UNITED
STATES
ENVIRONMENTAL
PROTECTION
AGENCY
WASHINGTON,
D.
C.
20460
OFFICE
OF
PREVENTION,
PESTICIDES
AND
TOXIC
SUBSTANCES
PC
Code
No.:
600016
DP
Barcode:
D
305124
Date:
June
21,
2005
SUBJECT:
Environmental
Fate
and
Ecological
Risk
Assessment
for
Ethylenethiourea
(
ETU)
a
Common
Degradate
of
the
Ethylenebisdithiocarbamate
Fungicides
(
EBDCs):
Metiram,
Mancozeb,
and
Maneb.
A
Part
of
EFED
Section
4
Reregistration
for
EBDCs
for
Use
in
Crops,
Some
Forestry
Trees,
Ornamental
Plantings,
Seed
Treatment,
and
Turf;
to
Control
a
Wide
Range
of
Fungi
(
Phase
3
Response).

TO:
Michael
Goodis,
Branch
Chief
Tawanda
Spears,
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.
ETU
is
a
common
degradate
of
the
EBDC
fungicides
metiram,
mancozeb
and
maneb.
This
document
should
be
considered
as
an
integral
part
of
the
REDs
for
the
three
EBDCs.

The
following
is
an
overview
of
our
findings:

Risk
to
Terrestrial
and
Aquatic
Organisms
EFED
chose
mancozeb's
use
patterns
to
estimate
ETU's
exposure
and
potential
risk.
EFED
didn't
estimate
ETU
exposure
or
potential
risk
from
metiram's
or
maneb's
uses.
EFED
expects
the
ETU
exposure
and
potential
risk
estimates
from
metiram's
and
maneb's
uses
would
be
comparable
to
mancozeb's
since
comparable
applications
patterns
are
used
for
all
3
EBDCs.
EFED
chose
mancozeb's
uses
because
the
use
pattern
is
broad
(
that
is,
many
application
sites)
thus
providing
a
comprehensive
view
of
the
potential
risks
posed
by
ETU.
EFED
expected
extra
modeling
and
Risk
1
Lethal
condition
in
which
the
skull
is
defective
with
the
brain
exposed
or
extruding.

2
Quotients
(
RQs)
calculations
for
metiram
and
maneb
would
be
repetitive
further
confirming
ETU's
potential
risks.

Mammalian
ETU
RQs
exceed
the
chronic
Level
of
Concern
(
LOC)
for
all
mancozeb's
use
patterns.
ETU
effects
triggering
this
potential
chronic
risk
were
based
on
developmental
defects
of
the
brain
(
that
is,
exencephaly1,
dilated
ventricles,
and
hypoplastic
cerebellum)
in
rats.
For
small
mammals
(
15­
gram)
feeding
on
short
grass,
ETU's
chronic
RQs
range
from
a
high
of
37
from
mancozeb
turf
applications
to
2
from
mancozeb
citrus
applications.
For
small
mammals
feeding
on
forage
and
small
insects,
the
chronic
RQs
range
from
a
high
of
21
from
mancozeb
turf
applications
to
2
from
mancozeb
vegetable
applications.
The
ETU
potential
chronic
risk
to
small
mammalian
herbivoreinsectivores
from
mancozeb's
use
on
citrus,
only,
is
below
chronic
LOCs.

For
medium
sized
mammals
(
35­
gram)
feeding
on
short
grass,
ETU's
chronic
RQ
range
from
26
for
turf
applications
of
mancozeb
to
1
on
citrus.
For
medium
sized
mammals
feeding
on
forage
and
small
insects,
ETU's
potential
chronic
risk
are
exceeded
for
all
mancozeb's
uses
except
mancozeb's
uses
on
citrus.
For
medium
sized
mammals
feeding
on
forage
and
small
insects,
the
RQs
exceeding
the
chronic
LOC
range
from
14
for
turf
applications
of
mancozeb
to
1
on
vegetables.

For
large
mammals
(
1,000
gram)
feeding
on
short
grass,
the
RQs
range
from
6
on
turf
to
1
on
bananas.
There
are
no
ETU
chronic
LOC
exceedances
to
large
mammals
from
mancozeb's
use
on
potato
&
sugar
beet,
fennel,
peanuts,
forestry
(
douglas
fir),
Christmas
tree
plantations,
tobacco,
cotton,
asparagus,
garlic
&
shallot,
ornamentals,
the
barley
crop
grouping.,
vegetables
or
citrus.
For
large
mammals
feeding
on
forage
and
small
insects,
ETU's
chronic
risk
are
exceeded
for
mancozeb's
uses
on
apples,
papaya,
pachysandra
groundcover,
and
turf
(
chronic
RQ
range
1
on
apples
to
3
on
turf),
only.

For
granivore
mammals
(
all
sizes),
no
ETU
chronic
LOC
from
mancozeb's
uses
was
exceeded.

EFED
does
not
expect
acute
risk
to
mammals
from
ETU
exposure.
Acutely,
ETU
is
practically
nontoxic
(
mouse
acute
oral
LD
50
=
2,300
mg/
kg)
to
mammals
and
EFED
has
not
documented
any
adverse
ETU
effects
from
field
incidents
to
mammals.
EFED
does
not
have
any
acute,
subacute
or
chronic
toxicity
data
to
evaluate
ETU's
toxicity
to
birds.

In
aquatic
habitats,
RQs
are
below
LOCs
for
ETU's
acute
risk
to
freshwater
fish,
freshwater
invertebrates,
and
nonvascular
aquatic
plants
from
mancozeb's
uses.
EFED
has
no
data
to
evaluate
ETU's
acute
risks
to
estuarine/
marine
fish
and
invertebrates.
EFED
has
no
data
to
evaluate
ETU's
acute
risks
to
vascular
aquatic
plants.
EFED
is
reserving
the
need
for
chronic
toxicity
testing
on
freshwater
and
estuarine­
marine
animals
until
EFED
receives
and
reviews
acute
toxicity
studies
for
all
the
surrogate
freshwater
and
estuarine­
marine
organisms.
EFED
does
not
evaluate
the
chronic
risk
to
aquatic
plants
because
EFED
hasn't
developed
methods
to
assess
chronic
risk
to
plants.
2
In
this
document
three
important
abbreviations
are
used:
Parent
EBDCs,
EBDCs
complex
and
Bound
species.
Parent
EBDCs
are
the
polymeric
EBDC
parents
(
metiram,
mancozeb
and
maneb)
present
in
the
active
ingredients
of
all
of
the
EBDCs
fungicides.
EBDCs
Complex
are
suites
of
multi
species
complex
resulting
from
degradation
of
the
polymeric
EBDC
parents
(
metiram,
mancozeb
and
maneb).
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).

3
Risks
to
Endangered
Species
Based
on
available
screening
level
information
there
is
a
potential
concern
for
chronic
ETU
effects
on
listed
mammals
should
exposure
actually
occur.
Chronic
ETU
RQs
exceed
LOCs
for
endangered
and
threatened
species
of
mammals.
The
Agency
does
not
currently
have
data
on
which
to
evaluate
the
toxicity
of
ETU
to
endangered
or
threatened
birds,
estuarine/
marine
fish,
or
aquatic
vascular
plants.
Thus,
risks
to
endangered
or
threatened
species
of
birds,
estuarine/
marine
fish,
or
aquatic
vascular
plants
from
ETU
exposure
is
uncertain.
EFED
is
requiring
the
data
to
assess
the
potential
risk
to
endangered
or
threatened
species
of
birds,
estuarine/
marine
fish,
and
aquatic
vascular
plants
through
this
document.
EFED
is
reserving
the
terrestrial
plant
ETU
data
needs
until
EFED
receives
and
completes
review
of
the
parent
EBDC's
toxicity
to
terrestrial
plants.

Risk
to
the
Water
Resources
The
unified
conceptual
model
for
EBDCs
suggests
that
ETU
is
produced
in
the
soil
system
from
applied
parents
through
two
main
processes,
namely:
initial
rapid
hydrolysis
of
the
applied
parent
EBDCs
2and
the
slow/
continuous
aerobic
soil
bio­
degradation
of
the
significant
absorbed
part
of
the
EBDCs
complex.
ETU
produced
in
the
soil
system
is
highly
vulnerable
to
bio­
degradations
but
its
high
water
solubility
and
mobility
can
give
it,
at
least
in
part,
the
potential
to
leach
to
groundwater
(
GW)
at
low
concentrations.
In
surfacewater
(
SW),
the
main
sources
of
ETU
are:
transportation
in
dissolved
run­
off,
formation
from
the
initial
rapid
hydrolysis
of
parent
EBDCs
deposited
by
drift
and
formation
from
the
soil
associated
bound
species
transported
on
soil
particles
by
runoff
and/
or
erosion.
Quantities
of
ETU
that
reach
or
form
in
natural
SW
are
expected
to
be
stable
to
hydrolysis/
direct
photolysis,
however,
it
was
reported
that
it
can
be
removed
rather
quickly
from
these
waters
by
indirect
photolysis
(
half­
lives
of
1­
4
days).

EDWCs
for
ETU,
the
EBDCs
common
degradate,
were
based
on
a
combined
monitoring
and
modeling
approach.
For
surface
water,
an
EDWC/
ETU
value
of
0.1
ppb
was
assigned
to
both
chronic/
non­
cancer
and
the
chronic/
cancer
values
and
was
based
on
a
2­
year
targeted
monitoring
study
conducted
by
the
EBDC
Task
Force
(
MRID
46145401).
The
targeted
surface
water
monitoring
study
provided
the
chronic
values
and
a
lower
bound
for
the
acute
drinking
water
exposure
estimate.
No
concentration
values
above
the
ETU
limit
of
detection
of
0.1
ppb
were
found
in
this
study.
Acute
peak
values
over
the
0.1
ppb
could
have
been
missed
as
a
result
of
the
14­
day
sampling
intervals.
Therefore,
modeling
was
necessary
to
estimate
these
values
in
order
to
assign
a
maximum
over
the
0.1
ppb
and
arrive
at
an
acute
range.
This
range
of
acute
EDWCs
was
established
with
the
lower
limit
of
0.1
ppb
(
based
on
monitoring)
and
an
upper
limit
of
25.2
ppb
4
(
based
on
environmental
fate
and
transport
simulation
modeling
using
the
linked
EPA
PRZM
and
EXAMS
models).
The
highest
value
in
this
national
level
range
can
be
reduced,
at
the
regional
level,
to
13.9
ppb.

The
assigned
acute
maximum
value
at
both
the
national
and
regional
levels
were
based
on
the
currently
approved
version
of
PRZM
which
is
only
capable
of
simulating
pesticide
metabolites
through
such
simplified
assumption
giving
a
relatively
high
uncertainty.
It
is
noted
that
the
assigned
acute
maximum
values
(
25.2
and
13.9
ppb)
could
be
as
low
as
2
and
1
ppb,
respectively
when
they
are
corrected
proportionally;
based
on
the
assumption
that
PRZM/
EXAMS
acute
estimates
can
be
corrected
so
that
the
maximum
chronic
value
for
monitored
sites
is
equal
to
0.1
ppb.

EDWC
of
0.21
ppb
was
assigned
to
ground
water
(
based
on
a
the
targeted
monitoring
study).
This
value
of
0.21
ppb
was
the
highest
measured
value
in
a
public
drinking
water
well
located
in
Lee
County,
Florida.
In
rural
areas,
the
highest
value
measured
by
the
EBDC
Task
Force
was
0.57
ppb
and
was
for
ground
water
from
a
private
well
near
an
EBDC
treated
field
in
an
apple
growing
region
of
New
York.
ETU
concentrations
in
the
range
of
0.1
to
0.25
ppb
were
also
measured
in
8
out
of
125
rural
wells.
Therefore,
exposure
to
higher
ETU
concentrations
(
over
the
assigned
0.21
ppb)
may
occur
in
localities
using
ground
water
wells
located
in
proximity
or
at
areas
with
heavy
use
of
the
EBDC
fungicides.

It
is
important
to
note
that
the
assigned
ETU/
EDWCs
represent
upper­
bound
conservative
estimates
of
the
total
ETU
residual
concentrations
that
might
be
found
in
drinking
water
derived
from
either
surface
water
and
groundwater
sources
due
to
the
use
of
the
EBDC
fungicides.
Additionally,
ETU
was
not
detected
in
any
of
the
treated
surface/
ground
water
community
drinking
water
even
when
it
was
detected
in
the
raw
water
(
this
was
the
case
for
only
four
samples
from
two
community
ground
water
wells
in
Florida).
The
registrant
claims
that
the
absence
of
ETU
in
potable
water
from
community
water
supplies
is
related
to
its
rapid
degradation
resulting
from
aeration
and
chemical
treatment
(
i.
e.
chlorination).
In
contrast,
home
filters
containing
stages
for
water
softening
and
particulate
removal
were
reported
to
be
ineffective
at
removing
ETU
from
rural
well
water
in
at
least
two
sites.

Uncertainties
Uncertainty
exists
in
the
results
of
some
laboratory
and
field
studies
conducted
with
ETU
as
the
test
substance
or
when
it
was
quantified
in
studies
conducted
with
parent
EBDCs.
With
the
exception
of
the
targeted
water
monitoring
study
(
LOQ=
0.10
ppb),
the
analytical
methods
for
determining
unlabeled
ETU
concentrations
were
not
sensitive
(
LOQ=
0.01
ppm).
Quantification
of
ETU
in
parent
EBDCs
laboratory
studies
was
also
affected
by
the
problems
identified
in
these
studies.
Relevant
RED
chapters
for
EBDCs
contains
details
about
these
problems
and
the
reader
is
referred
to
these
REDs.
Identification
and
quantification
of
ETU
degradation
products
were
not
complete;
except
for
EU
(
ethyleneurea).
Therefore,
uncertainty
exists
on
conclusions
related
to
the
assignment
of
degradation
products
to
either
parent
EBDCs
or
ETU
or
both.

Estimated
environmental
concentrations
(
EECs)
in
terrestrial
and
aquatic
systems
were
calculated
by
5
modeling
relevant
quantities
of
ETU.
For
terrestrial
exposure,
EFED
used
a
conversion
rate
(
from
parent­
EBDCs
to
ETU)
of
1.6
%,
9.6%
for
aerobic
soil
systems
and
23.6%
for
water/
sediment
systems.
For
the
terrestrial
systems,
the
conversion
rate
of
parent
to
ETU
on
foliage
is
not
known,
however,
the
day
after
treatment
dislodgeable
foliar
residue
data
EFED
received
from
HED
showed
a
maximum
1.6%
conversion
of
mancozeb
to
ETU
(
see
Table
II­
2)
on
treated
plants
immediately
after
application..
The
HED
studies
provided
mancozeb
to
ETU
conversion
information
on
3
crops
whereas
mancozeb
is
used
on
more
than
20
different
crop
groupings.
Based
on
this
data,
though
limited,
EFED
feels
it
is
reasonable
to
use
a
1.6%
foliar
conversion
rate
of
mancozeb
to
ETU
as
a
conservative
upper­
bound
estimate
in
this
screening
level
assessment.
For
the
soil
and
water/
sediment
systems,
the
conversion
rates,
on
concentration
basis,
were
derived
from
the
maximum
found
in
the
laboratory
studies,
higher
or
lower
conversion
rates
may
occur
in
the
natural
environment
depending
on
the
characteristics
of
the
systems
(
e.
g.
availability
of
moisture
and
biological
activity).
This
is
considered
as
an
uncertainty
along
with
the
assumption
that
conversion
to
ETU
occurs
at
application.
In
this
respect,
it
is
noted
that
the
maximum
ETU
attained
in
the
natural
environment
is
a
result
of
two
major
processes
formation
and
degradation.
This
maximum
is
expected
to
occur
shortly
after
the
parent
reaches
the
aquatic
system
by
drift
and
much
longer
after
foliar
applied
parent
reaches
the
soil
system.

ETU's
effects
on
some
terrestrial
and
aquatic
organisms
is
uncertain.
EFED
was
unable
to
assess
the
acute
or
chronic
ETU
risk
to
birds.
EFED
was
also
unable
to
assess
the
acute
and
chronic
risks
to
estuarine/
marine
fish
and
invertebrates,
the
chronic
risks
to
freshwater
fish,
or
acute
risks
to
aquatic
vascular
plants.
EFED
was
unable
to
assess
these
risks
because
of
lack
of
toxicity
data
on
these
organisms.

EFED
is
not
seeking
insect
testing
of
the
degradate,
ETU.
EFED
expects
substantial
ETU
exposure
to
honeybees
in
flight
or
while
foraging
on
the
nectar
or
pollen
producing
parts
of
plants
is
unlikely.
EFED
is
assuming
a
1.6%
conversion
rate
(
from
parent­
EBDCs
to
ETU)
for
terrestrial
exposure
as
a
conservative
estimate
of
exposure
to
ETU.
This
means
the
dominant
exposure
to
bees
would
be
from
the
parent
EBDCs,
not
ETU.
EFED
expects
the
parent
EBDCs'
use
patterns
would
result
in
ETU
exposure
to
pollinating
insects.
However,
the
parent
EBDCs
are
practically
nontoxic
(
metiram,
maneb,
and
mancozeb
acute
contact
LD
50
s
=
437,
>
12,
and
>
179
µ
g/
bee
,
respectively)
to
honeybees
from
short­
term
contact
exposure
(
Guideline
141­
1)
and
there
have
been
no
reported
adverse
effects
to
pollinating
insects
resulting
from
the
parent
EBDCs'
use.
EFED
also
expects
any
honeybee
acute
contact
toxicity
caused
by
ETU
would
have
been
expressed
in
the
acute
contact
LD
50
guideline
testing
performed
on
the
parent
compounds.

Endocrine
Disruption
Based
on
available
effects
data
in
mammals,
ETU
could
be
a
potential
endocrine
disruptor.
The
mammalian
feeding
studies
for
ETU
performed
on
rats
and
dogs
ranged
in
time
from
3
to
4
months.
These
feeding
studies
found
the
following
effects:
changes
in
thyroid
hormones;
changes
in
liver
enzymes;
microscopic
changes
in
the
liver
and
thyroids;
increased
thyroid
weights;
and
increased
relative
liver
weights.
HED
reviewed
a
one­
dose
developmental
gavage
study
done
on
pregnant
laboratory
rats.
This
study
determined
that
treatment­
related
developmental
effects
caused
by
ETU
involved
gross
developmental
defects,
central
nervous
system
defects,
skeletal
deficiencies,
6
cryptorchidism
(
failure
of
one
or
more
testes
to
descend
into
the
scrotum),
and
decreased
fetal
weight.
EFED
recommends
subjecting
ETU
to
more
definitive
testing
to
better
characterize
effects
related
to
its
endocrine
disruption
when
EPA
develops
suitable
screening
and
testing
protocols.

Data
Gaps
Environmental
Fate
Submitted
fate
data
are
adequate
to
characterize
the
environmental
fate
and
transport
of
ETU.
Additional
fate
data
for
ETU
may
be
necessary
pending
resolution
of
data
gaps
for
the
its
parent
EBDCs.
The
registrant
had
submitted
a
high
tier
targeted
monitoring
study
for
ETU,
therefore,
no
new
terrestrial
field
dissipation
study
is
required
at
this
time.
The
following
Table
lists
the
status
of
the
fate
data
requirements
for
ETU.

Status
of
environmental
data
requirements
for
ETU.

Guideline
Number
Data
Requirement
Is
Data
Needed?
MRID
Number
Study
Classification
161­
1
835.2
Hydrolysis
1
No
404661­
03
Acceptable
161­
2
835.2
Photo
Degradation
in
Water
1
No
404661­
02
Acceptable
161­
3
835.2
Photo
Degradation
on
Soil
1
No
404661­
01
Acceptable
162­
1
835.4
Aerobic
Soil
Metabolism
2
Reserved
408387­
01
Supplemental
451564­
01
and
452251­
01
162­
2
835.4
Anaerobic
Soil
No
Studies
submitted
162­
3
835.4
Anaerobic
Aquatic
Metabolism
3
No
001633­
35
Acceptable
00088820
402582­
03
Supplemental
162­
4
835.4
Aerobic
Aquatic
Metabolism
No
Studies
submitted
163­
1
835.1230
Adsorption/
Desorption
4
No
002588­
96
Acceptable
000971­
58
Supplemental
A­
2552­
29
835.1240
Leaching
No
405883­
01
Supplemental
163­
2
Laboratory
Volatility
No
423015­
01
Rejected
164­
1
835.6
Terrestrial
Field
Dissipation
No
A­
2552­
29
Supplemental
000889­
23
Guideline
Number
Data
Requirement
Is
Data
Needed?
MRID
Number
Study
Classification
7
165­
4
850.2
Accumulation
in
Fish
Waived
(
Octanol/
water
coefficient=
0.5)

1
Additional
studies
were
also
submitted
under
Accession
No.
2552­
29
but
all
were
rejected.
2
MRID
408387­
01
contains
two
separate
experiments
one
used
mancozeb
as
test
material
while
the
other
used
ETU.
3
MRID
001633­
35
is
a
maneb
study
in
which
ETU
was
tracked
and
half­
life
estimated.
MRID
000888­
20
and
its
supplement
402582­
03
contain
two
separate
experiments
one
used
mancozeb
as
test
material
while
the
other
used
ETU.
4
MRID
002588­
96
was
also
submitted
under
Accession
No.
402229­
02.
Note
that
MRID
000971­
58
is
a
laboratory
technical
report
submitted
by
the
registrant.

