
1
U.
S.
ENVIRONMENTAL
PROTECTION
AGENCY
WASHINGTON,
DC
20460
OFFICE
OF
PREVENTION,
PESTICIDES
AND
TOXIC
SUBSTANCES
PC
code:
057001
DP
Barcode:
D329617
July
14,
2006
MEMORANDUM:

Subject:
Revised
Screening
Ecological
Risk
Assessment
for
the
Reregistration
of
MGK­
264
Insecticide
Synergist
To:
Cathryn
O'Connell,
RM
52
Special
Review
and
Reregistration
Division
From:
William
P.
Eckel,
Ph.
D.
Environmental
Fate
and
Effects
Division
Environmental
Risk
Branch
II
Thru:
Tom
Bailey,
Branch
Chief
Environmental
Fate
and
Effects
Division
Environmental
Risk
Branch
II
Attached
is
the
Environmental
Fate
and
Effects
Division's
(
EFED)
environmental
risk
assessment
for
the
reregistration
of
MGK­
264
as
a
synergist
for
pyrethrin
and
pyrethroid
insecticides
for
indoor/
outdoor
use.
The
chapter
has
been
revised
to
reflect
responses
to
public
comments,
and
also
to
reflect
a
reduced
maximum
outdoor
use
rate
of
0.3
lb
ai/
acre.

Major
Findings.
"
Listed"
(
endangered
and
threatened)
freshwater
fish
may
be
at
risk
of
mortality
when
twenty
weekly
applications
are
made
at
the
new
maximum
outdoor
use
rate
(
0.3
lb/
acre).
No
acute
Levels
of
Concern
are
exceeded
for
freshwater
fish
or
invertebrates
when
only
ten
weekly
applications
are
made.

Chronic
risks
(
decreased
pup
weight
gain)
in
mammals
are
possible.
The
dietary­
based
risk
quotient
for
twenty
weekly
applications
is
greater
than
0.42
(>
0.42)
under
default
assumptions
(
35­
day
half­
life),
for
animals
consuming
short­
grass
food
items.
The
dose­
based
risk
quotients
for
15­
g
and
35­
g
mammals
exceed
the
chronic
LOC
for
short
grass,
tall
grass,
and
broadleaf
plant/
small
insect
food
categories.
For
1000­
g
mammals,
the
chronic
LOC
is
exceeded
for
animals
consuming
short
grass
food
items
only.
The
dose­
based
RQ
values
range
up
to
3.6
for
15­
g
mammals
consuming
short
grass.
The
no­
effect
level
(
NOAEL)
for
decreased
pup
weight
gain
was
not
established,
so
the
calculated
risk
quotients
are
smaller
than
they
would
be
if
the
no­
effect
level
was
known.
2
Risks
to
estuarine/
marine
species,
and
terrestrial
and
aquatic
plants,
and
reproductive
effects
in
birds
could
not
be
quantitatively
assessed
due
to
lack
of
data.
However,
"
listed"
estuarine/
marine
organisms
are
presumed
to
be
at
acute
risk
due
to
the
exceedence
of
the
Level
of
Concern
in
freshwater
fish
after
twenty
(
20)
weekly
applications.
Likewise,
birds
are
presumed
to
be
at
risk
of
reproductive
effects,
based
on
the
exceedence
of
the
Level
of
Concern
in
mammals.

A
major
uncertainty
in
this
assessment
is
the
lack
of
information
on
frequency
and
timing
of
application
of
MGK­
264.
The
Master
Label
appears
to
allow
daily
application.
A
conservative
assessment
would
therefore
assume
application
on
365
days
every
year.
For
the
purposes
of
this
assessment,
it
has
been
assumed
that
application
is
done
weekly,
and
1
through
20
applications
are
made
(
for
aquatic
exposure
using
PRZM­
EXAMS,
or
for
Hoerger­
Kenaga
terrestrial
exposure
analysis).

Environmental
Fate.
MGK­
264
has
the
molecular
formula
C17H25NO2
and
molecular
weight
275.38.
It
is
a
liquid
at
room
temperature
and
is
slightly
soluble
in
deionized
water
(
15
mg/
L).
The
log
octanol­
water
partition
coefficient
(
Log
Kow)
is
3.70.
Its
vapor
pressure
is
9.5
x
10­
5
mm
Hg
at
25
oC
and
2
mm
Hg
at
150
oC,
which
puts
it
in
the
semi­
volatile
range.
The
estimated
Henry's
Law
constant
is
2.85
x
10­
7
atm­
m3/
mole
at
25
oC.

MGK­
264
is
stable
to
hydrolysis,
direct
aqueous
photolysis,
and
soil
photolysis.
Aerobic
and
anaerobic
soil
metabolism
are
very
slow
(
mean
aerobic
half­
life
was
341
days).
MGK­
264
was
moderately
mobile
in
sand
and
sandy
loam
soils
(
Koc
=
636
in
sand)
and
slightly
mobile
in
silt
loam
and
clay
loam
soils
(
Koc
=
3106
in
clay
loam).
Adsorption
increased
with
increasing
organic
matter
content,
as
expected
for
a
neutral
organic
molecule.
MGK­
264
aerosols
in
air
are
expected
to
be
rapidly
degraded
(
half­
life
~
1.4
hr)
by
reaction
with
ozone
and
hydroxyl
radical
based
on
structure­
activity
relationships.
Free
radical
reactions
may
also
degrade
MGK­
264
in
natural
waters.

The
physical
properties
and
fate
characteristics
of
MGK­
264
indicate
that
it
is
a
persistent
compound,
and
that
it
will
be
moderately
mobile
in
coarse
soils
(
sand
and
sandy
loam).
MGK­
264
is
slightly
mobile
in
clay
soils,
which
may
serve
as
a
sink.
MGK­
264
may
partition
to
particulate
matter
in
water.
Volatilization
from
soil
or
water
is
not
expected
to
be
important.
MGK­
264
is
expected
to
be
an
aerosol
rather
than
in
the
gas
phase
(
as
a
result
of
spraying).
The
expected
half­
life
in
air
is
short,
so
long­
range
transport
is
not
expected.
The
combined
persistence
and
mobility
may
result
in
MGK­
264
being
found
in
surface
and
ground
water.
The
log
Kow
value
of
3.70
indicates
a
potential
for
bioconcentration
in
aquatic
organisms.

Labeling
Requirements.
Technical
MGK­
264
should
have
a
standard
label
warning
of
its
toxicity
to
fish
and
invertebrates.
Additional
label
warnings
on
end­
use
products
are
not
required
at
this
time,
and
will
likely
depend
on
the
toxicity
characteristics
of
the
co­
formulated
active
ingredients.

Data
Needs.
Our
understanding
of
the
exposure
of
aquatic
and
estuarine/
marine
organisms
would
be
improved
by
submission
of
data
on
aerobic
aquatic
metabolism
(
guideline
162­
4),
anaerobic
aquatic
metabolism
(
guideline
162­
3),
and
indirect
aqueous
photolysis.
These
three
studies
would
allow
refinement
of
the
modeled
aquatic
EECs,
and
possibly
remove
the
presumption
of
risk
to
aquatic
and
estuarine/
marine
organisms.
3
Potential
ecological
risks
would
be
clarified
by
submission
of
acute
toxicity
data
on
estuarine/
marine
fish,
invertebrates,
and
mollusks
(
guideline
72­
3).
Presently,
we
presume
that
there
is
a
risk
to
estuarine/
marine
species
because
of
the
presumed
risk
to
freshwater
species
after
twenty
(
20)
applications.
The
guideline
72­
3
studies
will
either
confirm
or
deny
the
presumption
of
risk.

The
measured
log
Kow
value
(
3.70)
indicates
a
potential
for
bioaccumulation
in
fish.
Since
we
expect
fish
to
be
exposed
to
MGK­
264,
a
fish
bioaccumulation
study
(
guideline
165­
4
)
would
indicate
if
there
is
any
potential
for
food­
chain
effects
in
fish
consumers.

The
exposure
of
birds
and
mammals
would
be
better
understood
if
data
on
the
dissipation
of
total
foliar
residues
(
guideline
132­
1a)
were
submitted.
Due
to
lack
of
this
data,
a
default
half­
life
of
35
days
on
foliage
has
been
assumed.
A
measured
foliar
dissipation
rate,
if
shorter
than
35
days,
might
remove
the
presumption
of
chronic
risk
to
mammals.

The
potential
chronic
risks
to
birds
would
be
clearer
if
a
study
on
avian
reproductive
effects
(
guideline
71­
4)
was
submitted.
Presently,
we
presume
a
chronic
risk
to
birds
because
the
chronic
RQ
for
mammals
exceeds
the
Level
of
Concern.
The
avian
reproduction
study
would
allow
confirmation
or
removal
of
the
presumption
of
risk
to
birds.

Endocrine
Disruption.
HED
has
concluded
that
MGK­
264
shows
no
evidence
of
being
an
endocrine
disruptor.

Endangered
Species.
Federally­
listed
(
endangered
and
threatened)
freshwater
aquatic
organisms
may
be
at
acute
risk
from
exposure
to
contaminated
water
bodies
receiving
run­
off
and
spray
drift
from
MGK­
264
treated
sites
(
after
twenty
weekly
applications).
Listed
mammals
are
also
at
chronic
risk
of
reproductive
effects
if
present
in
treated
areas.
We
presume
that
estuarine/
marine
organisms
may
also
be
at
acute
risk,
based
on
the
identified
risk
to
freshwater
organisms.
We
also
presume
that
birds
may
be
at
risk
of
reproductive
effects,
based
on
the
identified
risk
to
mammals.

EFED
cannot
determine
which
species
might
be
affected,
because
EFED's
endangered
species
data
base
(
LOCATES)
is
based
on
co­
occurrence
of
the
species
with
agricultural
crops
by
county.
Non­
agricultural
use
sites
such
as
lawns
and
ornamental
plants
have
not
been
specifically
associated
with
any
listed
species.
Because
the
lawn
and
ornamental
plants
use
pattern
may
be
geographically
widespread,
exposure
of
listed
species
cannot
be
ruled
out.

To
be
meaningful,
an
endangered
species
assessment
for
MGK­
264
would
have
to
consider
simultaneous
exposure
to
the
insecticides
it
is
used
to
synergize,
including
pyrethrins,
and
pyrethroids,
as
well
as
the
co­
synergist
piperonyl
butoxide.
4
Table
of
Contents
Page
1.
Problem
Formulation
5
1.1.
Source
and
Exposure
Characteristics
5
1.2.
Exposure
Pathways
6
1.3
Analysis
Plan
6
1.3.1.
a.
Terrestrial
Organisms
6
1.3.1.
b.
Aquatic
Organisms
7
1.3.1.
c.
Presumption
of
Risk
1.3.2
Ecological
Effects
and
Assessment
Endpoints
7
1.3.3.
Assessment
Endpoints
9
1.3.3.
a.
Aquatic
Organisms
9
1.3.3.
b.
Terrestrial
Organisms
9
1.3.4.
Conceptual
Model
9
2.
Exposure
and
Effects
Analysis
11
2.1
Environmental
Fate
Assessment
11
2.2.
Exposure
Analysis
11
2.2.1
Food
Residues
11
2.2.2
Exposure
Analysis
(
Aquatic
Ecosystems)
11
2.3.
Ecological
Response
Analysis
14
2.4.
Stressor­
Response
Profile
15
2.4.1.
Fish
and
Invertebrates
15
2.4.2.
Birds
15
2.4.3.
Mammals
15
3.
Risk
Characterization
16
3.1.
Risk
Estimation
16
3.1.1.
Terrestrial
Ecosystems
16
3.1.2.
Aquatic
Ecosystems
16
3.2.
Risk
Description
17
3.2.1
Endocrine
Disruption
18
3.3
Endangered
Species
18
4.
References
20
Appendices
21
5
1.
Problem
Formulation
1.1.
Source
and
Exposure
Characteristics.

MGK­
264
or
N­(
2­
ethylhexyl)­
5­
norbornene­
2,3­
dicarboximide
(
Figure
1)
is
an
insecticide
synergist.
Synergists
are
chemicals
that
lack
pesticidal
effects
of
their
own
but
enhance
the
pesticidal
properties
of
other
chemicals.
MGK­
264
is
usually
formulated
with
natural
pyrethrins,
piperonyl
butoxide
(
PBO),
or
synthetic
pyrethroids
and
is
an
ingredient
in
numerous
registered
pest
control
products.
It
has
numerous
and
varied
commercial
and
residential
applications,
is
available
in
a
broad
range
of
formulations,
and
is
applied
by
wide
variety
of
application
methods.
Commercial
uses
include
application
to
non­
food
plants,
applications
in
food
and
non­
food
handling
commercial
and
agricultural
structures
and
outdoor
premises,
housing
for
veterinary
use,
and
direct
application
to
non­
food
animals.
MGK­
264
is
not
used
on
animals
intended
for
human
consumption.
In
addition,
MGK­
264
is
currently
registered
for
use
in/
on
all
food
items
in
food
handling
establishments
where
food
and
food
products
are
held,
processed,
or
prepared
to
control
nuisance
and
food
product
contaminating
insects
such
as
ants,
cockroaches,
fleas
and
ticks.
Residentially,
it
is
used
to
control
insects
both
inside
the
home,
and
outside
on
gardens,
lawns
and
ornamentals,
patios,
and
other
outdoor
structures,
and
is
directly
applied
to
pets.
As
a
synergist,
it
inhibits
the
mixed
function
oxidase
system
of
insects
and
reduces
the
oxidative
breakdown
of
other
pesticides
like
pyrethrum
and
synthetic
pyrethroids.
Comprehensive
information
on
use
patterns
and
formulations
is
provided
in
the
MGK­
264
Master
Label
(
C.
Rodia,
Use
Closure
Memo,
11/
17/
03)
which
was
submitted
to
the
EPA
by
MGK
Company.
This
risk
assessment
for
MGK­
264
is
based
on
the
Master
Label,
as
modified
by
EPA
responses
to
public
comments
(
C.
O'Connor,
SRRD,
personal
communication
6/
6/
06),
and
a
maximum
label
rate
reduction
from
2.2
to
0.3
lb
ai/
acre.

