7
15863.33
7270.92
8923.41
991.49
*
Value
(
max
concentration)
used
to
calculate
acute
and
chronic
risk
quotients.
17
Seed
uses
Seeds
are
treated
with
thiram
before
they
are
planted.
Therefore,
EFED
has
calculated
the
EEC
for
seed
use
based
the
residual
concentration
of
thiram
on
the
seed.
The
EEC
of
thiram
as
residue
on
seeds
is
1000
ppm.
The
EEC
concentration
is
calculated
as
follows
:

0.001
lbs
ai./
lbs
seed
(
in
accordance
to
label)
=
1000
ppm
ai
as
residue
on
seeds
C.
Quantitative
Risk
Assessment
Birds
Acute
risk
quotients
for
birds
are
calculated
based
on
the
acute
dietary
LC
50
of
3950
ppm
for
the
northern
bobwhite
quail.
Chronic
risk
quotients
for
birds
are
calculated
using
the
LOAEC
(
9.6
ppm)
obtained
from
the
bird
reproductive
studies
testing
the
Mallard
and
Northern
bobwhite
quail.

The
level
of
concern
is
exceeded
for
acute
risk
to
birds
for
foliar
and
turf
uses,
and
the
LOC
is
exceeded
for
acute
restricted
risk
to
birds
for
use
on
seeds
(
See
Appendix
D).
In
addition,
the
level
of
concern
is
exceeded
for
chronic
risk
to
birds
for
foliar,
turf,
and
seed
uses.
EFED
concludes
that
although
thiram
exposure
from
the
seed
uses
may
not
be
continuous
or
recurring,
chronic
effects
to
birds
may
occur
as
a
result
of
initial
exposure
to
planted
seeds.
Furthermore,
the
chronic
risk
to
birds
for
any
of
the
uses
can
only
be
partially
assessed
because
the
chronic
toxicity
data
requirements
for
birds
is
only
partially
fulfilled
(
See
Appendix
A.
Toxicity
Summary
Sec.
A).

Mammals
Acute
and
chronic
risk
quotients
for
mammals
are
calculated
based
on
the
results
of
toxicity
tests
obtained
from
HED.
The
value
used
to
determine
the
acute
risk
quotients
is
2600
mg/
kg.
The
value
used
to
determine
the
chronic
risk
quotients
is
1.9
mg/
kg.

The
level
of
concern
is
exceeded
for
acute
risk
to
mammals
including
endangered
species
for
foliar
uses
and
turf,
and
the
level
of
concern
is
exceeded
for
acute
restricted
risk
to
mammals
including
endangered
species
for
only
the
seed
uses.
The
level
of
concern
is
exceeded
for
chronic
risk
to
mammals
including
endangered
species
for
use
on
foliar,
turf,
and
seed.
EFED
concludes
that
although
thiram
exposure
from
the
seed
uses
may
not
be
continuous
or
recurring,
chronic
effects
to
mammals
may
occur
as
a
result
of
initial
exposure
to
planted
seeds.

Appendix
D
demonstrates
the
acute
and
chronic
risk
quotients
for
mammals
for
use
on
turf,
seed,
and
foliar
(
apples,
peaches,
and
strawberries).
18
Insects
Thiram
is
practically
nontoxic
to
the
honeybee
(
LD
50>
200

g/
bee).
Therefore,
the
new
uses
are
predicted
to
pose
minimal
risk
to
nontarget
insects.

Threatened
or
endangered
species
The
level
of
concern
for
turf,
foliar,
and
seed
uses
is
exceeded
for
acute
and
chronic
risk
to
threatened
or
endangered
species
of
birds
and
mammals.
19
APPENDIX
A
Ecotoxicity
Data
I.
Toxicity
to
Freshwater
Organisms
a.
Freshwater
Fish,
Acute
Two
freshwater
fish
toxicity
studies
using
the
TGAI
are
required
to
establish
the
toxicity
of
thiram
to
fish.
The
preferred
test
species
are
rainbow
trout
(
a
coldwater
fish)
and
bluegill
sunfish
(
a
warmwater
fish).
Results
of
these
tests
are
tabulated
below.

Table
1.
Freshwater
Fish
Acute
Toxicity
Species/
Flow­
through
or
Static
%
ai
96­
hour
LC50
(
ppb)
Toxicity
Category
Study
Identification
Study
Classification
Bluegill
Sunfish
(
Leopmis
macrochirus)
99
42
Very
Highly
Toxic
MRID070801
Core
Bluegill
Sunfish
(
Leopmis
macrochirus)
75
280
Highly
Toxic
BAOTH102
Supplemental
Rainbow
trout
(
Oncorhynchus
mykiss)
75
500
Highly
Toxic
00090293
Supplemental
Rainbow
trout
(
Oncorhynchus
mykiss)

Harlequin
fish
(
Rasbar
heteromorpha)
99
80
130
7
Highly
Toxic
Very
Highly
Toxic
BAOTH102
00034713
Core
Supplemental
Since
the
LC50
falls
in
the
range
of
<
1­
1000
ppb,
thiram
is
categorized
as
highly
toxic
to
very
highly
toxic
to
freshwater
fish
on
an
acute
basis.
The
guideline
(
72­
1)
is
fulfilled.

b.
Freshwater
Fish,
Chronic
EFED
has
requested
that
a
Fish
Full
Life
Cycle
Test
(
Guideline
72­
5)
using
the
TGAI
for
thiram.
The
preferred
test
species
is
the
fathead
minnow
(
Pimephales
promelas).
The
guideline
(
72­
5)
has
not
yet
been
fulfilled.
The
study
must
be
conducted
to
fully
satisfy
the
requirement.
The
study
was
requested
for
the
following
reasons:


The
pesticide
is
intended
for
use
such
that
its
presence
in
water
is
likely
to
be
continuous
or
recurrent.


FIFRA
requires
a
fish
life­
cycle
test
for
any
pesticide
if
the
aquatic
acute
LC50
or
EC50
is
less
than
1
ppm.
The
LC50
of
the
freshwater
species,
the
rainbow
trout
(
Oncorhynchus
mykiss),
is
0.130
ppm
(
Study
Identification
#
BAOTH102).
20
c.
Freshwater
Invertebrates,
Acute
A
freshwater
aquatic
invertebrate
toxicity
test
(
guideline
72­
2)
using
the
TGAI
is
required
to
establish
the
toxicity
of
thiram
to
aquatic
invertebrates.
The
preferred
test
species
is
Daphnia
magna.
Results
of
this
test
are
tabulated
below.