Ecotoxicity
EFED
was
unable
to
assess
the
acute
or
chronic
ETU
risk
to
birds.
EFED
was
unable
to
assess
the
acute
risks
to
estuarine/
marine
fish
or
aquatic
vascular
plants.
EFED
was
unable
to
assess
these
risks
because
the
toxicity
of
ETU
to
these
organisms
is
unknown.
EFED
needs
studies
(
see
appendices
III
and
V)
to
provide
this
toxicity
information.
EFED
is
seeking
testing
on
terrestrial
nontarget
plant
species
for
all
the
parent
compounds
to
evaluate
the
phytotoxicty
of
these
compounds.
Terrestrial
plant
testing
on
ETU
is
held
in
reserve
pending
results
of
the
parental
testing.
EFED
is
reserving
the
need
for
chronic
toxicity
testing
on
freshwater
and
estuarine­
marine
animals
until
EFED
receives
and
reviews
acute
toxicity
studies
for
all
the
surrogate
freshwater
and
estuarine­
marine
organisms.
EFED
does
not
evaluate
the
chronic
risk
to
aquatic
plants
because
EFED
hasn't
developed
methods
to
assess
chronic
risk
to
plants.
The
following
Table
lists
the
status
of
the
ecological
data
needs
for
ETU.
EFED
continues
to
receive
EBDC
and
ETU
studies
for
review.
EFED
will
review
and
evaluate
outstanding
studies
and
include
these
studies
in
the
revised
chapters
for
the
EBDCs
and
ETU.
These
outstanding
studies
may
change
the
environmental
risk
assessment
or
the
data
needs
for
the
EBDCs.

Status
of
the
ecological
data
requirements
for
ETU.

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
(
6
Basic
Studies
in
Bold)

71­
1(
a)
Acute
Avian
Oral,
Quail/
Duck
TGAI
1,
2,
3,
4,
10,
&
11
No
Not
applicable
Not
applicable
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
Yes
71­
2(
b)
Acute
Avian
Diet,
Duck
TGAI
1,
2,
3,
4,
10,
&
11
No
Not
applicable
Not
applicable
Yes
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
No
Not
applicable
Not
applicable
Yes
71­
4(
b)
Avian
Reproduction
Duck
TGAI
1,
2,
3,
4,
10,
&
11
No
Not
applicable
Not
applicable
Yes
71­
5(
a)
Simulated
Terrestrial
Field
Study
1,
2,
3,
4,
10,
&
11
No
Not
applicable
Not
applicable
No
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)?

8
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
No
Not
applicable
Not
applicable
Yes
72­
1(
b)
Acute
Fish
Toxicity
Bluegill
(
TEP)
1,
2,
3,
4,
10,
&
11
No
Not
applicable
Not
applicable
No
72­
1(
c)
Acute
Fish
Toxicity
Rainbow
Trout
TGAI
1,
2,
3,
4,
10,
&
11
Yes
45910401
or
46020903
(
duplicate
MRID
No.)
Core
No
72­
1(
d)
Acute
Fish
Toxicity
Rainbow
Trout
(
TEP)
1,
2,
3,
4,
10,
&
11
No
Not
applicable
Not
applicable
No
72­
2(
a)
Acute
Aquatic
Invertebrate
Toxicity
(
Freshwater)
TGAI
1,
2,
3,
4,
10,
&
11
Yes
45910402
or
46020901
(
duplicate
MRID
No.)
Core
No
72­
2(
b)
Acute
Aquatic
Invertebrate
Toxicity
(
TEP)
1,
2,
3,
4,
10,
&
11
No
Not
applicable
Not
applicable
No
72­
3(
a)
Acute
Estu/
Mari
Tox
Fish
TGAI
1,
2,
3,
4,
10,
&
11
No
Not
applicable
Not
applicable
Yes
72­
3(
b)
Acute
Estu/
Mari
Tox
Mollusk
TGAI
1,
2,
3,
4,
10,
&
11
No
Not
applicable
Not
applicable
Yes
72­
3(
c)
Acute
Estu.
Mari
Tox
Shrimp
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
Not
applicable
Not
applicable
No
72­
3(
e)
Acute
Estu/
Mari
Tox
Mollusk
(
TEP)
1,
2,
3,
4,
10,
&
11
No
Not
applicable
Not
applicable
No
72­
3(
f)
Acute
Estu/
Mari
Tox
Shrimp
(
TEP)
1,
2,
3,
4,
10,
&
11
No
Not
applicable
Not
applicable
No
72­
4(
a)
Early
Life­
Stage
Fish
(
Freshwater
&
Estuarine/
Marine)
TGAI
1,
2,
3,
4,
10,
&
11
No
Not
applicable
Not
applicable
Reserved
72­
4(
b)
Life­
Cycle
Aquatic
Invertebrate
(
Freshwater
&
Estuarine/
Marine)
TGAI
1,
2,
3,
4,
10,
&
11
No
Not
applicable
Not
applicable
Reserved
72­
5
Life­
Cycle
Fish
(
Freshwater
&
Estuarine/
Marine)
TGAI
1,
2,
3,
4,
10,
&
11
No
Not
applicable
Not
applicable
Reserved
72­
6
Aquatic
Org.
Accumulation
TGAI
1,
2,
3,
4,
10,
&
11
No
Not
applicable
Not
applicable
No
72­
7(
a)
Simulated
Aquatic
Field
Study
(
TEP)
1,
2,
3,
4,
10,
&
11
No
Not
applicable
Not
applicable
No
72­
7(
b)
Actual
Aquatic
Field
Study
1,
2,
3,
4,
10,
&
11
No
Not
applicable
Not
applicable
No
§
158.540
PLANT
PROTECTION
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)?

122­
1(
a)
Seed
Germ./
Seedling
Emerg.­
Tier
I
(
TEP)
1,
2,
3,
4,
10,
&
11
No
Not
applicable
Not
applicable
Reserved
122­
1(
b)
Vegetative
Vigor­
Tier
I
(
TEP)
1,
2,
3,
4,
10,
&
11
No
Not
applicable
Not
applicable
Reserved
122­
2
Aquatic
Plant
Growth­
Tier
I
(
TEP)
1,
2,
3,
4,
10,
&
11
No
Not
applicable
Not
applicable
Yes3
123­
1(
a)
Seed
Germ./
Seedling
Emerg.­
Tier
II
(
TEP)
1,
2,
3,
4,
10,
&
11
No
Not
applicable
Not
applicable
No
123­
1(
b)
Vegetative
Vigor­
Tier
II
(
TEP)
1,
2,
3,
4,
10,
&
11
No
Not
applicable
Not
applicable
No
123­
2
Aquatic
Plant
Growth­
Tier
II
(
TEP)
1,
2,
3,
4,
10,
&
11
No
45910403
or
46020902
(
duplicate
MRID
No.)
Supplemental
Yes3
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
141­
1
Honey
Bee
Acute
Contact
TGAI
1,
2,
3,
4,
10,
&
11
No
Not
applicable
Not
applicable
No
141­
2
Honey
Bee
Residue
on
Foliage
(
TEP)
1,
2,
3,
4,
10,
&
11
No
Not
applicable
Not
applicable
No
141­
5
Field
Test
for
Pollinators
1,
2,
3,
4,
10,
&
11
No
Not
applicable
Not
applicable
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.
Tier
I
or
Tier
II
aquatic
plant
testing
is
recommended.

EFED
Label
Recommendations
There
are
no
recommendations
since
ETU
is
degradate
and
not
an
active
ingredient.

Potential
areas
of
change
to
the
risk
assessments
for
the
EBDCs
and
ETU
EFED
continues
to
receive
ETU
and
EU
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
ETU.
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
ETU.
10
Table
1
ETU
and
EU
degradate
studies
not
included
in
Section
4
Reregistration
for
EBDCs
as
of
5/
22/
05
Guideline
MRID
Number
Study
Status
Test
material
§
72­
4b
46462901
Ethylene
Thiourea
(
ETU):
A
Flow­
Through
Life­
Cycle
Toxicity
Test
with
the
Cladoceran
(
Daphnia
magna).
Graves,
W.
C.,
M.
A.
Mank,
and
J.
P.
Swigert.
1995.
Needs
EPA
Review
96.2%
ETU
§
72­
1c
46462902
Ethylene
Urea:
A
96­
Hour
Static
Acute
Toxicity
Test
With
The
Rainbow
Trout
(
Oncorhynchus
mykiss).
Palmer,
S.
J.,
Kendall,
T.
Z.
and
Krueger,
H.
O.
2001.
Needs
EPA
Review
90.8%
EU
§
72­
2a
46462903
Ethylene
Urea:
A
48­
Hour
Static
Acute
Toxicity
Test
With
The
Cladoceran
(
Daphnia
magna).
Palmer,
S.
J.,
Kendall,
T.
Z.
and
Krueger,
H.
O.
2001.
Needs
EPA
Review
96.0%
EU
§
123­
2
46462904
Ethylene
Urea:
A
96­
Hour
Toxicity
Test
with
the
Freshwater
Alga
(
Selenastrum
capricornutum).
Palmer,
S.
J.,
T.
Z.
Kendall,
and
H.
O.
Krueger
2001.
Needs
EPA
Review
90.8%
EU
UNITED
STATES
ENVIRONMENTAL
PROTECTION
AGENCY
WASHINGTON,
D.
C.
20460
OFFICE
OF
PREVENTION,
PESTICIDES,
AND
TOXIC
SUBSTANCES
Environmental
Fate
and
Ecological
Risk
Assessment
for
Ethylenethiourea
(
ETU)

A
Common
Degradate
of
the
EBDC
Fungicides:
Metiram,
Mancozeb,
and
Maneb
2­
Imidazolidinethione
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
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1
II.
Introduction
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5
a.
Sources
of
Environmental
Contamination
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5
b.
Approach
to
Risk
Assessment
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III.
Integrated
Environmental
Risk
Characterization
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a.
Overview
of
Environmental
Risk
Characterization
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14
b.
Key
Issues
of
Uncertainty
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17
i.
Environmental
Fate
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ii.
Ecological
Effects
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19
c.
Endangered
Species
Conclusions
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d.
Endocrine
Disruption
Concerns
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19
IV.
Environmental
Fate
Assessment
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21
a.
Production
from
EBDCs
in
Laboratory
and
Field
Studies
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21
i.
Aqueous
Media
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ii.
Soil
Systems
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iii.
Water/
Sediment
Systems
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23
b.
Chemical
Identity
and
Physicochemical
Properties
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24
c.
Fate
Processes
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25
i.
Aqueous
Solutions
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ii.
Soil
Systems
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27
iii.
Sediment/
Water
Systems
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27
d.
Mobility
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28
e.
Field
Dissipation
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29
f.
Bio­
accumulation
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30
g.
Transformation
Products
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30
V.
Water
Resource
Assessment
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33
a.
Surface
Water
Modeling
for
Aquatic
Exposure
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33
b.
Drinking
Water
Assessment
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VI.
Aquatic
Exposure
and
Risk
Assessment
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38
a.
Hazard
Summary
(
Acute/
Chronic)
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38
b.
Exposure
and
Risk
Quotients
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39
c.
Aquatic
Risk
Assessment
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39
i.
Incidents
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40
ii.
Endocrine
Disruptors
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40
iii.
Endangered
Species
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40
iii
VII.
Terrestrial
Exposure
and
Risk
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41
a.
Hazards
Summary
(
Acute/
Chronic)
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41
b.
Exposure
Summary
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42
c.
Risk
Quotients
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43
d.
Terrestrial
Risk
Assessment
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48
i.
Incidents
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49
ii.
Endocrine
Disruptors
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49
iii.
Endangered
Species
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49
APPENDIX
I:
Additional
Fate
Data
&
Background
for
Models
Used
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51
APPENDIX
II:
Hoerger­
Kenaga
Estimates
&
Fate
v.
5.0
Model
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52
a.
Hoerger­
Kenaga
Estimates
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52
b.
Fate
v.
5.0
Model
Terrestrial
Exposure
Values
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52
c.
Fate
v.
5.0
Model
Sample
Output
for
ETU
Residues
from
Mancozeb's
Use
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53
APPENDIX
III:
Ecological
Hazards
Assessment
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58
a.
Review
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58
b.
Toxicity
to
Terrestrial
Animals
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58
i.
Birds,
Acute,
Subacute
and
Chronic
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58
ii.
Mammals,
Acute
and
Chronic
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58
1.
Acute
Oral
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58
2.
Acute
Dermal
and
Inhalation
Toxicity
Testing
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
59
3.
Mammalian
Subchronic
Toxicity
Testing
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
59
4.
Mammalian
Reproductive
&
Developmental
Toxicity
Testing
.
.
.
.
.
.
59
iii.
Insect
Acute
Contact
.
.
.
.
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.
61
iv.
Terrestrial
Field
Testing
.
.
.
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.
61
c.
Toxicity
to
Aquatic
Organism.
.
.
.
.
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61
Preface
.
.
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.
61
i.
Toxicity
to
Freshwater
Animals
.
.
.
.
.
.
.
.
.
.
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.
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.
.
.
62
1.
Freshwater
Fish,
Acute
.
.
.
.
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.
62
2.
Freshwater
Invertebrates,
Acute
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
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.
.
.
.
62
ii.
Aquatic
Field
Studies
.
.
.
.
.
.
.
.
.
.
.
.
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.
.
.
.
.
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.
63
d.
Toxicity
to
Plants
.
.
.
.
.
.
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.
.
63
i.
Terrestrial
Plants
.
.
.
.
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.
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63
ii.
Aquatic
Plants
.
.
.
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.
.
63
iii.
Aquatic
Plant
Field
Studies
.
.
.
.
.
.
.
.
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.
.
.
.
.
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.
64
APPENDIX
IV:
Environmental
Exposure
Assessment
.
.
.
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.
.
65
a.
Review
of
Risk
Quotients
(
RQs)
.
.
.
.
.
.
.
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.
.
65
b.
Exposure
and
Risk
to
Terrestrial
Animals
.
.
.
.
.
.
.
.
.
.
.
.
.
.
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.
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.
.
66
i.
Birds
.
.
.
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66
iv
ii.
Mammals
.
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.
67
c.
Aquatic
Organisms
.
.
.
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.
.
74
i.
Review
.
.
.
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.
74
ii.
Freshwater
Fish
.
.
.
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.
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.
75
iii.
Freshwater
Invertebrates
.
.
.
.
.
.
.
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.
.
.
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.
.
.
.
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.
.
.
.
76
iv.
Exposure
and
Risk
to
Nontarget
Plants:
Aquatic
Plants
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
77
d.
Endangered
Species
.
.
.
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.
.
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.
.
78
e.
Ecological
Incidents
.
.
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.
78
APPENDIX
V:
US
EPA
Ecological
Incident
Information
System
.
.
.
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.
.
79
APPENDIX
VI.
HED
Memorandum
on
Surface/
Ground
water
EDWCs
.
.
.
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.
81
REFERENCES
.
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.
111
a.
Environmental
Fate
.
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.
111
b.
Ecological
Effects
.
.
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.
114
1
Lethal
condition
in
which
the
skull
is
defective
with
the
brain
exposed
or
extruding.

1
I.
Executive
Summary
ETU
is
a
common
degradate
of
metiram,
mancozeb
and
maneb
(
EBDCs).
The
EBDCs
are
nonsystemic,
contact
and
disease
prevention
fungicides
belonging
to
a
chemical
group
classified
as
ethylenebisdithiocarbamate
(
EBDC)
fungicides.
Pesticide
applicators
use
EBDCs
on
many
crops,
some
forestry
uses,
ornamental
plantings,
seed
treatment,
and
turf.

Mammalian
ETU
Risk
Quotients
(
RQs)
exceed
the
chronic
Level
of
Concern
(
LOC)
for
all
mancozeb's
use
patterns.
ETU
effects
triggering
this
potential
chronic
risk
were
based
on
developmental
defects
of
the
brain
(
that
is,
exencephaly1,
dilated
ventricles,
and
hypoplastic
cerebellum)
in
rats.
For
small
mammals
(
15­
gram)
feeding
on
short
grass,
ETU's
chronic
RQs
range
from
a
high
of
37
from
mancozeb
turf
applications
to
2
from
mancozeb
citrus
applications.
For
small
mammals
feeding
on
forage
and
small
insects,
the
chronic
RQs
range
from
a
high
of
21
from
mancozeb
turf
applications
to
2
from
mancozeb
vegetable
applications.
The
ETU
potential
chronic
risk
to
small
mammalian
herbivore­
insectivores
from
mancozeb's
use
on
citrus,
only,
is
below
chronic
LOCs.

For
medium
sized
mammals
(
35­
gram)
feeding
on
short
grass,
ETU's
chronic
RQ
range
from
26
for
turf
applications
of
mancozeb
to
1
on
citrus.
For
medium
sized
mammals
feeding
on
forage
and
small
insects,
ETU's
potential
chronic
risk
are
exceeded
for
all
mancozeb's
uses
except
mancozeb's
uses
on
citrus.
For
medium
sized
mammals
feeding
on
forage
and
small
insects,
the
RQs
exceeding
the
chronic
LOC
range
from
14
for
turf
applications
of
mancozeb
to
1
on
vegetables.
For
large
mammals
(
1,000
gram)
feeding
on
short
grass,
the
RQs
range
from
6
on
turf
to
1
on
bananas.
There
are
no
ETU
chronic
LOC
exceedances
to
large
mammals
from
mancozeb's
use
on
potato
&
sugar
beet,
fennel,
peanuts,
forestry
(
douglas
fir),
Christmas
tree
plantations,
tobacco,
cotton,
asparagus,
garlic
&
shallot,
ornamentals,
the
barley
crop
grouping.,
vegetables
or
citrus.
For
large
mammals
feeding
on
forage
and
small
insects,
ETU's
chronic
risk
LOCs
are
exceeded
for
mancozeb's
uses
on
apples,
papaya,
pachysandra
groundcover,
and
turf
(
chronic
RQ
range
1
on
apples
to
3
on
turf),
only.
For
granivore
mammals
(
all
sizes),
no
ETU
chronic
LOC
from
mancozeb's
uses
was
exceeded.

EFED
does
not
expect
acute
risk
to
mammals
from
ETU
exposure.
Acutely,
ETU
is
practically
nontoxic
(
mouse
acute
oral
LD
50
=
2,300
mg/
kg)
to
mammals
and
EFED
has
not
documented
any
adverse
ETU
effects
from
field
incidents
to
mammals.
EFED
does
not
have
any
acute,
subacute
or
chronic
toxicity
data
to
evaluate
ETU's
toxicity
to
birds.

The
acute
LOCs
for
ETU
are
not
exceeded
for
freshwater
fish
and
freshwater
invertebrates.
The
acute
LOCs
were
not
exceeded
for
nonvascular
aquatic
plants.
This
was
based
on
testing
in
1
of
4
surrogate
test
species.
Because
ETU
is,
acutely,
practically
nontoxic
to
mammals
EFED
expects
the
acute
risk
to
mammals
will
be
low.
Since
the
EBDCs
are
practically
nontoxic
to
bees
and
substantial
bee
contact
with
ETU
is
unlikely,
EFED
expects
the
acute
risk
to
terrestrial
nontarget
insects
will
be
low.
Because
EFED
lacks
toxicity
data,
EFED
is
uncertain
about
ETU's
acute
risks
to
birds,
2
In
this
document
three
important
abbreviations
are
used:
Parent
EBDCs,
EBDCs
complex
and
Bound
species.
Parent
EBDCs
are
the
polymeric
EBDC
parents
(
metiram,
mancozeb
and
maneb)
present
in
the
active
ingredients
of
all
of
the
EBDCs
fungicides.
EBDCs
Complex
are
suites
of
multi
species
complexes
resulting
from
degradation
of
the
polymeric
EBDC
parents
(
metiram,
mancozeb
and
maneb).
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).

