UNITED
STATES
ENVIRONMENTAL
PROTECTION
AGENCY
WASHINGTON,
D.
C.
20460
OFFICE
OF
PREVENTION,
PESTICIDES
AND
TOXIC
SUBSTANCES
PC
Code
No.:
014504
DP
Barcode:
D
305808
Date:
June
21,
2005
MEMORANDUM
SUBJECT:
Environmental
Fate
and
Ecological
Risk
Assessment
for
Mancozeb,
Section
4
Reregistration
for
Control
of
Fungal
Diseases
on
Numerous
Crops,
a
Forestry
Use
on
Douglas
Firs,
Ornamental
Plantings,
and
Turf
(
Phase
3
Response).

TO:
Michael
Goodis,
Branch
Chief
Christina
Scheltema,
Chemical
Review
Manager
Special
Review
and
Reregistration
Division
(
7508C)

FROM:
ERB
V
Team
for
EBDCs:
Gabe
Patrick,
Biologist,
Ecological
Effects
Reviewer
M.
A.
Ruhman,
Ph.
D.,
Agronomist,
Environmental
Fate
Reviewer
Ronald
Parker,
Ph.
D.,
Environmental
Engineer,
Environmental
Fate
Reviewer
Environmental
Fate
and
Effects
Division
(
7507C)

THROUGH:
Mah
T.
Shamim,
Ph.
D.,
Chief
Environmental
Risk
Branch
V
Environmental
Fate
and
Effects
Division
(
7507C)

The
EFED
screening
level
Environmental
Risk
Assessment
is
attached.
This
RED
document
should
be
considered
with
the
document
for
ETU,
the
degradate
of
concern
for
mancozeb.

The
following
is
an
overview
of
our
findings:

Risk
Summary
There
are
potential
chronic
risks
to
birds
and
mammals
for
all
mancozeb's
uses.
The
chronic
exceedances
to
birds
range
from
a
high
RQ
of
99
on
turf
to
a
low
of
1
on
citrus
using
a
total
foliar
dissipation
default
half­
life
value
of
35
days.
For
mammals,
the
range
of
RQ
exceedance
is
from
a
high
of
103
on
turf
to
a
low
of
1
on
peanuts
using
a
total
foliar
dissipation
default
half­
life
value
of
35
days.
There
are
potential
acute
and
chronic
risks
to
freshwater
fish
and
invertebrates;
and
acute
risks
to
estuarine/
marine
fish
and
invertebrates
for
all
mancozeb
modeled
uses
except
as
noted.
The
acute
RQs
exceeding
freshwater
fish
endangered
species
LOCs
for
mancozeb's
uses
range
from
0.1
to
0.46.
The
chronic
RQs
exceeding
LOCs
for
freshwater
fish
range
from
1.00
to
3.33.
The
acute
freshwater
invertebrates'
RQs
exceeding
endangered
species
LOCs
range
from
0.08
to
0.36
with
chronic
RQs
for
mancozeb's
use
on
sweet
corn,
tomatoes,
and
wheat
ranging
from
1.05
to
2.29.
The
1
In
this
document
three
important
abbreviations
are
used:
Parent
mancozeb,
Mancozeb
Complex
and
Bound
species.
Parent
mancozeb
is
the
polymeric
Parent
mancozeb
present
in
the
active
ingredient.
Mancozeb
Complex
is
a
suite
of
multi
species
complexes
resulting
from
degradation
of
the
polymeric
Parent
mancozeb.
The
suite
includes
the
following:
(
a)
species
reported
to
be
present
but
not
specifically
identified:
variable/
low
molecular
weight
polymeric
chains
(
i.
e
polymer
fragments),
monomeric
species,
and
EBDC
ligand
in
association
with
other
metal
ions
that
might
be
present
in
the
environment;
(
b)
species
identified
and
quantified:
Transient
species,
ETU
and
ETU
degradates;
and
(
c)
un­
identified
species
that
bound
to
soil
and
sediment
particles
(
referred
to
as
Bound
species).

2
Marshall,
W.
D.
1977.
J.
Agri.
Food
Chem.
25(
2),
357­
361.

2
acute
estuarine/
marine
fish
RQs
for
mancozeb
uses
on
apples,
tomatoes,
and
wheat
exceed
endangered
species
LOCs
ranging
from
0.05
to
0.13.
Estuarine/
marine
invertebrate
acute
RQs
exceed
LOCs
ranging
from
4.46
to
20.08.
EFED
does
not
calculate
risk
quotients
to
conduct
risk
assessments
on
terrestrial
invertebrates.
Since
mancozeb
is
practically
nontoxic
to
honeybees
(
acute
contact
LD
50
>
178
µ
g/
bee),
EFED
expects
a
low
acute
risk
to
nontarget
terrestrial
insects.
A
nonguideline
study
determined
that
mancozeb's
LR
50
(
residue
concentration
causing
50%
lethality)
for
Typhlodromus
pyri
(
a
beneficial
mite)
is
0.1
lb
active
ingredient/
A
and
the
LOAEC
which
can
be
expected
to
cause
adverse
reproductive
effects
is
0.02
lb
active
ingredient/
A.
Based
on
current
registered
mancozeb
application
rates
and
the
toxicity
indicated
from
this
study
it
would
appear
potential
adverse
effects
to
Typhlodromus
pyri
from
mancozeb's
uses
can
be
expected
if
exposure
to
mancozeb
occurs.
Due
to
lack
of
data,
EFED
did
not
assess
risks
to
terrestrial
plants
or
fully
assess
risks
to
aquatic
plants.
Based
on
data
for
one
surrogate
species,
mancozeb's
use
patterns
exceed
acute
risk
LOCs
for
nonvascular
aquatic
plants
with
acute
RQs
ranging
from
1.00
to
4.49.
EFED
did
not
assess
chronic
risks
to
estuarine/
marine
fish
and
invertebrates
due
to
lack
of
data.

Risk
to
the
Water
Resources
Mancozeb
is
non­
persistent
as
it
is
expected
to
decompose
rapidly
(
reach
<
10%
of
the
applied
within
3
days)
by
hydrolytic
reactions
in
the
main
compartments
of
the
natural
environment.
The
degradate
of
concern
in
the
process
of
mancozeb
decomposition
is
ETU,
a
B2
carcinogen
(
US
EPA,
2002).
Therefore,
risk
assessment
for
the
water
resource
from
the
common
EBDCs
degradate
ETU,
was
performed
for
the
application
of
all
EBDCs
including
mancozeb.
The
reader
is
referred
to
the
accompanied
ETU
document
for
this
assessment.

Uncertainties
(
1)
Environmental
Fate
EECs
for
Parent
mancozeb1
were
estimated
for
water
bodies
using
hydrolysis
half­
lives.
The
same
water
hydrolysis
half­
lives
were
used
for
soils
assuming
sufficient
moisture
is
available
in
soil
pores
for
hydrolysis
to
occur
at
the
same
rate.
Uncertainty
exists
on
whether
half­
lives
used
are
applicable
because
of
uncertainty
related
to
soil
moisture
availability;
soil
moisture
level
is
expected
to
impact
resultant
EECs.
Lower
EECs
are
expected
in
irrigated
and/
or
rain­
fed
soils
with
high
water
holding
capacity
(
WHC)
and
higher
EECs
are
expected
in
low
WHC
soils
under
dry
conditions.
Given
the
fact
that
mancozeb
is
applied
to
growing
crops,
moisture
is
expected
to
be
available
for
parent
to
hydrolyze
at
an
adjusted
rate
near
or
just
below
that
determined
from
aqueous
hydrolysis
half­
lives.
Other
factors
that
are
known
to
affect
hydrolytic
stability
of
mancozeb
include:
particle
size;
molecular
weight
distribution;
aqueous
media
pH
and
O
2
concentration2;
and
concentration
of
metal
ions.
3
EECs
for
Mancozeb
Complex
were
estimated
using
the
physicochemical
properties
and
hydrolysis
half­
lives
of
parent
mancozeb
in
addition
to
aerobic
soil
metabolism
half­
lives
and
sorption
coefficients
which
were
assigned
to
this
complex
rather
than
the
parent.
In
all
aerobic
soil
studies
two
separate
sets
of
determinations
were
conducted:
the
first
was
to
obtain
data
for
calculating
half­
lives
using
the
CS
2
­
method
to
quantify
the
parent
while
the
second
was
to
characterize
the
bio­
degradation
process.

EFED
believes
that
half­
lives
calculated
from
the
first
set
of
determinations
represent
hydrolytic
decomposition
of
Parent
mancozeb
rather
than
bio­
degradation.
Rapid
degradation
of
Parent
mancozeb
produces
a
complex,
the
Mancozeb
Complex,
which
appears
to
be
affected
by
slow
degradation
as
indicated
by
production
of
CO
2
.
Part
of
this
complex
may
contain
precursor(
s)
for
the
degradate
of
concern,
ETU.
Therefore,
EFED
used
the
second
set
of
experiments/
determinations
(
radioactivity
data)
for
calculating
half­
lives
and
assigned
it
to
the
Mancozeb
Complex.
Uncertainty
exists
in
these
complex
half­
lives
as
they
are
conservative
and
affected
by
the
validity
of
the
assumption
that
the
only
bio­
degradation
of
the
complex
was
represented
by
evolved
CO
2
.
Data
obtained
on
degradates
were
not
used
as
they
were
affected
by
impurities
in
the
test
materials,
hydrolytic
reactions
and
possible
artificial
degradation
during
extraction.

In
this
RED,
aerobic
soil
half­
lives
calculated
from
the
CS
2
­
method
are
considered
to
represent
hydrolysis
of
Parent
mancozeb
into
its
complex
as
modified
by
soil
conditions
(
i.
e.
moisture
content,
pH
and
O
2
concentration).
In
contrast,
half­
lives
calculated
from
evolved
CO
2
are
considered
to
represent
bio­
degradation
of
Mancozeb
Complex
left
in
the
soil
which
appears
to
occur
in
parallel
with
hydrolytic
decomposition
of
the
parent.
Likewise,
calculated
adsorption/
desorption
characteristics
(
K
d
and
K
oc
)
are
thought
to
represent
Mancozeb
Complex
as
they
were
approximated
from
column
leaching
studies;
with
no
1/
n
value
to
indicate
the
degree
of
non­
linearity
for
the
Freundlich
constant.

In
the
degradation
process
for
mancozeb,
Mn
and
Zn
ions/
salts
are
expected
to
dissipate
into
the
environment.
Although
EFED
recognizes
that
these
two
elements
are
micronutrient,
no
data
were
presented
to
evaluate
the
risk
that
might
be
associated
with
this
release
in
certain
environmental
settings
and
therefore,
uncertainty
exists
in
this
aspect
of
risk
assessment.

(
2)
Ecological
Effects
EFED
is
uncertain
about
mancozeb's
acute
risk
to
nontarget
terrestrial
plants
and
needs
testing
performed
at
mancozeb's
maximum
rate
of
application
in
the
environment.
EFED
has
not
received
studies
to
evaluate
the
acute
risk
of
Mancozeb
Complex
to
vascular
aquatic
plants
and
is
uncertain
about
this
risk.
EFED
has
received
one
acute
study
for
1
of
4
surrogate
species
needed
to
evaluate
the
acute
risk
to
nonvascular
aquatic
plants.
This
one
study
when
compared
to
Mancozeb
Complex'
exposure
showed
the
acute
RQs
exceeded
LOCs.
EFED
needs
testing
performed
on
3
more
surrogate
species
to
evaluate
fully
the
acute
risk
to
nonvascular
aquatic
plants.
EFED
has
no
data
to
evaluate
the
chronic
effects
to
estuarine/
marine
organisms
and
is
uncertain
about
the
chronic
risks
to
estuarine/
marine
organisms.
EFED
needs
whole
sediment
acute
toxicity
testing
on
freshwater
and
estuarine/
marine
invertebrates
because
Mancozeb
Complex
is
toxic
to
aquatic
invertebrates,
binds
to
sediment
,
and
may
persist
on
sediment
surfaces.
EFED
is
uncertain
about
the
risk
to
benthic
organisms.
4
Endocrine
Disruption
Mancozeb
toxicity
effects
noted
in
both
birds
and
mammals
could
be
a
result
of
possible
hormonal
disruptions.
The
avian
reproductive
studies
reviewed
by
EFED
noted
reproductive
effects
such
as
reductions
in:
egg
production;
early
and
late
embryo
viability;
hatchability;
offspring
weight
at
hatch
and
14­
days
of
age;
and
the
number
of
14­
day
old
survivors.
For
mammals,
EFED
noted
chronic
effects
in
a
3­
month
feeding
study
using
rats.
Effects
noted
in
females
rats
included
decreased
serum
thyroxine
levels.
Male
rat
effects
included:
body
weight
decrements;
changes
in
thyroid
hormones;
changes
in
liver
enzymes;
microscopic
changes
in
the
liver
and
thyroids;
increased
absolute
and
relative
thyroid
weights;
and
increased
relative
liver
weights.
Some
developmental
effects
noted
in
mammals
(
that
is,
rats)
were
gross
developmental
defects,
central
nervous
system
defects,
skeletal
defects,
cryptorchidism
(
failure
of
one
or
more
testes
to
descend
into
the
scrotum)
,
and
abortions.
Chronic
testing
in
freshwater
organisms
showed
immobility,
length
and
time
until
first
brood
in
daphnia
and
reduced
survival
and
lack
of
growth
effects
in
fathead
minnow.
These
effects
noted
in
freshwater
species
could
be
a
result
of
possible
hormonal
disruptions.

Data
Gaps
Environmental
Fate
Complete
characterization
of
the
fate
of
Mancozeb
Complex
requires
more
information
on
the
various
species
that
constitute
this
complex
including
the
soil/
sediment
bound
species.
Information
needed
are
for
each
of
these
constituents
and
includes:
their
physicochemical
properties
and
the
nature
of
their
association
with
soil/
sediment
particles.
Information
is
also
needed
for
the
release
of
Mn
and
Zn
ions
from
mancozeb
in
order
to
evaluate
possible
environmental
risk
that
might
be
associated
with
such
release
in
specific
environmental
settings.

Several
problems
were
identified
in
submitted
fate
studies
for
the
EBDCs
including
mancozeb.
These
problems
are
presented
in
detail
in
Appendix
I.
The
registrant
is
requested
to
address
these
problems.

The
following
Table
lists
the
status
of
the
fate
data
requirements
for
mancozeb.
In
the
Table,
hydrolysis,
adsorption/
desorption
and
leaching
studies
are
listed
as
supplemental
however,
no
new
studies
are
required
because
problems
found
in
these
studies
are
mostly
associated
with
the
unique
characteristics
of
this
chemical
in
aqueous
media.
Not
all
the
requirements
of
these
guideline
studies
can
be
met
due
to
the
high
susceptibility
of
this
chemical
to
hydrolysis.
In
contrast,
soil
and
aquatic
studies
are
classified
as
supplemental
mainly
because
of
incomplete
characterization
of
the
significant
bound
species.
Without
a
complete
characterization
of
these
species,
EFED
was
only
able
to
estimate
conservative
half­
lives
based
on
complete
mineralization
of
the
complex
into
CO
2
.
The
issues
of
the
Bound
species
and
use
of
CS
2
data
are
presented
in
detail
elsewhere
in
this
document
(
section
IV.
b.
iv);
the
registrant
is
requested
to
address
these
issues.

A
high
tier
targeted
monitoring
study
was
submitted
for
ETU,
the
degradate
of
concern
for
all
EBDCs
including
mancozeb,
therefore,
no
new
terrestrial
field
dissipation
study
is
required
at
this
time.
5
Status
of
environmental
fate
data
requirements
for
Mancozeb.

Guideline
Number
Data
Requirement
Is
Data
Needed?
MRID
Number
Study
Classification
161­
1
835.2
Hydrolysis
1
No
000971­
62
with
402582­
01
Supplemental
161­
2
835.2
Photo
Degradation
in
Water
2
No
001621­
03
Acceptable
161­
3
835.2
Photo
Degradation
on
Soil
2
No
002639­
07
Acceptable
162­
1
835.4
Aerobic
Soil
Metabolism
3
Reserved
457445­
01
Supplemental
162­
2
835.4
Anaerobic
Soil
Reserved
411771­
01
Not
Acceptable
162­
3
835.4
Anaerobic
Aquatic
Metabolism
Reserved
402582­
03
with
000888­
20
Supplemental
162­
4
835.4
Aerobic
Aquatic
Metabolism
¶
462043­
01
¶

163­
1
835.1230
Adsorption/
Desorption
4
No
402229­
01
Supplemental
000888­
22
835.1240
Leaching
5
No
405883­
02
Supplemental
163­
2
Laboratory
Volatility
Waived
based
on
low
vapor
pressure
and
inhalation
toxicity
164­
1
835.6
Terrestrial
Field
Dissipation
6
No
409236­
01
with
445241­
01
Published
Paper
165­
4
850.2
Accumulation
in
Fish
Waived
because
mancozeb
Kow
is
equal
to
22
1.
The
hydrolysis
study
was
first
submitted
under
MRID
00088­
19
and
under
MRID
402582 
02
(
A
better
copy
but
without
the
4
appendices
attached).
The
same
study
was
also
submitted
under
MRIDs
000889­
16
and
00649­
26.
MRIDs
00971­
55
and
00971­
59
are
a
non­
guideline
studies.
MRID
403819­
30
is
only
a
4
hour
study
dealing
with
changes
in
the
tank
mix
of
suspended
mancozeb
in
tap
water.
It
indicated
a
slight
increase
in
ETU
over
what
was
present
in
the
formulation
used
(
Manufacturing
process).
2.
Water
and
soil
photolysis
studies
were
also
submitted,
for
DCI,
under
MRIDs
002639­
07
and
002588­
96.
3.
Study
451452­
01
and
(
001621­
05
with
supplemental
408387­
0)
were
rejected.
4.
Study
000888­
22
is
the
same
study
under
MRIDs
001463­
70
and
000971­
57
5.
Study
000655­
31
was
rejected;
MRID
000971­
54
is
a
non­
guideline
simulated
run­
off
study
(
A
Note).
6.
Study
0001481­
26
was
rejected.
Studies
449962­
01;
439172­
39/
38
and
439703­
04
are
for
dimethomorph.
A
TFD
study
on
six
French
soils
and
an
article
from
J.
of
Pest
Management
are
available
in
addition
to
a
simulation
of
the
environmental
fate
of
Mancozeb/
ETU
under
condition
of
use
(
using
models
CREAMS
and
GLEAMS)
under
MRID
418419­
01.
Other
submitted
short
studies
(
Notes)
include:
MRID
014811­
26;
001619­
35.
¶
Decisions
reserved
after
full
review
of
the
study.

Ecotoxicity
EFED
is
uncertain
about
mancozeb's
acute
risk
to
aquatic
and
terrestrial
plants
because
EFED
lacks
toxicity
data
for
some
or
all
surrogate
species
representing
these
groups.
Because
EFED
lacks
chronic
mancozeb
toxicity
data,
EFED
is
uncertain
about
the
chronic
risks
to
estuarine/
marine
organisms.
EFED
needs
studies
presented
to
evaluate
these
uncertainties.
EFED
needs
whole
6
sediment
acute
toxicity
testing
on
freshwater
invertebrates
and
estuarine/
marine
because
Mancozeb
Complex
is
toxic
to
aquatic
invertebrates,
binds
to
sediment,
and
may
persist
on
sediment
surfaces.
In
some
risk
evaluations
EFED
has
used
supplemental
studies
to
make
a
risk
determination.
EFED
needs
core
studies
to
confirm
these
findings.

The
following
Table
lists
the
status
of
the
ecological
data
requirements
for
mancozeb.

Status
of
environmental
ecological
data
needs
for
Mancozeb.

Date:
May
13,
2005
Case
No:
0643
Chemical
No:
014504
MANCOZEB
DATA
NEEDS
FOR
THE
ENVIRONMENTAL
FATE
AND
EFFECTS
DIVISION
Data
Requirements
Composition1
Use
Pattern2
Does
EPA
Have
Data
To
Satisfy
This
Need?
(
Yes,
No,
Partially)
Bibliographic
Citation
Study
Classification
Additional
Data
Needed
Under
FIFRA
3(
c)(
2)(
B)?

§
158.490
WILDLIFE
AND
AQUATIC
ORGANISMS
71­
1(
a)
Acute
Avian
Oral,
Quail/
Duck
TGAI
1,
2,
3,
4,10,
&
11
Partially
00080716
Supplemental
Yes
71­
1(
b)
Acute
Avian
Oral,
Quail/
Duck
(
TEP)
1,
2,
3,
4,10,
&
11
No
not
applicable
not
applicable
No
71­
2(
a)
Acute
Avian
Diet,
Quail
TGAI
1,
2,
3,
4,
10,
&
11
No
not
applicable
not
applicable
Waived3
71­
2(
b)
Acute
Avian
Diet,
Duck
TGAI
1,
2,
3,
4,10,
&
11
No
not
applicable
not
applicable
Waived3
71­
3
Wild
Mammal
Toxicity
1,
2,
3,
4,10,
&
11
No
not
applicable
not
applicable
No
71­
4(
a)
Avian
Reproduction
Quail
TGAI
1,
2,
3,
4,
10,
&
11
Yes
44159501
44238001
Core
Core
No
71­
4(
b)
Avian
Reproduction
Duck
TGAI
1,
2,
3,
4,10,
&
11
Yes
41948401
Core
No
71­
5(
a)
Simulated
Terrestrial
Field
Study
1,
2,
3,
4,10,
&
11
No
not
applicable
not
applicable
No
71­
5(
b)
Actual
Terrestrial
Field
Study
1,
2,
3,
4,
10,
&
11
No
not
applicable
not
applicable
No
72­
1(
a)
Acute
Fish
Toxicity
Bluegill
TGAI
1,
2,
3,
4,10,
&
11
Yes
40118501
00097173
00097147
not
reported
45934702
Supplemental
Supplemental
Supplemental
Supplemental
Supplemental
Yes
72­
1(
b)
Acute
Fish
Toxicity
Bluegill
(
TEP)
1,
2,
3,
4,10,
&
11
No
not
applicable
not
applicable
Reserved4
72­
1(
c)
Acute
Fish
Toxicity
Rainbow
Trout
TGAI
1,
2,
3,
4,
10,
&
11
Yes
40118502
not
reported
45934701
Core
Supplemental
Supplemental
No
72­
1(
d)
Acute
Fish
Toxicity
Rainbow
Trout
(
TEP)
1,
2,
3,
4,10,
&
11
Partially
40467501
43917218
43917216
43917217
44950503
Supplemental
Supplemental
Supplemental
Supplemental
Core
Reserved4
72­
2(
a)
Acute
Aquatic
Invertebrate
Toxicity
TGAI
1,
2,
3,
4,10,
&
11
Yes
40118503
40467503
Core
Core
No
Date:
May
13,
2005
Case
No:
0643
Chemical
No:
014504
MANCOZEB
DATA
NEEDS
FOR
THE
ENVIRONMENTAL
FATE
AND
EFFECTS
DIVISION
Data
Requirements
Composition1
Use
Pattern2
Does
EPA
Have
Data
To
Satisfy
This
Need?
(
Yes,
No,
Partially)
Bibliographic
Citation
Study
Classification
Additional
Data
Needed
Under
FIFRA
3(
c)(
2)(
B)?

7
72­
2(
b)
Acute
Aquatic
Invertebrate
Toxicity
(
TEP)
1,
2,
3,
4,
10,
&
11
Partially
43917217
43917216
43917215
44950502
45934703
Supplemental
Supplemental
Supplemental
Core
Supplemental
Reserved4
850.1735
Whole
Sediment
Acute
Toxicity
Invertebrates,
Freshwater
TGAI
1,
2,
3,
4,10,
&
11
No
Not
applicable
Not
applicable
Yes
72­
3(
a)
Acute
Estu/
Mari
Tox
Fish
TGAI
1,
2,
3,
4,10,
&
11
No
40586802
41844901
Supplemental
Supplemental
Yes
72­
3(
b)
Acute
Estu/
Mari
Tox
Mollusk
TGAI
1,
2,
3,
4,
10,
&
11
Yes
40885102
Core
No
72­
3(
c)
Acute
Estu.
Mari
Tox
Shrimp
TGAI
1,
2,
3,
4,10,
&
11
No
41822901
40586801
Supplemental
Supplemental
Yes5
850.1740
Whole
Sediment
Acute
Toxicity
Invertebrates,
Est/
Mar
TGAI
1,
2,
3,
4,10,
&
11
No
Not
applicable
Not
applicable
Yes
72­
3(
d)
Acute
Estu/
Mari
Tox
Fish
(
TEP)
1,
2,
3,
4,
10,
&
11
No
41844902
40586804
Supplemental
Supplemental
Reserved4
72­
3(
e)
Acute
Estu/
Mari
Tox
Mollusk
(
TEP)
1,
2,
3,
4,10,
&
11
Partially
40885101
Core
Reserved4
72­
3(
f)
Acute
Estu/
Mari
Tox
Shrimp
(
TEP)
1,
2,
3,
4,10,
&
11
No
41822902
40586803
Supplemental
Supplemental
Yes
72­
4(
a)
Early
Life­
Stage
Fish
TGAI
1,
2,
3,
4,
10,
&
11
Partially
43230701
(
freshwater)
Core
Yes6
72­
4(
b)
Life­
Cycle
Aquatic
Invertebrate
TGAI
1,
2,
3,
4,10,
&
11
Partially
40953802
(
freshwater)
Core
Yes7
72­
5
Life­
Cycle
Fish
(
Freshwater
Fish)
TGAI
1,
2,
3,
4,10,
&
11
No
Not
applicable
Not
applicable
Yes
72­
6
Aquatic
Org.
Accumulation
TGAI
1,
2,
3,
4,
10,
&
11
72­
7(
a)
Simulated
Aquatic
Field
Study
(
TEP)
1,
2,
3,
4,10,
&
11
Not
applicable
(
not
required)
44944401
Supplemental9
No
72­
7(
b)
Actual
Aquatic
Field
Study
1,
2,
3,
4,10,
&
11
No
Not
applicable
Not
applicable
No
§
158.540
PLANT
PROTECTION
1,
2,
3,
4,
10,
&
11
122­
1(
a)
Seed
Germ./
Seedling
Emerg.­
Tier
I
(
TEP)
1,
2,
3,
4,10,
&
11
Partially
44283401
Core
Yes10
122­
1(
b)
Vegetative
Vigor­
Tier
I
(
TEP)
1,
2,
3,
4,10,
&
11
Partially
44283401
Core
Yes10
122­
2
Aquatic
Plant
Growth­
Tier
I
(
TEP)
1,
2,
3,
4,
10,
&
11
No
Not
applicable
Not
applicable
Yes8
Date:
May
13,
2005
Case
No:
0643
Chemical
No:
014504
MANCOZEB
DATA
NEEDS
FOR
THE
ENVIRONMENTAL
FATE
AND
EFFECTS
DIVISION
Data
Requirements
Composition1
Use
Pattern2
Does
EPA
Have
Data
To
Satisfy
This
Need?
(
Yes,
No,
Partially)
Bibliographic
Citation
Study
Classification
Additional
Data
Needed
Under
FIFRA
3(
c)(
2)(
B)?

123­
1(
a)
Seed
Germ./
Seedling
Emerg.­
Tier
II
(
TEP)
1,
2,
3,
4,10,
&
11
No
Not
applicable
Not
applicable
Reserved
123­
1(
b)
Vegetative
Vigor­
Tier
II
(
TEP)
1,
2,
3,
4,10,
&
11
No
Not
applicable
Not
applicable
Reserved
123­
2
Aquatic
Plant
Growth­
Tier
II
(
TEP)
1,
2,
3,
4,
10,
&
11
Partially
43664701
44283402
43917217
44950501
Core
Core
Supplemental
Supplemental
Yes8
124­
1
Terrestrial
Field
Study
1,
2,
3,
4,10,
&
11
No
Not
applicable
Not
applicable
No
124­
2
Aquatic
Field
Study
1,
2,
3,
4,10,
&
11
No
Not
applicable
Not
applicable
No
§
158.490
INSECT
TESTING
1,
2,
3,
4,
10,
&
11
141­
1
Honey
Bee
Acute
Contact
TGAI
1,
2,
3,
4,10,
&
11
Yes
00018842
44950504
(
TEP)(
contact)
44950504
(
TEP)(
oral)
Core
Core
Supplemental
No
141­
2
Honey
Bee
Residue
on
Foliage
(
TEP)
1,
2,
3,
4,10,
&
11
No
00001949
Supplemental
No
141­
5
Field
Test
for
Pollinators
1,
2,
3,
4,
10,
&
11
No
Not
applicable
Not
applicable
No
Nonguideline
Predatory
Mite
Acute
Contact
and
Reproductive
(
TEP)
1,
2,
3,
4,10,
&
11
Not
applicable
45577201
Supplemental
No
1.
Composition:
TGAI=
Technical
grade
of
the
active
ingredient;
PAIRA=
Pure
active
ingredient,
radiolabeled;
TEP=
Typical
end­
use
product
2.
Use
Patterns:
1=
Terrestrial/
Food;
2=
Terrestrial/
Feed;
3=
Terrestrial
Non­
Food;
4=
Aquatic
Food;
5=
Aquatic
Non­
Food
(
Outdoor);
6=
Aquatic
Non­
Food
(
Industrial);
7=
Aquatic
Non­
Food
(
Residential);
8=
Greenhouse
Food;
9=
Greenhouse
Non­
Food;
10=
Forestry;
11=
Residential
Outdoor;
12=
Indoor
Food;
13=
Indoor
Non­
Food;
14=
Indoor
Medical;
15=
Indoor
Residential
3.
Waived
for
mancozeb
per
memorandum
,
dated
10/
87,
from
EFED
to
RD.

4.
Additional
studies
on
multible
active
ingredient
(
MAI)
mancozeb
TEPs
may
be
required
in
the
future
if
these
TEPs
are
identified
as
being
of
toxicological
concern.
MRID
No.
40467501
has
been
downgraded
from
Core
to
Supplemental
because
the
endpoint
results
were
not
based
on
measured
concentrations
of
the
test
substance.

5.
Need
core
study.

6.
Core
study
for
estuarine/
marine
fish
for
the
TGAI
of
mancozeb
is
required.

7.
Core
study
for
estuarine/
marine
invertebrate
for
the
TGAI
of
mancozeb
is
required.

8.
Tier
I
or
Tier
II
aquatic
plant
growth
testing
needs
to
be
submitted
for
duckweed
(
Lemna
gibba),
marine
diatom
(
Skeletonema
costatum),
bluegreen
algae
(
Anabaena
flos­
aquae),
and
a
freshwater
diatom
for
mancozeb.

9.
Mesocosm
draft
study
given
abbreviated
review
with
final
submitted
under
MRID
No.
45014901
to
be
reviewed.
This
submission
was
not
an
EFED
data
requirement
but
was
submitted
under
section
6
(
a)(
2)
of
FIFRA.

10.
SAI
TEP
testing
is
recommended
for
mancozeb.

Environmental
Hazards
Labeling
Statements
for
Mancozeb
9
Manufacturing
Use
Do
not
discharge
effluent
containing
this
product
into
lakes,
streams,
ponds,
estuaries
oceans
or
other
waters
unless
in
accordance
with
the
requirements
of
a
National
Pollutant
Discharge
Elimination
System
(
NPDES)
permit
and
the
permitting
authority
has
been
notified
in
writing
prior
to
discharge.
Do
not
discharge
effluent
containing
this
product
to
sewer
systems
without
previously
notifying
the
local
sewage
treatment
plant
authority.
For
guidance
contact
your
State
Water
Board
or
Regional
Office
of
the
EPA.

End
Use
Products
Do
not
apply
directly
to
water
or
to
areas
where
surface
water
is
present
or
to
intertidal
areas
below
the
mean
high­
water
mark.
Do
not
contaminate
water
when
disposing
of
equipment
wash
water
or
rinsate.

This
pesticide
is
toxic
to
aquatic
organisms.

Label
statements
for
spray
drift
management
AVOIDING
SPRAY
DRIFT
AT
THE
APPLICATION
SITE
IS
THE
RESPONSIBILITY
OF
THE
APPLICATOR.
The
interaction
of
many
equipment­
and­
weather­
related
factors
determine
the
potential
for
spray
drift.
The
applicator
is
responsible
for
considering
all
these
factors
when
making
decisions.
Where
states
have
more
stringent
regulations,
they
should
be
observed.

Potential
areas
of
change
to
the
risk
assessments
for
the
EBDCs
and
ETU
EFED
continues
to
receive
mancozeb
studies
for
review.
These
submissions
resulted
from
conversations
between
OPP
and
the
EBDC
Task
Force
and
Dow
AgroSciences'
acquisition
of
Rohm
&
Haas
(
see
memo
dated
1­
27­
03
from
DOW's
Shannon
Bass).
To
meet
deadlines
for
sending
EFED's
risk
assessments
to
SRRD,
EFED
postponed
further
study
evaluation
of
new
studies.
Now
EFED
will
renew
evaluation
of
outstanding
studies
and
intends
to
include
these
studies
in
the
revised
chapters
for
the
mancozeb.
At
a
minimum
EFED
will
include
the
listed
studies
(
see
Table
1)
in
the
next
revision.
These
studies
are
not
expected
to
change
the
current
risk
assessment
for
mancozeb.

Table
1
Mancozeb
studies
not
included
in
Section
4
Reregistration
for
EBDCs
as
of
5/
23/
05
Guideline
MRID
Number
Study
Status
Test
material
§
72­
4a
46023701
Dithane
DG:
21­
Day
Prolonged
Toxicity
Study
in
the
Rainbow
Trout
Under
Flow­
Through
Conditions.
Wuthrich,
V.
1993.
Needs
EPA
Review
77.1%

§
72­
4b
46023702
Influence
of
Dithane
DG
on
the
Reproduction
of
Daphnia
Magna
Under
Flow­
Through
Conditions.
Wuthrich,
V.
1993..
Needs
EPA
Review
77.1%

Nonguideline
Reproducti
on
and
Growth
Study
46023704
A
Chronic
Toxicity
and
Reproduction
Test
Exposing
the
Earthworm
Eisenia
fetida
to
Dithane
M­
45
in
OECD
Artificial
Soil.
Nienstedt,
K.
M.
1999
Needs
EPA
Review
81.7%

§
72­
1c
46161001
The
Acute
Toxicity
of
Mancozeb
Technical
to
Rainbow
Trout
(
Salmo
gairdneri).
Douglas,
M.
T.,
J.
W.
Handley
and
I.
A.
Macdonald.
1988.
Needs
EPA
Review
>
90%
UNITED
STATES
ENVIRONMENTAL
PROTECTION
AGENCY
WASHINGTON,
D.
C.
20460
OFFICE
OF
PREVENTION,
PESTICIDES,
AND
TOXIC
SUBSTANCES
Environmental
Fate
and
Ecological
Risk
Assessment
for
the
Reregistration
of
Mancozeb
A
coordination
product
of
zinc
ion
and
manganese
ethylenebisdithiocarbamate
Prepared
by:

Mohammed
A.
Ruhman,
Ph.
D.
Ronald
Parker,
Ph.
D.
Gabe
Patrick
United
States
Environmental
Protection
Agency
Office
of
Pesticide
Programs
Environmental
Fate
and
Effects
Division
Environmental
Risk
Branch
V
401
M
Street,
SW
Mail
Code
7507C
Washington,
D.
C.
20460
Reviewed
by:
Mah
Shamim,
Ph.
D.
ii
TABLE
OF
CONTENTS
I.
Executive
Summary
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
1
II.
Introduction
.
.
.
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5
a.
Use
Characterization
.
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.
5
b.
Approach
to
Risk
Assessment
.
.
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7
III.
Integrated
Environmental
Risk
Characterization
.
.
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.
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.
.
13
a.
Overview
of
Environmental
Risk
.
.
.
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.
.
13
b.
Key
Issues
and
Uncertainty
.
.
.
.
.
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.
13
i.
Environmental
Fate
.
.
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.
14
ii.
Ecological
Effects
.
.
.
.
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.
15
c.
Endangered
Species
Conclusions
.
.
.
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18
d.
Endocrine
Disruption
Concerns
.
.
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.
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.
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.
18
IV.
Environmental
Fate
and
Transport
Assessment
.
.
.
.
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.
20
a.
Chemical
Identity
and
Physicochemical
Properties
.
.
.
.
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.
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.
20
b.
Fate
Processes
.
.
.
.
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21
i.
Aqueous
media
.
.
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.
23
ii.
Soil
.
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.
23
iii.
Sediment/
Water
Systems
.
.
.
.
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.
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.
25
iv.
Bound
Species,
CS2­
data
and
Half­
life
Determination
for
EBDCs
.
.
.
.
.
.
.
.
.
.
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.
.
.
25
c.
Mobility
.
.
.
.
.
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.
.
.
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.
28
d.
Field
Dissipation
.
.
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.
28
e.
Bio­
accumulation
.
.
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.
28
V.
Water
Resource
Assessment
.
.
.
.
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.
28
a.
Surface
Water
Monitoring
and
Modeling
.
.
.
.
.
.
.
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.
29
b.
Ground
Water
Monitoring
and
Modeling
.
.
.
.
.
.
.
.
.
.
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.
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.
30
c.
Drinking
Water
Assessment
.
.
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.
30
VI.
Aquatic
Exposure
and
Risk
Assessment
.
.
.
.
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.
30
a.
Hazard
Summary
.
.
.
.
.
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.
.
30
b.
Exposure
and
Risk
Quotients
.
.
.
.
.
.
.
.
.
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.
.
33
c.
Aquatic
Risk
Assessment
.
.
.
.
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.
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.
.
35
i.
Incidents
.
.
.
.
.
.
.
.
.
.
.
.
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.
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.
.
.
37
ii.
Endocrine
Disruptors
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
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.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
38
iii.
Endangered
Species
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
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.
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.
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.
.
.
.
.
.
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.
.
.
.
.
.
.
.
38
VII.
Terrestrial
Exposure
and
Risk
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
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.
.
.
.
.
.
.
.
.
.
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.
.
.
.
.
.
.
.
.
39
a.
Hazards
Summary
(
Acute/
Chronic
Toxicity)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
39
b.
Exposure
Summary
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
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.
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.
.
.
.
.
.
.
40
c.
Risk
Quotients
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
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.
.
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.
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.
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.
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.
.
.
.
.
.
.
40
d.
Terrestrial
Risk
Assessment
.
.
.
.
.
.
.
.
.
.
.
.
.
.
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.
.
.
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.
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.
.
.
.
.
46
i.
Incidents
.
.
.
.
.
.
.
.
.
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.
.
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.
.
.
.
.
.
51
ii.
Endocrine
Disruptors
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
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.
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.
.
.
.
.
.
.
.
51
iii.
Endangered
Species
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
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.
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.
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.
.
.
.
.
.
.
.
.
52
iii
APPENDIX
I:
Notes
on
Fate
Studies
and
Modeling
&
Additional
Fate
Data
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
53
a.
Notes
on
Fate
Studies
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
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.
.
.
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.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
53
i.
Aqueous
medium
studies
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
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.
.
.
.
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.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
53
ii.
Soil/
sediment
studies
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
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.
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.
.
.
.
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.
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.
.
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.
.
.
.
.
.
.
.
53
b.
Notes
on
Modeling
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
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.
.
.
.
.
.
.
.
.
56
i.
EECs
for
Parent
mancozeb
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
56
ii.
Background
Information
on
the
PRZM
and
EXAMS
models
&
the
Index
Reservoir
Scenario
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
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.
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.
.
.
.
.
57
iii.
Background
Information
on
SCIGROW
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
57
c.
Additional
Fate
Data
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
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.
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.
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.
.
.
.
.
.
.
.
.
58
APPENDIX
II:
Hoerger­
Kenaga
Estimates
&
Fate
v.
5.0
Model
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
59
a.
Hoerger­
Kenaga
Estimates
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
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.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
59
b.
Fate
v.
5.0
Model
Terrestrial
Exposure
Values
.
.
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.
.
60
c.
Fate
v.
5.0
Model
Sample
Output
for
Mancozeb
.
.
.
.
.
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.
60
APPENDIX
III:
Ecological
Hazards
Assessment
.
.
.
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.
.
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65
a.
Scope
.
.
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.
65
b.
Toxicity
to
Terrestrial
Animals
.
.
.
.
.
.
.
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.
.
.
.
.
.
.
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.
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.
.
65
i.
Birds,
Acute,
Subacute
and
Chronic
.
.
.
.
.
.
.
.
.
.
.
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.
.
.
.
.
.
.
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.
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.
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.
.
.
65
ii.
Mammals,
Acute
and
Chronic
.
.
.
.
.
.
.
.
.
.
.
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.
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.
.
.
.
.
.
67
1.
Acute
Oral
Toxicity
Testing
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
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.
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.
.
.
.
.
68
2.
Acute
Dermal
and
Inhalation
Toxicity
Testing
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
68
3.
Mammalian
Sub­
chronic
Toxicity
Testing
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
69
4.
Mammalian
Feeding,
Reproductive
and
Developmental
Toxicity
Testing
.
.
.
70
iii.
Insect
Acute
Contact
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
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.
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.
.
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.
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.
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.
.
.
71
iv.
Insect
and
Mite
Residual
Contact
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
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.
.
.
.
.
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.
.
.
.
.
.
.
.
72
v.
Terrestrial
Field
Testing
.
.
.
.
.
.
.
.
.
.
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.
.
.
.
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.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
73
c.
Aquatic
Organism
Toxicity
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
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.
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.
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.
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.
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.
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.
.
.
.
.
.
73
i.
Toxicity
to
Freshwater
Animals
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
73
1.
Freshwater
Fish,
Acute
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
73
2.
Freshwater
Fish,
Chronic
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
76
3.
Freshwater
Invertebrates,
Acute
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
76
4.
Freshwater
Invertebrate,
Chronic
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
78
5.
Freshwater
Field
Studies
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
79
ii.
Toxicity
to
Estuarine
and
Marine
Animals
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
80
1.
Estuarine
and
Marine
Fish,
Acute
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
80
2.
Estuarine
and
Marine
Fish,
Chronic
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
81
3.
Estuarine
and
Marine
Invertebrates,
Acute
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
81
4.
Estuarine
and
Marine
Invertebrate,
Chronic
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
83
5.
Estuarine
and
Marine
Field
Studies
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
83
iii.
Toxicity
to
Plants
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
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.
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.
.
.
.
.
.
.
.
.
.
83
1.
Terrestrial
Plants
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
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.
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.
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.
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.
.
.
.
83
2.
Terrestrial
Plant
Field
Studies
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
86
3.
Aquatic
Plants
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
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.
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.
.
.
.
.
.
.
.
86
4.
Aquatic
Plant
Field
Studies
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
88
APPENDIX
IV:
Environmental
Exposure
Assessment
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
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.
.
.
.
.
.
.
.
.
89
a.
Overview
of
Risk
Quotients
(
RQs)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
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.
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.
.
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.
.
.
.
.
.
.
.
89
iv
b.
Exposure
and
Risk
to
Terrestrial
Animals
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
91
i.
Birds
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
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.
.
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.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
91
ii.
Mammals
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
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.
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.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
98
iii.
Insects
and
Mites
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
105
c.
Aquatic
Organisms
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
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.
.
.
.
.
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.
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.
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.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
105
i.
Overview
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
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.
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.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
105
ii.
Freshwater
Fish
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
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.
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.
.
.
.
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.
.
.
.
.
.
.
.
.
.
.
.
.
.
106
iii.
Freshwater
Invertebrates
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
107
iv.
Estuarine/
Marine
Fish
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
108
v.
Estuarine/
Marine
Invertebrates
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
109
d.
Exposure
and
Risk
to
Non­
target
Plants:
Aquatic
Plants
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
110
e.
Endangered
Species
.
.
.
.
.
.
.
.
.
.
.
.
.
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.
.
.
.
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.
.
.
.
.
.
.
111
f.
Ecological
Incidents
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
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.
.
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.
.
.
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.
.
.
.
.
.
.
.
.
.
.
.
111
APPENDIX
V:
US
EPA
Ecological
Incident
Information
System
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
113
APPENDIX
VI:
EBDC
Aquatic
Studies
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
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.
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.
.
114
REFERENCES
.
.
.
.
.
.
.
.
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.
.
.
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.
.
.
.
.
.
.
118
1
I.
Executive
Summary
There
are
potential
chronic
risks
to
birds
and
mammals,
acute
and
chronic
risks
to
freshwater
animals,
acute
risks
to
estuarine/
marine
animals,
and
acute
risks
to
aquatic
nonvascular
plants.
These
potential
risks
occur
for
all
or
some
of
mancozeb's
uses.
Because
EFED
lacks
data,
EFED
is
uncertain
about
mancozeb's
potential
acute
risks
to
terrestrial
plants,
chronic
risks
to
estuarine/
marine
animals
and
acute
risks
to
aquatic
vascular
plants.

There
are
potential
chronic
risks
to
birds
and
mammals
for
all
mancozeb's
uses.
The
chronic
exceedances
to
birds
range
from
a
high
RQ
of
99
on
turf
to
a
low
of
1
on
citrus
using
a
total
foliar
dissipation
default
half­
life
value
of
35
days.
EFED
based
bird
chronic
reproductive
effects
on
reductions
in:
egg
production;
early
and
late
embryo
viability;
hatchability;
and
offspring
weight
at
hatch
and
14­
days
of
age
in
mallard
ducks.
For
mammals,
the
range
of
RQ
exceedance
is
from
a
high
of
103
on
turf
to
a
low
of
1
on
peanuts
using
a
total
foliar
dissipation
default
half­
life
value
of
35
days.
EFED
based
mammal
chronic
reproductive
effects
on
a
2­
generation
study
in
rats.
These
mammal
effects
were
parental
body
weight
decrements,
increased
relative
thyroid
weights,
and
increased
incidence
of
thyroid
follicular
cell
hyperplasia.
There
are
potential
acute
and
chronic
risks
to
freshwater
fish
and
invertebrates;
and
potential
acute
risks
to
estuarine/
marine
fish
and
invertebrates
for
all
mancozeb
modeled
uses
except
as
noted.

The
acute
RQs
exceeding
freshwater
fish
endangered
species
LOCs
for
mancozeb's
uses
range
from
0.1
to
0.46.
The
chronic
RQs
exceeding
LOCs
for
freshwater
fish
range
from
1.00
to
3.33.
EFED
based
chronic
freshwater
fish
effects
on
reduced
survival
and
lack
of
growth
effects
in
fathead
minnows.
The
acute
freshwater
invertebrates'
RQs
exceeding
endangered
species
LOCs
range
from
0.08
to
0.36
with
chronic
RQs
for
mancozeb's
use
on
sweet
corn,
tomatoes,
and
wheat
ranging
from
1.05
to
2.29.
Chronic
freshwater
invertebrate
effects
were
due
to
immobility,
length
and
time
until
first
brood
in
daphnia.
The
acute
estuarine/
marine
fish
RQs
for
mancozeb
uses
on
apples,
tomatoes,
and
wheat
exceed
endangered
species
LOCs
ranging
from
0.05
to
0.13.
Estuarine/
marine
invertebrate
acute
RQs
exceed
LOCs
ranging
from
4.46
to
20.08.

EFED
does
not
calculate
risk
quotients
to
conduct
risk
assessments
on
terrestrial
invertebrates.
Since
mancozeb
is
practically
nontoxic
to
honeybees
(
acute
contact
LD
50
>
178
µ
g/
bee),
EFED
expects
a
low
acute
risk
to
nontarget
terrestrial
insects.
A
nonguideline
study
determined
that
mancozeb's
LR
50
(
residue
concentration
causing
50%
lethality)
for
Typhlodromus
pyri
(
a
beneficial
mite)
is
0.1
lb
active
ingredient/
A
and
the
LOAEC
which
can
be
expected
to
cause
adverse
reproductive
effects
is
0.02
lb
active
ingredient/
A.
Based
on
current
registered
mancozeb
application
rates
and
the
toxicity
shown
from
this
study,
potential
adverse
effects
to
Typhlodromus
pyri
from
mancozeb's
uses
may
occur.
Due
to
lack
of
data
EFED
did
not
assess
risks
to
terrestrial
plants
or
fully
assess
risks
to
aquatic
plants.
Based
on
data
for
one
surrogate
species,
mancozeb's
use
patterns
exceed
acute
risk
LOCs
for
nonvascular
aquatic
plants
with
acute
RQs
ranging
from
1.00
to
4.49.
EFED
did
not
assess
chronic
risks
to
estuarine/
marine
fish
and
invertebrates
due
to
lack
of
data.

Mancozeb
is
a
non­
systematic
fungicide
applied
to
foliage
for
the
control
of
fungal
diseases
on
numerous
crops,
a
forestry
use
on
douglas
firs,
ornamental
plantings,
and
turf.
The
proposed
maximum
application
rates
for
the
major
crops
are16.8,
19.2
and
24
lbs
a.
i/
acre/
crop
cycle
for
tomatoes,
squash,
and
onions;
and
11.2
and
19.2
lbs
a.
i/
acre/
year
for
potatoes
and
pears,
respectively.
3
In
this
document
three
important
abbreviations
are
used:
Parent
mancozeb,
Mancozeb
Complex
and
Bound
species.
Parent
mancozeb
is
the
polymeric
Parent
mancozeb
present
in
the
active
ingredient.
Mancozeb
Complex
is
a
suite
of
multi
species
complexes
resulting
from
degradation
of
the
polymeric
Parent
mancozeb.
The
suite
includes
the
following:
(
a)
species
reported
to
be
present
but
not
specifically
identified:
variable/
low
molecular
weight
polymeric
chains
(
i.
e
polymer
fragments),
monomeric
species,
and
EBDC
ligand
in
association
with
other
metal
ions
that
might
be
present
in
the
environment;
(
b)
species
identified
and
quantified:
Transient
species,
ETU
and
ETU
degradates;
and
(
c)
un­
identified
species
that
bound
to
soil
and
sediment
particles
(
referred
to
as
Bound
species).

2
Mancozeb
is
applied
as
a
broadcast
treatment
using
both
air
and
ground
equipment,
used
as
a
root
dip
treatment,
and
has
numerous
seed
treatment
uses.