Table
2.
Freshwater
Invertebrate
Acute
Toxicity
Species/
Static
or
Flowthrough
%
ai
48­
hour
LC50
(
ppm)
Toxicity
Category
MRID
No.
Author/
Year
Study
Classification
Waterflea
(
Daphnia
magna)
98
0.21
highly
toxic
164662
Core
Thiram
is
categorized
as
highly
toxic
to
aquatic
invertebrates
on
an
acute
basis.
The
guideline
(
72­
2)
is
fulfilled.

d.
Freshwater
Invertebrate,
Chronic
(
Guideline
72­
4)

EFED
has
requested
the
freshwater
aquatic
invertebrate
life­
cycle
test
(
guideline
72­
4)
using
the
TGAI
of
thiram.
The
preferred
test
species
is
the
water
flea
(
Daphnia
magna).
The
guideline
(
72­
4)
has
not
yet
been
fulfilled.
The
study
was
requested
for
the
following
reasons:


The
pesticide
is
intended
for
use
such
that
its
presence
in
water
is
likely
to
be
continuous
or
recurrent.


FIFRA
guidelines
require
both
the
freshwater
aquatic
invertebrate
life­
cycle
test
for
any
pesticide
if
the
aquatic
acute
LC50
or
EC50
is
less
than
1
ppm.
The
waterflea
(
Daphnia
magna)
is
0.21
ppm
(
MRID
164662).

II.
Toxicity
to
Estuarine
and
Marine
Animals
a.
Estuarine
and
Marine
Fish,
Acute
Acute
toxicity
testing
with
estuarine/
marine
fish
using
the
TGAI
is
required
for
Thiram
because
the
end­
use
product
is
expected
to
reach
marine/
estuarine
habitats.
The
preferred
test
species
is
sheepshead
minnow.
Results
of
these
tests
are
tabulated
below.

Table
3.
Estuarine/
Marine
Fish
Acute
Toxicity
Species/
Static
or
Flow­
through
%
ai
96­
hour
LC50
(
ppm)
(
measured/
nominal)
Toxicity
Category
MRID
No.
Author/
Year
Study
Classification
Sheepshead
minnow
(
Cyprinodon
variegatus)
98
0.54
Highly
Toxic
425144­
01
Core
Since
the
LC50
falls
in
the
range
of
0.54
ppm,
is
categorized
as
highly
toxic
to
estuarine/
marine
fish
on
an
acute
basis.
The
guideline
(
72­
3a)
is
fulfilled.
21
b.
Estuarine
and
Marine
Fish,
Chronic
EFED
has
requested
the
estuarine/
marine
fish
life­
cycle
test
(
guideline
72­
5)
using
the
TGAI
of
thiram.
The
preferred
test
species
is
the
sheepshead
minnow
(
Cyprinodon
variegatus).
The
guideline
(
72­
5)
has
not
yet
been
fulfilled.
The
study
must
be
conducted
to
fully
satisfy
the
requirement.
The
study
was
requested
for
the
following
reasons:


The
pesticide
is
intended
for
use
such
that
its
presence
in
water
is
likely
to
be
continuous
or
recurrent.


FIFRA
requires
a
fish
life­
cycle
test
for
any
pesticide
if
the
aquatic
acute
LC50
or
EC50
is
less
than
1
ppm.
The
LC50
of
the
estuarine
marine
species,
the
sheepshead
minnow
(
Cyprinodon
variegtus),
is
0.54
ppm
(
Study
Identification
MRID425144­
01).

c.
Estuarine
and
Marine
Invertebrates,
Acute
Acute
toxicity
testing
with
estuarine/
marine
invertebrates
using
the
TGAI
is
required
for
thiram
because
the
end­
use
product
is
intended
for
direct
application
to
the
marine/
estuarine
environment
or
the
active
ingredient
is
expected
to
reach
this
environment
because
of
its
use
in
coastal
counties.
The
preferred
test
species
are
mysid
shrimp
and
eastern
oyster.
Results
of
these
tests
are
tabulated
below.

Table
4.
Estuarine/
Marine
Invertebrate
Acute
Toxicity
Species/
Static
or
Flow­
through
%
ai.
LC50/
EC50
(
ppb)
(
measured/
nominal)
Toxicity
Category
MRID
No.
Author/
Year
Study
Classification
Eastern
oyster
(
shell
deposition
or
embryolarvae
(
Crassostrea
gigas)
98.3
4.7
EC50
very
highly
toxic
424883­
01
Core
Mysid
(
Americamysis
bahia)
98.3
3.6
LC50
very
highly
toxic
424883­
02
Core
Since
the
LC50/
EC50
falls
in
the
range
of
<
1
ppb,
thiram
is
categorized
as
very
highly
toxic
to
estuarine/
marine
invertebrates
on
an
acute
basis.
The
guideline
(
72­
3b
and
72­
3c)
is
fulfilled.

d.
Estuarine
and
Marine
Invertebrate,
Chronic
EFED
has
requested
the
estuarine/
marine
aquatic
invertebrate
life­
cycle
test
(
guideline
72­
4)
using
the
TGAI
of
thiram.
The
preferred
test
species
is
the
Mysid
(
Americamysis
bahia).
The
guideline
(
72­
4)
has
not
yet
been
fulfilled.
The
study
must
be
conducted
to
fully
satisfy
the
requirement.
The
study
was
requested
for
the
following
reasons:


The
pesticide
is
intended
for
use
such
that
its
presence
in
water
is
likely
to
be
continuous
or
recurrent.
22

FIFRA
guidelines
require
the
estuarine/
marine
aquatic
invertebrate
life­
cycle
test
for
any
pesticide
if
the
aquatic
acute
LC50
or
EC50
is
less
than
1
ppm.
The
acute
LC50'
s
for
the
eastern
oyster
(
Crassostrea
virginia)
and
the
mysid
shrimp
(
Mysidopis
bahia)
are
0.0047
ppm
and
0.0036
ppm
respectively
(
MRIDs
424883­
01
and
424883­
02).

1.
Ecological
Toxicity
Data
a.
Toxicity
to
Terrestrial
Animals
i.
Birds,
Acute
and
Subacute
An
acute
oral
toxicity
study
using
the
technical
grade
of
the
active
ingredient
(
TGAI)
is
required
to
establish
the
toxicity
of
thiram
to
birds.
The
preferred
test
species
is
either
mallard
duck
(
a
waterfowl)
or
bobwhite
quail
(
an
upland
gamebird).
Results
of
this
test
are
tabulated
below.