3
Sue
XU.
2000,
Environmental
Fate
of
Ethylenethiourea.
California
Department
of
Pesticide
Regulation,
CA,
US.

2
estuarine/
marine
fish,
estuarine/
marine
invertebrates,
and
aquatic
vascular
plants.
Because
EFED
lacks
chronic
toxicity
data,
EFED
is
uncertain
about
the
chronic
risks
to
birds.
EFED
is
reserving
the
need
for
chronic
toxicity
testing
on
freshwater
and
estuarine­
marine
animals
until
EFED
receives
and
reviews
acute
toxicity
studies
for
all
the
surrogate
freshwater
and
estuarine­
marine
organisms.
EFED
does
not
evaluate
the
chronic
risk
to
aquatic
plants
because
EFED
hasn't
developed
methods
to
assess
chronic
risk
to
plants.

Applied
parent
EBDCs
are
the
main
source
for
environmental
contamination
with
ETU
as
it
is
one
of
the
main
constituents
of
the
EBDCs
degradate
complex
(
EBDCs
Complex)
2.
When
parent
EBDCs
are
applied,
major
portion
reaches
directly
targeted
crop
foliage
and
supporting
soil
system
while
much
smaller
portion
reaches
aquatic
systems
by
drift.
Parent
EBDCs
reaching
foliage,
soil
and
aquatic
systems
are
expected
to
decompose
relatively
fast
by
hydrolytic
reactions
into
the
EBDCs
Complex
which
contains
ETU.
Based
on
the
unified
conceptual
model
for
all
EBDCs,
ETU
is
mainly
produced
(
as
part
of
the
EBDCs
Complex)
by
both
the
initial
rapid
hydrolysis
of
parent
EBDCs
and
the
possible
slow/
continuous
degradation
of
the
soil/
sediment
associated
complex.

ETU
produced
in
and
transported
to
the
soil
system
is
highly
vulnerable
to
bio­
degradations
but
its
high
water
solubility
and
mobility
can
give
it,
at
least
in
part,
the
potential
to
leach
to
ground
water
at
low
concentrations.
In
surface
water,
sources
of
ETU
are:
formation
from
the
initial
rapid
hydrolysis
of
parent
EBDCs
deposited
by
drift,
transportation
by
runoff
in
dissolved
form,
and
the
possible
continuous/
slow
formation
from
bound
species
transported
on
soil
particles
by
runoff
and/
or
erosion.
Quantities
of
ETU
that
reach
or
form
in
natural
surfacewater
are
expected
to
be
stable
to
hydrolysis/
direct
photolysis,
however,
it
was
reported
that
it
can
be
removed
rather
quickly
from
these
waters
by
indirect
photolysis
(
half­
lives
of
1­
4
days)
3.

ETU
is
expected
to
partition
into
the
air
from
dry
soil
surfaces
as
indicated
from
its
vapor
pressure.
However,
its
high
water
solubility/
relatively
low
Henry's
law
constant
may
render
such
partition
unimportant
because
ETU
forms
from
EBDCs
only
when
water
is
present
(
i.
e.
in
wet
soil
or
water
bodies).
Additionally,
if
ETU
reaches
air
it
is
expected
to
partition
into
rain
or
be
affected
with
hydroxy
radicals
(
half­
life
of
8­
9
days
was
reported
for
ETU
in
the
air).
ETU
is
likely
to
be
not
persistent
in
air.
The
hydroxy
radical
half­
life
of
ETU
in
air
is
calculated
by
the
USEPA
computer
program
EPI
suite
v.
3.01
(
AOPWIN)
to
be
0.9
hours.
A
low
K
ow
value
is
reported
for
ETU,
3
therefore
the
chemical
is
not
expected
to
be
significantly
bio­
concentrated
by
aquatic
organisms
such
as
fish.

ETU
may
be
a
potential
endocrine
disruptor
based
on
effects
in
mammals.
The
mammalian
feeding
studies
for
ETU
performed
on
rats
and
dogs
ranged
in
time
from
3
to
4
months.
These
feeding
studies
found
the
following
effects:
changes
in
thyroid
hormones;
changes
in
liver
enzymes;
microscopic
changes
in
the
liver
and
thyroids;
increased
thyroid
weights;
and
increased
relative
liver
weights.
HED
reviewed
a
one­
dose
developmental
gavage
study
done
on
pregnant
laboratory
rats.
This
study
determined
that
treatment­
related
developmental
effects
caused
by
ETU
involved
gross
developmental
defects,
central
nervous
system
defects,
skeletal
deficiencies,
cryptorchidism
(
failure
of
one
or
more
testes
to
descend
into
the
scrotum),
and
decreased
fetal
weight.
EFED
recommends
subjecting
ETU
to
more
definitive
testing
to
better
characterize
effects
related
to
its
potential
endocrine
disruption
when
EPA
develops
suitable
screening
and
testing
protocols.

Targeted
surfacewater
(
SW)
monitoring
data
were
used
to
assign
a
value
of
0.1
ppb
for
both
the
chronic/
non­
cancer
and
chronic/
cancer
ETU/
EDWCs.
This
decision
was
based
on
a
2­
year
targeted
SW
monitoring
program
in
which
no
concentration
values
were
measured
above
the
ETU
detection
limit
of
0.1
ppb
in
either
raw
or
treated
community
water
from
surface
water
sources.
Sampling
was
executed
every
14­
day
during
the
historical­
EBDCs
­
use
season;
acute
peak
values
over
the
0.1
ppb
could
have
been
missed.
Therefore,
modeling
was
necessary
to
estimate
these
values
in
order
to
assign
a
maximum
value
for
an
acute
range
which
was
established
with
a
lower
limit
of
0.1
ppb
(
based
on
monitoring,
MRID
46145401)
and
an
upper
limit
of
25.2
ppb
(
based
on
modeling
using
the
linked
EPA
PRZM
and
EXAMS
models).
The
highest
value
in
this
national
level
range
can
be
reduced,
at
the
regional
level,
to
13.9
ppb.
Additionally,
the
assigned
acute
maximum
values
(
25.2
and
13.9
ppb)
could
be
as
low
as
2
and
1
ppb,
respectively
when
they
are
corrected
proportionally
(
based
on
the
assumption
that
PRZM/
EXAMS
acute
estimates
can
be
corrected
so
that
the
maximum
chronic
value
for
monitored
sites
is
equal
to
0.1
ppb).

An
EDWC
of
0.21
ppb
ETU
was
assigned
to
ground
water
based
on
a
the
targeted
ground
water
(
GW)
monitoring
study.
This
value
of
0.21
ppb
was
the
highest
measured
value
in
a
public
drinking
water
well
located
in
Lee
County,
Florida.
In
rural
areas,
the
highest
value
measured
by
the
EBDC
Task
Force
was
0.57
ppb
and
was
for
ground
water
from
a
private
well
near
an
EBDC
treated
field
in
an
apple
growing
region
of
New
York.
ETU
concentrations
in
the
range
of
0.1
to
0.25
were
also
measured
in
8
out
of
the
monitored
125
rural
wells
suggesting
that
exposure
to
higher
ETU
concentrations
(
over
the
assigned
0.21
ppb)
may
occur
in
localities
using
ground
water
wells
located
in
proximity
or
at
areas
with
heavy
EBDCs
use.
Assigned
ETU/
EDWCs
represent
upper­
bound
conservative
estimates
of
the
total
ETU
residual
concentrations
that
might
be
found
in
drinking
water
derived
from
either
surface
water
and
ground
water
sources
due
to
the
use
of
the
EBDC
fungicides.

It
is
important
to
note
that
ETU
was
not
detected
in
any
of
the
treated
surface/
ground
water
community
drinking
water
even
when
it
was
detected
in
the
raw
water.
The
registrant
claims
that
the
absence
of
ETU
in
potable
water
from
community
water
supplies
is
related
to
its
rapid
degradation
resulting
from
aeration
and
chemical
treatment
(
i.
e.
chlorination).
In
contrast,
home
filters
were
reported
to
be
ineffective
at
removing
ETU
from
rural
well
water
examined
at
two
sites.
4
II.
Introduction
a.
Sources
of
Environmental
Contamination
ETU
is
a
common
degradate
of
ethylenebisdithiocarbamate
(
EBDC)
fungicides,
mancozeb,
metiram,
and
maneb.
The
EBDCs
are
nonsystemic,
have
both
contact
toxicity
with
preventive
control,
and
control
a
wide
range
of
fungi.
The
formulation
types
for
EBDCs
include
dusts,
water
dispersible
granules
(
dry
flowables),
flowable
concentrates,
and
wettable
powders.

As
a
degradate
of
the
EBDCs,
EFED
expects
the
presence
of
ETU
wherever
the
use
of
these
fungicides
occur.
The
use
patterns
of
the
EBDCs
include
wide
use
on
crops,
forestry
uses,
and
uses
in
ornamental
plantings,
seed
treatment
and
turf.
The
reader
may
refer
to
the
detailed
listing
of
these
uses
in
the
REDs
for
mancozeb,
metiram,
and
maneb.
For
the
purpose
of
ecological
risk
assessment,
EFED
calculated
EECs
for
ETU's
terrestrial
exposure
based
on
mancozeb's
use
pattern
(
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
Crop
Maximum
Application
Rate
Number
of
Applications
Minimum
Application
Interval
(
day)
Per
Treatment
In
Total
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
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.

In
an
agricultural
setting,
ETU
is
introduced
into
or
formed
in
the
environment
in
four
ways
following
application
of
the
EBDC
fungicides.
First,
ETU
may
be
added
with
the
applied
formulation
as
it
may
form
in
these
formulations
as
a
result
of
particle
size
reduction
(
i.
e.
dry
and
wet
milling),
due
to
unfavorable
storage
and/
or
due
to
dilution
in
the
tank­
mix.
Second,
ETU
is
formed,
as
part
of
the
EBDCs
complex,
in
soil
pore
water/
water
bodies
from
hydrolytic
degradation
of
parent
EBDCs
following
its
application/
wash
off
to
soils
and/
or
after
reaching
water
bodies
by
drift.
Third,
ETU
is
produced
from
hydrolysis
of
some
species
of
the
EBDCs
complex
left
in
soil
pore
water
or
transported
by
run­
off
into
the
water,
and
left
unbound
to
the
sediment,
in
water/
sediment
systems.
Fourth,
ETU
may
be
produced
continuously
at
low
concentrations
from
the
slow
degradation
of
the
soil/
sediment
associated
Bound
species.
ETU
presence
in
the
formulations
of
EBDCs
is
difficult
to
establish,
but
is
expected
to
be
unimportant
in
most
cases.
Therefore,
ETU
production
from
EBDCs
in
the
environment
is
controlled
mainly
by
the
second
and
to
a
less
extent
the
third
and
fourth
processes
stated
above,
with
the
seconds
being
the
most
important.

ETU
may
also
be
introduced
into
the
environment
from
other
sources
such
as:
EBDC
manufacturing/
formulating
facilities,
EBDC
commercial
products
(
other
than
metiram,
mancozeb
and
maneb),
use
in
industry
(
as
an
accelerator
in
synthetic
rubber
production
and
as
vulcanizing
agent
in
6
production
of
some
types
of
poly­
ethers).
Environmental
contamination
from
these
industrial
uses
are
not
covered
by
this
document.
7
b.
Approach
to
Risk
Assessment
The
risk
assessment
for
ETU
was
based
on
its
EECs
in
important
environmental
compartments.
These
EECs
were
calculated
by
estimating
expected
quantities
of
ETU
that
would
be
produced
from
application
of
EBDCs.
Resultant
ETU
quantities
were
then
modeled
to
arrive
at
its
EECs
using
physicochemical
and
fate
properties
determined
for
ETU.
The
latter
EECs
along
with
related
ecological
effects
data
(
i.
e.,
available
aquatic
and
terrestrial
toxicity
data),
were
used
to
evaluate
and
characterize
ecological
risk
of
ETU
to
the
environment.

For
terrestrial
exposure,
EFED
calculated
the
EECs
for
ETU
based
on
mancozeb's
use
pattern.
EFED
could
have
calculated
RQs
based
on
the
use
patterns
of
the
other
two
parent
compounds
for
ETU,
metiram
and
maneb.
EFED
decided
not
to
make
these
extra
calculations
since
expected
results
would
be
the
same
and
would
only
further
confirm
ETU's
chronic
risk
to
mammals.
Also,
mancozeb
has
the
broadest
use
pattern
(
most
sites
of
application)
and
EFED
expected
mancozeb's
uses
would
provide
a
more
comprehensive
view
of
the
risks
posed
by
ETU.
The
EECs
modeled
for
ETU
assumed
1.6
percent
conversion
of
mancozeb
to
ETU
as
an
estimate
of
exposure.

HED
receives
dislodgeable
foliar
residue
(
DFR)
dissipation
half­
life
data
(
guideline
875.2100)
to
estimate
exposures
to
individuals
that
occur
as
a
result
of
working
in
an
environment
that
has
been
previously
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
(
Table
II­
2).

Table
II­
2.
Day
After
Treatment
(
DAT)
Summary
of
Mancozeb
and
ETU
Dislodgeable
Foliar
Residue
(
DFR)

MRID
(
Year)
CROP
(
Location)
Application
Method
Lb
ai/
acre
(
Application
Interval)
Mancozeb
DAT
0
DFR
(
ug/
cm2)
[
A]
ETU
DAT
0
DFR
(
ug/
cm2)
[
B]
DAT
0
DFR
Mancozeb
to
ETU
Conversion
(%)
[
B/(
A
+
B)]

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
4.53
13.7
or
20.13
3.4
3.7
0.0545
0.074
or
0.109
Not
available
Not
available
1.2
0.5
or
0.5
Not
available
Not
available
449617­
01(
99)
NC
Green
House
Tomatoes
Handgun
2.3
+
2.3
(
7
days)
5.1
0.0128
0.3
449596­
02(
99)
449596­
02(
99)
NY
Apples
WA
Apples
Airblast
Airblast
5.0
+
5.0
(
7
days)
5.0
+
5.0
(
7
days)
15.9
16.5
0.22
0.053
1.4
0.3
418369­
02(
91)
418369­
02(
91)
449596­
03(
99)
449596­
03(
99)
425602­
01(
91)
CA
Field
Tomatoes
MD
Field
Tomatoes
CA
Field
Tomatoes
FL
Field
Tomatoes
FL
Field
Tomatoes
Ground
boom
Airblast
Ground
boom
Ground
boom
Ground
boom
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)
6.85
5.33
6.8
7.4
6.29
0.070
0.087
0.0092
0.0023
0.021
1.0
1.6
0.1
0.03
0.3
449585­
01(
NA)
NC
Bermuda
grass
PA
Kentucky
bluegrass
CA
Tall
fescue
Ground
boom
Ground
boom
Ground
boom
16.1
*
1
10.5
*
1
11.3
*
1
0.15
0.078
0.19
Not
available
Not
available
Not
available
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
­
This
means
the
results
were
due
to
either
1.2
or
1.75
cm
diameter
leaf
punches
used
to
take
the
DFR
samples.
This
difference
resulted
from
a
reporting
discrepancy
in
the
study.
8
The
DAT
0
DFR
data
in
Table
II­
2
is
the
mancozeb
and
ETU
determined
to
be
present
on
the
leaves
of
the
treated
plants
immediately
after
application.
Mancozeb
is
used
on
more
than
20
crop
grouping
(
see
Table
II­
1)
or
more
than
40
crops.
These
DFR
studies
provides
mancozeb
to
ETU
degradation
information
on
3
crops.
Given
this
limited
information
EFED
feels
it
is
reasonable
to
use
a
1.6%
foliar
conversion
rate
(
MRID
418369­
02,
MD
Field
Tomatoes)
of
mancozeb
to
ETU
as
a
conservative
upper­
bound
estimate
in
this
screening
level
assessment.

EFED
calculated
the
exposure
estimates
of
ETU
to
be
a
fraction
of
the
exposure
estimates
for
mancozeb.
EFED
modeled
mancozeb
labeled
rates
using
FATE
version
5.0
then
multiplied
the
EECs
by
the
1.6%
conversion
rate.
The
FATE
model
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
adjusted
by
Fletcher,
and
others
(
1994)
and
assumes
1st
order
dissipation.
Appendix
II
provides
Kenaga
estimates
and
an
explanation
of
the
model
with
sample
production
reports.

EFED
needs
total
foliar
dissipation
residue
or
total
foliar
residue
(
TFR)
half­
life
information
as
a
modeling
input
value
to
estimate
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
data
chiefly
from
Willis
and
McDowell
(
1987).
Since
ETU
TFR
halflife
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
previously
treated
with
a
pesticide
(
also
referred
to
as
reentry
exposure).
DFR
is
pesticide
residue
on
treated
leaves'
surface.
EFED
would
expect
the
TFR
half­
life
values
for
ETU
would
be
at
least
as
long
as
the
ETU
DFR
values,
since
the
dislodgeable
residue
is
a
part
of
the
total
foliar
residue.
For
ETU,
HED
(
Dole
and
Dawson,
2003,
2003a,
and
2003b)
provided
the
following
Table
(
Table
II­
3)
with
MRID
Nos.
The
Mancozeb
Task
Force
provided
the
Biswis
study
through
a
literature
submission
(
Ollinger,
2005).
The
available
ETU
DFR
and
TFR
data
(
Table
II­
3)
represents
4
crops
(
grapes,
apples,
tomatoes,
and
turf).
Mancozeb
is
used
on
more
than
20
crop
grouping
(
see
Table
II­
1)
or
more
than
40
crops.

Table
II­
3.
Summary
of
ETU
DFR
&
TFR
Data
for
Crops.

MRID
(
Year)
CROP
EBDC
Applied
Lb
ai/
Acre
(
Application
Interval)
DFR
Half­
life
(
Days)
TFR
Half­
life
(
Days)

449596­
01(
99)
420449­
04(
90)
CA
Grapes
CA
Grapes
Mancozeb
Maneb
1.9
+
2.0
(
7
days)
1
3.2
*
3.0
(
30
days)
2
10.4
Not
available
Not
available
Not
available
449596­
02(
99)
451946­
01(
99)
NY
Apples
NY
Apples
Mancozeb
Maneb
5.0
+
5.0
(
7
days)
4.8
+
4.8
(
7
days)
7.7
8.4
Not
available
Not
available
449596­
02(
99)
451946­
01(
99)
413399­
01(
88)
WA
Apples
WA
Apples
CA
Apples
Mancozeb
Maneb
Metiram
5.0
+
5.0
(
7
days)
4.8
+
4.8
(
7
days)
4.8
*
3
(
42
days)
28.0
17.7
41.9
Not
available
Not
available
Not
available
449617­
01(
99
NC
Green
House
Tomatoes
Mancozeb
2.3
+
2.3
(
7
days)
9.1
Not
available
Table
II­
3.
Summary
of
ETU
DFR
&
TFR
Data
for
Crops.

MRID
(
Year)
CROP
EBDC
Applied
Lb
ai/
Acre
(
Application
Interval)
DFR
Half­
life
(
Days)
TFR
Half­
life
(
Days)

9
425602­
01(
91)
420449­
03(
91)
Biswis,
et
al.
2003
Biswis,
et
al.
2003
FL
Field
Tomatoes
FL
Field
Tomatoes
India
Tomatoes
India
Tomatoes
Mancozeb
Maneb
Mancozeb
Mancozeb
2.3
*
14
(
7
days)
1.9
*
9
(
7
days)
1.3
*
3
(
15
days)
2.7
*
3
(
15
days)
19.5
Not
available
Not
available
Not
available
Not
available
Not
available
4.33,4
4.73,4
449596­
03(
99)
419615­
01(
90)
CA
Field
Tomatoes
CA
Tomatoes
Mancozeb
Maneb
2.5
+
2.5
(
6
days)
2.4
*
3.0
(
10
days)
4.3
Not
available
Not
available
Not
available
449585­
01(
NA)
NC
Bermuda
grass
PA
Kentucky
bluegrass
CA
Tall
fescue
Mancozeb
Mancozeb
Mancozeb
16.1
*
1
10.5
*
1
11.3
*
1
Not
available
Not
available
Not
available
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).