Repeated
application
of
mancozeb
onto
many
crops
cause
it
to
reach
terrestrial
environments
as
Parent
mancozeb3
and
given
time
and
abundance
of
moisture
as
Mancozeb
Complex.
Assuming
similar
toxicity
for
parent
and
the
complex
and
based
on
available
screening
level
information,
there
is
a
potential
concern
for
mancozeb's
acute
and
chronic
effects
on
listed
Endangered
and
Threatened
species
of
freshwater
animals,
acute
effects
on
listed
estuarine/
marine
fish,
and
chronic
effects
on
listed
birds
and
mammals
should
exposure
actually
occur.

Mancozeb
is
a
coordination
product
of
Zn+
2
ions
and
manganese
ethylenebisdithiocarbamate.
Foliar
application
of
mancozeb
cause
it
to
reach
plant/
soil
surfaces
directly
and
air/
water
bodies
by
drift.
In
the
air,
mancozeb
will
eventually
be
deposited
onto
soil/
plant/
water
bodies
with
minimal
change.
On
plant
surfaces,
it
is
affected
by
physical
wash­
off
and
abiotic
hydrolytic
decomposition
given
time
and
water
availability.
Fate
of
mancozeb
reaching
the
soil
and
water/
sediment
systems
is
controlled
by
hydrolytic
decomposition
and
soil/
sediment
adsorption.

Parent
mancozeb
(
complete
polymeric
chains)
is
non­
persistent
in
most
of
the
natural
environments
as
it
is
expected
to
decompose
rapidly
(
reach
<
10%
of
the
applied
within
3
days)
by
hydrolytic
reactions.
Initial
hydrolytic
decomposition
of
mancozeb
appears
to
be
a
complex
process
and
may
involve
its
breakdown
into
variable/
low
molecular
weight
polymeric
chains
(
i.
e
polymer
fragments),
monomeric
species
and
EBDC
ligand
in
association
with
metal
ions.
The
rate
of
Parent
mancozeb
hydrolytic
decomposition
appears
to
increase
with
particle
size
reduction
of
the
applied
parent
and
availability
of
moisture,
oxygen,
and
presence
of
high
acidic
and
neutral
conditions.
The
final
product
of
hydrolytic
decomposition
of
Parent
mancozeb
in
water/
soil
pore
water
is
a
multi
species
complex
hereinafter
is
referred
to
as
the
"
Mancozeb
Complex".
Parent
mancozeb
is
not
expected
to
partition
into
the
air
from
soil
and
water
surfaces
due
to
low
vapor
pressure
and
low
Henry's
Law
constant.
Low
K
ow
values
are
reported
for
mancozeb,
therefore
the
chemical
will
not
be
significantly
bioconcentrated
by
aquatic
organisms
such
as
fish.

In
contrast,
Mancozeb
Complex
consists
of
transient
species
and
degradates
including
the
degradate
of
concern,
ETU
and
its
degradates.
In
aqueous
media,
transient
species
are
short­
lived
while
ETU
is
persistent;
unless
it
is
subjected
to
rapid
degradation
by
microbes
and/
or
indirect
photolysis.
In
soils/
sediments,
a
significant
portion
of
the
complex
partitions
into
the
soil/
sediment
particles
(
reached
55
to
70%
of
the
applied
parent
within
one
week).
In
these
systems,
species
identified
in
the
liquid/
extractable
phase
were
similar
in
identity
(
differ
in
concentration)
to
these
identified
in
aqueous
media.
Species
bound
to
soil/
sediment
were
poorly
characterized
and
claimed,
by
the
registrant,
to
3
be
dominated
by
ethylene
diamine
(
EDA).
In
the
absence
of
experimental
proof
of
EDA
or
complete
characterization
of
these
bound
species,
EFED
is
concerned
about
the
complex
as
it
is
persistent
and
could
contain
precursors
for
ETU.

Mancozeb
Complex
species
in
association
with
soil/
sediment,
appear
to
bio­
degrade
at
a
very
slow
rate
producing
mancozeb
degradates
including
ETU.
Complex
species
left
in
the
liquid
phase
may
continue
to
be
affected
by
hydrolytic
decomposition
along
with
microbial
activity
producing
degradates
including
ETU.
Submitted
fate
and
effects
data
are
adequate
to
characterize
the
environmental
fate
and
transport,
toxicity,
and
risk
of
the
"
multi
species
complex"
of
mancozeb
as
a
whole.
Based
on
submitted
fate
data,
most
of
the
constituents
of
this
complex
are
immobile
and
highly
persistent
in
the
environment,
with
aerobic
soil
metabolism
being
the
major
route
of
its
slow
dissipation.
As
mancozeb
and
its
complex
dissipate
in
aquatic
and
soil
systems,
degradation
products
are
produced
including
ETU.

Since
limited
data
were
available
to
evaluate
the
foliar
dissipation
of
mancozeb,
EFED
relied
on
a
default
total
foliar
dissipation
half­
life
of
35
days
to
evaluate
exposure
to
terrestrial
organisms.
The
stressor
in
this
case
is
Parent
mancozeb
although
hydrolytic
reactions
on
foliage
may
result
in
the
presence
of
Mancozeb
Complex
as
well.
Terrestrial
exposure
was
quantified
as
Estimated
Environmental
Concentrations
(
EECs)
by
modeling
for
the
maximum
application
rates.
For
the
aquatic
environment,
the
main
stressor
is
the
Mancozeb
Complex
and
its
EECs
were
estimated
using
tier
2
PRZM/
EXAM
modeling
for
the
various
crop
scenarios.
Drinking
water
assessment
was
performed
only
for
ETU
(
refer
to
the
accompanied
ETU
document);
the
degradate
of
concern
present
in
the
complex.

EFED
needs
data
to
characterize
the
risk
to
nontarget
terrestrial
plants.
Acutely,
mancozeb
is
practically
nontoxic
to
mammals
(
rat
acute
oral
LD
50
>
5,000
mg/
kg)
and
slightly
to
practically
nontoxic
to
avian
species.
EFED
expects
the
acute
risk
to
mammals
from
mancozeb's
uses
to
be
low
since
mancozeb
is
acutely,
practically
nontoxic
to
mammals.
Although
there
are
no
avian
dietary
feeding
studies
available,
EFED
expects
the
mancozeb's
acute
risk
to
birds
feeding
on
foliage,
seeds
or
insects
to
be
low.
The
reasoning
for
this
expectation
are
as
follows.
First,
the
multiple­
dose
oral
toxicity
studies
for
mancozeb
on
birds,
provided
LD
50
values
ranging
from
about
1,500
ppm
for
starlings
to
greater
than
6,400
ppm
for
mallard
ducks
and
Japanese
quail.
These
studies
categorized
mancozeb
as
slightly
to
practically
nontoxic
to
birds.
Second,
the
multiple­
dose
oral
toxicity
studies
were
initially
intended
to
be
dietary
feeding
studies
but
at
treated
feed
levels,
sufficient
to
determine
an
LC
50
,
the
birds
showed
an
aversion
to
eating
the
mancozeb
treated
feed.
Third,
if
an
LC
50
level
could
be
determined
for
mancozeb,
EFED
expects
it
would
be
comparable
to
metiram
or
maneb.
The
avian
LC
50
for
metiram
ranges
from
4,650
ppm
in
mallard
ducks
to
greater
than
4,650
ppm
in
bobwhite
quail
which
classifies
metiram
as
slightly
toxic.
The
avian
LC
50
for
maneb
ranges
from
greater
than
5,000
ppm
for
mallard
ducks
to
greater
than
10,000
ppm
for
bobwhite
quail
which
classifies
maneb
as
practically
nontoxic.
Finally,
there
are
no
incidents,
on
record,
that
show
mancozeb
has
been
responsible
for
bird
kills
or
poisonings.
EFED
does
not
believe
that
mancozeb's
acute
toxicity
is
the
major
issue
of
concern
for
birds
or
mammals.
EFED
expects
the
potential
chronic
risks
to
birds
and
mammals
to
be
a
more
critical
issue
than
the
acute
risks
from
mancozeb's
exposure
with
chronic
LOCs
exceeded
for
all
uses.
There
is
a
low
risk
concern
that
mancozeb
poses
an
acute
risk
to
nontarget
insects
because
mancozeb
is
practically
nontoxic
to
honeybees,
(
acute
contact
LD
50
>
178
µ
g/
bee).
Also,
there
is
no
incident
data
reporting
adverse
effects
to
honeybees
4
from
mancozeb's
use.
Potential
adverse
effects
to
Typhlodromus
pyri
(
a
beneficial
mite)
from
mancozeb's
uses
may
occur.
EFED
is
uncertain
about
mancozeb's
risk
to
non­
target
terrestrial
plants
and
needs
testing
performed
at
mancozeb's
maximum
rate
of
application
in
the
environment.

EFED
needs
data
to
characterize
Mancozeb
Complex's
chronic
risks
to
estuarine
or
marine
animals,
and
acute
risks
to
aquatic
vascular
plants.
Based
on
limited
data,
EFED
expects
Mancozeb
Complex
to
pose
a
potential
acute
risk
to
freshwater
fish,
freshwater
invertebrates,
estuarine/
marine
fish,
estuarine/
marine
invertebrate,
and
nonvascular
aquatic
plants.
The
RQs
also
exceed
chronic
LOCs
for
freshwater
fish
and
freshwater
invertebrates
presenting
a
potential
chronic
risk
to
these
organisms
.
5
II.
Introduction
Mancozeb
is
a
broad
spectrum
fungicide
belonging
to
a
chemical
class
of
polymeric
dithiocarbamates
and
a
group
classified
as
ethylene
bis
dithiocarbamate
(
EBDC)
fungicides.
It
is
a
non­
systemic,
contact,
fungicide
with
preventive
activity.
Mancozeb
is
marketed
by
several
companies
under
varied
names
and
formulations.
Formulation
types
include
dusts,
water
dispersible
granules
(
i.
e.
dry
flowables),
flowable
concentrates
and
wettable
powders.

a.
Use
Characterization
Currently,
there
are
110
registered
products
containing
mancozeb:
1
manufacturing­
use
product,
37
end­
use
products
(
EUP)
and
72
special
local
need
(
24­
c)
registrations
(
OPP
REFs
data
1999).
Registered
products
contain
either
multiple
or
single
active
ingredient.
A
synopsis
of
the
use
pattern
for
this
chemical
is
provided
in
Table
II­
1.

Table
II­
1.
Mancozeb
use
patterns.

Crop
Maximum
Application
Rate
Number
of
Applications
Minimum
Application
Interval
(
day)
Per
Treatment
In
Total
Apples,
Cranapple,
Pear
&
Quince
4.8
lbs
a.
i./
acre
19.2
lbs
a.
i./
acre/
year
4
7
Asparagus
1.6
lbs
a.
i./
acre
6.4
lbs
a.
i./
acre/
crop
cycle
4
10
Bananas
&
Plantain
2.4
lbs
a.
i./
acre
24
lbs
a.
i./
acre/
crop
cycle
10
14
Barley,
Oats,
Rye,
Triticale
&
Wheat
1.6
lbs
a.
i./
acre
4.8
lbs
a.
i./
acre/
crop
cycle
3
7
Caprifig
3.2
lbs
a.
i./
100
gal
dip
treatment
1
Not
applicable
Citrus
0.9
lbs
a.
i./
acre
Not
specified
7
Corn
(
unspecified)
(
East
of
the
Mississippi
River)
1.2
lbs
a.
i./
acre
18
lbs
a.
i./
acre/
crop
cycle
15
4
Corn
(
unspecified)
(
West
of
the
Mississippi
R.)
1.2
lbs
a.
i./
acre
12
lbs
a.
i./
acre/
crop
cycle
10
4
Cotton
1.6
lbs
a.
i./
acre
6.4
lbs
a.
i./
acre/
crop
cycle
4
10
Cranberry
4.8
lbs
a.
i./
acre
14.4
lbs
a.
i./
acre/
year
3
7
Cucumber
2.4
lbs
a.
i./
acre
19.2
lbs
a.
i./
acre/
year
8
7
Fennel
1.6
lbs
a.
i./
acre
12.8
lbs
a.
i./
acre/
year
8
7
Flax
0.4
lbs
a.
i/
100
lbs
seed
(
Seed
treatment)
1
Not
applicable
Grapes
(
East
of
the
Rocky
Mountains)
3.2
lbs
a.
i./
acre
19.2
lbs
a.
i./
acre/
year
6
7
Grapes
(
West
of
the
Rocky
Mountains)
2.0
lbs
a.
i./
acre
6.0
lbs
a.
i./
acre/
year
3
7
Melons
&
Squash
2.4
lbs
a.
i./
acre
19.2
lbs
a.
i./
acre/
crop
cycle
8
7
Onion,
Garlic,
&
Shallot
2.4
lbs
a.
i./
acre
24
lbs
a.
i./
acre/
crop
cycle
10
7
Papaya
2.0
lbs
a.
i./
acre
28.0
lbs
a.
i./
acre/
year
14
5
Peanuts
1.6
lbs
a.
i./
acre
12.8
lbs
a.
i./
acre/
crop
cycle
8
7
Pineapple
25.6
lbs
a.
i/
acre
(
Pre­
plant
dip
treatment)
1
Not
applicable
Potato
&
Sugar
Beet
1.6
lbs
a.
i./
acre
11.2
lbs
a.
i./
acre/
year
7
5
Rice
0.2
lbs
a.
i/
100
lbs
seed
(
Pre­
plant
seed
treatment)
1
Not
applicable
Crop
Maximum
Application
Rate
Number
of
Applications
Minimum
Application
Interval
(
day)
Per
Treatment
In
Total
6
Safflower
0.1
lbs
a.
i/
100
lbs
seed
(
Pre­
plant
seed
treatment)
1
Not
applicable
Sorghum
0.2
lbs
a.
i/
100
lbs
seed
(
Pre­
plant
seed
treatment)
1
Not
applicable
Tobacco
2.0
lbs
a.
i./
acre
Not
specified
5
Tomato
2.4
lbs
a.
i./
acre
16.8
lbs
a.
i./
acre/
crop
cycle
7
7
Vegetables
a
1.5
lbs
a.
i./
acre
Not
specified
7
Forestry
(
Douglas
Fir)
3.2
lbs
a.
i./
acre
Not
specified
14
Ornamental
Trees
(
Christmas
tree
plantations)
3.2
lbs
a.
i./
acre
Not
specified
14
Ornamentals
b
1.6
lbs
a.
i./
acre
Not
specified
7
Ornamentals
(
pachysandra
­
groundcover)
13.9
lbs
a.
i./
acre
69.5
lbs
a.
i./
acre/
crop
cycle
5
10
Turf
(
golf
course)
17.4
lbs
a.
i./
acre
Not
specified
5
Turf
c
19.0
lbs
a.
i./
acre
Not
specified
5
a
Beets
(
unspecified),
Broccoli,
Brussel
sprouts,
Cabbage,
Carrots,
Cauliflower,
Chard
(
Swiss,
Collards,
Coriander,
Dill,
Endive,
Kali,
Kohlrabi,
Leeks,
Lettuce,
Mustard,
Mustard
Cabbage,
Parsley,
Parsnip,
Radish,
Rape,
Roquette
(
Arugula),
Rutabaga,
Spinach
&
Turnip.
b
Trees,
Herbaceous
plants,
Nonflowering
plants
&
Woody
shrubs
and
Vines.
c
Commercial/
Industrial,
Sod
farm
&
Residential.

The
Environmental
Fate
and
Effects
Division
(
EFED)
utilized
OPP's
Label
Use
Information
System
(
LUIS)
(
updated
as
of
12/
14/
01),
OPP's
Reference
Files
System
(
REFS),
the
Mancozeb
Use
Closure
Memo
dated
4/
21/
99,
and
spot
checking
of
currently
registered
mancozeb
labels
to
determine
what
mancozeb
use
patterns
posed
the
most
significant
risk
to
the
environment.
EPA
use
data
(
BEAD's
Quantitative
Usage
Analysis
for
Mancozeb
dated
11/
24/
1998)
for
the
period
1987­
1996
shows
that
56%
of
the
tomatoes,
51%
of
the
squash,
42%
of
the
onions,
35%
of
the
potatoes
and
31%
of
the
pears
grown
in
the
US
are
treated
with
mancozeb.
EPA
use
data
(
BEAD's
Quantitative
Usage
Analysis
for
Mancozeb
dated
November
1,
2002)
for
the
period
1992­
2001,
shows
that
49%
of
the
fresh
tomatoes,
12%
of
processed
tomatoes,
41%
of
the
squash,
39%
of
the
onions,
36%
of
the
potatoes
and
32%
of
the
pears
grown
in
the
United
States
are
treated
with
mancozeb.
Figure
II­
1
shows
the
general
use
areas
for
mancozeb
across
the
US.
The
estimates
are
based
on
state­
level
of
pesticide
use
rates
for
individual
crops,
which
have
been
compiled
by
the
National
Center
for
food
and
agricultural
policy
(
NCFAP)
for
1991­
1993
and
1995,
and
on
county­
based
acreage
data
obtained
from
the
1992
census
of
agriculture.
7
Figure
II­
1.
Estimated
annual
use
of
mancozeb
in
the
U.
S.

b.
Approach
to
Risk
Assessment
The
risk
assessment
for
mancozeb
and/
or
its
complex
(
i.
e
stressors)
is
executed
in
two
tasks
namely,
the
ecological
and
the
drinking
water
resource
risk
assessments.
Each
of
these
tasks
contains
four
common
steps
and
differ
in
the
last
fifth
step.

The
first
common
step
in
the
plan
involves
examination
of
the
application
procedure
in
order
to
identify
major
source(
s)
of
chemical
contamination
to
important
compartments
of
the
environment.
It
also
involves
determination
of
expected
chemical
distribution
in
these
compartments.

The
second
common
step
involves
examination
of
the
fate
and
transport
data
to
identify
various
chemicals
and
processes
involved
in
transformation
and
transport
of
Parent
mancozeb
and/
or
Mancozeb
Complex.

The
third
common
step
requires
identification
of
important
stressor(
s)
that
are
involved
in
ecological
and
water
resource
exposure.
For
example,
execution
of
the
first
three
steps
in
the
analysis
plan
for
mancozeb
indicates
that
the
major
ecological
stressor
is
Parent
mancozeb
for
terrestrial
nontarget
species
and
Mancozeb
Complex
for
aquatic
nontarget
species.
Data
and
information
used
to
arrive
8
at
these
conclusions
are
covered
in
various
sections
of
this
document:
Introduction
for
the
first
step,
Environmental
Fate
and
Transport
characterization
for
the
second/
third
steps.

The
fourth
common
step
is
to
quantify
the
environmental
exposure
for
identified
stressors
by
calculating
EECs.
For
the
terrestrial
exposure,
EECs
were
generated
from
the
FATE
version
5.0
model
that
calculates
the
decay
of
a
chemical
applied
to
foliar
surfaces
for
single
or
multiple
applications.
The
model
assumes
initial
concentrations
on
plant
surfaces
based
on
Kenaga
predicted
maximum
and
mean
residues
as
modified
by
Fletcher
et
al.
(
1994)
and
assumes
1st
order
dissipation.
Kenaga
estimates
and
an
explanation
of
the
model
with
sample
output
are
presented
in
Appendix
II.

EFED
needs
total
foliar
dissipation
residue
or
total
foliar
residue
(
TFR)
half­
life
information
as
a
modeling
input
value
to
estimate
terrestrial
wildlife
exposure.
TFR
is
the
total
pesticide
residue
contained
both
on
the
surface
and
absorbed
into
treated
leaves.
EFED
has
no
requirements
for
submitting
such
data,
now,
and
relies
on
available
half­
life
data
chiefly
from
Willis
and
McDowell
(
1987).
Since
mancozeb
TFR
half­
life
information
was
not
available
from
Willis
and
McDowell
(
1987)
EFED
sought
surrogate
information
from
HED.
HED
receives
dislodgeable
foliar
residue
(
DFR)
dissipation
half­
life
data
(
guideline
875.2100)
to
estimate
exposures
to
individuals
that
occur
from
working
in
an
environment
that
has
been
treated
with
a
pesticide
(
also
referred
to
as
reentry
exposure).
DFR
is
the
amount
of
pesticide
residue
on
treated
leaves.
For
mancozeb
HED
(
Dole
and
Dawson,
2003)
provided
the
following
(
Table
II­
2)
with
MRID
Nos.
The
Mancozeb
Task
Force
provided
the
Biswis
and
Newsome
studies
through
a
literature
submission
(
Ollinger,
2005).

Table
II­
2.
Summary
of
Mancozeb
DFR
&
TFR
Data
for
Crops
MRID
(
Year)
CROP
(
Location)
Application
Method
Lb
ai/
acre
DFR
Half
Life
(
Days)
TFR
Half
Life
(
Days)

449596­
01(
99)
418369­
01(
91)
411339­
01(
86)
411339­
01(
86)
CA
Grapes
(
Poplar)
CA
Grapes
(
Biola)
CA
Grapes
(
Madera)
CA
Grapes
(
Fresno)
Airblast
Airblast
Airblast
Airblast
1.9
+
2.0
(
7
days)
1
3.2
*
3
(
1
month)
2
3.2
*
3
3.2
*
3
17.8
35.4
15.2
9.6
Not
available
Not
available
14.9
9.3
449617­
01(
99)
NC
Green
House
Tomatoes
Handgun
2.3
+
2.3
(
7
days)
10.1
Not
available
449596­
02(
99)
449596­
02(
99)
NY
Apples
WA
Apples
Airblast
Airblast
5.0
+
5.0
(
7
days)
5.0
+
5.0
(
7
days)
9.4
21.9
Not
available
Not
available
418369­
02(
91)
418369­
02(
91)
449596­
03(
99)
449596­
03(
99)
425602­
01(
91)
Biswis,
et
al.
2003
Biswis,
et
al.
2003
Newsome,
1976
Newsome,
1979
Newsome,
1979
CA
Field
Tomatoes
MD
Field
Tomatoes
CA
Field
Tomatoes
FL
Field
Tomatoes
FL
Field
Tomatoes
India
Tomatoes
India
Tomatoes
Canada
Tomatoes
Canada
Tomatoes
Canada
Tomatoes
Groundboom
Airblast
Groundboom
Groundboom
Groundboom
Backpack
Backpack
Groundboom
Groundboom
Groundboom
2.4
*
3.0
(
10
days)
2.3
*
5
(
7­
15
days)
1.7
+
1.7
(
6
days)
2.5
+
2.5
(
6
days)
2.3
*
3.0
(
7
days)
1.3
*
3
(
15
days)
2.7
*
3
(
15
days)
2.4
*
7
(
7
days)
1.2
*
7
(
7
days)
2.4
*
7
(
7
days)
11.7
9.9
6.3
4.9
8.1
Not
available
Not
available
Not
available
Not
available
Not
available
Not
available
Not
available
Not
available
Not
available
Not
available
1.63,4
2.04
7.73,4
11.23,4
9.13,4
449585­
01(
NA)
NC
Bermudagrass
PA
Kentucky
bluegrass
CA
Tall
fescue
Groundboom
Groundboom
Groundboom
16.1
*
1
10.5
*
1
11.3
*
1
3.0
6.6
2.3
Not
available
Not
available
Not
available
Note
1
­
This
means
that
1.9
lb
ai/
acre
was
applied
followed
by
an
application
of
2.0
lb
ai/
acre
7
days
later.
Note
2
­
This
means
that
3.2
lb
ai/
acre
was
applied
3
times
with
an
application
interval
of
one
month
between
each
application.
Note
3
­
Half­
life
values
calculated
by
EFED
from
the
data
provided
in
the
study.
Note
4
­
TFR
was
from
homogenized
samples
of
the
tomato
fruit,
only,
submitted
by
the
Mancozeb
Task
Force
(
Ollinger,
2005).
9
Most
of
these
studies
used
the
standard
dislodging
technique.
The
1986
study
on
grapes
at
Madera
and
Fresno,
California
also
used
the
total
extraction
method
(
T.
Dole,
per.
com.,
9/
13/
01).
Based
on
the
results
of
the
studies
listed
in
Table
II­
2,
EFED
would
expect
a
variation
in
the
half­
life
values
for
mancozeb.
This
variation
would
be
because
of
differences
in
application
methods
such
as
application
rates,
differences
in
crops
such
as
morphology,
and
regional
differences
such
as
weather.
HED's
review
showed
the
effects
of
climate
was
a
greater
effect
than
the
effects
of
crop
morphology
or
application
method.
"
The
EBDC
and
ETU
half
lives
were
typically
twice
as
long
in
the
west
as
in
the
east..."(
Dole
and
Dawson,
2003a).

Based
on
this
limited
information
EFED
expects
the
mancozeb
DFR
half­
life
would
be
comparable
to
the
mancozeb
TFR
half­
life
since
the
1986
study
on
grapes
at
Madera
and
Fresno,
California
showed
similar
DFR
and
TFR
half­
lives.
EFED
might
not
expect
such
a
likeness
if
the
pesticide
was
systemic
but
none
of
the
EBDCs
are
systemic.
The
tomato
DFR
half­
lives
are
from
tomato
leaves
whereas
the
tomato
TFR
data
is
from
tomato
fruit.
The
tomato
fruit
is
more
appropriately
termed
a
raw
agricultural
commodity
(
RAC).
The
tomato
DFR
and
TFR
half­
life
values
are
not
exactly
comparable
even
though
the
half­
life
values
are
in
the
same
general
range
(
that
is,
4.9
to
11.7
days
for
the
leaves
and
1.6
to
11.2
days
for
the
fruit).

The
1991
study
on
grapes
in
Biola,
California
shows
a
35.4
day
DFR
half­
life
at
the
maximum,
allowable,
mancozeb
single
application
rate
for
grapes.
This
35.4
day
DFR
half­
life
is
the
longest
mancozeb
DFR
half­
life
value
shown
in
Table
II­
2
and
is
comparable
to
the
upper
limit
of
pesticide,
TFR
half­
lives
provided
in
the
half­
life
listing
of
Willis
and
McDowell
(
1987).
EFED
routinely
uses
the
upper
limit
of
TFR
half­
life
values
(
that
is,
35
days)
provided
in
Willis
and
McDowell
(
1987)
to
perform
screening
level
risk
assessments.
EFED
believes
mancozeb's
DFR
half­
life
would
be
comparable
to
the
mancozeb's
TFR
half­
life
for
most
crops.
The
highest
DFR
value
shown
in
Table
II­
2
is
35.4
days.
It
is
reasonable
to
use
this
high­
end
estimate
(
that
is,
35
days)
in
this
screening
level
assessment.
It
is
reasonable
because
it
is
the
highest,
most
conservative,
half­
life
value
and
the
data
available
is
limited.
Mancozeb
is
used
on
more
than
20
crop
grouping
(
see
Table
II­
1)
or
more
than
40
crops.
The
DFR
studies
in
Table
II­
2
provide
half­
life
information
on
4
crops
(
that
is,
grapes,
apples,
tomatoes,
and
turf)
and
TFR
half­
life
information
on
2
crops
(
that
is,
grapes
and
tomatoes).
Given
this
limited
information
EFED
feels
it
is
reasonable
to
use
a
35­
day
TFR
half­
life
for
mancozeb
as
a
conservative
upper­
bound
estimate
in
this
screening
level
assessment.

For
the
aquatic
environments,
Parent
mancozeb
is
short­
lived
as
shown
from
half­
lives
calculated
from
registrant­
submitted
hydrolysis
studies.
With
the
exception
of
low
water
field
capacity
soils
in
very
dry
environments,
expected
environmental
concentrations
(
EECs)
for
the
parent
are
very
low.
Parent
EECs
were
calculated
using
the
hydrolysis
1st
order
rate
constant.
Parameters
determined
from
environmental
fate
studies
and
information
on
physicochemical
properties
were
used
in
estimating
EECs
of
the
resultant
Mancozeb
Complex.
This
complex
rather
than
parent
was
considered
to
be
the
stressor
in
aquatic
environments.
Because
monitoring
data
from
field
locations
are
not
available
for
mancozeb,
the
aquatic
exposure
EECs
are
based
on
results
of
the
linked
PRZM
(
Pesticide
Root
Zone
Model
version
3.1.2
beta;
Carsel
et
al.,
1997)
and
EXAMS
(
Exposure
Analysis
Modeling
System
version
2.98.04;
Burns,
2002)
used
with
crop­
specific
screening
scenarios.
Environmental
fate
parameters
used
in
the
linked
PRZM
and
EXAMS
models
and
the
predicted
EECs
can
be
found
in
Appendix
IV.
Modeling
was
performed
using
expected
quantities
of
parent
from
application
(
i.
e.
the
application
rate)
or
the
degradate
of
concern
ETU
that
would
be
produced
from
10
application
of
the
parent.
Applied
quantities
of
parent
or
equivalent
degradates
at
time
zero
were
modeled
to
arrive
at
related
EECs
using
available
physicochemical
and
fate
properties
determined
for
each
chemical.

The
fifth
step
for
drinking
water
assessment,
is
to
communicate
the
EDWCs
results
[
for
ETU,
the
stressor
identified
by
the
MARC
meeting
(
US
EPA,
2002)
as
the
degradate
of
concern]
for
HED.
Details
are
presented
in
the
accompanied
ETU
document
(
the
drinking
water
assessment
memorandum
covering
mancozeb
and
the
other
two
EBDCs:
metiram
and
maneb).
The
fifth
step
for
ecological
risk
assessment,
is
to
use
terrestrial
and
aquatic
EECs
along
with
related
ecological
effects
data
(
i.
e.,
available
terrestrial
and
aquatic
toxicity
data),
to
evaluate
and
characterize
ecological
risk
of
identified/
quantified
stressors
to
the
environment
by
calculating
risk
quotients
(
RQs).
RQs
are
the
ratio
of
estimated
environmental
concentrations
(
EECs)
to
ecotoxicity
values
(
see
Appendix
IV).

When
possible,
EFED
grouped
sites
having
similar
use
patterns
(
application
rates,
timings,
methods,
number
of
applications,
and
intervals
between
applications)
to
evaluate
the
risks.
EFED
does
not
currently
have
a
method
for
estimating
the
exposure
risks
from
the
use
of
mancozeb
on
caprifigs
or
pineapples
as
a
dip
treatment.
EFED
has
not
evaluated
these
risks
in
this
RED.
Mancozeb
has
many
seed
treatment
uses.
EFED
only
evaluated
certain
seed
treatment
uses
in
this
RED
(
see
Appendix
IV).
For
example,
if
the
only
use
of
mancozeb
for
a
particular
site
was
for
seed
treatment
then
EFED
evaluated
the
seed
treatment
use.
However,
if
a
particular
site
had
uses
other
than
seed
treatment
(
for
example,
foliar
applications
to
the
site)
then
EFED
evaluated
the
use
pattern
having
the
highest
exposure
for
that
site.
EFED
has
not
assessed
mancozeb's
chronic
risk
to
plants,
acute/
chronic
risks
to
nontarget
insects,
or
chronic
risk
from
granular/
bait
formulations
to
birds
and
mammals
because
EFED
has
not
developed
risk
quotient
methods
for
evaluating
these
risks.

EFED
looked
specifically
at
the
impact
of
EBDC
usage
on
turf.
Mancozeb
and
Maneb
both
include
turf
on
their
labels,
but
the
actual
usage
is
small
relative
to
other
crops.
Use
of
fungicides
is
generally
minimal
on
sod
farms
with
mancozeb
applied
to
2600
acres
(
about
4
square
miles)
or
about
0.9
percent
of
all
sod
grown
in
the
United
States.
The
average
number
of
fungicide
applications
is
1.9
nationally
with
a
maximum
use
rate
of
about
15
lbs
a.
i/
acre
applied
in
situations
when
either
severe
pest
pressure
conditions
exist,
or
curative
applications
are
utilized.
Typical
application
rates
are
lower.
Additionally,
the
non­
systematic
EBDCs
serve
as
a
rotational
partner
for
the
other
systemic
fungicides
used
in
the
pest
management
program.
Therefore,
risk
associated
with
turf
use
pattern
was
not
assessed
for
aquatic
environments
at
this
screening
level
risk
assessment.

EFED
did
not
calculate
RQs
for
the
acute
risk
to
avian
species
from
multiple
mancozeb
applications.
EFED
didn't
calculate
RQs
because
an
avian
LC
50
has
not
been
determined
from
dietary
exposure.
As
mentioned
in
Appendix
III,
EFED
waived
the
dietary
testing
that
would
have
provided
this
avian
LC
50
because
tests
indicated
birds
had
an
aversion
to
mancozeb
in
the
test
diet.
EFED
feels
the
acute
dietary
risk
to
birds
from
exposure
to
mancozeb
is
low
because
1)
of
this
aversion;
2)
there
was
a
low
acute
toxicity
of
mancozeb
to
birds
in
multiple
dosing
LD
50
studies;
3)
there
are
no
incidents
showing
mancozeb
has
been
responsible
for
bird
kills
or
poisonings;
and
4)
maneb
and
metiram
(
two
chemically
related
compounds)
were
slightly
to
practically
nontoxic
to
birds
in
dietary
LC
50
testing,
11
The
final
step
of
the
analysis
plan
will
decide
what
nontarget
species
are
at
potential
risk,
what
nontarget
species
are
at
a
low
risk,
and
where
areas
of
uncertainty
exists.
The
decision
is
based
on
comparing
calculated
RQs
to
the
level
of
concern
(
LOC).
See
Appendix
IV
for
the
criteria
used
by
EFED
for
determining
potential
risk
to
non­
target
organisms
and
the
subsequent
need
for
possible
regulatory
action.
The
complete
analysis
plan
and
results
are
presented
in
the
following
diagram
which
shows
the
first
five
steps
in
one
page
and
the
last
step
in
the
following
page.
In
the
diagram
for
the
last
step,
multiple
stressors
are
shown
in
blue,
and
the
assessment
endpoints
in
yellow.
The
assessment
endpoints
include
the
potential
short­
term
(
that
is,
acute)
and
long­
lasting
(
that
is,
chronic)
effects
to
categories
of
organisms
that
may
result
because
of
exposure
to
parent
mancozeb
and/
or
its
complex.

Summary
of
the
risk
assessment
procedure
for
mancozeb,
the
first
to
fifth
step:
results
and
conclusions.
12
Summary
of
the
risk
assessment
procedure
for
mancozeb,
the
last
step:
results
and
conclusions.
13
III.
Integrated
Environmental
Risk
Characterization
a.
Overview
of
Environmental
Risk
There
are
potential
chronic
risks
to
birds
and
mammals;
potential
acute
and
chronic
risks
to
freshwater
fish
and
invertebrates;
and
potential
acute
risks
to
estuarine/
marine
fish
and
invertebrates.
EFED
doesn't
perform
RQ
assessments
for
terrestrial
invertebrates;
however,
EFED
assumes
the
acute
risk
to
terrestrial
insects
is
low
because
mancozeb
is
practically
nontoxic
to
honeybees.
Based
on
current
registered
mancozeb
application
rates
and
the
toxicity
shown
there
may
be
potential
adverse
effects
to
T.
pyri
(
a
beneficial
mite).
Due
to
lack
of
data,
EFED
didn't
assess
risks
to
terrestrial
plants
or
chronic
risks
to
estuarine/
marine
fish
and
invertebrates.
Due
to
lack
of
data,
EFED
was
only
able
to
make
a
partial
risk
assessment
for
aquatic
plants.
Based
on
data
for
one
surrogate
species,
there
are
potential
acute
risks
to
nonvascular
aquatic
plants.

Parent
mancozeb
is
insoluble
in
water
but
is
expected
to
decompose
rather
quickly,
by
hydrolytic
reactions,
into
a
multi
species
complex
(
Mancozeb
Complex)
consisting
of
transient
species
and
degradates
including
the
degradate
of
concern
ETU.
Mancozeb
has
low
octanol/
water
partition
coefficients
(
K
ow
)
suggesting
that
it
would
not
be
significantly
bio­
concentrated
by
aquatic
organisms.
Furthermore,
mancozeb
has
a
very
low
vapor
pressure,
thus
indicating
that
volatilization
is
not
an
important
dissipation
pathway.

Due
to
rapid
hydrolytic
decomposition,
Parent
mancozeb
is
expected
to
exist
in
the
natural
environment
for
a
short
duration
(
1­
2
days).
However,
the
rate
of
hydrolytic
decomposition
of
the
parent
is
dependent
on
its
particle
size,
molecular
weight
distribution
as
well
as
on
environmental
factors
such
as
oxygen
concentration,
pH,
moisture,
temperature
and
aging.

Most
of
the
species
present
in
the
Mancozeb
Complex
are
expected
to
partition
into
the
soil/
sediment
particles;
with
varied
strength
of
bonding.
These
soil
associated
materials
are
not
largely
affected
by
abiotic
degradation
but
are
susceptible
to
very
slow
bio­
degradation
further
producing
degradates,
that
might
include
ETU,
at
a
very
slow
rate.

There
is
a
low
risk
concern
that
mancozeb
presents
an
acute
risk
to
birds,
mammals,
or
non­
target
insects
because
of
the
low
mancozeb
toxicity
to
these
organisms.
Also,
there
is
an
absence
of
incident
data
documenting
adverse
effects
from
mancozeb's
current
and
historical
uses.
Based
on
a
nonguideline
study,
EFED
expects
potential
acute
and
chronic
risks
to
Typhlodromus
pyri
(
a
beneficial
mite).
RQs
exceed
all
chronic
LOCs
for
mancozeb's
uses
for
both
birds
and
mammals.
Based
on
limited
data,
EFED
figures
Mancozeb
Complex
presents
an
potential
acute
risk
to
freshwater
fish,
freshwater
invertebrates,
estuarine/
marine
fish,
estuarine/
marine
invertebrate,
and
nonvascular
aquatic
plants
with
LOCs
exceeded.
The
RQs
exceed
chronic
LOCs
for
freshwater
fish
and
freshwater
invertebrates
for
mancozeb's
uses.
EFED
is
uncertain
about
mancozeb's
risk
to
nontarget
terrestrial
plants
and
needs
testing
performed
at
mancozeb's
maximum
rate
of
application
in
the
environment.
EFED
has
not
received
studies
to
evaluate
the
risk
of
Mancozeb
Complex
to
vascular
aquatic
plants.
EFED
has
no
data
to
evaluate
the
chronic
effects
to
estuarine/
marine
organisms.

b.
Key
Issues
and
Uncertainty
4
Marshall,
W.
D.
1977.
J.
Agri.
Food
Chem.
25(
2),
357­
361.

14
i.
Environmental
Fate
EECs
for
Parent
mancozeb
were
estimated
for
water
bodies
using
hydrolysis
half­
lives.
The
same
water
hydrolysis
half­
lives
were
used
for
soils
assuming
sufficient
moisture
is
available
in
soil
pores
for
hydrolysis
to
occur
at
the
same
rate.
Uncertainty
exists
on
whether
half­
lives
used
are
applicable
because
of
uncertainty
related
to
soil
moisture
availability;
soil
moisture
level
is
expected
to
impact
resultant
EECs.
Lower
EECs
are
expected
in
irrigated
and/
or
rain­
fed
soils
with
high
water
holding
capacity
(
WHC)
and
higher
EECs
are
expected
in
low
WHC
soils
under
dry
conditions.
Giving
the
fact
that
mancozeb
is
applied
to
growing
crops,
moisture
is
expected
to
be
available
for
parent
to
hydrolyze
at
an
adjusted
rate
near
or
just
below
that
determined
from
aqueous
hydrolysis
half­
lives.
Other
factors
that
are
known
to
affect
hydrolytic
stability
of
mancozeb
include:
particle
size;
molecular
weight
distribution;
aqueous
media
pH
and
O
2
concentration4;
and
concentration
of
metal
ions.

EECs
for
Mancozeb
Complex
were
estimated
using
the
physicochemical
properties
and
hydrolysis
half­
lives
of
parent
mancozeb
in
addition
to
aerobic
soil
metabolism
half­
lives
and
sorption
coefficients
which
were
assigned
to
this
complex
rather
than
the
parent.
In
all
aerobic
soil
studies
two
separate
sets
of
experiments/
determinations
were
conducted:
the
first
was
to
obtain
data
for
calculating
half­
lives
using
the
CS
2
­
method
to
quantify
the
parent
while
the
second
was
to
characterize
the
degradation
process.
EFED
believes
that
half­
lives
calculated
from
the
first
set
of
experiments/
determinations
represent
hydrolytic
decomposition
of
Parent
mancozeb
rather
than
biodegradation
Rapid
degradation
of
Parent
mancozeb
produces
a
complex,
the
Mancozeb
Complex,
which
appears
to
be
affected
by
slow
degradation
as
indicated
by
production
of
CO
2
.
Part
of
this
complex
may
contain
precursor(
s)
for
the
degradate
of
concern,
ETU
(
US
EPA,
2002).
Therefore,
EFED
used
the
second
set
of
experiments/
determinations
(
radioactivity
data)
for
calculating
half­
lives
and
assigned
it
to
the
Mancozeb
Complex.
Uncertainty
exists
in
these
complex
half­
lives
as
they
are
conservative
and
are
affected
by
the
validity
of
the
assumption
that
the
only
bio­
degradation
of
the
complex
was
represented
by
evolved
CO
2
.
Data
obtained
on
degradates
were
not
used
as
it
were
affected
by
impurities
in
the
test
materials,
hydrolytic
reactions
and
possible
artificial
degradation
during
extraction.

In
this
RED,
aerobic
soil
half­
lives
calculated
from
the
CS
2
­
method
are
considered
to
represent
hydrolysis
of
Parent
mancozeb
into
its
complex
as
modified
by
soil
conditions
(
i.
e.
moisture
content,
pH
and
O
2
concentration).
In
contrast,
half­
lives
calculated
from
evolved
CO
2
are
considered
to
represent
bio­
degradation
of
Mancozeb
Complex
left
in
the
soil
which
appears
to
occur
in
parallel
with
hydrolytic
decomposition
of
the
parent.
Likewise,
calculated
adsorption/
desorption
characteristics
(
K
d
and
K
oc
)
are
thought
to
represent
Mancozeb
Complex
as
it
were
approximated
from
a
column
leaching
study;
with
no
1/
n
value
to
indicate
the
degree
of
non­
linearity
for
the
Freundlich
constant.

In
the
degradation
process
for
mancozeb
Mn
and
Zn
ions/
salts
are
expected
to
dissipate
into
the
environment.
No
data
were
presented
to
evaluate
the
risk
that
might
be
associated
with
this
release
and
therefore,
uncertainty
exists
in
this
aspect
of
risk
assessment.
5
Dry
conditions
is
one
circumstance
that
may
explain
the
high­
end
(>
30
days)
foliar
dissipation
half­
life
values
for
the
EBDCs
in
general.
EFED
expects
differences
in
application
methods
such
as
application
rates,
differences
crops
such
as
morphology,
and
regional
differences
such
as
weather
also
affect
the
foliar
dissipation.
Another
reason
that
may
cause
longer
foliar
dissipation
half­
lives
is
sample
analysis.
Measurements
quantifying
the
foliar
dissipation
half­
life
routinely
use
measurements
of
the
evolved
CS2
in
the
headspace
of
a
sealed
vial.
Such
measurements
quantify
the
sulfur
from
both
the
parent
EBDC
and
the
EBDC
complex
in
the
sample.
This
means
the
EBDC's
foliar
dissipation
half­
lives
result
from
the
presence
over
time
of
both
the
parent
EBDC
and
the
EBDC
complex.

15
Complete
characterization
of
the
fate
of
Mancozeb
Complex
requires
more
information
on
the
various
species
that
constitute
this
complex
including
the
soil/
sediment
bound
species.
Information
needed
are
for
each
of
these
constituents
and
includes:
their
physicochemical
properties
and
the
nature
of
their
association
with
soil/
sediment
particles.

Additional
information
is
presented
in
Appendix
I
detailing
major
problems
in
mancozeb
fate
studies
which
adds
a
degree
of
uncertainty
for
estimated
fate
parameters
for
Parent
mancozeb
and
Mancozeb
Complex,
resultant
EECs,
and
surface
and
groundwater
modeling
results.

ii.
Ecological
Effects
How
does
EFED
expect
mancozeb
to
act
in
the
environment
after
it
is
applied?
Mancozeb
is
applied
to
over
20
different
crop
groupings,
with
forestry,
ornamental
and
turf
uses
(
see
Table
II­
1)
to
control
plant
diseases.
Mancozeb
has
broad
uses
in
the
US
and
because
of
this
EFED
expects
mancozeb
to
come
in
contact
with
non­
target
organisms
across
many
taxa.
EFED
presumes
applications
of
the
mancozeb
will
occur
when
there
is
heavy
plant
disease
pressure.
Heavy
disease
pressure
to
plants
results
when
there
is
high
moisture
from
rains.
These
rains
promote
conditions
for
the
growth
and
propagation
of
fungal
species.
EFED
expects
mancozeb
applications
will
result
in
rapid
degradation
of
mancozeb
to
Mancozeb
Complex
including
ETU
on
plant
surfaces.
EFED
figures
the
hydrolysis
of
the
mancozeb
will
be
variable
but
rather
fast,
that
is,
from
one
day
to
two
weeks.
EFED
assumes
rapid
degradation
will
occur
because
the
treated
plants
are
likely
to
either
be
wet
during
the
application
or
shortly
after
a
mancozeb
application.
All
the
mancozeb
uses
as
shown
in
Table
II­
1
need
repeat
applications
because
mancozeb
is
short­
lived
in
the
environment
as
shown
from
half­
lives
calculated
from
registrant­
submitted
hydrolysis
studies.
Except
for
applications
to
dry
soils
in
dry
environments,
EFED
expects
a
rapid
change
of
mancozeb
into
Mancozeb
Complex.
5
What
effect
does
EFED
expect
mancozeb
to
have
on
non­
target
terrestrial
species?
From
a
shortterm
or
acute
exposure
EFED
expects
mancozeb
is
a
low
risk
to
mammals
and
birds.
This
expectation
is
supported
by
toxicological
studies
and
the
lack
of
incident
data.
EFED
expects
mancozeb's
long­
term
or
chronic
effects
on
birds
and
mammals
to
be
a
potential
risk.
This
belief
is
supported
by
toxicological
studies
and
exposure
estimates.
EFED
expects
chronic
problems
that
affect
wildlife
from
the
use
of
mancozeb
would
be
largely
unnoticed
in
the
field
and
thus
EFED
would
not
expect
incident
reports,
from
adverse
chronic
exposure.
Mancozeb's
uses
exceeds
chronic
LOCs
for
terrestrial
animals
(
birds
and
mammals)
for
all
mancozeb
use
patterns
for
all
food
categories
in
birds
and
mammals
except
for
some
seed
categories
for
some
uses.
These
exceedances
occur
on
all
terrestrial
bird
and
mammal
food
items
(
that
is,
short
grass,
tall
grass,
broadleaf
forage,
insects,
fruits,
pods,
and
seeds).
These
chronic
exceedances
extend
throughout
the
application
periods
for
all
uses
ranging
from
more
than
45
days
for
tobacco
and
turf
to
more
than
170
days
for
bananas
and
16
plantain.
In
other
words,
there
are
potential
reproductive
risks
to
birds
and
mammals
from
the
first
application
through
the
last
application
and
beyond
for
all
mancozeb's
uses.

EFED
used
mancozeb's
use
on
tomatoes
as
an
example
(
see
Terrestrial
Risk
Assessment
beginning
on
p.
45).
Currently,
up
to
7
applications
of
mancozeb
are
allowed
to
be
applied
to
tomatoes
every
7
days
during
the
growing
season.
Pheasants,
cottontail
rabbits,
quail,
blackbirds,
deer,
raccoons,
opossums,
skunks,
songbirds,
woodchucks,
crows,
muskrats,
groundhogs,
and
wild
turkeys
all
feed
on
tomato
plant
parts.
As
well
as
feeding,
some
of
these
animals
use
areas
where
tomatoes
are
grown
for
nesting,
brood
rearing,
cover
and
loafing
(
Gusey
and
Maturdo,
1973).
The
applications
of
mancozeb
to
tomatoes
occur
from
seedling
emergence
(
spring)
until
5
days
before
harvest
(
late
summer/
early
fall)
which
coincides
with
the
timing
of
the
wildlife
activities
mentioned.
For
birds
and
mammals
this
potential
risk
begins
on
Day
1
when
mancozeb
is
applied
and
continues
throughout
the
tomato
growing
season
or
for
more
than
79
days
(
see
Figure
VII­
5,
p.
45).
During
this
time
period
there
could
potentially
be
reproductive
risks
to
birds
and
mammals
feeding
on
short
grass,
broadleaf
or
forage
plants,
tall
grass,
fruit,
pods,
seeds
and
insects
should
mancozeb
exposure
actually
occur.
The
studies
used
to
calculate
the
RQs
for
this
assessment
based
birds
chronic
reproductive
effects
on
reductions
in:
egg
production;
early
and
late
embryo
viability;
hatchability;
and
offspring
weight
at
hatch
and
14­
days
of
age.
EFED
based
mammal
reproductive
effects
on
parental
body
weight
decrements,
increased
relative
thyroid
weights,
and
increased
incidence
of
thyroid
follicular
cell
hyperplasia.

Mancozeb
is
practically
nontoxic
to
the
honeybee
from
acute
contact
exposure.
EFED
does
not
perform
risk
quotient
assessments
for
terrestrial
insects.
Based
on
the
lack
of
acute
mancozeb
toxicity
to
honeybees,
EFED
expects
a
low
acute
risk
to
nontarget
terrestrial
insects.
EFED
reviewed
a
nonguideline
mancozeb
study
(
MRID
No.
45577201)
on
a
beneficial
mite,
Typhlodromus
pyri.
T.
pyri
mainly
feeds
on
herbivorous
pest
mites
such
a
European
red
mite,
two­
spotted
spider
mite
and
the
apple
rust
mite.
T.
pyri
can
also
survive
on
alternative
food
sources
such
as
pollen,
fungi
and
plant
juices
when
their
primary
food
sources
are
not
available.
In
other
words,
these
mites
are
an
adaptable,
beneficial
mite.
This
study
determined
that
mancozeb's
LR
50
(
residue
concentration
on
foliage
causing
50%
lethality)
for
T.
pyri
is
0.1
lb
active
ingredient/
A.
The
LOAEC
which
can
be
expected
to
cause
adverse
reproductive
effects
is
0.02
lb
active
ingredient/
A
(
lowest
concentration
tested).
Reproductive
effects
were
based
on
a
reduction
in
mean
number
of
eggs
hatched
per
female.
The
current
maximum
single
application
rate
for
mancozeb
to
apple
orchards
(
where
T.
pyri
is
commonly
found)
is
4.8
lb
active
ingredient/
A
with
a
maximum
of
4
applications
made
per
crop
cycle
at
a
minimum
of
every
7
days.
Based
on
current
registered
mancozeb
application
rates
and
the
toxicity
shown
from
this
study,
should
exposure
to
mancozeb
occur,
there
may
be
potential
adverse
effects
to
T.
pyri.