Table
5.
Avian
Acute
Oral
Toxicity
Species
%
ai
LD50
(
mg/
kg)
Toxicity
Category
Identification
No.
Study
Classification1
Ring­
neck
Pheasant
(
Phasianus
colchicus)
99
673
moderately
toxic
Baoth103
Supplemental
Mallard
duck
(
Anas
platyrhynchos)

Red­
wing
blackbird
(
Agelaius
phoeniceus)

Starling
14
Day
(
Sturnus
vulgatis)
99
99
99
>
2800
>
100
>
100
practically
nontoxic
moderately
toxic
moderately
toxic
Baoth103
MRID
075683
MRID
075683
Core
Supplemental
Supplemental
1
Core
(
study
satisfies
guideline).
Supplemental
(
study
is
scientifically
sound,
but
does
not
satisfy
guideline)

Since
the
LD50
falls
in
the
range
of
51
­
>
2000
mg/
kg,
thiram
is
categorized
as
moderately
toxic
to
practically
nontoxic
to
avian
species
on
an
acute
oral
basis.
The
avian
acute
oral
toxicity
test
requirement,
guideline
71­
1,
is
fulfilled.
23
Two
subacute
dietary
studies
using
the
TGAI
are
required
to
establish
the
toxicity
of
thiram
to
birds.
The
preferred
test
species
are
mallard
duck
and
bobwhite
quail.
Results
of
these
tests
are
tabulated
below.

Table
6.
Avian
Subacute
Dietary
Toxicity
Species
%
ai
5­
Day
LC50
(
ppm)
1
Toxicity
Category
MRID
No.
Study
Classification
Bobwhite
(
Colinus
virginianus)

Mallard
(
Anas
platyrhynchos)

Ring­
necked
pheasant
(
Phasianus
colchicus)

Japanese
quail
(
Coturnix
c.
japonia)
Tech
Tech.

Tech
Tech
3950
5000
>
5000
>
5000
slightly
toxic
slightly
toxic
pratically
nontoxic
pratically
nontoxic
MRID
022923
MRID
022923
MRID
022923
MRID
022923
Core
Core
Supplemental
Supplemental
1
Test
organisms
observed
an
additional
three
days
while
on
untreated
feed.

Since
the
LC50
falls
in
the
range
of
1000­>
5000
ppm,
thiram
is
categorized
as
slightly
toxic
to
practically
nontoxic
to
avian
species
on
a
subacute
dietary
basis.
The
guideline
(
71­
2)
is
fulfilled.

ii.
Birds,
Chronic
Avian
reproduction
studies
using
the
TGAI
are
required
for
thiram
because
the
following
conditions
are
met:
(
1)
birds
may
be
subject
to
repeated
or
continuous
exposure
to
the
pesticide,
especially
preceding
or
during
the
breeding
season,
(
2)
the
pesticide
is
stable
in
the
environment
to
the
extent
that
potentially
toxic
amounts
may
persist
in
animal
feed,
(
3)
the
pesticide
is
stored
or
accumulated
in
plant
or
animal
tissues,
and/
or,
(
4)
information
derived
from
mammalian
reproduction
studies
indicates
reproduction
in
terrestrial
vertebrates
may
be
adversely
affected
by
the
anticipated
use
of
the
product.
The
preferred
test
species
are
mallard
duck
and
bobwhite
quail.
Results
of
these
tests
are
tabulated
below.
24
Table
7.
Avian
Reproduction
Species/
Study
Duration
%
ai
NOEC/
LOEC
(
ppm)
LOEC
Endpoints
MRID
No.
Author/
Year
Study
Classification
Northern
bobwhite
quail
(
Colinus
virginianus)
97.5
500/
2500
egg
production,
reductions
in
the
egg
set
of
eggs
laid,
viable
embryos
of
eggs
set,
normal
hatchlings
of
eggs
laid,
normal
hatchlings
of
eggs
set,
and
14­
day
old
survivors
of
eggs
set;
and
reductions
in
feed
consumption,
14­
day
old
survivor
weight,
and
hen
bodyweights.
436125­
02
Core
Mallard
duck
(
Anas
platyrhynchos)
98.7
9.6/
39.7
eggs
set,
viable
embryos,
live
3­
week
embryos,
normal
hatchlings,
14­
day
old
survivors,
eggs
set/
eggs
laid,
normal
hatchlings/
live
3­
week
embryos,
and
normal
hatchlings/
eggs
laid
45441201
Core
Mallard
duck
(
Anas
platyrhynchos)
97.5
<
50/
50
egg
productions,
eggs
set/
eggs
laid,
and
normal
hatchlings/
eggs
laid
436125­
01
Supplemental
iii.
Mammals,
Acute
and
Chronic
Wild
mammal
testing
is
required
on
a
case­
by­
case
basis,
depending
on
the
results
of
lower
tier
laboratory
mammalian
studies,
intended
use
pattern
and
pertinent
environmental
fate
characteristics.
In
most
cases,
rat
or
mouse
toxicity
values
obtained
from
the
Agency's
Health
Effects
Division
(
HED)
substitute
for
wild
mammal
testing.
These
toxicity
values
are
reported
below.

Table
8.
Mammalian
Toxicity
Species/
Study
Duration
%
ai
Test
Type/
Classification
Toxicity
Value
Affected
Endpoints
MRID
No.

laboratory
rat
(
Rattus
norvegicus)

laboratory
rat
(
Rattus
norvegicus)
99.0
97.5
Acute
Oral
LD50
Reproduction
Study­
2
Generation
Species/
Core
2600
mg/
kg
1.9
mg/
kg/
day
Mortality
Body
Weight
00153548
42095901
An
analysis
of
the
results
indicate
that
thiram
is
categorized
as
practically
nontoxic
to
small
mammals
on
an
acute
oral
basis.

iv.
Insects
25
A
honey
bee
acute
contact
study
using
the
TGAI
is
required
for
thiram
because
its
foliar
uses
(
peaches,
strawberries,
and
apples)
will
result
in
honey
bee
exposure.
Results
of
this
test
are
tabulated
below.

Table
9.
Nontarget
Insect
Acute
Contact
Toxicity
Species
%
ai
LD50
Toxicity
Category
MRID
No.
Study
Classification
Honey
bee
(
Apis
mellifera)
technical
73.72
(
ug/
bee)
non­
toxic
0003635
core
An
analysis
of
the
results
indicate
that
thiram
categorize
as
nontoxic
to
bees
on
an
acute
contact
basis.
The
guideline
(
141­
1)
is
fulfilled.

II.
Toxicity
to
Plants
a.
Terrestrial
Currently,
terrestrial
plant
testing
is
not
required
for
pesticides
other
than
herbicides
except
on
a
case­
by­
case
basis
(
e.
g.,
labeling
bears
phytotoxicity
warnings
incident
data
or
literature
that
demonstrate
phytotoxicity).
Therefore,
EFED
does
not
require
terrestrial
plant
testing
for
thiram.

b.
Aquatic
Aquatic
plant
testing
(
EC
50
Aquatic
Plant
Test:
Guideline
122­
2
(
Tier
I
))
is
required
for
thiram
for
the
following
reasons:
1)
It
has
outdoor
non­
residential
terrestrial
uses.
2)
It
may
move
off­
site
by
runoff
(
solubility
>
10
ppm
in
water)
or
may
move
by
drift
(
aerial
or
irrigation)
3)
It
is
applied
directly
to
aquatic
use
sites.
The
tier
I
study
as
defined
in
the
Pesticide
Registration
Rejection
Rate
Analysis
(
EPA
738­
R­
94­
085
December
1994)
requires
the
EC50
aquatic
plant
test
for
Lemna
gibba
and
Selenastrum
capricornutum.
The
results
of
the
aquatic
plant
toxicity
tests
are
demonstrated
below
in
Table
10.