Based
on
the
results
of
the
studies
listed
in
Table
II­
3,
EFED
would
expect
a
variation
in
the
half­
life
values
for
ETU.
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).
HED
selected
these
ETU
DFR
half­
life
values
from
8
mancozeb
studies,
6
maneb
studies,
and
1
metiram
study
submitted.
HED's
based
its
selection
on
the
best
data
quality
to
represent
a
crop
and
climate
scenario
(
T.
Dole,
per.
com.,
7/
23/
04).
The
ETU
half­
life
results
from
the
1988
metiram
study
on
California
apples
(
MRID
413399­
01)
may
have
resulted
from
leaf
degradation
interference.
The
samples
on
this
study
were
not
dislodged
until
arriving
at
the
laboratory
following
overnight
shipment.
Current
guidelines
require
the
samples
to
be
dislodged
within
4
hours
of
collection
(
T.
Dole,
per.
com.,
7/
23/
04).

EFED
reviewed
ETU
half­
life
data
submitted
by
the
Mancozeb
Task
Force
(
Ollinger,
2005.,
Mar.
7,
2005).
Based
on
Biswas,
et
al.
(
2003),
EFED
estimated
the
mean
high­
end
ETU
TFR
on
homogenized
tomatoes
was
4.7
days.
It
should
be
noted
plant
food
items
for
wildlife
includes
leaves,
fruit,
pods,
and
seeds.
The
screening
level
half­
life
value
can't
be
limited
to
fruit,
only,
and
must
be
a
high­
end
estimate
across
all
plants
for
screening
level
assessments.
There
was
some
indication
of
ETU
translocation
to
tomatoes
(
Biswas
et
al,
2003),
however
the
information
provided
was
insufficient
to
conclude
ETU
is
systemic.

ETU
is
not
applied
in
the
environment,
by
itself,
but
is
a
degradate
of
the
Parent
EDBC.
Estimates
of
ETU
presence
on
wildlife
food
items
is
dependent
on
the
presence
of
the
Parent
EDBC.
As
long
as
the
Parent
EDBC
is
present,
ETU
will
be
produced
through
hydrolysis.
For
modeling
purposes,
the
estimated
1.6%
conversion
(
see
Table
II­
2)
of
Parent
EDBC
to
ETU
is
the
more
important
factor
in
determining
the
presence
of
ETU
than
the
half­
life
value
of
ETU.
This
means
EFED
expects
ETU
will
be
produced
after
each
application
of
the
Parent
EDBC.
The
presence
of
ETU
is
directly
dependent
on
the
degradation
rate
of
the
Parent
EDBC.
As
the
Parent
EDBC
degrades
ETU
will
be
produced.
EFED
is
estimating
this
level
to
be
1.6%
of
the
Parent
EDBC
based
on
foliar
10
conversion
rate.
Using
ETU
TFR
half­
life
modeling
values
identical
with
the
modeling
values
used
for
the
Parent
EDBC
insures
this
1.6%
change­
over
of
Parent
EDBC
to
ETU
is
included
in
the
ETU
exposure
estimate
and
more
accurately
reflects
ETU
exposure
to
terrestrial
wildlife.

For
modeling
purposes,
this
means
the
half­
life
of
the
degradate,
ETU,
needs
to
be
the
same
as
the
half­
life
of
the
Parent
EBDC.
Since
EFED
based
the
terrestrial
EEC
modeling
used
in
this
ETU
assessment
on
mancozeb's
use
pattern,
EFED
used
a
35­
day
TFR
half­
life
value
for
ETU's
terrestrial
EEC
modeling.
This
35­
day
half­
life
value
matches
the
half­
life
value
used
for
mancozeb's
terrestrial
EEC
modeling
used
in
the
mancozeb
RED.
This
wouldn't
be
the
case
if
EFED
expected
ETU's
TFR
half­
life
was
longer
than
the
Parent
EBDC.
In
such
cases,
EFED
would
use
the
high­
end
estimated
TFR
half­
life
value
of
ETU
because
EFED
would
expect
build­
up
of
ETU
beyond
the
TFR
half­
life
of
the
Parent
EBDC.
EFED
doesn't
expect
DFR
or
TFR
half­
life
values
for
ETU
to
be
longer
than
35
days.
Except
for
the
questionable
results
from
the
1988
metiram
study
on
California
apples
showing
a
41­
day
ETU
DFR
half­
life,
none
of
the
DFR
or
TFR
half­
life
values
listed
in
Table
II­
3
are
longer
than
35
days.

For
aquatic
exposure,
EFED
calculated
EECs
for
ETU
in
these
systems
using
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)
for
Tier
II
estimates.

EFED
looked
specifically
at
the
impact
of
ETU
from
EBDCs
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
2,600
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
resultant
ETU
from
EBDCs
turf
use
pattern
was
assessed
for
drinking
water
and
aquatic
environments
using
only
one
application
of
EBDCs
parents
at
17.4
lb
a.
i/
acre.
However,
ETU/
EDWCs
and
EECs
were
also
calculated/
characterized
for
the
possibility
of
three
applications
of
EBDCs
parents
at
17.4
lb
a.
i/
acre
at
5
and
7
days
intervals.

To
evaluate
the
potential
risk
to
aquatic
and
terrestrial
organisms,
from
ETU
exposure,
EFED
calculated
risk
quotients
(
RQs).
RQs
are
the
ratio
of
estimated
environmental
concentrations
(
EECs)
to
ecotoxicity
values
(
see
Appendix
IV).
EFED
based
the
EECs
for
ETU
on
maximum
application
rates
for
the
EBDCs'
registered
use
patterns.
EFED
compared
these
RQs
to
the
level
of
concern
(
LOC)
(
see
Appendix
IV
for
these
values)
to
decide
potential
risk
to
nontarget
organisms.

EFED
is
uncertain
about
ETU's
acute
risks
to
birds,
estuarine/
marine
fish,
estuarine/
marine
invertebrates,
and
aquatic
vascular
plants.
Because
EFED
lacks
chronic
toxicity
data,
EFED
is
uncertain
about
the
chronic
risks
to
birds.
EFED
needs
studies
(
see
appendices
III)
to
provide
this
toxicity
information.
EFED
is
seeking
testing
on
terrestrial
nontarget
plant
species
for
all
the
parent
compounds
to
evaluate
the
phytotoxicty
of
these
compounds.
EFED
is
reserving
terrestrial
plant
11
testing
requests
for
ETU
awaiting
the
results
of
the
parental
testing.
Currently,
the
Agency
does
not
perform
RQ
assessments
for
chronic
risk
to
plants,
acute
or
chronic
risks
to
nontarget
insects,
or
chronic
risk
from
granular
or
bait
formulations
to
birds
or
mammals.
EFED
also
uses
adverse
effect
incident
data
in
evaluating
a
chemical's
risk.

A
summary
of
the
risk
assessment
is
presented
in
a
diagram
(
Figure
II­
1)
which
shows
the
single
stressor,
ETU
in
blue,
and
the
assessment
endpoints
in
yellow.
It
also
shows
which
nontarget
organisms
are
at
potential
risk
and
where
areas
of
uncertainty
exists.
The
assessment
endpoints
include
the
potential
short­
term
(
that
is,
acute)
and
long­
lasting
(
that
is,
chronic)
effects
to
these
organisms
that
may
result
because
of
exposure
to
ETU.
Most
of
the
uncertainties
shown
in
Figure
II­
1
result
from
missing
data
although
some
of
the
uncertainties
are
due
to
lack
of
methodology.
For
example,
EFED
has
not
developed
a
method
for
evaluating
the
chronic
risks
to
plants.
12
Figure
II­
1.
Summary
of
Risk
Assessment
for
ETU.
4
The
issue
of
Bound
species
is
discussed
in
detail
in
the
accompanied
RED
chapters
for
metiram,
mancozeb
and
maneb.

13
III.
Integrated
Environmental
Risk
Characterization
a.
Overview
of
Environmental
Risk
Characterization
EFED
expects
ETU
to
be
a
potential
chronic
risk
to
mammals
(
LOCs
are
exceeded).
No
acute
LOCs
were
exceeded
for
freshwater
fish
and
freshwater
invertebrates.
No
acute
LOCs
were
exceeded
for
nonvascular
aquatic
plants.
The
nonvascular
aquatic
plant
testing
was
based
on
testing
in
1
of
4
surrogate
test
species.
Because
ETU
is,
acutely,
practically
nontoxic
to
mammals
EFED
expects
the
acute
risk
to
mammals
will
be
low.
Since
the
EBDCs
are
practically
nontoxic
to
bees
and
significant
bee
contact
with
ETU
is
unlikely,
EFED
expects
the
acute
risk
to
terrestrial
nontarget
insects
will
be
low.
Because
EFED
lacks
toxicity
data,
EFED
is
uncertain
about
ETU's
acute
risks
to
birds,
estuarine/
marine
fish,
estuarine/
marine
invertebrates,
and
aquatic
vascular
plants.
Because
EFED
lacks
chronic
toxicity
data,
EFED
is
uncertain
about
the
chronic
risks
to
birds.
EFED
is
reserving
the
need
for
chronic
toxicity
testing
on
freshwater
and
estuarine­
marine
animals
until
EFED
receives
and
reviews
acute
toxicity
studies
for
all
the
surrogate
freshwater
and
estuarine­
marine
organisms.
EFED
does
not
evaluate
the
chronic
risk
to
aquatic
plants
because
EFED
hasn't
developed
methods
to
assess
chronic
risk
to
plants.

ETU
is
a
product
of
degradation
of
applied
EBDC
fungicides
and
is
classified
by
the
Agency
as
a
B2
carcinogen
(
US
EPA
,2002).
Environmental
risk
characterization
requires
estimation
of
expected
environmental
concentrations
(
EECs)
of
ETU
in
various
environmental
compartments.
These
concentrations
are
dependent
on
physicochemical
properties
and
fate
and
transport
processes
for
EBDCs
(
ETU
parents)
as
well
as
those
for
ETU
itself.
EBDCs'
properties/
processes
are
important
in
characterizing
ETU
production
(
when,
where,
and
quantities/
rates),
while
ETU's
properties/
processes
are
important
in
characterizing
its
dissipation
through
degradation
and/
or
transportation
within/
into
various
environmental
compartments.

When
EBDCs
are
applied,
the
major
portion
will
reach
the
soil
directly
or
indirectly
through
wash­
off
from
plant
surfaces.
Another
much
smaller
amounts
of
EBDCs
might
reach
water
bodies
by
drift
and/
or
run­
off.

In
terrestrial
environments,
EBDCs
are
applied
to
growing,
rain
fed
and/
or
irrigated
crop
foliage.
Therefore,
moisture
is
expected
to
be
available
in
sufficient
quantities
to
cause
decomposition
of
these
compounds,
by
hydrolytic
reactions
into
EBDCs
complex
(
ETU
included)
at
plant
surfaces
and
in
soil
pore
water.
Hydrolytic
reactions
are
expected
to
be
variable
but
relatively
fast.
Most
conservative
estimation
indicates
that
applied
parent
EBDCs
can
be
converted
into
EBDCs
complex
(
ETU
included),
within
one
day,
one
week
and
two
weeks
from
the
last
application
of
metiram,
mancozeb
and
maneb,
respectively.
ETU
in
the
EBDCs
complex
is
expected
to
partition
into
soil
pore
water
while
most
of
the
other
constituents
of
the
EBDCs
complex
appear
to
partition
into
the
soil
particles
as
bound
species.
Unfortunately,
in
submitted
aerobic
soil
experiments,
no
complete
characterization
was
conducted
for
these
significant
bound
species;
and
claimed,
by
the
registrant,
to
be
dominated
by
ethylene
diamine
(
EDA)
without
experimental
proof.
In
these
experiments,
sulfur
material
balance
suggested
that
bound
species
are
suspicious
of
being
precursors
for
ETU
(
possible
presence
of
sulfur
in
the
Bound
species).
This
residue
(
the
bound
species)
4
is
persistent
and
appear
to
bio­
degrade
slowly
possibly
into
low
amounts
of
ETU
resulting
in
another
slow
but
continuous
5
Blazquez,
C.
H.
1973.
J.
Agric.
Food
Chem.
21(
3):
330­
332.

6
Lethal
condition
in
which
the
skull
is
defective
with
the
brain
exposed
or
extruding.

14
source
of
low
concentrations
of
ETU
in
the
soil
environment
(
over
that
produced
by
initial
hydrolysis).

In
contrast,
a
small
fraction
of
the
applied
parent
EBDCs
reaches
aquatic
environments
by
drift
resulting
in
very
low
parent
concentrations.
At
such
concentrations,
parent
EBDCs
reaching
water
bodies
would
be
highly
vulnerable
to
hydrolytic
decomposition
and
be
completely
converted
into
EBDCs
complex
(
ETU
included).
With
time,
hydrolytic
reactions
are
capable
of
increasing
the
concentration
of
ETU
in
the
EBDCs
complex
to
near
dominance.
However,
ETU
produced
in
these
aquatic
systems
is
expected
to
be
susceptible
to
degradation
by
microbial
activity
(
in
biologically
active
systems)
and/
or
by
indirect
photolysis.

Physicochemical
and
fate
properties
of
ETU
were
used
in
the
process
of
estimating
EECs
for
ETU.
Abiotic
hydrolysis
and
direct
photolysis
laboratory
studies
conducted
with
ETU
show
that
it
is
stable,
although
it
was
reported
to
be
highly
susceptible
to
indirect
photolysis
in
natural
waters.
Short
halflives
were
estimated
for
ETU
in
aerobic
soil
(
few
days)
while
field
dissipation
studies
suggested
longer
half­
lives
(<
one
week).
Given
its
high
solubility
and
mobility
(
water
solubility:
20,000
ppm,
K
d
,
Freundlich:
0.51
to
1.14),
ETU
has
the
potential,
at
least
in
part,
to
leach
to
ground
water.
However,
ETU
that
forms
and/
or
reaches
natural
surface
waters
may
not
persist
due
to
reported
short
indirect
photolysis
half­
lives
related
to
the
presence
of
sensitizers.
For
example,
ETU
degraded
with
a
half­
life
of
<
1
day
(
occurred
between
the
time
of
application
and
sampling
at
day
0)
in
a
natural
drainage
water
obtained
from
a
field
in
Florida5.

The
limited
ecotoxicological
data
for
ETU
does
not
exceed
the
acute
LOCs
for
freshwater
fish,
freshwater
invertebrates,
and
nonvascular
aquatic
plants.
In
contrast,
EBDCs
complex
(
suite
of
transient
species
and
degradation
products
from
the
parent
EBDC)
do
present
a
risk.
The
RQs,
for
the
EBDCs
complex,
exceed
LOCs
for
these
aquatic
organisms.
Based
on
this,
EFED
expects
an
early
acute
exposure
risk
to
these
aquatic
organisms
from
the
uses
of
the
EBDC
fungicides.
This
acute
risk
is
caused
by
the
EBDCs
complex
and
is
expected
to
disappear
over
time
as
the
complex
degrades
rather
quickly
into
ETU
by
hydrolytic
reactions
in
aquatic
environments.
The
acute
fish
studies
showing
risk
from
the
EBDCs
complex
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.
At
some
point
beyond
this
48
to
120­
hour
exposure
period,
EFED
would
expect
a
reduced
acute
toxicity
to
these
organism
when
the
conversion
of
the
EBDCs
complex
to
ETU
is
complete.

EFED
does
not
expect
a
significant
acute
risk
from
ETU
to
mammals.
ETU
is
practically
nontoxic
to
mammals
(
the
mouse
acute
oral
LD
50
is
2,300
mg/
kg).
Based
on
reported
incidents
in
Ecological
Incident
Information
System
(
EIIS),
EFED
has
not
been
able
to
document
any
adverse
effects
to
terrestrial
organisms
for
the
parent
EBDCs
or
ETU.
Because
ETU
is
practically
nontoxic
to
mammals
on
an
acute
basis
and
EFED
found
no
documented
incidents
linking
the
parent
EBDCs
or
ETU
to
adverse
effects
in
mammals,
EFED
did
not
calculate
acute
RQs
for
mammals.

Mammalian
ETU
Risk
Quotients
(
RQs)
exceed
the
chronic
Level
of
Concern
(
LOC)
for
all
mancozeb's
use
patterns.
ETU
effects
triggering
this
chronic
risk
were
based
on
developmental
defects
of
the
brain
(
that
is,
exencephaly6,
dilated
ventricles,
and
hypoplastic
cerebellum)
in
rats.
For
15
small
mammals
(
15­
gram)
feeding
on
short
grass,
the
ETU's
chronic
RQs
range
from
a
high
of
37
from
mancozeb
turf
applications
to
2
from
mancozeb
citrus
applications.
For
small
mammals
feeding
on
forage
and
small
insects,
the
chronic
RQs
range
from
a
high
of
21
from
mancozeb
turf
applications
to
2
from
mancozeb
vegetable
applications.
There
are
no
ETU
chronic
LOC
exceedances
to
small
mammalian
herbivore­
insectivores
from
mancozeb's
use
on
citrus.
For
medium
sized
mammals
(
35­
gram)
feeding
on
short
grass,
ETU's
chronic
RQ
range
from
26
for
turf
applications
of
mancozeb
to
1
on
citrus.
For
medium
sized
mammals
feeding
on
forage
and
small
insects,
ETU's
potential
chronic
risk
are
exceeded
for
all
mancozeb's
uses
except
mancozeb's
uses
on
citrus.
For
medium
sized
mammals
feeding
on
forage
and
small
insects,
the
RQs,
exceeding
the
LOC,
range
from
14
for
turf
applications
of
mancozeb
to
1
on
vegetables.
For
large
mammals
(
1,000
gram)
feeding
on
short
grass,
the
RQs
range
from
6
on
turf
to
1
on
bananas.
There
are
no
ETU
chronic
LOC
exceedances
to
large
mammals
from
mancozeb's
use
on
potato
&
sugar
beet,
fennel,
peanuts,
forestry
(
douglas
fir),
Christmas
tree
plantations,
tobacco,
cotton,
asparagus,
garlic
&
shallot,
ornamentals,
the
barley
crop
grouping.,
vegetables
or
citrus.
For
large
mammals
feeding
on
forage
and
small
insects,
ETU's
chronic
risk
are
exceeded
for
mancozeb's
uses
on
apples,
papaya,
pachysandra
groundcover,
and
turf
(
chronic
RQ
range
1
on
apples
to
3
on
turf),
only.
For
granivore
mammals
(
all
sizes),
no
ETU
chronic
LOC
from
mancozeb's
uses
were
exceeded.

EFED
calculated
the
EECs
for
ETU's
terrestrial
exposure
based
on
mancozeb's
use
pattern.
EFED
could
also
have
calculated
RQs
based
on
the
use
patterns
of
the
other
two
parent
compounds
for
ETU,
metiram
and
maneb.
EFED
decided
not
to
make
these
extra
calculations
since
expected
results
would
be
the
same.
Also,
mancozeb
has
the
broadest
use
pattern
(
that
is,
most
sites
of
application)
and
EFED
expected
mancozeb's
uses
would
provide
a
more
comprehensive
view
of
the
risks
posed
by
ETU.

EFED
presumes
applications
of
EBDCs
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
EBDCs
applications
will
result
in
degradation
of
parent
EBDCs
to
ETU
on
plant
surfaces.
Based
on
hydrolytic
reaction
rates,
this
degradation
is
estimated
to
occur
from
one
day
to
two
weeks
following
application.
The
frequent
applications
of
EBDCs
in
wet
conditions,
would
provide
a
continuous
exposure
to
ETU.

There
are
over
twenty
different
crop
groupings
listed
in
each
RED
for
mancozeb
and
maneb.
The
RED
for
metiram
shows
two
different
crop
groupings.
Each
of
these
groupings
represent
a
unique
use
pattern
based
on
rates
of
application,
number
of
applications
allowed
a
crop
cycle,
and
minimum
intervals
between
applications.
EBDCs
are
used
throughout
the
US.
Based
on
these
uses,
there
is
a
high
likelihood
that
applications
will
result
in
ETU
exposure
to
mammals.
Mammals
are
in
and
around
all
sites
included
in
labels.
As
an
example,
cottontail
rabbits,
deer,
raccoons,
opossums,
skunks,
woodchucks,
muskrats,
and
groundhogs
all
feed
on
parts
of
tomato
plants.
As
well
as
feeding,
some
of
these
animals
use
areas
where
tomatoes
are
grown
for
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
(
in
late
summer
or
early
fall)
which
coincides
with
the
timing
of
the
mammal
pursuits
mentioned.
EFED
expects
mammalian
exposure
to
ETU
to
be
continuous
during
this
time
period.
Even
though
EFED
expects
a
continuous
exposure
to
mammals
from
ETU,
the
developmental
study
used
for
ETU's
chronic
assessment
endpoint
results
from
a
short­
term
exposure.
This
means
that
even
a
single
application
could
result
in
a
potential
chronic
16
toxicity
risk
to
mammals
from
ETU
exposure.