EFED
has
one
Tier
I
terrestrial
plant
test
that
showed
mancozeb
did
not
adversely
affect
non­
target
terrestrial
plants.
However,
the
application
rate
used
in
this
study
(
that
is,
1.38
lb
ai/
A)
was
below
maximum
labeling
rates
allowed
for
mancozeb
(
for
example,
19.0
lb
ai/
A
on
turf).
EFED
is
uncertain
about
mancozeb's
risk
to
non­
target
terrestrial
plants
and
needs
testing
performed
at
mancozeb's
maximum
rate
of
application
in
the
environment.

What
effect
does
EFED
expect
mancozeb
to
have
on
non­
target
aquatic
species?
EFED
expects
mancozeb
to
reach
aquatic
environments
through
drift
and
runoff
since
mancozeb
is
not
labeled
for
6
Based
on
green
algae,
(
Pseudokirchneriella
subcapitata)
testing.

7The
highest
ETU
RQ
is
0.0005
(
see
EFED's
ETU
chapter).

17
direct
application
to
aquatic
environments.
Mancozeb
has
low
solubility
in
water
(
6­
20
ppm)
but
EFED
expects
it
to
decompose
rather
quickly,
by
hydrolytic
reactions,
into
a
multi­
species
complex
(
Mancozeb
Complex)
consisting
of
transient
species
and
degradates
including
the
degradate
of
concern
ETU.
Once
mancozeb
reaches
the
aquatic
environment
EFED
believes
the
Mancozeb
Complex
will
be
the
portion
of
the
mancozeb
that
is
available
to
aquatic
organisms.
EFED
expects
most
of
the
transient
species
present
in
the
Mancozeb
Complex
to
partition
into
the
sediment
particles
with
varied
strength
of
bonding.
ETU
is
an
important
transformation
product
present
in
the
Mancozeb
Complex.
In
aqueous
media,
transient
species
do
not
last
long
while
ETU
is
persistent
unless
ETU
is
subjected
to
rapid
degradation
by
microbes
and/
or
indirect
photolysis.

Based
on
laboratory
studies
and
modeled
EECs,
calculated
RQs
show
that
Mancozeb
Complex
are
a
potential
acute
risk
to
freshwater
fish,
freshwater
invertebrates,
estuarine/
marine
fish,
estuarine/
marine
invertebrate,
and
nonvascular
aquatic
plants.
EFED
estimated
the
highest
Mancozeb
Complex
aquatic
EEC
expected
from
drift
and
runoff
would
be
210.8
ppb.
Based
on
this
residue
level
and
individual
laboratory
studies
EFED
estimated
the
likelihood
of
adverse
Mancozeb
Complex
effects
to
individual
estuarine/
marine
invertebrates
and
nonvascular
aquatic
plants
was
100%.
EFED
was
unable
to
predict
the
likelihood
of
adverse
Mancozeb
Complex
effects
to
individual
freshwater
fish,
freshwater
invertebrates,
and
estuarine/
marine
fish
because
slope
values
were
not
reported
(
see
Section
VI).

EFED
has
no
data
to
evaluate
the
chronic
effects
to
estuarine/
marine
organisms.
The
chronic
RQs
exceed
LOCs
for
freshwater
fish
for
all
mancozeb's
modeled
uses
(
chronic
RQ
ranges
from
1.00
to
3.33).
The
chronic
RQs
exceed
LOCs
for
freshwater
invertebrates
for
mancozeb's
use
on
sweet
corn,
tomatoes,
and
wheat
(
chronic
RQ
ranges
from
1.05
to
2.29).
The
studies
used
to
calculate
the
RQs
for
this
assessment
based
freshwater
fish
chronic
effects
on
reduced
survival
and
lack
of
growth
effects..
EFED
based
freshwater
invertebrates
chronic
effects
on
immobility,
length
and
time
until
first
brood..

ETU
is
an
important
transformation
product
of
parent
and
its
transformation
products
containing
the
EBDC
ligand.
These
species
are
short­
lived
in
aquatic
media
and
ETU
is
persistent
in
this
media
unless
ETU
is
subjected
to
rapid
degradation
by
microbes
and/
or
indirect
photolysis.
The
ETU
acute
RQs
for
nonvascular
aquatic
plants6,
freshwater
fish
and
freshwater
invertebrates
were
well
below7
the
lowest
LOC
(
endangered
species
LOC
=
0.05)
for
aquatic
organisms.
EFED
does
not
know
how
acutely
toxic
ETU
is
to
estuarine/
marine
fish
or
invertebrates
because
data
hasn't
been
reviewed
for
evaluating
this
hazard.
This
means
the
Mancozeb
Complex,
other
than
ETU,
is
responsible
for
the
acute
toxicity
to
freshwater
fish,
freshwater
invertebrates,
and
nonvascular
aquatic
plants.
EFED
expects
the
acute
toxicity
to
freshwater
fish,
freshwater
invertebrates,
estuarine/
marine
fish
and
nonvascular
aquatic
plants,
from
exposure
to
the
Mancozeb
Complex,
will
not
last
long.
The
acute
fish
studies
have
a
duration
of
96
hours,
while
the
acute
invertebrate
studies
last
48
hours
and
the
nonvascular
aquatic
plant
studies
are
120
hours
in
duration.
Acceptable
aquatic
half­
life
data
is
unavailable
for
most
products
of
the
Mancozeb
Complex.
EFED
expects
mancozeb
to
hydrolyze
quickly
(
that
is,
within
hours)
to
its
residues.
Based
on
this
information,
EFED
expects
the
18
Mancozeb
Complex'
acute
toxicity
to
these
aquatic
organisms
will
last
for
120
hours
but
suspects
this
toxicity
will
rapidly
decline
after
this
time
period
as
these
complexes
degrade
to
ETU.
However,
EFED
expects
there
will
still
be
enough
Mancozeb
Complex
to
present
an
acute
risk
to
estuarine/
marine
invertebrates
and
a
chronic
risk
to
freshwater
fish
and
freshwater
invertebrates.
EFED
expects
the
acute
risk
to
estuarine/
marine
invertebrates
will
persist
because
Mancozeb
Complex
are
very
highly
toxic
to
these
organisms
(
mysid
shrimp
EC50
=
10.5
ppb).
Modeled
Mancozeb
Complex
EECs
for
selected
sites
range
from
4.3
to
16.7
ppb
21
days
after
mancozeb
applications
(
see
Table
V.
2).
This
combination
of
exposure
and
toxicity
suggests
acute
LOCs
could
still
be
triggered
for
estuarine/
marine
invertebrates
21
days
after
mancozeb
is
applied.

EIIS
reported
mancozeb
in
three
fish
kill
incidents
(
see
Table
VI­
3).
One
incident
occurred
in
1970,
another
in
1992
and
the
latest
occurred
in
1995.
In
the
1970
and
1992
incidents,
mancozeb
had
been
applied
with
insecticides
highly
toxic
to
fish
(
thiodan
and
endosulfan)
and,
because
of
sample
analysis,
EFED
classified
mancozeb
as
unlikely
to
have
been
responsible
for
the
these
fish
kills.
The
third
incident
in
1995
involved
an
accidental
mancozeb
spill
into
a
stream
that
was
the
source
water
for
a
salmon
hatchery
which
resulted
in
a
fish
kill
at
the
salmon
hatchery.
Although
no
samples
were
analyzed
(
fish
or
water),
EFED
considered
mancozeb
to
be
a
probable
cause
to
the
kill.
Thus
other
than
the
one
accidental
spill
incident
EFED
has
not
received
incident
reports
showing
adverse
acute
effects
from
Mancozeb
Complex.

c.
Endangered
Species
Conclusions
Based
on
available
screening
level
information,
there
is
a
potential
concern
for
mancozeb's
acute
and
chronic
effects
on
listed
Endangered
and
Threatened
species
of
freshwater
animals,
acute
effects
on
listed
estuarine/
marine
fish,
and
chronic
effects
on
listed
birds
and
mammals
should
exposure
actually
occur.
EFED
is
uncertain
about
mancozeb's
risk
to
endangered/
threatened
non­
target
terrestrial
plants
and
needs
testing
performed
at
mancozeb's
maximum
rate
of
application
in
the
environment.
There
are
no
nonvascular
aquatic
plant
or
estuarine/
marine
invertebrate
species
on
the
endangered
species
list.

d.
Endocrine
Disruption
Concerns
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
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,
mancozeb
and
ETU
may
be
subjected
19
to
additional
screening
and
or
testing
to
better
characterize
effects
related
to
possible
endocrine
disruption.
The
avian
reproductive
studies
reviewed
by
EFED
noted
reproductive
effects
such
as
reductions
in:
egg
production;
early
and
late
embryo
viability;
hatchability;
offspring
weight
at
hatch
and
14­
days
of
age;
and
the
number
of
14­
day
old
survivors.
For
mammals
chronic
effects
were
noted
such
as
decreased
serum
thyroxine
levels
being
the
endpoints
affected
in
females
and
body
weight
decrements,
changes
in
thyroid
hormones,
changes
in
liver
enzymes,
microscopic
changes
in
the
liver
and
thyroids,
increased
absolute
and
relative
thyroid
weights,
and
increased
relative
liver
weights
being
the
endpoints
affected
in
males.
Some
developmental
effects
noted
in
mammals
were
gross
developmental
defects,
central
nervous
system
defects,
skeletal
defects,
cryptorchidism
(
failure
of
one
or
more
testes
to
descend
into
the
scrotum)
,
abortions,
etc.
See
Appendix
III
for
a
detailed
listing
of
the
studies
and
results.
These
effects
noted
in
both
birds
and
mammals
could
be
a
result
of
potential
hormonal
disruptions.
Chronic
testing
in
freshwater
organisms
showed
immobility,
length
and
time
until
first
brood
in
daphnia
and
reduced
survival
and
lack
of
growth
effects
in
fathead
minnow.
See
Appendix
III
for
a
detailed
listing
of
the
studies
and
results.
These
effects
noted
in
freshwater
species
could
be
a
result
of
potential
hormonal
disruptions.

Based
on
these
effects
in
freshwater
fish,
freshwater
invertebrates,
birds
and
mammals,
EFED
recommends
that
when
appropriate
screening
and/
or
testing
protocols
being
considered
under
the
Agency's
EDSP
have
been
developed,
mancozeb
be
subjected
to
more
definitive
testing
to
better
characterize
effects
related
to
its
possible
endocrine
disruptor
activity.
8
Tomlin,
C.
D.
S.
(
ed.).
The
Pesticide
Manual
­
World
Compendium,
11
th
ed.,
British
Crop
Protection
Council,
Surrey,
England
1997
76];
and
Wauchope
R.
D.
et
al.
1991.
Rev
Environmental
Contamination
Toxicology
123:
1­
36.

20
IV.
Environmental
Fate
and
Transport
Assessment
The
fate
of
Parent
mancozeb
was
evaluated
by
considering
data
on
its
hydrolytic
stability.
Practically,
Parent
mancozeb
is
short­
lived,
therefore
it
was
important
to
evaluate
the
fate
and
transport
of
resultant
Mancozeb
Complex
by
its
degradation
processes
in
aqueous
phases
as
well
as
soil
and
field
environments.
Transformation
products
identified
in
fate
studies
were
also
given
the
required
emphasis
here
and
in
the
accompanied
document
for
ETU.

a.
Chemical
Identity
and
Physicochemical
Properties
Table
IV­
1
summarizes
the
important
physicochemical
properties
of
mancozeb.
Mancozeb
is
a
high
molecular­
weight
polymer
(
molecular­
weight
for
each
monomer
unit
is
265)
with
low
water
solubility
(
6­
20
ppm).
The
chemical
structure
of
mancozeb
is
usually
represented
by
one
unit
of
the
polymer;
a
monomeric
Mn+
2
and
Zn+
2
EBDC.
It
has
a
water
solubility
of
6­
13
ppm
accompanied
by
complete
hydrolytic
decomposition
or
degradation.
Low
solubilities
of
6.2­
6.0
ppm
were
reported
elsewhere8
while
the
high
solubility
of
13
ppm
was
reported
by
the
registrant
(
MRID
402582­
01).
Variations
in
reported
solubilities
were
reported
by
the
registrant
to
be
related
to
uncertainties
in
the
analytical
methodology
used
and
the
difficulty
in
measuring
the
water
solubility
for
a
complex
that
is
fundamentally
unstable
in
water.

Volatilization
from
water
and/
or
dry/
moist
soil
surfaces
is
not
expected
to
be
an
important
dissipation
process
based
upon
vapor
pressure
and
calculated
Henry's
Law
constant.
Mancozeb
has
a
low
K
ow
suggesting
that
it
will
not
be
significantly
bio­
concentrated
by
aquatic
organisms
such
as
fish
or
aquatic
invertebrates.
21
Table
IV­
1.
Nomenclature
and
physical
chemical
identity
of
the
mancozeb
complex
and
ETU.

Name
A
coordination
product
of
zinc
ion
and
manganese
ethylenebisdithiocarbamate
Structure
of
Mancozeb
and
its
Main
Degradate
ETU
CAS
Name
((
1,2­
ethanediylbis(
carbamodithioato))(
2­)
Mn
mixture
with
((
1,2­
ethandiylbis(
carbamodithioate))(
2­))
zinc
CAS
Registry
No.
8018­
01­
7
PC
Code
014504
Empirical
Formula
(
C4H6MnN2S4)
x(
Zn)
y;
where
x=
1
and
y=
1/
11
Molecular
Weight
271=
(
265.3)
x
+
(
65.4)
y
Formulated
Products
Dust;
flowable
suspension;
liquid
flowable;
water
dispersible
granules;
wettable
powder
K
OW
21;
based
on
its
reported
log
of
1.33
1
Vapor
Pressure
1.32x10­
10
atm.
@
25
oC
(
Registrant
data);
1.29x10­
10
atm.
1
Henry's
Law
constant1
5.5X10­
9
atm.
m3
mole­
1
(
Calculated
by
reviewer).

Boiling
Point
Stable
under
normal,
dry
storage
conditions.
Slowly
decomposed
by
heat
and
moisture.

Water
Solubility
Decomposes
in
water
to
levels
of
6­
20
ppm
(
MRID
457445­
01).
Reported
as
solubility
values
in
other
references:
6.2
ppm
@
pH
7.5
and
25
oC
2
and
6.0
ppm
3.
1
US
Dept
Agri.
The
Pesticide
Properties
Database
(
on
mancozeb
(
8018­
01­
7;
as
of
Aug
10,
1999).
Available
from:
http://
wizard.
arsusda.
gov/
rsml/
textfiles/
MANCOZEB
2
Tomlin,
C.
D.
S.
(
ed.).
The
Pesticide
Manual
­
World
Compendium,
11
th
ed.,
British
Crop
Protection
Council,
Surrey,
England
1997
76.
3
Wauchope
R.
D.
et
al.
1991.
Rev
Environmental
Contamination
Toxicology
123:
1­
36.

b.
Fate
Processes
Table
IV­
2
contains
a
summary
of
data
obtained
from
guideline
studies
conducted
on
mancozeb.
Submitted
guideline
studies
suggest
that
under
typical
application
rates
into
natural
environment,
Parent
mancozeb
is
expected
to
decompose
(
within
3
days)
by
hydrolytic
reactions
and
resists
both
water/
soil
direct
photolysis
or
volatilization.
Therefore,
hydrolytic
reactions
are
extremely
important
in
the
fate
of
Parent
mancozeb
and
its
decomposition
to
Mancozeb
Complex.

Mancozeb
Complex
consists
of
transient
species,
degradates
and
other
unidentified
materials.
Based
on
data
summarized
in
Table
IV­
2,
the
main
process
involved
in
Parent
mancozeb
dissipation
is
hydrolysis.
In
contrast,
the
main
processes
involved
in
the
fate
of
resultant
Mancozeb
Complex
is
its
strong
affinity
for
adsorption
to
the
soil/
sediment
followed
by
limited
biotic
degradation.
As
a
result
of
bio­
degradation
of
the
complex,
slow
and
continuos
release
of
transient
species
and
degradates
including
ET,
at
low
concentrations,
is
expected
to
occur
over
time.

Mobility
of
Mancozeb
Complex
in
the
natural
environment
is
expected
to
be
limited
because
of
its
strong
affinity
to
adsorption.
In
contrast,
the
degradate
of
concern
(
ETU)
is
predicted
to
be
susceptible
to
leaching
due
to
its
high
solubility
and
mobility.
In
the
soil
environment,
ETU
lacks
22
stability
which
can
limit
its
leaching,
however,
its
slow
and
steady
formation
from
Mancozeb
Complex
can
overcome
the
lack
of
stability
and
make
it
available
for
leaching
at
low
concentrations.

Table
IV­
2.
Environmental
fate
data
summary
for
mancozeb.

Parameter
Value
Source
(
MRID
)

Hydrolysis
Half­
lives,
for
the
process
of
decomposition
by
oxidation
in
water,
depends
on
the
pH
of
the
aqueous
media
as
follows:
Acidic:
t1/
2=
0.8
days
@
pH
5;
Neutral:
t1/
2=
0.7
days
@
pH
7;
Basic:
t1/
2=
1.4
days
@
pH
9.
000971­
62
402582­
01
Photo
lysis
Stable
in
water
(
direct
photolysis),
No
data
for
indirect
photolysis
001621­
03
Stable
on
soil
002639­
07
Aerobic
Soil
Metabolism
Half­
lives
were
calculated
by
EFED
based
on
evolved
CO2:
t1/
2=
121
days
in
Speyer
2.3/
Germany
at
20
0
C,
a
sandy
loam
soil
(
66%
sand,
27%
silt,
7%
clay,
pH
6.5,
0.71%
organic
carbon,
CEC
of
11
meq/
100g
soil,
and
maximum
water
holding
capacity
of
37%).
t1/
2=
161
days
in
Speyer
2.2/
Germany
at
20
0
C,
a
loamy
sand
soil
(
77%
sand,
15%
silt,
8%
clay,
pH
5.7,
2.17%
organic
carbon,
CEC
of
11
meq/
100g
soil,
and
maximum
water
holding
capacity
of
50%).
t1/
2=
143
days
in
Sonozan/
France
at
20
0
C,
a
silty
clay
loam
soil
(
20%
sand,
56%
silt,
24%
clay,
pH
5.8,
0.99%
organic
carbon,
CEC
of
16
meq/
100g
soil,
and
maximum
water
holding
capacity
of
55%).
t1/
2=
198
days
in
Sonozan/
France
at
10
0
C,
a
silty
clay
loam
soil
(
20%
sand,
56%
silt,
24%
clay,
pH
5.8,
0.99%
organic
carbon,
CEC
of
16
meq/
100g
soil,
and
maximum
water
holding
capacity
of
55%).
(
Registrant
calculated
half­
lives
for
all
soils
were
<
1
Hour)
457445­
01
Anaerobic
Soil
No
acceptable
studies.

Aerobic
Aquatic
Metabolism
(
aerobic
water/
anaerobic
sediment)
Initial
review
data:
Half­
lives
for
Mancozeb
Complex
were
calculated
by
EFED
based
on
evolved
CO2:
t1/
2=
111
days
in
a
river
water/
sediment
from
Germany
at
20
0
C,
sediment
contains
81%
sand,
12%
silt,
and
7%
clay;
pH
6.9,
1.35%
organic
carbon,
and
a
CEC
of
3
meq/
100g
sediment.
t1/
2=
391
days
in
a
pond
water/
sediment
from
Germany
at
20
0
C,
sediment
contains
59%
sand,
36%
silt,
and
5%
clay;
pH
6.6,
5.03%
organic
carbon,
and
a
CEC
of
7
meq/
100g
sediment.
Calculate
DT50s
for
Parent
mancozeb
were
>
1
day
due
to
hydrolytic
instability.
462043­
01
Anaerobic
Aquatic
Metabolism
t1/
2=
92
days
000888­
20
Adsorption
Coefficients
(
L
Kg­
1)
Sandy
Loam
Kd
=
3.82
and
KOC
=
1,642
Silty
Loam
Kd
=
11.63
and
KOC
=
1,000
Silty
Loam
Kd
=
22.40
and
KOC
=
860
405883­
02
Field
Dissipation
Half­
life
for
Parent
mancozeb
was
reported
to
equal
3
days
Published
paper*

Accumulation
in
Fish
Waived
because
mancozeb
Kow
is
equal
to
22
23
*
Published
paper:
(
Calampang
S.
et
al,
1993.
International
J.
of
Pest
Management,
39(
2)
161­
166).

i.
Aqueous
media
When
insoluble
Parent
mancozeb
is
suspended
in
an
aqueous
medium
at
concentration
levels
between
6
to13
ppm,
it
decomposes
rather
quickly.
Decomposition
appears
to
occur
by
detachment
of
the
coordinated
EBDC
ligand
from
the
metal
ions
(
most
likely
via
oxidation).
In
turn,
the
free
ligand,
a
soluble
entity,
reacts
with
water
to
produce
transient
species.
Transient
species
further
decompose
into
water
soluble
degradates
dominated
by
ethylene
thiourea
(
ETU).
The
same
process
of
decomposition
appears
to
occur
in
hydrolysis
studies
of
mancozeb
in
water.
In
a
supplemental
28­
day
study,
14C
Mancozeb
at
concentration
level
of
20
ppm
degraded
with
very
short
half­
lives
(<
2
days)
in
sterilized
buffered
aqueous
solutions
of
pH
5,
7,
and
9
when
incubated
in
the
dark
at
25
0C
(
MRID
000971­
62
with
Addendum
402582­
01).
Actual
hydrolytic
half­
lives
were
thought
to
be
probably
shorter
than
calculated
because
of
apparent
anomalies
present
in
TLC
identification/
quantification
of
the
parent
(
refer
to
Appendix
I).
Anomalies
were
also
present
in
TLC
identification/
quantification
of
transient
species
and
degradates,
especially
ETU.
In
this
data,
the
major
degradation
product
at
all
three
pH
levels
was
EU,
reaching
a
maximum
of
38­
47%
of
the
applied
parent
after
two
weeks;
these
levels
of
EU
were
maintained
to
the
date
of
study
termination.
ETU
was
3­
10%
of
the
applied
at
time
zero,
increased
to
a
maximum
of
21­
37%
at
day
2,
and
then
declined
to
1­
7%
at
day
14.
This
data
give
an
estimated
ETU
half­
lives
of
<
1
day
at
pH
5
and
1­
4
days
at
pH
7
and
9
which
conflict
with
data
indicated
ETU
stability
at
the
same
pH
levels
(
MRID
404661­
03).
Other
transient
species
identified
included
EBIS
(
Max
of
5­
21%),
Hydantoin
(
Max
0.5­
20%),
Jaffa's
Base
(
Max
4­
7%),
Ethylenediamine
(
Max
0.3­
6%)
and
two
unknown
species
(
Max
total
of
13­
34%).

Mancozeb
does
not
absorb
light
in
the
range
of
sunlight
and
it
was
found
not
to
undergo
photodegradation
in
water
under
sunlight
conditions
(
MRID
001621­
03).
Observed
degradation
was
related
to
hydrolysis
with
only
small
contribution
of
photo
reactions,
likely
resulting
from
photolytic
reactions
of
transient
chemical
species.
There
are
no
acceptable
data
on
the
degradation
of
mancozeb
in
the
presence
of
photo­
sensitizers
to
assess
the
contribution
of
indirect
photolysis
in
surface
water.
Therefore,
the
photolytic
behavior
of
mancozeb
in
surface
water
is
uncertain.

Guidance
for
both
hydrolysis
and
aqueous
photolysis
studies
calls
for
using
a.
i.
concentrations
within
the
known
solubility
range.
However,
when
mancozeb
is
applied
at
these
low
concentrations,
it
decomposes
resulting
in
no
mancozeb
being
present.
Therefore,
in
such
studies
hydrolysis/
photolysis
rates
of
Parent
mancozeb
can
only
be
determined
with
observed
effects
being
those
related
to
Mancozeb
Complex
(
i.
e.
effects
on
transient
species
and
degradates).

ii.
Soil
The
results
of
the
soil
photolysis
study
conducted
for
mancozeb
suggested
soil
photolysis
is
not
an
important
process
in
the
fate
of
mancozeb
(
MRID
002639­
07).
Interpretation
of
the
results
of
this
study
was
complicated
by
many
factors
including
the
use
of
inappropriate
light
source,
the
expected
effects
of
decomposition
of
parent
in
the
soil
water
and/
or
the
water
used
in
the
extraction
process.

Three
aerobic
soil
studies
were
submitted
for
mancozeb
but
only
one
(
MRID
457445­
01)
was
considered
supplemental
while
the
other
two
were
considered
unacceptable
(
MRID
001621­
05
w/
supplement
408387­
01
and
451452­
01).
Many
reasons
were
sited
for
unacceptability
of
the
studies
24
including:
high
impurity
(
purity
as
low
as
59%)
and
instability
of
the
test
substance,
use
of
formulated
products,
effects
of
extraction
systems
on
the
integrity
of
the
test
substance,
poor
or
nondetermination
of
mass
balance,
incomplete
characterization
of
the
bound
species/
degradation
products,
insufficient
duration,
and
inadequacy
of
the
procedures
used
in
quantifying
the
parent
mancozeb
(
mancozeb
did
not
migrate
from
the
origin
of
the
TLC
plates).

In
the
supplemental
aerobic
soil
study
(
MRID
457445­
01),
three
German
soils
were
treated
with
14C
mancozeb
at
a
rate
of
3.61
ppm,
incubated
under
aerobic
conditions
at
20
±
2
0C
and
40%
of
the
soil
WHC
for
120
days.
Parent
was
identified/
quantified
only
in
the
extract
by
HPLC
with
TLC
confirmation.
Bound
species
was
quantified
by
radioactivity
data
(
reached
a
maximum
range
of
59­
71%
of
the
applied
parent
within
four
weeks
and
decreased
to
a
maximum
range
of
49­
58%
at
the
end
of
the
120­
day
study
period).
This
Bound
species
was
only
characterized
using
a
fulvic/
humic
acid/
humin
fractionation
system.
In
this
study,
Parent
mancozeb
disappeared
rapidly
from
the
three
soils
with
a
half­
life
of
<
1
hour.
The
author
stated
that
Parent
mancozeb
initial
and
rapid
disappearance
implies
that
it
degraded
by
hydrolysis
(
i.
e.
chemical
hydrolysis).
EFED
agrees
with
this
interpretation
which
was
previously
suggested,
by
EFED,
for
all
EBDCs.

Furthermore,
EFED
suggested
a
second
process
to
be
involved
in
mancozeb
degradation
in
aerobic
soil;
a
very
slow
bio­
degradation
occurring
in
parallel
with
the
first
rapid
hydrolysis.
In
this
scheme,
the
first
process
transforms
Parent
mancozeb
into
a
multi
species
complex
(
Mancozeb
Complex)
while
the
second
process
transforms
Mancozeb
Complex
into
further
degradates
and
CO
2
.
Therefore,
a
second
set
of
half­
lives
were
calculated
by
EFED
for
the
Mancozeb
Complex
as
species
present
in
this
complex
can
be
precursors
for
the
degradate
of
concern,
ETU.
For
this
purpose,
EFED
used
the
mass
balance
data
(
radioactivity
data)
and
assumed
that
the
only
bio­
degradation
of
the
complex
was
represented
by
evolved
CO
2
.
EFED
calculated
first
order
half­
lives
for
Mancozeb
Complex
are
summarized
in
Table
IV­
2
and
indicate
that
the
complex
is
moderately
persistent
(
long
half­
lives
in
the
range
of
121­
161
days).

Transformation
products
in
the
acceptable
aerobic
soil
study
(
MRID
457445­
01)
were
identified/
quantified
only
in
the
extract
by
HPLC
with
TLC
confirmation.
The
list
of
metabolites
included:

EBIS
was
detected
in
the
three
soils
at
maximum
amounts
in
the
range
of
3­
29%
of
the
applied
only
1.5
hours
after
application
and
reached
<
1%
of
the
applied
within
1­
4
weeks
(
estimated
half­
life
of
<
0.6
day).

ETU
was
detected
in
the
three
soils
at
maximum
amounts
in
the
range
of
15­
25%
of
the
applied
one
day
after
application
and
decreased
steadily
to
reached
#
2%
of
the
applied
at
the
120­
day
study
(
estimated
half­
life
of
4­
18
days).

EU
was
detected
in
the
three
soils
at
maximum
amounts
in
the
range
of
12­
19%
of
the
applied
1­
7
days
after
application
and
decreased
to
maintain
a
nearly
constant
range
between
<
3
to
<
1%
of
the
applied
to
the
end
of
the
experiment
(
estimated
half­
life
#
3
days).

An
un­
known
metabolite
appeared
only
immediately
after
application
at
concentrations
of
nearly
10%,
reached
a
value
of
nearly
20%
at
1.5
hours
after
application,
and
degraded
rapidly
thereafter
25
(
estimated
half­
life
<
1
day).
Additional
twelve
unknowns
were
also
detected
in
all
three
soils
and
none
of
them
exceeded
7.4%
of
the
applied
radioactivity.

iii.
Sediment/
Water
Systems
A
supplemental
anaerobic
aquatic
metabolism
study
conducted
with
mancozeb,
at
20
ppm,
reported
a
half­
live
of
92
days
(
MRID
000888­
20
with
Addendum
402582­
03).
The
study
used
a
soil
slurry
incubated
in
the
dark
at
pH
7
and
48%
moisture
with
anaerobic
conditions
established
by
flushing
with
nitrogen.
Although
the
study
didn't
fully
investigate
the
fate/
degradation
products
of
mancozeb
in
sediment/
water
systems,
the
results
suggest
that
anaerobic
conditions
appear
to
be
conductive
for
slowing
down
mancozeb
decomposition
in
these
systems.

It
is
important
to
note
that
various
submitted
studies
indicate
that
when
mancozeb
is
introduced
into
a
sediment/
water
system
at
low
concentrations,
decomposition
in
water
can
control
its
initial
fate.
This
is
because,
mancozeb
is
expected
to
degrade
very
quickly
into
the
Mancozeb
Complex
(
transient
species
and
other
known
degradates
including
ETU).
Given
the
use
patterns
of
mancozeb
(
no
direct
aquatic
use),
it
appears
that
the
process
of
decomposition
in
water
is
important
depending
on
resident
time/
moisture
availability
on
plant
leaf
surfaces
and
when
mancozeb
is
introduced
into
the
sediment/
water
systems
by
erosion
and/
or
drift.
In
the
latter
case,
it
is
expected
that
mancozeb
will
be
introduced
into
the
system
at
very
low
concentrations
causing
mancozeb
to
decompose
into
its
complex.
A
significant
part
of
this
complex
is
expected
to
partition
into
the
water
suspended
solids
and
sediments
as
predicted
from
estimated
high
K
oc
values
(
refer
to
mobility).

Initial
review
of
a
newly
submitted
river
and
pond
aerobic
water/
anaerobic
sediment
study
(
MRID
462043­
01)
indicates
that
Parent
mancozeb
(
DT
50
<
1
day)
is
short­
lived
in
these
systems
while
Mancozeb
Complex
is
relatively
persistent
(
t
1/
2
=
111
days
in
the
river
system
and
391
days
in
the
pond
system).
As
it
was
indicated
by
the
author
hydrolytic
instability
of
mancozeb
is
the
reason
for
the
observed
short
half­
lives
in
aquatic
systems
tested.
In
the
river
system,
un­
identified
Bound
species
increased
from
1%
at
day
0
to
a
maximum
of
43%
at
day
59
and
was
40%
at
the
end
of
the
experiment
(
105
days).
Likewise,
un­
identified
Bound
species,
in
the
pond
system,
increased
from
2%
at
day
0
to
a
maximum
of
44%
at
the
end
of
the
experiment
(
105
days).
To
account
for
this
unidentified
residue,
EFED
calculated
half­
lives
from
CO2
data
and
assigned
it
to
the
Mancozeb
Complex
(
suite
of
species
resulting
from
observed
rapid
hydrolysis
of
the
parent).
Calculated
Mancozeb
Complex
half­
lives
were
111
days
(
r2
=
0.98)
for
the
river
system
and
391
days
(
r2
=
0.97)
for
the
pond
system.
These
half­
lives
are
considered
conservative
as
they
represent
complete
mineralization
of
the
test
substance.

iv.
Bound
Species,
CS
2
­
data
and
Half­
life
Determination
for
EBDCs
The
registrant
claims
that
the
CS
2
­
method
quantitatively
determines
sulfur
containing
dithiocarbamates
(
parent
EBDCs
and
EBDCs
species
formed
by
hydrolytic
reactions)
in
aqueous
media,
soil
and
water/
sediment
systems
including
bound
species
to
soil/
sediment.
In
support,
the
registrant
stated
that
classical
chemistry
suggests
that
the
dithiocarbamate
functionality
would
not
be
9
Marshall,
W.
D.
1977.
J.
Agri.
Food
Chem.
25(
2):
357­
361.

10
Panel
on:
Determination
of
Dithiocarbamate
Residue
of
the
Analytical
Methods
for
Residues
of
Pesticides
and
Veterinary
Products
in
Foodstuffs
of
the
Ministry
of
Agriculture,
Fisheries,
and
Food
(
MAFF).
1981.
Analyst
106:
782­
787.

11
MRID
451452­
02:
Aerobic
Soil
Metabolism
of
[
14C]
Mancozeb
in
Soil,
Xenobiotic
Laboratories
Inc.,
XBL
Report
No.
RPT006055,
06/
09/
00.

26
stable
under
the
acid
hydrolytic
conditions
used
by
the
CS
2
­
method
to
release
CS
2
.
Many
literature
examples
were
cited
to
indicate
method
reliability
including:
demonstration
of
rapid
EBDCs
degradation
at
elevated
temperatures
and
acidic
conditions
in
aqueous
media9;
recommendation,
after
careful
review,
of
a
similar
method
for
analysis
of
dithiocarbamate
residues
by
a
Panel
set
up
by
the
Committee
for
Analytical
Methods
for
Residues
of
Pesticides
and
Veterinary
Products
in
Foodstuffs
of
the
Ministry
of
Agriculture,
Fisheries,
and
Food
(
MAFF)
in
197710;
obtaining
a
recovery
of
98.0
±
15.8%
for
mancozeb
in
freshly
fortified
control
soil
samples11;
and
the
extensive
use
of
the
method
for
over
10
years
with
the
greatest
effort
towards
crop
residue
analysis.
Therefore,
the
registrant
argues
that
the
appropriate
method
for
calculating
half­
lives
of
EBDCs
in
fate
studies
is
the
use
of
CS
2
­
method
data
rather
than
the
evolved
CO
2
­
data.
Half­
lives
obtained
for
parent
EBDCs
are
expected
to
be
conservative
due
to
the
fact
that
CS
2
is
expected
to
evolve
not
only
from
parent
but
also
from
EBDC
species/
degradates
containing
structural
sulfur
(
e.
g
EBIS
and
ETU).

With
one
exception,
EFED
agrees
with
conclusions
stated
above
and
therefore,
the
use
of
CS
2
­
data
was
acceptable
for
calculating
conservative
parent
EBDCs
half­
lives
in
aqueous
hydrolysis
studies.
In
addition,
EFED
suggests
that
calculated
half­
lives,
on
the
basis
of
CS
2
­
data,
are
acceptable
as
parent
hydrolysis
half­
lives
in
soil
and
water/
sediment
systems.
The
exception
is
that
EFED
can
not
consider
the
significant
bound
species,
in
aerobic
and
aquatic
studies,
to
be
included
as
part
of
the
species
determined
by
the
CS
2
­
method
in
the
absence
of
their
complete
characterization.
Quantitative
generation
of
CS
2
from
largely
known
EBDC
species
in
aqueous
media
and
possibly
in
plant
residue
and
freshly
fortified
soil
may
not
necessarily
be
comparable
to
unknown
EBDCs
species
in
aged
soil/
sediment.
In
the
absence
of
characterization
data
on
the
significant
bound
species,
EFED
has
no
other
way
to
calculate
bio­
degradation
half­
lives
other
than
the
use
of
evolved
CO
2
­
data.
EFED
recognizes
that
resultant
bio­
degradation
half­
lives
would
be
conservative
as
it
represents
complete
mineralization
of
the
EBDCs
Complex
as
a
whole.
Giving
the
fact
that
parent
EBDCs
are
shortlived
it
was
necessary
to
assign
these
half­
lives
to
all
of
the
hydrolytic
products
which
were
referred
to
as
the
EBDCs
Complex.
EFED
believes
that
it
is
justified
to
use
the
term
EBDCs
Complex
and
to
use
CO
2
for
calculating
its
half­
lives
in
soil
and
water/
sediment
systems.

In
few
of
the
submitted
fate
studies,
only
limited
data
were
provided
on
the
significant
bound
species
found
in
soil
and
water/
sediment
studies.
Fractionation
of
the
Bound
species
was
performed
into
fulvic
and
humic
fractions
with
no
further
determination
of
identity/
quantity
of
species
present.
Without
presenting
direct
evidence,
the
registrant
stated
that
consistent
with
current
mechanistic
studies,
"
bound
EBDC'
is
significantly
comprised
of
short­
chain
polar
degradates
such
as
ethylenediamine
"
EDA".
In
support
of
this
suggestion,
the
registrant
described
an
EBDCs
degradation
scheme
claimed
to
be
well
documented
in
the
literature.
The
scheme
starts
with
parent
EBDCs
hydrolyzing
directly
or
indirectly
(
though
short­
lived
poly­
EBDC
species)
into
a
predominant
single
EBDC
anion.
Resultant
EBDC
anion
transforms
further
to
EDA
(
by
hydrolysis
of
the
end
12
Marshall,
W.
D.
1977.
J.
Agri.
Food
Chem.
25(
2):
357­
361.

13
Caldwell,
J.,
and
Cotgreave,
I.
A.
1984.
Methodol.
Surv.
Biocchem.
Anal.
14,
47;
and
van
Dijken,
J.
P.
1981.
Bos.
Arch.
Micobiol.
128,
320.

14
Davis,
J.
1993.
Env.
Tox.
&
Chem.
12:
27­
35.

15
Newsome,
W.
H.,
et
al.
1975.
J.
Agric.
Food
Chem.
23(
4):
756­
758.

16
Blazquez,
C.
H.
1973.
J.
Agrc.
Food
Chem.
21
(
3):
330­
332.

17
Davis,
J.
W.
1993.
Environ.
Toxicol.
&
Chem.
12:
27­
35.

27
units)
and/
or
to
ETU
(
by
cyclization).
Formed
ETU
may
further
transforms
into
EDA.
Predominating
degradation
pathway
for
EBDC
anion
to
either
EDA
or
ETU
is
determined
principally
by
the
pH
of
the
media.
For
example,
It
was
suggested
that
EBDCs
may
degrade
via
two
different
routs
with
both
routes
eventually
forming
EDA12,
which
in
turn
transformed
into
glycine13.
Other
cited
literature
include:
a
report
that
the
EDA
has
a
Freundlich
adsorption
coefficient
range
of
15­
238
suggesting
that
it
binds
strongly
to
soil14;
low
levels
of
EDA
were
identified
in
soil
samples
from
at
least
one
cropped
field
treated
with
maneb,
at
normal
commercial
rates,
in
Ottawa,
Canada15;
low
levels
of
EDA
was
observed
at
time
zero
sampling
following
application
of
high
levels
of
EDA
to
a
Florida­
based
Immokalee
fine
sand
(
observed
low
levels
were
taken
to
suggest
EDA
tightly
binds
to
soil)
16;
and
that
the
finding
of
the
last
researcher
was
confirmed
by
studying
the
physicochemical
factors
influencing
EDA
sorption
to
soil
which
included
cation
exchange
capacity
(
CEC)
and
organic
matter
content,
batch
equilibrium
studies
demonstrated
that
EDA
binds
rapidly
and
strongly
to
soil
with
an
average
Koc
of
4,76617.

As
stated
above,
the
registrant
is
proposing
two
possible
theories
that
may
explain
the
nature
of
the
bound
species,
namely:
EDA
and
polar
natural
products.
However,
in
the
soil/
sediment
studies,
sulfur
balance
appears
to
decrease
with
time
coinciding
with
the
observed
increase
in
bound
species
which
would
suggest
that
the
bound
species
contain
sulfur.
EDA
has
no
structural
sulfur
and
its
presence
as
a
major
part
of
the
bound
species
can
not
explain
the
observed
sink
in
sulfur
balance.
This
sink
may,
however,
be
explained
by
the
presence
of
EBDC
species
with
high
affinity
to
soil/
sediment
and
in
which
structural
sulfur
resists
being
evolved,
as
CS
2
,
by
reagents/
heat
used
in
the
CS
2
­
method.
Therefore,
EFED
is
proposing
that
the
bound
species
are
probably
sulfur
containing
compounds
that
can
be
"
ETU
precursors".
In
absence
of
data
on
the
identity
of
the
significant
and
persistent
bound
species,
EFED
suggests
that
the
"
ETU
precursor"
theory
has
more
relevance
than
the
EDA
because
the
former
can
explain
the
observed
sink
in
sulfur
balance.
Additional
reasons
include:
EDA
was
identified
at
low
levels
in
only
one
hydrolysis
study
and
this
identification
was
carried
out
by
the
TLC
method
without
confirmation;
the
rapid
degradation
predicted
for
EDA
in
water/
soils
using
US
EPA
EPI
suite
program
v3.10;
and
the
non­
detection
(
possibly
because
they
were
not
tracked)
of
any
form
of
sulfur
bearing
compounds
(
such
as:
elemental
sulfur,
sulfates,
CS
2
,
H
2
S
and
others)
that
may
have
formed
in
any
of
the
submitted
fate
studies.

In
order
to
solve
the
problem
of
the
identity
of
bound
species,
EFED
proposes
that
the
registrant
conduct
one
complete
aerobic
soil
study.
In
the
proposed
study,
greater
efforts
should
be
exercised
to
try
to
characterize
bound
species.
In
addition,
EDA;
and
ETU,
EBIS,
and
all
types
of
sulfur
bearing
compounds
should
be
tracked
(
possibly
by
labeling
structural
sulfur
in
parent
EBDC).
A
28
sterile
soil
treatment
should
also
be
included
in
order
to
determine
the
relative
importance
of
the
active
dissipation/
degradation
processes
in
aerobic
soils
(
binding
to
soil/
hydrolysis
compared
to
biodegradation

c.
Mobility
Mobility
in
soil
studies
were
complicated
by
the
instability
of
the
parent
at
concentrations
used:
0.1
to
1
ppm
(
MRID
00888­
22)
and
0.5
to
5
ppm
(
MRID
402229­
01).
The
results
of
these
two
supplemental
studies
indicated
varied
predictions
for
mobility
(
from
immobile
to
medium
mobility).
Because
of
effects
of
decomposition
of
parent,
parameters
for
mobility
were
calculated
from
leaching
radioactivity
profiles
obtained
for
three
soils
(
Table
IV­
3).
Therefore,
K
d
and
K
oc
values
do
not
represents
mancozeb
but
rather
Mancozeb
Complex
formed
as
a
result
of
rapid
hydrolysis.

Table
IV­
3.
K
ads
and
K
oc
and
characteristics
of
the
soils
used
in
the
adsorption/
desorption
study
(
MRID
405883­
02).

Soil
Name
Not
Specified
Lawrenceville
Washington
Textural
class
Sandy
Loam
Silty
Loam
Silty
Loam
Clay
(%)
6
26
18
pH
(
water)
7.8
6.1
6.2
%
Organic
carbon
0.23
1.16
2.62
C.
E.
C
(
meq/
100g)
7.5
6.1
7.9
K
d
3.82
11.63
22.4
K
oc
1,642
1,000
860
d.
Field
Dissipation
A
half­
life
of
3
days
was
reported
for
a
silty
clay
loam
soil
under
Philippine
field
conditions
using
soil
column
received
natural
rain
(
a
total
of
12"
in
21
days).
CS
2
­
determined
mancozeb
remained
on
the
top
2.5
and
no
leaching
was
observed
under
the
conditions
of
the
experiment.
ETU
and
EU
were
the
only
degradation
products
whereas
bound
species
were
not
characterized
and
accounted
for
38­
70%
of
the
total
residues
(
Calampang
S.
et
al,
1993.
International
J.
of
Pest
Management,
39(
2)
161­
166).

e.
Bio­
accumulation
The
fish
bio­
accumulation
study
was
waived
based
on
the
reported
low
Kow
value
of
22
for
mancozeb.
Kow
value
indicates
low
potential
for
bio­
concentration
in
aquatic
organisms
such
as
fish.

V.
Water
Resource
Assessment
Parent
mancozeb
is
not
expected
to
be
present
in
significant
amounts
in
the
environment
except
for
short
duration
because
it
will
hydrolyze
rather
quickly
into
its
complex.
More
details
about
Parent
mancozeb
EECs
are
presented
in
Appendix
I
(
section
b.
i).
29
This
water
resource
assessment
is
for
Mancozeb
Complex;
the
resultant
complex
from
expected
rapid
hydrolysis
of
Parent
mancozeb
in
the
natural
environment.
Mancozeb
Complex
was
determined
to
consist
of
a
suite
of
chemical
species:
transient
species,
ETU,
ETU
degradates
(
EU,
hydantoine
and
others),
and
the
significant
unknown
Bound
species
(
suspected
of
containing
persistent
precursors
for
ETU).
Among
the
constituents
of
Mancozeb
Complex,
ETU
is
the
species
of
concern.
Therefore,
a
complete
water
resource
assessment
was
performed
for
ETU
while
only
surface
water
modeling
was
necessary
for
Mancozeb
Complex.
The
resultant
EECs
were
used
in
the
ecological
risk
assessment
of
Mancozeb
Complex.

a.
Surface
Water
Monitoring
and
Modeling
EFED
is
not
aware
of
surface­
water
monitoring
data
for
mancozeb.
Monitoring
data
were
submitted
to
the
Agency
by
the
EBDC
Task
Force
only
for
the
degradate
of
concern
ETU,
this
data
will
be
discussed
separately
in
the
accompanied
ETU
chapter.
The
surface
water
assessment
of
Mancozeb
Complex
is
therefore
based
upon
computer
modeling.

Because
monitoring
data
from
field
locations
are
not
available
for
mancozeb,
the
surface
water
assessment
was
therefore
carried
out
using
the
linked
PRZM
and
EXAMS
models.
PRZM/
EXAMS
input
values
are
listed
in
Table
V.
1
and
the
results
in
Table
V.
2.
This
data
were
used
for
estimating
EECs
necessary
for
the
ecological
risk
assessment
of
Mancozeb
Complex.

Table
V.
1.
PRZM/
EXAMS
Input
Parameters
for
Mancozeb
Complex*.

Input
Parameter
Value
Reference
Molecular
Weight
(
grams)
265
This
value
was
used
in
modeling
as
it
was
obtained
from
other
reference.
It
is
recognized
however,
that
the
registrant
value
is
271
grams
Vapor
Pressure
(
torr)
1.003
e­
7
Registrant
data
Bacterial
Bio­
lysis
in
the
water
column
(
days)
0
(
Stable)
Guidance**
because:
No
aerobic
aquatic
metabolism
study/
significant
hydrolysis.
Note:
half­
lives
measured
from
a
newly
submitted
aerobic
water/
anaerobic
sediment
were:
111
days
for
a
river
system
and
391
days
for
a
pond
system
(
the
upper
confidence
bound
on
the
mean
for
these
two
values=
682
days)
(
MRID
462043­
01).
Therefore
the
assumption
of
stability
is
reasonable.

Bacterial
Bio­
lysis
in
benthic
sediment
(
days)
276
Guidance**
because:
anaerobic
aquatic
metabolism
t
½
for
one
soilx3
(
MRID
000888­
20);
92x3=
276
Aerobic
Soil
Metabolism
Half­
life
(
days)
182
Upper
confidence
bound
on
the
mean
for
four
soils
(
MRID
457445­
01)

Application
Method
Aerial
Product
Label
Depth
of
Incorporation
(
inches)
0
Product
Label
Application
Efficiency
(
fraction)
0.95
Guidance**
Input
Parameter
Value
Reference
30
Spray
Drift
(
fraction)
0.05
Guidance**

Solubility
(
mg/
L
or
ppm)
6
Registrant
data
Koc
(
L
Kg­
1)
1,167
Average
for
three
soils
(
MRID
405883­
02)

pH
7
Hydrolysis
Half­
life
(
days)
0.7
MRIDs
000971­
62/
402582­
01
Photolysis
Half­
life(
days)
0
(
Stable)
MRID
001621­
03
*
Parent
mancozeb
Parameters
for
Molecular
Weight
(
grams);
Vapor
Pressure
(
torr);
Solubility
(
mg/
L
or
ppm);
and
pH
7
Hydrolysis
Half­
life
were
used.
**
Guidance
for
Chemistry
and
Management
Practice
Input
Parameters
For
Use
in
Modeling
the
Environmental
Fate
and
Transport
of
Pesticides,
Version
2/
November
7,
2000.