Table
10.
Nontarget
Insect
Acute
Contact
Toxicity
Species
%
ai
LD50
MRID
No.
Study
Classification
Selenastrum
capricornutum
99%
0.14
ppm
44086101
Core
Lemma
Gibba
98.7%
1.6
mg
a.
i./
L
45441202
Core
26
APPENDIX
B
Tier
I
Model
Limitations
Limitations
of
the
SCI­
GROW
Analysis
The
SCI­
GROW
model
(
Screening
Concentrations
in
Ground
Water)
is
a
model
for
estimating
concentrations
of
pesticides
in
ground
water
under
"
maximum
loading"
conditions.
SCI­
GROW
provides
a
screening
concentration;
an
estimate
of
likely
ground
water
concentrations
if
the
pesticide
is
used
at
the
maximum
allowed
label
rate
in
areas
with
ground
water
exceptionally
vulnerable
to
contamination.
In
most
cases,
a
majority
of
the
use
area
will
have
ground
water
that
is
less
vulnerable
to
contamination
than
the
areas
used
to
derive
the
SCIGROW
estimate.

The
SCI­
GROW
model
is
based
on
scaled
ground
water
concentration
from
ground
water
monitoring
studies,
environmental
fate
properties
(
aerobic
soil
half­
lives
and
organic
carbon
partitioning
coefficients­
K
oc's)
and
application
rates.
The
model
is
based
on
permeable
soils
that
are
vulnerable
to
leaching
and
on
shallow
ground
water
(
10­
30
feet).
27
APPENDIX
C
Assumptions
used
in
the
LFATE
spreadsheet
program
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
=
C
i
e­
kT
or
in
integrated
form:
ln
(
CT/
C
i)
=
­
kT
Where:
CT
=
concentration
at
time
T
on
day
zero
C
i
=
concentration
in
parts
per
million
(
ppm)
present
initially
(
on
day
zero)
on
the
surfaces.
C
i
is
calculated
based
on
Canoga
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
PPM
on
the
plant
surface
and
the
addition
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/
T1/
2)
instead
of
being
input
directly.
In
accordance
with
EFED
policy
since
the
half­
life
of
thiram
is
greater
than
30
(
days),
the
half­
life
chosen
to
calculate
the
terrestrial
EEC
is
30
days
(
EFED
Policy
Memorandum,
Calculation
of
Terrestrial
EECs,
August
20,
1999).

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
following
table
demonstrates
the
input
value
for
the
LFATE
program
for
each
of
the
crop
uses.

Table
A.
Input
values
for
LFATE
Crops
Half­
life
(
k)
(
days)
Frequency
of
Applications
Maximum
#
of
Applications
per
Year
Application
Rate
apples
30
10
5
4.5
peaches
30
10
3.44
3.8
strawberries
30
10
15
3.3
Turf
30
7
8
13.6
28
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.

Table
A.
Acute
and
Chronic
Risk
Quotients
Calculations
for
Birds
for
Seed
Uses
Only
Concentration
of
Thiram
as
residue
on
treated
seeds
(
ppm)
LC50
ppm
NOEAC
ppm
Acute
RQ1(
EEC/
LC50)
Chronic
RQ
(
EEC/
NOEAC)

999
3950
9.6
0.25
104
Table
B.
Mammalian
(
Herbivore/
Insectivore)
Acute
and
Chronic
Risk
Quotients
for
Application
of
Thiram
on
Seed
Uses
Based
on
a
Rat
Acute
LD50
of
2600
and
a
Rat
Chronic
NOAEL
of
1.9
mg/
kg
Concentration
as
Residue
on
Seed
(
ppm)
Body
Weight
(
g)
%
Body
Weight
Consumed
Rat
LD50
(
mg/
kg)
Rat
Chronic
NOEAC
(
1.9
mg/
kg/
day)
converted
to
ppm)
Acute
RQ1
Chronic
RQ
999
15
95
2600
38
0.36
24.97
35
66
2600
38
0.25
17.35
1000
15
2600
38
0.06
3.94
RQ
=
EEC
(
ppm)/
LD50
(
mg/
kg)*
%
Body
Weight
Consumed
APPENDIX
D
29
Chemical
Name:
Thiram
Use
Apples
Formulation
Technical
Inputs
Application
Rate
4.5
lbs
a.
i./
acre
Half­
life
30
days
Frequency
of
Application
7
days
Maximum
#
Apps./
Year
8
Outputs
Maximum
56
day
Average
Concentration
Concentration
(
PPM)
(
PPM)
Short
Grass
5249.06
3264.00
Tall
Grass
2405.82
1496.00
#
days
Broadleaf
plants/
sm
Insects
2952.60
1836.00
Exceeded
Fruits/
pods/
lg
insects
328.07
204.00
on
short
grass
(
in
first
56)

Avian
Acute
LC50
(
ppm)
3950
21
Chronic
NOAEC
(
ppm)
9.6
56
Max
Single
Application
which
does
NOT
exceed
Acute
RQ
Chronic
RQ
Avian
Acute
16.458
(
Max.
res.
mult.
apps.)
Avian
Chronic
0.040
(
lb
a.
i.)
Short
Grass
1.33
546.78
Tall
Grass
0.61
250.61
#
days
Mammalian
Acute
72.22
Broadleaf
plants/
sm
Insects
0.75
307.56
Exceeded
Mammalian
Chronic
0.01
Fruits/
pods/
lg
insects
0.08
34.17
on
short
grass
(
in
first
56)

Mammalian
Acute
LD50
(
mg/
kg
bw/
d
2600
38
Rat
Calculated
LC50
(
ppm)
52000
Chronic
NOAEL
(
mg/
kg
1.9
56
Rat
Calculated
NOAEL
(
ppm)
38
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
1.92
1.33
0.30
0.10
2762.66
Tall
Grass
0.88
0.61
0.14
0.05
1266.22
Broadleaf
plants/
sm
insects
1.08
0.75
0.17
0.06
1554.00
Fruits/
pods/
lg
insects
0.12
0.08
0.02
0.01
172.67
Seeds
(
granivore)
0.03
0.02
0.00
0.01
Length
of
Simulation
1
year
Level
of
Concern
193.00
(
ppm)