As
mentioned
above,
EFED
has
not
been
able
to
document
any
adverse
effects
to
terrestrial
wildlife
for
EBDCs
or
ETU
based
on
reported
incidents
in
EIIS.
These
incident
reports
mainly
deal
with
field
mortality
(
that
is,
acute
exposure)
of
wildlife
and
phytotoxicity
issues.
EFED
contends
chronic
problems
that
affect
wildlife
from
the
use
of
the
parent
EBDCs,
whether
they
result
from
short­
term
or
long­
term
exposure,
would
go
unnoticed
in
the
field.
Because
of
this,
EFED
would
not
expect
incident
reports,
dealing
with
chronic
adverse
effects,
for
the
EBDCs
and
their
common
degradate,
ETU.

b.
Key
Issues
of
Uncertainty
i.
Environmental
Fate
Two
types
of
fate
studies
were
used
in
collecting
laboratory
and
field
fate
data
on
ETU.
The
1st
type
used
parent
EBDCs
as
the
test
substance
in
order
to
study
ETU
formation
from
these
parents.
The
2nd
type
used
ETU
as
the
test
substance
in
order
to
study
the
fate
of
ETU
in
various
experimental
laboratory
and
field
conditions.

In
calculating
EECs
for
ETU,
application
equivalent
rates
of
ETU
were
calculated
using
the
maximum
ETU
produced
in
the
1st
type
of
studies
(
laboratory
studies
were
used).
Uncertainty
exists
in
the
determined
maximum
ETU
because
of
problems
associated
with
parent
EBDCs
laboratory
studies
which
were
complicated
by
the
introduction
of
artifacts
before
the
experiments,
during
parent
preparation,
and
at
the
end
of
the
experiment
during
extraction.
In
these
experiments,
rapid
degradation
of
the
parent
occurred
before
time
zero
and
in
most
aqueous
solution
experiments,
an
EBDC
complex
(
suite
of
degradation
products)
rather
than
parent
was
actually
observed.
In
addition,
identification/
quantification
of
ETU
and
other
degradation
products
were
largely
dependent
on
the
TLC
methods
which
were
affected
by
poor
separation
of
the
degradates
and
the
occurrence
of
degradation
caused
by
solvent
systems
employed.
The
reader
is
referred
to
RED
chapters
of
EBDCs
for
more
information
about
stated
problems.
In
modeling,
complete
conversion
of
applied
parent
EBDCs
into
ETU
was
assumed
to
occur
at
application
resulting
in
another
uncertainty.
Fate
studies
have
shown
that
complete
conversion
of
applied
parent
EBDCs
into
ETU
does
not
occur
at
application
as
ETU
forms
by
more
than
one
processes
occurring
at
different
times
and
in
variable
rates.

For
the
2nd
type
of
studies,
uncertainty
exists
in
the
results
of
some
laboratory
and
field
experiments
(
unlabeled
ETU)
conducted
with
analytical
methods
not
sensitive
enough
to
measure
the
concentration
of
ETU
in
soil
and
water
(
LOQ
=
0.01
ppm).
Fortunately,
new
and
adequate
analytical
methods
were
used
in
water
monitoring
studies
(
LOQ
=
0.10
ppb
in
water
samples;
MRID
448804­
01).
Additionally,
in
these
ETU
studies,
identification
and
quantification
of
ETU
degradation
products
were
not
complete;
except
of
EU
(
ethyleneurea).
Therefore,
uncertainty
exists
on
conclusions
related
to
the
assignment
of
degradation
products
to
either
parent
EBDCs
or
ETU
or
both.
The
list
of
these
degradates
include:
HYD
(
hydantoine
or
glycolylurea),
J.
B.
(
Jaffe's
base),
Glycine,
IMID
(
2­
imidazoline),
and
EDA
(
ethylenediamine).
However,
these
degradates
are
considered
to
be
"
ETU
degradation
products"
based
on
results
of
studies
on
maneb
and
ETU
in
7
R.
C.
Rhodes
1977.
Studies
with
manganese
14C­
Ethylene
bis
dithiocarbamate
(
14C­
Maneb)
fungicide
and
14C­
Ethylenethiourea
(
14C­
ETU)
in
plants,
soil,
and
water.
J.
Agr.
Food
Chem.,
Vol.
25:
3,
pp528­
533.

17
plants,
soil,
and
water7.
18
ii.
Ecological
Effects
Because
EFED
lacks
toxicity
data,
EFED
is
uncertain
about
ETU's
acute
risks
to
birds,
estuarine/
marine
fish,
estuarine/
marine
invertebrates,
and
aquatic
vascular
plants.
Because
EFED
lacks
chronic
toxicity
data,
EFED
is
uncertain
about
the
chronic
risks
to
birds.
EFED
needs
effects
studies
(
see
appendices
III
and
V)
to
provide
this
toxicity
information.
EFED
is
seeking
testing
on
terrestrial
nontarget
plant
species
for
all
the
parent
compounds
to
evaluate
the
phytotoxicty
of
these
compounds.
EFED
is
reserving
terrestrial
plant
testing
requests
for
ETU
awaiting
the
results
of
the
parental
testing.
EFED
is
not
seeking
insect
testing
of
the
degradate,
ETU.
EFED
believes
substantial
ETU
exposure
to
honeybees
in
flight
or
while
foraging
on
the
nectar
or
pollen
producing
parts
of
plants
is
unlikely.
EFED
is
assuming
a
1.6%
conversion
rate
(
from
parent­
EBDCs
to
ETU
on
foliage)
for
terrestrial
exposure
as
a
conservative
estimate
of
exposure
to
ETU.
This
means
the
dominant
exposure
to
bees
would
be
from
the
parent
EBDCs
not
ETU.
Although
the
parent
EBDCs'
use
patterns
would
result
in
exposure
to
pollinating
insect
the
parent
EBDCs
are
practically
nontoxic
(
metiram,
maneb,
and
mancozeb
acute
contact
LD
50
s
=
437,
>
12,
and
>
179
µ
g/
bee
,
respectively)
to
honeybees
from
short­
term
contact
exposure
(
Guideline
141­
1)
and
there
have
been
no
reported
adverse
effects
to
pollinating
insects
resulting
from
the
parent
EBDCs'
use.
Finally,
EFED
believes
any
honeybee
acute
contact
toxicity
caused
by
ETU
would
have
been
expressed
in
the
acute
contact
LD
50
guideline
testing
performed
on
the
parent
compounds.

c.
Endangered
Species
Conclusions
Based
on
available
screening
level
information
there
is
a
potential
concern
for
chronic
ETU
effects
on
listed
mammals
should
exposure
actually
occur.
Chronic
ETU
RQs
exceed
LOCs
for
endangered
and
threatened
species
of
mammals.
The
Agency
does
not
currently
have
data
on
which
to
evaluate
the
toxicity
of
ETU
to
endangered
or
threatened
birds,
estuarine/
marine
fish,
or
aquatic
vascular
plants.
Thus,
risks
to
endangered
or
threatened
species
of
birds,
estuarine/
marine
fish,
or
aquatic
vascular
plants
from
ETU
exposure
is
uncertain.
EFED
is
requiring
the
data
to
assess
the
potential
risk
to
endangered
or
threatened
species
of
birds,
estuarine/
marine
fish,
or
aquatic
vascular
plants
through
this
document.
EFED
is
reserving
the
terrestrial
plant
ETU
data
needs
until
EFED
receives
and
completes
review
of
the
parent
EBDC's
toxicity
to
terrestrial
plants.

d.
Endocrine
Disruption
Concerns
The
Federal
Food,
Drug,
and
Cosmetic
Act
(
FFDCA)
requires
EPA,
as
amended
by
the
Food
Quality
Protection
Act
(
FQPA),
to
develop
a
screening
program.
This
program
is
to
decide
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
there
was
scientific
basis
for
including,
as
part
of
the
program,
the
androgen
and
thyroid
hormone
systems,
as
well
as
the
estrogen
hormone
system.
EPA
also
adopted
EDSTAC's
recommendation
including
in
the
Program
evaluations
of
potential
effects
in
wildlife.
For
pesticide
chemicals,
EPA
will
use
FIFRA
and
FFDCA
authority
to
require
the
wildlife
evaluations.
EPA
will
use
FFDCA
authority
to
evaluate
effects
in
wildlife
from
tests
that
Food
and
Drug
Administration
uses
to
discover
effects
in
humans.
As
the
science
develops
and
allows,
EPA
may
add
screening
of
more
hormone
systems
to
the
Endocrine
Disruptor
Screening
Program
(
EDSP).
19
The
mammalian
feeding
studies
for
ETU
performed
on
rats
and
dogs
ranged
in
time
from
3
to
4
months.
These
feeding
studies
found
the
following
effects:
changes
in
thyroid
hormones;
changes
in
liver
enzymes;
microscopic
changes
in
the
liver
and
thyroids;
increased
thyroid
weights;
and
increased
relative
liver
weights.
HED
reviewed
a
one­
dose
developmental
gavage
study
done
on
pregnant
laboratory
rats.
This
study
determined
that
treatment­
related
developmental
effects
caused
by
ETU
involved
gross
developmental
defects,
central
nervous
system
defects,
skeletal
deficiencies,
cryptorchidism
(
failure
of
one
or
more
testes
to
descend
into
the
scrotum),
and
decreased
fetal
weight.
See
Appendix
III
for
a
detailed
listing
of
the
studies
and
results.
These
toxicological
effects
noted
in
mammals
could
be
a
result
of
hormonal
disruptions
and
may
suggest
that
ETU
may
be
an
endocrine
disruptor.
Based
on
these
effects
in
mammals,
EFED
recommends
that
when
EPA
develops
suitable
screening
and
testing
protocols,
considered
under
the
Agency's
EDSP,
ETU
be
subjected
to
more
definitive
testing
to
better
characterize
effects
related
to
its
potential
endocrine
disruption.
20
IV.
Environmental
Fate
Assessment
Formation
of
ethylene
thiourea
(
ETU)
is
a
result
of
EBDCs
degradation.
ETU
formation
from
EBDCs
has
been
observed
in
laboratory
hydrolysis,
and
metabolism
studies,
as
well
as
in
field
studies.
Abiotic
hydrolysis
and
photolysis
laboratory
studies
with
ETU
show
that
ETU
is
stable
for
at
least
30
days.
Although
it
has
been
shown
that
ETU
rapidly
degrades
in
the
presence
of
microorganisms
(
half­
lives
of
few
days
in
soil
aerobic
conditions),
longer
ETU
half­
lives
in
the
field
have
been
reported
(<
one
week).

ETU
is
highly
soluble
and
mobile
with
potential
to
leach
to
ground
water
and/
or
reach
surface
water
by
runoff
in
dissolved
form.
However,
in
natural
surface
waters
indirect
photolysis
is
expected
to
affect
the
possibilities
for
surfacewater
contamination.
Soil
associated
Bound
Species,
suspected
producer
of
ETU,
can
also
reach
surface
water
adsorbed
on
soil
particles
and
carried
by
erosion.

a.
Production
from
EBDCs
in
Laboratory
and
Field
Studies
ETU
appears
to
be
the
main
transformation
product
of
the
EBDC
fungicides
that
results
from
abiotic
and
biotic
degradation
processes
in
both
field
and
laboratory
studies.
Other
transient
species
and
degradates
were
also
identified.
Qualitative
and
quantitative
characterization
of
the
degradates
in
laboratory
and
field
experiments
were
complicated
by
the
introduction
of
artifacts
before
the
experiments,
during
parent
preparation,
and
at
the
end
of
the
experiment
during
extraction.
In
these
experiments,
rapid
degradation
of
the
parent
occurred
before
time
zero
and
in
most
aqueous
solution
experiments,
EBDCs
complex
rather
than
parent
was
actually
used.
In
addition,
identification
of
transient
species
and
degradates
was
largely
dependent
on
the
TLC
methods
which
was
affected
by
poor
separation
of
the
degradates
and
the
occurrence
of
degradation
caused
by
the
solvent
systems
employed.

Hereunder
is
a
summary
of
reported
laboratory
data
on
degradation
of
EBDCs
and
production
of
ETU,
transient
species
and
other
transformation
products.
The
summary
covers
only
major
processes
and
should
be
considered
with
the
above
mentioned
experimental
uncertainties.

i.
Aqueous
Media
Hydrolysis
is
the
major
process
for
production
of
ETU
from
parent
EBDCs
in
aqueous
buffered
media;
parents
are
unstable
to
hydrolysis.
Table
IV­
1
lists
hydrolysis
half­
lives
and
degradation
products
for
metiram,
mancozeb
and
maneb
at
pH
7.
The
results
indicate
that
parent
EBDCs
are
highly
susceptible
to
hydrolysis
in
the
order
of
maneb
(
highest)
then
mancozeb
followed
by
metiram
(
lowest).
Initial
suite
of
degradation
products
included
transient
species,
ETU
and
other
degradation
products
(
i.
e.
the
EBDCs
Complex).
ETU
appears
to
increase
with
time
to
dominance
(
from
18%
up
to
36%
of
ETU
within
30
days)
while
transient
species
reach
maximums/
disappear
early.
ETU
has
been
shown
to
resist
hydrolysis,
indicating
that
a
complete
conversion
of
parent
EBDCs
into
hydrolysis
persistent
ETU,
is
possible
to
occur
in
most
environmentally
relevant
aqueous
media.
21
Table
IV­
1.
Summary
of
hydrolysis
studies
for
various
EBDCs
at
pH
7
(
Note:
to
arrive
at
%
ETU,
on
concentration
bases,
the
value
in
the
table
should
be
multiplied
by
0.385%).

Test
Material
1
and
(
Concentration
in
ppm)
Hallife
(
days)
Length
of
Study
(
Days)
Transient
Species
2
ETU
(%
of
Applied,
as
parent)
Other
Degradates
3
MRID
Reference
(
Analysis
Procedure)
Max.
at
(
Day)
Min.
at
(
Day)
Major
Minor
Metiram
Complex
(
6­
141)
ND
40
Carbimid
93%

(
5)
87%
(
40)
None
EU;
HYD;
Polar;
Unknowns
001551­
89
(
TLC)

Metiram
(
16.7)
1.8
10
Degradates
were
not
identified/
quantified
001467­
64
Mancozeb
(
20)
0.7
28
In
the
DER
for
the
addendum
(
MRID
402582­
01),
data
were
reported
only
in
range
of
values.
In
summary,
the
transient
species
was
EBIS;
ETU
reached
a
max.
of
21­
37%
at
day
2
and
declined
to
1­
7%
at
day
14;
major
degradates
were
EU,
HYD
and
unknowns;
and
minor
degradates
were
J.
B
and
ethylene
diamine
(
EDA).
000971­
62
402582­
01
(
TLC)

Maneb
(
10)
0.1
30
EBIS
47.7%
(
30)
No
decline
EU;
Unknowns
Three
unknowns
453936­
01
(
TLC)
1
In
the
case
of
the
first
metiram
study,
a
high
concentration
suspension
(
2,143
ppm)
was
used.
Only
the
dissolved
part
is
considered
here
and
is
referred
to
as
Metiram
Complex.
It
is
important
to
note
that,
during
the
experiment,
the
total
concentration
of
this
complex
changed
with
time
from
<
1%
of
the
parent
applied
(.
6ppm)
at
time
zero
to
nearly
7%
(.
141ppm)
at
the
end
of
the
experiment.
2
These
products
are
considered
as
transient
species
because
they
form
early
in
the
process,
reach
maximums
and
decline
sharply.
3
Major=
when
maximum
is
>
10%;
Minor=
when
maximum
is
<
10%.
ND=
Not
determined.

ii.
Soil
Systems
In
aerobic
soil
systems,
initial
hydrolysis
of
parent
EBDCs
appears
to
be
the
major
process
in
their
degradation
and
the
rapid
production
of
the
EBDCs
complex.
EFED
believes
that
short
aerobic
soil
half­
lives
reported
for
all
EBDCs,
by
the
registrant,
are
mainly
related
to
the
rapid
hydrolytic
conversion
of
parent
EBDCs
into
EBDCs
complex.
Following
initial
hydrolysis,
the
major
part
of
EBDCs
complex
becomes
bound
to
the
soil
(
bound
species)
and
possibly
degrade
slowly
into
ETU.
Therefore,
ETU
is
produced
in
the
soil
system
partially
by
initial
rapid
hydrolysis
of
parent
EBDCs
and
possibly
by
the
slow
biodegradation
of
the
bound
species
(
long
Bound
species
half­
lives)
.

Following
formation,
produced
ETU
is
subjected
to
rapid
degradation
(
short
aerobic
soil
half­
lives).
Final
ETU
concentration
is
therefore
dependent
on
two
competing
processes:
formation
(
abiotic
and
biotic)
and
biotic
degradation.
As
shown
in
Table
IV­
2,
ETU
forms
in
aerobic
soils
as
a
major
degradate
at
the
short
term
and
end
up
as
a
minor
one
at
the
long
term.
Data
indicates
that
the
range
of
maximum
conversion
rates,
on
concentration
basis,
is
between
0.9
and
9.3%
occurring
mainly
within
one
week.
22
Table
IV­
2.
Summary
of
aerobic
soil
studies
for
EBDCs
(
Note:
to
arrive
at
%
ETU,
on
concentration
bases,
the
value
in
the
table
should
be
multiplied
by
0.385%).

Soil
Texture
and
(
Parent
EBDCs
Concentration
in
ppm)
Hal­
life
(
days)
1
Length
of
Study
(
Days)
Transient
Species
2
ETU
(%
of
Applied)
Other
Degradates
3
MRID
Reference
(
Analysis
Procedure)
Max.
at
(
Day)
Min.
at
(
Day)
Major
Minor
Metiram
Loam
(.
10)
<
1
454
365
EBIS
12.5%
(
4)
<
1%
(
30)
None
Unknown
001552­
88
(
TLC)

Loamy
Sand
(.
10)
<
1
388
365
EBIS
2.3%
(
1)
<
1%
(
60)
None
Unknown
Silt
Loam
(.
20)
7­
33
390
59
EBIS
4.1%
(
7)
<
1%
(
59)
None
EU
451452­
03
(
HPLC/
MS)

Loamy
Sand
(.
8)
1
387
365
TDIT
EBIS
Carbimid
11.2%
(
2)
0.0%
(
14)
None
EU
459069­
01
(
HPLC/
LC)

Mancozeb
Sandy
Loam
(
3.3)
<
0.1
121
120
EBIS
22.0%
(
1)
2.2%
(
120)
EU
Unknowns
457445­
01
(
HPLC/
TLC)

Loamy
Sand
(
3.3)
<
0.1
161
120
EBIS
24.8%
(
1)
1.3%
(
120)
EU
Unknowns
Silty
Clay
Loam
(
3.3)
<
0.1
143
120
EBIS
14.7%
(
1)
<
1%
(
120)
EU
Unknowns
Maneb
Loamy
Sand
(
8.78)
Parent
Never
Detected
145
32
EBIS
Carbimid
20.4%
(
7)
13%
(
32)
None
EU;
Unknowns
405852­
01
(
TLC)

Sandy
Loam
(
9.12)
Parent
Never
Detected
75
30
EBIS
Carbimid
10.0%
(
30)
No
decline
EU;
Unknowns
None
Silt
Loam
(
15­
21)
<
1
270
60
EBIS
7.2%
(
1)
<
1%
(
30)
EU;
Unknowns
None
451452­
02
(
HPLC/
MS)

1
Top
values
are
half­
lives
calculated,
by
the
registrant,
for
parent
EBDCs
(
from
CS2
data).
Bottom
values
are
halflives
calculated,
by
EFED,
for
EBDCs
complex
(
from
CO2
data)
2
These
products
are
considered
as
transient
species
because
they
form
early
in
the
process,
reach
maximums
and
decline
sharply.
3
Major=
when
maximum
is
>
10%;
Minor=
when
maximum
is
<
10%.

iii.
Water/
Sediment
Systems
Processes
occurring
in
water/
sediment
systems
appear
to
be
similar
to
those
in
the
soil
systems.
Initial
hydrolysis
of
parent
EBDCs
appears
to
be
a
major
process
in
the
rapid
production
of
the
EBDCs
complex
and
the
short
half­
lives
reported
by
the
registrant
for
all
EBDCs.
Following
initial
hydrolysis,
the
major
part
of
the
EBDCs
complex
becomes
bound
to
the
sediment
as
bound
species
8
Nash
R.
G.
and
Beall
L.
M.
1980.
J
Agric
Food
Chem
28:
322.