According
to
information
submitted
by
the
registrant,
most
of
the
use
of
MGK­
264
is
for
indoor/
residential
insect
control
(
ant
&
roach,
crack
&
crevice,
flying
insect
killer,
personal
insect
repellent,
total
release
aerosol,
wasp
&
hornet,
fog),
direct
application
to
animals
(
barn,
horse,
pet,
poultry),
veterinary
uses,
and
disease
vector
control.

While
any
of
these
uses
may
result
in
some
release
to
the
environment,
the
outdoor
application
to
lawns
and
ornamental
plants
is
the
most
likeliest
to
result
in
exposure
of
non­
target
organisms.
6
Figure
1.
Structure
of
MGK­
264
1.2.
Exposure
Pathways.

Outdoor
ground
applications
of
MGK­
264
may
result
in
residues
at
the
use
site
that
terrestrial
organisms
can
ingest,
inhale
or
touch
(
i.
e.,
dermal
exposure).
The
Master
Label
(
Table
2)
does
not
list
any
aerial
application
equipment;
therefore
aerial
application
will
not
be
considered
in
this
assessment.
Additionally,
MGK­
264
may
reach
offsite
terrestrial
or
aquatic
systems
through
spray
drift
during
application
or
from
surface
water
run­
off.
Indirect
exposure
through
the
food
chain
may
potentially
occur
in
both
the
terrestrial
and
aquatic
ecosystem.

1.3.
Analysis
Plan.

Risks
to
terrestrial
and
aquatic
organisms
will
be
assessed
as
described
below.
Applications
were
assumed
to
occur
either
once,
or
numerous
times
at
weekly
intervals,
since
the
Master
Label
only
limits
applications
to
no
more
than
daily.
The
risk
assessment
will
focus
on
the
toxic
effects
of
MGK­
264
alone,
rather
than
any
effects
caused
by
its
synergistic
interaction
with
other
active
ingredients
(
except
where
only
mixture
toxicity
data
is
available).
Such
effects
are
best
addressed
by
an
assessment
of
the
formulated
products
of
the
other
active
ingredients.

1.3.1.
a.
Terrestrial
Organisms.
Onsite
exposure
of
non­
target
birds
and
mammals
to
MGK­
264
via
ingestion
will
be
assessed
by
assuming
100%
of
their
diet
is
obtained
from
onsite
sources
using
the
Hoerger­
Kenaga
nomogram
for
estimating
residues
on
plants,
seeds,
insects,
and
other
food
items
and
the
T­
REX
version
1.2.3
tool
(
USEPA
2005).
Offsite
non­
target
bird
and
mammal
exposures
to
plant
and
insect
residues
will
not
be
quantitatively
evaluated
in
this
screening
assessment
because
onsite
plant
and
insect
residue
levels
will
be
higher
than
offsite
residue
levels.
Because
100%
of
the
diet
is
assumed
to
come
from
onsite
sources,
and
incidental
soil
ingestion
in
contrast
represents
a
minor
exposure
component,
incidental
soil
ingestion
will
not
be
quantitatively
evaluated.
For
the
scenario
considered,
acute
and
chronic
risk
quotient
C
H
3
C
H
3
N
O
C
H
2
O
7
(
RQ)
values
will
be
calculated
by
dividing
estimated
exposure
concentrations
(
EECs)
by
the
most
sensitive
toxicity
endpoints
for
acute
exposure
(
median
lethal
dose,
LD50)
and
chronic
exposure
(
no­
observed­
adverse­
effect­
level,
NOAEL),
respectively.
Due
to
lack
of
foliar
dissipation
data,
a
default
half­
life
of
35
days
will
be
used
in
calculating
EECs.
The
observed
stability
of
MGK­
264
in
laboratory
fate
experiments
supports
the
35­
day
assumption.
The
RQ
values
will
then
be
compared
to
standard
Levels
of
Concern
(
LOCs).

1.3.1.
b.
Aquatic
Organisms.
EECs
of
MGK­
264
in
an
aquatic
system
due
to
run­
off
and
spray
drift
from
a
ground
application
to
lawn
or
ornamentals,
the
uses
most
likely
to
result
in
the
highest
aquatic
EECs,
will
be
modeled
using
PRZM­
EXAMS.
These
modeled
exposure
concentrations
will
then
be
divided
by
the
most
sensitive
of
96­
h
LC50
values
for
fish
and
96­
hr
LC50
or
EC50
(
or
48­
h
EC50
for
daphnids)
for
aquatic
invertebrates,
to
calculate
acute
RQs.
No
chronic
data
for
fish
or
aquatic
invertebrates
exist
so
chronic
risks
can
not
be
assessed.
Additionally,
acute
and
chronic
risks
to
estuarine/
marine
fish
and
invertebrates
could
not
be
assessed
because
no
acute
or
chronic
toxicity
studies
for
these
organisms
were
submitted
by
the
registrant,
and
none
were
found
in
the
open
literature
(
ECOTOX
2004).

The
PRZM­
EXAMS
analysis
will
represent
the
combined
exposure
in
the
EFED
standard
surface
water
model
due
to
run­
off
and
1%
spray
drift
from
ground
application.
The
Florida
and
Pennsylvania
PRZM
turf
scenarios
will
be
used
to
represent
the
effect
of
application
to
turf,
lawns,
and
ornamental
plants.

1.3.1.
c.
Presumption
of
Risk.
RQ
values
will
be
compared
to
standard
Levels
of
Concern
(
LOCs).
LOCs
are
the
Agency's
interpretative
policy
and
are
used
to
analyze
potential
risk
to
non­
target
organisms
and
the
need
to
consider
regulatory
action.
If
model
calculations
show
that
exposures
will
produce
RQ
values
that
exceed
the
LOCs
for
endangered
or
nonendangered
species,
then
modeling
refinements
or
alternative
application
rates/
scenarios
may
be
investigated
to
determine
if
there
are
alternative
application
rates
or
methods
that
do
not
result
in
unacceptable
adverse
effects
for
these
non­
target
species.

1.3.2.
Ecological
Effects
and
Assessment
Endpoints.

Assessment
endpoints
are
defined
as
"
explicit
expressions
of
the
actual
environmental
value
that
is
to
be
protected."
Defining
an
assessment
endpoint
involves
two
steps:
1)
identifying
the
valued
attributes
of
the
environment
that
are
considered
to
be
at
risk,
and
2)
operationally
defining
the
assessment
endpoint
in
terms
of
an
ecological
entity
(
e.
g.,
a
community
of
fish
and
aquatic
invertebrates)
and
its
attributes
(
i.
e.,
survival
and
reproduction).
Therefore,
selection
of
the
assessment
endpoints
is
based
on
valued
entities
(
i.
e.,
ecological
receptors),
the
ecosystems
potentially
at
risk,
the
migration
pathways
of
pesticides,
and
the
routes
by
which
ecological
receptors
are
exposed
to
pesticide­
related
contamination.
The
selection
of
clearly
defined
assessment
endpoints
is
important
because
they
provide
direction
and
boundaries
in
the
risk
assessment
for
addressing
risk
management
issues
of
concern.

Ecosystems
potentially
at
risk
are
expressed
in
terms
of
the
broad
taxa
(
e.
g.,
birds,
mammals,
fish)
selected
as
assessment
endpoints.
The
typical
attributes
for
screening­
level
pesticide
ecological
risks
are
survival,
reproduction
and
growth
for
both
aquatic
and
terrestrial
animal
species.
Aquatic
animal
species
of
potential
concern
include
freshwater
fish
and
invertebrates,
estuarine/
marine
fish
and
invertebrates,
and
amphibians.
Terrestrial
animal
species
of
potential
concern
include
birds,
mammals,
and
beneficial
insects.
In
order
to
protect
threatened
and
endangered
species,
all
endpoints
are
measured
at
the
individual
level.
Although
all
endpoints
are
measured
at
the
individual
level,
they
provide
insight
about
risks
at
higher
8
levels
of
biological
organization
(
e.
g.
populations
and
communities).
For
example,
pesticide
effects
on
individual
survivorship
have
important
implications
for
both
population
rates
of
increase
and
habitat
carrying
capacity.

For
terrestrial
and
semi­
aquatic
plants,
the
screening
assessment
endpoint
is
the
perpetuation
of
populations
of
non­
target
species
(
crops
and
non­
crop
plant
species).
Existing
testing
requirements
have
the
capacity
to
evaluate
emergence
of
seedlings
and
vegetative
vigor.
Although
it
is
recognized
that
the
endpoints
of
seedling
emergence
and
vegetative
vigor
may
not
address
all
terrestrial
and
semi­
aquatic
plant
life
cycle
components,
it
is
assumed
that
impacts
at
emergence
and
in
active
growth
have
the
potential
to
impact
individual
competitive
ability
and
reproductive
success.

For
aquatic
plants,
the
assessment
endpoint
is
the
maintenance
and
growth
of
standing
crop
or
biomass.
Measurement
endpoints
for
this
assessment
endpoint
focus
on
algal
and
vascular
plant
(
i.
e.,
duckweed)
growth
rates
and
biomass
measurements.

The
ecological
relevance
of
selecting
the
above­
mentioned
assessment
endpoints
is
as
follows:
1)
complete
exposure
pathways
exist
for
these
receptors;
2)
the
receptors
may
be
potentially
sensitive
to
pesticides
in
affected
media
and
in
residues
on
plants,
seeds,
and
insects;
and
3)
the
receptors
could
potentially
inhabit
areas
where
pesticides
are
applied,
or
areas
where
runoff
and/
or
spray
drift
may
impact
the
sites
because
suitable
habitat
is
available.

Each
assessment
endpoint
requires
one
or
more
"
measures
of
ecological
effect,"
which
are
defined
as
changes
in
the
attributes
of
an
assessment
endpoint
itself
or
changes
in
a
surrogate
entity
or
attribute
in
response
to
exposure
to
a
pesticide.
Ecological
measurement
endpoints
for
the
screening
level
risk
assessment
are
based
at
a
minimum
on
a
suite
of
registrant­
submitted
toxicity
studies
performed
on
a
limited
number
of
organisms
in
the
following
broad
groupings:

°
Birds
(
mallard
duck
and
bobwhite
quail
acute
oral,
dietary
and
reproductionguideline
tests)
which
are
also
used
as
surrogates
for
terrestrial­
phase
amphibians
and
reptiles,
°
Mammals
(
laboratory
rat
acute
and
reproductive
guideline
tests),
°
Freshwater
Fish
(
bluegill
sunfish
and
rainbow
trout
acute
and
early
life
stage
guideline
tests)
which
are
also
used
as
a
surrogate
for
aquatic
phase
amphibians,
°
Freshwater
invertebrates
(
Daphnia
magna
acute
and
reproduction
guideline
tests),
°
Estuarine/
marine
fish
(
Sheepshead
Minnow
or
silversides
acute
or
early
life
stage
guideline
tests),
°
Estuarine/
marine
invertebrates
(
Crassostrea
virginica
shell
deposition
or
embryo/
larval
development
and
Americamysis
bahia,
gammarid
amphipods,
or
penaeid
shrimp
acute
and
reproduction
guideline
tests),
°
Terrestrial
plants
(
corn,
onion,
ryegrass,
wheat,
buckwheat,
cucumber,
soybean,
sunflower,
tomato,
and
turnip
vegetative
vigor
and
seedling
emergence
guideline
tests),
and
°
Algae
and
aquatic
plants
(
Lemna
gibba
and
Selenastrum
capricornutum).

Within
each
of
these
very
broad
taxonomic
groups,
the
most
sensitive
acute
and
chronic
endpoint
is
selected
from
the
available
test
data,
as
the
data
sets
allow.

The
risk
assessment
will
focus
on
the
toxic
effects
of
MGK­
264
alone,
rather
than
any
effects
caused
by
its
synergistic
interaction
with
other
active
ingredients
(
except
where
only
mixture
toxicity
data
is
available).
Such
effects
are
best
addressed
by
an
assessment
of
the
9
formulated
products
of
the
other
active
ingredients.
The
risk
assessment
will
be
limited
to
organisms
for
which
we
have
toxicity
data
(
as
described
below).
Risk
presumptions
may
be
extended
to
similar
organisms
(
e.
g.,
estuarine/
marine
organisms
may
be
presumed
to
be
at
risk
if
freshwater
aquatic
organisms
are
at
risk).

1.3.3.
Assessment
Endpoints.

1.3.3.
a.
Aquatic
Organisms.

Based
on
the
available
data
and
the
ecosystems
believed
to
be
at
risk,
the
assessment
endpoint
is
death
of
the
endangered
or
non­
endangered
non­
target
organism
(
fish
or
invertebrate).
The
stressor
is
exposure
to
MGK­
264
alone.
Chronic
risks
to
fish
or
invertebrates
cannot
be
assessed
due
to
lack
of
toxicity
data.
Risks
to
benthic
organisms
also
cannot
be
assessed
due
to
lack
of
data.

