UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON D.C., 20460

OFFICE OF 

PREVENTION, PESTICIDES AND 

TOXIC SUBSTANCES

								

MEMORANDUM

Subject:	Napropamide: Justification for Environmental Fate and Effects
studies from Reregistration Eligibility Decision (RED) not included in
the DCI. 

		

From:		James Parker 

		Reregistration Branch 1

	Special Review and Registration Division

		

Date:		January 29, 2008

	     	

The purpose of this memo is to publicize the Agency’s rationale for
not including specific ecological studies in the Napropamide Data
Call-In, which were previously required in the Reregistration
Eligibility Decision (RED) document.  By electing to provide this
information to the public, the Agency hopes to continue to support clear
and transparent decision making practices.  

1.	850.1300 Freshwater invertebrate chronic toxicity - This study
requirement was fulfilled by an acceptable study (MRID No. 464787-04).

2.	850.1350 Estuarine/marine invertebrate chronic toxicity test - The
chronic freshwater invertebrate toxicity test was used to calculate a
chronic risk quotient (RQ) of 0.016, which is well below the
level-of-concern (LOC) of 1.  Thus, risk to estuarine/marine
invertebrates is unlikely.

3. 	850.1500 Fish Life Cycle Study - A supplemental, non-guideline
sub-chronic fish toxicity study resulted in a no-effect level more than
two orders of magnitude above the highest 60-day Estimated Environmental
Concentration (EEC).  Therefore the Agency does not anticipate that
napropamide exposure will lead to chronic risk to fish.

4. 	850.4400 Aquatic Plant Toxicity Test - A supplemental freshwater
algae study reports a NOEC of 5.05 ppm, which is much greater than the
highest acute EEC.  Hence, it appears unlikely that napropamide exposure
would lead to risk to aquatic plants (excluding endangered species).