Table
V.
2.
PRZM/
EXAMS
output
EECs
for
Mancozeb
Complex*

Crop
Rate
(
lbs/
Acre)
Number
of
Applications
Interval
Peak
(
ppb)
96
Hour
(
ppb)
21
Day
(
ppb)
60
Day
(
ppb)
Annual
Average
(
ppb)

Apples
(
NC)
4.8
4
7
73.4
22.8
7.0
3.2
0.5
Sweet
Corn
(
OR)
1.2
15
4
68.2
24.6
9.6
4.5
1.1
Potatoes
(
ME)
1.6
7
5
46.8
13.3
4.3
2.2
0.5
Tomatoes
(
FL)
2.4
7
7
210.8
56.0
16.7
7.3
1.4
Wheat
(
TX)
1.6
3
7
103.4
29.7
7.7
3.2
0.6
b.
Ground
Water
Monitoring
and
Modeling
EFED
is
not
aware
of
ground
water
monitoring
data
for
mancozeb.
Monitoring
data
were
submitted
to
the
Agency
by
the
EBDC
Task
Force
only
for
the
degradate
of
concern
ETU,
this
data
will
be
discussed
separately
in
the
accompanied
ETU
RED
chapter.
No
ground
water
modeling
was
performed
for
Mancozeb
Complex
because
the
only
species
of
concern
is
ETU
for
which
modeling
can
be
found
in
the
accompanied
ETU
chapter.

c.
Drinking
Water
Assessment
Assessments
for
surface/
ground
drinking
water
were
only
performed
for
the
degradate
of
concern,
ETU.
This
assessment
can
be
found
in
the
accompanied
RED
chapter
for
ETU.

VI.
Aquatic
Exposure
and
Risk
Assessment
a.
Hazard
Summary
Acutely,
mancozeb
is
highly
toxic
to
cold
water
(
freshwater)
fish
(
LC
50
=
460
­
640
ppb)
and
moderately
toxic
to
warm
water
(
freshwater)
fish
and
estuarine/
marine
fish
(
LC
50
=
1,350
­
4,200
ppb).
The
acute
toxicity
classification
of
estuarine/
marine
fish
is
based
on
supplemental
studies.
31
EFED
needs
a
core
study
(
guideline
72­
3a)
to
fulfill
this
requirement
(
see
Appendix
III).
Chronic
freshwater
NOAEC
and
LOAEC
values
were
determined
to
be
2.19
and
4.56
ppb,
respectively,
with
survival
and
lack
of
growth
being
the
endpoints
affected.
No
acceptable
data
has
been
filed
to
assess
the
chronic
effects
of
mancozeb
to
estuarine/
marine
fish.
EFED
needs
an
estuarine/
marine
fish
early
life­
stage
toxicity
test
(
guideline
72­
4a)
to
fulfill
this
requirement
(
see
Appendix
III).
Acute
toxicity
values
for
aquatic
invertebrates
suggest
that
mancozeb
is
highly
toxic
to
freshwater
invertebrates
(
Daphnia
EC
50
=
580
­
1,000
ppb)
and
moderately
to
very
highly
toxic
to
estuarine/
marine
invertebrates
(
oyster
EC
50
=
1,600
ppb
and
mysid
shrimp
EC
50
=
10.5
ppb).
The
toxicity
classification
of
shrimp
is
based
on
supplemental
studies
and
EFED
needs
a
core
study
to
fulfill
this
guideline
(
72­
3c)
(
see
Appendix
III).
A
chronic
freshwater
invertebrate
life
cycle
study
on
Daphnia
magna
showed
the
NOAEC
was
7.3
ppb
and
the
LOAEC
was
12
ppb.
The
endpoints
affected
in
this
study
were
immobility
of
the
test
species
and
length
and
time
until
first
brood.
No
acceptable
data
has
been
filed
to
assess
the
chronic
effects
of
mancozeb
to
estuarine/
marine
invertebrates.
EFED
needs
an
estuarine/
marine
invertebrate
life
cycle
toxicity
test
(
guideline
72­
4b)
to
fulfill
this
requirement
(
see
Appendix
III).
A
Tier
II
aquatic
plant
growth
study
reviewed
on
mancozeb
showed
the
EC
50
was
47
ppb
and
the
NOAEC
was
22
ppb.
The
endpoint
affected
was
growth
inhibition.
The
test
species
in
the
study
was
green
algae
(
Selenastrum
capricornutum),
a
freshwater
nonvascular
plant.
There
was
no
data
submitted
to
evaluate
the
affects
mancozeb
has
on
the
additional
aquatic
test
species:
duckweed
(
Lemna
gibba),
marine
diatom
(
Skeletonema
costatum),
blue­
green
algae
(
Anabaena
flosaquae
and
a
freshwater
diatom.
Aquatic
plant
growth
studies
at
the
Tier
I
or
Tier
II
level
(
guidelines
123­
1
or
123­
2,
respectively)
needs
to
be
submitted
for
these
additional
species
(
see
Appendix
III).

The
EDBCs
(
metiram,
mancozeb,
and
maneb),
unlike
most
pesticide
active
ingredients
are
not
welldefined
monomeric
substances.
The
EBDCs
are
polymeric
complexes
and
are
nearly
insoluble
in
water
with
a
high
affinity
to
adsorption
by
soil
or
sediment
particles.
The
EBDC
portion
that
dissolves
in
water
and
breaks
up
into
a
suite
of
transient
species
and
degradates,
is
the
EBDC
complex.
This
complex
is
not
the
parent
material
by
itself.

Studies
provided
estimates
of
the
EBDC
parent
material
in
test
concentrations
used
for
evaluating
the
toxicity
to
aquatic
organisms.
These
studies
showed
low
recoveries
of
the
test
substance.
For
example,
measuring
carbon
disulfide
(
CS
2
)
containing
residues,
using
gas
chromatography,
one
study
found
roughly
a
40%
±
10%
average
of
nominal
levels
of
the
"
parent
complexes".
Through
filtering
and
measuring
the
treatment
water,
the
recovery
of
"
parent
complexes"
was
around
15%
±
10%
average
of
nominal
levels
(
MRID
No.
43525001,
Monk,
1994).
Filtering
of
the
test
solution
before
analytical
measurement
increases
the
accurate
measurement
of
the
test
material
in
solution
because
this
removes
the
undissolved
material
in
the
solution.
This
remaining,
soluble
portion
of
the
chemical
is
more
biologically
available
to
aquatic
organisms
and
represents
a
more
conservative
estimate
of
the
toxicity
to
these
organisms.
These
filtered
and
measured
"
parent
complexes",
is
the
portion
of
the
parent
material
that
is
available
to
aquatic
organisms
in
the
environment
(
see
Figure
VI­
1).
The
EPA's
Rejection
Rate
Analysis
determined
that
studies,
testing
materials
having
poor
water
solubility,
were
to
use
measured
as
opposed
to
nominal
concentrations.
Studies
were
to
use
measured
concentrations
for
fixing
aquatic
toxicological
endpoints
for
compounds
with
poor
solubility
(
US
EPA.
December,
1994).
EFED
believes
filtered
and
measured
samples
provide
a
more
conservative
estimate
of
the
EBDCs'
toxicity
to
aquatic
organisms.
Also,
EFED
believes
the
filtered
and
measured
samples
32
provide
a
more
true
estimate
of
aquatic
organism
exposure
to
the
EBDC
complexes
in
the
environment.

Modeling
estimates
using
PRZM­
EXAMS
are
also
estimating
EBDC
complexes
by
predicting
the
EECs
using
the
physicochemical
properties
of
the
EBDC,
parent
aerobic
soil
metabolism
half­
lives
and
sorption
coefficients.
Appendix
VI
shows
the
toxicity
to
aquatic
organisms
found
from
the
various
EBDC
aquatic
toxicological
studies.
These
endpoints
are
an
estimate
of
the
EBDC
complex
that
fixes
the
toxicities
(
that
is,
LC
50
s,
EC
50
s,
and
NOAECs).
The
modeling
EECs
are
also
estimates.
Influences
such
as
particle
size,
conditions
of
storage,
degree
of
decomposition,
pH,
and
the
presence
of
other
cations
(
see
Figure
VI­
1)
would
always
cause
difficulty
in
providing
definite
aquatic
toxicological
endpoints
for
the
EBDCs.
33
Table
VI­
1:
Toxicological
Endpoints
Used
to
Determine
Aquatic
Risk
Quotients
(
RQs)
for
Mancozeb
Type
of
Toxicity
Organism
Species
Toxicological
Endpoint
Acute
Freshwater
fish
rainbow
trout
(
Salmo
gairdneri)
LC
50
=
460
ppb
Chronic
fathead
minnow
(
Pimephales
promelas)
NOAEC
=
2.19
ppb1
Acute
Freshwater
invertebrate
waterflea
(
Daphnia
magna)
LC
50
=
580
ppb
Chronic
waterflea
(
Daphnia
magna)
NOAEC
=
7.3
ppb2
Acute
Estuarine/
marine
fish
sheepshead
minnow
(
Cyprinodon
variegatus)
LC
50
=
1,600
ppb
Chronic
no
data
no
data
Acute
Estuarine/
marine
invertebrate
mysid
shrimp
(
Americamysis
bahia)
EC
50
=
10.5
ppb
Chronic
no
data
no
data
Acute
Aquatic
plant
green
algae
(
Selenastrum
capricornutum)
EC
50
=
47
ppb
1
Due
to
survival
and
lack
of
growth
effects.
2
Due
to
immobility,
length
and
time
until
first
brood.

b.
Exposure
and
Risk
Quotients
EFED
performed
Tier
II
modeling
(
PRZM/
EXAMS)
for
selected
sites
for
which
EFED
currently
has
modeling
scenarios.
Below
(
Figure
VI­
2)
are
graphs
representing
Mancozeb
Complex'
aquatic
risks
to
non­
target
organisms.
EFED
selected
representative
mancozeb
use
patterns
at
maximum
application
rates
and
minimum
intervals
between
applications.
For
a
more
detailed
listing
and
explanation
of
mancozeb's
risk,
see
Appendix
IV.
EFED
does
not
have
a
method
to
evaluate
chronic
risks
to
non­
target
aquatic
plants.

The
results
show:
1)
The
acute
RQs
exceed
freshwater
fish
endangered
species
LOCs
for
all
mancozeb
uses
(
acute
RQ
ranges
from
0.1
to
0.46).
The
chronic
RQs
exceed
LOCs
for
freshwater
fish
for
all
mancozeb's
modeled
uses
(
chronic
RQ
ranges
from
1.00
to
3.33).
2)
The
acute
freshwater
invertebrates'
RQs
exceed
endangered
species
LOCs
for
all
mancozeb
uses
except
walnuts
(
acute
RQ
ranges
from
0.08
to
0.36).
The
chronic
RQs
exceed
LOCs
for
freshwater
invertebrates
for
mancozeb's
use
on
sweet
corn,
tomatoes,
and
wheat
(
chronic
RQ
ranges
from
1.05
to
2.29).
3)
The
acute
estuarine/
marine
fish
RQs
exceed
endangered
species
LOCs
for
mancozeb
uses
apples,
tomatoes,
and
wheat
(
acute
RQ
ranges
from
0.05
to
0.13).
4)
The
results
show
estuarine/
marine
invertebrate
acute
RQs
exceed
LOCs
for
all
mancozeb
uses
(
acute
RQ
ranges
from
4.46
to
20.08).
There
are
currently
no
estuarine/
marine
invertebrates
listed
as
endangered
species.
34
0.01
0.1
1
10
100
Risk
Quotient
Potato
Corn
(
Sweet)
Apples
Wheat
Tomato
Sites
Estuarine/
Marine
Fish
Acute
Freshwater
Invertebrates
Acute
Freshwater
Fish
Acute
Aquatic
Non­
Vascular
Plants
Acute
Estuarine/
Marine
Invertebrates
Acute
Freshwater
Invertebrates
Chronic
Freshwater
Fish
Chronic
Mancozeb
Aquatic
Risks
Based
on
PRZM­
EXAMS
Modeling
Figure
VI­
2
RQ
greater
or
equal
to
1.0
exceeds
aquatic
plant
acute
and
acute
endangered
species
LOCs.
RQ
greater
or
equal
to
0.5
exceeds
aquatic
animal
acute,
acute
restricted
use
and
acute
endangered
species
LOCs.
RQ
greater
or
equal
to
0.1
exceeds
aquatic
animal
acute
restricted
use
and
acute
endangered
species
LOCs.
RQ
greater
or
equal
to
0.05
exceeds
aquatic
animal
acute
endangered
species
LOCs.
RQ
greater
or
equal
to
1
exceeds
animal
chronic
LOCs.
There
are
no
estuarine/
marine
invertebrates
or
non­
vascular
aquatic
plant
species
listed
on
the
endangered
species
list.
5)
Mancozeb's
use
patterns
on
all
modeled
uses
exceed
acute
risk
LOCs
for
nonvascular
aquatic
plants
(
acute
RQ
ranges
from
1.00
to
4.49).
There
are
no
nonvascular
aquatic
plants
listed
as
endangered
species.
18
Based
on
green
algae,
(
Pseudokirchneriella
subcapitata)
testing.

19The
highest
ETU
RQ
is
0.0005
(
see
EFED's
ETU
chapter).

35
c.
Aquatic
Risk
Assessment
Dose/
response
slope
values
for
the
toxicological
endpoints
(
see
Table
V­
1)
used
to
calculate
aquatic
animal
RQs
for
mancozeb
were
not
reported
for
freshwater
fish,
freshwater
invertebrates,
or
estuarine/
marine
fish,
in
the
studies
used
to
determine
these
endpoints.
Lacking
slope
information,
the
likelihood
of
individual
effects,
from
Mancozeb
Complex
exposure,
to
freshwater
fish,
freshwater
invertebrates,
and
estuarine/
marine
fish
was
not
determined.

1)
The
estuarine/
marine
invertebrate
acute
RQs
exceed
LOCs
for
all
mancozeb
uses
(
acute
RQ
ranges
from
4.46
to
20.08).
There
are
currently
no
estuarine/
marine
invertebrates
listed
as
endangered
species.
At
the
peak
Mancozeb
Complex
aquatic
EEC
expected
from
drift
and
runoff
of
210.8
ppb,
the
likelihood
of
adverse
Mancozeb
Complex
effects
to
individual
estuarine/
marine
invertebrate
is
1
in
1
or
100%.
EFED
calculated
this
chance
estimate
using
Equation
V­
1
with
an
estuarine/
marine
invertebrate
acute
LC
50
=
10.5
ppb
and
a
slope
=
3.0
from
MRID
No.
41822901
and
LC
k
=
210.8
ppb.

2)
Mancozeb's
use
patterns
on
all
modeled
uses
exceed
acute
risk
LOCs
for
nonvascular
aquatic
plants
(
acute
RQ
ranges
from
1.00
to
4.49).
There
are
no
nonvascular
aquatic
plants
listed
as
endangered
species.
At
the
peak
Mancozeb
Complex
aquatic
EEC
expected
from
drift
and
runoff
of
210.8
ppb,
the
likelihood
of
adverse
Mancozeb
Complex
effects
to
individual
nonvascular
aquatic
plants
is
1
in
1
or
100%.
EFED
calculated
this
chance
estimate
using
a
nonvascular
aquatic
plants
LC
50
=
47
ppb;
LC
k
=
210.8
ppb;
and
slope
=
4.1
from
MRID
No.
43664701.

Based
on
laboratory
data
and
modeled
EECs,
the
Mancozeb
Complex
are
responsible
for
exceeding
acute
LOCs
and
not
the
degradate,
ETU.
The
ETU
acute
RQs
for
nonvascular
aquatic
plants18,
freshwater
fish
and
freshwater
invertebrates
were
well
below19
the
lowest
LOC
(
endangered
species
LOC
=
0.05)
for
aquatic
organisms.
This
means
the
Mancozeb
Complex,
other
than
ETU,
is
responsible
for
the
acute
toxicity
to
freshwater
fish,
freshwater
invertebrates,
and
nonvascular
aquatic
plants.
EFED
does
not
know
how
acutely
toxic
ETU
is
to
estuarine/
marine
fish
or
invertebrates
because
no
data
has
been
reviewed
for
evaluating
this
hazard.
Also
EFED
needs
ETU
data
to
evaluate
fully
the
acute
risks
to
aquatic
plants
(
vascular
and
nonvascular)
and
the
chronic
risks
to
freshwater
and
esturine/
marine
organisms.

ETU
is
an
important
transformation
product
of
all
the
EBDC
complexes.
These
complexes
are
shortlived
in
aquatic
media
and
ETU
is
persistent
in
this
media
unless
ETU
is
subjected
to
rapid
degradation
by
microbes
and/
or
indirect
photolysis..
Because
of
this,
EFED
expects
the
acute
toxicity
to
freshwater
fish,
freshwater
invertebrates,
estuarine/
marine
fish
and
nonvascular
aquatic
plants,
from
exposure
to
the
Mancozeb
Complex,
will
not
last
long.
The
acute
fish
studies
have
a
duration
of
96
probit
k
=
(
log
LC
­
log
LC
)
*
slope
+
probit
50%

k
=
new
percentage
mortality
k
50
Equation
VI­
1
36
hours,
while
the
acute
invertebrate
studies
last
48
hours
and
the
nonvascular
aquatic
plant
studies
are
120
hours
in
duration.
Acceptable
aquatic
half­
life
data
is
unavailable
for
most
products
of
the
Mancozeb
Complex.
EFED
expects
mancozeb
to
hydrolyze
quickly
(
that
is,
within
hours)
to
its
complex.
Based
on
this
information,
EFED
expects
the
Mancozeb
Complex'
acute
toxicity
to
these
aquatic
organisms
will
last
for
120
hours
but
suspects
this
toxicity
will
rapidly
decline
after
this
time
period
as
this
complex
degrades
to
ETU.
EFED
suspects
the
Mancozeb
Complex'
acute
toxicity
will
decrease
after
about
120
hours.
However,
EFED
expects
there
will
still
be
enough
Mancozeb
Complex
to
present
an
acute
risk
to
estuarine/
marine
invertebrates
and
a
chronic
risk
to
freshwater
fish
and
freshwater
invertebrates
as
mentioned
in
Section
b.,
above.
EFED
expects
the
acute
risk
to
estuarine/
marine
invertebrates
will
persist
because
the
Mancozeb
Complex
isvery
highly
toxic
these
organisms
(
mysid
shrimp
EC50
=
10.5
ppb).
Modeled
Mancozeb
Complex
EECs
for
selected
sites
range
from
2.3
to
14.4
ppb
21
days
after
mancozeb
applications
(
see
Table
V.
2).
This
combination
of
exposure
and
toxicity
suggests
acute
LOCs
could
still
be
triggered
for
estuarine/
marine
invertebrates
21
days
after
mancozeb
is
applied.

A
registrant
filed
a
draft
mesocosm
study
to
the
Agency
as
MRID
44944401
under
section
6(
a)(
2).
Section
6(
a)(
2)
of
FIFRA
requires
pesticide
product
registrants
to
file
adverse
effects
information
about
their
products
to
the
EPA.
EFED
believes
the
registrant
submitted
a
completed
study
to
OPP
under
MRID
No.
45014901
but
EFED
has
not
reviewed
this
final
study.
The
author
conducted
the
study
in
Germany.
EFED
completed
an
abbreviated
review
of
the
draft
study
(
MRID
44944401)
in
February,
2000
and
a
provides
the
following
synopsis
of
the
abbreviated
review.

This
study
followed
the
Society
of
Environmental
Toxicology
and
Chemistry
(
SETAC)
"
Guidance
Document
on
Testing
Procedures
for
Pesticides
in
Freshwater
Mesocosms"
(
July
1991).
The
field
study
lasted
2.5
months:
preapplication
(
three
weeks);
application
(
seven
weeks);
and
the
postapplication
period
(
four
weeks).
The
author
used
ten
outdoor
fiberglass
tanks
(
mesocosms)
in
this
study
­
3
controls
and
7
treatment
tanks.
Each
mesocosm
was
about
2
m
in
diameter
and
1.6
m
deep
with
an
estimated
volume
of
5
m3.
The
treatment
tanks
received
eight
simulated
spray
drift
applications
of
Penncozeb
80
WP
(
80%
mancozeb
ai)
each
separated
by
one
week
using
handheld
sprayers.
The
seven
treatment
tanks'
nominal
concentrations
of
Penncozeb
®
80WP
were:
1.25,
4.0,
12.5,
40.0,
125.0,
400.0,
and
1250.0
ppb.
The
author
based
the
results
on
nominal
concentrations
of
the
formulated
product
not
measured
concentrations
of
mancozeb
in
the
treatment
tanks.
The
author
conducted
the
mesocosm
study
using
nonreplicated
treatments.
Dose
response
values
(
EC
20
and
EC
50
)
were
derived
by
employing
nonlinear
regression
analysis.
The
EC
20
was
regarded
by
the
authors
as
the
threshold
level,
below
which
no
ecologically
relevant
effects
occur.
The
following
table
provides
the
toxicity
of
Penncozeb
80
WP
to
various
aquatic
species
in
this
study.

Table
VI­
2:
Freshwater
Organism
Toxicity
from
MRID
44944401 
A
Draft
Mesocosm
Study
Taxon
Species
Period
EC20/
EC50
1
(
ppb
Penncozeb
80
WP)

Zooplankton
Cladocera
Daphnia
magna
Application
252/
408
Cladocera
Daphnia
longispina
Application
332/
398
Cladocera
Scapholeberis
mucronata
Application
188/
263
Cladocera
Chydorus
sphaericus
Application
67/
134
Copepoda
Copepod
nauplii
Application
29/
57
Table
VI­
2:
Freshwater
Organism
Toxicity
from
MRID
44944401 
A
Draft
Mesocosm
Study
Taxon
Species
Period
EC20/
EC50
1
(
ppb
Penncozeb
80
WP)

37
Rotifera
Keratella
quadrata
Application
22/
27
Rotifera
Cephalodella
sp.
Application
15/
31
Rotifera
Brachionus
leydigi
Application
5.5/
9.2
Phytoplankton
Protista
Volvox
sp.
Application
1.6/
4.8
1
Based
on
reductions
in
individual
species
densities.

The
EC
50
of
408
ppb
for
Daphnia
magna
determined
in
this
mesocosm
study
(
see
Table
VI­
2)
compares
closely
to
the
laboratory
determined
Daphnia
magna
EC
50
of
580
ppb
used
for
calculating
mancozeb's
acute
aquatic
invertebrate
RQs
in
this
assessment.
Both
toxicity
values
were
based
on
nominal
values
of
a
80%
mancozeb
formulation
although
the
EC
50
of
580
ppb
is
based
on
mortality
with
replicated
results.
The
author
believed
the
rotifer
component
of
zooplankton
to
be
the
most
representative
for
direct
sensitivity
to
the
test
material,
since
the
EC
20
for
Volvox
sp.
was
based
on
highly
variable
counts
of
this
species.
Also,
it
was
unknown
whether
the
toxicity
to
Volvox
sp.
was
a
direct
effect
from
the
chemical,
an
indirect
effect
because
of
competition
with
other
autotrophs,
or
a
combination
of
the
two
effects.
Based
on
this
the
author
estimated
a
range
from
4.0
to
5.5
ppb
would
be
a
safe
level
(
that
is,
a
NOAEC)
for
all
organisms
identified
in
the
study.

The
EPA's
"
Aquatic
Mesocosm
Tests
to
Support
Pesticide
Registrations
EPA
540/
09­
88­
035"
(
March
1988)
requires
three
replicates
at
each
treatment
level,
a
mesocosm
size
of
300
m3
in
volume
and
the
inclusion
of
viable
finfish
in
the
study.
These
three
major
departures
from
EPA
guideline
requirements
are
noted
at
this
time.
Although
EFED
has
not
reviewed
the
final
mesocosm
study,
a
review
of
this
draft
study
suggests
the
study
is
scientifically
sound
and
useful
in
showing
the
sensitivity
differences
across
freshwater
invertebrate
taxa
from
exposure
to
Mancozeb
Complex.

i.
Incidents
EIIS
reported
mancozeb
in
three
fish
kill
incidents
(
see
Table
VI­
3).
One
incident
occurred
in
1970,
another
in
1992
and
the
latest
occurred
in
1995.
In
the
1970
and
1992
incidents,
mancozeb
had
been
applied
with
insecticides
highly
toxic
to
fish
(
thiodan
and
endosulfan)
and,
because
of
sample
analysis,
EFED
classified
mancozeb
as
unlikely
to
have
been
responsible
for
the
these
fish
kills.
The
third
incident
in
1995
involved
an
accidental
mancozeb
spill
into
a
stream
that
was
the
source
water
for
a
salmon
hatchery
which
resulted
in
a
fish
kill
at
the
salmon
hatchery.
Although
no
samples
were
analyzed
(
fish
or
water),
EFED
considered
mancozeb
to
be
a
probable
cause
to
the
kill.

Table
VI­
3:
Mancozeb
Incidents
from
EIIS
Incident
Number
Pesticide(
s)
Involved
Date
(
month/
year)
Adverse
Effect
Magnitude
of
Damage
B0000­
233
mancozeb,
sulfur,
&
thiodan
7/
1970
Fish
kill
thousands
I000799­
008
mancozeb,
maneb,
fenarimol,
&
endosulfan
4/
1992
Fish
kill
>
600
fish
Table
VI­
3:
Mancozeb
Incidents
from
EIIS
Incident
Number
Pesticide(
s)
Involved
Date
(
month/
year)
Adverse
Effect
Magnitude
of
Damage
38
I008745­
004
mancozeb
7/
1995
Fish
kill
30,000
to
35,000
fish
ii.
Endocrine
Disruptors
Chronic
testing
in
freshwater
organisms
showed
immobility,
length
and
time
until
first
brood
in
daphnia
and
reduced
survival
and
lack
of
growth
effects
in
fathead
minnow.
See
Appendix
III
for
a
detailed
listing
of
the
studies
and
results.
These
effects
noted
in
freshwater
species
could
be
a
result
of
hormonal
disruptions
and
could
suggest
that
mancozeb
may
be
an
possible
disruptor.
Based
on
these
effects
in
freshwater
fish
and
invertebrates,
EFED
recommends
mancozeb
be
subjected
to
more
definitive
testing
to
better
characterize
effects
related
to
its
possible
endocrine
disruption.
This
testing
should
occur
when
EPA
develops
suitable
screening
and
testing
protocols,
considered
under
the
Agency's
EDSP.

iii.
Endangered
Species
Based
on
available
screening
level
information,
there
is
a
potential
concern
for
mancozeb's
acute
and
chronic
effects
on
listed
Endangered
and
Threatened
species
of
freshwater
animals
and
acute
effects
on
listed
estuarine/
marine
fish
should
exposure
actually
occur.
There
are
no
nonvascular
aquatic
plant
or
estuarine/
marine
invertebrate
species
on
the
endangered
species
list.
39
VII.
Terrestrial
Exposure
and
Risk
a.
Hazards
Summary
(
Acute/
Chronic
Toxicity)

Avian
acute
oral
toxicity
testing
was
conducted
for
mancozeb
using
the
English
sparrow,
mallard
duck
and
Japanese
quail
as
test
species.
The
acute
oral
LD
50
was
determined
to
be
~
1500
mg/
kg
for
the
sparrow
and
>
6400
mg/
kg
for
the
duck
and
quail.
These
studies
were
not
the
standard
single
oral
dose
studies
but
were
multiple
oral
dose
studies
that
were
accepted
as
supplemental
studies
in
lieu
of
the
standard
testing.
Therefore,
mancozeb
is
categorized
as
slightly
to
practically
nontoxic
to
avian
species
on
an
acute
oral
basis.
The
requirement
for
avian
subacute
dietary
testing
was
waived.
In
a
memorandum
dated,
October
27,
1987,
from
EFED
to
RD,
EFED
waived
the
requirement
for
these
studies
because
it
was
felt
that
the
multiple
dosing
studies,
mentioned
above,
exceeded
the
requirements
for
dietary
testing
and
dietary
testing
that
was
attempted
on
mallard
ducks
and
bobwhite
quail
indicated
the
birds
had
an
aversion
to
test
diet
and
would
not
consume
the
test
material.
Chronic
avian
reproduction
testing
was
conducted
for
mancozeb
on
mallard
ducks
and
bobwhite
quails.
The
lowest
NOAEC
was
determined
to
be
125
ppm
on
the
ducks
with
a
LOAEC
of
1,000
ppm
based
upon
reductions
in:
egg
production;
early
and
late
embryo
viability;
hatchability;
and
offspring
weight
at
hatch
and
14­
days
of
age.
Two
(
2)
studies
on
quails
yielded
NOAECs
of
125
and
300
ppm.
The
LOAECs
for
both
of
these
studies
was
1000
ppm
based
upon
reductions
in
the
hatchlings'
and
14­
day
old
survivors'
weights
and
the
reduction
in
the
number
of
14­
day
old
survivors.

Mancozeb
is
practically
nontoxic
to
small
mammals
on
an
acute
oral
basis
with
LD
50
>
5,000
mg/
kg
in
tests
done
on
laboratory
rats.
Results
from
chronic
reproduction
study
for
mancozeb
indicate
a
parental
toxicity
at
a
LOAEL
of
1,200
ppm
(
NOAEL
=
120
ppm)
with
parental
body
weight
decrements,
increased
relative
thyroid
weights,
and
increased
incidence
of
thyroid
follicular
cell
hyperplasia
being
the
endpoints
affected.

Currently,
EFED
does
not
assess
risk
to
non­
target
insects
using
risk
quotient
methodology.
Results
of
acceptable
studies
are
used
for
recommending
appropriate
label
precautions.
Since
mancozeb
was
determined
to
be
practically
nontoxic
to
honey
bees
(
LD
50
>
179
µ
g/
bee)
no
bee
precautionary
labeling
is
required
on
mancozeb
product
labeling.
A
beneficial
mite
study
(
MRID
No.
45577201)
determined
that
mancozeb's
LR
50
(
residue
concentration
on
foliage
causing
50%
lethality)
for
Typhlodromus
pyri
is
0.1
lb
active
ingredient/
A
and
the
LOAEC
which
can
potentially
be
expected
to
cause
adverse
reproductive
effects
is
0.02
lb
active
ingredient/
A
(
lowest
concentration
tested).

Tier
I
seedling
emergence
and
vegetative
vigor
studies
for
a
TEP
(
a
60%
mancozeb
and
9%
dimethomorph
mixture
)
have
been
reviewed.
Ten
(
10)
different
plant
species
were
exposed
to
the
TEP
in
each
study
which
included
representative
plants
from
the
dicotyledonous
and
monocotyledonous
families.
These
studies
indicated
the
TEP
had
less
than
a
25%
inhibition
on
the
various
growth
paramenters
that
were
checked.
To
fully
evaluate
the
risk
to
non­
target
terrestrial
plants
and
rule
out
any
possible
synergistic
effects,
EFED
is
recommending
that
Tier
I
seedling
emergence
and
vegetative
vigor
studies
for
a
single
active
ingredient
(
mancozeb,
only)
TEP
be
submitted.
For
a
more
detailed
listing
and
explanation
of
mancozeb's
hazards
to
all
terrestrial
organisms,
see
Appendix
III.
40
Table
VII­
1:
Toxicological
Endpoints
Used
to
Determine
Risk
Quotients
(
RQs)
for
Mancozeb
Type
of
Toxicity
Organism
Species
Toxicological
Endpoint
Acute
oral
Bird
English
sparrow
(
Passer
domesticus)
LD
50
 

1,500
mg/
kg
Chronic
Bird
mallard
duck
(
Anas
platyrhynchos)
NOAEC
=
125
ppm1
Chronic
Mammal
laboratory
rat
(
Rattus
norvegicus)
NOAEL
=
120
ppm2
1
Due
to
reductions
in:
egg
production;
early
and
late
embryo
viability;
hatchability;
and
offspring
weight
at
hatch
and
14­
days
of
age.
2
Reproductive
study,
due
to
parental
body
weight
decrements,
increased
relative
thyroid
weights,
and
increased
incidence
of
thyroid
follicular
cell
hyperplasia.

b.
Exposure
Summary
Terrestrial
exposure
was
evaluated
using
estimated
environmental
concentrations
generated
from
the
FATE
version
5.0
model
that
calculates
the
decay
of
a
chemical
applied
to
foliar
surfaces
for
single
or
multiple
applications.
The
model
assumes
initial
concentrations
on
plant
surfaces
based
on
Kenaga
predicted
maximum
and
mean
residues
as
modified
by
Fletcher
et
al.
(
1994)
and
assumes
1st
order
dissipation.
Kenaga
estimates
and
an
explanation
of
the
model
with
sample
output
are
presented
in
Appendix
II.
EFED
used
a
35­
day
TFR
half­
life
value
for
estimating
terrestrial
EECs.
Mancozeb
is
used
on
more
than
20
crop
grouping
(
see
Table
II­
1)
or
more
than
40
crops.
The
DFR
studies
in
Table
II­
2
provide
half­
life
information
on
4
crops
(
that
is,
grapes,
apples,
tomatoes,
and
turf)
and
TFR
half­
life
information
on
2
crops
(
that
is,
grapes
and
tomatoes).
The
upper
limit
on
half­
life
values
listed
in
Table
II­
2
is
35.4
days.
It
is
reasonable
to
use
this
high­
end
estimate
in
Table
II­
2
(
that
is,
35
days)
in
this
screening
level
assessment.
It
is
reasonable
because
it
is
the
highest,
worst
case,
half­
life
value
and
the
data
available
is
limited.

c.
Risk
Quotients
Chronic
concerns
to
terrestrial
animals
are
exceeded
when
the
RQ
reaches
1.0.
Below
are
graphs
(
figures
VII­
1
through
VII­
4)
representing
mancozeb's
potential
chronic
risks
to
non­
target
terrestrial
animals.
These
graphs
show
the
chronic
RQs
that
can
be
expected
from
terrestrial
animals
feeding
on
the
food
items
listed.
These
chronic
RQs
are
derived
from
EECs
based
on
the
maximum
and
mean
residue
estimates
(
see
Appendix
II)
that
are
expected
on
these
food
items
following
mancozeb's
applications
to
various
sites
shown.
For
example,
the
chronic
RQ
for
birds
feeding
on
short
grass
as
a
result
of
mancozeb
being
applied
to
turf
is
over
90
(
figure
VII­
1)
at
maximum
residue
levels
and
over
30
(
figure
VII­
1)
at
mean
residue
levels.
As
can
be
seen
from
these
graphs,
all
mancozeb's
uses
exceed
chronic
LOCs
for
birds
and
mammals.
The
chronic
exceedances
to
birds
range
from
a
high
RQ
of
91
(
figure
VII­
1)
on
turf
to
a
low
of
1
(
figure
VII­
2)
on
citrus.
For
mammals,
the
range
of
RQ
exceedance
is
from
a
high
of
94
(
figure
VII­
3)
on
turf
to
a
low
of
1
(
figure
VII­
4)
on
peanuts.
These
potential
risks
are
based
on
mancozeb's
current
use
patterns
at
maximum
application
rates
and
minimum
intervals
between
applications.
41
1
10
100
Risk
Quotient
(
RQ)

Turfe
Ornamentals
(
pachysandra)
Turf
(
golf
course)
Papaya
Apples,
etc.
Grapes
(
E.
of
Rocky
Mtns.)
Onion,
Garlic,
&
Shallot
Cranberry
Cucumber
Melons/
Squash
Tomato
Corn
(
E.
of
Miss.
River)

Sites
Mean
for
Fruits,
Pods,
Seeds,
and
Large
Insects
Max.
for
Fruits,
Pods,
Seeds,
and
Large
Insects
Mean
for
Tall
grass
Mean
for
Broadleaf/
Forage
Plants
&
Small
Insects
Mean
for
Short
grass
Max.
for
Tall
grass
Max.
for
Broadleaf/
Forage
Plants
&
Sm
Max.
for
Short
grass
Mancozeb
Avian
Chronic
Risk
Maximum
and
Mean
Risk
Figure
VII­
1
42
1
10
100
Risk
Quotient
(
RQ)

Bananas/
Plantain
Corn
(
W.
of
Miss.
River)
Potato/
Sugar
Beet
Fennel
Peanuts
Forestry
Tobacco
Grapes
(
W.
of
Rocky
Mtns.)
Asparagus
Cotton
Ornamentals
Barley,
etc.
Vegetables
Citrus
Sites
Mean
for
Fruits,
Pods,
Seeds,
and
Large
Insects
Max.
for
Fruits,
Pods,
Seeds,
and
Large
Insects
Mean
for
Tall
grass
Mean
for
Broadleaf/
Forage
Plants
&
Small
Insec
Mean
for
Short
grass
Max.
for
Tall
grass
Max.
for
Broadleaf/
Forage
Plants
&
Max.
for
Short
grass
Mancozeb
Avian
Chronic
Risk
Maximum
and
Mean
Risk
Figure
VII­
2
43
1
10
100
Risk
Quotient
(
RQ)

Turf
Ornamentals
(
pachysandra)
Turf
(
golf
course)
Papaya
Apples,
etc.
Grapes
(
E.
of
Rocky
Mtns.)
Onion,
Garlic,
&
Shallot
Cranberry
Cucumber
Melons/
Squash
Tomato
Corn
(
E.
of
Miss.
River)

Sites
Mean
for
Fruits,
Pods,
Seeds,
and
Large
Insects
Max.
for
Fruits,
Pods,
Seeds,
and
Large
Insects
Mean
for
Tall
grass
Mean
for
Broadleaf/
Forage
Plants
&
Small
In
Mean
for
Short
grass
Max.
for
Tall
grass
Max.
for
Broadleaf/
Forage
Plant
Max.
for
Short
grass
Mancozeb
Mammalian
Chronic
Risk
Maximum
and
Mean
Risk
Figure
VII­
3
It
should
also
be
noted
that
the
applications
of
maneb
to
tobacco,
vegetables,
forestry,
ornamentals
and
turf
assumed
3
applications
per
crop
cycle
since
the
labeling
did
not
indicate
the
number
of
applications
that
could
be
made.
Even
at
this
relatively
low
number
of
applications
chronic
LOC
exceedances
are
high.
44
1
10
100
Risk
Quotient
(
RQ)

Bananas/
Plantain
Corn
(
W.
of
Miss.
River)
Potato/
Sugar
Beet
Fennel
Peanuts
ForestryTobacco
Grapes
(
W.
of
Rocky
Mtns.)
AsparagusCotton
Ornamentals
Barley,
etc.
Vegetables
Citrus
Sites
Mean
for
Fruits,
Pods,
Seeds,
and
Large
Insects
Max.
for
Fruits,
Pods,
Seeds,
and
Large
Insects
Mean
for
Tall
grass
Mean
for
Broadleaf/
Forage
Plants
&
Small
In
Mean
for
Short
grass
Max.
for
Tall
grass
Max.
for
Broadleaf/
Forage
Plants
Max.
for
Short
grass
Mancozeb
Mammalian
Chronic
Risk
Maximum
and
Mean
Risk
Figure
VII­
4
45
EFED
expects
the
potential
acute
risk
to
terrestrial
animals
from
mancozeb's
use
are
a
low
risk
concern
since
mancozeb
is
slightly
to
practically
nontoxic
to
birds
and
practically
nontoxic
to
mammals
on
an
acute
oral
basis.
Acute
RQs
were
not
generated
for
birds
and
mammals.
Since
mancozeb
has
numerous
seed
treatment
uses,
EFED
calculated
RQs
for
birds
from
several
seed
treatment
uses.
The
acute
RQs
for
applications
of
mancozeb
treated
seed
are
in
Appendix
IV,
Table
5.
Results
showed
no
LOCs
were
exceeded.
For
a
more
detailed
listing
and
explanation
of
mancozeb's
risk
to
all
terrestrial
organisms,
see
Appendix
IV.
46
Mancozeb's
Residue
from
Tomato
Use
Based
on
Fate
v.
5
Modeling
1
10
100
1000
10000
1
4
7
10
131619
22
252831
34
37
4043
4649
5255
5861
6467
7073
76
79
Day
ppm
Mancozeb's
Avian
NOAEC
=
125
ppm
Mancozeb's
Mammalian
NOAEL
=
120
ppm
Maximum
Residue
on
Short
Grass
Maximum
Residue
on
Broadleaf/
Forage
Plants
&
Small
Insects
Maximum
Residue
on
Tall
grass
Mean
Residue
on
Short
grass
Mean
Residue
on
Broadleaf/
Forage
Plants
&
Small
Insects
Mean
Residue
on
Tall
grass
Maximum
Residue
on
Fruits,
Pods,
Seeds,
and
Large
Insects
Mean
Residue
on
Fruits,
Pods,
Seeds,
and
Large
Insects
Figure
VII­
5
d.
Terrestrial
Risk
Assessment
The
RQ
values
for
mancozeb's
use
patterns
show
there
is
a
low
acute
risk
to
birds
from
eating
mancozeb
treated
seed
with
no
LOCs
exceeded
(
Table
5,
Appendix
IV).
EFED
calculated
the
RQs
using
the
LD
50
/
sq.
ft
method
for
certain
seed
treatment
uses
to
make
this
determination.
Also
EFED
made
the
following
estimate
to
compare
an
English
house
sparrow's
seed
consumption
with
the
number
of
mancozeb
treated
seeds
needed
to
reach
a
toxic
dose
(
Keehner
D.
July,
1999a).
An
English
house
sparrow's
multiple
dose
acute
oral
LD
50
is
about
1,500
mg
ai/
kg
for
mancozeb
(
MRID
No.
00036094).
Its
food
consumption
is
19.0%
of
body
wt/
day
(
that
is,
5
grams).
Based
on
this,
a
26
gram
English
house
sparrow
would
need
to
consume
591
mancozeb
treated
rice
seeds
to
reach
its
LD
50
(
see
formula
in
Table
5,
Appendix
IV).
15,000
rice
seeds
per
pound
divided
by
4.5359
x
102
grams
per
pound
yields
33
rice
seeds
per
gram.
An
English
house
sparrow,
assuming
it
is
consuming
only
mancozeb
treated
rice
seeds,
would
consume
165
rice
seeds
each
day
(
33
rice
seeds
each
gram
*
5
grams
each
day).
This
consumption
rate
would
be
roughly
4
times
less
than
the
expected
multiple
dose
LD
50
of
591
rice
seeds.
Also,
the
assumption
the
sparrow
would
consume
only
rice
seeds
in
a
single
day
is
unlikely.

Wildlife
can
be
found
in
and
around
all
of
the
sites
mancozeb
is
currently
labeled
for.
For
example,
tomatoes
are
widely
grown
across
the
U.
S.
on
both
a
commercial
and
noncommercial
basis.
Approximately
975,000
lbs
ai
of
mancozeb
are
applied
annually
to
US
fresh
tomatoes
with
56%
of
the
total
fresh
tomato,
U.
S.
planted,
acres
being
treated
with
mancozeb
(
EPA
use
data
1987­
1996)(
BEAD's
Quantitative
Usage
Analysis
for
Mancozeb
dated
11/
24/
1998).
Currently,
up
to
7
20
Rate
reductions
determined
by
randomly
inputing
rates
into
ELL­
Fate
spreadsheet
program
until
the
mammalian
chronic
risk
from
mancozeb
residues
on
short
grass
is
less
than
or
equal
to
1.

47
applications
of
mancozeb
are
allowed
to
be
applied
to
tomatoes
every
7
days
during
the
growing
season.
Pheasants,
cottontail
rabbits,
quail,
blackbirds,
deer,
raccoons,
opossums,
skunks,
songbirds,
woodchucks,
crows,
muskrats,
groundhogs,
and
wild
turkeys
all
feed
on
tomato
plants.
In
addition
to
feeding,
some
of
these
animals
utilize
areas
in
and
around
tomatoes
for
nesting,
brood
rearing,
cover
and
loafing
(
Gusey
and
Maturdo,
1973).
The
applications
of
mancozeb
to
tomatoes
occur
from
seedling
emergence
(
spring)
until
5
days
prior
to
harvest
(
late
summer/
early
fall)
which
coincides
with
the
timing
of
the
wildlife
activities
mentioned.
Figure
VII­
5
shows
the
residue
levels
(
ppm)
that
can
be
expected
on
various
avian
and
mammalian
food
items
as
a
result
of
mancozeb's
use
on
tomatoes.
These
mancozeb
residues
are
based
on
mancozeb
being
applied
7
times
every
7
days
at
a
maximum
application
rates
(
2.4
lb
ai/
A).
This
figure
also
shows
the
NOAEC
(
125
ppm)
for
birds
and
the
NOAEL
(
120
ppm)
for
mammals
as
horizontal
lines.
Mancozeb
residue
levels
above
these
lines
pose
a
potential
risk
of
adverse
reproductive
effects
to
the
birds
and/
or
mammals
feeding
on
these
food
items.
For
birds
this
potential
risk
begins
on
Day
1
when
mancozeb
residues
range
from
17
to
576
ppm
for
any
and
all
food
items
the
birds
may
ingest
except
for
fruits,
pods,
seeds,
and
large
insects.
This
potential
risk
continues
throughout
the
tomato
growing
season
for
more
than
79
days.
On
Day
79
the
mancozeb
residues
would
range
from
40
ppm
as
the
mean
residue
on
fruit,
pods,
seeds,
and
large
insects
to
1,355
ppm
as
the
maximum
residue
on
short
grass.
Likewise,
the
potential
reproductive
risk
to
mammals
from
feeding
on
short
grass
(
at
maximum
or
mean
residue
levels),
broadleaf/
forage
plants,
small
insects,
and
tall
grass
at
maximum
expected
mancozeb
residues
would
begin
on
Day
1
and
continue
throughout
the
tomato
growing
season
for
more
than
79
days.
From
figure
VII­
5,
the
only
food
items
that
birds
and
mammals
could
feed
on
without
a
potential
reproductive
risk
are
fruit,
pods,
seeds
and
large
insects
and
this
assumes
that
only
mean
mancozeb
residues
would
be
expected
on
these
food
items.

In
this
screening
level
assessment,
mancozeb's
high
application
rates
combined
with
repeat
applications
are
a
major
reason
why
avian
and
mammalian
LOCs
are
exceeded.
Single
application
rates
range
from
0.9
lb
ai/
A
on
citrus
to
19
lb
ai/
A
on
turf.
Labeling
allows
repeat
applications
at
these
maximum
rates
for
all
mancozeb's
uses.
These
high
applications
rates
with
repeat
applications
increases
the
exposure
of
mancozeb
to
nontarget
organism.
High
exposure
is
the
reason
for
high
RQs.
One
way
to
grasp
the
impact
of
the
high
exposure
is
to
use
modeling
to
estimate
the
reductions
needed
to
reduce
the
EECs
below
the
LOCs.
Using
modeling
to
calculate
EECs
below
LOCs
is
simply
a
rough
estimate
but
does
provide
some
insight
into
the
extent
mancozeb's
application
rates
contributes
to
potential
chronic
risk
to
birds
and
mammals.