1.3.3.
b.
Terrestrial
Organisms.

Because
MGK­
264
was
practically
non­
toxic
to
the
mallard,
bob­
white
quail
and
laboratory
rat,
and
no
deaths
were
observed
even
at
the
highest
doses
tested,
we
presume
that
there
is
no
acute
risk
to
birds
or
mammals.
Based
on
the
chronic
data
for
the
rat,
the
assessment
endpoint
is
decreased
pup
weight
gain.
This
effect
may
lead
to
adverse
outcomes
such
as
reduced
survival
of
young
animals.

1.3.4.
Conceptual
Model.

The
conceptual
model
(
Figure
2)
diagrams
the
relationships
between
the
stressor
and
the
ecological
entities
potentially
exposed.
It
should
be
noted
that
these
entities
are
likely
exposed
to
other
chemical
and
environmental
stressors
(
e.
g.,
habitat
loss)
as
well,
but
only
the
effects
of
the
pesticide
are
considered
in
this
assessment.
Based
on
the
foregoing
discussion,
the
conceptual
model
for
exposure
of
non­
target
fish
and
invertebrates
involves
ground
application
of
MGK­
264
(
stressor)
to
a
terrestrial
site
(
lawn
or
ornamental
plants)
resulting
in
spray
drift
or
run­
off
to
the
aquatic
ecosystem.
The
non­
target
aquatic
organisms
are
then
exposed
to
MGK­
264
in
the
water
column.
Exposure
to
the
stressor
in
sufficient
concentration
may
result
in
death
of
the
non­
target
fish
or
invertebrates
or
reproductive
impairment.

Exposure
of
birds
and
mammals
in
terrestrial
environments
is
expected
to
primarily
be
via
consumption
of
spray­
contaminated
food
items
(
foliage,
seeds,
insects,
etc.).
Exposure
in
sufficient
concentration
is
expected
to
lead
to
mortality
and
decreased
reproductive
success.
10
Figure
2.
Conceptual
Model
for
Ground
Applications
of
MGK­
264
to
Lawn
and
Ornamental
Plants
Source:
Ground
application
to
lawn
and
ornamental
plant

Stressor:
MGK­
264TM
(
synergist)


Offsite
Potential
Exposure
Pathways:
­
surface
water
run­
off
and
spray
drift
Onsite
Potential
Exposure
Pathway:
Foliage
deposits
Non­
target
Receptors:
freshwater
fish,
estuarine/
marine
fish,
freshwater
invertebrates,
estuarine/
marine
invertebrates,
aquatic
and
terrestrial
plants
Non­
target
receptors:
Birds,
mammals,
beneficial
insects,
other
terrestrial
invertebrates
Measurement
Endpoints:
acute
and
chronic
(
reproductive)
effects
on
birds,
reptiles,
terrestrial
phase­
amphibians
and
mammals;
acute
and
chronic
effects
on
aquatic
organisms
11
2.
Exposure
and
Effects
Analysis
2.1
Environmental
Fate
Assessment
MGK­
264
has
the
molecular
formula
C17H25NO2
and
molecular
weight
275.38.
It
is
a
liquid
at
room
temperature
and
is
slightly
soluble
in
deionized
water
(
15
mg/
L).
The
log
octanolwater
partition
coefficient
(
Log
Kow)
is
3.70
(
SRC
PhysProp
database).
Its
vapor
pressure
is
9.5
x
10­
5
mm
Hg
at
25
oC
and
2
mm
Hg
at
150
oC,
which
puts
it
in
the
semi­
volatile
range
(
The
normal
boiling
point
estimated
by
the
MPBPWIN
v1.40
program
in
EPISuite
was
443
oC).
The
estimated
Henry's
Law
constant
is
2.85
x
10­
7
atm­
m3/
mole
at
25
oC
(
SRC
PhysProp
database).
Appendix
A
provides
a
summary
and
evaluation
of
Subdivision
N
fate
guideline
studies
submitted
by
the
registrant.
The
following
environmental
fate
assessment
and
the
inputs
used
for
terrestrial
exposure
and
aquatic
exposure
models
are
based
on
results
from
these
studies.

MGK­
264
is
stable
to
hydrolysis,
direct
aqueous
photolysis,
and
soil
photolysis.
Aerobic
and
anaerobic
soil
metabolism
are
very
slow
(
mean
aerobic
half­
life
was
341
days).
MGK­
264
was
moderately
mobile
in
sand
and
sandy
loam
soils
(
Koc
=
636
in
sand)
and
slightly
mobile
in
silt
loam
and
clay
loam
soils
(
Koc
=
3106
in
clay
loam).
Adsorption
increased
with
increasing
organic
matter
content,
as
expected
for
a
neutral
organic
molecule.
MGK­
264
aerosols
in
air
are
expected
to
be
rapidly
degraded
(
half­
life
~
1.4
hr)
by
reaction
with
ozone
and
hydroxyl
radical
based
on
structure­
activity
relationships
(
Hazardous
Substances
Data
Bank
monograph
for
MGK­
264,
found
at
toxnet.
nlm.
nih.
gov).
Free
radical
reactions
may
also
degrade
MGK­
264
in
natural
waters.

The
physical
properties
and
fate
characteristics
of
MGK­
264
indicate
that
it
is
a
persistent
compound,
and
that
it
will
be
mobile
in
coarse
soils
(
sand
and
sandy
loam).
MGK­
264
is
immobile
in
clay
soils,
which
may
serve
as
a
sink.
MGK­
264
may
partition
to
particulate
matter
in
water.
Volatilization
from
soil
or
water
is
not
expected
to
be
important.
MGK­
264
is
expected
to
be
an
aerosol
rather
than
in
the
gas
phase
(
as
a
result
of
spraying).
The
expected
half­
life
in
air
is
short,
so
long­
range
transport
is
not
expected.
The
combined
persistence
and
mobility
may
result
in
MGK­
264
being
found
in
surface
and
ground
water.
The
Log
Kow
value
of
3.70
(
SRC
PhysProp
Database)
indicates
a
potential
for
bioconcentration
in
aquatic
organisms,
although
the
fish
bioaccumulation
study
has
previously
been
waived.
This
study
is
now
being
requested.

2.2.
Exposure
Analysis.
The
following
sections
describe
the
quantitative
assessment
of
exposure
for
terrestrial
and
aquatic
organisms
as
outlined
in
the
Analysis
Plan.

2.2.1.
Food
Residues.

Hoerger
and
Kenaga
(
1972)
as
modified
by
Fletcher
et
al.
(
1994)
empirically
derived
residue
concentrations
on
avian
and
mammalian
dietary
food
items
immediately
following
application
of
any
pesticide
at
1
pound
of
active
ingredient
per
acre
(
lb
ai/
A).
These
EECs
are
given
in
Table
1.
12
Table
1.
EECs
on
Avian
and
Mammalian
Food
Items
for
a
1
lb
ai/
A
Application
of
Any
Pesticide
Food
Item
EEC
(
ppm)
Predicted
Maximum
Residue
(
1)
EEC
(
ppm)
Predicted
Mean
Residue
(
1)
Short
grass
240
85
Tall
grass
110
36
Broad­
leaved/
forage
plants,
and
small
insects
135
45
Fruits,
pods,
seeds,
and
large
insects
15
7
Specific
residue
levels
for
MGK­
264
uses
and
exposure
of
birds
and
mammals
were
modeled
with
the
T­
REX
model
(
USEPA
2005),
which
adjusts
the
Hoerger­
Kenaga
nomogram
exposure
for
the
MGK­
264
application
rate,
adjusts
toxicity
results
based
on
allometric
body
relationships
and
calculates
RQs.
It
was
assumed
that
MGK­
264
was
applied
once
at
the
maximum
outdoor
use
rate
(
0.3
lb
ai/
acre).
One,
two,
three,
10
and
20
weekly
applications
were
modeled
because
there
was
no
label
limit
for
number
of
applications.
The
default
assumption
for
the
decay
rate
on
foliage
(
35­
day
half­
life)
was
used.
This
assumption
is
supported
by
the
observed
stability
of
MGK­
264
in
laboratory
fate
experiments.
Table
2
gives
the
predicted
maximum
residues
of
MGK­
264
that
are
expected
to
occur
on
selected
avian
or
mammalian
dietary
food
items.

Table
2.
Maximum
EECs
on
Avian
and
Mammalian
Food
Items
for
MGK­
264
Application
at
the
Maximum
Outdoor
Use
Rate
(
0.3
lb
ai/
acre)
No.
of
applications
Short
Grass
(
ppm)
Tall
Grass
(
ppm)
Broad­
leaved
/
forage
plants,
small
insects
(
ppm)
Fruits/
pods/
seeds/
large
insects
(
ppm)
1
72
33
41
4.5
2
135
62
76
8.4
3
189
87
106
12
10
417
191
235
26
20
521
239
283
33
2.2.2.
Exposure
Analysis
(
Aquatic
Ecosystems).

Exposure
due
to
terrestrial
application
(
lawns
and
ornamental
plants)
was
assessed
using
the
standard
farm
pond
scenario
in
the
PRZM­
EXAMS
models.
The
Pennsylvania
and
Florida
turf
scenarios
were
used
to
represent
use
on
turf
or
ornamental
plants
in
the
northeast
and
southeast,
respectively.
All
exposure
analyses
were
done
at
maximum
application
rates
with
assumed
intervals
and
number
of
applications.

The
following
input
parameters
(
Table
3)
were
used
for
the
linked
PRZM
and
EXAMS
models.
The
values
were
selected
in
accordance
with
the
EFED
Input
Parameter
Guidance
dated
February
28,
2002.
The
Pennsylvania
and
Florida
turf
scenarios
were
chosen
to
represent
use
on
lawns
and
ornamental
plants.
The
standard
surface
water
scenario
was
used.
13
Table
3.
PRZM­
EXAMS
Input
Parameters
Input
Parameter
Value
Reference/
Comment
Application
Rate
(
max.)
0.3
lb
ai/
acre
Post­
RED
negotiation
with
registrant
Application
Interval
7
days
Assumed:
Master
Label
allows
daily
application
Number
of
Applications
1,
2,
3,
10,
20
Because
Master
Label
does
not
limit
number
of
applications
assessed
a
number
of
alternatives
Organic
Carbon
Partition
Coefficient
(
Koc)
899
mL/
g
MRID
426225­
01,
426225­
02
(
used
lowest
non­
sand
Koc;
studies
ranged
from
636
to
3106
mL/
g)
Solubility
in
Water
150
mg/
L
EFED
Input
parameter
Guidance
(
Feb.
28
2002)
requires
use
of
10x
solubility
(
15
mg/
L)
in
PRZMEXAMS
modeling
Soil
Metabolism
Half­
Life
430
days
MRID
431945­
01
(
90th
percentile
upper
bound,
per
Input
Parameter
Guidance,
on
values
of
294
and
388
days)
Benthic
Metabolism
Half­
Life
Stable
No
data
Aquatic
Metabolism
Half­
Life
860
days
No
study
submitted:
value
is
2x
soil
metabolism
half­
life
input
value
Hydrolysis
Half­
Life
Stable
MRID
422226­
01,
423550­
01
Aqueous
Photolysis
Half­
Life
Stable
MRID
422226­
02,
423550­
02
Molecular
Weight
(
g/
mole)
275.39
From
molecular
formula
Henry's
Law
Constant
2.85
E­
7
atm­
m3/
mol
Calculated
from
vapor
pressure
and
solubility
Vapor
Pressure
1.8
E­
5
torr
From
EPISuite
experimental
database
Chemical
Application
Method
(
CAM)
2
Implies
linear
foliar
application
based
on
crop
canopy
Incorporation
Depth
0
cm
Assumed
no
incorporation;
no
information
on
Master
Label
Application
Efficiency
0.99
Value
for
ground
application
Spray
Drift
Fraction
0.01
Value
for
ground
application
Application
Date
April
1
Assumed:
no
information
on
Master
Label
The
results
of
the
PRZM­
EXAMS
modeling
are
given
in
Table
4.
These
water­
column
concentrations
will
be
used
as
the
measures
of
exposure
for
aquatic
organisms
such
as
fish
and
invertebrates.
The
Florida
peak
EECs
(
4
to
77
ppb)
were
slightly
higher
than
the
Pennsylvania
EECs
(
2.7
to
70
ppb),
depending
on
the
number
of
applications.
The
differences
are
likely
due
to
environmental
factors
(
soil
and
rainfall)
encoded
in
the
scenarios.
14
Table
4.
PRZM­
EXAMS
Results
(
EECs)
for
Surface
Water
Scenario
(
in
ppb)
No.
of
applications
Peak
96­
hour
21­
days
60­
days
90­
days
Yearly
Avg.
of
Yearly
Florida
Turf
Scenario
1
4.0
4.0
3.8
3.5
3.5
3.1
2.5
2
8.0
7.9
7.5
7.0
6.9
6.2
4.9
3
11.9
11.7
11.1
10.5
10.2
9.3
7.4
10
41.2
40.7
39.2
37.0
36.3
32.1
25.9
20
77.3
76.2
74.0
71.2
70.3
63.2
53.7
Pennsylvania
Turf
Scenario
1
2.7
2.6
2.5
2.4
2.3
2.2
1.6
2
5.4
5.3
5.2
4.9
4.9
4.6
3.3
3
8.4
8.3
8.0
7.7
7.7
7.2
5.1
10
32.6
32.4
31.3
29.5
29.1
26.4
19.7
20
70.4
69.7
67.5
64.4
63.0
58.2
43.1
2.3.
Ecological
Response
Analysis.