Acute
Mammalian
RQs
Mammalian
Class
Body
Wgt
%
body
wgt
consumed
Short
grass
Tall
grass
Broadleaf
plantsFruit/
pods/
lg
insects
15
95
1.92
0.88
1.08
0.12
Herbivores/
35
66
1.33
0.61
0.75
0.08
insectivores
1000
15
0.30
0.14
0.17
0.02
21
21
0.03
Grainivores
35
15
0.02
1000
3
0.00
Chronic
Mammalian
RQs
2762.66
1266.22
1554.00
172.67
Terresterial
Application
Residues
0
1000
2000
3000
4000
5000
6000
0
4
8
12
16
20
24
28
32
36
40
44
48
52
Days
Concentration
(
PPM)
Short
Grass
Tall
Grass
Broadleaf
plants/
sm
Insects
Fruits/
pods/
l
Terrestrial
(
Bird
and
Mammal)
Risk
Quotient
Calculation
For
Foliar,
Turf
and
Seed
Uses
Figure
A.
Terrestrial
Organism
Risk
Quotient
Calculations
for
Thiram
Use
on
Apples
30
Chemical
Name:
Thiram
Use
Peaches
Formulation
Technical
Inputs
Application
Rate
3.8
lbs
a.
i./
acre
Half­
life
30
days
Frequency
of
Application
7
days
Maximum
#
Apps./
Year
8
Outputs
Maximum
56
day
Average
Concentration
Concentration
(
PPM)
(
PPM)
Short
Grass
4432.54
2756.27
Tall
Grass
2031.58
1263.29
#
days
Broadleaf
plants/
sm
Insects
2493.30
1550.40
Exceeded
Fruits/
pods/
lg
insects
277.03
172.27
on
short
grass
(
in
first
56)

Avian
Acute
LC50
(
ppm)
3950
8
Chronic
NOAEC
(
ppm)
9.6
56
Max
Single
Application
which
does
NOT
exceed
Acute
RQ
Chronic
RQ
Avian
Acute
16.458
(
Max.
res.
mult.
apps.)
Avian
Chronic
0.040
(
lb
a.
i.)
Short
Grass
1.12
461.72
Tall
Grass
0.51
211.62
#
days
Mammalian
Acute
72.22
Broadleaf
plants/
sm
Insects
0.63
259.72
Exceeded
Mammalian
Chronic
0.01
Fruits/
pods/
lg
insects
0.07
28.86
on
short
grass
(
in
first
56)

Mammalian
Acute
LD50
(
mg/
kg
bw/
d
2600
33
Rat
Calculated
LC50
(
ppm)
52000
Chronic
NOAEL
(
mg/
kg
1.9
56
Rat
Calculated
NOAEL
(
ppm)
38
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
1.62
1.13
0.26
0.09
2332.92
Tall
Grass
0.74
0.52
0.12
0.04
1069.25
Broadleaf
plants/
sm
insects
0.91
0.63
0.14
0.05
1312.27
Fruits/
pods/
lg
insects
0.10
0.07
0.02
0.01
145.81
Seeds
(
granivore)
0.02
0.02
0.00
0.01
Length
of
Simulation
1
year
Level
of
Concern
193.00
(
ppm)

Acute
Mammalian
RQs
Mammalian
Class
Body
Wgt
%
body
wgt
consumed
Short
grass
Tall
grass
Broadleaf
plantsFruit/
pods/
lg
insects
15
95
1.62
0.74
0.91
0.10
Herbivores/
35
66
1.13
0.52
0.63
0.07
insectivores
1000
15
0.26
0.12
0.14
0.02
21
21
0.02
Grainivores
35
15
0.02
1000
3
0.00
Chronic
Mammalian
RQs
2332.92
1069.25
1312.27
145.81
Terresterial
Application
Residues
0
500
1000
1500
2000
2500
3000
3500
4000
4500
5000
0
4
8
12
16
20
24
28
32
36
40
44
48
52
Days
Concentration
(
PPM)
Short
Grass
Tall
Grass
Broadleaf
plants/
sm
Insects
Fruits/
pods/
l
Figure
B.
Terrestrial
Organism
Risk
Quotient
Calculations
for
Thiram
Use
on
Peaches
31
Figure
C.
Terrestrial
Organism
Risk
Quotient
Calculations
for
Thiram
Use
on
Strawberries.
32
Chemical
Name:
Thiram
Use
Strawberries
Formulation
Technical
Inputs
Application
Rate
3.3
lbs
a.
i./
acre
Half­
life
30
days
Frequency
of
Application
7
days
Maximum
#
Apps./
Year
8
Outputs
Maximum
56
day
Average
Concentration
Concentration
(
PPM)
(
PPM)
Short
Grass
3849.31
2393.60
Tall
Grass
1764.27
1097.07
#
days
Broadleaf
plants/
sm
Insects
2165.24
1346.40
Exceeded
Fruits/
pods/
lg
insects
240.58
149.60
on
short
grass
(
in
first
56)

Avian
Acute
LC50
(
ppm)
3950
0
Chronic
NOAEC
(
ppm)
9.6
56
Max
Single
Application
which
does
NOT
exceed
Acute
RQ
Chronic
RQ
Avian
Acute
16.458
(
Max.
res.
mult.
apps.)
Avian
Chronic
0.040
(
lb
a.
i.)
Short
Grass
0.97
400.97
Tall
Grass
0.45
183.78
#
days
Mammalian
Acute
72.22
Broadleaf
plants/
sm
Insects
0.55
225.55
Exceeded
Mammalian
Chronic
0.01
Fruits/
pods/
lg
insects
0.06
25.06
on
short
grass
(
in
first
56)

Mammalian
Acute
LD50
(
mg/
kg
bw/
d
2600
27
Rat
Calculated
LC50
(
ppm)
52000
Chronic
NOAEL
(
mg/
kg
1.9
56
Rat
Calculated
NOAEL
(
ppm)
38
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
1.41
0.98
0.22
0.07
2025.95
Tall
Grass
0.64
0.45
0.10
0.03
928.56
Broadleaf
plants/
sm
insects
0.79
0.55
0.12
0.04
1139.60
Fruits/
pods/
lg
insects
0.09
0.06
0.01
0.00
126.62
Seeds
(
granivore)
0.02
0.01
0.00
0.00
Length
of
Simulation
1
year
Level
of
Concern
193.00
(
ppm)