To
reduce
the
exposure
risk
to
birds
and
mammals
from
mancozebs's
use
on
tomatoes,
the
maximum
single
application
rate
would
need
to
be
reduced
from
the
current
2.4
lb
ai/
A
to
0.1
lb
ai/
A
(
see
figure
VII­
6)
20.
This
calls
for
a
24­
fold
decrease
in
the
maximum
application
rate
of
mancozeb
to
tomatoes.
A
combination
of
rate
drops
with
a
decrease
in
the
number
of
applications
per
growing
season,
could
also
be
used
to
lessen
the
EECs.
However,
to
reduce
the
chronic
EEC
exposure
risk,
essentially
only
1
mancozeb
application
could
be
made
to
tomatoes
at
a
maximum
application
rate
of
0.5
lb
ai/
A
(
see
figure
VII­
7).
This
translates
to
a
5­
fold
application
rate
decrease
and
cuts
out
all
multiples
applications.
Current
labeling
allows
seven
mancozeb
applications
to
tomatoes.
48
Mancozeb
Chemical
Name:
Tomatoes
Use
Non­
granular
Formulation
Inputs
lbs
a.
i./
acre
0.1
Application
Rate
days
35
Half­
life
days
7
Application
Interval
7
Maximum
#
Apps./
Yea
Outputs
56
Day
Average
Maximum
Concentration
Concentration
(
PPM)
(
PPM)
73.52
115.15
Short
Grass
33.70
52.78
Tall
Grass
41.36
64.77
Broadleaf
plants/
Insec
4.60
7.20
Seeds
1600
Acute
LC50
(
ppm)
Avian
125
Chronic
NOAEC
(
pp
Chronic
RQ
Acute
RQ
(
Max.
res.
mult.
apps.)
0.92
0.0720
Short
Grass
0.42
0.0330
Tall
Grass
0.52
0.0405
Broadleaf
plants/
Insec
0.06
0.0045
Seeds
5000
Acute
LD50
(
mg/
kg)
Mammalian
120
Chronic
NOAEL
(
mg
1000
g
mammal
35
g
mamma
15
g
mammal
Rat
Chron
Dietary
Acute
RQ
Acute
RQ
Acute
RQ
RQ
(
mult.
apps)
(
mult.
apps)
(
mult.
apps)
0.96
0.00345
0.01520
0.02188
Short
Grass
0.44
0.00158
0.00697
0.01003
Tall
Grass
0.54
0.00194
0.00855
0.01231
Broadleaf
plants/
Insec
0.06
0.00022
0.00095
0.00137
Seeds
Figure
VII­
6:
Mancozeb's
Reduction
in
Application
Rate
to
Tomatoes
(
Libelo.
1999)
49
Mancozeb
Chemical
Name:
Tomatoes
Use
Non­
granular
Formulation
Inputs
lbs
a.
i./
acre
0.5
Application
Rate
days
35
Half­
life
days
0
Application
Interval
1
Maximum
#
Apps./
Yea
Outputs
56
Day
Average
Maximum
Concentration
Concentration
(
PPM)
(
PPM)
73.23
120.00
Short
Grass
33.56
55.00
Tall
Grass
41.19
67.50
Broadleaf
plants/
Insec
4.58
7.50
Seeds
1600
Acute
LC50
(
ppm)
Avian
125
Chronic
NOAEC
(
pp
Chronic
RQ
Acute
RQ
(
Max.
res.
mult.
apps.)
0.96
0.0750
Short
Grass
0.44
0.0344
Tall
Grass
0.54
0.0422
Broadleaf
plants/
Insec
0.06
0.0047
Seeds
5000
Acute
LD50
(
mg/
kg)
Mammalian
120
Chronic
NOAEL
(
mg
1000
g
mammal
35
g
mamma
15
g
mammal
Rat
Chron
Dietary
Acute
RQ
Acute
RQ
Acute
RQ
RQ
(
mult.
apps)
(
mult.
apps)
(
mult.
apps)
1.00
0.00360
0.01584
0.02280
Short
Grass
0.46
0.00165
0.00726
0.01045
Tall
Grass
0.56
0.00203
0.00891
0.01283
Broadleaf
plants/
Insec
0.06
0.00023
0.00099
0.00143
Seeds
Figure
VII­
7:
Mancozeb's
Reduction
in
Number
of
Applications
to
Tomatoes
(
Libelo.
1999)

Excluding
mancozeb's
dip
treatment
and
seed
treatment
uses,
there
are
over
twenty
different
crop
groupings
listed
in
Table
II­
1,
above.
Each
of
these
groupings
represent
a
unique
use
pattern
based
on
rates
of
application,
number
of
applications
allowed
per
crop
cycle
or
season,
and
minimum
intervals
between
applications.
The
risk
assessment,
using
tomatoes
as
an
example,
could
be
extended
to
each
of
these
separate
crop
groupings
with
similar
results.
The
potential
temporal
chronic
risks
to
birds
and
mammals
from
mancozeb's
current
uses
are
provided
in
Table
VII­
2.
As
with
the
tomato
use
the
potential
chronic
risks
to
birds
and
mammals
begins
with
the
first
application
of
mancozeb
to
the
crop
and
continues
throughout
the
crop
cycle.
50
Table
VII­
2.
Temporal
Chronic
Risks
as
a
Result
of
Mancozeb
Residues
on
Avian/
Mammalian
Food
Items.
1
Crop
Number
of
Days
Mancozeb
ResiduesExceed
Birds'
Chronic
NOAEC
(
125
ppm)
&
Mammals'
Chronic
NOAEL
(
120
ppm)
(
days)
7
Range
of
Average,
Daily,
Maximum
Mancozeb
Residues
on
Short
Grass
to
Average,
Daily,
Mean
Mancozeb
Residues
on
Fruits,
Pods,
Seed
&
Large
Insects
(
ppm)

Apples,
Cranapple,
Pear,
&
Quince
>
58
2,451
to
71
Asparagus
>
70
733
to
21
Bananas
&
Plantain
>
170
1,448
to
42
Barley,
Oats,
Rye,
Triticale,
&
Wheat
>
51
668
to
19
Citrus2
>
51
375
to
11
Corn
(
unspecified)
>
90
1,688
to
49
Cotton
>
70
733
to
21
Cranberry
>
50
2,001
to
58
Cucumber
>
86
1,883
to
55
Fennel
>
86
1,255
to
37
Garlic
&
Shallot
>
86
647
to
19
Grapes
>
72
2,123
to
62
Melons
&
Squash
>
86
1,883
to
55
Onion
>
100
2,119
to
62
Papaya
>
65
3,275
to
96
Peanuts
>
86
1,255
to
37
Potato
&
Sugar
Beet
>
65
1,310
to
38
Tobacco2
>
45
890
to
26
Tomato
>
79
1,745
to
51
Vegetables2,3
>
51
625
to
18
Forestry
(
Douglas
Fir)
2
>
72
1,101
to
32
Ornamental
Trees2,4
>
72
1,101
to
32
Ornamentals2,5
>
51
667
to
19
Turf2,6
>
45
7,747
to
226
1.
Based
on
FATE
v
5.0
modeling
with
a
total
foliar
residue
half­
life
of
35
days.
2.
Maximum
number
of
applications/
year
or
crop
cycle
not
specified
on
labeling.
Assumed
3
applications
per
crop
cycle.
3.
Beets
(
unspecified),
Broccoli,
Brussel
sprouts,
Cabbage,
Carrots,
Cauliflower,
Chard
(
Swiss),
Collards,
Coriander,
Dill,
Endive,
Kale,
Kohlrabi,
Leeks,
Lettuce,
Mustard,
Mustard
Cabbage,
Parsley,
Parsnip,
Radish,
Rape,
Roquette
(
Arrugula),
Rutabaga,
Spinach,
&
Turnip
4.
Christmas
Tree
Plantations
5.
Trees,
Herbaceous
Plants,
Non
Flowering
Plants,
&
Woody
Shrubs
and
Vines
6.
Commercial/
Industrial,
Golf
Course,
Sod
Farm
&
Residential
7.
Maximum
Number
of
Applications
*
Minimum
Interval
Between
Applications
+
30
days
Table
VII­
2
lists
the
number
of
days
mancozeb's
potential
chronic
risks
to
birds
and
mammals
extends.
The
third
column
of
Table
VII­
2
shows
range
of
average
maximum
residues
to
average
mean
residues
for
the
days
listed
in
the
middle
column.
51
i.
Incidents
The
Ecological
Incident
Information
System
(
EIIS)
showed
mancozeb
was
connected
to
bird
kill
and
plant
damage
incidents.
The
bird
kill
occurred
in
1992
on
an
island
near
France.
In
this
case,
mancozeb
had
been
applied
with
an
insecticide
(
methomyl)
highly
toxic
[
methomyl
mallard
duck
acute
oral
LD
50
=
15.9
mg/
kg
(
US
EPA.
1998)]
to
birds.
The
insecticide
was
confirmed
through
sampling
and
mancozeb
was
determined
to
be
a
possible
contributory
cause
to
the
bird
kill.
The
plant
damage
incident,
reported
mancozeb
had
been
tanked
mixed
with
benomyl
and
applied
to
apple
trees.
This
application
may
have
caused
leaves
and
blossoms
to
drop
from
the
trees.
All
US
pesticide
uses
of
benomyl
were
voluntarily
canceled
by
the
registrant,
DuPont,
in
2001
(
USEPA.
2001).
According
to
the
registrant,
identical
applications
made
by
other
growers
in
the
area
to
apple
orchards
did
not
result
in
this
damage
and
mancozeb
was
determined
to
be
a
possible
contributory
cause
to
the
damage.

The
acute
toxicity
data
provided
in
this
document
for
birds
shows
mancozeb
is
slightly
to
practically
nontoxic
to
birds
(
oral
LD
50
~
1500
mg/
kg
for
the
sparrow
and
>
6400
mg/
kg
for
the
duck
and
quail).
Methomyl
is
highly
toxic
to
birds.
It
is
unlikely
mancozeb
contributed
to
this
bird
kill
and
more
likely
methomyl
caused
the
kill.
Current
toxicity
data
received
on
MAI
nontarget
plant
testing
with
mancozeb
does
not
show
mancozeb
should
adversely
affect
terrestrial
plants
(
none
of
the
ten
terrestrial
plant
species
tested
displayed
$
25%
inhibition
to
plant
growth).
However,
SAI
testing
is
being
required
for
mancozeb
to
confirm
the
terrestrial
plant
toxicity
status
of
mancozeb
(
see
Appendix
III
for
details).
At
this
point,
it
would
appear
the
plant
damage
was
not
likely
to
have
been
caused
from
mancozeb
exposure.

Even
though
mancozeb
appears
to
pose
a
low
acute
risk
to
terrestrial
animals
and
plants,
the
chronic
LOCs
to
terrestrial
animals
(
birds
and
mammals)
are
exceeded
for
all
mancozeb
use
patterns.
The
incident
reports
sent
to
EPA
mainly
deal
with
field
mortality
of
wildlife
and
phytotoxicity
issues.
Chronic
problems
that
affect
wildlife
from
the
use
of
mancozeb
and
it's
degradate,
ETU,
would
be
expected
to
be
largely
unnoticed
in
the
field
and
thus
incident
reports,
from
chronic
problems
in
wildlife,
would
not
be
expected.

ii.
Endocrine
Disruptors
EPA
is
required
under
the
Federal
Food,
Drug,
and
Cosmetic
Act
(
FFDCA),
as
amended
by
the
Food
Quality
Protection
Act
(
FQPA),
to
develop
a
screening
program
to
determine
whether
certain
substances
(
including
all
pesticide
active
and
other
ingredients)
"
may
have
an
effect
in
humans
that
is
similar
to
an
effect
produced
by
a
naturally­
occurring
estrogen,
or
other
such
endocrine
effects
as
the
Administrator
may
designate."
Following
the
recommendations
of
its
Endocrine
Disruptor
Screening
and
Testing
Advisory
Committee(
EDSTAC),
EPA
determined
that
there
was
scientific
basis
for
including,
as
part
of
the
program,
the
androgen­
and
thyroid
hormone
systems,
in
addition
to
the
estrogen
hormone
system.
EPA
also
adopted
EDSTAC's
recommendation
that
the
Program
include
evaluations
of
potential
effects
in
wildlife.
For
pesticide
chemicals,
EPA
will
use
FIFRA
and,
to
the
extent
that
effects
in
wildlife
may
help
determine
whether
a
substance
may
have
an
effect
in
humans,
FFDCA
authority
to
require
the
wildlife
evaluations.
As
the
science
develops
and
resources
allow,
screening
of
additional
hormone
systems
may
be
added
to
the
Endocrine
Disruptor
Screening
Program
(
EDSP).
52
The
avian
reproductive
studies
reviewed
by
EFED
noted
reproductive
effects
such
as
reductions
in:
egg
production;
early
and
late
embryo
viability;
hatchability;
offspring
weight
at
hatch
and
14­
days
of
age;
and
the
number
of
14­
day
old
survivors.
For
mammals
chronic
effects
were
noted
such
as
decreased
serum
thyroxine
levels
being
the
endpoints
affected
in
females
and
body
weight
decrements,
changes
in
thyroid
hormones,
changes
in
liver
enzymes,
microscopic
changes
in
the
liver
and
thyroids,
increased
absolute
and
relative
thyroid
weights,
and
increased
relative
liver
weights
being
the
endpoints
affected
in
males.
Some
developmental
effects
noted
in
mammals
were
gross
developmental
defects,
central
nervous
system
defects,
skeletal
defects,
cryptorchidism
(
failure
of
one
or
more
testes
to
descend
into
the
scrotum)
,
abortions,
etc.
See
Appendix
III
for
a
detailed
listing
of
the
studies
and
results.
These
effects
noted
in
both
birds
and
mammals
could
be
a
result
of
hormonal
disruptions
and
may
tend
to
support
the
concern
that
mancozeb
may
be
an
endocrine
disruptor.
Based
on
these
effects
in
birds
and
mammals,
EFED
recommends
that
when
appropriate
screening
and/
or
testing
protocols
being
considered
under
the
Agency's
EDSP
have
been
developed,
mancozeb
be
subjected
to
more
definitive
testing
to
better
characterize
effects
related
to
its
possible
endocrine
disruptor
activity.

iii.
Endangered
Species
Based
on
available
screening
level
information,
there
is
a
potential
concern
for
mancozeb's
chronic
effects
on
listed
Endangered
and
Threatened
species
of
birds
and
mammals
should
exposure
actually
occur.
EFED
is
uncertain
about
mancozeb's
risk
to
endangered/
threatened
non­
target
terrestrial
plants
and
needs
testing
performed
at
mancozeb's
maximum
rate
of
application
in
the
environment.
53
APPENDIX
I:
Notes
on
Fate
Studies
and
Modeling
&
Additional
Fate
Data
a.
Notes
on
Fate
Studies
i.
Aqueous
medium
studies
Guidance
for
hydrolysis
and
aqueous
photolysis
require
EBDC
parent
to
be
applied
at
concentrations
within
the
solubility
range.
It
was
established
that
any
part
of
EBDC
parent
that
goes
into
solution
will
completely
decompose,
by
hydrolytic
reactions,
into
a
suite
of
multi
species;
the
EBDCs
Complex.
Reported
levels
of
EBDC
parents
solubilities
water
were
near
2
ppm
for
metiram
and
in
the
range
of
6­
22
ppm
for
mancozeb
and
6­
200
ppm
for
maneb;
at
these
levels
EBDC
parents
decompose
or
hydrolyze
completely.
Additionally,
particle
size
reduction
(
i.
e.
sonication)
is
believed
to
cause
an
increase
in
the
level
susceptibility
of
parent
EBDCs
to
decomposition.
In
most
studies,
levels
used
in
aqueous
media
studies
were
near
this
critical
range
of
susceptibility,
parent
was
determined
by
CS
2
and
suspensions
were
prepared
using
ultrasonic.
Therefore,
calculated
hydrolysis
and/
or
photolysis
half­
lives
are
affected
by:

(
1)
Occurrence
of
hydrolytic
decomposition
during
preparation
of
stock
solution;
indicated
by
the
presence
of
high
concentrations
of
transient
species
and
degradates
at
time
zero.

(
2)
An
increase
of
hydrolytic
reactions
caused
by
reduction
of
particle
size
by
sonication;
and
(
3)
Nonspecificity
of
CS
2
­
determination
for
EBDC
parent
in
the
presence
of
its
hydrolytic
complex
because
it
was
experimentally
proven
that
CS
2
evolves
from
at
least
one
of
its
constituents;
EBIS.

(
4)
influence
of
the
presence
of
metal
ions
on
solubility
of
EBDC
parent
(
i.
e
decomposition
to
EBDCs
Complex).
These
metal
ions
are
introduced
to
the
system
from
chemicals
present
in
buffer
solutions.

In
studies
were
the
solvent
DMSO
is
used,
no
half­
life
could
be
calculated
for
EBDCs
because
no
EBDC
parent
would
be
present
at
time
zero.
This
solvent
appears
to
cause
complete
breakage
of
the
EBDC
complex
into
various
transformation
products
dominated
by
ETU.
This
means
that
such
studies
can
only
be
used
to
identify
effects
of
pH
or
photon
energy
and
aging
on
the
suite
of
EBDCs
Complex
present
at
time
zero.

ii.
Soil/
sediment
studies
Problems
associated
with
soil
sediment/
studies
include:

(
1)
Degradation
of
EBDC
parent,
by
decomposition
in
water,
before
time
zero
and
when
the
application
suspension
is
prepared.
In
most
cases,
resultant
application
suspensions
were
dominated
by
the
EBDCs
Complex.
Analysis
was
not
always
performed
for
suspensions
just
before
application.

(
2)
Extraction
systems
(
i.
e.,
acetonitrile/
water
or
methanol/
water)
appear
to
affect
the
integrity
of
the
parent.
Therefore,
resultant
suite
of
EBDCs
Complex
(
in
the
extraction
solution)
was
at
least
partly
artificial
and
can
not
be
used
to
represent
the
suite
that
might
form
in
the
environment.
The
use
of
different
extraction
systems
made
it
difficult
to
compare
results
obtained
from
different
soils.
54
0
7
14
21
28
Time
(
days)
30
60
50
70
%
of
Applied
Radioactivity
SL
(
Germany)
Loam
(
Germany)
SiL
(
Germany)
SiL
(
Germany)
Approximation
0
50
100
Time
(
days)
50
65
60
70
%
of
Applied
Radioactivity
SL
(
Germany)
Loam
(
Germany)
SiL
(
Germany)
SiL
(
Germany)
Approximation
(
3)
EBDCs
Complex
has
high
affinity
to
soil
and
no
characterization
was
conducted
for
the
resultant
bound
species.
Therefore,
bound
EBDC
Complex
is
suspicious
of
containing
active
species
that
can
be
precursors
for
the
degradate
of
concern
ETU.
For
example,
In
mancozeb
aerobic
soil
studies,
Bound
species
degraded
after
reaching
a
plateau
in
the
range
of
55­
70%.
Production
of
degradates
and
CO
2
,
increased
after
the
Bound
species
reach
the
described
plateau.
Figure
1
shows
bound
radioactivity
distribution
with
time
as
reported
for
soils
in
four
aerobic
soil
studies.

(
4)
Nonspecificity
of
CS
2
­
determination
for
EBDC
parent
in
the
presence
of
its
hydrolytic
complex
because
it
was
experimentally
proven
that
CS
2
evolves
from
at
least
one
of
its
constituent;
EBIS.

(
5)
Chromatographic
separation
between
EBDC
parent
and
various
species
in
its
complex
was
not
conclusive
and
solvents
used
appear
to
affect
the
integrity
of
parent
and
some
degradates
and/
or
transient
species.

Figure
1.
Change
of
bound
radioactivity
with
time
in
four
aerobic
soils
treated
with
mancozeb.

Therefore,
the
above
mentioned
difficulties
should
be
taken
in
consideration
in
determining
species
present
in
fate
studies
and
those
expected
to
be
present
in
the
natural
environment.
For
example,
in
mancozeb,
it
is
expected
that
species
present
in
fate
studies
are
those
shown
in
Figure
2
and
those
55
in
compartments
of
the
natural
environment
are
those
shown
in
Figure
3.
56
0
7
14
21
28
35
42
Time
(
days);
Four
Applications
at
days:
0,
7,
14
and
21
0
1
2
7
Expected
Metiram
Parent
Concentration
(
ppm)

Parent
EECs
based
on
Hydrolysis
half­
life=
0.7
day)
b.
Notes
on
Modeling
i.
EECs
for
Parent
mancozeb
EECs
for
Parent
mancozeb
are
presented
in
the
Figure
4.
Data
for
EECs
were
calculated
using
the
slope
of
the
line
for
0.7
days
(
Table
IV.
2);
the
estimated
hydrolysis
half.
Other
assumptions
included:

­
Application
rate
of
4.8
lbs
a.
i/
Acre
applied
four
times
at
7­
day
intervals;

­
All
applied
material
reached
the
soil
and
mixed
with
top
2"
giving
a
zero
time
concentration
of
7.1
ppm.

­
Enough
moisture
is
present
to
complete
hydrolytic
reactions.

Data
indicate
that
soil
EECs
of
Parent
mancozeb
are
expected
to
be
below
1
ppm
(.
14%
of
the
applied)
within
2
days
of
the
first
application
and
reach
less
than
0.01
ppm
(<
1%
of
the
applied)
just
before
the
second
application.
The
same
is
repeated
after
each
of
the
four
application
with
negligible
amounts
being
left
within
one
week
from
the
last
application.
This
data
are
believed
to
represent
concentrations
in
soil
environments
where
most
of
the
pesticide
is
applied.
However,
higher
EECs
is
expected
in
dry
conditions
and
in
soils
with
very
low
water
holding
capacity.

Considering
that
only
a
small
fraction
of
the
applied
material
would
reach
water
bodies
by
drift,
Mancozeb
Complex,
not
parent,
is
the
species
expected
to
be
found
in
water
bodies
affected
by
drift.

Figure
4.
EECs
for
Parent
mancozeb
following
four
applications
of
4.8
lbs
a.
i/
acre
applied
four
times
at
7­
day
intervals.
57
ii.
Background
Information
on
the
PRZM
and
EXAMS
models
&
the
Index
Reservoir
Scenario
The
linked
PRZM
and
EXAMS
models
are
used
in
this
case
as
a
second
tier
screen
designed
to
estimate
the
pesticide
concentrations
found
in
water
for
use
in
drinking
water
assessments.
They
provide
high­
end
values
on
the
concentrations
that
might
be
found
in
a
small
drinking
water
reservoir
due
to
the
use
of
pesticide.
The
Drinking
Water
Index
Reservoir
scenario
includes
a
427
acres
field
immediately
adjacent
to
a
13
acres
reservoir,
9
feet
deep,
with
continuous
site­
specific
flow.
This
amount
can
be
reduced
due
to
degradation
in
field
and
the
effect
of
binding
to
soil.
Spray
drift
is
equal
to
6.4%
of
the
applied
concentration
from
the
ground
spray
application
and
16%
for
aerial
applications.

The
PRZM/
EXAMS
modeling
system
with
the
Index
Reservoir
scenario
also
makes
adjustments
for
the
percent
cropped
area.
While
it
is
assumed
that
the
entire
watershed
would
not
be
treated,
the
use
of
a
PCA
is
still
a
screen
because
it
represents
the
highest
percentage
of
crop
cover
of
any
large
watershed
in
the
US,
and
it
assumes
that
the
entire
crop
is
being
treated.
Various
other
conservative
assumptions
of
this
scenario
include
the
use
of
a
small
drinking
water
reservoir
surrounded
by
a
runoff­
prone
watershed,
the
use
of
the
maximum
use
rate
and
no
buffer
zone.

iii.
Background
Information
on
SCIGROW
SCI­
GROW
is
a
screening
model
which
the
Office
of
Pesticide
Programs
(
OPP)
in
EPA
frequently
uses
to
estimate
pesticide
concentrations
in
vulnerable
ground
water.
The
model
provides
an
exposure
value
which
is
used
to
determine
the
potential
risk
to
the
environment
and
to
human
health
from
drinking
water
contaminated
with
the
pesticide.
The
SCI­
GROW
estimate
is
based
on
environmental
fate
properties
of
the
pesticide
(
aerobic
soil
degradation
half­
life
and
linear
adsorption
coefficient
normalized
for
soil
organic
carbon
content),
the
maximum
application
rate,
and
existing
data
from
small­
scale
prospective
ground­
water
monitoring
studies
at
sites
with
sandy
soils
and
shallow
ground
water.

Pesticide
concentrations
estimated
by
SCI­
GROW
represent
conservative
or
high­
end
exposure
values
because
the
model
is
based
on
ground­
water
monitoring
studies
which
were
conducted
by
applying
pesticides
at
maximum
allowed
rates
and
frequency
to
vulnerable
sites
(
i.
e.,
shallow
aquifers,
sandy,
permeable
soils,
and
substantial
rainfall
and/
or
irrigation
to
maximize
leaching).
In
most
cases,
a
large
majority
of
the
use
areas
will
have
ground
water
that
is
less
vulnerable
to
contamination
than
the
areas
used
to
derive
the
SCI­
GROW
estimate.
SCIGROW
provides
a
groundwater
screening
exposure
value
to
be
used
in
determining
the
potential
risk
to
human
health
from
drinking
water
contaminated
with
the
pesticide.
SCIGROW
estimates
likely
groundwater
concentrations
if
the
pesticide
is
used
at
the
maximum
allowable
rate
in
areas
where
groundwater
is
exceptionally
vulnerable
to
contamination.
In
most
cases,
a
large
majority
of
the
use
area
will
have
groundwater
that
is
less
vulnerable
to
contamination
than
the
areas
used
to
derive
the
SCIGROW
estimate.
58
c.
Additional
Fate
Data
The
following
are
additional
fate
data
on
mancozeb
mobility:

Table
1.
K
ads
and
K
oc
and
characteristics
of
the
soils
used
in
the
adsorption/
desorption
study
(
MRID
00888­
22)

Soil/
Sediment
Type
Solomon
CL
Virdan
SiCL
1
Sassafras
SL
Hagerstown
SiL
Cecil
Clay
2
Delaware
River
Sediment
Textural
class
Clay
Loam
silty
Clay
loam
Sandy
Loam
Silty
Loam
Clay
Silt
Clay
(%)
32
18
6.0
28
54
8
pH
(
water)
7.4
6.0
4.9
6.4
4.7
5.7
%
Organic
carbon
8.78
3.08
0.23
1.98
0.23
6.28
C.
E.
C
(
meq/
100g)
49.9
21.4
1.6
9.4
6.9
8.5
K
ads
32
49
18
4
50
101
K
oc
365
1,591
7,826
202
21,739
1,608
1
Montmorillonite
Clay;
2
Kaolinite
clay.

Table
2.
K
ads
and
K
oc
and
characteristics
of
the
soils
used
in
the
adsorption/
desorption
study
(
MRID402229­
01)

State
Georgia
Georgia
Pennsylvania
Mississippi
Textural
class
Sand
(
GA)
Sandy
Loam
Silty
Loam
Clay
loam
Clay
(%)
4
12
20
28
pH
(
water)
5.7
5.9
6.4
7.4
%
Organic
carbon
0.5
1.6
2.0
1.5
C.
E.
C
(
meq/
100g)
3.5
5.7
9.6
12.9
K
ads
11.67
9.89
7.26
10.13
K
oc
2,320
618
363
675
59
APPENDIX
II:
Hoerger­
Kenaga
Estimates
&
Fate
v.
5.0
Model
a.
Hoerger­
Kenaga
Estimates
EFED
uses
Hoerger
and
Kenaga
estimates
(
1972)
as
changed
by
Fletcher
and
other
researchers
(
1994)
to
estimate
the
residues
on
plants
and
insects.
Hoerger­
Kenaga
categories
represent
preferred
foods
of
various
terrestrial
vertebrates.
Upland
game
birds
prefer
fruits
and
bud
and
shoot
tips
of
leafy
crops.
Hares
and
hoofed
mammals
consume
leaves
and
stems
of
leafy
crops.
Rodents
consume
seeds,
seedpods
and
grasses;
and
various
birds,
mammals,
reptiles
and
terrestrial­
phase
amphibians
consume
insects.
Terrestrial
vertebrates
also
may
contact
pesticides
applied
to
soil
by
swallowing
pesticide
granules
or
pesticide­
laden
soil
when
foraging.
Rich
in
minerals,
soil
comprises
5
to
30%
of
dietary
intake
by
many
wildlife
species
(
Beyer
and
Conner).

Hoerger
and
Kenaga
based
pesticide
environmental
concentration
estimates
on
residue
data
correlated
from
more
than
20
pesticides
on
more
than
60
crops.
These
estimates
are
representative
of
many
geographic
regions
(
7
states)
and
a
wide
array
of
cultural
practices.
Hoerger­
Kenaga
estimates
also
considered
differences
in
vegetative
yield,
surface
to
mass
ratio
and
interception
causes.
In
1994,
Fletcher,
Nellessen
and
Pfleeger
reexamined
the
Hoerger­
Kenaga
simple
linear
model
(
y=
B1x,
where
x=
application
rate
and
y=
pesticide
residue
in
ppm)
to
decide
whether
the
terrestrial
EEC's
were
accurate.
They
compiled
a
data
set
of
pesticide
day­
0
and
residue­
decay
data
involving
121
pesticides
(
85
insecticides,
27
herbicides,
and
9
fungicides
from
17
different
chemical
classes)
on
118
species
of
plants.
After
analysis,
their
conclusions
were
that
Hoerger­
Kenaga
estimates
needed
only
minor
changes
to
increase
the
predictive
values.
They
recommended
an
increase
for
forage
and
fruit
categories
from
58
to
135
ppm
and
from
7
to
15
ppm,
respectively.
Otherwise,
the
Hoerger­
Kenaga
estimates
were
accurate
in
predicting
the
maximum
residue
values
after
a
1
lb
ai/
acre
application.
Mean
values
represent
the
arithmetic
mean
of
values
from
samples
collected
the
day
of
pesticide
treatment.
The
values
in
the
table
below
are
the
predicted
0­
day
maximum
and
mean
residues
of
a
pesticide
that
may
occur
on
selected
avian,
mammalian,
reptilian
or
terrestrial­
phase
amphibian
food
items.
These
predicted
residues
occur
immediately
following
a
direct
single
application
at
a
1
lb
ai/
acre
application
rate.
For
pesticides
applied
as
a
nongranular
product
(
for
example,
liquid
or
dust),
EFED
compared
the
estimated
environmental
concentrations
(
EECs)
on
food
items
following
product
application
to
LC
50
values
to
assess
risk.
EFED
based
the
estimated
environmental
concentrations
of
ETU
on
food
items
on
Kenaga
maximum
and
mean
predicted
values.

Estimated
Environmental
Concentrations
on
Avian
and
Mammalian
Food
Items
(
ppm)
Following
a
Single
Application
at
1
lb
ai/
A)

Food
Items
EEC
(
ppm)
Predicted
Maximum
Residue1
EEC
(
ppm)
Predicted
Mean
Residue1
Short
grass
240
85
Tall
grass
110
36
Broadleaf/
forage
plants
and
small
insects
135
45
Fruits,
pods,
seeds,
and
large
insects
15
7
1
Predicted
maximum
and
mean
residues
are
for
a
1
lb
ai/
a
application
rate
and
are
based
on
Hoerger
and
Kenaga
(
1972)
as
modified
by
Fletcher
et
al.
(
1994).
60
b.
Fate
v.
5.0
Model
Terrestrial
Exposure
Values
The
model
assumes
a
first
order
decay
to
fix
the
concentration
at
each
day
after
first
application
based
on
the
concentration
resulting
from
the
first
and
more
applications.
The
model
calculates
decay
from
the
first
order
rate
equation:

CT
=
Ci
e­
kT
or
in
integrated
form:
ln
(
CT/
Ci)
=
­
kT
Where:

CT
=
concentration
at
time
T
on
day
zero
Ci
=
concentration
in
parts
per
million
(
ppm)
present
initially
(
on
day
zero)
on
the
surfaces.
The
model
calculates
Ci
based
on
Kenaga
and
Fletcher
by
multiplying
the
application
rate,
in
pounds
active
ingredient
per
acre.
The
model
multiplies
the
application
rate
by
240
(
mean
of
85)
for
short
grass,
110
(
mean
of
36)
for
tall
grass,
and
135
(
mean
of
45)
for
broad­
leaf
plants
and
insects
and
15
(
mean
of
7)
for
seeds.
The
model
converts
extra
applications
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
reported
by
half­
life,
the
model
calculates
the
rate
constant
from
the
half­
life
(
k
=
ln
2/
T1/
2).
Choosing
the
degradation
rate
and
half­
life
to
use
in
terrestrial
exposure
calculations
is
open
for
debate
and
should
be
done
by
a
qualified
scientist.

T=
time,
in
days,
since
the
start
of
the
simulation.
The
first
application
is
on
day
0.
The
simulation
runs
for
the
number
of
days
entered
by
the
modeler.

The
program
calculates
concentration
on
each
surface
on
a
daily
interval
for
the
number
of
days
entered
by
the
modeler.
The
modeler
chooses
the
days
based
on
the
guidance
provided
in
Urban,
2000.
The
modeler
uses
the
following
formula
with
acute
exposure
addition
of
30
days
or
the
chronic
exposure
addition
of
60
days:

maximum
number
of
applications
crop
cycle
or
season
minimum
interval
between
applications
(
days)
+
30
or
60
days
*

The
model
calculates
maximum
and
mean
EECs
based
on
the
maximum
and
mean
Kenaga­
Fletcher
values
listed
in
Table
1
above.
These
EECs
are
the
maximum
amounts
collecting
on
each
day
during
the
interval
chosen.
The
model
calculates
these
EECs
for
the
different
food
item
groupings.

c.
Fate
v.
5.0
Model
Sample
Output
for
Mancozeb
RUN
No.
1
FOR
MANCOZEB
ON
APPLES,
ETC
***
INPUT
VALUES
***
­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­
61
RATE(#/
AC)
APPLICATIONS
HALF­
LIFE
AVIAN
(
ppm)
MAMMALIAN
(
mg/
kg)
ONE(
MAX)
NO.­
INTERVAL
(
DAYS)
LC50
NOAEC
LD50
NOAEL
­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­
4.800(
15.783)
4
7
35.0
*******
*******
*******
*******

MAXIMUM
&
58
DAY
AVERAGE
KENAGA/
FLETCHER
RESIDUES:
95th%
(
mean)
in
ppm
­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­
SHORT
BROADLEAF
TALL
SEED
GRASS
&
INSECTS
GRASS
FRUIT
____________________
________________
________________
________________
MAX
3787.96(
1341.57)
2130.73(
710.24)
1736.15(
568.19)
236.75(
110.48)

RUN
No.
2
FOR
MANCOZEB
ON
ASPARAGUS
***
INPUT
VALUES
***
­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­
RATE(#/
AC)
APPLICATIONS
HALF­
LIFE
AVIAN
(
ppm)
MAMMALIAN
(
mg/
kg)
ONE(
MAX)
NO.­
INTERVAL
(
DAYS)
LC50
NOAEC
LD50
NOAEL
­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­
1.600(
4.873)
4
10
35.0
*******
*******
*******
*******

MAXIMUM
&
70
DAY
AVERAGE
KENAGA/
FLETCHER
RESIDUES:
95th%
(
mean)
in
ppm
­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­
SHORT
BROADLEAF
TALL
SEED
GRASS
&
INSECTS
GRASS
FRUIT
____________________
________________
________________
________________
MAX
1169.41(
414.16)
657.79(
219.26)
535.98(
175.41)
73.09(
34.11)

Below
are
lists
of
daily
Kenaga­
Flether
pesticide
residue
values
for
four
avian/
mammalian
food
groupings
for
MANCOZEB
use
on
TOMATO
Values
are
in
parts
per
million
(
ppm).

SHORT
BROADLEAF
TALL
SEED
GRASS
&
INSECTS
GRASS
FRUIT
DAILY
DAILY
DAILY
DAILY
VALUES
VALUES
VALUES
VALUES
DAY
95%
MEAN
95%
MEAN
95%
MEAN
95%
MEAN
___
_______________
_______________
_______________
_______________

1
576.00
204.00
324.00
108.00
264.00
86.40
36.00
16.80
2
564.71
200.00
317.65
105.88
258.82
84.71
35.29
16.47
3
553.63
196.08
311.42
103.81
253.75
83.04
34.60
16.15
4
542.78
192.23
305.31
101.77
248.77
81.42
33.92
15.83
5
532.13
188.46
299.32
99.77
243.89
79.82
33.26
15.52
6
521.70
184.77
293.45
97.82
239.11
78.25
32.61
15.22
7
511.47
181.14
287.70
95.90
234.42
76.72
31.97
14.92
8
1077.44
381.59
606.06
202.02
493.83
161.62
67.34
31.43
9
1056.31
374.11
594.17
198.06
484.14
158.45
66.02
30.81
10
1035.60
366.77
582.52
194.17
474.65
155.34
64.72
30.20
11
1015.29
359.58
571.10
190.37
465.34
152.29
63.46
29.61
12
995.38
352.53
559.90
186.63
456.22
149.31
62.21
29.03
13
975.86
345.62
548.92
182.97
447.27
146.38
60.99
28.46
14
956.72
338.84
538.16
179.39
438.50
143.51
59.80
27.90
15
1513.96
536.20
851.60
283.87
693.90
227.09
94.62
44.16
16
1484.28
525.68
834.91
278.30
680.29
222.64
92.77
43.29
17
1455.17
515.37
818.53
272.84
666.95
218.28
90.95
42.44
18
1426.63
505.27
802.48
267.49
653.87
214.00
89.16
41.61
19
1398.66
495.36
786.75
262.25
641.05
209.80
87.42
40.79
20
1371.23
485.64
771.32
257.11
628.48
205.68
85.70
39.99
21
1344.34
476.12
756.19
252.06
616.16
201.65
84.02
39.21
22
1893.98
670.79
1065.36
355.12
868.07
284.10
118.37
55.24
23
1856.84
657.63
1044.47
348.16
851.05
278.53
116.05
54.16
62
24
1820.43
644.74
1023.99
341.33
834.36
273.06
113.78
53.10
25
1784.73
632.09
1003.91
334.64
818.00
267.71
111.55
52.05
26
1749.74
619.70
984.23
328.08
801.96
262.46
109.36
51.03
27
1715.42
607.55
964.93
321.64
786.24
257.31
107.21
50.03
28
1681.79
595.63
946.00
315.33
770.82
252.27
105.11
49.05
29
2224.81
787.95
1251.45
417.15
1019.70
333.72
139.05
64.89
30
2181.18
772.50
1226.91
408.97
999.71
327.18
136.32
63.62
31
2138.41
757.35
1202.85
400.95
980.10
320.76
133.65
62.37
32
2096.48
742.50
1179.27
393.09
960.88
314.47
131.03
61.15
33
2055.36
727.94
1156.14
385.38
942.04
308.30
128.46
59.95
34
2015.06
713.67
1133.47
377.82
923.57
302.26
125.94
58.77
35
1975.55
699.67
1111.24
370.41
905.46
296.33
123.47
57.62
36
2512.81
889.95
1413.45
471.15
1151.70
376.92
157.05
73.29
37
2463.53
872.50
1385.74
461.91
1129.12
369.53
153.97
71.85
38
2415.22
855.39
1358.56
452.85
1106.98
362.28
150.95
70.44
39
2367.86
838.62
1331.92
443.97
1085.27
355.18
147.99
69.06
40
2321.43
822.17
1305.80
435.27
1063.99
348.21
145.09
67.71
41
2275.91
806.05
1280.20
426.73
1043.12
341.39
142.24
66.38
42
2231.28
790.24
1255.09
418.36
1022.67
334.69
139.45
65.08
43
2763.53
978.75
1554.48
518.16
1266.62
414.53
172.72
80.60
44
2709.33
959.56
1524.00
508.00
1241.78
406.40
169.33
79.02
45
2656.21
940.74
1494.12
498.04
1217.43
398.43
166.01
77.47
46
2604.12
922.29
1464.82
488.27
1193.55
390.62
162.76
75.95
47
2553.05
904.21
1436.09
478.70
1170.15
382.96
159.57
74.46
48
2502.99
886.48
1407.93
469.31
1147.20
375.45
156.44
73.00
49
2453.91
869.09
1380.32
460.11
1124.71
368.09
153.37
71.57
50
2405.79
852.05
1353.26
451.09
1102.65
360.87
150.36
70.17
51
2358.61
835.34
1326.72
442.24
1081.03
353.79
147.41
68.79
52
2312.36
818.96
1300.70
433.57
1059.83
346.85
144.52
67.44
53
2267.02
802.90
1275.20
425.07
1039.05
340.05
141.69
66.12
54
2222.56
787.16
1250.19
416.73
1018.67
333.38
138.91
64.82
55
2178.98
771.72
1225.68
408.56
998.70
326.85
136.19
63.55
56
2136.25
756.59
1201.64
400.55
979.12
320.44
133.52
62.31
57
2094.36
741.75
1178.08
392.69
959.92
314.15
130.90
61.09
58
2053.29
727.21
1154.98
384.99
941.09
307.99
128.33
59.89
59
2013.03
712.95
1132.33
377.44
922.64
301.95
125.81
58.71
60
1973.55
698.97
1110.12
370.04
904.55
296.03
123.35
57.56
61
1934.85
685.26
1088.35
362.78
886.81
290.23
120.93
56.43
62
1896.91
671.82
1067.01
355.67
869.42
284.54
118.56
55.33
63
1859.71
658.65
1046.09
348.70
852.37
278.96
116.23
54.24
64
1823.25
645.73
1025.58
341.86
835.65
273.49
113.95
53.18
65
1787.49
633.07
1005.47
335.16
819.27
268.12
111.72
52.14
66
1752.44
620.66
985.75
328.58
803.20
262.87
109.53
51.11
67
1718.08
608.49
966.42
322.14
787.45
257.71
107.38
50.11
68
1684.39
596.55
947.47
315.82
772.01
252.66
105.27
49.13
69
1651.36
584.86
928.89
309.63
756.87
247.70
103.21
48.16
70
1618.98
573.39
910.67
303.56
742.03
242.85
101.19
47.22
71
1587.23
562.14
892.82
297.61
727.48
238.08
99.20
46.29
72
1556.10
551.12
875.31
291.77
713.21
233.42
97.26
45.39
73
1525.59
540.31
858.14
286.05
699.23
228.84
95.35
44.50
74
1495.67
529.72
841.32
280.44
685.52
224.35
93.48
43.62
75
1466.34
519.33
824.82
274.94
672.07
219.95
91.65
42.77
76
1437.59
509.15
808.64
269.55
658.90
215.64
89.85
41.93
77
1409.40
499.16
792.79
264.26
645.97
211.41
88.09
41.11
78
1381.76
489.37
777.24
259.08
633.31
207.26
86.36
40.30
79
1354.67
479.78
762.00
254.00
620.89
203.20
84.67
39.51
80
1328.10
470.37
747.06
249.02
608.71
199.22
83.01
38.74
81
1302.06
461.15
732.41
244.14
596.78
195.31
81.38
37.98
82
1276.53
452.10
718.05
239.35
585.07
191.48
79.78
37.23
83
1251.49
443.24
703.97
234.66
573.60
187.72
78.22
36.50
84
1226.95
434.55
690.16
230.05
562.35
184.04
76.68
35.79
85
1202.89
426.02
676.63
225.54
551.33
180.43
75.18
35.08
86
1179.31
417.67
663.36
221.12
540.52
176.90
73.71
34.40
63
87
1156.18
409.48
650.35
216.78
529.92
173.43
72.26
33.72
88
1133.51
401.45
637.60
212.53
519.52
170.03
70.84
33.06
89
1111.28
393.58
625.10
208.37
509.34
166.69
69.46
32.41
90
1089.49
385.86
612.84
204.28
499.35
163.42
68.09
31.78
91
1068.13
378.29
600.82
200.27
489.56
160.22
66.76
31.15
92
1047.18
370.88
589.04
196.35
479.96
157.08
65.45
30.54
93
1026.65
363.60
577.49
192.50
470.55
154.00
64.17
29.94
94
1006.51
356.47
566.16
188.72
461.32
150.98
62.91
29.36
95
986.78
349.48
555.06
185.02
452.27
148.02
61.67
28.78
96
967.43
342.63
544.18
181.39
443.40
145.11
60.46
28.22
97
948.46
335.91
533.51
177.84
434.71
142.27
59.28
27.66
98
929.86
329.32
523.04
174.35
426.18
139.48
58.12
27.12
99
911.62
322.87
512.79
170.93
417.83
136.74
56.98
26.59
100
893.75
316.54
502.73
167.58
409.63
134.06
55.86
26.07
101
876.22
310.33
492.87
164.29
401.60
131.43
54.76
25.56
102
859.04
304.24
483.21
161.07
393.73
128.86
53.69
25.06
103
842.19
298.28
473.73
157.91
386.01
126.33
52.64
24.56
104
825.68
292.43
464.44
154.81
378.44
123.85
51.60
24.08
105
809.49
286.69
455.34
151.78
371.02
121.42
50.59
23.61
106
793.61
281.07
446.41
148.80
363.74
119.04
49.60
23.15
107
778.05
275.56
437.65
145.88
356.61
116.71
48.63
22.69
108
762.79
270.16
429.07
143.02
349.61
114.42
47.67
22.25
109
747.84
264.86
420.66
140.22
342.76
112.18
46.74
21.81
110
733.17
259.67
412.41
137.47
336.04
109.98
45.82
21.38
111
718.79
254.57
404.32
134.77
329.45
107.82
44.92
20.96
112
704.70
249.58
396.39
132.13
322.99
105.70
44.04
20.55
113
690.88
244.69
388.62
129.54
316.65
103.63
43.18
20.15
114
677.33
239.89
381.00
127.00
310.44
101.60
42.33
19.76
115
664.05
235.18
373.53
124.51
304.36
99.61
41.50
19.37
116
651.03
230.57
366.20
122.07
298.39
97.65
40.69
18.99
117
638.26
226.05
359.02
119.67
292.54
95.74
39.89
18.62
118
625.75
221.62
351.98
117.33
286.80
93.86
39.11
18.25
119
613.48
217.27
345.08
115.03
281.18
92.02
38.34
17.89
120
601.45
213.01
338.31
112.77
275.66
90.22
37.59
17.54
121
589.65
208.84
331.68
110.56
270.26
88.45
36.85
17.20
122
578.09
204.74
325.18
108.39
264.96
86.71
36.13
16.86
123
566.75
200.73
318.80
106.27
259.76
85.01
35.42
16.53
124
555.64
196.79
312.55
104.18
254.67
83.35
34.73
16.21
125
544.74
192.93
306.42
102.14
249.67
81.71
34.05
15.89
126
534.06
189.15
300.41
100.14
244.78
80.11
33.38
15.58
127
523.59
185.44
294.52
98.17
239.98
78.54
32.72
15.27
128
513.32
181.80
288.74
96.25
235.27
77.00
32.08
14.97
129
503.26
178.24
283.08
94.36
230.66
75.49
31.45
14.68
130
493.39
174.74
277.53
92.51
226.14
74.01
30.84
14.39
131
483.71
171.32
272.09
90.70
221.70
72.56
30.23
14.11
132
474.23
167.96
266.75
88.92
217.35
71.13
29.64
13.83
133
464.93
164.66
261.52
87.17
213.09
69.74
29.06
13.56
134
455.81
161.43
256.39
85.46
208.91
68.37
28.49
13.29
135
446.87
158.27
251.37
83.79
204.82
67.03
27.93
13.03
136
438.11
155.16
246.44
82.15
200.80
65.72
27.38
12.78
137
429.52
152.12
241.60
80.53
196.86
64.43
26.84
12.53
138
421.10
149.14
236.87
78.96
193.00
63.16
26.32
12.28
139
412.84
146.21
232.22
77.41
189.22
61.93
25.80
12.04
140
404.74
143.35
227.67
75.89
185.51
60.71
25.30
11.81
141
396.81
140.54
223.20
74.40
181.87
59.52
24.80
11.57
142
389.03
137.78
218.83
72.94
178.30
58.35
24.31
11.35
143
381.40
135.08
214.54
71.51
174.81
57.21
23.84
11.12
144
373.92
132.43
210.33
70.11
171.38
56.09
23.37
10.91
145
366.59
129.83
206.20
68.73
168.02
54.99
22.91
10.69
146
359.40
127.29
202.16
67.39
164.72
53.91
22.46
10.48
147
352.35
124.79
198.20
66.07
161.49
52.85
22.02
10.28
148
345.44
122.34
194.31
64.77
158.33
51.82
21.59
10.08
149
338.67
119.94
190.50
63.50
155.22
50.80
21.17
9.88
64
150
332.03
117.59
186.76
62.25
152.18
49.80
20.75
9.68
151
325.51
115.29
183.10
61.03
149.19
48.83
20.34
9.49
152
319.13
113.03
179.51
59.84
146.27
47.87
19.95
9.31
153
312.87
110.81
175.99
58.66
143.40
46.93
19.55
9.13
154
306.74
108.64
172.54
57.51
140.59
46.01
19.17
8.95
155
300.72
106.51
169.16
56.39
137.83
45.11
18.80
8.77
156
294.83
104.42
165.84
55.28
135.13
44.22
18.43
8.60
157
289.05
102.37
162.59
54.20
132.48
43.36
18.07
8.43
158
283.38
100.36
159.40
53.13
129.88
42.51
17.71
8.27
159
277.82
98.39
156.27
52.09
127.33
41.67
17.36
8.10
160
272.37
96.47
153.21
51.07
124.84
40.86
17.02
7.94
161
267.03
94.57
150.21
50.07
122.39
40.05
16.69
7.79
162
261.80
92.72
147.26
49.09
119.99
39.27
16.36
7.64
163
256.66
90.90
144.37
48.12
117.64
38.50
16.04
7.49
164
251.63
89.12
141.54
47.18
115.33
37.74
15.73
7.34
165
246.69
87.37
138.77
46.26
113.07
37.00
15.42
7.20
166
241.86
85.66
136.04
45.35
110.85
36.28
15.12
7.05
167
237.11
83.98
133.38
44.46
108.68
35.57
14.82
6.92
168
232.46
82.33
130.76
43.59
106.55
34.87
14.53
6.78
169
227.91
80.72
128.20
42.73
104.46
34.19
14.24
6.65
170
223.44
79.13
125.68
41.89
102.41
33.52
13.96
6.52
171
219.06
77.58
123.22
41.07
100.40
32.86
13.69
6.39
172
214.76
76.06
120.80
40.27
98.43
32.21
13.42
6.26
173
210.55
74.57
118.43
39.48
96.50
31.58
13.16
6.14
174
206.42
73.11
116.11
38.70
94.61
30.96
12.90
6.02
175
202.37
71.67
113.83
37.94
92.75
30.36
12.65
5.90
176
198.40
70.27
111.60
37.20
90.93
29.76
12.40
5.79
177
194.51
68.89
109.41
36.47
89.15
29.18
12.16
5.67
178
190.70
67.54
107.27
35.76
87.40
28.60
11.92
5.56
179
186.96
66.21
105.16
35.05
85.69
28.04
11.68
5.45
180
183.29
64.92
103.10
34.37
84.01
27.49
11.46
5.35
181
179.70
63.64
101.08
33.69
82.36
26.95
11.23
5.24
182
176.17
62.40
99.10
33.03
80.75
26.43
11.01
5.14
183
172.72
61.17
97.16
32.39
79.16
25.91
10.80
5.04
184
169.33
59.97
95.25
31.75
77.61
25.40
10.58
4.94
185
166.01
58.80
93.38
31.13
76.09
24.90
10.38
4.84
186
162.76
57.64
91.55
30.52
74.60
24.41
10.17
4.75
187
159.57
56.51
89.76
29.92
73.13
23.93
9.97
4.65
188
156.44
55.40
88.00
29.33
71.70
23.47
9.78
4.56
189
153.37
54.32
86.27
28.76
70.29
23.01
9.59
4.47
190
150.36
53.25
84.58
28.19
68.92
22.55
9.40
4.39
191
147.41
52.21
82.92
27.64
67.56
22.11
9.21
4.30
192
144.52
51.19
81.29
27.10
66.24
21.68
9.03
4.22
193
141.69
50.18
79.70
26.57
64.94
21.25
8.86
4.13
194
138.91
49.20
78.14
26.05
63.67
20.84
8.68
4.05
195
136.19
48.23
76.60
25.53
62.42
20.43
8.51
3.97
196
133.52
47.29
75.10
25.03
61.19
20.03
8.34
3.89
197
130.90
46.36
73.63
24.54
59.99
19.63
8.18
3.82
198
128.33
45.45
72.19
24.06
58.82
19.25
8.02
3.74
199
125.81
44.56
70.77
23.59
57.66
18.87
7.86
3.67
200
123.35
43.69
69.38
23.13
56.53
18.50
7.71
3.60
___
_______________
_______________
_______________
_______________
SHORT
BROADLEAF
TALL
SEED
GRASS
&
INSECTS
GRASS
FRUIT
AVERAGE
AVERAGE
AVERAGE
AVERAGE
VALUES
VALUES
VALUES
VALUES
DAY
95%
MEAN
95%
MEAN
95%
MEAN
95%
MEAN
___
_______________
_______________
_______________
_______________

997.24
353.19
560.95
186.98
457.07
149.59
62.33
29.09
65
APPENDIX
III:
Ecological
Hazards
Assessment
a.
Scope
The
toxicity
testing
required
does
not
test
all
species
of
birds,
fish,
mammals,
invertebrates,
and
plants.
EFED
uses
only
two
surrogate
species
for
birds
(
Bobwhite
quail
and
mallard
ducks)
to
represent
all
bird
species
(
over
900
in
the
US).
EFED
uses
three
species
of
freshwater
fish
(
rainbow
trout,
bluegill
sunfish
and
fathead
minnow)
to
act
as
surrogate
test
species
for
all
freshwater
fish
species
(
over
900
in
the
US).
One
estuarine
fish
species
(
sheepshead
minnow)
serves
as
surrogate
for
all
estuarine
and
marine
fish
(
over
300
in
the
US).
The
surrogate
species
for
terrestrial
invertebrates
is
the
honeybee.
For
freshwater
invertebrates
the
surrogate
species
is
usually
the
waterflea
(
Daphnia
magna).
For
estuarine
and
marine
invertebrates
the
surrogate
species
are
mysid
shrimp
and
eastern
oyster.
EFED
uses
these
four
species
to
represent
all
invertebrates
species
(
over
10,000
in
the
US).
For
plants,
there
are
ten
surrogate
species
used
for
all
terrestrial
plants
and
five
surrogate
species
used
for
all
aquatic
plants.
There
are
over
20,000
plant
species
in
the
US
which
includes
flowering
plants,
conifers,
ferns,
mosses,
liverworts,
hornworts
and
lichens.
There
are
over
27,000
species
of
algae
worldwide.