Appendix
B
summarizes
and
evaluates
the
registrant
submitted
ecotoxicity
studies.
The
following
effects
analysis
and
selection
of
endpoints
for
use
in
the
screeing
analysis
are
based
on
these
studies.
The
registrant
has
submitted
the
basic
freshwater
acute
fish
and
daphnid
toxicity
studies
but
no
data
for
estuarine/
marine
species.
Two
bird
subacute
dietary
toxicity
studies
and
acute
oral
toxicity
studies
were
provided.
No
aquatic
or
avian
chronic
studies
were
conducted.
Both
rat
acute
oral
and
multi­
generation
reproduction
studies
from
HED
are
also
listed.
The
toxicity
values
selected
for
use
in
calculating
RQs,
their
toxicity
categories,
and
MRIDs
are
provided
in
Table
5.

Table
5.
Acute
MGK­
264
Toxicities
to
Fish,
Daphnids,
and
Birds,
and
Acute
and
Chronic
Toxicity
to
Mammals
Taxonomic
Group
Animal
(
guideline)
Toxicity
Endpoint
Effect
Toxcity
Category
MRID
and
Classification
Freshwater
fish
Rainbow
Trout
(
72­
1)
96­
h
LC50
=
1.4
ppm
Mortality
Moderately
toxic
41911501
Core
Bluegill
Sunfish
(
72­
1)
96­
h
LC50
=
2.4
ppm
Mortality
Moderately
toxic
41819701
Core
Freshwater
invertebrate
Daphnid
(
72­
2)
48­
h
EC50
=
2.3
ppm
Immobilization
(
as
surrogate
for
mortality)
Moderately
toxic
41526102
Core
Bird
(
dietary)
Bobwhite
Quail
(
71­
2a)
5­
day
LC50
>
5620
ppm
(
no
deaths)
Practically
nontoxic
41687301
Core
Mallard
Duck
(
71­
2b)
5­
day
LC50
>
5620
ppm
(
no
deaths)
Practically
nontoxic
41526102
Core
Bird
(
acute
oral)
Bobwhite
Quail
Single
dose
LD50
>
2250
mg/
kg­
bw
(
no
deaths)
Practically
nontoxic
41821501
Core
Mallard
Duck
Single
dose
LD50
>
2250
mg/
kg­
bw
(
no
deaths)
Practically
nontoxic
41821502
Core
Mammal
Rat
(
acute)
LD50
>
20,000
mg/
kg­
bw*
(
no
deaths)
Practically
nontoxic
42155701
Core
Rat
(
chronic)
LOAEL
=
1250
mg/
kg­
diet**
(
most
sensitive
reproduction
endpoint
was
reduced
body
weight
gain
in
pups)
­­
41752305
*
Contains
multiple
active
ingredients
**
The
lowest
concentration
tested
15
2.4.
Stressor­
Response
Profile
2.4.1
Fish
and
Invertebrates.
The
available
studies
show
that
MGK­
264
is
moderately
toxic
to
rainbow
trout,
bluegill
sunfish,
and
daphnids
(
LC50
and
EC50
values
ranged
from
1.4
to
2.4
ppm).

2.4.2.
Birds.
MGK­
264
is
practically
nontoxic
to
bobwhite
quail
and
mallard
duck
on
an
acute
basis
(
single
dose
LD50s
>
2250
mg/
kg­
bw)
and
dietary
basis
(
5­
day
LC50s
>
5620
ppm).
No
mortality
was
observed
at
any
dose
level,
thus
there
is
no
toxicity
endpoint
with
which
to
conduct
a
risk
assessment.

2.4.3.
Mammals.
MGK­
264
is
practically
nontoxic
on
an
acute
basis
to
the
laboratory
rat
(
LD50
>
20,000
mg/
kg
body
weight
or
400,000
ppm
in
diet).
No
mortality
was
observed
at
any
dose
level,
thus
there
is
no
toxicity
endpoint
with
which
to
conduct
an
acute
risk
assessment.

The
multi­
generation
reproduction
study
yielded
a
LOAEL
of
1250
mg/
kg
diet,
with
an
endpoint
of
reduced
body
weight
gain
in
the
pups.
A
NOAEL
was
not
observed
in
the
study.
16
3.
Risk
Characterization
3.1
Risk
Estimation.

3.1.1.
Terrestrial
Ecosystems.

Chronic
risk
quotients
for
mammals
(
as
represented
by
rats)
are
given
in
Table
6a
and
6b.
The
RQ
values
are
based
on
a
value
of
<
62.5
mg/
kg
body
weight
since
the
chronic
LOAEL
value
for
rats
was
1250
mg/
kg
diet
and
no
NOAEL
was
observed
(
see
Table
5),
and
the
maximum
estimated
exposure
concentrations
given
in
Table
2.
The
Level
of
Concern
(
dietary­
based
RQ
=
1.0)
is
not
exceeded
for
any
number
of
applications,
however
chronic
(
reproductive)
risk
in
mammals
cannot
be
precluded
because
a
no­
effect
level
(
NOAEL)
was
not
obtained
experimentally.
The
dose­
based
RQ
values
for
20
applications,
however,
exceeded
the
LOC
for
15­
g
and
35­
g
mammals
(
short
grass,
tall
grass
and
broadleaf
plant/
small
insects
foods)
and
1000­
g
mammals
(
short
grass).
Until
a
definitive
NOAEL
is
established,
there
is
a
presumption
of
reproductive
risk
to
mammals.

Table
6a.
Dietary­
Based
Chronic
Risk
Quotients
for
Mammals
(
Rat)
(
Assessment
Endpoint:
Reduced
Weight
Gain
in
Pups)
Diets
Frequency
of
Applications
(
1250
mg/
kg
diet)
1
2
3
10
20
Short
grass
>
0.06
>
0.11
>
0.15
>
0.33
>
0.42
Tall
grass
>
0.03
>
0.05
>
0.07
>
0.15
>
0.19
Broadleaf
plants/
sm
insects
>
0.03
>
0.06
>
0.09
>
0.19
>
0.23
Fruits/
pod/
lg
insects
>
0.00
>
0.01
>
0.01
>
0.02
>
0.03
Note:
Bold
RQ
indicates
that
the
chronic
Level
of
Concern
(
RQ
=
1)
is
exceeded
.

Table
6b.
Dose­
Based
Risk
Quotients
for
15­
g,
35­
g
and
1000­
g
Mammals
(
20
applications)

Diets
15­
gram
35­
gram
1000­
gram
Short
grass
>
3.6
>
3.1
>
1.7
Tall
grass
>
1.7
>
1.4
>
0.8
Broadleaf
plants/
sm
insects
>
2.0
>
1.7
>
0.9
Fruits/
pod/
lg
insects
>
0.23
>
0.19
>
0.1
Note:
Bold
RQ
indicates
that
the
chronic
Level
of
Concern
(
RQ
=
1)
is
exceeded
.

3.1.2.
Aquatic
Ecosystems.

RQs
for
freshwater
fish
(
as
represented
by
the
rainbow
trout
and
bluegill
sunfish)
and
freshwater
invertebrates
(
as
represented
by
Daphnia
magna)
are
given
in
Table
7.
The
RQ
values
are
based
on
the
LC50
and
EC50
values
given
in
Table
5
and
the
peak
estimated
exposure
concentrations
given
in
Table
4.
17
Table
7.
Acute
Risk
Quotients
for
Freshwater
Organisms
(
Assessment
Endpoint:
Death
or
Immobilization)
Test
Species
1
appl.
2
appl.
3
appl.
10
appl.
20
appl.
PRAM­
EXAMS
Florida
Turf
Scenario
rainbow
trout
<
0.05
<
0.05
<
0.05
<
0.05
0.055
bluegill
sunfish
<
0.05
<
0.05
<
0.05
<
0.05
<
0.05
Daphnia
<
0.05
<
0.05
<
0.05
<
0.05
<
0.05
PRZM­
EXAMS
Pennsylvania
Turf
Scenario
rainbow
trout
<
0.05
<
0.05
<
0.05
<
0.05
0.050
bluegill
sunfish
<
0.05
<
0.05
<
0.05
<
0.05
<
0.05
Daphnia
<
0.05
<
0.05
<
0.05
<
0.05
<
0.05
Note:
Bold
RQs
exceed
endangered
species
Level
of
Concern.

No
acute
aquatic
LOC
(
RQ
=
0.5)
is
exceeded
for
rainbow
trout,
bluegill
sunfish,
and
daphnid
at
up
to
20
applications
of
MGK­
264.
Endangered
("
listed")
species
LOC
(
RQ
=
0.05)
is
exceeded
only
for
rainbow
trout
with
>
10
applications
(
Florida)
or
>
10
applications
(
Pennsylvania).

3.2.
Risk
Description.

MGK­
264
is
a
synergist
for
pyrethrin,
and
pyrethroid
insecticides.
It
is
often
used
in
combination
with
another
synergist,
piperonyl
butoxide.
This
enables
the
same
degree
of
insect
pest
control
to
be
achieved
with
a
lower
application
rate
of
the
synergized
insecticide.

In
this
assessment,
a
revised
maximum
application
rate
of
0.3
lbs
a.
i./
A
for
lawn
insect
control
is
used.
Because
of
nonspecific
application
instructions
on
the
label
(
apply
whenever
it
is
necessary)
an
arbitrary
application
frequency
of
up
to
20
applications
at
7­
day
intervals
for
lawn
and
ornamental
scenarios
is
used.
The
assumptions
of
a
seven­
day
application
interval
and
the
number
of
applications
are
both
arbitrary,
and
a
major
source
of
uncertainty
in
the
assessment.

Only
outdoor
uses
of
MGK­
264
were
assessed
in
this
document,
because
indoor
uses
are
considered
unlikely
to
result
in
exposures
to
wildlife.
However,
the
large
majority
of
MGK­
264
use
in
indoors.
Thus,
the
risks
described
here
should
be
considered
in
that
light.

The
risks
deemed
to
be
of
concern
in
this
assessment
include
acute
toxicity
(
death,
or
immobilization
followed
by
predation)
in
"
listed"
freshwater
fish
and
invertebrates
(
assuming
20
weekly
applications),
and
chronic
toxicity
(
reduced
weight
gain
of
pups)
in
mammals.
By
extension,
we
would
expect
adverse
acute
effects
in
"
listed"
estuarine/
marine
animals,
and
adverse
reproductive
effects
in
birds
because
of
the
effects
seen
in
freshwater
fish
and
mammals,
respectively.

The
presumption
of
acute
risk
to
"
listed"
freshwater
and
estuarine/
marine
organisms
could
be
removed
if
the
number
of
applications
was
limited
to
10
(
ten)
with
an
interval
of
7
days.

Because
MGK­
264
is
never
used
alone,
its
adverse
effects
must
be
considered
in
light
of
the
other
active
ingredients
used.
Generally
speaking,
MGK­
264
is
less
toxic
to
the
species
of
concern
for
pyrethrins
and
pyrethroids
(
aquatic
invertebrates).
However,
the
effect
of
MGK­
264
(
blocking
de­
toxifying
enzymes
in
invertebrates)
makes
a
given
dose
of
pyrethrin/
pyrethroid
more
toxic.
This
synergistic
effect,
by
the
same
token,
allows
less
pyrethrin/
pyrethroid
to
be
used
to
achieve
a
desired
level
of
insect
pest
control.
Thus,
should
the
MGK­
264
and
18
pyrethrin/
pyrethroid
become
separated
by
fate
processes
(
such
as
their
widely
different
solubilities),
then
the
lower
amount
of
pyrethrin/
pyrethroid
used
may
cause
fewer
adverse
effects.
If,
however,
invertebrates
are
exposed
to
both
active
ingredients
(
MGK­
264
and
pyrethrin/
pyrethroid)
simultaneously,
then
there
is
a
potential
for
greater
adverse
effects
than
if
exposure
was
to
the
pyrethrin/
pyrethroid
alone.
This
might
occur
also
if
the
pyrethroid
or
pyrethrin
is
present
in
the
sediment
of
a
water
body,
and
MGK­
264
is
introduced
into
the
system
at
a
later
time.

The
synergistic
effect
of
MGK­
264
combined
with
the
synthetic
pyrethroids
deltamethrin
and
fenvalerate
on
the
aquatic
snail
Lymnaea
acuminata
was
studied.
The
results
show
significant
decreases
in
the
LC10,
LC50,
and
LC90
values
of
both
pyrethroids.
With
a
1:
5
mixture
of
pyrethroid
+
MGK­
264,
the
synergist
ratios
for
LC50
at
48
hrs
were
25x
and
6.13x
for
deltamethrin
and
fenvalerate,
respectively
(
Sahay
and
Agarwal,
1997).
In
a
separate
experiment,
the
synergist
effect
of
MGK­
264
on
fenvalerate­
resistant
German
cockroaches
was
studied.
The
results
showed
that
MGK­
264
reduced
the
fenvalerate
LC50
resistance
ratio
by
55­
fold
from
the
original
825­
fold
level
(
Danxia
Wu
et
al.
1998).
These
studies
illustrate
the
increase
in
toxicity
that
may
be
expected
from
simultaneous
exposure
to
MGK­
264
and
representative
pyrethroid
insecticides.

