Office of Prevention, 			Pesticides, and

Toxic Substances

MEMORANDUM

Date:  January 17, 2007

SUBJECT:     Response to Ethofumesate RED Error Comments From Bayer
Cropscience   

                       (PC Code: 110601, DP Barcode: D296953)

FROM:          Lewis Ross Brown, Biologist

          Amer Al-Mudallal, Environmental Scientist

                      Nancy Andrews, Branch Chief

          Environmental Risk Branch I

          Environmental Fate and Effects Division (7507C)

TO:                Nathan Mottl, Chemical Review Manager

                      Special Review Branch I

                      Special Review and Registration Division (7508C)

EFED/ERB1 has reviewed the Ethofumesate RED Error Comments from Bayer
Cropscience.  The following errors are being corrected or addressed by
EFED:

Bayer Comments:

Bayer Comment E. Cover memorandum dated August 20, 2005 to Ethofumesate
Revised Environmental Fate and Effects Division Preliminary Risk
Assessment for the Ethofumesate Reregistration Eligibility Decision
Document (OPP-2004-0346-0022 and OPP-2004-0346-0023)

E1. On the 4th Page of Document E (pages are not numbered) it is stated
that

“No toxicity testing was performed for aquatic vascular plants.
Therefore,

additional data for aquatic vascular plants is needed to fully
understand the

effect of ethofumesate on aquatic systems (including indirect and
habitat

effects)”.

Aquatic plant toxicity study conduced with Lemna minor (OPPTS 850.4400):
submitted on 01/21/05 (MRID 46450701)

EFED Response:

This study has been reviewed by EFED/ERB1, categorized as
“Supplemental” based on its scientific data, and incorporated into
the RED during Public Comment Period.  

All other BCS registrant comments have been addressed in an agency
memorandum dated August 31, 2005 (DP Barcode: D296942).

 