Acute
Mammalian
RQs
Mammalian
Class
Body
Wgt
%
body
wgt
consumed
Short
grass
Tall
grass
Broadleaf
plants/
Fruit/
pods/
lg
insects
15
95
1.41
0.64
0.79
0.09
Herbivores/
35
66
0.98
0.45
0.55
0.06
insectivores
1000
15
0.22
0.10
0.12
0.01
21
21
0.02
Grainivores
35
15
0.01
1000
3
0.00
Chronic
Mammalian
RQs
2025.95
928.56
1139.60
126.62
Terresterial
Application
Residues
0
500
1000
1500
2000
2500
3000
3500
4000
4500
0
4
8
12
16
20
24
28
32
36
40
44
48
52
Days
Concentration
(
PPM)
Short
Grass
Tall
Grass
Broadleaf
plants/
sm
Insects
Fruits/
pods/
l
Fi
gu
re
D.
Te
rr
est
ria
l
Or
ga
nis
m
Ri
sk
Q
uo
tie
nt
Ca
lcu
lat
io
ns
for
Th
ira
m
Us
e
on
Tu
rf.
33
Chemical
Name:
Thiram
Use
Turf
Formulation
Technical
Inputs
Application
Rate
13.6
lbs
a.
i./
acre
Half­
life
30
days
Frequency
of
Application
7
days
Maximum
#
Apps./
Year
8
Outputs
Maximum
56
day
Average
Concentration
Concentration
(
PPM)
(
PPM)
Short
Grass
15863.83
9864.54
Tall
Grass
7270.92
4521.25
#
days
Broadleaf
plants/
sm
Insects
8923.41
5548.81
Exceeded
Fruits/
pods/
lg
insects
991.49
616.53
on
short
grass
(
in
first
56)

Avian
Acute
LC50
(
ppm)
3950
49
Chronic
NOAEC
(
ppm)
9.6
56
Max
Single
Application
which
does
NOT
exceed
Acute
RQ
Chronic
RQ
Avian
Acute
16.458
(
Max.
res.
mult.
apps.)
Avian
Chronic
0.040
(
lb
a.
i.)
Short
Grass
4.02
1652.48
Tall
Grass
1.84
757.39
#
days
Mammalian
Acute
72.22
Broadleaf
plants/
sm
Insects
2.26
929.52
Exceeded
Mammalian
Chronic
0.01
Fruits/
pods/
lg
insects
0.25
103.28
on
short
grass
(
in
first
56)

Mammalian
Acute
LD50
(
mg/
kg
bw/
d
2600
56
Rat
Calculated
LC50
(
ppm)
52000
Chronic
NOAEL
(
mg/
kg
1.9
56
Rat
Calculated
NOAEL
(
ppm)
38
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
5.80
4.03
0.92
0.31
8349.39
Tall
Grass
2.66
1.85
0.42
0.14
3826.80
Broadleaf
plants/
sm
insects
3.26
2.27
0.51
0.17
4696.53
Fruits/
pods/
lg
insects
0.36
0.25
0.06
0.02
521.84
Seeds
(
granivore)
0.08
0.06
0.01
0.02
Length
of
Simulation
1
year
Level
of
Concern
193.00
(
ppm)

Acute
Mammalian
RQs
Mammalian
Class
Body
Wgt
%
body
wgt
consumed
Short
grass
Tall
grass
Broadleaf
plantsFruit/
pods/
lg
insects
15
95
5.80
2.66
3.26
0.36
Herbivores/
35
66
4.03
1.85
2.27
0.25
insectivores
1000
15
0.92
0.42
0.51
0.06
21
21
0.08
Grainivores
35
15
0.06
1000
3
0.01
Chronic
Mammalian
RQs
8349.39
3826.80
4696.53
521.84
Terresterial
Application
Residues
0
2000
4000
6000
8000
10000
12000
14000
16000
18000
0
4
8
12
16
20
24
28
32
36
40
44
48
52
Days
Concentration
(
PPM)
Short
Grass
Tall
Grass
Broadleaf
plants/
sm
Insects
Fruits/
pods/
l
Table
A.
Acute
and
Chronic
Risk
Quotients
Calculations
for
Birds
for
Seed
Uses
Only
Concentration
of
Thiram
as
residue
on
treated
seeds
(
ppm)
LC50
ppm
NOEAC
ppm
Acute
RQ1(
EEC/
LC50)
Chronic
RQ
(
EEC/
NOEAC)

1000
3950
9.6
0.25
104
34
Table
B.
Mammalian
(
Herbivore/
Insectivore)
Acute
and
Chronic
Risk
Quotients
for
Application
of
Thiram
on
Seed
Uses
Only
Based
on
a
Rat
Acute
LD50
of
2600
and
a
Rat
Chronic
NOAEL
of
1.9
mg/
kg/
day
Concentration
as
Residue
on
Seed
(
ppm)
Body
Weight
(
g)
%
Body
Weight
Consumed
Rat
LD50
(
mg/
kg)
Rat
Chronic
NOEAC
(
1.9
mg/
kg/
day)
converted
to
ppm)
Acute
RQ1
Chronic
RQ
1000
15
95
2600
38
0.36
24.97
35
66
2600
38
0.25
17.35
1000
15
2600
38
0.06
3.94
RQ
=
EEC
(
ppm)/
LD50
(
mg/
kg)*
%
Body
Weight
Consumed
APPENDIX
E
Environmental
Fate
Study
Bibliography
35
Guideline
161­
1
Status:
Supplemental.
MRID
41840601
(
1991),
Norris,
K.
J.
Determination
of
the
hydrolysis
of
14C­
Thiram.
Reviewed
by
J.
Carleton
(
original
review
by
J.
Hetrick).
MRID
45714101
(
2002),
Shepler,
K.
and
Runes,
H.
Hydrolysis
of
14C­
Thiram
at
pH
5,7,
and
9.
Reviewed
by
M.
Mahoney.

Guideline
161­
2
Status:
Fulfilled.
MRID
45651201
(
2001),
Shepler,
K.
and
Runes,
H.
Photodegradation
of
14C­
Thiram
in
sterilized
buffer
at
pH
5
by
artificial
light.
Reviewed
by
M.
Mahoney.
Supplemental:
MRID
41753801
(
1991),
Norris,
K.
J.
Determination
of
the
photodegradation
in
water
of
14C­
Thiram.
Reviewed
by
J.
Carleton
(
original
review
by
J.
Hetrick).

Guideline
161­
3
Status:
Fulfilled.
MRID
45724501
(
2002),
Shepler,
K.
and
Runes,
H.
Photodegradation
study
of
14C­
Thiram
in/
on
soil
by
artificial
light.
Reviewed
by
M.
Mahoney
Unacceptable:
MRID
43661801
(
1997),
Burri,
R.
Photodegradation
study
of
14C­
Thiram
on
soil.
Reviewed
by
J.
Carleton.

Guideline
162­
1
Status:
Fulfilled.
MRID
43734901
(
1995),
Morgenroth,
U.
and
Müller­
Kallert,
H.
M.
14C­
Thiram:
degradation
and
metabolism
in
one
soil
incubated
under
aerobic
conditions.
Reviewed
by
J.
Carleton.

Guideline
162­
3
Status:
Fulfilled.
MRID
43628501
(
1994),
Wyss­
Benz,
M.
14C­
Thiram:
degradation
and
metabolism
in
an
anaerobic
aquatic
system.
Reviewed
by
J.
Carleton.