Terrestrial
mammals
may
be
risk
of
reduced
pup
weight
gain
application
of
MGK­
264
to
food
items.
This
is
uncertain
because
the
no­
effect
level
for
this
toxic
endpoint
is
not
known.
The
risk
quotients
given
in
Tables
6a
and
6b
are
minimums
because
they
were
calculated
using
a
lowest­
adverse
effect
level
(
LOAEL).
Low
weight
gain
in
pups
may
lead
to
a
lower
survival
rate.
This
may
result
in
food
chain
disruptions,
with
lower
populations
of
the
affected
mammals
for
predators,
and
overpopulation
of
animals
or
plants
that
the
affected
mammal
consumes.

This
assessment
has
considered
exposure
to
MGK­
264
itself,
and
not
to
any
possible
degradates.
While
eight
degradates
were
noted
in
the
aerobic
soil
metabolism
study,
at
up
to
15%
or
the
applied
radiation,
none
of
them
were
specifically
identified
by
chemical
formula
or
structure.
It
is
likely
that
reaction
would
occur
at
the
double
bond
of
the
norbornene
ring
(
epoxidation)
or
that
there
would
be
a
ring
opening
of
the
carboximide
ring.

3.2.1.
Endocrine
Disruption.
The
Health
Effects
Division
has
determined
that
MGK­
264
has
no
apparent
effects
on
the
endocrine
system.

3.3.
Endangered
Species
3.3.1
Direct
Effects
Federally­
listed
(
endangered
and
threatened)
freshwater
fish
may
be
at
acute
risk
from
exposure
to
contaminated
water
bodies
receiving
run­
off
and
spray
drift
from
MGK­
264
treated
sites
after
twenty
weekly
applications.
.
We
presume
that
estuarine/
marine
organisms
may
also
be
at
acute
risk,
based
on
the
identified
risk
to
freshwater
organisms.

Listed
mammals
may
be
at
chronic
risk
of
reproductive
effects
if
present
in
treated
areas
We
presume
that
birds
may
be
at
risk
of
reproductive
effects,
based
on
the
identified
risk
to
mammals.

EFED
has
no
data
on
the
toxicity
to
insects
of
MGK­
264
by
itself.
There
are
no
registered
products
that
contain
only
MGK­
264
as
an
active
ingredient,
because
of
its
use
as
a
synergist
for
other
insecticides.
Thus,
we
are
unable
to
determine
if
there
are
potential
direct
effects
on
Listed
insect
species,
where
MGK­
264
is
the
sole
stressor.
19
EFED
cannot
determine
which
species
might
be
exposed,
because
EFED's
endangered
species
data
bases
are
based
on
co­
occurrence
of
the
species
with
agricultural
crops
by
county.
Because
the
lawn
and
ornamental
plants
use
pattern
may
be
geographically
widespread,
exposure
of
listed
species
cannot
be
ruled
out.

3.3.2
Indirect
Effects
Based
on
the
potential
direct
effects,
taxa
reliant
on
freshwater
or
estuarine
fish,
birds
or
mammals,
may
be
at
indirect
risk
of
adverse
effects.

To
be
meaningful,
an
endangered
species
assessment
for
MGK­
264
would
have
to
consider
simultaneous
exposure
to
the
insecticides
it
is
used
to
synergize,
including
pyrethrins,
pyrethroids,
and
the
co­
synergist
piperonyl
butoxide.
20
4.
References
Danxia
Wu
et
al.,
1998,
Pesticide
Biochemistry
and
Physiology
61,
pp.
53­
62.

EFED
Input
Parameter
Guidance,
February
28,
2002.

EFED
interim
standard
Rice
Paddy
Model
(
10/
29/
2002)

Fletcher,
J.
S.,
J.
E.
Nellesson
and
T.
G.
Pfleeger.
1994.
Literature
review
and
evaluation
of
the
EPA
food­
chain
(
Kenaga)
nomogram,
an
instrument
for
estimating
pesticide
residues
on
plants.
Environ.
Tox.
And
Chem.
13(
9):
1383­
1391.

Hazardous
Substances
Data
Bank
monograph
for
MGK­
264.
National
Library
of
Medicine.
(
toxnet.
nlm.
nih.
gov)

Hoerger,
F.
D.
and
E.
E.
Kenaga.
1972.
Pesticide
residues
on
plants:
Correlation
of
representative
data
as
a
basis
for
estimation
of
their
magnitude
in
the
environment.
in,
Environmental
Quality.
F.
Coulston
and
F.
Korte,
Eds.
Academic
Press,
New
York.
Vol.
I,
pp.
9­
28.

Master
Label
for
MGK­
264
(
4/
21/
2003),
30
pp.

MPBPWIN
v1.40
program
in
EPISuite
program.
Syracuse
Research
Corporation
(
http://
www.
epa.
gov/
oppt/
exposure/
docs/
episuitedl.
htm)

Sahay,
N.
and
R.
A.
Agarwal,
1997,
Chemosphere,
Vol.
35,
No.
5,
pp.
1011­
1021.

Syracuse
Research
Corporation
(
SRC)
PhysProp
Database.
(
http://
www.
syrres.
com/
esc/
physprop.
htm)

United
States
Environmental
Protection
Agency
(
USEPA).
2005.
User's
Guide,
T­
REX
Version
1.2.3
(
Terrestrial
Residue
Exposure
Model).
Environmental
Fate
and
Effects
Division,
Office
of
Pesticides
Program.
August
8.

Use
Closure
Memo,
11/
17/
03.
C.
Rodia,
USEPA
Office
of
Pesticide
Programs,
Special
Review
and
Reregistration
Division.
21
APPENDICES
Appendix
A:
Summary
of
Subdivision
N
Fate
Guideline
Studies
i.
Degradation
Hydrolysis
(
161­
1)

N­
Octyl
bicycloheptene
dicarboximide
was
stable
to
hydrolysis
in
pH
5,
7,
and
9
aqueous
buffer
solutions
that
were
incubated
in
darkness
at
25
oC
for
30
days.
MRID
42222601
Photolysis
in
Water
(
161­
2)

N­
Octyl
bicycloheptene
dicarboximide
was
stable
in
aqueous
buffered
pH
7
solutions
that
were
continuously
irradiated
with
a
xenon
arc
lamp
at
25
oC
for
30
days.
MRID
42222602
Photodegradation
on
Soil
(
161­
3)

MGK­
264
[
N­(
2­
ethylhexyl­
5­
norbornene­
2,3­
dicarboximide)]
photodegraded
slowly,
declining
from
98.39
to
80.14%
of
the
applied
on
sandy
loam
soil
during
31
days
(
737
hours)
of
irradiation
using
a
xenon
lamp
at
26
oC.
The
spectral
irradiance
and
intensity
of
the
xenon
lamp
was
similar
to
sunlight
at
wavelengths
between
290
and
750
nm.
In
the
dark
control
during
the
same
period,
MGK­
264
declined
from
an
average
98.39
to
86.13%
of
the
applied.
No
degradates
were
recovered
from
either
the
irradiated
or
dark
control
soils
at
>
1%
of
the
applied.
MRID
42807501
Aerobic
Soil
Metabolism
(
162­
1)

MGK­
264
[
N­(
2­
ethylhexyl­
5­
norbornene­
2,3­
dicarboximide)]
degraded
with
a
calculated
half­
life
of
388
days
in
sandy
loam
soil
that
was
treated
at
8.7­
9.6
µ
g/
g
with
MGK­
264
and
incubated
in
darkness
at
25
oC
and
70­
75%
of
field
moisture
capacity
for
365
days.
Eight
degradates,
each
at
maximums
of
1.1­
15.3%
of
the
applied
(
0.09­
1.46
µ
g/
g),
were
isolated
from
the
soil
but
were
not
identified.
At
365
days
posttreatment,
uncharacterized
volatile
residues
totaled
7­
12%
of
the
applied
(
0.6­
1.2
µ
g/
g),
and
CO2
totaled
0.3­
0.7%
(
0.03­
0.07
µ
g/
g).
MRID
43194501
Anaerobic
Soil
Metabolism
(
162­
2)

MGK­
264
[
N­(
2­
ethylhexyl­
5­
norbornene­
2,3­
dicarboximide)]
declined
from
8.05
to
6.91
µ
g/
g
during
60
days
of
anaerobic
(
flooded
plus
nitrogen
atmosphere)
incubation
in
sandy
loam
soil
that
was
treated
with
MGK­
264
at
9­
10
µ
g/
g
and
incubated
under
anaerobic
conditions
in
darkness
at
25
oC
for
60
days
following
30
days
of
aerobic
incubation.
Four
degradates,
each
at
maximums
of
0.40­
8.6%
of
the
applied
(
0.04­
0.88
µ
g/
g),
were
isolated
from
the
floodwater
and
soil
but
were
not
identified.
At
90
days
posttreatment,
uncharacterized
volatile
residues
collected
in
ethylene
glycol
trapping
solutions
totaled
3.7­
5.2%
of
the
applied
(
0.3­
0.5
µ
g/
g),
and
CO2
totaled
<
0.01%.
MRID
43194502
Anaerobic
Aquatic
Metabolism
(
162­
3)

Waived
2/
4/
1994.

Aerobic
Aquatic
Metabolism
(
162­
4)

Waived
2/
4/
1994.

Terrestrial
Field
Dissipation
(
164­
1)

Waiver
requested
(
date).

Long­
Term
Soil
Dissipation
(
164­
5)

Waived
2/
4/
1994.
22
ii.
Mobility
Leaching
and
Adsorption/
Desorption
(
163­
1)

MGK­
264
was
very
mobile
to
moderately
mobile
in
sand
and
sandy
loam
soils
and
relatively
immobile
in
silt
loam
and
clay
loam
soils.
Freundlich
Kads
values
were
1.6
for
the
Tiffany
sand
soil
(
0.5
%
OM),
2.7
for
the
San
Joaquin
sandy
loam
(
0.5
%
OM),
5.4
for
the
Anthony
sandy
loam
soil
(
0.7
%
OM),
20
for
the
Dundee
clay
loam
soil
(
1.3
%
OM),
and
33
for
the
Gardena
silt
loam
soil
(
4.2
%
OM).
Adsorption
increased
with
increasing
soil
organic
matter
content.
Freundlich
Kdes
values
ranged
from
9.1
to
10.2
for
the
above
soils.
Kocads
values
were
636
for
Tiffany
sand,
899
for
San
Joaquin
sandy
loam,
1,555
for
Anthony
sandy
loam,
1,588
for
Gardena
silt
loam,
and
3,106
for
Dundee
clay
loam
soil.
Kocdes
values
were
4,099
for
Tiffany
sand,
3,049
for
San
Joaquin
sandy
loam,
2,797
for
Anthony
sandy
loam,
441
for
Gardena
silt
loam,
and
1,419
for
Dundee
clay
loam
soil.
MRID
42622501
Aged
Leaching­
Adsorption­
Desorption
(
163­
1)

Reserved.

Fish
Bioaccumulation
(
165­
4)

Waived
2/
4/
1994.
23
Appendix
B.
Summary
of
Ecotoxicity
Data
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
MGK­
264
to
birds.
The
preferred
test
species
is
either
mallard
duck
(
a
waterfowl)
or
bobwhite
quail
(
an
upland
gamebird).
The
registrant
submitted
one
study
of
each
(
MRID
418215­
01,
418215­
02)
and
because
both
satisfied
guideline
testing
requirements,
the
guideline
71­
1
requirement
is
fulfilled.
Results
of
these
tests
are
tabulated
below.

Avian
Acute
Oral
Toxicity
Species
%
ai
LD50
(
mg/
kg­
bw)
Toxicity
Category
MRID
No.
Author/
Year
Study
classification
(
1)

Northern
bobwhite
quail
(
Colinus
virginianus)
93.1
>
2250
(
no
mortality
at
any
treatment
level)
Practically
nontoxic
418215­
01
Campbell
1991
Acceptable
Mallard
duck
(
Anas
platyrhynchos)
92.9
>
2250
(
no
mortality
at
any
treatment
level)
Practically
nontoxic
418215­
02
Campbell
1991
Acceptable
(
1)
Acceptable
(
study
satisfies
guideline).
Supplemental
(
study
is
scientifically
sound,
but
does
not
satisfy
guideline)

Since
the
acute
oral
LD50
values
are
greater
than
2250
mg/
kg­
bw,
MGK­
264
is
classified
as
practically
non­
toxic
to
avian
species
on
an
acute
oral
basis.

Two
subacute
dietary
studies
using
the
TGAI
are
required
to
establish
the
toxicity
of
MGK­
264
to
birds.
The
preferred
test
species
are
mallard
duck
and
bobwhite
quail.
The
registrant
submitted
one
study
of
each
(
MRID
416873­
01,
416873­
02)
and
because
both
satisfied
guideline
testing
requirements,
the
guideline
71­
2
requirement
is
fulfilled.
Results
of
these
tests
are
tabulated
below.