The
surrogate
species
testing
scheme
used
in
this
assessment
assumes
that
a
chemical's
method
of
action
and
toxicity
found
for
avian
species
is
similar
to
that
in
all
reptiles
(
over
300
species
in
the
US).
The
same
assumption
applies
to
amphibians
(
over
200
species
in
the
US)
and
fish.
EFED
assumes
the
tadpole
stage
of
amphibians
has
the
same
sensitivity
as
a
fish.
Therefore,
EFED
considers
the
results
from
toxicity
tests
on
surrogate
species
are
applicable
to
other
member
species
within
their
class
and
extrapolates
this
toxicity
to
reptiles
and
amphibians.
EFED
got
the
US
species
numbers
noted
in
this
section
from:
http://
www.
natureserve.
org/
summary
(
NatureServe:
An
online
encyclopedia
of
life
[
web
application].
2000)
and
the
worldwide
species
number
from
Ecological
Planning
and
Toxicology,
Inc.
1996.

b.
Toxicity
to
Terrestrial
Animals
i.
Birds,
Acute,
Subacute
and
Chronic
An
acute
oral
toxicity
study
using
the
technical
grade
of
the
active
ingredient
(
TGAI)
is
required
to
establish
the
toxicity
of
mancozeb
to
birds.
The
avian
oral
LD
50
is
an
acute,
single­
dose
laboratory
study
designed
to
estimate
the
quantity
of
toxicant
required
to
cause
50%
mortality
in
a
test
population
of
birds.
The
preferred
test
species
is
either
the
Mallard
Duck,
a
waterfowl,
or
Bobwhite
quail,
an
upland
gamebird.
The
TGAI
is
administered
by
oral
intubation
to
adult
birds,
and
the
results
are
expressed
as
LD
50
milligrams
(
mg)
active
ingredient
(
a.
i.)
per
kilogram
(
kg).
Toxicity
category
descriptions
are
the
following
(
Brooks,
1973):

If
the
LD
50
is
less
than
10
mg
a.
i./
kg,
then
the
test
substance
is
very
highly
toxic.
If
the
LD
50
is
10­
to­
50
mg
a.
i./
kg,
then
the
test
substance
is
highly
toxic.
If
the
LD
50
is
51­
to­
500
mg
a.
i./
kg,
then
the
test
substance
is
moderately
toxic.
If
the
LD
50
is
501­
to­
2,000
mg
a.
i./
kg,
then
the
test
substance
is
slightly
toxic.
If
the
LD
50
is
greater
than
2,000
mg
a.
i./
kg,
then
the
test
substance
is
practically
nontoxic.
66
EFED
did
not
receive
a
single
oral
dose
study
to
fulfill
this
guideline
but
did
review
several
multiple
oral
dose
studies.
The
results
of
these
studies
are
in
Table
1,
below.
Since
the
LD
50
falls
in
the
range
of
approximately
1,500
mg
ai/
kg
to
greater
than
6,400
mg
ai/
kg,
mancozeb
is
categorized
as
slightly
to
practically
nontoxic
to
avian
species
on
an
acute
oral
basis.
The
guideline
71­
1(
a)
is
not
fulfilled.
A
core
study
to
fulfill
this
guideline
is
required
to
be
submitted.
The
studies
were
categorized
as
supplemental
because:
the
species
tested
were
not
preferred
species;
multiple
dose
as
opposed
to
recommended
single
dose
study
was
peformed;
regurgitation
made
determination
of
toxicity
dosages
difficult;
age
and
source
of
test
animals
was
not
provided;
acclimation
period,
diet
composition,
or
dose
preparation
was
not
provided;
the
number
of
test
animals
was
below
recommended
levels;
and/
or
statistical
analysis
was
unable
to
be
performed.
The
toxicity
value
(
LD
50
)
appearing
in
the
shaded
area
of
the
table
will
be
used
to
calculate
the
acute
avian
risk
quotients
(
RQs).

Table
1:
Avian
(
also
Reptilian
and
Terrestrial­
Phase
Amphibian)
Acute
Oral
Toxicity
­
Mancozeb
Technical
Species
%
ai
LD
50
(
mg
ai/
kg)
Toxicity
Category
MRID
No.
Author/
year
Classification1
English
sparrow
(
Passer
domesticus)
­
10
day
study
duration
86.0
~
1500
(
Toxanal
Approximate
estimate)
Probit
LD
50
=
1833
95%
CI
=
863
­
8186
Probit
slope
=
4.24
95%
CI
=
0.44
­
8.03
slightly
toxic
00036094/
Robinson,
D.
&
K.
Shillam/
19663
Supplemental2
Mallard
Duck
(
Anas
platyrhynchos)
86.0
>
6400
practically
nontoxic
00080716/
Harper,
K.
&
A.
Palmer/
1964
Supplemental2
Japanese
Quail
(
Coturnix
japonica)
86.0
>
6400
practically
nontoxic
00080717/
Harper,
K.
&
A.
Palmer/
1965
Supplemental2
Core
(
study
satisfies
guideline).
Supplemental
(
study
is
scientifically
sound,
but
does
not
satisfy
guideline)
2
Cited
in
the
1987
Reregistration
Standard
as
fulfilling
data
requirement.
3
Four
birds
were
used
in
each
of
5
dosage
group.

Two
dietary
studies
using
the
TGAI
are
required
to
establish
the
toxicity
of
mancozeb
to
birds.
These
avian
dietary
LC
50
tests,
using
the
Mallard
Duck
and
Bobwhite
Quail,
are
acute,
eight­
day
dietary
laboratory
studies
designed
to
estimate
the
quantities
of
toxicant
required
to
cause
50%
mortality
in
the
two
respective
test
populations
of
birds.
The
TGAI
is
administered
by
mixture
to
juvenile
birds'
diets
for
five
days
followed
by
three
days
of
"
clean"
diet,
and
the
results
are
expressed
as
LC
50
parts
per
million
(
ppm)
active
ingredient
(
a.
i.)
in
the
diet.
Toxicity
category
descriptions
are
the
following
(
Brooks,
1973):

If
the
LC
50
is
less
than
50
ppm
a.
i.,
then
the
test
substance
is
very
highly
toxic.
If
the
LC
50
is
50­
to­
500
ppm
a.
i.,
then
the
test
substance
is
highly
toxic.
If
the
LC
50
is
501­
to­
1,000
ppm
a.
i.,
then
the
test
substance
is
moderately
toxic.
If
the
LC
50
is
1001­
to­
5,000
ppm
a.
i.,
then
the
test
substance
is
slightly
toxic.
If
the
LC
50
is
greater
than
5,000
ppm
a.
i.,
then
the
test
substance
is
practically
nontoxic.

EFED
has
not
received
any
studies
to
fulfill
this
requirement.
In
a
memorandum
dated,
October
27,
1987,
from
EFED
to
RD,
EFED
waived
the
requirement
for
these
studies
because
it
was
felt
that
the
multiple
dosing
studies,
mentioned
above,
exceeded
the
requirements
for
dietary
testing
and
dietary
testing
that
was
attempted
on
mallard
ducks
and
bobwhite
quail
indicated
the
birds
had
an
aversion
67
to
test
diet
and
would
not
consume
the
test
material.
The
requirement
for
submission
of
guidelines
71­
2(
a)
and
71­
2(
b)
is
waived.

Avian
reproduction
studies
using
the
Bobwhite
Quail
and
Mallard
Duck
are
laboratory
tests
designed
to
estimate
the
quantity
of
toxicant
required
to
adversely
affect
the
reproductive
capabilities
of
a
test
population
of
birds.
The
TGAI
is
administered
by
mixture
to
breeding
birds'
diets
throughout
their
breeding
cycle.
Test
birds
are
approaching
their
first
breeding
season
and,
generally,
are
18­
to­
23
weeks
old.
The
onset
of
the
exposure
period
is
at
least
10
weeks
prior
to
egg
laying.
Exposure
period
during
egg
laying
is
generally
10
weeks
with
a
withdrawal
period
of
three
additional
weeks
if
reduced
egg
laying
is
noted.
Results
are
expressed
as
No
Observed
Adverse
Effect
Concentration
(
NOAEC)
and
various
observable
effect
levels,
such
as
the
Lowest
Observable
Adverse
Effect
Concentration
(
LOAEC),
quantified
in
units
of
parts
per
million
of
active
ingredient
(
ppm
a.
i.)
in
the
diet.

Avian
reproduction
studies
using
the
TGAI
are
required
for
mancozeb
because
birds
may
be
subject
to
repeated
or
continuous
exposure
to
the
pesticide,
especially
preceding
or
during
the
breeding
season,
the
pesticide
is
stable
in
the
environment
to
the
extent
that
potentially
toxic
amounts
may
persist
in
animal
feed
and
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
(
Table
2).
The
toxicity
value
(
NOAEC)
appearing
in
the
shaded
area
of
the
table
will
be
used
to
calculate
the
chronic
avian
risk
quotients
(
RQs).

Avian
reproduction
studies
using
bobwhite
quail
and
mallard
duck
(
Guideline
71­
4;
resulted
in
LOAECs
of
1000
ppm
based
on
reductions
in
hatchling
weight,
14­
day
old
survivors
weight,
embryo
viability,
hatchability,
and
the
percentage
of
14­
day
old
survivors
when
compared
to
the
control
(
Table
2).
The
NOAEC
ranges
from
125
to
300
ppm.
Guidelines
71­
4(
a)
and
(
b)
for
the
TGAI
of
mancozeb
are
fulfilled
(
MRID
Nos.
44159501,
41948401
and
44238001).

Table
2:
Avian
(
Reptilian
&
Terrestrial­
Phase
Amphibian)
Reproduction
Chronic
Toxicity
­
Mancozeb
Technical
Species/
Study
Duration
%
ai
NOAEC/
LOAEC
(
ppm
ai)
LOAEC
Endpoints
MRID
No.
Author/
year
Classification1
Northern
bobwhite
(
Colinus
virginianus)
/
22
weeks
81.9
125/
1000
Hatchling
wt.,
14­
day
old
survivor
wt.,
&
%
of
14­
day
old
survivors
44159501/
Mitchell
L.
et
al./
1996
Core
Mallard
Duck
(
Anas
platyrhynchos)
/
22
weeks
80.1
125/
1000
Reductions
in:
egg
production;
early
and
late
embryo
viability;
hatchability;
and
offspring
weight
at
hatch
and
14­
days
of
age.
41948401/
Beavers,
J.
et
al./
1991
Core
Northern
bobwhite
(
Colinusvirginianus)
/
22
weeks
86.2­
88.5
300/
1000
14­
day
old
survivors
wt.
44238001/
Johnson,
A./
1993
Core
1
Core
(
study
satisfies
guideline).
Supplemental
(
study
is
scientifically
sound,
but
does
not
satisfy
guideline)
2
Based
on
2/
9/
95
review
or
D210278
memorandum
dated
4/
25/
94
ii.
Mammals,
Acute
and
Chronic
68
1.
Acute
Oral
Toxicity
Testing
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.
The
toxicity
values
used
in
this
assessment
were
taken
from
HED's
Tox
One­
Liner,
preliminary
draft
HED
reports
received
in
October,
1999
and
the
final
Hazard
Identification
Assessment
Review
Committee
(
HIARC)
report
on
mancozeb
dated
November
16,
1999.
These
toxicity
values
are
reported
below.
The
toxicity
values
(
LD
50
and
NOAEL)
appearing
in
the
shaded
areas
of
the
tables
will
be
used
to
calculate
the
acute
and
chronic
mammalian
risk
quotients
(
RQ's)
in
subsequent
sections.
Toxicity
category
descriptions
are
the
following
(
Brooks,
1973):

If
the
LD
50
is
less
than
10
mg
a.
i./
kg,
then
the
test
substance
is
very
highly
toxic.
If
the
LD
50
is
10­
to­
50
mg
a.
i./
kg,
then
the
test
substance
is
highly
toxic.
If
the
LD
50
is
51­
to­
500
mg
a.
i./
kg,
then
the
test
substance
is
moderately
toxic.
If
the
LD
50
is
501­
to­
2,000
mg
a.
i./
kg,
then
the
test
substance
is
slightly
toxic.
If
the
LD
50
is
greater
than
2,000
mg
a.
i./
kg,
then
the
test
substance
is
practically
nontoxic.

The
results
indicate
that
mancozeb
is
practically
nontoxic
to
mammals
on
an
acute
oral
basis
(
Table
3).

Table
3:
Mammalian
Acute
Oral
Toxicity
­
Mancozeb
Species
%
ai
LD50
(
mg
ai/
kg)
Toxicity
Category)
Affected
Endpoints
MRID
or
Accession
(
AC)
No.

Technical
laboratory
rat
(
Rattus
norvegicus)
laboratory
mouse
(
Mus
musculus)
l
80.0
>
5,000
(
male)
practically
nontoxic
mortality
AC259044
laboratory
rat
(
Rattus
norvegicus)
72.6
>
5,000
(
male
&
female)
Probit
slope
=
4.5
(
default)
1
practically
nontoxic
mortality
00142522
laboratory
rat
(
Rattus
norvegicus)
70.0
&
75.0
>
5,000
practically
nontoxic
mortality
AC254377
End­
Use
Formulation
­
Mancozeb
laboratory
rat
(
Rattus
norvegicus)
36.0
>
5,000
(
male)
practically
nontoxic
mortality
AC238564
1
Raw
data
unavailable
to
estimate
slope.
Used
default
assumption
cited
in
Urban
and
Cook
(
1986).

2.
Acute
Dermal
and
Inhalation
Toxicity
Testing
In
addition
to
acute
oral
routes
of
exposure,
terrestrial
vertebrates
entering
treatment
area
may
be
acutely
exposed
to
mancozeb
through
other
routes
of
exposure.
Toxicity
category
descriptions
associated
with
dermal
routes
of
exposure
include
the
following
(
US
EPA
CFR.
Part
156):

If
the
LD50
is
less
than
or
equal
to
200
mg/
kg,
then
the
test
substance
is
in
Toxicity
Category
I.
If
the
LD50
is
greater
than
200
through
2,000
mg/
kg,
then
the
test
substance
is
in
Toxicity
Category
II.
If
the
LD50
is
greater
than
2,000
through
5,000
mg/
kg,
then
the
test
substance
is
in
Toxicity
Category
III
69
If
the
LD50
is
greater
than
5,000
mg/
kg,
then
the
test
substance
is
in
Toxicity
Category
IV.

The
results
indicate
that
mancozeb
is
a
Category
IV
toxicant
to
mammals
on
an
acute
dermal
basis.
(
Table
4).

Table
4:
Mammalian
Acute
Dermal
Toxicity
­
Mancozeb
Technical
Surrogate
Species
%
ai
LD50
(
mg
ai/
kg)
Toxicity
Category
Affected
Endpoints
MRID
or
Accession
(
AC)
No.

laboratory
rabbit
(
Sylvilagus
sp.)
70.0
&
75.0
>
5,000
Category
IV
not
reported
AC254377
laboratory
rabbit
(
Sylvilagus
sp.)
72.6
>
5,000
Category
IV
not
reported
00142522
The
acute
inhalation
toxicity
results
for
mancozeb
are
indicated
in
Table
5
below.
Toxicity
category
descriptions
associated
with
inhalation
routes
of
exposure
include
the
following
(
US
EPA
CFR.
Part
156):

If
the
LC50
is
less
than
or
equal
to
0.05
mg/
liter,
then
the
test
substance
is
in
Toxicity
Category
I.
If
the
LC50
is
greater
than
0.05
mg/
liter
through
0.5
mg/
liter,
then
the
test
substance
is
in
Toxicity
Category
II.
If
the
LC50
is
greater
than
0.5
mg/
liter
through
2.0
mg/
liter,
then
the
test
substance
is
in
Toxicity
Category
III
If
the
LC50
is
greater
than
2.0
mg/
liter,
then
the
test
substance
is
in
Toxicity
Category
IV.

Mancozeb
is
a
Category
IV
toxicant
to
mammals
based
on
acute
inhalation
exposure.

Table
5:
Mammalian
Acute
Inhalation
Toxicity
­
Mancozeb
Technical
Surrogate
Species/
Formulation
%
A.
I.
LC50
(
mg/
liter)
Toxicity
Category
Affected
Endpoints
MRID
or
Accession
(
AC)
No.

laboratory
rat
(
Rattus
norvegicus)
80.0
>
5.14
Category
IV
not
reported
AC246662
laboratory
rat
(
Rattus
norvegicus)
72.6
>
5.14
Category
IV
not
reported
00142522
laboratory
rat
(
Rattus
norvegicus)
70.0
&
75.0
>
5.14
Category
IV
not
reported
AC254377
3.
Mammalian
Sub­
chronic
Toxicity
Testing
The
submitted
mammalian
sub­
chronic
feeding
studies
(
Table
6)
indicate
that
extended
exposure
to
Mancozeb
Complex
via
the
diet
at
levels
of
250
ppm
will
cause
decreased
serum
thyroxine
levels
in
females
and
body
weight
decrements,
changes
in
thyroid
hormones,
changes
in
liver
enzymes,
70
microscopic
changes
in
the
liver
and
thyroids,
increased
absolute
and
relative
thyroid
weights,
and
increased
relative
liver
weights
in
males.

Table
6:
Mammalian
Subchronic
Toxicity
­
Mancozeb
Surrogate
Species/
%
ai
NOAEL/
LOAEL
(
mg/
kg/
day)
LOAEL
Endpoints
MRID
or
Accession
(
AC)
No.

Laboratory
rat
(
Rattus
norvegicus)/
feeding­
3
months
84.0
9.2417.82
(
125/
250
ppm)
female
14.98/
59.92
(
250/
1000
ppm)
male
female
­
decreased
serum
thyroxine
levels
male
­
body
weight
decrements,
changes
in
thyroid
hormones,
changes
in
liver
enzymes,
microscopic
changes
in
the
liver
and
thyroids,
increased
absolute
and
relative
thyroid
weights,
and
increased
relative
liver
weights
00261536
Laboratory
mouse
(
Mus
musculus)/
feeding­
3
months
83.1
18.13/
166.9
(
100/
1000
ppm)
microscopic
lesions
of
thyroid
follicular
cell
hypertrophy
or
hyperplasia
in
females
and
decreased
liver
MFO
enzyme
activity
in
males
AC259888
4.
Mammalian
Feeding,
Reproductive
and
Developmental
Toxicity
Testing
As
indicated
in
Table
7,
treatment­
related
developmental
effects
caused
by
mancozeb
involved
gross
developmental
defects,
central
nervous
system
defects,
skeletal
defects,
cryptorchidism
(
failure
of
one
or
more
testes
to
descend
into
the
scrotum)
,
abortions,
and
decreased
fetal
weight
(
see
MRID
No.
00246663).
This
particular
study
is
also
listed
as
a
study
in
the
toxicological
endpoints
for
mancozeb's
metabolite,
ETU
(
see
Appendix
III
of
the
ETU
chapter).
Although
mancozeb
and
ETU
caused
many
of
the
same
developmental
effects,
ETU
caused
these
effects
at
a
much
lower
level
(
1000
ppm)
as
compared
to
mancozeb
(
10,240
ppm).
Parental
effects
in
the
reproductive
study
on
rats
included
body
weight
decrements,
increased
relative
thyroid
weights,
and
increased
incidence
of
thyroid
follicular
cell
hyperplasia
(
see
MRID
No.
41365201)
at
the
1200
ppm
level.
There
were
no
adverse
offspring
effects
attributed
to
mancozeb
in
this
study.
A
long
term
(
1
year)
feeding
study
on
dogs
resulted
in
decreased
body
weights
in
males
and
anemia
in
females
at
200
ppm
level
for
mancozeb.

Table
7:
Mammalian
Feeding,
Developmental
and
Reproductive
Chronic
Toxicity
­
Mancozeb
Technical
Species/
Study
Duration
%
ai
Test
Type
NOAEL/
LOAEL
Toxicity
Value
(
mg/
kg/
day)
Affected
Endpoints
MRID
or
Accession
(
AC)
No.

Domestic
dog
(
Canis
familiaris)/

1­
year
80.6
Feeding
1.75/
7.26
(
50/
200
ppm)

male
7.02/
29.24
(
200/
800
ppm)

female
male
­
decreased
body
weight
gain
female
­
anemia
41810501
Table
7:
Mammalian
Feeding,
Developmental
and
Reproductive
Chronic
Toxicity
­
Mancozeb
Technical
Species/
Study
Duration
%
ai
Test
Type
NOAEL/
LOAEL
Toxicity
Value
(
mg/
kg/
day)
Affected
Endpoints
MRID
or
Accession
(
AC)
No.

71
laboratory
rat
(
Rattus
norvegicus)

/
2­
year
83.8
Feeding
4.83/
30.9
(
125/
750
ppm)

male
6.72/
40.2
(
125/
750
ppm)

female
thyroid
toxicity
and
bilateral
retinopathy
41903601
laboratory
rat
(
Rattus
norvegicus)
/
not
reported
83.0
Developmental
32/
128
(­
640/
2560
ppm)
(
maternal)
128/
512
(­
2560/
10,240
ppm)
(
developmental)
mat.
­
decreased
food
consumptionn
&
body
wt.
gain
dev.
­
gross
developmental
defects,
central
nervous
system
defects,
skeletal
defects,
cryptorchidism,
abortions,
increased
resorptions,
and
decreased
fetal
weight
00246663
laboratory
rabbit
(
Oryctolagus
cuniculus)/
not
reported
83.0
Developmental
30/
80
(
990/
2,640
ppm)
(
maternal
&
developmental)
mat.
­
abortions,
mortality,
and
clinical
signs
dev.
­
abortions
40433001
laboratory
rat
(
Rattus
norvegicus)

/
2
generation
84.0
Reproductive
6.95/
68.9
(
male)

(
120/
1200
ppm)

(
parental)

$
69.9/
 
69.9
($
1200/
 
1200
ppm)

(
reproductive)
parental
­
body
weight
decrements,
increased
relative
thyroid
weights,
and
increased
incidence
of
thyroid
follicular
cell
hyperplasia
reproductive
­
No
adverse
offspring
effects
were
attributed
to
mancozeb.
Fecundity
and
gestation
indices;
litter
sizes;
and
pup
viability,
survival,

and
body
weights
were
all
similar
among
the
groups
41365201
iii.
Insect
Acute
Contact
A
honey
bee
acute
contact
study
using
the
TGAI
is
required
for
mancozeb
because
its
outdoor
use
will
result
in
honey
bee
exposure.
The
acute
contact
LD
50
,
using
the
honey
bee,
Apis
mellifera,
is
an
acute
contact,
single­
dose
laboratory
study
designed
to
estimate
the
quantity
of
toxicant
required
to
cause
50%
mortality
in
a
test
population
of
bees.
The
TGAI
is
administered
by
one
of
two
methods:
whole
body
exposure
to
technical
pesticide
in
a
nontoxic
dust
diluent;
or,
topical
exposure
to
technical
pesticide
via
micro­
applicator.
The
median
lethal
dose
(
LD
50
)
is
expressed
in
micrograms
of
active
ingredient
per
bee
(:
g
a.
i./
bee).
Results
of
this
test
are
tabulated
below
(
Table
8).
Toxicity
category
descriptions
are
the
following
(
Atkins,
1981):

If
the
LD
50
is
less
than
2
:
g
a.
i./
bee,
then
the
test
substance
is
highly
toxic.
If
the
LD
50
is
2
to
less
than
11
:
g
a.
i./
bee,
then
the
test
substance
is
moderately
toxic.
If
the
LD
50
is
11
:
g
a.
i./
bee
or
greater,
then
the
test
substance
is
practically
nontoxic
The
LD
50
for
mancozeb
was
greater
than
178
:
g
per
bee
and
it
is,
therefore,
classified
as
practically
nontoxic
to
bees.
The
guideline
(
141­
1)
is
fulfilled
(
MRID
No.
00018842).
72
EFED
reviewed
a
multiple
active
ingredient
(
MAI)
TEP
study
(
MRID
No.
44950504)
for
a
product
containing
mancozeb
and
the
fungicide
zoxamide.
Table
8
includes
the
results
from
this
study.
EFED
classified
the
acute
oral
toxicity
portion
of
this
study
as
supplemental
because
this
study
is
not
an
OPP
guideline
required
study.
This
acute
oral
bee
study
was
scientifically
sound.
This
MAI
TEP
is,
acutely,
practically
nontoxic
to
honeybees.
Table
8:
Non­
target
Insect
Acute
Toxicity
­
Mancozeb
Species
%
ai
LD
50
(
µ
g
a.
i./
bee)
Toxicity
Category
MRID/
Accession
(
AC)
No.
Author/
Year
Study
Classification1
Technical
Honey
bee
(
Apis
mellifera)
72.0
>
178.87
(
contact)
practically
nontoxic
00018842/
Atkins,
E.
et
al./
1969
Core2
End­
Use
Product
Honey
bee
(
Apis
mellifera)
8.3
(
zoxamide)
69.0
(
mancozeb)
>
200
(
contact)
practically
nontoxic
44950504/
Engelhard,
E./
1997
Core
Honey
bee
(
Apis
mellifera)
8.3
(
zoxamide)
69.0
(
mancozeb)
>
153
(
oral)
Virtually
nontoxic3
44950504/
Engelhard,
E./
1997
Supplemental
1
Core
(
study
satisfies
guideline).
Supplemental
(
study
is
scientifically
sound,
but
does
not
satisfy
guideline)
2
Study
used
in
1987
Reregistration
Standard.
3
Toxicity
category
source:
1985.
International
Commission
for
Bee
Botany
Third
Symposium
on
the
"
Harmonization
of
methods
for
testing
the
toxicity
of
pesticides
to
bees".

iv.
Insect
and
Mite
Residual
Contact
A
honey
bee
toxicity
of
residues
on
foliage
study
is
required
on
an
end­
use
product
for
any
pesticide
intended
for
outdoor
application
when
the
proposed
use
pattern
indicates
that
honey
bees
may
be
exposed
to
the
pesticide
and
when
the
formulation
contains
one
or
more
active
ingredients
having
an
acute
contact
honey
bee
LD
50
which
falls
in
the
moderately
toxic
or
highly
toxic
range.
The
purpose
of
this
guideline
study
is
to
develop
data
on
the
residual
toxicity
to
honey
bees.
Bee
mortality
determinations
are
made
from
bees
exposed
to
treated
foliage
harvested
at
various
time
periods
after
treatment.
Mancozeb,
as
indicated
in
the
acute
toxicity
test
in
Table
8,
above,
is
practically
nontoxic
to
honey
bees.
Because
of
this,
a
honey
bee
toxicity
of
residues
on
foliage
(
guideline
141­
2)
is
not
required
for
mancozeb.
However,
the
information
in
Table
9
is
included
in
this
document
because
this
study
was
cited
in
the
1987
Reregistration
Standard
for
mancozeb.
The
residual
toxicity
of
mancozeb
to
honey
bees
at
an
application
rate
of
0.27
lb
ai/
A
is
low.

Table
9:
Summary
of
Honey
Bee
Residue
on
Foliage
­
Mancozeb
Species
%
ai
LD50
(
µ
g
a.
i./
bee)
Toxicity
Category
MRID/
Accession
(
AC)
No.
Author/
Year
Study
Classification1
Honey
bee
(
Apis
mellifera)
72.0
At
0.27
lb
ai/
A
low
toxicity
from
direct
application
or
residue
not
applicable
00001949/
Johansen,
C.
and
J.
Eves/
1969
Supplemental2
1
Core
(
study
satisfies
guideline).
Supplemental
(
study
is
scientifically
sound,
but
does
not
satisfy
guideline)
2
Study
used
in
1987
Reregistration
Standard.
73
A
predatory
mite
(
Typhlodromus
pyri)
study
(
MRID
No.
4577201)
was
submitted
by
Dow
Agro
Sciences
on
12/
14/
01
in
response
to
FIFRA
6
(
a)(
2)
without
concluding
that
this
information
should
be
regarded
as
an
"
unreasonable
adverse
effect
on
the
environment."
This
study
is
not
an
Office
of
Pesticides
(
OPP)
guideline
study.
This
study
was
generated
to
comply
with
European
Council
Directive
(
ECD)
91/
414/
EEC
as
amended
by
ECD
96/
12/
EC.
The
results
of
this
are
listed
in
Table
9a
below.

Table
9a:
Summary
of
Residual
and
Reproductive
Toxicity
to
Typhlodromus
pyri
­
Mancozeb
Species
%
ai
LR50
a
(
lb
a.
i./
A)
Affected
Endpoints
NOAEC/
LOAE
C
Toxicity
Value
(
lb
a.
i./
A)
Affected
Endpoints
MRID/
Accession
(
AC)
No.
Author/
Year
Study
Classification1
Predatory
or
Beneficial
Mite
(
Typhlodromus
pyri)
81.8
0.1
Mortality
<
0.02/
0.02
Reduction
in
mean
number
of
eggs
hatched
per
female.
45577201/
Nienstedt,
K
and
S.
Kollmann/
2001
Supplemental
a
Residue
concentration
on
foliage
causing
50%
lethality.

v.
Terrestrial
Field
Testing
No
studies
were
submitted
and
no
studies
are
required.

c.
Aquatic
Organism
Toxicity
i.
Toxicity
to
Freshwater
Animals
1.
Freshwater
Fish,
Acute
Two
freshwater
fish
toxicity
studies
using
the
TGAI
are
required
to
establish
the
toxicity
of
mancozeb
to
fish.
The
preferred
test
species
are
rainbow
trout
(
a
coldwater
fish;
Guideline
72­
1c)
and
bluegill
sunfish
(
a
warmwater
fish;
Guideline
72­
1a).
Results
of
these
tests
are
tabulated
below.
The
toxicity
category
descriptions
for
freshwater
and
estuarine/
marine
fish
and
aquatic
invertebrates,
are
defined
below
in
parts
per
million
(
ppm),
the
standard
units
of
measure
(
Brooks,
1973).
The
toxicity
values
(
LC
50
)
appearing
in
the
shaded
area
of
the
tables
will
be
used
to
calculate
the
acute
aquatic
risk
quotients
(
RQ's)
in
subsequent
sections.

If
the
LC
50
is
less
than
0.1
ppm
a.
i.,
then
the
test
substance
is
very
highly
toxic.
If
the
LC
50
is
0.1­
to­
1.0
ppm
a.
i.,
then
the
test
substance
is
highly
toxic.
If
the
LC
50
is
greater
than
1
and
up
through
10
ppm
a.
i.,
then
the
test
substance
is
moderately
toxic.
If
the
LC
50
is
greater
than
10
and
up
through
100
ppm
a.
i.,
then
the
test
substance
is
slightly
toxic.
If
the
LC
50
is
greater
than
100
ppm
a.
i.,
then
the
test
substance
is
practically
nontoxic.

Since
the
LC
50
falls
in
the
range
of
0.46­
3.9
ppm,
for
the
TGAI,
mancozeb
is
categorized
as
highly
to
moderately
toxic
to
freshwater
fish
on
an
acute
basis
(
see
Table
10).
The
supplemental
studies
were
not
conducted
according
to
acceptable
protocols:
the
toxicity
end
points
were
not
based
on
74
measured
concentrations;
terminal
wet
weights
of
control
fish
were
lower
than
the
minimum
required
initial
weight
of
test
fish;
the
results
are
from
measured
but
unfiltered
samples;
and/
or
the
information
was
provided
as
a
reference
source
with
no
supporting
data
or
statistical
analysis.
Guideline
72­
1(
c)
for
the
TGAI
of
mancozeb
is
fulfilled
(
MRID
No.
40118502).
Guideline
72­
1(
a)
is
not
fulfilled
for
the
TGAI.
A
core
study
is
required
to
be
submitted
to
fulfill
this
guideline
requirement
for
acute
toxicity
to
warmwater
fish.

End­
use
product
testing
was
required
to
support
the
cranberry,
wild
rice
and
taro
uses
of
mancozeb
(
see
Mancozeb
1987
Registration
Standard).
EFED
subsequently
allowed
TEP
testing
(
with
80%
WP)
to
fulfill
TGAI
testing
requirements.
Justification
provided
by
the
registrant
was
that
the
enduse
product
had
greater
solubility
in
water
than
the
TGAI.
Because
of
this,
the
requirement
for
submission
of
single
active
ingredient
(
SAI)
testing
of
a
mancozeb
TEP
(
guideline
71b)
can
be
fulfilled
through
the
testing
of
the
80%
WP
formulation
of
mancozeb
thus
fulfilling
both
the
TGAI
and
TEP
testing
requirement
for
the
acute
toxicity
to
warmwater
fish.
A
study
of
rainbow
trout
was
conducted
using
a
mancozeb
formulated
product
containing
37%
active
ingredient.
This
study
(
MRID
No.
40467501)
was
originally
classified
as
core
but
is
being
downgraded
to
supplemental
because
the
toxicity
end
point
was
not
based
on
measured
concentrations.
However,
this
guideline
requirement
(
guideline
72­
1d)
has
been
fulfilled
as
a
result
of
the
core
guideline
72­
1(
c)
submission
(
MRID
No.
40118502)
and
no
additional
acute
coldwater
fish
toxicity
testing
using
a
SAI
mancozeb
TEP
is
required.

Guidelines
72­
1(
d),
the
acute
toxicity
of
mancozeb
to
rainbow
trout
using
a
single
active
TEP
is
fulfilled
(
MRID
No.
40467501).

Studies
were
also
review
for
multiple
active
ingredient
(
MAI)
TEP
products
containing
mancozeb
and
the
fungicides
dimethomorph
and
zoxamide.
The
results
from
these
studies
are
also
found
in
Table
10.
The
supplemental
studies
did
not
meet
guideline
requirements
for
one
or
more
reasons:
the
study
did
not
include
an
inert
ingredient
control,
the
test
material
at
various
concentrations
was
not
measured,
and/
or
the
range
of
test
concentrations
in
the
study
was
not
appropriate
for
determining
an
LC
50
.
Requirements
for
future
MAI
TEP
testing
of
mancozeb
is
being
reserved
and
may
be
required
if
these
TEP
formulations
are
identified
as
being
a
toxicological
concern
to
freshwater
organisms.
75
Table
10:
Freshwater
Fish
96­
hr
Acute
Toxicity
­
Mancozeb.

Species/
Flow­
through
or
Static
%
ai
LC
50
/
(
C.
I.)
(
ppm
ai)/
(
measured/
nominal)
Toxicity
Category
MRID
/
Accession
No./
Author/
Year
Study
Classification1
Technical
Bluegill
sunfish
(
Lepomis
macrochirus)
/
static
(
72
hour)
80.0
3.85/
(
3.55­
4.18)
(
nominal)
moderately
toxic
00097147/
McCann,
J./
1967
Supplemental
Bluegill
sunfish
(
Lepomis
macrochirus)
/
static
80.0
1.35/
(
0.6­
2.9)
(
not
reported)
moderately
toxic
00097173/
McCann,
J.
&
F.
Pitcher/
1973
Supplemental2
Bluegill
sunfish
(
Lepomis
macrochirus)
/
static
80.0
1.54/
(
not
reported)
moderately
toxic
40118501/
Terr.&
Aquatic
Bio.
Lab.,
Beltsville,
MD/
1980
Supplemental2
Bluegill
sunfish
(
Lepomis
macrochirus)
/
static
80.0
2.04/
(
1.84­
2.26)
3
(
measured)
moderately
toxic
not
reported/
Terr.
&
Aquatic
Bio.
Lab.
Beltsville,
MD/
1980
Supplemental
Bluegill
sunfish
(
Lepomis
macrochirus)
/
flowthrough
81.3
>
3.6
(
highest
dose
tested)
(
measured)
moderately
toxic
45934702/
Rhodes,
J.
E./
2000
Supplemental
Rainbow
Trout
(
Salmo
gairdneri)/
static
80.0
0.64/
(
0.46­
0.89)
3
(
not
reported)
highly
toxic
not
reported/
Animal
Biology
La.
b./
1977
Supplemental
Rainbow
Trout
(
Salmo
gairdneri)/
static
80.0
0.46/
(
0.40­
0.54)
3
(
measured)
Probit
slope
=
4.5
(
default)
7
highly
toxic
40118502/
Terr.&
Aquatic
Bio.
Lab.,
Beltsville,
MD/
1980
Core2
Rainbow
Trout
(
Oncorhynchus
mykiss)/
flowthrough
81.3
0.91/
(
0.77­
1.1)
(
measured)
slope
=
not
reported
highly
toxic
45934701/
Rhodes,
J.
E./
2000
Supplemental
End­
Use
Product
Rainbow
Trout
(
Oncorhynchus
mykiss)
/
static
37.0
1.1/
(
0.85­
1.4)
3
(
nominal)
moderately
toxic
40467501/
Bowman,
J.
H./
1987
Supplemental
Rainbow
Trout
(
Oncorhynchus
mykiss)
/
static
renewal
8.94/
59.75
0.55/
(
0.46­
0.68)
3
(
nominal)
highly
toxic
43917218/
Toy,
R.
&
A.
Gray/
1991
Supplemental
Rainbow
Trout
(
Oncorhynchus
mykiss)
/
static
renewal
8.94/
59.75
0.68/
(
0.47­
0.98)
3
(
nominal)
highly
toxic
43917216/
Toy,
R.
&
A.
Gray/
1991
Supplemental
Rainbow
Trout
(
Oncorhynchus
mykiss)
/
static
renewal
7.54/
67.75
0.39/
(
0.36­
0.43)
3
(
nominal)
highly
toxic
43917217/
Toy,
R.
&
A.
Gray/
1992
Supplemental
Rainbow
Trout
8.266/
69.0
1.9/
moderately
44950503/
Rhodes,
J.
E.
and
Core
76
1
Core
(
study
satisfies
guideline).
Supplemental
(
study
is
scientifically
sound,
but
does
not
satisfy
guideline)
2
Study
used
in
1987
Reregistration
Standard.
3
Based
on
total
formulation.
4
Dimethomorph
5
Mancozeb
6
Zoxamide
7
Raw
data
unavailable
to
estimate
slope.
Used
default
assumption
cited
in
Urban
and
Cook
(
1986).

2.
Freshwater
Fish,
Chronic
A
freshwater
fish
early
life­
stage
test
using
the
TGAI
is
required
for
mancozeb
because
the
end­
use
product
is
expected
to
be
transported
to
water
from
the
intended
use
site,
and
the
following
conditions
are
met:
(
1)
the
pesticide
is
intended
for
use
such
that
its
presence
in
water
is
likely
to
be
continuous
or
recurrent,
(
2)
an
aquatic
acute
LC
50
or
EC
50
is
less
than
1ppm,
and
(
3)
the
EEC
in
water
is
equal
to
or
greater
than
0.01
of
any
acute
LC
50
or
EC
50
value.
Acceptable
freshwater
test
species
are
rainbow
trout,
brook
trout,
coho
salmon,
Chinook,
bluegill,
brown
trout,
lake
trout,
northern
pike,
fathead
minnow,
white
sucker
and
channel
catfish.
The
fish
early
life­
stage
is
a
laboratory
test
designed
to
estimate
the
quantity
of
toxicant
required
to
adversely
effect
the
reproductive
capabilities
of
a
test
population
of
fish.
The
test
should
be
performed
using
flowthrough
conditions.
The
TGAI
is
administered
into
water
containing
the
test
species,
providing
exposure
throughout
a
critical
life­
stage,
and
the
results
are
expressed
as
a
No
Observed
Adverse
Effect
Concentration
(
NOAEC)
and
LOAEC
(
Lowest
Observed
Adverse
Effect
Concentration)
in
parts
per
billion
(
ppb)
of
active
ingredient.
The
No
Observed
Adverse
Effect
Concentration
represents
an
exposure
concentration,
at
or
below
which
biologically
significant
effects
will
not
occur
to
species
of
similar
sensitivities.
Table
11
is
a
summary
of
a
freshwater
fish
early
life­
stage
test
(
Guideline
72­
4a).
The
toxicity
value
(
NOAEC)
appearing
in
the
shaded
area
of
the
table
will
be
used
to
calculate
the
chronic
aquatic
risk
quotients
(
RQ's)
in
subsequent
sections.
Guideline
72­
4(
a)
for
freshwater
species
is
fulfilled
(
MRID
No.
43230701).

Table
11:
Freshwater
Fish
Early
Life­
Stage
Toxicity
Under
Flow­
through
Conditions
­
Mancozeb
Technical
Species/
Static
or
Flowthrough
Study
Duration
%
ai
NOAEC/
LOAEC
(
ppb
ai)/
(
measured/
nominal)
Endpoints
Affected
MRID/
Accession
(
AC)
No.
Author/
Year
Study1
Classification
Fathead
minnow
(
Pimephales
promelas)
/
flow­
through/
35
days
79.3
2.19/
4.56
(
measured)
Survival
and
lack
of
growth
effects
43230701/
Rhodes,
et
al./
1994
Core
1
Core
(
study
satisfies
guideline).
Supplemental
(
study
is
scientifically
sound,
but
does
not
satisfy
guideline)

A
freshwater
fish
life­
cycle
test
using
the
TGAI
is
required
for
mancozeb
because
the
end­
use
product
is
expected
to
be
transported
to
water
from
the
intended
use
site
and
any
EEC
is
equal
to
or
greater
than
one­
tenth
of
the
NOAEC
in
the
fish
life­
stage
or
invertebrate
life­
cycle
test.
The
PRZM/
EXAMS
modeled
peak
EECs
for
mancozeb's
current
use
patterns
range
from
46.8
ppb
for
potato
applications
to
210.8
ppb
for
tomato
applications.
The
preferred
test
species
is
fathead
minnow.
The
freshwater
fish
life­
cycle
test
(
Guideline
72­
5)
has
not
been
fulfilled.
A
core
study
for
this
guideline
is
required
to
be
submitted.

3.
Freshwater
Invertebrates,
Acute
77
A
freshwater
aquatic
invertebrate
toxicity
test
using
the
TGAI
is
required
to
establish
the
toxicity
of
mancozeb
to
aquatic
invertebrates.
The
preferred
test
organism
is
Daphnia
magna,
but
early
instar
amphipods,
stoneflies,
mayflies,
or
midges
may
also
be
used.
Results
of
this
test
are
tabulated
below
(
Table
12).
The
toxicity
value
(
EC
50
)
appearing
in
the
shaded
area
of
the
table
will
be
used
to
calculate
the
acute
risk
quotients
(
RQ's)
in
subsequent
sections.
Since
the
LC
50
/
EC
50
falls
in
the
range
of
0.58
to
1.0
ppb,
mancozeb
is
categorized
very
highly
toxic
to
freshwater
aquatic
invertebrates
on
an
acute
basis.
Guideline
72­
2(
a)
for
the
TGAI
of
mancozeb
is
fulfilled
(
MRID
Nos.
40118503
and
40467503).

Studies
were
also
review
for
MAI
TEP
products
containing
mancozeb
and
dimethomorph.
The
results
from
these
studies
are
also
found
in
Table
12.
The
supplemental
studies
did
not
meet
guideline
requirements
for
one
or
more
reasons:
the
study
did
not
include
an
inert
ingredient
control,
the
test
material
at
various
concentrations
was
not
measured,
the
results
are
from
measured
but
unfiltered
samples,
and/
or
the
range
of
test
concentrations
in
the
study
was
not
appropriate
for
determining
an
LC
50
.
Requirements
for
future
MAI
TEP
testing
of
mancozeb
is
being
reserved
and
may
be
required
if
these
TEP
formulations
are
identified
as
being
a
toxicological
concern
to
freshwater
organisms.
78
Table
12:
Freshwater
Invertebrate
Acute
Toxicity
­
Mancozeb
Technical
Species/
Static
or
Flowthrough
Duration
%
ai
LC
50
/

EC
50
(
ppm)/(
C.
I.)/

(
nominal/
measured)
Toxicity
Category
MRID/
Accession
(
AC)

No.
Author/
Year
Study
Classification1
Technical
Daphnid
(
Daphnia
magna)/
static
(
48
hr.)
80.0
0.58/

(
0.46­
0.73)
3
(
nominal)

Probit
slope
=
4.5
(
default)
8
highly
toxic
40118503/
Terr.&

Aquatic
Bio.

Lab.,
Beltsville,

MD/
1980
Core2
Daphnid
(
Daphnia
magna)
static
(
48
hr.)
82.4
1.0/

(
0.87­
1.30)

(
nominal)
highly
toxic
40467503/
Forbis,

A./
1987
Core
End­
Use
Product
Daphnid
(
Daphnia
magna)
static
(
48
hr.)
7.54/
67.75
1.1/

(
0.48­
2.3)
3
(
nominal)
moderately
toxic
43917217/
Toy,
R.
&
A.

Gray/
1992
Supplemental
Daphnid
(
Daphnia
magna)
static
(
48
hr.)
8.94/
59.75
4.6/

(
0.41­
2.8)
3
(
nominal)
moderately
toxic
43917216/
Toy,
R.
&
A.

Gray/
1991
Supplemental
Daphnid
(
Daphnia
magna)
static
(
48
hr.)
8.94/
59.75
1.5/

(
1.1­
2.2)
3
(
nominal)
moderately
toxic
43917215/
Toy,
R.
&
A.

Gray/
1991
Supplemental
Daphnid
(
Daphnia
magna)
flowthrough
(
48
hr.)
8.266/
69.05
3.8/

(
3.0
­
5.0)
3
(
measured/
calculated)

slope
=
not
reported
moderately
toxic
44950502/
Madsen,
T.
J
&
T.
Leak/
1998
Core
Daphnid
(
Daphnia
magna)
flowthrough
(
48
hr.)
4.097/
66.66
5
1.8/

(
1.5
­
2.1)
3
(
measured)

slope
=
4.6
moderately
toxic
45934703/
Rhodes,

J./
2001
Supplemental
1
Core
(
study
satisfies
guideline).
Supplemental
(
study
is
scientifically
sound,
but
does
not
satisfy
guideline)
2
Study
used
in
1987
Reregistration
Standard.
3
Based
on
total
formulation.
4
Dimethomorph
5
Mancozeb
6
Zoxamide
7
IR6141
(
Benalaxyl)
8
Raw
data
unavailable
to
estimate
slope.
Used
default
assumption
cited
in
Urban
and
Cook
(
1986).

4.
Freshwater
Invertebrate,
Chronic
A
freshwater
aquatic
invertebrate
life­
cycle
test
using
the
TGAI
is
required
for
mancozeb
since
the
end­
use
product
is
expected
to
be
transported
to
water
from
the
intended
use
site,
and
the
following
conditions
are
met:
(
1)
the
pesticide
is
intended
for
use
such
that
its
presence
in
water
is
likely
to
be
continuous
or
recurrent,
(
2)
the
aquatic
acute
LC
50
or
EC
50
is
less
than
1.0
ppm,
and
(
3)
the
EEC
79
in
water
is
equal
to
or
greater
than
0.01
of
any
acute
EC
50
or
LC
50
value.
The
preferred
test
species
is
Daphnia
magna.
Results
of
this
test
are
tabulated
below.
The
toxicity
value
(
NOAEC)
appearing
in
the
shaded
area
of
the
table
will
be
used
to
calculate
the
chronic
risk
quotients
(
RQ's)
in
subsequent
sections.
Guideline
72­
4(
b)
for
mancozeb
is
fulfilled
(
MRID
No.
40953802).

Table
13:
Freshwater
Aquatic
Invertebrate
Life­
Cycle
Toxicity
­
Mancozeb
Technical
Species/
Static
Renewal
or
Flowthrough
%
ai
21­
day
NOAEC/
LOAEC
(
ppb)/
(
measured/
nominal)
Endpoints
Affected
MRID/
Accession
(
AC)
No.
Author/
Year
Study
Classification1
Daphnid(
Daphnia
magna/
flowthrough
82.4
7.3/
12.0
/(
measured)
immobility,
length
and
time
until
first
brood
40953802/
Burgess,
D./
1988
Core
1
Core
(
study
satisfies
guideline).
Supplemental
(
study
is
scientifically
sound,
but
does
not
satisfy
guideline)

5.
Freshwater
Field
Studies
A
draft
mesocosm
study
was
performed
and
submitted
to
the
Agency
as
MRID
44944401.
An
abbreviated
review
of
this
study
was
completed
in
February
2000
and
a
synopsis
of
the
abbreviated
review
is
submitted
below.

This
study
followed
the
Society
of
Environmental
Toxicology
and
Chemistry
(
SETAC)
"
Guidance
Document
on
Testing
Procedures
for
Pesticides
in
Freshwater
Mesocosms"
(
July
1991)
and
employed
the
regression
approach.
Ten
outdoor
fiberglass
tanks
(
mesocosms)
were
used
in
this
study
­
3
controls
and
7
treatment
tanks.
Each
mesocosm
was
approximately
2
m
in
diameter
and
1.6
m
deep
with
an
approximate
volume
of
5
m3.
The
treatment
tanks
received
eight
simulated
spray
drift
applications
of
Penncozeb
80
WP
(
80%
mancozeb
ai)
each
separated
by
one
week.
The
nominal
concentrations
selected
for
each
treatment
tank
were:
1.25,
4.0,
12.5,
40,
125,
400,
and
1250
ppb
of
Penncozeb
80
WP.
Since
the
half­
life
of
the
parent
material
was
reported
to
range
from
2
hours
for
acidic
pH
to
14
hours
for
alkaline
pH
in
an
aquatic
environment,
mancozeb's
degradate
(
ETU)
was
assayed
to
confirm
the
presence
of
treatment
material
in
the
treatment
tanks.
The
limit
of
determination
in
this
study,
for
ETU,
ranged
from
1.7
to
3.4
ppb.
Generally,
all
samples
in
which
ETU
was
detected
came
from
the
1250
ppb
Penncozeb
80
WP
treatment
group
and
because
of
this
the
results
were
based
upon
nominal
concentrations
of
the
formulated
product
and
not
measured
concentrations
of
the
actual
test
material
in
the
treatment
tanks.