Guideline
163­
1
Status:
Supplemental.
MRID
43787501
(
1995),
Morgenroth,
U.
Adsorption/
desorption
of
14C­
thiram
on
four
soils.
Reviewed
by
J.
Carleton.

Guideline
164­
1
Status:
Supplemental.
MRID
44724501
(
1998),
Dykeman,
R.
G.
Determination
of
the
dissipation
of
residues
of
thiram
in
California
turf
and
bare
ground
plots
treated
with
Spotrete
J
75WDG.
Reviewed
by
J.
Carleton.

Guideline
164­
1
Status:
Fulfilled.
MRID
44724502
(
1998),
Dykeman,
R.
G.
Determination
of
the
dissipation
of
residues
of
thiram
in
North
Carolina
turf
and
bare
ground
plots
treated
with
Spotrete
J
75WDG.
Reviewed
by
J.
Carleton.
36
APPENDIX
F
Environmental
Fate
Data
Requirements
for
Thiram
Guideline
#
Data
Requirement
Is
Data
Requirement
Satisfied?
MRID
#'
s
Study
Classification
161­
1
Hydrolysis
no
45714101
41840601
supplemental
supplemental
161­
2
Photodegradation
in
Water
yes
45651201
41758301
acceptable
supplemental
161­
3
Photodegradation
on
Soil
yes
45724501
43661801
acceptable
invalid
161­
4
Photodegradation
in
Air
waived
162­
1
Aerobic
Soil
Metabolism
yes
43734901
acceptable
162­
2
Anaerobic
Soil
Metabolism
no
40768103
invalid
162­
3
Anaerobic
Aquatic
Metabolism
yes
43628501
acceptable
162­
4
Aerobic
Aquatic
Metabolism
yes
45243401
acceptable
163­
1
Leaching­
Adsorption/
Desorption
no
43787501
supplemental
163­
2
Laboratory
Volatility
not
required
163­
3
Field
Volatility
not
required
164­
1
Terrestrial
Field
Dissipation
yes
44724501
44724502
supplemental
acceptable
164­
2
Aquatic
Field
Dissipation
not
required
164­
3
Forestry
Dissipation
not
required
165­
4
Accumulation
in
Fish
not
required
165­
5
Accumulation­
aquatic
non­
target
not
required
166­
1
Ground
Water­
small
prospective
not
required
166­
2
Ground
Water­
small
retrospective
not
required
201­
1
Droplet
Size
Spectrum
not
required
202­
1
Drift
Field
Evaluation
not
required
37
APPENDIX
G
Ecological
Effects
Data
Requirements
for
Chemical
Thiram
Guideline
#
Data
Requirement
Is
Data
Requirement
Satisfied?
Id.
#'
s
Study
Classificatio
n
71­
1
Avian
Oral
LD50
Yes
BAOTH103
Core
71­
2
Avian
Dietary
LC50
Yes
MRID
022923
Core
71­
4
Avian
Reproduction
Yes
MRID
45441201
Core
72­
1
Freshwater
Fish
LC50
Yes
BAOTH102
Core
72­
2
Freshwater
Invertebrate
Acute
LC50
Yes
MRID
164662
Core
72­
3(
a)
Estuarine/
Marine
Fish
LC50
Yes
MRID
425144­
01
Core
72­
3(
b)
Estuarine/
Marine
Mollusk
EC50
Yes
MRID
424883­
01
Core
72­
3
©
Estuarine/
Marine
Shrimp
EC50
Yes
MRID
424883­
02
Core
72­
4(
a)
Freshwater
Fish
Early
Life­
Stage
No
NA
NA
72­
4(
b)
Aquatic
Invertebrate
Life­
Cycle
No
NA
NA
72­
5
Freshwater
Fish
Full
Life­
Cycle
No
NA
NA
122­
1(
a)
Seed
Germ./
Seedling
Emergence
Not
required
NA
NA
122­
1(
b)
Vegetative
Vigor
Not
required
NA
NA
122­
2
Aquatic
Algal
Growth
Yes
MRID
426460­
01
Core
123­
1(
a)
Seed
Germ./
Seedling
Emergence
Not
Required
NA
NA
123­
1(
b)
Vegetative
Vigor
Not
Required
NA
NA
123­
2
Aquatic
Plant
Growth
Yes
MRID
45441202
NA
144­
1
Honey
Bee
Acute
Contact
LD50
Yes
MRID
0003635
Core
141­
2
Honey
Bee
Residue
on
Foliage
Not
required
NA
NA
1
The
bobwhite
quail
reproductive
study
(
MRID436125­
02)
was
core.
However,
the
mallard
study
436125­
01
was
declared
supplemental
because
the
NOEAC
was
not
obtained.
EFED
has
required
the
mallard
study
be
repeated
in
order
to
obtain
a
NOEAC.
The
guideline
(
71­
4)
has
not
yet
been
fulfilled.
38
N
C
S
S
C
N
CH3
CH3
CH3
CH3
*
*
S
S
*
*

N
C
N
S
CH3
CH3
CH3
CH3
N
C
N
CH3
CH3
CH3
CH3
O
N
C
CH3
CH3
S
C
N
S
S
CH3
CH3
N
C
O
S
CH3
CH3
OH
APPENDIX
H
Chemical
Names
and
Structures
of
Thiram
and
Degradates
Thiram
(
tetramethyl
thiuram
disulfide):
(*
denotes
position
of
radiolabels)

TMTU
(
1,1,3,3­
tetramethyl­
2­
thiourea):

TMU
(
1,1,3,3­
tetramethylurea):

TMTM
(
tetramethylthiuram
monosulfide):

M6.5
(
dimethylcarbamo
(
thioperoxic)
acid):
39
40
APPENDIX
I
Descriptions
of
PRZM/
EXAMS
Scenarios
Apple
Scenario:

The
apple
orchard
is
in
Washington
County,
Oregon.
It
has
a
Cornelius
silt
loam
soil,
a
fine­
silty,
mixed,
mesic
Mollic
Fragixeralfs,
in
MLRA
2.
The
Cornelius
silt
loam
is
a
deep,
moderately
well
drained
soil
that
formed
in
silty
loess­
like
material
located
on
uplands
with
slopes
of
2­
60
percent.
The
series
is
typical
of
cultivated
walnut
and
other
orchard
crops
of
the
region.
The
Cornelius
silt
loam
is
a
Hydrologic
Group
C.
There
are
approximately
200
acres
of
apple
orchards
in
Washington
County,
which
is
among
the
lowest
in
the
State.
However,
the
region
is
known
for
high
rainfall
potential,
steep
slopes,
and
vulnerable
soils,
making
it
an
ideal
"
high­
end"
region
for
pesticide
runoff
potential.
The
weather
data
is
from
weather
station
W24232
in
Salem,
Oregon.
The
weather
data
file
is
also
part
of
the
PIRANHA
shell
and
is
used
to
represent
the
weather
for
MLRA
2.