Avian
Subacute
Dietary
Toxicity
Species
%
ai
5­
Day
LC50
(
ppm)
(
1)
Toxicity
Category
MRID
No.
Author/
Year
Study
Classification
(
2)

Northern
bobwhite
quail
(
Colinus
virginianus)
92.9
>
5620
(
no
mortality
at
any
treatment
level)
Practically
nontoxic
416873­
01
Campbell
1990
Acceptable
Mallard
duck
(
Anas
platyrhynchos)
92.9
>
5620
(
no
mortality
at
any
treatment
level)
Practically
nontoxic
416873­
02
Campbell
1990
Acceptable
1)
Test
organisms
observed
an
additional
three
days
while
on
untreated
feed.
(
2)
Acceptable
(
study
satisfies
guideline).
Supplemental
(
study
is
scientifically
sound,
but
does
not
satisfy
guideline)

Since
the
5­
day
LC50
values
are
greater
than
5620
ppm,
MGK­
264
is
classified
as
practically
non­
toxic
to
avian
species
on
a
subacute
dietary
basis.
24
ii.
Birds,
Chronic
Because
MGK­
264
is
relatively
persistent
and
timing
of
use
may
coincide
with
all
portions
or
some
portions
of
reproduction
in
birds
reproductive
testing
in
at
least
one
bird
species
is
required.
No
study
was
submitted
by
the
registrant
and
none
were
found
in
ECOTOX.

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,
mouse,
rabbit,
or
dog
toxicity
values
obtained
from
the
Agency's
Health
Effects
Division
(
HED)
substitute
for
wild
mammal
testing.
Toxicity
studies
submitted
to
HED
and
their
values
are
reported
below.

Mammalian
Toxicity
Species/
Study
Duration
%
ai
Test
type
Toxicity
value
Affected
endpoints
MRID
No.

laboratory
rat
(
Rattus
norvegicus)
Formulated
product
(
mixed
ai)
Acute
oral
LD50
>
20
g/
kg
Mortality
417523­
05
Laboratory
rat
(
Rattus
norvegicus)
Multiple
generation
reproduction
study
NOEL
<
62.5
mg/
kg­
body
weight
Pup
weight
gain
421557­
01
The
results
indicate
that
MGK­
264
is
classified
as
Toxicity
Category
IV
chemical
to
small
mammals
on
an
acute
oral
basis.
Examination
of
HED's
DER
on
the
rat
multiple­
generation
reproductive
study
(
MRID
41752305
)
provides
details
on
MGK­
264
dietary
effects
on
F1
and
F2
reproductive,
offspring
survival,
and
pup
body
weight
parameters.
These
are
summarized
below.

Reproductive
Effects
in
Laboratory
Rats
from
Chronic
Dietary
Exposure
to
MGK­
264
PARAMETER
SIGNIFICANT
DIETARY
LEVEL
F1
F2
Reproductive
Parameter
No.
mating
(
F0)
Fertility
index
Pregnancy
index
Gestation
index
Gestation
length
(
day)
No
effect
No
effect
Offspring
Survival
Total
no.
live
pups
No
effect
Mean
no.
live
pups/
litter
No
effect
Mean
no.
dead
pups/
litter
 
2500
ppm
Live
birth
index
(%)
10000
(
highest
dose)
Viability
index
(%)
No
effect
Lactate
index
(%)
No
effect
No
effect
Mean
pup
body
weight
(
g)
 
1250
ppm
(
lowest
dose)
 
1250
ppm
Although
the
mean
number
of
dead
pups
per
litter
was
significantly
different
from
the
control
at
 
2500
ppm,
there
is
no
dose­
response
relationship
established
(
there
was
no
effect
for
25
the
highest
dose
of
10,000
ppm).
For
the
live
birth
index
(%)
parameter
with
the
highest
dosage,
the
effect
is
significantly
different
from
the
second
control,
but
it
was
within
the
error
term
(
i.
e.,
less
than
the
difference
between
the
two
controls).
The
only
parameter
showing
constant
significant
effects
in
both
the
F1
and
F2
generations
was
the
mean
pup
body
weight
parameter.

iv.
Insects
A
honey
bee
acute
contact
study
using
the
TGAI
is
required
for
MGK­
264
because
its
use
(
lawn/
turf/
ornamental
plants)
will
result
in
honey
bee
exposure.
No
study
was
submitted.

b.
Toxicity
to
Freshwater
Aquatic
Animals
i.
Freshwater
Fish,
Acute
Two
freshwater
fish
toxicity
studies,
one
with
a
warmwater
and
one
with
a
coldwater
species,
using
the
TGAI
are
required
to
establish
the
toxicity
of
MGK­
264
to
fish.
The
preferred
test
species
are
rainbow
trout
(
a
coldwater
fish)
and
bluegill
sunfish
(
a
warmwater
fish).
The
registrant
submitted
one
study
of
each
(
MRID
419115­
01,
418197­
01)
and
because
both
satisfied
guideline
testing
requirements,
the
guideline
72­
1
requirement
is
fulfilled
Results
of
these
tests
are
tabulated
below.
Since
the
96­
h
LC50
values
fall
in
the
range
of
1.4
to
2.4
ppm,
MGK­
264
is
classified
as
moderately
toxic
to
freshwater
fish
on
an
acute
basis.

Freshwater
Fish
Acute
Toxicity
Species/
(
Flow­
through
or
Static)
%
ai
96­
hour
LC50
(
ppm))
Toxicity
category
MRID
No.
Author/
Year
Study
Classification(
1)

Rainbow
trout
(
Oncorhynchus
mykiss
static
92.9
1.4
Moderately
toxic
419115­
01
Bowman
1991
Acceptable
Bluegill
sunfish
(
Lepomis
macrochirus)
92.9
2.4
Moderately
toxic
418197­
01
Bowman
1991
Acceptable
(
1)
Acceptable
(
study
satisfies
guideline).
Supplemental
(
study
is
scientifically
sound,
but
does
not
satisfy
guideline)

Since
the
LC50
falls
in
the
range
of
1.4
to
2.4
ppm,
MGK­
264
is
moderately
toxic
to
freshwater
fish
on
an
acute
basis.
The
guideline
(
72­
1)
is
fulfilled
(
MRID
419115­
01,
418197­
01).

ii.
Freshwater
Fish,
Chronic
No
study
was
submitted
and
none
were
found
in
ECOTOX.

iii.
Freshwater
Invertebrates,
Acute
A
freshwater
aquatic
invertebrate
toxicity
test
using
the
TGAI
is
required
to
establish
the
toxicity
of
MGK­
264
to
aquatic
invertebrates.
The
preferred
test
species
is
Daphnia
magna.
Results
of
this
test
are
tabulated
below.

Freshwater
Invertebrate
Toxicity
Species/(
Static
or
Flow­
through)
%
ai
48­
hour
LC50/
EC50
(
ppm)
(
measured/
nomin
al)
Toxicity
Category
MRID
No.
Author/
Year
Study
Classification
26
Waterflea
(
Daphnia
magna)
92.9
2.3
Moderately
toxic
415261­
02
Bowman/
Bir
gess
1991
core
Since
theEC50
is
2.3
ppm,
MGK­
264
is
moderately
toxic
to
aquatic
invertebrates
on
an
acute
basis.
The
guideline
(
72­
2)
is
fulfilled
(
MRID
415261­
02
).

c.
Toxicity
to
Estuarine
and
Marine
Animals
No
study
was
submitted.
27
Appendix
C.
TREX
output
for
twenty
(
20)
applications
Acute
and
Chronic
RQs
are
based
on
the
Upper
Bound
Upper
Bound
Kenaga
Residues
For
RQ
Calculation
Kenaga
Residues.

Chemical
Name:
MGK­
264
The
maximum
single
day
residue
estimation
is
used
for
Use
Ornamentals
and
lawns
both
the
acute
and
reproduction
RQs.

Formulation
0
Application
Rate
0.3
lbs
a.
i./
acre
RQs
reported
as
"
0.00"
in
the
RQ
tables
below
should
be
noted
as
Half­
life
35
days
<
0.01
in
your
assessment.
This
is
due
to
rounding
and
significant
Application
Interval
7
days
figure
issues
in
Excel.

Maximum
#
Apps./
Year
20
Length
of
Simulation
1
year
Endpoints
Bobwhite
quail
LD50
(
mg/
kgbw
2250.00
Bobwhite
quail
LC50
(
mg/
kgdiet
5620.00
0
NOAEL(
m
g/
kg­
bw)
0.00
Avian
Bobwhite
quail
NOAEC
(
mg/
kgdiet
0.00
LD50
(
mg/
kg­
bw)
20000.00
LC50
(
mg/
kg­
diet)
0.00
NOAEL
(
mg/
kg­
bw)
62.50
Mammals
NOAEC
(
mg/
kg­
diet)
1250.00
Kenaga
Dietary­
based
EECs
(
ppm)
Values
Short
Grass
521.44
Tall
Grass
238.99
Broadleaf
plants/
sm
Insects
293.31
Fruits/
pods/
seeds/
lg
insects
32.59
Avian
Results
Avian
Body
Ingestion
(
Fdry)
Ingestion
(
Fwet)
%
body
wgt
FI
Class
Weight
(
g)
(
g
bw/
day)
(
g/
day)
consum
ed
(
kgdiet
day)

Small
20
5
23
114
2.28E­
02
Mid
100
13
65
65
6.49E­
02
Large
1000
58
291
29
2.91E­
01
28
Avian
Body
Adjusted
LD50
Weight
(
g)
(
mg/
kgbw
20
1620.97
100
2063.57
1000
2914.87
Avian
Classes
and
Body
Weights
small
mid
large
Dose­
based
EECs
(
mg/
kg­
bw)

20
g
100
g
1000
g
Short
Grass
593.87
338.65
151.62
Tall
Grass
272.19
155.21
69.49
Broadleaf
plants/
sm
Insects
334.05
190.49
85.28
Fruits/
pods/
seeds/
lg
insects
37.12
21.17
9.48
Avian
Acute
RQs
Dose­
based
RQs
(
Dose­
based
EEC/
adjusted
LD50)
20
g
100
g
1000
g
Short
Grass
0.37
0.16
0.05
Tall
Grass
0.17
0.08
0.02
Broadleaf
plants/
sm
insects
0.21
0.09
0.03
Fruits/
pods/
seeds/
lg
insects
0.02
0.01
0.00
RQs
Dietary­
based
RQs
(
Dietary­
based
EEC/
LC50
or
NOAEC)

Acute
Chronic
Short
Grass
0.09
#
DIV/
0!

Tall
Grass
0.04
#
DIV/
0!

Broadleaf
plants/
sm
Insects
0.05
#
DIV/
0!

Fruits/
pods/
seeds/
lg
insects
0.01
#
DIV/
0!

Note:
To
provide
risk
management
with
the
maximum
possible
information,
it
is
recommended
that
both
the
dosebased
and
concentration­
based
RQs
be
calculated
when
data
are
available
MGK­
264
Ornamental
s
and
lawns
Upper
bound
Kenaga
Residues
Mammalian
Results
Mammalian
Body
Ingestion
(
Fdry)
Ingestion
(
Fwet)
%
body
wgt
FI
29
Class
Weight
(
g
bwt/
day)
(
g/
day)
consum
ed
(
kgdiet
day)

15
3
14
95
1.43E­
02
Herbivores/
35
5
23
66
2.31E­
02
insectivores
1000
31
153
15
1.53E­
01
15
3
3
21
3.18E­
03
Grainvores
35
5
5
15
5.13E­
03
1000
31
34
3
3.40E­
02
Mammalian
Body
Adjusted
Adjusted
Class
Weight
LD50
NOAEL
15
43956.61
137.36
Herbivores/
35
35565.59
111.14
insectivores
1000
15383.21
48.07
15
43956.61
137.36
Grainvores
35
35565.59
111.14
1000
15383.21
48.07
Mammalian
Classes
and
Body
weight
Herbivores/
insectivores
Granivores
Dose­
Based
EECs
(
mg/
kg­
bw)
15
g
35
g
1000
g
15
g
35
g
1000
g
Short
Grass
497.15
343.60
79.66
Tall
Grass
227.86
157.48
36.51
Broadleaf
plants/
sm
Insects
279.65
193.27
44.81
Fruits/
pods/
seeds/
lg
insects
31.07
21.47
4.98
6.90
4.77
1.11
15
g
mammal
35
g
mammal
1000
g
mammal
Dose­
based
RQs
(
Dose­
based
EEC/
LD50
or
NOAEL)

Acute
Chronic
Acute
Chronic
Acute
Chronic
Short
Grass
0.01
3.62
0.01
3.09
0.01
1.66
Tall
Grass
0.01
1.66
0.00
1.42
0.00
0.76
Broadleaf
plants/
sm
insects
0.01
2.04
0.01
1.74
0.00
0.93
Fruits/
pods/
lg
insects
0.00
0.23
0.00
0.19
0.00
0.10
Seeds
(
granivore)
0.00
0.05
0.00
0.04
0.00
0.02
Mammal
RQs
Dietary­
based
RQs
(
Dietary­
based
EEC/
LC50
or
NOAEC)

Acute
Chronic
Short
Grass
#
DIV/
0!
0.42
Tall
Grass
#
DIV/
0!
0.19
Broadleaf
plants/
sm
insects
#
DIV/
0!
0.23
Fruits/
pods/
seeds/
lg
insects
#
DIV/
0!
0.03
Note:
To
provide
risk
management
with
the
maximum
possible
information,
it
is
recommended
that
both
the
dosebased
and
concentration­
based
RQs
be
calculated
when
data
are
available
30
MGK­
264
Ornamental
s
and
lawns
Upper
bound
Kenaga
Residues
Terrestrial
Residues
Graph
31
32
Appendix
D:
PRZM­
EXAMS
Oput
for
twenty
(
20)
applications
1.
Florida
Turf
stored
as
03lb20x.
out
Chemical:
MGK­
264
PRZM
environment:
FLturfC.
txt
modified
Monday,
16
June
2003
at
13:
48:
06
EXAMS
environment:
pond298.
exv
modified
Thuday,
29
August
2002
at
16:
33:
30
Metfile:
w12834.
dvf
modified
Wedday,
3
July
2002
at
09:
04:
28
Water
segment
concentrations
(
ppb)