Since
the
mesocosm
study
was
conducted
using
non­
replicated
treatments,
dose
response
values
(
EC
20
and
EC
50
)
were
derived
by
employing
non­
linear
regression
analysis.
The
EC
20
was
regarded
as
the
threshold
level,
below
which
no
ecologically
relevant
effects
occur.
The
following
table
provides
the
toxicity
of
Penncozeb
80
WP
to
various
aquatic
species
in
this
study.

Species
Period
EC20/
EC50
(
ppb
Penncozeb
80
WP)

Zooplankton
Species
Period
EC20/
EC50
(
ppb
Penncozeb
80
WP)

80
Daphnia
magna
Application
252/
408
Daphnia
longispina
Application
332/
398
Chydorus
sphaericus
Application
67/
134
Scapholeberis
mucronata
Application
188/
263
Copepod
nauplii
Application
29/
57
Brachionus
leydigi
Application
5.5/
9.2
Keratella
quadrata
Application
22/
27
Hexarthra
sp.
Application
Post­
Application
12/
12
12/
12
Cephalodella
sp.
Application
15/
31
Phytoplankton
Volvox
sp.
Application
1.6/
4.8
The
PRZM/
EXAMS
modeled
peak
EECs
for
mancozeb's
current
use
patterns
range
from
46.8
ppb
for
potato
applications
to
210.8
ppb
for
tomato
applications
(
see
Table
V.
2).
The
test
levels
used
on
this
study
were
equivalent
to:
1.0,
3.2,
10.0,
32.0,
100.0,
320.0,
and
1000.0
ppb
of
mancozeb
which
indicates
this
study
adequately
covers
the
Mancozeb
Complex
that
would
currently
be
expected
to
occur
in
aquatic
environments.
It
should
be
noted
that
EPA's
"
Aquatic
Mesocosm
Tests
to
Support
Pesticide
Registrations
EPA
540/
09­
88­
035"
(
March
1988)
requires
three
replicates
per
treatment
level,
a
mesocosm
size
of
300
m3
in
volume
and
the
inclusion
of
viable
finfish
in
the
study.
These
three
major
departures
from
EPA
guideline
requirements
are
noted
at
this
time.
EFED
has
recently
been
made
aware
that
the
finalization
of
this
study
has
been
submitted
to
OPP
under
MRID
No.
45014901.
It
is
not
anticipated
that
a
review
of
the
final
study
will
be
completed
prior
to
the
publication
of
the
draft
RED
for
mancozeb.
However,
since
the
RED
process
is
rather
lengthy
it
is
anticipated
that
a
review
of
MRID
No.
45014901
will
be
completed
and
included
in
this
chapter
prior
to
publication
of
the
final
RED
for
mancozeb.
At
this
time,
until
a
review
of
the
final
document
can
be
completed
the
study
is
categorized
as
supplemental.

ii.
Toxicity
to
Estuarine
and
Marine
Animals
1.
Estuarine
and
Marine
Fish,
Acute
Acute
toxicity
testing
with
estuarine
and
marine
fish
using
the
TGAI
is
required
for
mancozeb
because
the
end­
use
product
is
expected
to
reach
the
marine/
estuarine
environment
because
of
its
use
in
coastal
counties.
The
preferred
test
organisms
are
the
sheepshead
minnow.
Results
of
these
tests
are
tabulated
in
Table
14,
below.
The
supplemental
studies
were
not
conducted
according
to
acceptable
protocols:
there
was
precipitation
in
test
vessels,
concentrations
were
not
measured,
the
size
of
the
test
fish
was
unknown,
and/
or
the
weight
of
the
test
fish
was
unknown.
Based
on
the
81
results
of
these
tests,
mancozeb
is
moderately
toxic
to
estuarine
fish.
Guideline
72­
3(
a)
is
not
fulfilled.
A
core
study
for
determining
the
acute
toxicity
to
estuarine/
marine
fish
must
be
submitted.
The
toxicity
value
(
LC
50
)
appearing
in
the
shaded
area
of
the
table
will
be
used
to
calculate
the
acute
risk
quotients
(
RQ's)
in
subsequent
sections.

The
results
for
Guideline
72­
3(
d)
studies
for
single
active
ingredient
TEP
formulations
are
also
listed
in
Table
14.
Requirements
for
future
MAI
TEP
testing
of
mancozeb
is
being
reserved
and
may
be
required
if
these
TEP
formulations
are
identified
as
being
a
toxicological
concern
to
estuarine/
marine
organisms.

Table
14:
Summary
of
acute
96­
hr
toxicity
tests
for
Estuarine/
Marine
Fish
with
Mancozeb.

Species/
static
or
flowthrough
%
A.
I.
LC50/(
C.
I.)/
ppm
ai/
(
measured/
nominal
)
Toxicity
Category
MRID
No.
Author/
year
Classification1
Technical
Sheepshead
Minnow/
(
Cyprinodon
variegatus)/
static
82.4
4.2/
(
2.3­
6.5)
/(
nominal)
moderately
toxic
40586802/
Ward,
G../
1987
Supplemental
Sheepshead
Minnow/
(
Cyprinodon
variegatus)/
flowthrough
82.4
1.6/
(
not
reported)/
(
measured)
Probit
slope
=
4.5
(
default)
4
moderately
toxic
41844901/
Mmanning,
C.
et
al./
1990
Supplemental
End­
Use
Formulation
Sheepshead
Minnow/
(
Cyprinodon
variegatus)/
flowthrough
37.0
2.72
(
1.0)
3/
(
2.2­
3.8)
/(
nominal)
moderately
toxic
41844902/
Manning,
C.
et
al./
1990
Supplemental
Sheepshead
Minnow/
(
Cyprinodon
variegatus)/
static
37.0
4.22/
(
2.3­
6.5)
/(
nominal)
moderately
toxic
40586804/
Ward,
G./
1988
Supplemental
1
Core
(
study
satisfies
guideline).
Supplemental
(
study
is
scientifically
sound,
but
does
not
satisfy
guideline)
2
Based
on
total
formulation.
3
Based
on
active
ingredient.
4
Raw
data
unavailable
to
estimate
slope.
Used
default
assumption
cited
in
Urban
and
Cook
(
1986).

2.
Estuarine
and
Marine
Fish,
Chronic
An
estuarine/
marine
fish
early
life­
stage
toxicity
test
using
the
TGAI
is
required
for
mancozeb
because
the
end­
use
product
is
expected
to
be
transported
to
the
estuarine/
marine
environment
from
the
intended
use
site,
and
the
following
conditions
are
met:
the
pesticide
is
intended
for
use
such
that
its
presence
in
water
is
likely
to
be
continuous
or
recurrent
and
the
EEC
in
water
is
equal
to
or
greater
than
0.01
of
any
acute
LC
50
or
EC
50
value.
The
preferred
test
species
is
sheepshead
minnow.
The
guideline
(
72­
4a)
estuaine/
marine
fish
is
not
fulfilled.
A
core
study
is
required
to
be
submitted
for
this
guideline.

3.
Estuarine
and
Marine
Invertebrates,
Acute
82
Acute
toxicity
testing
with
estuarine/
marine
invertebrates
using
the
TGAI
is
required
for
mancozeb
because
the
end­
use
product
is
expected
to
reach
the
marine/
estuarine
environment
because
of
it
use
in
coastal
counties.
The
preferred
test
species
are
mysid
shrimp
and
eastern
oyster.
Results
of
these
tests
are
tabulated
below.
The
toxicity
value
(
EC
50
)
appearing
in
the
shaded
area
of
the
table
will
be
used
to
calculate
the
acute
risk
quotients
(
RQ's)
in
subsequent
sections.
Since
the
TGAI
EC
50
ranges
from
0.0105
to
1.6
ppm,
the
mancozeb
is
considered
to
be
very
highly
toxic
to
moderately
toxic
to
estuarine/
marine
invertebrates
on
an
acute
exposure.
However,
there
is
a
uncertainty
is
the
supplemental
study
(
MRID
No.
40586801)
because
the
concentration
of
the
test
material
was
not
measured
after
a
substantial
decrease
in
dissolved
oxygen
and
subsequent
aeration
which
may
have
altered
the
concentration
of
the
test
material
in
the
solution.
There
is
an
uncertainty
is
the
supplemental
study
(
MRID
No.
41822901)
because
the
shrimp
tested
were
older
than
what
was
recommended
and
the
control
appeared
to
have
been
contaminated
with
the
test
material.
Guideline
72­
3(
b)
for
the
TGAI
acute
toxicity
to
estuarine/
marine
organism­
mollusk
is
fulfilled
(
MRID
No.
40885102).
Guideline
72­
3(
c)
for
the
acute
toxicity
to
estuarine/
marine
organism­
shrimp
is
not
fulfilled.
A
core
study
using
the
TGAI
of
mancozeb
must
be
submitted
for
this
guideline.
Guideline
72­
3(
e),
acute
toxicity
to
estuarine/
marine
mollusk
for
a
single
active
ingredient
mancozeb
TEP,
is
fulfilled
(
MRID
No.
40885101).
Guideline
72­
3(
f),
acute
toxicity
to
estuarine/
marine
shrimp
for
a
single
active
ingredient
mancozeb
TEP,
is
not
fulfilled.
A
core
study
using
a
mancozeb
TEP
must
be
submitted
for
this
guideline.
Requirements
for
future
MAI
TEP
testing
of
mancozeb
is
being
reserved
and
may
be
required
if
these
TEP
formulations
are
identified
as
being
a
toxicological
concern
to
estuarine/
marine
organisms.

Table
15:
Estuarine/
Marine
Invertebrate
Acute
Toxicity
­
Mancozeb
Species/
Static
or
Flow­
through
%
ai.
96­
hour
EC50
(
ppm
ai)(
C.
I.)/
(
measured/
nominal)
Toxicity
Category
MRID
No./
Author/
Year
Study
Classification1
Technical
Eastern
oyster
(
Crassostrea
virginica)/
flowthrough
(
shell
deposition)
82.4
1.60/
(
1.4­
1.8)
/(
measured)
moderately
toxic
40885102/
Manning,
C./
1988
Core
Mysid
(
Americamysis
bahia)/
flowthrough
82.4
0.0105/
(
0.086­
0.014)
/(
measured)

slope
=
3.0
Probit
LD
50
=
0.0106
95%
CI
=
0.0086
­

0.0142
Probit
slope
=
3.0
95%
CI
=
2.0
­
4.0
very
highly
toxic
41822901/
Ward,

G./
1990
Supplemental
Mysid
(
Americamysis
bahia)/
static
(
24
hr.)
82.4
0.067/

(
0.058­
0.079)

/(
nominal)
very
highly
toxic
40586801/
Ward,

G./
1988
Supplemental
End­
Use
Formulation
Table
15:
Estuarine/
Marine
Invertebrate
Acute
Toxicity
­
Mancozeb
Species/
Static
or
Flow­
through
%
ai.
96­
hour
EC50
(
ppm
ai)(
C.
I.)/
(
measured/
nominal)
Toxicity
Category
MRID
No./
Author/
Year
Study
Classification1
83
Eastern
oyster
(
Crassostrea
virginica)/

flowthrough
(
shell
deposition)
37.0
1.53/

(
0.4­
3.4)

/(
measured)
moderately
toxic
40885101/
Manning,

C./
1988
Core
Mysid
(
Americamysis
bahia)//

flowthrough
37.0
0.0095/

(
0.0083­
0.0114)

/(
measured)
very
highly
toxic
41822902/
Ward,
G.,

et.
al/
1990
Supplemental
Mysid
(
Americamysis
bahia)/
static
(
24
hr.)
37.0
0.218/

(
0.185­
0.265)

/(
nominal)
highly
toxic
40586803/
Ward,

G./
1988
Supplemental
1
Core
(
study
satisfies
guideline).
Supplemental
(
study
is
scientifically
sound,
but
does
not
satisfy
guideline)

4.
Estuarine
and
Marine
Invertebrate,
Chronic
An
estuarine/
marine
invertebrate
life­
cycle
toxicity
test
(
Guideline
72­
4b)
using
the
TGAI
is
required
for
mancozeb
because
the
end­
use
product
is
expected
to
be
transported
to
the
estuarine/
marine
environment
from
the
intended
use
site,
the
pesticide
is
intended
for
use
such
that
its
presence
in
water
is
likely
to
be
continuous
or
recurrent,
any
aquatic
acute
LC
50
or
EC
50
is
less
than
1.0
ppm,
and
the
EEC
in
water
is
equal
to
or
greater
than
0.01
of
any
acute
LC
50
or
EC
50
value.
The
preferred
test
species
is
mysid
shrimp.
This
guideline
has
not
been
fulfilled
and
a
core
study
for
this
guideline
is
required
to
be
submitted.

5.
Estuarine
and
Marine
Field
Studies
No
studies
were
submitted
and
no
studies
are
required.

iii.
Toxicity
to
Plants
1.
Terrestrial
Plants
Terrestrial
plant
Tier
I
seedling
emergence
and
vegetative
vigor
testing
of
a
mancozeb
TEP
is
currently
recommended
for
all
pesticides
having
outdoor
uses.
For
seedling
emergence
and
vegetative
vigor
testing
the
following
plant
species
and
groups
should
be
tested:
(
1)
six
species
of
at
least
four
dicotyledonous
families,
one
species
of
which
is
soybean
(
Glycine
max)
and
the
second
is
a
root
crop,
and
(
2)
four
species
of
at
least
two
monocotyledonous
families,
one
of
which
is
corn
(
Zea
mays).
Tier
I
tests
measure
the
response
of
plants,
relative
to
a
control,
at
a
test
level
that
is
equal
to
the
highest
use
rate
(
expressed
as
lbs
ai/
A).
Tier
II
studies
are
required
if
the
Tier
I
studies
indicate
any
of
the
test
species,
when
exposed
to
the
test
material,
displayed
a
$
25%
inhibition
of
various
growth
parameters
as
compared
to
the
control.
84
Tier
I
seedling
emergence
[
guideline
122­
1(
a)]
and
vegetative
vigor
[
guideline
122­
1(
b)]
studies
for
the
MAI
TEP,
Acrobat
MZ,
(
a
mixture
of
mancozeb
and
dimethomorph)
have
been
reviewed.
Results
of
these
studies
are
tabulated
in
Tables
16
and
17,
below.
For
Tier
I
seedling
emergence,
soybean
and
tomato
are
the
most
sensitive
dicots
with
4%
plant
dry
weight
inhibition
and
onion
is
the
most
sensitive
monocot
with
12%
plant
dry
weight
inhibition
when
compared
to
the
controls
at
the
application
rate
of
1.38
and
0.20
lb
ai/
A
of
mancozeb
and
dimethomorph,
respectively.
For
Tier
I
vegetative
vigor,
tomato
is
the
most
sensitive
dicot
with
a
4%
plant
dry
weight
inhibition
and
onion
is
the
most
sensitive
monocot
with
12%
plant
dry
weight
inhibition
when
compared
to
the
controls
at
the
application
rate
previously
indicated.

Since
none
of
the
ten
species
exposed
displayed
$
25%
inhibition
for
the
parameters
tested,
guidelines
122­
1
(
a)
and
(
b)
have
been
fulfilled
for
this
TEP
(
MRID
No.
44283401).
Requirements
for
future
MAI
TEP
testing
of
mancozeb
is
being
reserved
and
may
be
required
if
these
TEP
formulations
are
identified
as
being
a
toxicological
concern
to
terrestrial
plants.
Due
to
the
mixture
of
mancozeb
and
dimethomorph
that
was
used
in
the
only
study
evaluated
for
this
guideline
requirement,
EFED
still
has
concerns
about
the
effects
that
mancozeb
as
a
SAI
TEP
would
have
on
non­
target
terrestrial
plants
and
is
recommending
the
submission
of
Tier
I
seedling
emergence
[
guideline
122­
1(
a)]
and
vegetative
vigor
[
guideline
122­
1(
b)]
studies
for
a
mancozeb
SAI
TEP.

Tier
II
Vegetative
Vigor
testing
is
not
required,
at
this
time,
for
mancozeb
but
is
being
reserved
pending
the
results
of
Tier
I
testing
of
a
mancozeb
SAI
TEP.
85
Table
16:
Non­
target
Terrestrial
Plant
Seedling
Emergence
Toxicity
(
Tier
I)
­
Acrobat
MZ
­
Mancozeb
and
Dimethomorph
­
End­
Use
Formulation
Species
%
ai
Mancozeb/

Dimethomorp
h
Mancozeb/

Dimethomorp
h
Dose
(
lbs
ai/
A)
%
Inhibition
Response/

Endpoint
Affected
MRID
No.

Author/
Year
Study
Classification1
Monocot­
Corn
60/
9
1.38/
0.20
0.0/
no
parameter
affected
44283401/
Chetram,
R.
et
al./
1997
Core
Monocot­

Onion
60/
9
1.38/
0.20
12.0/
dry
weight
44283401/
Chetram,
R.
et
al./
1997
Core
Monocot­

Ryegrass
60/
9
1.38/
0.20
4.0/
height
=
dry
weight
44283401/
Chetram,
R.
et
al./
1997
Core
Monocot­
Oat
60/
9
1.38/
0.20
3.0/
height
44283401/
Chetram,
R.
et
al./
1997
Core
Dicot­

Cucumber
60/
9
1.38/
0.20
0.0/
no
parameter
affected
44283401/
Chetram,
R.
et
al./
1997
Core
Dicot­
Soybean
60/
9
1.38/
0.20
4.0/
dry
weight
44283401/
Chetram,
R.
et
al./
1997
Core
Dicot­
Cabbage
60/
9
1.38/
0.20
1.0/
height
44283401/
Chetram,
R.
et
al./
1997
Core
Dicot­
Radish
60/
9
1.38/
0.20
2.0/
emergence
44283401/
Chetram,
R.
et
al./
1997
Core
Dicot­
Lettuce
60/
9
1.38/
0.20
0.0/
no
parameter
affected
44283401/
Chetram,
R.
et
al./
1997
Core
Dicot­
Tomato
60/
9
1.38/
0.20
4.0/
dry
weight
44283401/
Chetram,
R.
et
al./
1997
Core
1
Core
(
study
satisfies
guideline).
Supplemental
(
study
is
scientifically
sound,
but
does
not
satisfy
guideline).
86
Table
17:
Non­
target
Terrestrial
Plant
Vegetative
Vigor
Toxicity
(
Tier
I)
­
Acrobat
MZ
­
Mancozeb
and
Dimethomorph
­
End­
Use
Formulation
Species
%
ai
Mancozeb/

Dimethomorph
Mancozeb/

Dimethomorph
Dose
(
lbs
ai/
A)
%
Inhibition
Response/

Endpoint
Affected
MRID
No.

Author/
Year
Study
Classification1
Monocot­
Corn
60/
9
1.38/
0.20
2.0/
dry
weight
44283401/
Chetram,

R.
et
al./
1997
Core
Monocot­
Onion
60/
9
1.38/
0.20
2.0/
dry
weight
44283401/
Chetram,

R.
et
al./
1997
Core
Monocot­
Ryegrass
60/
9
1.38/
0.20
0.0/
no
parameter
affected
44283401/
Chetram,

R.
et
al./
1997
Core
Monocot­
Oat
60/
9
1.38/
0.20
2.0/
height
44283401/
Chetram,

R.
et
al./
1997
Core
Dicot­
Cucumber
60/
9
1.38/
0.20
10.0/
dry
weight
44283401/
Chetram,

R.
et
al./
1997
Core
Dicot­
Soybean
60/
9
1.38/
0.20
0.0/
no
parameter
affected
44283401/
Chetram,

R.
et
al./
1997
Core
Dicot­
Cabbage
60/
9
1.38/
0.20
0.0/
no
parameter
affected
44283401/
Chetram,

R.
et
al./
1997
Core
Dicot­
Radish
60/
9
1.38/
0.20
5.0/
dry
weight
44283401/
Chetram,

R.
et
al./
1997
Core
Dicot­
Lettuce
60/
9
1.38/
0.20
3.0/
dry
weight
44283401/
Chetram,

R.
et
al./
1997
Core
Dicot­
Tomato
60/
9
1.38/
0.20
6.0/
dry
weight
44283401/
Chetram,

R.
et
al./
1997
Core
1
Core
(
study
satisfies
guideline).
Supplemental
(
study
is
scientifically
sound,
but
does
not
satisfy
guideline).

2.
Terrestrial
Plant
Field
Studies
No
studies
were
submitted
and
no
studies
are
required.

3.
Aquatic
Plants
Aquatic
plant
testing
is
recommended
for
all
pesticides
having
outdoor
uses
(
Keehner.
July
1999).
The
tests
are
performed
on
species
from
a
cross­
section
of
the
non­
target
aquatic
plant
population.
The
preferred
test
species
are
duckweed
(
Lemna
gibba),
marine
diatom
(
Skeletonema
costatum),
blue­
green
algae
(
Anabaena
flos­
aquae),
freshwater
green
alga
(
Selenastrum
capricornutum),
and
a
freshwater
diatom.
Tier
I
aquatic
plant
testing
is
a
maximum
dose
test
designed
to
quickly
evaluate
the
toxic
effects
to
the
test
species
in
terms
of
growth
and
reproduction
and
to
determine
the
need
for
additional
aquatic
plant
testing.
Tier
II
aquatic
plant
testing
is
a
multiple
dose
test
of
the
plants
species
that
showed
a
phytotoxic
effect
to
the
pesticide
being
tested
at
the
Tier
I
level.
Tier
II
testing
is
aimed
to
determine
the
detrimental
effect
levels
of
the
chemical
on
the
aquatic
plants
which
showed
a
greater
than
50%
detrimental
effect
in
Tier
I
testing.
21
EFED
based
the
EC
05
on
a
calculated
value
(
that
is,
17.9
ppb)
since
a
NOAEC
was
not
established
on
MRID
No.
43664701.
EFED
used
the
following
formula:
probit
k
=
(
log
LC
k
­
log
LC
50
)
*
slope
+
probit
50%;
where:
k
=
5%
growth
inhibition
and
LC
k
=
17.9
ppb
(
Urban
and
Cook,
1986).

87
For
mancozeb,
one
Tier
II
core
study
has
been
submitted
for
S.
capricornutum.
Results
of
Tier
II
toxicity
testing
on
the
technical
material
are
tabulated
in
Table
18,
below.
The
EC
50
for
S.
capricornutum
was
47.0
ppb
a.
i.
based
on
growth
inhibition;
the
NOAEC
was
<
22.0
ppb
21.
The
toxicity
value
(
EC
50
)
appearing
in
the
shaded
area
of
the
table
will
be
used
to
calculate
the
acute
risk
quotients
(
RQ's)
in
subsequent
sections.
Guideline
123­
2
(
Tier
II)
has
been
partially
fulfilled
(
MRID
No.
43664701).
Guideline
122­
2
(
Tier
I)
or
Guideline
123­
2
(
Tier
II)
aquatic
plant
growth
testing
needs
to
be
submitted
for
duckweed
(
Lemna
gibba),
marine
diatom
(
Skeletonema
costatum),
bluegreen
algae
(
Anabaena
flos­
aquae),
and
a
freshwater
diatom.

The
results
of
aquatic
plant
Tier
II
toxicity
for
end­
use
formulations
of
the
active
ingredients,
mancozeb
and
dimethomorph
are
also
tabulated
in
the
Table
18,
below.
The
supplemental
studies
did
not
fufill
guideline
requirements
because
the
duration
of
the
study
was
less
than
the
required
120
hours
and
an
inert
ingredient
control
was
not
included
in
the
test.
Guideline
123­
2
(
Tier
II),
for
the
indicated
(
see
Table
18),
end­
use
formulation
of
dimethomorph
and
zoxamide
with
mancozeb
have
been
fulfilled
for
nonvascular
plants
(
MRID
No.
44283402).
A
core
study
for
this
end­
use
formulation
needs
to
be
submitted
for
the
the
vascular
non­
target
test
species,
duckweed
(
Lemna
gibba).
88
Table
18:
Non­
target
Aquatic
Plant
Toxicity
(
Tier
II)
­
Mancozeb
Technical
Species/
duration
%
A.
I.
EC50/
NOAEC
(
ppb
ai)
MRID
No.

Author/
year
Classification1
Nonvascular
Plants
frreshwater
green
algae
(
Selenastrum
capricornutum)

/
120
hrs.
82.4
47.0/<
22.0
slope
=
4.1
Probit
LD
50
=
46
95%
CI
=
41.3
­
50.1
Probit
slope
=
4.0
95%
CI
=
3.4
­
4.6
43664701/
Forbis,
A./
1990
Core
End­
Use
Formulation
freshwater
green
algae
(
Selenastrum
capricornutum)

/
72
hrs.
7.5
(
dimethomorph)

67.7
(
mancozeb)
19/
4.32
43917217/
Toy,
R
&
A.

Gray/
1992
Supplemental
freshwater
green
algae
(
Selenastrum
capricornutum)

/
120
hrs.
9.0
(
dimethomorph)

60.0
(
mancozeb)
112/
282
44283402/
Hughes,
J.
et
al./
1997
Core
marine
diatom
(
Skeletonema
costatum)/
120
hrs.
9.0
(
dimethomorph)

60.0
(
mancozeb)
139/
1042
44283402/
Hughes,
J.
et
al./
1997
Core
freshwaterr
diatom
(
Navicula
pelliculosa)/
120
hrs.
9.0
(
dimethomorph)

60.0
(
mancozeb)
13.71/
2.882
44283402/
Hughes,
J.
et
al./
1997
Core
freshwater
bluegreen
algae
(
Anabaena
flosaquae
120
hrs.
9.0
(
dimethomorph)

60.0
(
mancozeb)
130/
282
44283402/
Hughes,
J.
et
al./
1997
Core
1
Core
(
study
satisfies
guideline).
Supplemental
(
study
is
scientifically
sound,
but
does
not
satisfy
guideline).

2
Based
upon
total
product
concentration.

4.
Aquatic
Plant
Field
Studies
No
studies
were
submitted
and
no
studies
are
required.
89
APPENDIX
IV:
Environmental
Exposure
Assessment
a.
Overview
of
Risk
Quotients
(
RQs)

Risk
characterization
integrates
the
results
of
the
exposure
and
ecotoxicity
data
to
evaluate
the
likelihood
of
adverse
ecological
effects.
The
Agency
calls
this
integration
the
quotient
method.
The
Agency
calculates
risk
quotients
(
RQs)
by
dividing
exposure
estimates
by
acute
and
chronic
ecotoxicity
values.

RQ
=
EXPOSURE/
TOXICITY
EFED
compares
RQs
to
OPP's
levels
of
concern
(
LOCs).
OPP
uses
these
LOCs
to
analyze
potential
risk
to
non­
target
organisms
and
the
need
to
consider
regulatory
action.
This
method
signals
that
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
risks
­
the
risks
warrant
regulatory
action
as
well
as
restricted
use
classification;
(
2)
acute
restricted
use
­
the
potential
for
acute
risk
exists,
but
the
restricted
use
classification
may
mitigate
the
risk;
(
3)
acute
endangered
species
­
the
risk
may
adversely
affect
endangered
species;
and
(
4)
chronic
risk
­
the
risk
may
warrant
regulatory
action
because
there
is
a
potential
for
chronic
risk.
Currently,
EFED
does
not
perform
assessments
for
chronic
risk
to
plants,
acute
or
chronic
risks
to
non­
target
insects,
or
chronic
risk
from
granular
or
bait
formulations
to
birds
or
mammals.

The
Agency
gets
ecotoxicity
test
values
(
measurement
endpoints)
used
in
the
acute
and
chronic
risk
quotients
from
required
studies.
Examples
of
ecotoxicity
values
gathered
from
short­
term
laboratory
studies
that
assess
acute
effects
are:
(
1)
LC
50
(
fish
and
birds);
(
2)
LD
50
(
birds
and
mammals);
(
3)
EC
50
(
aquatic
plants
and
aquatic
invertebrates);
and
(
4)
EC
25
(
terrestrial
plants).
Examples
of
toxicity
test
effect
levels
drawn
from
the
results
of
long­
term
laboratory
studies
that
assess
chronic
effects
are:
(
1)
LOAEL
or
LOAEC
(
birds,
fish,
and
aquatic
invertebrates)
and
(
2)
NOAEL
or
NOAEC
(
birds,
fish
and
aquatic
invertebrates).
For
birds,
mammals,
fish
and
aquatic
invertebrates,
the
Agency
uses
the
NOAEL
or
NOAEC
as
the
ecotoxicity
test
value
in
assessing
chronic
effects,
although
the
Agency
may
use
other
values
when
justified.
Tabulated
below
are
risk
presumptions
and
the
matching
RQs
and
LOCs.

Risk
quotients
are
index
or
reference
values
used
to
show
potential
ecological
risk.
There
are
limits
with
the
use
of
risk
quotients
in
assessing
the
risk
to
non­
target
animals
and
plants.
The
likelihood
of
an
adverse
effect
does
not
increase
with
the
size
of
the
risk
quotient.
(
Urban,
2000).
An
LOC
defined
as
1
(
see
table
below)
provides
the
reference
point
for
estimating
the
exposure
to
toxicity
risk
(
that
is,
risk
quotient).
Values
at
or
above
this
reference
point
trigger
risk
concerns.
A
risk
quotient
value
of
100
compared
to
a
value
of
50
does
not
suggest
a
greater
risk
or
a
risk
that
is
more
likely
to
occur.
Both
these
values
are
above
the
reference
point
for
risk
of
1.
The
risk
quotient
value
of
100
reflects
an
exposure
level
that
is
twice
has
high
as
the
risk
quotient
value
of
50.
The
"
exposure"
in
the
"
RQ
=
Exposure/
Toxicity"
ratio
is
twice
has
high
for
RQ
of
100
as
for
the
RQ
of
50.
Risk
quotients
are
nonprobabilistic
and
have
numerical
and
dichotomous
results.
The
numerical
result
90
drawn
from
the
calculation
either
exceeds
a
fixed
LOC
or
does
not
exceed
it.
(
US
EPA.
June
30,
1995).

Table
1.
Risk
presumptions
for
terrestrial
animals
based
on
risk
quotients
(
RQ)
and
levels
of
concern
(
LOC).

Risk
Presumption
RQ
LOC
Birds
Acute
Risk
EEC1/
LC
50
or
LD
50
/
ft2
or
LD
50
/
day3
0.5
Acute
Restricted
Use
EEC/
LC
50
or
LD
50
/
ft2
or
LD
50
/
day
(
or
LD
50
<
50
mg/
kg)
0.2
Acute
Endangered
Species
EEC/
LC
50
or
LD
50
/
ft2
or
LD
50
/
day
0.1
Chronic
Risk
EEC/
NOAEC
1
Wild
Mammals
Acute
Risk
EEC/
LC
50
or
LD
50
/
ft2
or
LD
50
/
day
0.5
Acute
Restricted
Use
EEC/
LC
50
or
LD
50
/
ft2
or
LD
50
/
day
(
or
LD
50
<
50
mg/
kg)
0.2
Acute
Endangered
Species
EEC/
LC
50
or
LD
50
/
ft2
or
LD
50
/
day
0.1
Chronic
Risk
EEC/
NOAEC
1
1
abbreviation
for
Estimated
Environmental
Concentration
(
ppm)
on
avian/
mammalian
food
items
2
mg/
ft2
3
mg
of
toxicant
consumed/
day
LD
50
*
wt.
of
bird
LD
50
*
wt.
of
bird
Table
2.
Risk
presumptions
for
aquatic
animals
based
on
risk
quotients
(
RQ)
and
levels
of
concern
(
LOC).

Risk
Presumption
RQ
LOC
Acute
Risk
EEC1/
LC
50
or
EC
50
0.5
Acute
Restricted
Use
EEC/
LC
50
or
EC
50
0.1
Acute
Endangered
Species
EEC/
LC
50
or
EC
50
0.05
Chronic
Risk
EEC/
NOAEC
1
1
EEC
=
(
ppm
or
ppb)
in
water
Table
3.
Risk
presumptions
for
plants
based
on
risk
quotients
(
RQ)
and
levels
of
concern
(
LOC).

Risk
Presumption
RQ
LOC
Terrestrial
and
Semi­
Aquatic
Plants
Acute
Risk
EEC1/
EC
25
1
Acute
Endangered
Species
EEC/
EC
05
or
NOAEC
1
Aquatic
Plants
Acute
Risk
EEC2/
EC
50
1
Acute
Endangered
Species
EEC/
EC
05
or
NOAEC
1
1
EEC
=
lbs
ai/
A
2
EEC
=
(
ppb/
ppm)
in
water
91
b.
Exposure
and
Risk
to
Terrestrial
Animals
i.
Birds
EFED
does
not
currently
have
an
exposure
scenario
for
determining
the
exposure
risks
from
the
use
of
mancozeb
on
caprifigs
or
pineapples
as
a
dip
treatment
and
these
risks
have
not
been
evaluated
in
this
RED.

The
acute
risk
to
avian
species
as
a
result
of
exposure
to
mancozeb
from
multiple
applications
of
mancozeb
nongranular
products
was
not
able
to
be
made
because
an
avian
LC
50
has
not
been
determined
from
dietary
exposure.
As
mentioned
in
Appendix
III,
the
dietary
testing
that
would
have
provided
this
toxicity
information
was
waived
by
EFED.
The
chronic
risk
quotients
for
multiple
broadcast
applications
of
nongranular
mancozeb
products
are
tabulated
below.
Analysis
of
the
results
indicate
that
for
multiple
applications
of
mancozeb
nongranular
products,
avian
chronic
levels
of
concern
(
LOCs)
are
exceeded
for
all
uses
patterns.
92
Table
4:
Avian
Chronic
Risk
Quotients
for
Multiple
Broadcast
Applications
of
Nongranular
Mancozeb
based
on
a
Mallard
Duck
(
Anas
platyrhynchos)
NOAEC
of
125
ppm.

Application
Rate
Chronic
RQ
Chronic
RQ
(
lbs
ai/
A)/

Based
on
Based
on
Number
of
Mean
EECs
Maximum
EECs
Mean
Maximum
Applications/
Site/

(
Mean
EEC/
NOAEC)
2
(
Max.
EEC/
NOAEC)
2
EEC
(
ppm)
1
EEC
(
ppm)
1
Food
Items
Interval
Application
Method
10.7
30.3
1,342
3,788
Short
grass
4.8/
4
Apples,
Cranapple,

4.5
13.9
568
1,736
Tall
grass
7­
day
interval
Pear,
&
Quince
5.7
17.0
710
2,131
Broadleaf
plants/
Insects
ground
&
aerial
0.9
1.9
110
237
Seeds
3.3
9.4
414
1,169
Short
grass
1.6/
4
Asparagus
1.4
4.3
175
536
Tall
grass
10­
day
interval
ground
&
aerial
1.8
5.3
219
658
Broadleaf
plants/
Insects
0.3
0.6
34
73
Seeds
6.3
17.8
790
2,230
Short
grass
2.4/
10
Bananas
&
Plantain
2.7
8.2
335
1,022
Tall
grass
14­
day
interval
ground
&
aerial
3.3
10.0
418
1,254
Broadleaf
plants/
Insects
0.5
1.1
65
139
Seeds
2.9
8.1
357
1,009
Short
grass
1.6/
3
Barley,
Oats,
Rye,

1.2
3.7
151
463
Tall
grass
7­
day
interval
Triticale,
&
Wheat
1.5
4.5
189
568
Broadleaf
plants/
Insects
ground
&
aerial
0.2
0.5
29
63
Seeds
1.6
4.5
201
568
Short
grass
0.9/
3
a
Citrus
0.7
2.1
85
260
Tall
grass
7­
day
interval
ground
&
aerial
0.9
2.6
106
319
Broadleaf
plants/
Insects
0.1
0.3
17
35
Seeds
7.4
21.0
931
2,629
Short
grass
1.2/
15
Corn
(
unspecified)

3.2
9.6
394
1,205
Tall
grass
4­
day
interval
(
E.
of
Miss.
River)

3.9
11.8
493
1,479
Broadleaf
plants/
Insects
ground
&
aerial
0.6
1.3
77
164
Seeds
5.9
16.6
733
2,069
Short
grass
1.2/
10
Corn
(
unspecified)

2.5
7.6
310
948
Tall
grass
4­
day
interval
(
W.
of
Miss.
River)

3.1
9.3
388
1,164
Broadleaf
plants/
Insects
ground
&
aerial
0.5
1.0
60
129
Seeds
3.3
9.4
414
1,169
Short
grass
1.6/
4
Cotton
1.4
4.3
175
536
Tall
grass
10­
day
interval
ground
&
aerial
1.8
5.3
219
658
Broadleaf
plants/
Insects
0.3
0.6
34
73
Seeds
8.6
24.2
1,072
3,028
Short
grass
4.8/
3
Cranberry
3.6
11.1
454
1,388
Tall
grass
7­
day
interval
ground
&
aerial
4.5
13.6
568
1,703
Broadleaf
plants/
Insects
0.7
1.5
88
189
Seeds
93
Table
4
(
continued):
Avian
Chronic
Risk
Quotients
for
Multiple
Broadcast
Applications
of
Nongranular
Mancozeb
based
on
a
Mallard
Duck
(
Anas
platyrhynchos)
NOAEC
of
125
ppm.

Application
Rate
Chronic
RQ
Chronic
RQ
(
lbs
ai/
A)/

Based
on
Based
on
Number
of
Mean
EECs
Maximum
EECs
Mean
Maximum
Applications/
Site/

(
Mean
EEC/
NOAEC)
2
(
Max.
EEC/
NOAEC)
2
EEC
(
ppm)
1
EEC
(
ppm)
1
Food
Items
Interval
Application
Method
8.4
23.9
1,056
2,982
Short
grass
2.4/
8
Cucumber
3.6
10.9
447
1,367
Tall
grass
7­
day
interval
ground
&
aerial
4.5
13.4
559
1,677
Broadleaf
plants/
Insects
0.7
1.5
87
186
Seeds
5.6
15.9
704
1,988
Short
grass
1.6/
8
Fennel
2.4
7.3
298
911
Tall
grass
7­
day
interval
ground
&
aerial
3.0
8.9
373
1,118
Broadleaf
plants/
Insects
0.5
1.0
58
124
Seeds
9.5
26.8
1,187
3,350
Short
grass
3.2/
6
Grapes
4.0
12.3
503
1,536
Tall
grass
7­
day
interval
(
E.
of
Rocky
Mtns.)

5.0
15.1
628
1,885
Broadleaf
plants/
Insects
ground
&
aerial
0.8
1.7
98
209
Seeds
3.6
10.1
447
1,262
Short
grass
2.0/
3
Grapes
1.5
4.6
189
578
Tall
grass
7­
day
interval
(
W.
of
Rocky
Mtns.)

1.9
5.7
237
710
Broadleaf
plants/
Insects
ground
&
aerial
0.3
0.6
37
79
Seeds
8.4
23.9
1,056
2,982
Short
grass
2.4/
8
Melons
&
Squash
3.6
10.9
447
1,367
Tall
grass
7­
day
interval
ground
&
aerial
4.5
13.4
559
1,677
Broadleaf
plants/
Insects
0.7
1.5
87
186
Seeds
9.5
26.7
1,182
3,337
Short
grass
2.4/
10
Onion,
Garlic,
&
Shallot
4.0
12.2
501
1,530
Tall
grass
7­
day
interval
ground
&
aerial
5.0
15.0
626
1,877
Broadleaf
plants/
Insects
0.8
1.7
97
209
Seeds
14.4
40.7
1,803
5,091
Short
grass
4.0/
7
Papaya
6.1
18.7
764
2,334
Tall
grass
5­
day
interval
ground
&
aerial
7.6
22.9
955
2,864
Broadleaf
plants/
Insects
1.2
2.5
149
318
Seeds
5.6
15.9
704
1,988
Short
grass
1.6/
8
Peanuts
2.4
7.3
298
911
Tall
grass
7­
day
interval
ground
&
aerial
3.0
8.9
373
1,118
Broadleaf
plants/
Insects
0.5
1.0
58
124
Seeds
94
Table
4
(
continued):
Avian
Chronic
Risk
Quotients
for
Multiple
Broadcast
Applications
of
Nongranular
Mancozeb
based
on
a
Mallard
Duck
(
Anas
platyrhynchos)
NOAEC
of
125
ppm.

Application
Rate
Chronic
RQ
Chronic
RQ
(
lbs
ai/
A)/

Based
on
Based
on
Number
of
Mean
EECs
Maximum
EECs
Mean
Maximum
Applications/
Site/

(
Mean
EEC/
NOAEC)
2
(
Max.
EEC/
NOAEC)
2
EEC
(
ppm)
1
EEC
(
ppm)
1
Food
Items
Interval
Application
Method
5.8
16.3
721
2,037
Short
grass
1.6/
7
Potato
&
Sugar
Beet
2.4
7.5
305
933
Tall
grass
5­
day
interval
ground
&
aerial
3.1
9.2
382
1,146
Broadleaf
plants/
Insects
0.5
1.0
59
127
Seeds
3.7
10.5
463
1,309
Short
grass
2.0/
3
a
Tobacco
1.6
4.8
196
600
Tall
grass
5­
day
interval
ground
&
aerial
2.0
5.9
245
736
Broadleaf
plants/
Insects
0.3
0.7
38
82
Seeds
7.8
22.1
979
2,764
Short
grass
2.4/
7
Tomato
3.3
10.1
415
1,267
Tall
grass
7­
day
interval
ground
&
aerial
4.1
12.4
518
1,554
Broadleaf
plants/
Insects
0.6
1.4
81
173
Seeds
2.7
7.6
335
946
Short
grass
1.5/
3
a
Vegetablesb
1.1
3.5
142
434
Tall
grass
7­
day
interval
ground
&
aerial
1.4
4.3
177
532
Broadleaf
plants/
Insects
0.2
0.5
28
59
Seeds
5.1
14.3
634
1,791
Short
grass
3.2/
3
a
Forestry
(
Douglas
Fir)

2.1
6.6
269
821
Tall
grass
14­
day
interval
ground
&
aerial
2.7
8.1
336
1,008
Broadleaf
plants/
Insects
0.4
0.9
52
112
Seeds
5.1
14.3
634
1,791
Short
grass
3.2/
3
a
Ornamental
Trees
c
2.1
6.6
269
821
Tall
grass
14­
day
interval
ground
&
aerial
2.7
8.1
336
1,008
Broadleaf
plants/
Insects
0.4
0.9
52
112
Seeds
95
Table
4
(
continued):
Avian
Chronic
Risk
Quotients
for
Multiple
Broadcast
Applications
of
Nongranular
Mancozeb
based
on
a
Mallard
Duck
(
Anas
platyrhynchos)
NOAEC
of
125
ppm.

Application
Rate
Chronic
RQ
Chronic
RQ
(
lbs
ai/
A)/

Based
on
Based
on
Number
of
Mean
EECs
Maximum
EECs
Mean
Maximum
Applications/
Site/

(
Mean
EEC/
NOAEC)
2
(
Max.
EEC/
NOAEC)
2
EEC
(
ppm)
1
EEC
(
ppm)
1
Food
Items
Interval
Application
Method
2.9
8.1
357
1,009
Short
grass
1.6/
3
a
Ornamentals
d
1.2
3.7
151
463
Tall
grass
7­
day
interval
ground
&
aerial
1.5
4.5
189
568
Broadleaf
plants/
Insects
0.2
0.5
29
63
Seeds
33.1
93.4
4,133
11,670
Short
grass
13.9/
5
Ornamentals
14.0
42.8
1,751
5,349
Tall
grass
10­
day
interval
(
pachysandra
groundcover)

17.5
52.5
2,188
6,564
Broadleaf
plants/
Insects
ground
2.7
5.8
340
729
Seeds
32.3
91.1
4,032
11,384
Short
grass
17.4/
3
a
Turf
(
golf
course)

13.7
41.7
1,708
5,218
Tall
grass
5­
day
interval
ground
17.1
51.2
2,135
6,404
Broadleaf
plants/
Insects
2.7
5.7
332
712
Seeds
35.2
99.4
4,403
12,431
Short
grass
19.0/
3
a
Turf
e
14.9
45.6
1,865
5,697
Tall
grass
5­
day
interval
ground
&
aerial
18.6
55.9
2,331
6,992
Broadleaf
plants/
Insects
2.9
6.2
363
777
Seeds
1
Assumes
degradation
using
FATE
version
5.0
program
with
a
half­
life
of
35
days.
EFED
uses
this
value
as
a
default
value
when
the
foliar
dissipation
for
a
particular
pesticide
is
unknown.

2
RQ
greater
or
equal
to
1.00
exceeds
chronic
LOC.

a
Maximum
number
of
applications/
year
or
crop
cycle
not
specified
(
assumed
3
applications).

b
Beets
(
unspecified),
Broccoli,
Brussel
sprouts,
Cabbage,
Carrots,
Cauliflower,
Chard
(
Swiss),

Collards,
Coriander,
Dill,
Endive,
Kale,
Kohlrabi,
Leeks,
Lettuce,
Mustard,
Mustard
Cabbage,

Parsley,
Parsnip,
Radish,
Rape,
Roquette
(
Arrugula),
Rutabaga,
Spinach,
&
Turnip
c
Christmas
Tree
Plantations
d
Trees,
Herbaceous
Plants,
Non
Flowering
Plants,
&
Woody
Shrubs
and
Vines
e
Commercial/
Industrial,
Sod
Farm,
&
Residential
96
The
acute
risk
quotients
for
applications
of
mancozeb
treated
seed
are
tabulated
below.
Ecological
risks
from
seed
treatments
are
assessed
by
the
same
method
used
for
granular
and
bait
products.
For
typical
in­
furrow
planting
or
drill
seeded,
1%
of
the
seeds
planted
are
assumed
to
be
exposed.
The
number
of
lethal
doses
(
LD
50
s)
that
are
available
within
one
square
foot
immediately
after
application
(
LD
50
s/
ft2)
is
used
as
the
risk
quotient
for
seeds
treated
with
mancozeb.
This
calculation
does
not
include
the
untreated
area
between
rows.
Birds
have
been
reported
following
directly
behind
planting
equipment
to
forage
on
worms
and
other
invertebrates
exposed
by
the
freshly
tilled
soil.
Therefore,
it
is
assumed
that
birds
will
forage
mostly
within
the
planted
area
where
the
pesticide
treated
seed
is
planted.
This
planted
area
is
assumed
to
be
1.2
inches
(
0.1
feet)
wide
for
in­
furrow
planting
(
EEB
Guidance
Doc.
E­
02C.
June,
1995).
Risk
quotients
are
calculated
for
three
separate
weight
class
of
birds:
1000
g
(
e.
g.,
waterfowl),
180
g
(
e.
g.,
upland
gamebird),
and
20
g
(
e.
g.,
songbird).
The
amount
of
mancozeb
on
a
seed
was
estimated
to
determine
the
number
of
seeds
that
would
need
to
consumed
to
reach
the
LD
50
(
Keehner
D.
July,
1999a).

An
analysis
of
the
results
indicates
that
for
single
applications
of
mancozeb
treated
seed
no
acute
risk,
acute
restricted
use
or
acute
endangered
species
levels
of
concern
are
exceeded
for
the
use
patterns
indicated.
Chronic
risk
to
birds
from
exposure
to
treated
seed
are
not
currently
be
performed
by
EFED
because
the
appropriate
exposure
scenario
has
not
been
developed.
Based
upon
the
English
House
Sparrow,
multiple
dose
acute
oral
LD
50
of
approximately
1,500
mg
ai/
kg
for
mancozeb
(
MRID
No.
00036094)
and
a
food
consumption
of
19.0%
of
body
wt/
day
(
5
grams),
a
26
gram
English
House
Sparrow
would
need
to
consume
591
rice
seeds
to
reach
its
LD
50
(
see
formula
in
table
5).
15,000
rice
seeds
per
pound
divided
by
4.5359
x
102
grams
per
pound
yields
33
rice
seeds
per
gram.
An
English
House
Sparrow,
assuming
it
is
consuming
only
mancozeb
treated
rice
seeds,
would
consume
165
rice
seeds
per
day
(
33
rice
seeds
per
gram
*
5
grams
per
day).
This
consumption
rate
would
be
approximately
4
times
less
than
the
expected
multiple
dose
LD
50
of
591
rice
seeds
and
the
scenario
that
the
sparrow
would
consume
only
rice
seeds
in
a
single
day
is
unlikely.

It
should
be
noted
that
mancozeb
is
used
for
treating
additional
seeds
and
seed
pieces
that
are
not
listed
in
Table
5,
below.
Table
5
represents
a
listing
of
crop
seeds
that
are
treated
and
no
additional
application
methods
(
i.
e.
broadcast,
dip
treatments,
etc.)
are
used
to
apply
mancozeb
to
the
sites
listed
in
Table
5.
97
Table
5:
Avian
Acute
risk
Quotients
for
Single
Applications
of
Mancozeb
Treated
Seed
Based
on
an
English
Sparrow
(
Passer
domesticus
)

LD50
of
1500
mg
ai/
kg.