Cotton
Scenario:

The
cotton
field
is
in
Yazoo
County,
Mississippi.
It
has
a
Loring
silt
loam
soil,
a
finesilty
mixed,
mesic
Thermic
Typic
Fragiudalf,
in
MLRA
O­
134.
The
Loring
silt
loam
is
a
moderately
well
drained
soil
with
a
fragipan
formed
in
loess
on
level
to
strongly
sloping
upland
and
stream
terraces
on
slopes
of
0­
20
percent.
The
Loring
silt
loam
is
a
Hydrologic
Group
C
soil
with
SCS
curve
numbers
that
were
measured
on
a
real
field
in
Yazoo
County,
Mississippi
under
cotton
culture.
There
are
approximately
101,000
acres
of
cotton
grown
in
Yazoo
County,
which
is
the
most
of
any
county
in
Mississippi
and
among
the
top
10
percent
in
the
U.
S.
USLE
C
Factors
were
developed
by
George
Foster
at
the
University
of
Mississippi
in
consultation
with
Ronald
Parker
of
the
US
EPA
to
represent
a
cotton
field
with
one
year
tilled
followed
by
two
years
under
conservation
tillage
using
RUSLE.
The
weather
data
is
from
weather
station
W03940
in
Jackson,
Mississippi.
The
weather
data
file
is
also
part
of
the
PIRANHA
shell
and
is
used
to
represent
the
weather
for
MLRA
131.
This
weather
data
was
used
rather
than
the
MLRA
140
weather
data
as
it
was
expected
to
better
represent
the
weather
in
Yazoo
County.

Turf
scenario:

The
field
used
to
represent
Florida
turf
is
derived
from
that
for
citrus
production
in
Collier
or
Hendry
Counties
in
Southwest
Florida.
The
soil
selected
to
simulate
the
field
is
a
Wabasso
fine
sand.
Wabasso
fine
sand,
is
a
sandy,
siliceous,
hyperthermic
Alfic
Alaquods.
These
soils
are
often
used
for
citrus
production
and
truck
crops.
Wabasso
fine
sand
is
a
deep
to
very
deep,
poorly
to
very
poorly
drained,
slow
to
ponded
runoff,
rapidly
permeable
in
the
top
horizon
and
slow
to
very
slowly
permeable
in
the
lower
horizons
soil
that
formed
in
sandy
and
loamy
marine
sediments.
These
soils
are
generally
found
on
flatwoods,
flood
plains,
and
depressions
and
have
41
slopes
of
0
to
2
percent.
The
soil
is
extensive
in
Florida.
Wabasso
fine
sand
is
a
Hydrologic
Group
D
soil.

Use
of
Index
Reservoir
and
Percent
Cropped
Areas
in
Modeling
PRZM­
EXAMS
modeling
using
the
Index
Reservoir
(
IR)
and
the
Percent
Crop
Area
(
PCA)
adjustment
was
used
to
estimate
concentrations
in
surface
water
used
as
a
source
of
drinking
water.
The
index
reservoir
represents
a
watershed
that
is
more
vulnerable
than
most
used
as
drinking
water
sources.
It
was
developed
from
a
real
watershed
in
western
Illinois.
The
index
reservoir
is
used
as
a
standard
watershed
that
is
combined
with
local
soils,
weather,
and
cropping
practices
to
represent
a
vulnerable
watershed
for
each
crop
that
could
support
a
drinking
water
supply.
If
a
community
derives
its
drinking
water
from
a
large
river,
the
estimated
exposure
would
likely
be
higher
than
the
actual
exposure.
Conversely,
a
community
that
derives
its
drinking
water
from
smaller
bodies
of
water
with
minimal
outflow
would
likely
get
higher
drinking
water
exposure
than
estimated
using
the
index
reservoir.
Areas
with
a
more
humid
climate
that
use
a
similar
reservoir
and
cropping
patterns
would
likely
get
more
pesticides
in
their
drinking
water
than
predicted
levels.

A
single
steady
flow
has
been
used
to
represent
the
flow
through
the
reservoir.
Discharge
from
the
reservoir
also
removes
chemical
from
it
so
this
assumption
will
underestimate
removal
from
the
reservoir
during
wet
periods
and
overestimate
removal
during
dry
periods.
This
assumption
can
underestimate
or
overestimate
the
concentration
in
the
pond
depending
upon
the
annual
precipitation
pattern
at
the
site.
The
index
reservoir
scenario
uses
the
characteristic
of
a
single
soil
to
represent
the
soil
in
the
basin.
In
fact,
soils
can
vary
substantially
across
even
small
areas,
and
thus,
this
variation
is
not
reflected
in
these
simulations.
The
index
reservoir
scenario
does
not
consider
tile
drainage.
Areas
that
are
prone
to
substantial
runoff
are
often
tile
drained.
This
may
underestimate
exposure,
particularly
on
a
chronic
basis.
EXAMS
is
unable
to
easily
model
spring
and
fall
turnover
which
results
in
complete
mixing
of
the
chemical
through
the
water
column
at
these
times.
Because
of
this
inability,
Shipman
City
Lake
has
been
simulated
without
stratification.
There
is
data
to
suggest
that
Shipman
City
Lake
does
indeed
stratify
in
the
deepest
parts
of
the
lake
at
least
in
some
years.
This
may
result
in
both
over
and
underestimation
of
the
concentration
in
drinking
water
depending
upon
the
time
of
the
year
and
the
depth
the
drinking
water
intake
is
drawing
from.

Development
of
a
Percent
Crop
Area
(
PCA)
watershed­
based
adjustment
factor
for
the
percent
of
land
in
production
for
potatoes
has
not
been
performed.
The
SAP
recommended
against
the
use
of
the
PCA
for
`
minor'
crops
because
it
believed
that
the
scale
of
the
watershed
size
used
to
develop
the
PCA
(
8­
digit
HUC)
was
too
large
to
capture
each
drinking
water
watershed
and
the
resulting
PCAs
would
likely
be
highly
inaccurate
and
not
conservative
(
for
the
purpose
of
PCA
development,
potatoes
can
be
considered
a
minor
crop).
In
the
absence
of
a
crop
specific
PCA,
a
default
PCA
of
0.9
is
currently
being
used.
42
Tier
2
modeling
with
the
index
reservoir
and
the
PCA
is
intended
for
use
as
a
screen.
That
is,
the
estimate
should
be
higher
than
most
values
that
are
seen
in
areas
where
a
particular
crop
is
grown.
A
preliminary
assessment
comparing
monitoring
data
for
a
few
chemicals
to
estimates
made
using
these
methods
indicate
the
estimate
may
not
be
consistently
conservative.
However,
monitoring
data
at
drinking
water
facilities
is
sparsely
available
and
we
are
unable
to
check
the
validity
for
most
crops
against
monitoring
data
at
this
time.