Year
Peak
96
hr
21
Day60
Day90
DayYearly
1961
21.46
20.91
19.06
16.79
15.71
7.213
1962
29.09
28.51
27.4
26.1
26.17
18.77
1963
46.53
45.66
43.11
40.6
38.92
30.21
1964
62.82
61.99
59.31
55.86
54.63
43.12
1965
57.99
57.42
55.55
53.09
51.83
47.62
1966
77.33
76.22
72.08
70.07
68.1
54.71
1967
66.26
65.68
64.76
62.17
62.08
57.12
1968
76.6
76.18
74.18
71.31
70.44
62.48
1969
84.03
83.18
81.19
77.26
76.13
66.54
1970
70.19
70.12
69.64
68.65
67.94
62.84
1971
66.79
66.31
65.17
64.19
63.54
59.4
1972
81.22
80.3
77.01
72.27
71.63
62.92
1973
68.15
67.99
67.42
66.33
65.55
63.27
1974
69.34
68.89
67.25
66.49
65.56
60.28
1975
60.4
60.13
59.77
59.02
58.43
56.85
1976
66.91
66.27
64.22
61.17
59.73
56.41
1977
70.79
70.14
68.22
65.89
64.41
57.9
1978
66.84
66.35
64.61
62.51
62.13
58.73
1979
73.28
72.59
71.32
69.32
69.13
61.69
1980
63.01
62.93
62.64
61.96
61.38
58.85
1981
70.39
69.66
67.38
64.46
62.63
55.48
1982
69.17
68.54
66.95
66.1
65.39
59.29
1983
69.67
69.25
67.8
67.02
66.68
60.81
1984
70.75
70.2
68.51
67.17
66.27
63.4
1985
63.69
63.38
62.56
61.74
61.14
59.98
1986
75.21
74.43
72.79
68.79
67.05
59.35
1987
59.21
59.14
58.87
58.35
57.89
55.36
1988
53.39
53.12
52.18
51.24
50.83
49.68
1989
69.66
68.77
66.32
61.58
58.71
50.84
1990
54.7
54.57
54.08
53.17
52.64
50.57
Sorted
results
Prob.
Peak
96
hr
21
Day
60
Day
90
Day
Yearly
0.032258064516129
84.03
83.18
81.19
77.26
76.13
66.54
0.0645161290322581
81.22
80.3
77.01
72.27
71.63
63.4
0.0967741935483871
77.33
76.22
74.18
71.31
70.44
63.27
0.129032258064516
76.6
76.18
72.79
70.07
69.13
62.92
0.161290322580645
75.21
74.43
72.08
69.32
68.1
62.84
0.193548387096774
73.28
72.59
71.32
68.79
67.94
62.48
0.225806451612903
70.79
70.2
69.64
68.65
67.05
61.69
0.258064516129032
70.75
70.14
68.51
67.17
66.68
60.81
0.290322580645161
70.39
70.12
68.22
67.02
66.27
60.28
0.32258064516129
70.19
69.66
67.8
66.49
65.56
59.98
0.354838709677419
69.67
69.25
67.42
66.33
65.55
59.4
0.387096774193548
69.66
68.89
67.38
66.1
65.39
59.35
0.419354838709677
69.34
68.77
67.25
65.89
64.41
59.29
0.451612903225806
69.17
68.54
66.95
64.46
63.54
58.85
0.483870967741936
68.15
67.99
66.32
64.19
62.63
58.73
0.516129032258065
66.91
66.35
65.17
62.51
62.13
57.9
0.548387096774194
66.84
66.31
64.76
62.17
62.08
57.12
0.580645161290323
66.79
66.27
64.61
61.96
61.38
56.85
0.612903225806452
66.26
65.68
64.22
61.74
61.14
56.41
0.645161290322581
63.69
63.38
62.64
61.58
59.73
55.48
0.67741935483871
63.01
62.93
62.56
61.17
58.71
55.36
0.709677419354839
62.82
61.99
59.77
59.02
58.43
54.71
0.741935483870968
60.4
60.13
59.31
58.35
57.89
50.84
33
0.774193548387097
59.21
59.14
58.87
55.86
54.63
50.57
0.806451612903226
57.99
57.42
55.55
53.17
52.64
49.68
0.838709677419355
54.7
54.57
54.08
53.09
51.83
47.62
0.870967741935484
53.39
53.12
52.18
51.24
50.83
43.12
0.903225806451613
46.53
45.66
43.11
40.6
38.92
30.21
0.935483870967742
29.09
28.51
27.4
26.1
26.17
18.77
0.967741935483871
21.46
20.91
19.06
16.79
15.71
7.213
0.1
77.257
76.216
74.041
71.186
70.309
63.235
Average
of
yearly
averages:
53.7227666666667
Inputs
generated
by
pe4.
pl
­
8­
August­
2003
Data
used
for
this
run:
Output
File:
03lb20x
Metfile:
w12834.
dvf
PRZM
scenario:
FLturfC.
txt
EXAMS
environment
file:
pond298.
exv
Chemical
Name:
MGK­
264
Description
Variable
Name
Value
Units
Comments
Molecular
weight
mwt
275.39
g/
mol
Henry's
Law
Const.
henry
2.85e­
7
atm­
m^
3/
mol
Vapor
Pressure
vapr
1.8e­
5
torr
Solubility
sol
150
mg/
L
Kd
Kd
mg/
L
Koc
Koc
899
mg/
L
Photolysis
half­
life
kdp
0
days
Half­
life
Aerobic
Aquatic
Metabolism
kbacw
860
days
Halfife
Anaerobic
Aquatic
Metabolism
kbacs
0
days
Halfife
Aerobic
Soil
Metabolism
asm
430
days
Halfife
Hydrolysis:
pH
5
0
days
Half­
life
Hydrolysis:
pH
7
0
days
Half­
life
Hydrolysis:
pH
9
0
days
Half­
life
Method:
CAM
2
integer
See
PRZM
manual
Incorporation
Depth:
DEPI
0
cm
Application
Rate:
TAPP
0.336
kg/
ha
Application
Efficiency:
APPEFF
0.99
fraction
Spray
Drift
DRFT
0.01
fraction
of
application
rate
applied
to
pond
Application
Date
Date
01­
04
dd/
mm
or
dd/
mmm
or
dd­
mm
or
dd­
mmm
Interval
1
interval
7
days
Set
to
0
or
delete
line
for
single
app.
Interval
2
interval
7
days
Set
to
0
or
delete
line
for
single
app.
Interval
3
interval
7
days
Set
to
0
or
delete
line
for
single
app.
Interval
4
interval
7
days
Set
to
0
or
delete
line
for
single
app.
Interval
5
interval
7
days
Set
to
0
or
delete
line
for
single
app.
Interval
6
interval
7
days
Set
to
0
or
delete
line
for
single
app.
Interval
7
interval
7
days
Set
to
0
or
delete
line
for
single
app.
Interval
8
interval
7
days
Set
to
0
or
delete
line
for
single
app.
Interval
9
interval
7
days
Set
to
0
or
delete
line
for
single
app.
Interval
10
interval
7
days
Set
to
0
or
delete
line
for
single
app.
Interval
11
interval
7
days
Set
to
0
or
delete
line
for
single
app.
Interval
12
interval
7
days
Set
to
0
or
delete
line
for
single
app.
Interval
13
interval
7
days
Set
to
0
or
delete
line
for
single
app.
Interval
14
interval
7
days
Set
to
0
or
delete
line
for
single
app.
Interval
15
interval
7
days
Set
to
0
or
delete
line
for
single
app.
Interval
16
interval
7
days
Set
to
0
or
delete
line
for
single
app.
Interval
17
interval
7
days
Set
to
0
or
delete
line
for
single
app.
Interval
18
interval
7
days
Set
to
0
or
delete
line
for
single
app.
Interval
19
interval
7
days
Set
to
0
or
delete
line
for
single
app.
Record
17:
FILTRA
IPSCND
1
UPTKF
0
Record
18:
PLVKRT
0
PLDKRT
0
FEXTRC
0.5
Flag
for
Index
Res.
Run
IR
Pond
Flag
for
runoff
calc.
RUNOFF
none
none,
monthly
or
total(
average
of
entire
run)
34
2.
Pennsylvania
Turf
stored
as
03lb20x.
out
Chemical:
MGK­
264
PRZM
environment:
PAturfC.
txt
modified
Satday,
12
October
2002
at
16:
27:
02
EXAMS
environment:
pond298.
exv
modified
Thuday,
29
August
2002
at
16:
33:
30
Metfile:
w14737.
dvf
modified
Wedday,
3
July
2002
at
09:
06:
12
Water
segment
concentrations
(
ppb)