Number
of
%
(
decimal)
of
Site/
Application
Method
Seeds
Seeds
Pesticide
Bird
Body
Application
Pounds
Planted
Seed
per
Acre3
Consumed
to
Mg
AI
per
Acute
RQ
2
Exposed
1
Left
on
Weight
Rate
Seed
Treatment
(
lb.
ai
/
100
lb
seed)

Reach
LD50
5
Per
Seed
4
Pound
3
(
LD50/
sq.
ft)
(
mg
ai/
sq.
ft)
the
Surface
(
grams)
(
lb
ai/
A)
Row
Width
(
feet)
Flaxa/
In­
furrow­
Incorporated
1,356
0.022
82,000
0.00926
0.28
0.01
20
0.32
80
12,203
0.00103
180
0.40
67,792
0.00019
1000
0.1
Riceb
/
In­
furrow
(
drilled)­
Incorporated
496
0.060
15,000
0.00312
0.09
0.01
20
0.18
90
4,464
0.00035
180
0.2
24,802
0.00006
1000
0.1
Safflowerb
/
In­
furrow­
Incorporated
529
0.057
8,000
0.00061
0.02
0.01
20
0.035
35
4,762
0.00007
180
0.1
26,456
0.00001
1000
0.1
Sorghumc
/
In­
furrow­
Incorporated
529
0.057
16,000
0.00078
0.02
0.01
20
0.018
9
4,762
0.00009
180
0.2
26,456
0.00002
1000
0.1
1
Exposed
=
App.
Rate
(
lbs.
ai/
A)*
453,590
mg/
lbs
*
%
(
decimal)
on
surface/[
linear
ft
of
row/
A
(
ft/
A)*
row
width
(
ft)]

2
RQ
=
Exposed
(
mg
ai/
sq.
ft.)/[
LD50(
mg
ai/
kg)
*
Weight
of
the
Animal
(
g)/
1000
(
g/
kg)]
RQ
greater
or
equal
to
0.5
exceeds
acute
high,
acute
restricted
use
and
acute
endangered
species
LOCs.

RQ
greater
or
equal
to
0.2
exceeds
acute
restricted
use
and
acute
endangered
species
LOCs.

RQ
greater
or
equal
to
0.1
exceeds
acute
endangered
species
LO
3
Sources:
flax
(
EPA
file
source);
rice
(
http://
ext.
msstate.
edu/
anr/
plantsoil/
rice/
riceq4.
html)
;

safflower
(
http://
www.
montana.
edu/
wwwpb/
ag/
saff_
for.
html);
sorghum(
http://
www.
aes.
purdue.
edu/
AgAnswrs/
1995/
6­
13Corn_
Sorghum_
Swit
4
Mg
AI
per
Seed
=
seed
treatment
rate
(
lb
ai/
100
lb
seed)/
100
lb
seed/
seeds
per
lb
*
453,590
mg/

5
Number
of
Seeds
Consumed
to
Reach
LD50
=
[
LD50(
mg
ai/
kg)
*
Weight
of
the
Animal
(
g)/
1000
(
g/
kg)]/
mg
ai
per
seed
a
Assumes
10
inch
row
spacing
or
52,272
linear
ft
of
row
per
acre
b
Assumes
6
inch
row
spacing
or
87,120
linear
ft
of
row
per
acre
c
Assumes
15
inch
row
spacing
or
34,848
linear
ft
of
row
per
acre
98
ii.
Mammals
As
identified
in
Appendix
III,
mancozeb
is
practically
nontoxic
(
rat
LD
50
>
5,000
mg/
kg)
to
mammals
on
an
acute
basis.
Because
of
this,
the
acute
exposure
to
mancozeb
presents
a
low
risk
to
mammals
so
RQs
for
acute
exposure
were
not
determined.
The
chronic
mammalian
risk
quotients
for
multiple
broadcast
applications
of
nongranular
products
are
tabulated
below
in
table
6.
The
results
indicate
that
chronic
mammalian
LOCs
are
exceeded
for
all
mancozeb
use
patterns
listed.
99
Table
6:
Mammalian
Chronic
Risk
Quotients
for
Multiple
Applications
of
Mancozeb
Nongranula
NOAEL
of
120
ppm
Based
on
Parental
Body
Weight
Decrements,
Increased
Relative
Thyroid
W
Incidence
of
Thyroid
Follicular
Cell
Hyperplasia
in
a
2­
Generation
Reproductive
Study
on
labaratory
rats
(
Rattus
n
Application
Rate
Chronic
RQ
Chronic
RQ
(
lbs
ai/
A)/

Based
on
Based
on
Number
of
Mean
EECs
Maximum
EECs
Mean
Maximum
Applications/
Site/

(
Mean
EEC/
NOAE
2
(
Max.
EEC/
NOAE
2
EEC
(
ppm)
1
EEC
(
ppm1
Food
Items
Interval
Application
Method
11.2
31.6
1,342
3,788
Short
grass
4.8/
4
Apples,
Cranapple,

4.7
14.5
568
1,736
Tall
grass
7­
day
interva
Pear,
&
Quince
5.9
17.8
710
2,131
Broadleaf
plants/
Ins
ground
&
aerial
0.9
2.0
110
237
Seeds
3.5
9.7
414
1,169
Short
grass
1.6/
4
Asparagus
1.5
4.5
175
536
Tall
grass
10­
day
interva
ground
&
aerial
1.8
5.5
219
658
Broadleaf
plants/
Ins
0.3
0.6
34
73
Seeds
6.6
18.6
790
2,230
Short
grass
2.4/
10
Bananas
&
Plantain
2.8
8.5
335
1,022
Tall
grass
14­
day
interva
ground
&
aerial
3.5
10.5
418
1,254
Broadleaf
plants/
Ins
0.5
1.2
65
139
Seeds
3.0
8.4
357
1,009
Short
grass
1.6/
3
Barley,
Oats,
Rye,

1.3
3.9
151
463
Tall
grass
7­
day
interval
Triticale,
&
Wheat
1.6
4.7
189
568
Broadleaf
plants/
Ins
ground
&
aerial
0.2
0.5
29
63
Seeds
1.7
4.7
201
568
Short
grass
0.9/
3a
Citrus
0.7
2.2
85
260
Tall
grass
7­
day
interval
ground
&
aerial
0.9
2.7
106
319
Broadleaf
plants/
Ins
0.1
0.3
17
35
Seeds
7.8
21.9
931
2,629
Short
grass
1.2/
15
Corn
(
unspecified)

3.3
10.0
394
1,205
Tall
grass
4­
day
interval
(
E.
of
Miss.
River)

4.1
12.3
493
1,479
Broadleaf
plants/
Ins
ground
&
aerial
0.6
1.4
77
164
Seeds
100
Table
6
(
continued):
Mammalian
Chronic
Risk
Quotients
for
Multiple
Applications
of
Mancozeb
Nongranular
(
Br
NOAEL
of
120
ppm
Based
on
Parental
Body
Weight
Decrements,
Increased
Relative
Thyroid
W
Incidence
of
Thyroid
Follicular
Cell
Hyperplasia
in
a
2­
Generation
Reproductive
Study
on
labaratory
rats
(
Rattus
Application
Rate
Chronic
RQ
Chronic
RQ
(
lbs
ai/
A)/

Based
on
Based
on
Number
of
Mean
EECs
Maximum
EECs
Mean
Maximum
Applications/
Site/

(
Mean
EEC/
NOAE
2
(
Max.
EEC/
NOAEL
2
EEC
(
ppm)
1
EEC
(
ppm)
1
Food
Items
Interval
Application
Method
6.1
17.2
733
2,069
Short
grass
1.2/
10
Corn
(
unspecified)

2.6
7.9
310
948
Tall
grass
4­
day
interval
(
W.
of
Miss.
River)

3.2
9.7
388
1,164
Broadleaf
plants/
Inse
ground
&
aerial
0.5
1.1
60
129
Seeds
3.5
9.7
414
1,169
Short
grass
1.6/
4
Cotton
1.5
4.5
175
536
Tall
grass
10­
day
interva
ground
&
aerial
1.8
5.5
219
658
Broadleaf
plants/
Inse
0.3
0.6
34
73
Seeds
8.9
25.2
1,072
3,028
Short
grass
4.8/
3
Cranberry
3.8
11.6
454
1,388
Tall
grass
7­
day
interval
ground
&
aerial
4.7
14.2
568
1,703
Broadleaf
plants/
Inse
0.7
1.6
88
189
Seeds
8.8
24.8
1,056
2,982
Short
grass
2.4/
8
Cucumber
3.7
11.4
447
1,367
Tall
grass
7­
day
interval
ground
&
aerial
4.7
14.0
559
1,677
Broadleaf
plants/
Inse
0.7
1.6
87
186
Seeds
5.9
16.6
704
1,988
Short
grass
1.6/
8
Fennel
2.5
7.6
298
911
Tall
grass
7­
day
interval
ground
&
aerial
3.1
9.3
373
1,118
Broadleaf
plants/
Inse
0.5
1.0
58
124
Seeds
9.9
27.9
1,187
3,350
Short
grass
3.2/
6
Grapes
4.2
12.8
503
1,536
Tall
grass
7­
day
interval
(
E.
of
Rocky
Mtns.)

5.2
15.7
628
1,885
Broadleaf
plants/
Inse
ground
&
aerial
0.8
1.7
98
209
Seeds
101
Table
6
(
continued):
Mammalian
Chronic
Risk
Quotients
for
Multiple
Applications
of
Mancozeb
Nongranular
(
Broadca
NOAEL
of
120
ppm
Based
on
Parental
Body
Weight
Decrements,
Increased
Relative
Thyroid
Weigh
Incidence
of
Thyroid
Follicular
Cell
Hyperplasia
in
a
2­
Generation
Reproductive
Study
on
labaratory
rats
(
Rattus
norve
Application
Rate
Chronic
RQ
Chronic
RQ
(
lbs
ai/
A)/

Based
on
Based
on
Number
of
Mean
EECs
Maximum
EECs
Mean
Maximum
Applications/
Site/

(
Mean
EEC/
NOAEL
2
(
Max.
EEC/
NOAEL
2
EEC
(
ppm)
1
EEC
(
ppm)
1
Food
Items
Interval
Application
Method
3.7
10.5
447
1,262
Short
grass
2.0/
3
Grapes
1.6
4.8
189
578
Tall
grass
7­
day
interval
(
W.
of
Rocky
Mtns.)

2.0
5.9
237
710
Broadleaf
plants/
Inse
ground
&
aerial
0.3
0.7
37
79
Seeds
8.8
24.8
1,056
2,982
Short
grass
2.4/
8
Melons
&
Squash
3.7
11.4
447
1,367
Tall
grass
7­
day
interval
ground
&
aerial
4.7
14.0
559
1,677
Broadleaf
plants/
Inse
0.7
1.6
87
186
Seeds
9.8
27.8
1,182
3,337
Short
grass
2.4/
10
Onion,
Garlic,
&
Shallot
4.2
12.7
501
1,530
Tall
grass
7­
day
interval
ground
&
aerial
5.2
15.6
626
1,877
Broadleaf
plants/
Inse
0.8
1.7
97
209
Seeds
15.0
42.4
1,803
5,091
Short
grass
4.0/
7
Papaya
6.4
19.4
764
2,334
Tall
grass
5­
day
interval
ground
&
aerial
8.0
23.9
955
2,864
Broadleaf
plants/
Inse
1.2
2.7
149
318
Seeds
5.9
16.6
704
1,988
Short
grass
1.6/
8
Peanuts
2.5
7.6
298
911
Tall
grass
7­
day
interval
ground
&
aerial
3.1
9.3
373
1,118
Broadleaf
plants/
Inse
0.5
1.0
58
124
Seeds
6.0
17.0
721
2,037
Short
grass
1.6/
7
Potato
&
Sugar
Beet
2.5
7.8
305
933
Tall
grass
5­
day
interval
ground
&
aerial
3.2
9.5
382
1,146
Broadleaf
plants/
Inse
0.5
1.1
59
127
Seeds
3.9
10.9
463
1,309
Short
grass
2.0/
3a
Tobacco
1.6
5.0
196
600
Tall
grass
5­
day
interval
ground
&
aerial
2.0
6.1
245
736
Broadleaf
plants/
Inse
0.3
0.7
38
82
Seeds
102
Table
6
(
continued):
Mammalian
Chronic
Risk
Quotients
for
Multiple
Applications
of
Mancozeb
Nongranular
(
Bro
NOAEL
of
120
ppm
Based
on
Parental
Body
Weight
Decrements,
Increased
Relative
Thyroid
W
Incidence
of
Thyroid
Follicular
Cell
Hyperplasia
in
a
2­
Generation
Reproductive
Study
on
labaratory
rats
(
Rattus
n
Application
Rate
Chronic
RQ
Chronic
RQ
(
lbs
ai/
A)/

Based
on
Based
on
Number
of
Mean
EECs
Maximum
EECs
Mean
Maximum
Applications/
Site/

(
Mean
EEC/
NOAE
2
(
Max.
EEC/
NOAEL
2
EEC
(
ppm)
1
EEC
(
ppm)
1
Food
Items
Interval
Application
Method
8.2
23.0
979
2,764
Short
grass
2.4/
7
Tomato
3.5
10.6
415
1,267
Tall
grass
7­
day
interval
ground
&
aerial
4.3
13.0
518
1,554
Broadleaf
plants/
Inse
0.7
1.4
81
173
Seeds
2.8
7.9
335
946
Short
grass
1.5/
3a
Vegetables
b
1.2
3.6
142
434
Tall
grass
7­
day
interval
ground
&
aerial
1.5
4.4
177
532
Broadleaf
plants/
Inse
0.2
0.5
28
59
Seeds
5.3
14.9
634
1,791
Short
grass
3.2/
3a
Forestry
(
Douglas
Fir)

2.2
6.8
269
821
Tall
grass
14­
day
interva
ground
&
aerial
2.8
8.4
336
1,008
Broadleaf
plants/
Inse
0.4
0.9
52
112
Seeds
5.3
14.9
634
1,791
Short
grass
3.2/
3a
Ornamental
Trees
c
2.2
6.8
269
821
Tall
grass
14­
day
interva
ground
&
aerial
2.8
8.4
336
1,008
Broadleaf
plants/
Inse
0.4
0.9
52
112
Seeds
3.0
8.4
357
1,009
Short
grass
1.6/
3a
Ornamentals
d
1.3
3.9
151
463
Tall
grass
7­
day
interval
ground
&
aerial
1.6
4.7
189
568
Broadleaf
plants/
Inse
0.2
0.5
29
63
Seeds
34.4
97.2
4,133
11,670
Short
grass
13.9/
5
Ornamentals
14.6
44.6
1,751
5,349
Tall
grass
10­
day
interva
(
pachysandra
groundco
18.2
54.7
2,188
6,564
Broadleaf
plants/
Inse
ground
2.8
6.1
340
729
Seeds
103
104
Table
6
(
continued):
Mammalian
Chronic
Risk
Quotients
for
Multiple
Applications
of
Mancozeb
Nongranular
(
B
NOAEL
of
120
ppm
Based
on
Parental
Body
Weight
Decrements,
Increased
Relative
Thyroid
Incidence
of
Thyroid
Follicular
Cell
Hyperplasia
in
a
2­
Generation
Reproductive
Study
on
labaratory
rats
(
Rattu
Application
Rate
Chronic
RQ
Chronic
RQ
(
lbs
ai/
A)/

Based
on
Based
on
Number
of
Mean
EECs
Maximum
EECs
Mean
Maximum
Applications/
Site/

(
Mean
EEC/
NOAE
2
(
Max.
EEC/
NOAE
2
EEC
(
ppm)
1
EEC
(
ppm1
Food
Items
Interval
Application
Method
33.6
94.9
4,032
11,384
Short
grass
17.4/
3a
Turf
(
golf
course)

14.2
43.5
1,708
5,218
Tall
grass
5­
day
interval
ground
17.8
53.4
2,135
6,404
Broadleaf
plants/
Inse
2.8
5.9
332
712
Seeds
36.7
103.6
4,403
12,431
Short
grass
19/
0/
3a
Turf
e
15.5
47.5
1,865
5,697
Tall
grass
5­
day
interval
ground
&
aerial
19.4
58.3
2,331
6,992
Broadleaf
plants/
Inse
3.0
6.5
363
777
Seeds
1
Assumes
degradation
using
FATE
version
5.0
program
with
a
half­
life
of
35
days.
EFED
uses
this
a
default
value
when
the
foliar
dissipation
for
a
particular
pesticide
i
2
RQ
greater
or
equal
to
1.0
exceeds
chronic
risk
LOCs.

a
Maximum
number
of
applications/
year
or
crop
cycle
not
(
assumed
3
applicatio
b
Beets
(
unspecified),
Broccoli,
Brussel
sprouts,
Cabbage,
Carrots,
Cauliflower,
C
Collards,
Coriander,
Dill,
Endive,
Kale,
Kohlrabi,
Leeks,
Lettuce,
Mustard,
Mus
Parsley,
Parsnip,
Radish,
Rape,
Roquette
(
Arrugula),
Rutabaga,
Spin
c
Christmas
Tree
Plantations
d
Trees,
Herbaceous
Plants,
Non
Flowering
Plants,
&
Woody
Shrubs
e
Commercial/
Industrial,
Sod
Farm
&
Residential
105
iii.
Insects
and
Mites
Currently,
EFED
does
not
assess
risk
to
non­
target
insects
or
mites
using
risk
quotient
methodology.
Results
of
acceptable
studies
are
used
for
recommending
appropriate
label
precautions.
Since
mancozeb
was
determined
to
be
practically
nontoxic
to
honey
bees
(
LD
50
>
179
µ
g/
bee)
no
bee
precautionary
labeling
is
required
on
mancozeb
product
labeling.
A
beneficial
mite
study
(
MRID
No.
45577201)
determined
that
mancozeb's
LR
50
(
residue
concentration
on
foliage
causing
50%
lethality)
for
Typhlodromus
pyri
is
0.1
lb
active
ingredient/
A
and
the
LOAEC
which
can
be
expected
to
cause
adverse
reproductive
effects
is
0.02
lb
active
ingredient/
A
(
lowest
concentration
tested).
The
current
maximum
single
application
rate
for
mancozeb
to
apple
orchards
(
where
Typhlodromus
pyri
is
commonly
found)
is
4.8
lb
active
ingredient/
A
with
a
maximum
of
4
applications
made
per
crop
cycle
at
a
minimum
of
every
7
days.
Based
on
current
registered
mancozeb
application
rates
and
the
toxicity
indicated
from
this
study
it
would
appear
that
adverse
effects
to
Typhlodromus
pyri
from
mancozeb
uses
can
be
expected.

c.
Aquatic
Organisms
i.
Overview
Because
monitoring
data
from
field
locations
are
not
available
for
mancozeb,
EFED
based
the
surface
water
exposure
EECs
of
mancozeb
on
screening
models.
EFED
used
Tier
II
modeling,
the
Pesticide
Root
Zone
Model
version
3.1.2
beta
(
Carsel
and
others.,
1997)
and
Exposure
Analysis
Modeling
System
version
2.98.04
(
Burns,
1997)
(
PRZM/
EXAMS),
to
estimate
aquatic
EECs.

The
PRZM/
EXAMS
modeling
tools
used
by
EFED
are
designed
to
be
conservative
tools;
with
90%
of
simulated
sites
expected
to
have
environmental
concentrations
lower
than
the
Tier
II
estimates.
EFED
uses
environmental
fate
and
transport
computer
models
to
calculate
refined
EECs.
PRZM
simulates
pesticide
surface
water
runoff
on
daily
time
steps,
incorporating
runoff,
infiltration,
erosion,
and
evaporation.
The
model
calculates
foliar
dissipation
and
runoff,
pesticide
uptake
by
plants,
soil
microbial
transformation,
volatilization,
and
soil
dispersion
and
retardation.
EXAMS
simulates
pesticide
fate
and
transport
in
an
aquatic
environment
(
one
hectare
body
of
water,
two
meters
deep
with
no
outlet).
The
EECs
used
in
the
assessment
has
both
an
average
magnitude
and
a
duration
over
which
that
average
magnitude
is
calculated.
Concentration
values
chosen
for
use
in
the
assessment
are
those
that
would
be
expected
to
be
equaled
or
exceeded
only
once
every
ten
years
based
on
the
30­
year
weather
history
at
the
site.
The
Tier
II
model
uses
a
single
site
which
represents
a
high
exposure
scenario
for
the
use
of
the
pesticide
on
a
particular
crop
use
site.
The
model
simulates
weather
and
agricultural
practice
at
the
site
over
multiple
years
so
the
probability
of
an
EEC
occurring
at
that
site
can
be
estimated.
The
PRZM/
EXAMS
modeling
approach
is
an
uncertain
predictor
of
water
concentrations
in
estuarine/
marine
systems.
EFED
suspects,
though
it
hasn't
been
empirically
proved,
that
flushing
and
exchange
rates
within
these
systems
may
differ
from
those
assumed
in
the
existing
surface
water
modeling.
Sometimes,
flushing
and
exchange
may
be
greater
than
accounted
for
in
the
EXAMS
model
and
true
estuarine/
marine
water
concentrations
may
be
lower.
In
other
cases
tidal
entrapment
of
pollutants
may
contribute
to
higher
effective
pesticide
concentrations
than
predicted
by
the
model.
106
Table
9:
Mancozeb
Acute
and
Chronic
Risk
Quotients
for
Freshwater
Fish
Based
On
a
Rainbow
Trout
(
Salmo
gairdneri
)
LC50
of
460
ppb
and
a
Fathead
Minnow
(
Pimephales
promelas
)
NOAEC
of
2.19
ppb.
Application
Rate
(
lbs
ai/
A)/

Number
of
Chronic
RQ
Acute
RQ
EEC
60­
Day
Applications/
Site/

(
60­
Day
EEC/
NOAEC)
3
(
Peak
EEC/
LC50)
2
Average
(
ppb)
1
EEC
Peak
(
ppb)
1
Interval
Application
Method/

1.46
0.16
3.2
73.4
4.8/
4
Apples
7­
day
interval
ground
&
aerial
2.05
0.15
4.5
68.2
1.2/
15
Corn
(
Sweet)

4­
day
interval
ground
&
aerial
1.00
0.10
2.2
46.8
1.6/
7
Potato
5­
day
interval
ground
&
aerial
3.33
0.46
7.3
210.8
2.4/
7
Tomato
7­
day
interval
ground
&
aerial
1.46
0.22
3.2
103.4
1.6/
3
Wheat
7­
day
interval
ground
&
aerial
1
Based
on
PRZM
version
3.12/
EXAMS
version
2.97.5
modeling.
2
RQ
greater
or
equal
to
0.5
exceeds
acute
risk,
acute
restricted
use
and
acute
endangered
species
LOCs.

RQ
greater
or
equal
to
0.1
exceeds
acute
restricted
use
and
acute
endangered
species
LOCs.

RQ
greater
or
equal
to
0.05
exceeds
acute
endangered
species
LOCs.

3
RQ
greater
or
equal
to
1.00
exceeds
chronic
LOC.
EFED
uses
the
EECs
for
assessing
acute
and
chronic
risks
to
aquatic
organisms.
EFED
uses
peak
EEC
values
to
calculate
acute
RQs
for
single
and
multiple
applications
for
all
aquatic
organisms.
EFED
uses
21­
day
EECs
for
invertebrates
and
60­
day
EECs
for
fish
to
calculate
chronic
RQs.

EFED
selected
boundaries
used
Tier
II
(
PRZM/
EXAMS)
modeling
using
Agency
guidance
(
WQTT/
EFED/
OPP.
August,
2000)
and
EFED
calculated
degradation
rate
constants
from
review
of
registrant
filed
environmental
fate
studies.
EFED
provides
summary,
of
the
environmental
fate
limits
used
in
the
model
for
mancozeb
and
the
EECs,
in
section
V­­
Water
Resource
Assessment.

ii.
Freshwater
Fish
Tabulated
below
in
Table
9
are
mancozeb's
acute
and
chronic
risk
quotients
for
freshwater
fish.
The
results
show
that
acute
RQs
exceed
endangered
species
LOCs
for
all
mancozeb
uses
(
acute
RQ
ranges
from
0.1
to
0.46).
The
chronic
RQs
exceed
LOCs
for
freshwater
fish
for
all
mancozeb's
modeled
uses
(
chronic
RQ
ranges
from
1.00
to
3.33).
EFED
modeled
on
representative
mancozeb
uses.
EFED
has
not
developed
PRZM/
EXAMS
schemes
for
modeling
all
mancozeb
uses.
107
Table
10:
Mancozeb
Acute
and
Chronic
Risk
Quotients
for
Freshwater
Invertebrates
Based
On
a
water
flea
(
Daphnia
magna)

EC50
of
580
ppb
and
a
NOAEC
of
7.3
ppb
Application
Rate
(
lbs
ai/
A)/

Number
of
Chronic
RQ
Acute
RQ
EEC
21­
Day
Applications/
Site/

(
21­
Day
EEC/
NOAEC)
3
(
Peak
EEC/
EC50)
2
Average
(
ppb)
1
EEC
Peak
(
ppb)
1
Interval
Application
Method/

0.96
0.13
7.00
73.4
4.8/
4
Apples
7­
day
interval
ground
&
aerial
1.32
0.12
9.60
68.2
1.2/
15
Corn
(
Sweet)

4­
day
interval
ground
&
aerial
0.59
0.08
4.30
46.8
1.6/
7
Potato
5­
day
interval
ground
&
aerial
2.29
0.36
16.70
210.8
2.4/
7
Tomato
7­
day
interval
ground
&
aerial
1.05
0.18
7.7
103.4
1.6/
3
Wheat
7­
day
interval
ground
&
aerial
1
Based
on
PRZM
version
3.12/
EXAMS
version
2.97.5
modeling.
2
RQ
greater
or
equal
to
0.5
exceeds
acute
risk,
acute
restricted
use
and
acute
endangered
species
LOCs.

RQ
greater
or
equal
to
0.1
exceeds
acute
restricted
use
and
acute
endangered
species
LOCs.

RQ
greater
or
equal
to
0.05
exceeds
acute
endangered
species
LOCs.

3
RQ
greater
or
equal
to
1.00
exceeds
chronic
LOC.
iii.
Freshwater
Invertebrates
Tabulated
below
in
Table
10
are
mancozeb's
acute
and
chronic
risk
quotients
for
freshwater
invertebrates.
The
results
show
that
acute
RQs
exceed
endangered
species
LOCs
for
all
mancozeb
uses
(
acute
RQ
ranges
from
0.08
to
0.36).
The
chronic
RQs
exceed
LOCs
for
freshwater
invertebrates
for
mancozeb's
use
on
sweet
corn,
tomatoes,
and
wheat
(
chronic
RQ
ranges
from
1.05
to
2.29).
108
Table
11:
Mancozeb
Acute
Risk
Quotients
for
Estuarine/
Marine
Fish
Based
on
a
Sheepshead
Minnow
(
Cyprinodon
variegatus)
LC50
of
1,600
ppb.
Application
Rate
(
lbs
ai/
A)/

Number
of
Acute
RQ
Applications/
Site/

(
Peak
EEC/
LC50)
2
EEC
Peak
(
ppb)
1
Interval
Application
Method/

0.05
73.4
4.8/
4
Apples
7­
day
interval
ground
&
aerial
0.04
68.2
1.2/
15
Corn
(
Sweet)

4­
day
interval
ground
&
aerial
0.03
46.8
1.6/
7
Potato
5­
day
interval
ground
&
aerial
0.13
210.8
2.4/
7
Tomato
7­
day
interval
ground
&
aerial
0.06
103.4
1.6/
3
Wheat
7­
day
interval
ground
&
aerial
1
Based
on
PRZM
version
3.12/
EXAMS
version
2.97.5
modeling.
2
RQ
greater
or
equal
to
0.5
exceeds
acute
risk,
acute
restricted
use
and
acute
endangered
species
LOCs.

RQ
greater
or
equal
to
0.1
exceeds
acute
restricted
use
and
acute
endangered
species
LOCs.

RQ
greater
or
equal
to
0.05
exceeds
acute
endangered
species
LOCs.
iv.
Estuarine/
Marine
Fish
Tabulated
below
in
Table
11
are
mancozeb's
acute
risk
quotients
for
esturarine/
marine
fish.
The
results
show
that
acute
RQs
exceed
endangered
species
LOCs
for
mancozeb
uses
on
apples,
tomatoes,
and
wheat
(
acute
RQ
ranges
from
0.05
to
0.13).
109
Table
12:
Mancozeb
Acute
Risk
Quotients
for
Estuarine/
Marine
Invertebrates
Based
on
a
Mysid
shrimp
(
Americamysis
bahia
)
EC50
of
10.5
ppb
Application
Rate
(
lbs
ai/
A)/

Number
of
Acute
RQ
Applications/
Site/

(
Peak
EEC/
EC50)
2
EEC
Peak
(
ppb)
1
Interval
Application
Method/

6.99
73.4
4.8/
4
Apples
7­
day
interval
ground
&
aerial
6.50
68.2
1.2/
15
Corn
(
Sweet)

4­
day
interval
ground
&
aerial
4.46
46.8
1.6/
7
Potato
5­
day
interval
ground
&
aerial
20.08
210.8
2.4/
7
Tomato
7­
day
interval
ground
&
aerial
9.85
103.4
1.6/
3
Wheat
7­
day
interval
ground
&
aerial
1
Based
on
PRZM
version
3.12/
EXAMS
version
2.97.5
modeling.
2
RQ
greater
or
equal
to
0.5
exceeds
acute
risk,
acute
restricted
use
and
acute
endangered
species
LOCs.

RQ
greater
or
equal
to
0.1
exceeds
acute
restricted
use
and
acute
endangered
species
LOCs.

RQ
greater
or
equal
to
0.05
exceeds
acute
endangered
species
LOCs.
v.
Estuarine/
Marine
Invertebrates
Tabulated
below
in
Table
12
are
mancozeb's
acute
risk
quotients
for
esturarine/
marine
invertebrates.
The
results
show
that
acute
RQs
exceed
LOCs
for
all
mancozeb
uses
(
acute
RQ
ranges
from
4.46
to
20.08).
There
are
currently
no
estuarine/
marine
invertebrates
listed
as
endangered
species.
110
Table
13:
Acute
Risk
Quotients
for
Aquatic
Non­
Vascular
Plants
Based
Upon
a
Green
Algae(
Selenastrum
capricornutum)
EC50
of
47.0
ppb
Application
Rate
(
lbs
ai/
A)/

Number
of
Non­
Target
Plant
Applications/
Site/
RQ
(
EEC/
EC50)
3
EEC
Peak
(
ppb)
1
Interval
Application
Method/

1.56
73.4
4.8/
4
Apples
7­
day
interval
ground
&
aerial
1.45
68.2
1.2/
15
Corn
(
Sweet)

4­
day
interval
ground
&
aerial
1.00
46.8
1.6/
7
Potato
5­
day
interval
ground
&
aerial
4.49
210.8
2.4/
7
Tomato
7­
day
interval
ground
&
aerial
2.20
103.4
1.6/
3
Wheat
7­
day
interval
ground
&
aerial
1
Based
on
PRZM
version
3.12/
EXAMS
version
2.97.5
modeling.

2
RQ
greater
or
equal
to
1.0
exceeds
acute
risk
LOCs.
d.
Exposure
and
Risk
to
Non­
target
Plants:
Aquatic
Plants
Exposure
to
non­
target
aquatic
plants
may
occur
through
runoff
or
spray
drift
from
adjacent
treated
sites
or
directly
from
such
uses
as
aquatic
weed
or
mosquito
larvae
control.
EFED
assesses
an
aquatic
vascular
plant
risk
for
acute
risk
from
the
surrogate
duckweed
Lemna
gibba.
EFED
makes
nonvascular
aquatic
plant
acute
risk
assessments
using
either
algae
or
a
diatom,
whichever
is
the
most
sensitive
species.
So
far,
there
are
no
known
nonvascular
plant
species
on
the
endangered
species
list.
Runoff
and
drift
exposure
is
computed
from
PRZM/
EXAMS.
EFED
calculates
the
risk
quotient
by
dividing
the
pesticide's
initial
or
peak
concentration
in
water
by
the
plant
EC
50
value.

Shown
in
Table
13
are
the
acute
risk
quotients
for
freshwater,
nonvascular
green
alga
(
Selenastrum
capricornutum).
Mancozeb's
use
patterns
on
all
modeled
uses
exceed
acute
risk
LOCs
for
nonvascular
aquatic
plants
(
acute
RQ
ranges
from
1.00
to
4.49).
111
e.
Endangered
Species
Based
on
available
screening
level
information,
there
is
a
potential
concern
for
mancozeb's
acute
and
chronic
effects
on
listed
Endangered
and
Threatened
species
of
freshwater
animals,
acute
effects
on
listed
estuarine/
marine
fish,
and
chronic
effects
on
listed
birds
and
mammals
should
exposure
actually
occur.
EFED
is
uncertain
about
mancozeb's
risk
to
endangered/
threatened
non­
target
terrestrial
plants
and
needs
testing
performed
at
mancozeb's
maximum
rate
of
application
in
the
environment.
There
are
no
nonvascular
aquatic
plant
or
estuarine/
marine
invertebrate
species
on
the
endangered
species
list.

f.
Ecological
Incidents
The
Ecological
Incident
Information
System
(
EIIS)
(
see
Appendix
V
for
background
information)
showed
that
mancozeb
was
reported
in
three
fish
kill
incidents.
One
incident
occurred
in
1970,
another
in
1992
and
the
latest
occurred
in
1995.
In
the
1970
and
1992
incidents,
mancozeb
had
been
applied
with
an
insecticide
highly
toxic
to
fish
and,
because
of
sample
analysis,
EFED
classified
mancozeb
as
unlikely
to
have
been
responsible
for
the
these
fish
kills.
The
third
incident
in
1995
involved
a
mancozeb
accidental
spill
into
a
stream
that
was
the
source
water
for
a
salmon
hatchery
which
resulted
in
a
fish
kill
at
the
salmon
hatchery.
Although
no
samples
were
analyzed
(
fish
or
water),
EFED
classed
mancozeb
to
be
a
probable
contributory
cause
to
the
kill.
A
fourth
incident
involved
mancozeb
in
a
1992
bird
kill
on
an
island
near
France.
In
this
case,
mancozeb
had
been
applied
with
an
insecticide
(
methomyl)
highly
toxic
to
birds.
The
insecticide
was
confirmed
through
sampling
and
mancozeb
was
classified
as
a
possible
contributory
reason
for
the
bird
kill.
The
acute
toxicity
data
provided
in
this
document
for
birds
shows
mancozeb
is
slightly
to
practically
nontoxic
to
birds
(
oral
LD
50
~
1500
mg/
kg
for
the
sparrow
and
>
6400
mg/
kg
for
the
duck
and
quail).
Methomyl
is
highly
toxic
to
birds
[
acute
oral
LD
50
=
15.9
mg/
kg
(
US
EPA.
1998)].
It
is
unlikely
mancozeb
contributed
to
this
bird
kill
and
more
likely
methomyl
caused
the
kill.
A
fifth,
and
final
incident,
reported
that
mancozeb
tanked
mixed
with
benomyl
and
applied
to
apple
trees
may
have
caused
leaves
and
blossoms
to
drop
from
the
trees.
According
to
the
registrant,
identical
applications
made
by
other
growers
in
the
area
to
apple
orchards
did
not
result
in
this
damage
and
EFED
classed
mancozeb
as
a
possible
contributory
cause
of
the
damage.
112
Mancozeb
Incidents
from
EIIS
Incident
Number
Pesticide(
s)
Involved
Date
(
month/
year)
Adverse
Effect
Magnitude
of
Damage
B0000­
501­
42
mancozeb
&
benomyl
unknown
Plant
damage
not
reported
B0000­
233
mancozeb,
sulfur,
&
thiodan
7/
1970
Fish
kill
thousands
I006382­
002
mancozeb
&
methomyl
9/
1972
Bird
kill
­
35
birds
killed
­
31
intoxicated
­
involved
green
finches,
gold
finches,
and
linnets
I000799­
008
mancozeb,
maneb,
fenarimol,
&
endosulfan
4/
1992
Fish
kill
>
600
fish
I008745­
004
mancozeb
7/
1995
Fish
kill
30,000
to
35,000
fish
113
APPENDIX
V:
US
EPA
Ecological
Incident
Information
System
The
Office
of
Pesticide
Programs
(
OPP)
has
tracked
incidents
reports,
given
to
EPA
since
about
1994,
by
assigning
identification
number
in
an
Incident
Data
System
(
IDS)
and
microfiching
the
reports.
The
Environmental
Fate
and
Effects
Division
(
EFED)
then
enters
the
ecological
related
incident
reports
into
a
second
database,
the
Ecological
Incident
Information
System
(
EIIS).
This
second
database
has
some
85
fields
for
potential
data
entry.
EFED
has
also
made
an
effort
to
enter
information
into
EIIS
on
incident
reports
received
before
establishment
of
current
databases.
Although
EFED
has
added
many
of
these
reports,
EIIS
does
not
yet
provide
a
listing
of
all
incident
reports
received
by
EPA.
OPP
does
not
receive
incident
reports
in
a
consistent
format.
For
example,
states
and
various
labs
usually
have
their
own
report
formats.
The
incidents
reports
may
involve
multiple
incidents
involving
multiple
chemicals
in
one
report,
and
may
report
on
only
part
of
an
incident
investigation
(
for
example,
residues).
EFED
has
made
some
progress
in
recent
years,
both
in
getting
incident
reports
sent
and
entered.
However,
there
has
never
been
enough
staff
time
and
effort
assigned
to
recording
incidents.
For
example,
the
staff
time
and
effort
assigned
to
tracking
and
reviewing
laboratory
toxicity
studies
are
greater
than
those
assigned
to
tracking
incidents.

EFED
classifies
EIIS
entered
incidents
into
one
of
several
certainty
levels:
highly
probable,
probable,
possible,
unlikely,
or
unrelated.
In
brief,
"
highly
probable"
incidents
usually
need
carcass
residues,
show
large
cholinesterase
inhibition
(
for
chemicals
such
as
organophosphates
that
depress
brain
and
blood
cholinesterase),
or
clear
circumstances
about
the
exposure.
"
Probable"
incidents
include
those
where
residues
were
not
available
or
circumstances
were
less
clear
than
for
"
highly
probable."
"
Possible"
incidents
include
those
where
multiple
chemicals
may
have
been
involved
and
it
is
not
clear
what
the
contribution
was
of
a
given
chemical.
OPP
uses
the
"
unlikely"
category,
for
example,
where
a
given
chemical
is
almost
nontoxic
to
the
category
of
organism
killed
or
the
chemical
was
tested
for
but
not
detected
in
samples.
"
Unrelated"
incidents
are
those
that
OPP
confirms
was
not
pesticiderelated

EFED
also
classes
EIIS
entered
incidents
as
use
or
misuse.
Unless
specifically
confirmed
by
a
state
or
federal
agency
to
be
misuse,
or
there
was
clear
misuse
such
as
intentional
baiting
to
kill
wildlife,
EFED
would
not
typically
consider
incidents
to
be
misuse.
For
example,
data
entry
personnel
often
do
not
have
a
copy
of
the
specific
label
used
in
a
given
application,
and
would
not
usually
be
able
to
detect
various
label­
specific
violations.

EFED
believes
the
number
pesticide
related
incidents
reported
in
EIIS,
while
large,
are
a
small
fraction
of
pesticide
incidents.
EIIS
entered
incidents
requires
that
mortality
incidents
be
seen,
reported,
examined,
and
have
investigation
reports
sent
to
EPA.
Incidents
often
are
not
seen,
because
of
scavenger
removal
of
carcasses,
decay
in
a
field,
or
simply
because
carcasses
may
be
hard
to
see
on
many
sites.
Poisoned
wildlife
may
also
move
off­
site
to
less
visible
areas
before
dying.
Incidents
often
are
not
seen
because
few
people
are
systematically
looking.
Finders,
seeing
incidents,
may
not
report
incidents
to
suitable
authorities
to
examine
the
incident.
The
finder
may
not
know
that
it
is
important
to
report
incidents
or
may
not
know
who
to
contact.
He
or
she
may
not
feel
they
have
the
time
or
wish
to
make
a
telephone
call,
may
hesitate
to
call
because
of
their
own
involvement
in
the
kill,
or
the
call
may
be
long­
distance
which
may
discourage
the
caller.
Incidents
reported
may
not
get
examined
if
time
or
people
are
limited
or
may
not
get
examined
thoroughly,
with
residue
and
cholinesterase
analyzes,
for
example.
Also,
if
kills
are
not
reported
and
examined
at
once,
there
will
be
little
chance
of
documenting
the
cause,
since
tissues
and
residues
may
decay
quickly.
States
often
do
not
send
reports
of
examined
incidents
to
EPA,
since
reporting
by
states
is
voluntary
and
some
investigators
may
believe
that
they
don't
have
the
time
or
people
to
send
incident
reports
to
EPA.
(
Felkel.
2000)
114
APPENDIX
VI:
EBDC
Aquatic
Studies
EBDC
Aquatic
Studies
Used
for
Calculating
Risk
Quotients
With
Associated
Study
Parameters
­
3/
13/
2003
MRID
No.
Chemical
Species
Tested
Water
type
Water
Analysis
(
cations,
anions,

EC)
Test
Type1
Nominal
Test
Concentrations
Range
(
ppm)
Measured
(
unfiltered)

Test
Concentrations
Range
(
ppm)
Measured
(
filtered)

Test
Concentrations
Range
(
ppm)
and
Filter
Size
(
µ
m)
Test
Aquaria
Size
(
L)
Chemical
Analyses
(
Parent
or
Other?)
Toxicity
Endpoint
(
ppm)
Exposure
Time
(
hours)
Study
Categorization
43525001
metiram
Rainbow
trout
freshwater
mixture
of
tap
water,
unchlorinated
water,
deionized
water
(
chemical
analysis
­
not
reported)
F
0.01
­
1.0
ND2
­
0.527
ND2
­
0.233
filter
size
=

0.05
60
GC3
for
CS
2
LC
50
=

0.2294
96
core
44301101
metiram
water
flea
freshwater
deionized
water,

EDTA
free,
and
HCL
fortified
samples
for
analysis
S
0.1
­
1.0
0.051
­
0.511
Not
applicable
0.25
GC3
for
CS
2
EC
50
>

0.3586
(
highest
concentr
a­
tion
tested)
48
supplemental
43199601
metiram
green
algae
freshwater
Na
2
EDTA
S
0.001
­

1.0
Not
applicable
Not
applicable
0.1
Not
applicable
EC
50
=

0.0775
72
supplemental
40706001
maneb
Rainbow
trout
freshwater
softwater
and
well
water
(
chemical
analysis
­
not
reported)
S
0.08
­
1.0
0.009
­
0.225
Not
applicable
30
GC3
for
CS
2
LC
50
=
0.04166
96
supplemental
41346301
maneb
fathead
minnow
freshwater
EDTA
F
0.0013
­

0.020
0.00096
­

0.012
Not
applicable
11.5
GC3
for
CS
2
NOAEC
=
0.00616
35
days
core
EBDC
Aquatic
Studies
Used
for
Calculating
Risk
Quotients
With
Associated
Study
Parameters
­
3/
13/
2003
MRID
No.
Chemical
Species
Tested
Water
type
Water
Analysis
(
cations,
anions,

EC)
Test
Type1
Nominal
Test
Concentrations
Range
(
ppm)
Measured
(
unfiltered)

Test
Concentrations
Range
(
ppm)
Measured
(
filtered)

Test
Concentrations
Range
(
ppm)
and
Filter
Size
(
µ
m)
Test
Aquaria
Size
(
L)
Chemical
Analyses
(
Parent
or
Other?)
Toxicity
Endpoint
(
ppm)
Exposure
Time
(
hours)
Study
Categorization
115
40749402
maneb
water
flea
freshwater
softwater
and
well
water
S
0.08
­
1.0
ND2
­
0.39
Not
applicable
0.1
GC3
for
CS
2
LC
50
=

0.126
48
core
40943101
maneb
Atlantic
silverside
Estuari
ne/
mar
ine
filtered
(
0.5
µ
m)

seawater
(
salinity
~
20%)

&
EDTA
F
0.12
­
1.5
ND2
­
1.10
Not
applicable
9
GC3
for
CS
2
LC
50
=

0.186
96
core
41000002
maneb
mysid
shrimp
Estuari
ne/
mar
ine
filtered
(
0.5
µ
m)

seawater
(
salinity
~
20%)

&
EDTA
F
0.005
­

0.060
ND2
­
0.0064
Not
applicable
6.4
GC3
for
CS
2
LC
50
=

0.0036
96
supplemental
40943501
maneb
green
algae
freshwater
Na
2
EDTA
S
0.0026
­

0.040
0.0004
­

0.0067
Not
applicable
0.25
GC3
for
CS
2
EC
50
=
0.01348
120
core
40118502
mancozeb
Rainbow
trout
freshwater
Not
reported
S
0.22
­
4.5
Not
applicable
Not
applicable
Not
reported
Not
applicable
LC
50
=

0.465
96
core9
43230701
mancozeb
fathead
minnow
freshwater
EDTA
added
F
0.0003
­

0.02
0.000236
­

0.01910
ND2
­
0.007973
Not
applicable
~
12.2
GC3
for
CS
2
&

LSC10
for
14C
NOAEC
=
0.002196
for
GC
&

0.00237
for
LSC
28
days
core
40118503
mancozeb
water
flea
freshwater
Not
reported
S
0.026
­

2.0
Not
applicable
Not
applicable
Not
reported
Not
applicable
EC
50
=

0.585
48
core9
EBDC
Aquatic
Studies
Used
for
Calculating
Risk
Quotients
With
Associated
Study
Parameters
­
3/
13/
2003
MRID
No.
Chemical
Species
Tested
Water
type
Water
Analysis
(
cations,
anions,

EC)
Test
Type1
Nominal
Test
Concentrations
Range
(
ppm)
Measured
(
unfiltered)

Test
Concentrations
Range
(
ppm)
Measured
(
filtered)

Test
Concentrations
Range
(
ppm)
and
Filter
Size
(
µ
m)
Test
Aquaria
Size
(
L)
Chemical
Analyses
(
Parent
or
Other?)
Toxicity
Endpoint
(
ppm)
Exposure
Time
(
hours)
Study
Categorization
116
mancozeb
water
flea
freshwater
EDTA
added
F
0.003
­

0.05
0.0029
­

0.053
Not
applicable
1.0
GC3
for
CS
2
&

LSC10
for
14C
NOAEC
=
0.00736
for
LSC
21
days
core
41844901
mancozeb
sheepshead
minnow
Estuari
ne/
mar
ine
filtered
seawater
with
well
water
(
salinity
~
20%)

Na
3
EDTA
added
F
0.6
­
7.7
0.28
­
3.7
Not
applicable
9
GC3
for
CS
2
LC
50
=

1.66
96
supplemental
41822901
mancozeb
mysid
shrimp
Estuari
ne/
mar
ine
filtered
seawater
with
well
water
(
salinity
~
20%)

Na
3
EDTA
added
F
0.003
­

0.04
0.0034
­

0.017
Not
applicable
6
GC3
for
CS
2
LC
50
=
0.01056
96
supplemental
43664701
mancozeb
green
algae
freshwater
Na
2
EDTA
S
0.033
­

0.50
0.022
­
0.376
Not
applicable
0.1
GC3
for
CS
2
EC
50
=

0.047
120
core
1.
For
aquatic
organisms
(
fish,
zooplankton,
and
phytoplankton),
tests
are
carried
out
using
either
static
(
S)
or
flow­
through
(
F)
methods.
In
the
static
method,
the
pesticide
and
test
organisms
are
added
to
the
test
solution
and
kept
there
for
the
remainder
of
the
study
time.
In
the
flow­
through
method,
a
freshly
prepared,
pesticide­
spiked
test
solution
flows
through
the
test
chamber
continuously
for
the
duration
of
the
test.
The
flow­
through
method
provides
a
higher
continuous
dose
of
the
pesticide;
however,
the
static
method
does
not
remove
waste
products
and
may
accumulate
toxic
pesticide
breakdown
products
and
metabolites.
Neither
method
exactly
mimics
a
natural
system.
(
http://
docs.
pesticideinfo.
org/
documentation4/
ref_
ecotoxicity4.
html
)
Flow­
through
system
allows
the
testing
of
volatile
and
instable
chemicals,
problematic
in
static
test
systems.

2.
None
detected
3.
Gas
chromatography
EBDC
Aquatic
Studies
Used
for
Calculating
Risk
Quotients
With
Associated
Study
Parameters
­
3/
13/
2003
MRID
No.
Chemical
Species
Tested
Water
type
Water
Analysis
(
cations,
anions,

EC)
Test
Type1
Nominal
Test
Concentrations
Range
(
ppm)
Measured
(
unfiltered)

Test
Concentrations
Range
(
ppm)
Measured
(
filtered)

Test
Concentrations
Range
(
ppm)
and
Filter
Size
(
µ
m)
Test
Aquaria
Size
(
L)
Chemical
Analyses
(
Parent
or
Other?)
Toxicity
Endpoint
(
ppm)
Exposure
Time
(
hours)
Study
Categorization
117
4.
Based
on
filtered
and
measured
concentration.

5.
Based
on
nominal
concentration.

6.
Based
on
measured
(
unfiltered)
concentration.

7.
Measured
estimate
is
based
on
15%
of
nominal
test
concentrations
remaining
at
end
of
test.
No
actual
values
were
provided
in
DER
and
the
limits
of
detection
at
lower
values
is
questionable.
Measured
EC
50
was
based
on
actual
mean
green
algae
cell
counts
at
end
of
study.
Aquatic
plant
studies
base
the
test
concentrations
on
the
0­
hour
concentrations
because
the
plants
will
take­
up
test
material
during
the
study
period
and
loss
of
test
material
is
not
necessarily
due
to
instability
of
test
material.

8.
Based
on
actual
cell
counts,
not
on
measured
concentration
levels.

9.
Categorization
based
on
acceptance
in
1987
Mancozeb
Standard
10.
LSC
detection.
The
process
by
which
radioactive
decay
energy
is
converted
to
visible
light
and
measured
in
an
organic
liquid
environment
is
called
LIQUID
SCINTILLATION
COUNTING
(
LSC).
In
Liquid
Scintillation
Counting,
the
amount
of
light
produced
is
proportional
to
the
amount
of
radiation
present
in
the
sample
and
the
energy
of
the
light
produced
is
proportional
to
the
energy
of
the
radiation
that
is
present
in
he
sample.
This
makes
LSC
a
very
convenient
tool
to
measure
radioactivity.
http://
www.
sfu.
ca/~
rsafety/
APPEND9.
pdf
118
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