23
and
appear
to
degrade
slowly
possibly
into
ETU;
which
partitions
into
the
water
column.
Unlike
the
soil
system,
data
indicate
that
ETU
remained
the
major
degradation
product
in
the
system
as
a
whole.
The
range
of
maximum
conversion
rates,
on
concentration
basis,
observed
in
the
three
aquatic
studies
was
from
15
to
24%
occurring
within
3
days
(
Table
IV­
3).

Table
IV­
3.
Summary
of
aerobic
soil
studies
for
EBDCs
(
Note:
to
arrive
at
%
ETU,
on
concentration
bases,
the
value
in
the
table
should
be
multiplied
by
0.385%).

Water/
Sediment
System
and
(
Parent
EBDCs
Concentration)
Hal­
life
(
days)
1
Length
of
Study
(
Days)
Transient
Species
2
ETU
(%
of
Applied)
Other
Degradates
3
MRID
Reference
(
Analysis
Procedure)
Max.
at
(
Day)
Min.
at
(
Day)
Major
Minor
Metiram
(
1:
1.4­
1.5
Aerobic
water:
Anaerobic
sediment)

Pond
water/
Loamy
Sand
Sediment
(
0.6
ppm)
0.9
858
100
EBIS
61.4%
(
1)
47%
(
100)
Unknowns
EU
459334­
01
(
HPLC)

Stream
water/
Loamy
Sand
Sediment
(
0.6
ppm)
0.5
173
100
EBIS
52.2%
(
1)
20%
(
100)
Unknowns
EU
Mancozeb
(
soil
slurry
containing
48%
moisture)

Soil
Slurry
(
20
ppm)
92
ND
196
Degradates
were
not
identified/
quantified
000888­
20
402582­
03
Maneb
(
8:
1
Anaerobic
water:
Anaerobic
sediment)

Lake
water/
Loamy
Sand
Sediment
(
9
ppm)
Parent
never
detected
ND
275
EBIS
38.6%
(
3)
7.3%
(
275)
EU
EU
Unknowns
001633­
35
(
TLC)

1
Top
values
are
half­
lives
calculated,
by
the
registrant,
for
parent
EBDCs
(
from
CS2
data).
Bottom
values
are
halflives
calculated,
by
EFED,
for
EBDCs
complex
(
from
CO2
data)
2
These
products
are
considered
as
transient
species
because
they
form
early
in
the
process,
reach
maximums
and
decline
sharply.
3
Major=
when
maximum
is
>
10%;
Minor=
when
maximum
is
<
10%.
ND=
Not
Determined
(
No
CO2
data)

b.
Chemical
Identity
and
Physicochemical
Properties
ETU
is
a
common
degradate
of
the
EBDC
fungicides
mancozeb,
maneb,
metiram
and
the
no
longer
registered
zineb.
It
is
also
used
industrially
as
a
cross
linking
agent
in
the
manufacturing
of
synthetic
rubbers.
The
chemical
structure
and
physical
chemical
characteristics
of
ETU
are
listed
in
Table
IV­
4.

Considering
the
highest
vapor
pressure
value
alone(
Table
IV­
4),
ETU
is
expected
to
partition
into
the
air
from
dry
soil
surfaces.
However,
its
high
water
solubility/
relatively
low
Henry's
law
constant
may
render
such
partition
unimportant
because
ETU
forms
from
EBDCs
only
when
water
is
present
(
i.
e.
in
wet
soil
or
water
bodies).
A
high
water
solubility
is
reported
for
ETU
which
makes
it
readily
available
for
leaching
in
soils.
Data
collected
from
a
microagroecosystem
chamber
indicate
that
small
amounts
of
ethylene
thiourea
may
volatilize
from
soil
and
plant
surfaces8.
Also,
ETU
was
not
detected
in
a
US
ambient
air
monitoring
study
of
the
USEPA
designated
189
Hazardous
Air
9
Kelly
T.
J.
et
al.
1994.
Environ
Sci.
Technol
28:
378­
87
10
Sue
Xu.
2000.
Environmental
Fate
of
Ethylenethiourea,
California
Department
of
Pesticide
Regulations,
CA,
USA;
and
IUPAC.
1977.
Ethylenethiourea,
Pure
&
Appl.
Chem.
49,
675­
689.

24
Pollutants9(
1).
[(
1)
The
low
K
ow
value
for
ETU,
suggests
that
it
will
not
significantly
bio­
concentrated
by
aquatic
organisms
such
as
fish.
Table
IV­
4.
Nomenclature
and
physical
chemical
identity
of
ETU.

CAS
2­
Imidazolidinethione
Structure
of
ETU
CAS
Registry
No.
96­
45­
7
PC
Code
Not
applicable
Molecular
Weight
102.2
(
C3­
H6­
N2­
S)

K
OW
0.2
(
MRID
406510­
01)

Vapor
Pressure
1.28x10­
3
and
6.59x10­
6
atm.*

Henry's
Law
constant1
3.4X10­
7
atm.
m3
mole­
1**

Water
Solubility
20,000
ppm
@
20
oC
and
90,000
ppm
@
60
oC
*
The
first
value
is
converted
from
a
value
of
9.728x10­
1
mm
Hg
or
torr;
the
second
value
was
reported
by
Neely
WB,
Blau
GE;
1985.
Environmental
Exposure
from
Chemicals.
Boca
Raton,
FL:
CRC
Press
pp.
31
(
converted
from
reported
value
of
5.01x10­
3
mm
Hg
or
torr).
**
Estimated
by
using
a
fragment
constant
estimation
method
by
Meylan
W.
M,
Howard
P.
H.
1991.
Env.
Tox.
Chem
10:
1283­
93.

c.
Fate
Processes
ETU
is
mainly
produced
from
hydrolytic
degradation
of
parent
EBDCs
following
its
application
to
soils
and/
or
after
reaching
water
bodies
by
drift
as
part
of
the
resultant
EBDCs
complex.
In
these
systems,
un­
identified
species
of
the
formed
EBDCs
complex
partitions,
in
significant
amounts,
between
the
solid
(
bound
species)
and
liquid
phases.
ETU
is
further
produced
by
hydrolytic
reactions
for
the
part
left
in
pore
water/
water
bodies
and
by
bio­
degradation
for
the
significant
part
bound
to
soil/
sediment
particles
(
bound
species).

Table
IV­
5
contains
a
summary
of
data
obtained
from
guideline
studies
conducted
on
ETU
as
a
test
substance.
Based
on
this
data,
ETU
is
expected
to
be
highly
susceptible
to
aerobic
soil
degradation,
but
stable
to
water
hydrolysis/
direct
photolysis
as
well
as
soil
photolysis.
While
ETU
is
stable
to
laboratory
direct
photolysis
in
sterile
water,
aqueous
photolysis
(
indirect
photolysis)
was
considered
to
be
a
major
degradation
pathway
for
ETU
in
natural
water
systems10.
In
the
soil
system,
ETU
lacks
stability
which
can
limit
its
availability
for
leaching
but
its
high
solubility/
mobility
can
cause
it
to
leach,
at
low
concentrations,
into
ground
water
or
be
transported
in
solution
into
surfacewater.

Table
IV­
5.
Environmental
fate
data
summary
for
ETU.

Parameter
Value
Source
(
MRID
)

Hydrolysis
Stable
@
25
oC
and
pH
5,
7,
and
9
404661­
03
Photolysis
Stable
in
pH
7
sterile
buffered
water
404661­
02
1­
4
days
in
natural
waters
(
indirect
photolysis)
8
Parameter
Value
Source
(
MRID
)

11
Ross,
R.
D.,
Crosby,
D.
G.
1973.
Photolysis
of
Ethylenethiourea.
J.
Agr.
Food
Chem.,
21(
3):
335­
337.

25
Stable
on
soil
404661­
01
Aerobic
Soil
2
Metabolism
t1/
2=
1.6
days
in
Collamer
silt
loam
at
70%
of
the
WHC
1
t1/
2=
1.4
days
in
Oakville
sand
at
70%
of
the
WHC
t1/
2=
3.2
days
in
Collamer
silt
loam
at
40%
of
the
WHC
451564­
01
Anaerobic
Soil;
Aerobic
Aquatic
Metabolism;
and
Bio­
accumulation
Factor
:
No
acceptable
studies.

Anaerobic
Aquatic
Metabolism
t1/
2=
149
days
in
a
1:
8
lake
sediment:
water
ratio.
t1/
2=
29­
35
days
in
a
48%
moisture
slurry.
001633­
35
000888­
20&
402582­
03
Adsorption
Coefficients
(
L
Kg­
1)
Sand
Kd
=
0.73
and
KOC=
150
Silty
Loam
Kd=
1.14
and
KOC=
57
Sandy
Loam
Kd=
0.67
and
KOC=
42
Clay
Loam
Kd=
0.51
and
KOC=
34
Clay
Loam
Kd
=
5
and
KOC=
54
Silty
Clay
Loam
Kd=
9
and
KOC=
276
Sandy
Loam
Kd=
2
and
KOC=
783
Silty
Loam
Kd=
3
and
KOC=
165
Clay
Kd=
2
and
KOC=
855
River
Silt
Kd=
29
and
KOC=
464
002588­
96
000971­
58
Field
Dissipation
DT50
=
1­
6
days
or
t
½
=
4
days
in
a
fine
sand
soil
DT50
=
<
7
days
in
Keyport
silt
loam
soil
Accession
No.
255229
000889­
23
Accumulation
in
Fish
Waived
(
Octanol/
water
coefficient=
0.5)

1
WHC=
water
holding
capacity
at
a
bar.
2
This
same
study
may
have
been
also
submitted
under
MRID
452251­
01.

i.
Aqueous
Solutions
In
a
30­
day
hydrolysis
study,
no
detectable
degradation
of
14C­
ETU
occurred
in
water
at
pH
5,
7,
and
9
(
MRID
404661­
03),
therefore
ETU
is
expected
to
be
stable
to
hydrolysis
in
the
environment.
No
significant
photo­
degradation
was
observed
for
14C­
ETU
during
a
30­
day
experiment
indicating
ETU
is
stable
to
aqueous
photolysis
(
MRID
404661­
02).
Similar
results
were
reported
for
photolysis
in
de­
ionized
water
by
Ross
and
Crosby11.
Lack
of
photolysis
was
attributed
to
the
fact
that
ETU
does
not
absorb
energy
in
the
sunlight
region
as
maximum
absorbency
lies
at
240
nm.

In
other
photolysis
experiments
reported
by
Ross
and
Crosby.,
rapid
loss
of
ETU
occurred
in
the
presence
of
dissolved
oxygen
and
sensitizers
such
as
acetone
(
loss
of
95%
within
4
hours)
or
riboflavin.
Identified
degradation
products
included
EU,
glycine,
and
glycine
sulfate
with
the
sulfate
quantitatively
accounting
for
the
sulfur
from
decomposed
ETU.
Furthermore,
50­
90%
of
ETU
decomposed
within
3
to
24
days
when
mixed
with
boiled
drainage
water
and
exposed
to
sunlight
compared
to
no
effects
occurred
in
the
dark
controls.
The
authors
suggested
that
natural
photosensitizers
present
in
the
drainage
water
may
have
played
an
important
role
in
the
observed
photo­
degradation
of
ETU.
As
cited
by
the
registrant,
the
same
workers
demonstrated
later
that
exposure
to
light
resulted
in
the
formation
of
stable
photooxidants
(
tryptophane
and
tyrosine),
which
12
Ross,
R.
D.
1974.
Photooxidation
in
Agricultural
Waters.
Thesis,
University
of
California,
Davis,
California,
USA.

13
Engst,
R.
1977.
Pure
&
Appl.
Chem.
49,
p.
675.

14
Cruickshank,
P.
A.
and
Jarrow,
H.
C.
1973.
J.
Agric.
Food
Chem.
21
(
3):
333­
335.

26
were
capable
of
degrading
ETU
in
a
dark
soil
environment12.
It
has
been
postulated
that
these
amino
acids
are
capable
of
oxidizing
ETU
through
their
ability
to
form
hydroperoxides13.
Cruickshank
and
Jarrow14
have
confirmed
that
there
are
many
sensitizers
capable
of
catalyzing
the
photo­
oxidation
of
ETU.

ii.
Soil
Systems
In
the
most
recent
7­
14­
day
supplemental
aerobic
soil
study,
Collamer
silt
loam
(
10%
clay,
pH
6.1,
2.09%
OC,
and
13
meq/
100
g
CEC)
and
Oakville
sand
(
2%
clay,
pH
6.8,
1.22%
OC,
and
6
meq/
100
g
CEC)
were
treated
with
non­
radiolabeled
ETU
at
a
nominal
application
rate
of
5
ppm
(
MRID
452251­
01).
Calculated
first
order
half­
lives
were
1.6
or
3.2
days
in
the
silt
loam
soil
moistened
to
70%
or
40%
of
the
WHC,
respectively
and
1.4
days
in
the
sandy
soil
moistened
to
70%
of
the
WHC.
This
study
was
conducted
with
the
objective
of
determining
the
kinetics
for
ETU
degradation
in
aerobic
soil.
Un­
extracted
residues
and
CO
2
were
not
measured
and
material
balance
was
not
determined.
Ethyleneurea
(
EU)
was
the
only
degradate
monitored
declining
to
<
1%
after
reaching
a
maximum
of
only
3­
3.4%
of
the
applied
ETU
at
<
1­
2
days
.
Results
indicate
that
ETU
is
not
persistent
in
the
aerobic
soil
environment
and
that
a
slight
decrease
in
the
rate
of
bio­
degradation
is
expected
with
reduction
of
available
soil
moisture.

In
a
previous
supplemental
study
14C­
ETU,
at
10
ppm,
degraded
with
a
half­
life
of
<
2
days
in
silt
loam
soil
incubated
in
the
dark
at
23
±
0.6
oC
and
23%
soil
moisture
content
(
MRID
408387­
01).
At
day
2,
56%
of
the
applied
radioactivity
was
extractable
and
was
20%
as
EU
and
36%
un­
known.
By
the
end
of
this
93­
day
study,
un­
identified/
un­
extractable
14C­
residue
comprise
88%
of
the
applied
radioactivity
and
14CO
2
totaled
40%.
The
interpretation
of
the
results
was
complicated
by
not
specifying
purity
of
the
test
substance,
incomplete
characterization
of
residue,
and
the
extremely
variable
material
balance
(
ranged
from
66­
131%
of
the
applied
radioactivity
during
the
study).

ETU
degradation
pattern
and
rates
on
soil
for
irradiated
and
dark
control
samples
were
almost
identical
indicating
that
photo­
degradation
is
not
expected
to
affect
the
environmental
fate
of
ETU
present
on
soil
surfaces
(
MRID
404661­
01).

iii.
Sediment/
Water
Systems
In
an
anaerobic
aquatic
soil
study,
the
natural
lake
Mendota
sediment
(
55%
sand,
40%
silt,
5%
clay,
8.3%
organic
matter,
7.9
pH
and
14
meq/
100g
CEC)
and
water
(
pH
7.9
and
dissolved
oxygen
9
ppm)
were
fortified
with
ethylene­
labeled
14C­
maneb
at
.9
ppm
level
(
MRID
001633­
35).
Maneb
was
never
identified
and
appear
to
have
degraded
by
hydrolysis
into
the
transient
EBIS,
two
major
degradates
ETU
and
EU,
and
one
minor
un­
identified
degradate.
ETU
was
more
prominent
in
the
water
phase
reflecting
its
high
solubility.
In
the
total
system,
ETU
degraded
very
slowly
from
a
maximum
concentration
of
39%
on
day
3
with
an
estimated
half­
life
of
149
days.
Therefore,
ETU
is
expected
to
be
reasonably
stable
under
anaerobic
aquatic
conditions.
Only
TLC
was
used
for
quantification
of
degradates
and
assigned
R
f
values
varied
from
one
plate
to
another.
This
causes
27
uncertainty
on
conclusions
drawn
from
the
results
of
the
study.

Additionally,
in
a
supplemental
anaerobic
aquatic
metabolism
study,
ETU
(
at
0.5
ppm
level)
degraded
with
a
reported
half­
life
ranging
from
29
to
35
days
(
MRID
000888­
20
and
Addendum
402582­
03).
The
study
used
a
sediment
slurry
(
from
a
pond
in
Newtown,
PA)
incubated
in
the
dark
at
pH
7
to
7.5
and
48%
moisture
with
anaerobic
conditions
established
by
flushing
with
nitrogen.
Although
the
study
didn't
fully
investigate
the
fate
of
ETU
in
the
aquatic
soil/
water
system,
the
results
suggest
that
anaerobic
conditions
appear
to
be
conductive
for
slowing
down
ETU
decomposition
in
such
systems
compared
to
aerobic
soil
systems.

d.
Mobility
A
24
hour
14C­
ETU
batch
equilibrium
study
(
MRID
002588­
96)
indicates
that
"
ETU
residue
containing
significant
quantities
of
ETU"
was
characterized
by
very
high
mobility
in
clay
loam
and
sandy
loam
soils
and
was
highly
mobile
in
silt
loam
and
sand
soils
(
Table
IV­
6).
Initially,
reported
data
indicate
extensive
degradation
of
ETU
was
found
in
the
supernatant
after
the
24­
hour
adsorption
period.
The
radioactivity
in
the
supernatant
consisted
of
ETU
+
HYD
"
hydantoin"
(
29­
61%);
EDA
"
ethylenediamine"
+
J.
B
"
Jaffe's
base"
(
7­
22%);
EU
"
ethyleneurea"
(
17%);
and
unidentified
radioactivity
(
22­
39%).
Later,
the
registrant,
claimed
that
the
observed
degradation
products
might
have
been
"
TLC
artifacts"
as
in
a
separate
but
similar
experiment,
the
registrant
found
that
86­
100%
of
the
radioactivity
in
the
supernatant
was
ETU.
EFED
reviewer
noted
the
possibility
of
degradation
of
ETU
before
conducting
the
experiment
but
concluded
that
it
is
clear
that
"
ETU
residues"
included
significant
quantities
of
ETU
and
shown
to
be
very
mobile.

Table
IV­
6.
Soil
characteristics
and
the
adsorption
parameters
of
the
soils
used
in
14C­
ETU
adsorption/
desorption
study.

Source
Georgia
Pennsylvania
Georgia
Mississippi
Soil
Textural
Class
Sand
Silt
Loam
Sandy
Loam
Clay
Loam
Clay
4%
20%
12%
28%

pH
(
water)
5.7
6.4
5.9
7.4
C.
E.
C
(
meq/
100
g)
4
10
6
13
Organic
Carbon
0.5%
2.0%
1.6%
1.5%

Kad
0.73
1.14
0.67
0.51
1/
n
0.522
0.327
0.469
0.406
Koc
150
57
42
34
Mobility
Class
High
Very
High
In
a
supplemental
study
(
Accession
Number
2552­
29),
14C­
ETU
mobility
was
investigated
by
the
TLC
method
in
which
determined
R
f
values
ranged
from
0.61
to
1.0
(
Table
IV­
7).
These
values
were
taken
to
indicate
medium
to
high
mobility.
Adsorption
was
positively
correlated
to
organic
carbon
content
of
the
soils.
In
one
of
the
soils
(
Hagerstown
silty
clay
loam),
ETU
residues
were
immobile
after
six
days
of
dry
incubation,
however,
it
became
slightly
mobile
(
R
f
.0.2)
when
the
residue
were
subjected
to
a
wet­
dry
cycle.
In
contrast,
a
previous
experiment
conducted
with
the
same
soils
(
MRID
000658­
59)
showed
parent
maneb
to
be
characterized
with
immobility
to
medium
mobility
(
Table
IV­
7).
15
Meylan
W.
M.
et
al
1992.
Environ
Sci
Technol
26:
1560­
67
28
Table
IV­
7.
Soil
characteristics
and
the
adsorption
parameters
of
the
soils
used
in
14C­
ETU
adsorption/
desorption
study1.