Year
Peak
96
hr
21
Day60
Day90
DayYearly
1961
15.52
15.05
13.63
11.94
10.94
4.887
1962
16.56
16.43
15.87
14.88
14.44
11.81
1963
23.91
23.54
22.76
21.58
21.43
16.14
1964
21.42
21.33
20.86
20.53
20.46
20.19
1965
22.42
22.37
22.13
21.59
21.46
21.1
1966
27.32
27.07
26.67
25.65
25.17
22.29
1967
35.66
35.19
34.38
33.13
32.46
27.77
1968
35.19
34.92
34.15
33
32.45
30.31
1969
52.88
52.1
49.3
44.99
43.07
34.24
1970
39.94
39.76
39.25
38.9
38.41
37.64
1971
54.82
54.19
52.66
50.69
49.71
41.96
1972
62.81
62.17
59.82
57.72
56.32
50.64
1973
64.88
64.4
62.56
59.96
59.6
56.18
1974
63.4
62.99
61.71
60.28
59.35
56.78
1975
57.95
57.65
56.57
55.65
54.88
53.9
1976
64.81
64.34
62.17
60.3
59.76
53.56
1977
56.35
56.34
56.29
56.22
55.93
53.3
1978
64.24
63.63
61.54
58.65
57.31
52.41
1979
62.41
61.97
60.56
58.67
57.7
53.93
1980
54.25
54.25
54.24
54.16
53.9
51
1981
49.13
49
48.94
48.76
48.32
46.35
1982
69.66
68.78
65.72
61.3
59.25
49.93
1983
52.78
52.78
52.64
52.29
51.77
50.29
1984
57.58
57.27
56.41
55.13
54.84
50.95
1985
72.95
72.05
68.98
64.88
63.42
53.26
1986
59.87
59.83
59.7
59.52
59.1
56.47
1987
77.36
76.44
73.36
68.81
66.67
56.78
1988
66.58
66.31
65.04
62.97
62.85
60.81
1989
62.34
62.04
61.03
59.84
59.32
58.74
1990
70.49
69.85
67.72
64.51
63.07
58.4
Sorted
results
Prob.
Peak
96
hr
21
Day
60
Day
90
Day
Yearly
0.032258064516129
77.36
76.44
73.36
68.81
66.67
60.81
0.0645161290322581
72.95
72.05
68.98
64.88
63.42
58.74
0.0967741935483871
70.49
69.85
67.72
64.51
63.07
58.4
0.129032258064516
69.66
68.78
65.72
62.97
62.85
56.78
0.161290322580645
66.58
66.31
65.04
61.3
59.76
56.78
0.193548387096774
64.88
64.4
62.56
60.3
59.6
56.47
0.225806451612903
64.81
64.34
62.17
60.28
59.35
56.18
0.258064516129032
64.24
63.63
61.71
59.96
59.32
53.93
0.290322580645161
63.4
62.99
61.54
59.84
59.25
53.9
0.32258064516129
62.81
62.17
61.03
59.52
59.1
53.56
0.354838709677419
62.41
62.04
60.56
58.67
57.7
53.3
0.387096774193548
62.34
61.97
59.82
58.65
57.31
53.26
0.419354838709677
59.87
59.83
59.7
57.72
56.32
52.41
0.451612903225806
57.95
57.65
56.57
56.22
55.93
51
0.483870967741936
57.58
57.27
56.41
55.65
54.88
50.95
0.516129032258065
56.35
56.34
56.29
55.13
54.84
50.64
0.548387096774194
54.82
54.25
54.24
54.16
53.9
50.29
0.580645161290323
54.25
54.19
52.66
52.29
51.77
49.93
0.612903225806452
52.88
52.78
52.64
50.69
49.71
46.35
0.645161290322581
52.78
52.1
49.3
48.76
48.32
41.96
0.67741935483871
49.13
49
48.94
44.99
43.07
37.64
0.709677419354839
39.94
39.76
39.25
38.9
38.41
34.24
0.741935483870968
35.66
35.19
34.38
33.13
32.46
30.31
0.774193548387097
35.19
34.92
34.15
33
32.45
27.77
0.806451612903226
27.32
27.07
26.67
25.65
25.17
22.29
0.838709677419355
23.91
23.54
22.76
21.59
21.46
21.1
35
0.870967741935484
22.42
22.37
22.13
21.58
21.43
20.19
0.903225806451613
21.42
21.33
20.86
20.53
20.46
16.14
0.935483870967742
16.56
16.43
15.87
14.88
14.44
11.81
0.967741935483871
15.52
15.05
13.63
11.94
10.94
4.887
0.1
70.407
69.743
67.52
64.356
63.048
58.238
Average
of
yearly
averages:
43.0672333333333
Inputs
generated
by
pe4.
pl
­
8­
August­
2003
Data
used
for
this
run:
Output
File:
03lb20x
Metfile:
w14737.
dvf
PRZM
scenario:
PAturfC.
txt
EXAMS
environment
file:
pond298.
exv
Chemical
Name:
MGK­
264
Description
Variable
Name
Value
Units
Comments
Molecular
weight
mwt
275.39
g/
mol
Henry's
Law
Const.
henry
2.85e­
7
atm­
m^
3/
mol
Vapor
Pressure
vapr
1.8e­
5
torr
Solubility
sol
150
mg/
L
Kd
Kd
mg/
L
Koc
Koc
899
mg/
L
Photolysis
half­
life
kdp
0
days
Half­
life
Aerobic
Aquatic
Metabolism
kbacw
860
days
Halfife
Anaerobic
Aquatic
Metabolism
kbacs
0
days
Halfife
Aerobic
Soil
Metabolism
asm
430
days
Halfife
Hydrolysis:
pH
5
0
days
Half­
life
Hydrolysis:
pH
7
0
days
Half­
life
Hydrolysis:
pH
9
0
days
Half­
life
Method:
CAM
2
integer
See
PRZM
manual
Incorporation
Depth:
DEPI
0
cm
Application
Rate:
TAPP
0.336
kg/
ha
Application
Efficiency:
APPEFF
0.99
fraction
Spray
Drift
DRFT
0.01
fraction
of
application
rate
applied
to
pond
Application
Date
Date
01­
04
dd/
mm
or
dd/
mmm
or
dd­
mm
or
dd­
mmm
Interval
1
interval
7
days
Set
to
0
or
delete
line
for
single
app.
Interval
2
interval
7
days
Set
to
0
or
delete
line
for
single
app.
Interval
3
interval
7
days
Set
to
0
or
delete
line
for
single
app.
Interval
4
interval
7
days
Set
to
0
or
delete
line
for
single
app.
Interval
5
interval
7
days
Set
to
0
or
delete
line
for
single
app.
Interval
6
interval
7
days
Set
to
0
or
delete
line
for
single
app.
Interval
7
interval
7
days
Set
to
0
or
delete
line
for
single
app.
Interval
8
interval
7
days
Set
to
0
or
delete
line
for
single
app.
Interval
9
interval
7
days
Set
to
0
or
delete
line
for
single
app.
Interval
10
interval
7
days
Set
to
0
or
delete
line
for
single
app.
Interval
11
interval
7
days
Set
to
0
or
delete
line
for
single
app.
Interval
12
interval
7
days
Set
to
0
or
delete
line
for
single
app.
Interval
13
interval
7
days
Set
to
0
or
delete
line
for
single
app.
Interval
14
interval
7
days
Set
to
0
or
delete
line
for
single
app.
Interval
15
interval
7
days
Set
to
0
or
delete
line
for
single
app.
Interval
16
interval
7
days
Set
to
0
or
delete
line
for
single
app.
Interval
17
interval
7
days
Set
to
0
or
delete
line
for
single
app.
Interval
18
interval
7
days
Set
to
0
or
delete
line
for
single
app.
Interval
19
interval
7
days
Set
to
0
or
delete
line
for
single
app.
Record
17:
FILTRA
IPSCND
1
UPTKF
0
Record
18:
PLVKRT
0
PLDKRT
0
FEXTRC
0.5
Flag
for
Index
Res.
Run
IR
Pond
Flag
for
runoff
calc.
RUNOFF
none
none,
monthly
or
total(
average
of
entire
run)
36
Appendix
E:
Environmental
Fate
and
Ecological
Effects
Data
Requirements
for
MGK­
264
Guideline
#
Data
Requirement
Is
Data
requirement
satisfied?
MRID
No.
Study
Classification
161­
1
835.2120
Hydrolysis
Yes
42222601
Acceptable
161­
2
835.2240
Photodegradation
in
water
Yes
42222602
Acceptable
161­
3
835.2410
Photodegradation
on
soil
Yes
42807501
Acceptable
161­
4
835.2370
Photodegradation
in
air
­­
­­
­­
162­
1
835.4100
Aerobic
soil
metabolism
Yes
43194501
Supplemental,
upgradeable
162­
2
835.4200
Anaerobic
soil
metabolism
Yes
43194502
Acceptable
162­
3
835.4400
Anaerobic
aquatic
metabolism
Waived
02/
04/
1994
­­
­­
162­
4
835.4300
Aerobic
aquatic
metabolism
Waived
02/
04/
1994
­­
­­
163­
1
835.1240835.12
30
Leaching­
adsorption/
desorption
Yes
42622501
Acceptable
(
unaged
portion)
163­
2
835.1410
Laboratory
volatility
­­
­­
­­
163­
3
835.8100
Field
volatility
­­
­­
­­
164­
1
835.6100
Terrestrial
field
dissipation
­­
­­
­­
164­
2
835.6200
Aquatic
field
dissipation
­­
­­
­­
164­
3
835.6300
Forestry
dissipation
­­
­­
­­
164­
4
835.6400
Combination
products
and
tank
mixtures
dissipation
­­
­­
­­

165­
4
850.1730
Accumulation
in
fish
Requested
­­
­­
165­
5
850.1950
Accumulation­
aquatic
nontarget
­­
­­
­­
166­
1
835.7100
Ground
water
 
small
prospective
­­
­­
­­
201­
1
840.1100
Droplet
size
spectrum
­­
­­
­­
202­
1
840.1200
Drift
field
evaluation
­­
­­
­­

Table
A2.
Status
of
ecological
effect
data
needs
for
MGK­
264
Guideline
#
Data
requirement
Are
data
adequate
for
risk
assessment?
MRID
No.
Study
classification
71­
1a
Bobwhite
quail
acute
oral
DR
NS
­­
71­
1b
Mallard
duck
acute
oral
ND
NS
­­
71­
2a
Bobwhite
quail
subacute
dietary
Yes
41687301
Core
71­
2b
Mallard
duck
subacute
dietary
Yes
41687302
Core
71­
3
Wild
mammal
toxicity
ND
NS
­­
71­
4a
Bobwhite
quail
reproduction
DR
NS
­­
71­
4b
Mallard
duck
reproduction
ND
NS
­­
71­
5a
Simulated
terrestrial
field
study
ND
NS
­­
71­
5b
Actual
terrestrial
field
study
ND
NS
­­
72­
1a
Freshwater
fish
(
bluegill
sunfish0
acute
Yes
41819701
core
72­
1b
Freshwater
fish
acute
ND
NS
­­
72­
1c
Freshwater
fish
(
rainbow
trout)
acute
Yes
42202201
Core
72­
1d
Freshwater
fish
(
acute)
ND
NS
­­
72­
2a
Freshwater
invertebrate
(
wateflea)
acute
yes
41526101
core
72­
2b
Freshwater
invertebrate
(
wateflea)
acute
ND
NS
­­
72­
3a
Estuarine/
marine
fish
(
sheepshead
minnow)
acute
DR
NS
­­

72­
3b
Estuarine/
marine
invertebrate
(
eastern
oyster)
acute
DR
NS
­­

72­
3c
Estuarine/
marine
invertebrate
(
mysid
shrimp)
acute
DR
NS
­­

72­
4a
Freshwater
fish
early
life
stage
(
fathead
minnow)
DR
NS
­­

72­
4b
Freshwater
invertebrate
life
cycle
(
waterflea)
ND
NS
­­

72­
4c
Estuarine/
marine
invertebrate
life
cycle
(
mysid
shrimp)
ND
NS
­­

72­
4
Estuarine/
marine
fish
early
life
stage
ND
NS
­­
37
72­
5
Freshwater
fish
life
cycle
ND
NS
­­
72­
6
Aquatic
organism
accumulation
ND
NS
­­
72­
7a
Simulated
aquatic
field
study
ND
NS
­­
72­
7b
Actual
aquatic
field
study
ND
NS
­­
122­
1a
Seed
germination/
seedling
emergence
(
tier
1)
ND
NS
­­

122­
1b
Vegetative
vigor
(
tier
1)
ND
NS
­­
122­
2
Aquatic
plant
growth
(
tier
1)
ND
NS
­­
122­
2
Aquatic
plant
algal
growth
9tier
1)
ND
NS
­­
123­
1a
Seed
germination/
seedling
emergence
(
tier
2)
ND
NS
­­

123­
1b
Vegetative
vigor
(
tier
2)
ND
NS
­­
123­
2
Aquatic
plant
growth
(
tier
2)
ND
NS
­­
124­
1
Terrestrial
field
study
ND
NS
­­
124­
2
Aquatic
field
study
ND
NS
­­
141­
1
Honey
bee
acute
contact
ND
NS
­­
141­
2
Honey
bee
residue
on
foliage
ND
NS
­­
141­
5
Field
test
for
pollinatoris
ND
NS
­­
DR
=
Data
required;
ND
=
No
data
to
evaluate;
NS
=
No
data
submitted.
38
APPENDIX
F
Toxicity
Data
Toxicity
testing
reported
in
this
section
does
not
represent
all
species
of
bird,
mammal,
or
aquatic
organism.
Only
two
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
toxicity
are
similar.
The
same
assumption
is
used
for
fish
and
amphibians.

Ecological
Effects
Characterization
Risk
assessment
of
a
pesticide's
ecological
effects
integrates
the
results
of
exposure
and
toxicity
data
to
evaluate
the
likelihood
of
adverse
ecological
effects
on
a
non­
target
species.
The
means
of
integrating
these
exposure
factors
is
the
risk
quotient
(
RQ)
method.
Risk
quotients
are
calculated
by
dividing
estimated
environmental
concentrations
(
EECs)
of
the
pesticide
by
acute
and
chronic
toxicity
values.
EECs
are
based
on
the
maximum
application
rates
for
that
pesticide.

Risk
quotients
are
then
compared
to
the
Agency's
levels
of
concern
(
LOCs).
These
LOCs
are
used
to
analyze
potential
risk
to
non­
target
organisms
and
the
need
to
consider
regulatory
action.
The
criteria
are
used
to
indicate
when
a
pesticide
used
as
directed
has
the
potential
to
cause
adverse
effects
on
non­
target
organisms.
LOCs
currently
address
the
following
risk
presumption
categories:
(
1)
acute
high:
high
potential
for
acute
risk
for
all
nontarget
organisms
which
may
warrant
regulatory
action
in
addition
to
restricted
use
classification;
(
2)
acute
restricted
use:
potential
for
acute
risk
for
all
nontarget
organisms,
but
may
be
mitigated
through
restricted
use
classification;
(
3)
acute
endangered
species:
endangered
species
may
be
adversely
affected
by
use;
and
(
4)
chronic
risk:
potential
for
chronic
risk
may
warrant
regulatory
action.
Currently,
the
Agency
does
not
perform
assessments
for
chronic
risk
to
plants,
acute
chronic
risks
to
non­
target
insects,
or
chronic
risk
from
granular/
bait
formulations
to
birds
or
mammals.
In
addition,
the
Agency
considers
any
incident
data
that
is
submitted
concerning
adverse
effects
on
non­
target
species.

Spray
Applications
to
Foliage
The
estimated
environmental
concentration
(
EEC)
values
used
for
foliar
terrestrial
exposure
are
derived
from
the
Kenega
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
and
the
derived
dietary
value
for
mammals
(
based
on
acute
LD50
lab
rat
studies).
EFED
uses
the
FATE
model
for
multiple
applications,
incorporating
the
appropriate
dissipation
half­
life
to
generate
EECs.
For
single
application
EECs,
day
zero
maximum
Fletcher
residue
values
are
used
(
lbs
ai/
A
x
240,
110,
135,
and
15
ppm).
39
RQ
Calculations,
LOCs,
and
Risk
Presumptions
for
Terrestrial
Animals
Risk
Presumption
RQ
LOC
Birds
Acute
Risk
EEC1/
LC50,
LD50/
sq
ft2,
or
LD50/
day3
0.5
Acute
Restricted
Use
EEC/
LC50,
LD50/
sq
ft,
or
LD50/
day
(
or
LD50
<
50
mg/
kg)
0.2
Acute
Endangered
Species
EEC/
LC50,
LD50/
sq
ft,
or
LD50/
day
0.1
Chronic
Risk
EEC/
NOAEC
1
Mammals
Acute
Risk
EEC/
LC50,
LD50/
sq
ft,
or
LD50/
day
0.5
Acute
Restricted
use
EEC/
LC50,
LD50/
sq
ft,
or
LD50/
day
(
or
LD50
<
50
mg/
kg)
0.2
Acute
Endangered
Species
EEC/
LC50,
LD50/
sq
ft,
or
LD50/
day
0.1
Chronic
Risk
EEC/
NOAEC
1
(
1)
EEC:
Estimated
Environmental
Concentration
(
ppm)
on
avian/
mammalian
food
items.
(
2)
mg/
sq
ft/
LD50*
wt.
of
bird.
(
3)
(
mg
of
toxicant
consumed/
day)/
LD50*
wt.
of
bird.

RQ
Calculations,
LOCs,
and
Risk
Presumptions
for
Aquatic
Animals
Risk
Presumption
RQ
LOC
Acute
Risk
EEC/(
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
RQ
Calculations,
LOCs,
and
Risk
Presumptions
for
Plants
Risk
Presumption
RQ
LOC
Terrestrial
and
Semi­
aquatic
Plants
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./
acre.
(
2)
EEC
=
ppb
or
ppm
in
water