Soil
Name
Celeryville
muck
Lakeland
SL
Barnes
CL
Hagerstown
SiCL
Norfolk
SL
Textural
Class
Muck
soil
Sandy
Loam
Clay
Loam
Silty
Clay
Loam
Sandy
Loam
Clay
Content
Not
determined
12%
34.4%
39.5%
11%

pH
(
water)
5.0
6.4
7.4
6.8
5.1
Field
Capacity
113.0%
8.5%
28.5
25.8%
6.5%

Organic
Carbon
52.56%
0.52%
4.01%
1.45%
0.08%

Rf
for
ETU
0.61
1.00
0.83
0.96
0.96
Mobility
Class
for
ETU
Medium
Very
high
Rf
for
maneb
1
0.00
0.10
0.17
0.42
Mobility
Class
for
maneb
Immobile
Slight
Medium
1
This
study
is
a
published
article
by
Helling,
C.
S.
and
Thompson
S.
M.
1974.
Azide
and
ethylenethiourea
mobility
in
soils.
Soil
Science
Society
of
America
Proc.
38:
79­
85.

In
a
supplemental
column
leaching
study
(
MRID
405883­
01),
14C­
ETU
was
applied,
to
four
soils
at
10
ppm,
aged
for
24
hours,
and
resultant
residues
(
un­
identified)
were
leached
for
1
to
25
days
with
25"
de­
ionized
water.
The
radioactivity
leaching
profiles
indicated
that
"
14C­
ETU
residues"
were
very
highly
mobile
in
the
sandy
loam
soil
and
were
very
mobile
in
the
clay
loam
and
the
two
silt
loam
soils.
The
leachate
from
the
sandy
loam
soil
columns
contained
91%
of
the
applied
radioactivity
while
it
contained
22­
46%
of
the
applied
radioactivity
in
the
other
three
soils.
After
leaching,
the
greatest
concentration
of
radioactivity
in
the
soil
columns
was
in
the
top
and
was
5%
in
the
sandy
loam
column
and
18­
55%
in
the
other
three
soils.
Many
problems
were
associated
with
this
experiment
including:
inadequate
separation
between
ETU
and
its
degradates
in
the
TLC
system
used;
ETU
had
degraded
in
all
four
soils
prior
to
aging
and
was
not
detected
in
the
two
silt
loam
soils
after
aging;
and
most
degradates
were
not
characterized
at
any
point
in
the
experiment.
Therefore,
data
presented
preclude
any
conclusions
on
the
identity
of
the
leached
materials
as
it
can
only
be
referred
to
as
"
14CETU
residues"
.

Structural
method,
estimated
a
K
oc
value
of
6.5
for
ETU
based
on
molecular
connectivity
indices15.
This
estimated
value
supports
results
of
studies
indicating
very
high
mobility
of
ETU
in
the
soil
system.
Therefore,
studies
indicating
different
conclusions
may
have
been
affected
by
degradation
of
ETU
prior
to
and/
or
during
the
aging
process.

e.
Field
Dissipation
In
a
supplemental
field
study,
ETU
was
applied
to
Immokalee
fine
sand
soil
giving
an
extremely
high
zero
concentration
of
220
ppm
(
Accession
No
255229).
Following
application,
ETU
degraded
with
an
estimated
half­
life
of
1­
6
days.
EFED
calculated
first
order
half­
life
(
t
½
)
is
equal
to
4
days
(
R2=
0.90)
using
reported
data
from
this
study.
Patterns
of
formation
and
decline
of
the
degradates
were
not
addressed.
16
R.
C.
Rhodes
1977.
Studies
with
manganese
14C­
Ethylene
bis
dithiocarbamate
(
14C­
Maneb)
fungicide
and
14C­
Ethylenethiourea
(
14C­
ETU)
in
plants,
soil,
and
water.
J.
Agr.
Food
Chem.,
Vol.
25:
3,
pp528­
533.

29
In
another
supplemental
field
dissipation
study,
14C­
ETU,
at
a
rate
of
2
lb
a.
i/
acre,
was
studied
using
in
situ
soil
columns
of
Keyport
silt
loam
soil
(
Clay=
21%,
O.
C=
1.34%,
pH=
5.4,
and
CEC=
9
meq/
100g)
isolated
by
12"
sections
of
4"
diameter
stainless
steel
tubing.
The
study
was
conducted
for
52
weeks
and
received
a
total
of
54"
of
rainfall
(
MRID
000889­
23).
Half
life
of
1
to
4
weeks
(
DT
50
.
16
days)
was
estimated
from
the
"
total
radioactivity"
remained
in
the
whole
12"
soil
column.
This
half­
life
was
taken
to
represent
the
overall
half­
life
for
ETU
and
its
degradation
products.
Although
no
data
was
reported
for
ETU
itself,
it
was
claimed
that
specific
analysis
showed
a
half­
life
of
<
1
week
for
intact
14C­
ETU.
Only
58%
of
the
applied
radioactivity
was
extractable
after
1
week.
TLC
analysis
of
this
extractable
radioactivity
showed
that
79%
(
i.
e
46%
of
the
total)
was
EU
and
the
rest
(
i.
e
12%
of
the
total)
was
polar
material
which
remained
at
the
origin
of
the
TLC
plates.
The
results
of
this
study
were
also
reported
by
Rhodes
elsewhere16
f.
Bio­
accumulation
A
waiver
for
the
fish
bio­
accumulation
study
was
granted
based
on
the
determined
octanol/
water
partitioning
coefficient
of
0.2
(
MRID
406510­
01);
therefore
ETU
is
not
expected
to
accumulate
in
fish.

g.
Transformation
Products
Tables
IV­
8
and
IV­
9
summarize
data
reported
on
various
transformation
products
of
ETU
in
submitted
fate
studies
and
in
the
literature.
Most
of
these
same
transformation
products
were
also
reported
to
be
present
(
along
transient
species
and
ETU)
in
fate
studies
for
various
EBDCs
(
test
material
is
one
of
the
EBDCs).
This
suggests
that
EBDCs
degrade
to
ETU,
through
various
transient
species.
Formed
ETU
appears
to
then
degrade
into
various
ETU
transformation
products
and
CO
2
.

Table
IV­
8.
Identity/
structure
of
ETU
transformation
products.

Transformation
Product
Name
CAS
Number
Structure
Abbr.*
Common
IUPAC
EU
Ethyleneurea
2­
Imidazolidone
107­
15­
3
HYD
Hydantoine
Or
Glycolylurea
2,4­(
3H,
5H)­
Imidazoledione
Molecular
formula/
mass:
C3H4N2O2
(
100.08)
461­
72­
3
J.
B
Jaffe's
Base
1­(
4,5­
Dihydro­
1H­
imidazol­
2­
yl)­
imidazolidin­
2­
thion
484­
92­
4
Transformation
Product
Name
CAS
Number
Structure
Abbr.*
Common
IUPAC
30
GLY
Glycine
Amino
acetic
acid
56­
40­
6
IMID
2­
Imidazoline
2­
Imidazoline
504­
75­
6
EDA
ethylenediamine
Not
reported
(
NR)
(
NR)

Others:
CO2,
Un­
identified
polar
materials
(
Polar),
Un­
identified
Bound
species
(
Bound)

*
Abbreviated.

In
submitted
fate
studies,
identification/
quantification
of
various
ETU
transformation
products
were
based
on
TLC
without
confirmation
with
other
methods;
one
aerobic
study
was
an
exception.
The
results
obtained
from
TLC
were
affected
mainly
by
poor
separation
of
the
degradates.
Additionally,
many
problems
were
cited
for
most
of
these
studies
including:
use
of
test
material
with
unknown
purity,
un­
determined
or
variable
material
balance,
tracking
of
only
selected
degradates,
and
unidentification
quantification
of
Bound
species.

Data
suggest
that
the
major
transformation
products
of
ETU
in
important
environmental
compartments
are
EU,
un­
identified
Bound
species
and
CO
2
.
Other
transformation
products
such
as
un­
identified
polar
compounds,
HYD,
J.
B,
GLY
and
IMID
may
form
only
in
certain
uncommon
environmental
conditions.

Table
IV­
9.
Reported
occurrences
for
ETU
transformation
products.

Study
Type
Aqueous
UV
photolysis
Plants*
Aerobic
soil**
Field
Procedure(
s)
TLC/
IR/
MS
TLC/
IR/
MS
HPLC/
MS/
MS
TLC
only
Time
of
Occurrence
after
a
rapid
degradation
of
ETU
After
14
days
EU
after
2
days
After
7
days
Reference
or
MRID
Rhodes
(
1)
Rhodes
(
1)
452251­
01
Rhodes
(
1);
000889­
23
EU
Major
Intermediate
to
GLY***
40%
3.4%
46%
of
residue
HYD
Major
Intermediate
to
GLY***
NP
ND
Not
present
J.
B
Maximum
of
16%
56%
ND
Not
present
GLY***
Major
Final
product
Not
present
ND
Not
present
IMID
Not
present
(
NP)
Minor
amounts
ND
Not
present
Polar
Compounds
NP
NP
ND
12%
of
residue
CO2
Not
determined
(
ND)
ND
ND
Not
determined
Study
Type
Aqueous
UV
photolysis
Plants*
Aerobic
soil**
Field
Procedure(
s)
TLC/
IR/
MS
TLC/
IR/
MS
HPLC/
MS/
MS
TLC
only
Time
of
Occurrence
after
a
rapid
degradation
of
ETU
After
14
days
EU
after
2
days
After
7
days
Reference
or
MRID
Rhodes
(
1)
Rhodes
(
1)
452251­
01
Rhodes
(
1);
000889­
23
31
Bound
species
Not
Present
(
no
solids)
ND
ND
58%
of
residue
*
Plants*=
Applied
to
tomato
plants;
only
trace
amounts
of
radioactivity
constituted
plant
up­
take.
**
In
a
supplemental
aerobic
soil
study
(
MRID
408387­
01),
Extractable
radioactivity
was
20%
as
EU
and
36%
un­
known
at
day
2.
By
the
end
of
this
93­
day
study,
un­
identified/
un­
extractable
14C­
residue
comprise
88%
of
the
applied
radioactivity
and
14CO2
totaled
40%;
Procedure
used
for
identification/
quantification
was
TLC
only
and
the
material
balance
was
extremely
variable.
***
GLY***=
Glycine
and
glycine
sulfate
with
sulfur
in
sulfate
accounting
for
structural
ETU.
(
1)
R.
C.
Rhodes
1977.
Studies
with
manganese
14C­
Ethylene
bis
dithiocarbamate
(
14C­
Maneb)
fungicide
and
14C­
Ethylenethiourea
(
14C­
ETU)
in
plants,
soil,
and
water.
J.
Agr.
Food
Chem.,
Vol.
25:
3,
pp528­
533.
17
Note:
Parent
rate
(
kg/
ha)=
5.38
arrived
at
by
multiplying
the
parent
rate
of
4.8
(
lb/
a)
by
1.121
and
ETU
rate
(
kg/
ha)=
0.52
arrived
at
by
multiplying
the
parent
rate
of
5.38
(
kg/
ha)
by
0.096
32
V.
Water
Resource
Assessment
a.
Surface
Water
Modeling
for
Aquatic
Exposure
ETU
is
a
common
degradate
of
the
EBDC
fungicides
metiram,
mancozeb
and
maneb.
For
aquatic
exposure,
EFED
based
the
preliminary
aquatic
exposure
EECs
for
ETU
on
the
results
of
screening
models.
The
models
are
the
Tier
II
linked,
Pesticide
Root
Zone
Model
version
3.1.2
beta
(
Carsel
and
others,
1997)
and
Exposure
Analysis
Modeling
System
version
2.98.04
(
Burns,
1997);
referred
to
as
PRZM/
EXAMS.

In
modeling,
ETU
rate,
was
calculated
by
assuming
very
rapid
and
complete
degradation
of
applied
EBDCs
to
ETU.
ETU
rate
was
not
based
on
the
molar
conversion
of
38.5%
but
rather
on
the
maximum
conversion
rate
of
9.6%
(
observed
in
the
laboratory
aerobic
soil
studies
on
concentration
basis)
for
parent
entering
soil
systems
upon
application
and
23.6%
(
observed
in
the
laboratory
aerobic/
anaerobic
water/
sediment
systems
on
concentration
basis)
for
amounts
entering
aquatic
systems
by
drift.
These
conversion
rates
were
arrived
at
as
a
result
of
examination
of
fate
and
transport
data
of
parent
EBDCs
which
indicate
that
ETU
is
their
major
transformation
product
resulting
from
abiotic
and
biotic
degradation
processes
in
both
field
and
laboratory
studies.
Reported
laboratory
data
on
degradation
of
EBDCs
and
the
maximum
ETU
produced
are
summarized
in
Table
V­
1.

Table
V­
1.
Maximum
ETU
produced
in
fate
studies
for
parent
EBDCs.

Type
of
Study
Parent
EBDCs
Used
as
a
Test
Substance
(
Number
of
Studies)
Maximum
ETU
Formed
As
%
Parent
Equivalent
As
%
ETU*

Aqueous
Hydrolysis
Maneb
(
1);
Metiram
(
1)
93.0%
35.8%

Aerobic/
Anaerobic
Aquatic
Metiram
(
2);
Maneb
(
1)
61.4%
23.6%

Aerobic
Soil
Metiram
(
4);
Mancozeb
(
3);
Maneb
(
3)
24.8%
09.6%

*
%
ETU=
%
Parent
Equivalent
multiplied
by
Molar
ratio
of
Parent
to
ETU
of
38.5%.
For
example,
the
maximum
for
hydrolysis
studies=
93%
x
0.385
=
35.8%.

Examination
of
data
indicate
that
the
maximum
observed
conversion
of
parent
to
ETU
is
expected
to
be
the
highest
in
water
systems
(
35.8%)
followed
by
water/
sediment
systems
(
23.6%)
and
the
lowest
in
aerobic
soil
systems
(
9.6%).
Although
these
values
represent
the
maximum
found
in
the
laboratory,
higher
or
lower
conversion
rates
may
occur
in
the
natural
environment
depending
on
the
characteristics
of
the
systems
(
e.
g.
availability
of
moisture
and
biological
activity).
This
is
considered
as
an
uncertainty
along
with
the
assumption
that
conversion
to
ETU
occurs
at
application.
In
this
respect,
it
is
noted
that
the
maximum
ETU
attained
in
the
natural
environment
is
a
result
of
two
major
processes
formation
and
degradation.
This
maximum
is
expected
to
occur
shortly
after
the
parent
reaches
the
aquatic
system
by
drift
and
much
longer
after
foliar
applied
parent
reaches
the
soil
system.

In
assigning
the
value
for
ETU
application
rate
for
modeling,
EFED
used
the
parent/
ETU
conversion
value
of
9.6%
for
ETU
expected
to
form
(
from
applied
parent)
in
the
soil
system.
This
value
(
equal
to
0.52
kg
a.
i./
ha
for
apples17)
was
assigned
to
be
the
parent
equivalent
ETU
rate.
PRZM/
EXAMS
33
will
use
this
value
to
calculate
drift
by
multiplying
0.52
by
0.05
(
5%
drift).
This
ETU
rate
is
accurate
only
for
the
soil
system
and
needs
to
be
corrected
for
the
aquatic
system.
Therefore,
a
correction
factor
of
2.458
was
used
and
was
affected
by
changing
the
drift
from
0.05
(
the
default
value)
to
0.123.
Changing
the
drift
fraction
by
the
stated
factor
will
result
in
an
exact
account
for
the
observed
23.6%
parent/
ETU
conversion
rate
in
aquatic
systems.

Inputs
used
for
modeling
include
the
fate
and
transport
parameters
determined
for
the
EBDC
metabolite/
degradate
ETU
(
Table
V­
2).
As
shown
in
Table
V­
2,
ETU
has
an
aerobic
soil
half­
life
of
about
3
days;
in
the
absence
of
data,
the
aquatic
aerobic
metabolism
half­
life
was
assumed
to
be
about
6
days,
or
double
the
soil
half
life.
The
measured
anaerobic
aquatic
metabolism
half­
life,
however,
is
substantially
longer
(
149
days)
possibly
leading
to
the
periodic
detections
in
groundwater.
It
is
highly
soluble
in
water
(
20,000
ppm);
highly
vulnerable
to
indirect
photolysis
(
half­
life=
1
day),
and
moderately
mobile
(
288
L/
kg).
It
also
has
a
relatively
high
vapor
pressure
but
high
solubility
reduces
the
possibility
of
losses
from
surface
water
due
to
volatilization.

Table
V­
2.
PRZM/
EXAMS
Input
Parameters
for
ETU.

Input
Parameter
Value
Reference
Molecular
Weight
(
grams)
102.2
Product
chemistry
submission
Vapor
Pressure
(
torr)
9.728e­
1
Registrant
data
Aerobic
Soil
Metabolism
Half­
life
(
days)
3.14
Upper
confidence
bound
on
the
mean
for
three
soils
(
MRID
452251­
01)

Bacterial
Bio­
lysis
in
the
water
column
(
days)
(
Aerobic
Aquatic
metabolism
half­
life)
6.28
Aerobic
soil
t
½
x2:
No
aerobic
aquatic
metabolism
study/
No
significant
hydrolysis
(
Guidance)
1
Bacterial
Bio­
lysis
in
benthic
sediment
(
days)
(
Anaerobic
Aquatic
metabolism
half­
life)
447
Only
one
value
is
available=
149
days
(
MRID
001633­
35);
use
149x3=
447
days
(
Guidance)
1
Application
Rate
Varies
by
crop
and
calculated
from
parent
rate
as
described
in
Table
V­
3
below.

Application
Method
Aerial
Product
Label
Depth
of
Incorporation
(
inches)
0
Product
Label
Spray
Drift
(
fraction)
0.123
This
value
is
increased
from
the
default
value
of
0.05
by
a
factor
of
2.458
2
Solubility
(
mg/
L
or
ppm)
20,000
Product
chemistry
submission
Koc
(
L
Kg­
1)
288
Average
for
ten
soils
(
MRIDs
002588­
96&
000971­
58)

pH
7
Hydrolysis
Half­
life
(
days)
Stable
MRID
404661­
03
Photolysis
Half­
life(
days)
1
This
is
the
indirect
photolysis
half­
life
reported
for
ETU;
ETU
is
stable
to
direct
photolysis
(
MRID
404661­
02)

1
Guidance
for
Chemistry
and
Management
Practice
Input
Parameters
For
Use
in
Modeling
the
Environmental
Fate
and
Transport
of
Pesticides,
Version
2/
November
7,
2000.

2
This
2.458
correction
factor
was
arrived
at
by
dividing
23.6%
(
conversion
of
parent
to
ETU
in
aquatic
systems)
by
9.6%
(
conversion
of
parent
to
ETU
in
the
soil
systems).
34
As
shown
in
Table
V­
3,
the
PRZM/
EXAMS
farm
pond
simulation
modeling
was
performed
for
22
crop
scenarios
to
cover
the
extensive
use
patterns
for
all
EBDCs.

Table
V­
3.
PRZM/
EXAMS
Additional
input
parameters
for
various
scenarios.

Scenario
Parent
EBDC
Rate
ETU
Rate
Application
Date(
dd/
mm)
Number
of
Applications
Interval
(
Days)
(
lbs/
a)
kg/
ha
1
kg/
ha
2
Apples
NC,
Apples
PA,
and
Apples
OR
(
Metiram,
Mancozeb
and
Maneb)
4.80
5.38
0.52
07/
03
20/
03
15/
03
04
7
Tomatoes
FL,
Tomatoes
PA,
and
Tomatoes
CA
(
Mancozeb)
2.40
2.69
0.26
11/
02
06/
08
06/
07
07
7
Peppers
FL
(
Maneb)
2.40
2.69
0.26
09/
10
06
7
Sweet
Corn
FL,
and
Sweet
Corn
OR
(
Maneb)
1.20
1.35
0.13
07/
11
03/
07
15
05
3
3
Potatoes
ME,
Potatoes
ID
(
Maneb)
1.60
1.79
0.17
07/
07
15/
07
10
5
Wheat
TX,
Wheat
ND,
and
Wheat
OR
(
Mancozeb)
1.60
1.79
0.17
02/
04
24/
05
16/
04
03
7
Cabbage
FL
(
Maneb)
1.60
1.79
0.17
10/
10
01/
15
06
7
Grapes
CA
(
Mancozeb
and
Maneb)
3.2
3.59
0.34
15/
02
06
7
Almonds
CA
(
Maneb)
6.4
7.17
0.69
20/
03
04
7
Onions
CA
(
Mancozeb
and
Maneb)
2.40
2.69
0.26
15/
03
10
7
Turf
FL
(
Mancozeb
and
Maneb)
3
17.4
19.51
1.87
15/
03
01
None
Sugar
beet
CA,
and
Sugar
beet
(
Mancozeb
and
Maneb)
1.60
1.79
0.17
01/
03
01/
08
07
7
Peanuts
NC
(
Mancozeb)
1.80
2.02
0.19
21/
03
07
5
1
Parent
rate
(
kg/
ha)=
parent
rate
(
lbs
a.
i./
a)
x
1.121.
2
ETU
rate
(
kg/
ha)=
parent
rate
(
kg
a.
i./
ha)
x
0.096.
3
Label
didn't
specify
the
number
of
applications,
one
application
was
assumed
at
a
rate
of
17.4
lbs
a.
i/
acre.
However,
PRZM/
EXAMS
runs
were
also
executed
for
three
applications,
17.4
lbs
a.
i/
acre
each
applied
at
5
and
7
days
intervals.

Finally,
Table
V­
4
summarizes
the
EECs
for
ETU,
in
ppb,
which
were
obtained
for
the
highest
peak
values
(
Peak)
along
with
those
after
96
hours;
21/
60
and
90
days;
the
yearly
average
and
the
average
for
all
years.
These
EEC
values
were
used
in
the
ecological
risk
assessment
for
aquatic
systems.
18
USEPA/
Office
of
Water
1993.
Federal­
State
Toxicology
and
Risk
Analysis
Committee
(
FSTRAC).
Summary
of
State
and
Federal
Drinking
Water
Standards
and
Guidelines.

35
Table
V­
4.
PRZM/
EXAMS
farm
pond
modeling
results
for
ETU
(
EECs
for
ETU
in
ppb).

Scenario
Peak
96
hr
21
Day
60
Day
90
Day
Yearly
Average
Average
of
All
Years
FL
peppers
12.3
10.0
6.5
3.2
2.2
0.6
0.3
FL
turf
1
11.5
9.5
5.4
2.9
2.0
0.5
0.4
NC
apples
11.2
9.7
7.4
4.1
2.8
0.7
0.6
FL
sweet
corn
11.0
9.0
5.2
3.1
2.1
0.6
0.4
FL
tomatoes
10.9
8.6
4.3
2.7
1.9
0.5
0.4
CAalmonds
10.2
8.8
7.0
4.1
2.8
0.7
0.6
PA
tomatoes
9.4
7.8
5.1
3.4
2.5
0.7
0.5
PAapples
8.7
7.5
6.0
3.4
2.3
0.6
0.5
CA
onions
8.6
7.0
5.6
4.9
3.7
0.9
0.9
OR
apples
7.6
6.6
5.4
3.2
2.2
0.6
0.5
NC
peanuts
6.2
5.3
3.8
2.2
1.5
0.4
0.3
CA
grapes
5.2
4.5
3.9
2.8
2.0
0.5
0.5
FL
cabbage;
Jan
application
4.8
4.2
2.9
1.9
1.3
0.3
0.2
ME
potatoes
4.3
3.7
2.9
2.1
1.6
0.5
0.4
MN
sugar
beet
4.3
3.6
2.4
1.7
1.3
0.4
0.3
FL
cabbage;
Oct
application
3.9
3.0
2.0
1.3
0.9
0.2
0.2
TX
wheat
3.9
3.1
1.9
0.8
0.6
0.1
0.1
CA
sugar
beet
3.2
2.9
2.5
1.8
1.3
0.3
0.3
IDpotatoes
2.8
2.3
2.0
1.6
1.1
0.3
0.3
CA
tomatoes
2.6
2.0
1.6
1.3
0.9
0.2
0.2
OR
sweet
corn
2.5
2.1
1.5
0.7
0.6
0.2
0.1
OR
wheat
2.2
1.9
1.4
0.8
0.5
0.1
0.1
ND
wheat
2.2
1.8
1.3
0.6
0.4
0.1
0.1
1
These
are
the
results
for
one
application
(
17.4
lbs
a.
i/
acre).
The
results
for
three
applications
(
17.4
lbs
a.
i/
acre
each)
are
as
follows
(
ETU
in
ppb):

For
5­
day
intervals:
26.7
(
Peak);
22.4
(
96
hr);
16.5
(
21
Day);
8.6
(
60
Day);
5.8
(
90
Day);
1.5
(
Yearly);
and
1.0
(
All
Years);
and
For
7­
day
intervals:
32.0
(
Peak);
26.4
(
96
hr);
16.5
(
21
Day);
8.5
(
60
Day);
5.8
(
90
Day);
1.4
(
Yearly);
and
1.0
(
All
Years).

b.
Drinking
Water
Assessment
Ethylenethiourea
(
ETU)
is
a
common
metabolite
of
all
of
the
EBDC
fungicides
and
may
reach
both
surface
and
groundwater
under
some
conditions.
In
contrast,
parent
EBDCs
metiram,
maneb
and
mancozeb
are
short­
lived
in
soil
and
in
water
and
would
not
themselves
be
expected
to
remain
in
surface
water
long
enough
to
reach
a
location
that
would
supply
water
for
human
consumption
whether
from
surface
or
ground
water.
ETU
is
not
regulated
under
the
Safe
Drinking
Water
Act
with
no
established
MCL.
However,
since
ETU
is
a
B2
carcinogen,
drinking
water
health
advisories
have
been
set
by
the
EPAs
Office
of
Water.
Concentration
values
were
set
at
15
µ
g/
l
(
ppb)
in
Florida
and
3
µ
g/
l
(
ppb)
in
Maine18.

EDWCs
of
ETU
is
included
in
detail
in
Appendix
VI
(
Memorandum
to
HED
dated
08/
25/
04).
In
this
memorandum,
these
values
were
calculated
for
use
in
an
FQPA
human
health
risk
assessment.
This
is
a
revised
memo
presenting
the
Estimated
Drinking
Water
Concentrations
(
EDWCs)
for
the
EBDC
degradate
ETU
for
use
in
an
FQPA
human
health
risk
assessment.
The
referenced
assessment
addresses
exposure
to
ETU
only.
The
chronic
EDWC
for
surface
water
is
0.1
ppb
and
is
based
on
a
monitoring
study
conducted
by
the
EBDC
Task
Force.
A
range
of
acute
EDWCs
is
established
with
36
a
lower
limit
of
0.1
ppb
(
based
on
monitoring)
and
an
upper
limit
of
25.2
ppb
(
based
on
environmental
fate
and
transport
simulation
modeling
using
the
linked
EPA
PRZM
and
EXAMS
models).
The
ground
water
EDWC
is
0.21
ppb
(
based
on
a
targeted
monitoring
study).

As
suggested
by
the
registrant,
EFED
used
NASS
reported
typical
highest
one­
in­
ten
years
application
rate
of
1.18
lb
a.
i./
A
(
0.11
kg/
hac
ETU)
in
conducting
a
new
PRZM/
EXAMS
run
for
the
upper
acute
limit
of
25.2
ppb
(
FL
peppers).
The
rate
was
inferred
from
NASS
summaries
(
refer
to
the
table
provided
by
the
registrant
below).
As
expected
the
upper
acute
limit
of
25.2
ppb
(
FL
peppers)
has
changed
to
10.7
ppb;
this
value
was
reported
in
a
new
memo
for
HED.

Table:
NASS
maneb
pepper
actual
use
information
as
reported
by
the
registrant
from:
www.
pestmanagement.
inf/
nass
Active
Ingredient
Per
Application
(
lb/
appli./
ac)

Year
Minimum
Maximum
Average
1992
1.19
1.37
1.26
1994
0.98
1.27
1.13
1996
1.09
1.31
1.19
1998
1.03
1.14
1.08
2000
0.97
1.65
1.21
2002
1.01
1.45
1.23
Note:
the
average
of
the
six
yearly
averages
is
1.18
lb
a.
i./
A,
equivalent
to
an
ETU
rate
of
0.11
kg/
ha.
37
VI.
Aquatic
Exposure
and
Risk
Assessment
a.
Hazard
Summary
(
Acute/
Chronic)

Based
on
acute
exposure
from
core
studies,
ETU
is
practically
nontoxic
to
cold
water
fish
(
rainbow
trout
LC
50
>
502
ppm
based
on
measured
samples)
and
slightly
toxic
to
freshwater
invertebrates
(
daphnid
EC
50
=
26.9
ppm
based
on
measured
samples).
These
two
studies
fulfill
guidelines
72­
1(
c)
for
freshwater
fish
and
72­
2(
a)
for
freshwater
invertebrates.
A
Tier
II
(
guideline
123­
2)
supplemental
study
for
Pseudokirchneriella
subcapitata
(
formerly
Selenastrum
capricornutum),
a
freshwater
green
alga,
showed
an
ETU
EC
50
of
23.0
ppm
a.
i.
based
on
a
decline
in
cell
density.
EFED
classified
this
study
as
supplemental
because
the
test
duration
was
only
72
hours
and
the
guidelines
require
the
test
duration
to
be
120
hours.

EFED
has
limited
acute
toxicity
data
to
evaluate
ETU's
toxicity
to
aquatic
organisms.
EFED
is
requiring
submission
of
or
reserving
submission
for
the
following
guidelines
studies:

72­
1(
a)
Acute
Fish
Toxicity
Bluegill
a
freshwater
fish
dwelling
in
warm
waters
72­
3(
a)
Acute
Estuarine/
Marine
Toxicity
Fish
72­
3(
b)
Acute
Estuarine/
Marine
Toxicity
Mollusk
72­
3(
c)
Acute
Estuarine/
Marine
Toxicity
Shrimp
72­
4(
a)
Early
Life­
Stage
Fish
for
freshwater
and
estuarine/
marine
species
72­
4(
b)
Life­
Cycle
Aquatic
Invertebrate
for
freshwater
and
estuarine/
marine
species
122­
2
(
Tier
I)
or
123­
2
(
Tier
II)
Aquatic
Plant
Growth
EFED
needs
submission
of
these
studies
for
the
TGAI
of
ETU.
The
first
study
listed
above
[
72­
1(
a)]
is
a
basic
study
need
for
all
pesticides.
EFED
is
requiring
this
study
for
ETU
because
ETU
is
a
degradate
toxic
to
mammals
which
may
also
be
toxic
to
aquatic
wildlife.
The
next
three
studies
[
72­
3(
a,
b,
and
c)],
deal
with
the
acute
toxicity
to
estuarine
and
marine
species.
EFED
needs
these
studies
because
of
the
EBDCs'
use
in
coastal
counties
where
EFED
expects
estuarine
or
marine
exposure
to
the
EBDCs
and
their
common
degradate,
ETU.
The
next
two
studies
[
72­
4(
a
and
b)]
deal
with
chronic
toxicity
to
aquatic
fish
and
aquatic
invertebrate
species.
EFED
reserves
the
need
for
these
studies
pending
completed
ETU
acute
toxicity
testing
of
freshwater
and
estuarine
marine
organisms.
ETU
has
not
triggered
any
risk
based
on
acute
freshwater
fish
and
invertebrate
testing
with
no
LOCs
exceeded
for
freshwater
fish
and
invertebrates.
EFED
evaluated
this
ETU
risk
based
on
mancozeb's
use
pattern.
ETU
does
not
appear
to
be
persistent
in
the
aquatic
environment.
Quantities
of
ETU
that
reach
or
form
in
natural
surfacewater
are
expected
to
be
stable
to
hydrolysis/
direct
photolysis,
however,
it
was
reported
that
ETU
can
be
removed
rather
quickly
from
these
waters
by
indirect
photolysis
(
half­
lives
of
1­
4
days)(
Sue
XU,
2000).
EFED
is
reserving
the
requirement
for
Life
Cycle
Fish
studies
for
both
freshwater
and
estuarine
or
marine
fish
species
(
guideline
72­
5)
awaiting
the
results
of
the
Early
Life­
Stage
testing
(
guideline
72­
4a),
if
this
study
is
needed.
EFED
still
needs
core
studies
to
evaluate
ETU's
toxicity
to
aquatic
plants
[
guidelines
122­
2
(
Tier
I)
or
123­
2
(
Tier
II)].
For
a
more
detailed
listing
and
explanation
of
ETU's
hazards
to
aquatic
organisms,
see
Appendix
III.
38
Table
VI­
1:
Toxicological
Endpoints
Used
to
Determine
Aquatic
Risk
Quotients
(
RQs)
for
ETU
Type
of
Toxicity
Organism
Species
Toxicological
Endpoint
Acute
Freshwater
fish
rainbow
trout
(
Oncorhynchus
mykiss)
LC
50
>
502
ppm
Chronic
no
data
no
data
Acute
Freshwater
invertebrate
waterflea
(
Daphnia
magna)
LC
50
=
26.9
ppm
Chronic
no
data
no
data
Acute
Estuarine/
marine
fish
no
data
no
data
Chronic
no
data
no
data
Acute
Estuarine/
marine
invertebrate
no
data
no
data
Chronic
no
data
no
data
Acute
Aquatic
plant
green
algae
(
Pseudokirchneriella
subcapitata)
EC
50
=
23
ppm
b.
Exposure
and
Risk
Quotients
EFED
calculated
surface
water
concentrations
of
ETU
using
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)
for
Tier
II
estimates
(
see
section
V.
Water
Resource
Assessment,
for
detailed
explanation).
EFED
used
the
peak
EECs
to
assess
the
acute
risks
to
aquatic
organisms
from
multiple
applications.

EFED
has
limited
aquatic
toxicological
data
for
ETU.
However,
the
data
available
show
that
ETU
does
not
exceed
acute
risk
LOCs
for
freshwater
fish,
freshwater
invertebrates
or
nonvascular
aquatic
plants.
See
tables
5,
6,
and
7
in
Appendix
IV
(
pages
72­
75)
for
a
detailed
listing
of
the
calculations
and
RQ
results.
EFED
did
not
evaluate
acute
risks
to
estuarine
and
marine
animals
because
of
the
lack
of
data.
Through
this
document,
EFED
is
requiring
submission
of
this
missing
data.
EFED
does
not
perform
chronic
assessments
to
nontarget
aquatic
plants
because
EFED
has
not
developed
a
risk
scheme
for
assessing
chronic
risk
to
plants.

c.
Aquatic
Risk
Assessment
The
limited
ecotoxicological
data
for
ETU
shows
ETU
is
a
small
acute
toxicity
risk
to
freshwater
fish,
freshwater
invertebrates,
and
nonvascular
aquatic
plants
with
no
LOCs
exceeded.
EFED
has
not
received
any
adverse
aquatic
incidents
reports
about
ETU.
The
study
used
to
assess
the
risk
to
aquatic
nonvascular
plants
is
supplemental
and
EFED
needs
core
data.
EFED
needs
aquatic
plant
studies
for
a
vascular
aquatic
plant,
a
marine
diatom,
a
blue­
green
algae
and
a
freshwater
diatom
to
evaluate
fully
ETU's
risk
to
aquatic
plants.
EFED
needs
core
studies
to
evaluate
the
acute
risks
to
estuarine
and
marine
organisms
for
ETU.

The
EDBCs
(
metiram,
mancozeb,
and
maneb),
unlike
most
pesticide
active
ingredients
are
not
welldefined
monomeric
substances
(
DÇtzer,
1994).
The
EDBCs
are
polymeric
complexes
and
are
nearly
insoluble
in
water
with
a
high
affinity
to
adsorption
by
soil
and
sediment
particles.
The
EBDC
portion
39
that
dissolves
in
water
breaks
up
into
a
suite
of
transient
(
that
is,
unpermanent
or
fleeting)
chemical
arrangements
and
degradates.
This
mix
is
no
longer
the
parent
material
by
itself
but
is
consider
to
be
EBDC
complex.
EBDC
complex
consists
of
transient
species
and
degradates
including
the
degradate
of
concern
ETU.
Over
time
ETU
is
an
important
transformation
product
of
the
EDBCs.

In
contrast
to
the
small
risk
ETU
poses
to
freshwater
fish,
freshwater
invertebrates,
and
nonvascular
aquatic
plants,
with
no
LOCs
exceeded,
the
EBDC
complex
which
contain
this
degradate,
show
risk
to
freshwater
fish,
freshwater
invertebrates,
and
nonvascular
aquatic
plants.
The
EBDCs'
RQs
for
freshwater
fish,
freshwater
invertebrates,
and
nonvascular
aquatic
plants
exceed
acute
LOCs
(
see
individual
chapters
for
mancozeb,
metiram,
and
maneb).
All
the
parent
compounds
exceed
the
acute
aquatic
LOCs
for
one
or
more
use
patterns
while
ETU
does
not
exceed
LOCs.
Based
on
laboratory
data
and
modeled
EECs,
the
EBDC
complex
resulting
from
parent
compounds
are
responsible
for
exceeding
LOCs
and
not
the
common
degradate,
ETU.
This
means
the
EBDC
portion
that
dissolves
in
water
and
breaks
up
into
a
suite
of
transient
species
and
degradates,
other
than
ETU,
are
responsible
for
the
acute
toxicity
to
freshwater
fish,
freshwater
invertebrates,
and
nonvascular
aquatic
plants.
EFED
expects
an
early
acute
exposure
risk
to
these
aquatic
organisms
from
the
uses
of
the
EBDC
fungicides.
This
acute
risk
is
caused
by
the
EBDCs
complex
and
is
expected
to
disappear
over
time
as
the
complex
degrades
rather
quickly
into
ETU
by
hydrolytic
reactions
in
aquatic
environments.
Because
of
this,
EFED
expects
the
acute
toxicity
to
freshwater
fish,
freshwater
invertebrates,
and
nonvascular
aquatic
plants,
from
exposure
to
the
EBDC
complexes,
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
EBDC
complexes.
EFED
expects
the
parent
EBDCs
to
hydrolyze
quickly
(
that
is,
within
hours)
to
its
complexes.
Based
on
this
information,
EFED
expects
the
EBDC
complexes'
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.

i.
Incidents
Based
on
information
available
in
the
Ecological
Incident
Information
System
(
EIIS),
the
Office
of
Pesticide
Programs
(
OPP)
has
not
received
any
incident
reports
about
adverse
aquatic
wildlife
exposure
to
ETU.
However,
since
ETU
is
a
degradate
of
the
EDBCs
and
not
a
pesticide,
it
is
unlikely
that
OPP
would
receive
incident
reports
for
ETU.
Filed
incident
reports
would
most
likely
be
for
one
of
the
EBDCs,
not
specifically
for
ETU.
See
Appendix
VI
for
description
and
background
of
EIIS.

ii.
Endocrine
Disruptors
Based
on
limited
ETU
aquatic
toxicological
data,
ETU
does
not
appear
to
cause
endocrine
disrupting
effects
in
the
aquatic
organisms
tested.
However,
EFED
cannot
fully
evaluate
aquatic
organisms
for
endocrine
induced
effects
because
of
lack
of
data.

iii.
Endangered
Species
At
the
current
application
rates
and
use
patterns,
ETU,
as
a
degradate
of
the
EDBC
fungicides,
is
not
likely
to
result
in
acute
risks
to
endangered
or
threatened
species
of
freshwater
fish
or
invertebrates
because
no
LOCs
are
exceeded.
As
pointed
out
in
section
VI.
a.
­
Hazard
Summary
(
Acute/
Chronic),
above,
the
Agency
does
not
currently
have
data
on
which
to
evaluate
the
toxicity
of
ETU
to
endangered
19
The
failure
of
one
or
more
testes
to
descend
into
the
scrotum.

40
or
threatened
species
for
all
aquatic
organisms
groupings.
Because
of
this,
the
risks
to
endangered
or
threatened
species
of
some
aquatic
organisms
from
ETU
exposure
is
uncertain.
EFED
is
requiring
the
data
to
assess
the
risk
to
endangered
or
threatened
species
for
these
aquatic
organism
groupings
through
this
document.

VII.
Terrestrial
Exposure
and
Risk
a.
Hazards
Summary
(
Acute/
Chronic)

EFED
does
not
have
any
acute,
subacute
or
chronic
toxicity
data
to
evaluate
ETU's
toxicity
to
birds.
Because
of
this,
EFED
needs
the
Avian
Acute
Oral,
Avian
Acute
Dietary,
and
Avian
Reproduction
studies
[
guidelines
71­
1(
a),
71­
2
(
a
and
b),
and
71­
4
(
a
and
b),
respectively]
for
the
TGAI
of
ETU.

ETU
is
practically
nontoxic
to
small
mammals
from
acute
oral
exposure
(
LD
50
of
2,300
mg/
kg
in
tests
done
on
laboratory
mice).
The
Hazard
Identification
Assessment
Review
Committee
(
HIARC)
report
(
2003)
concluded
there
were
data
gaps
for
a
developmental
toxicity
study
in
rabbits
and
a
2­
generation
reproduction
toxicity
in
rats.
Results
from
a
one­
dose
developmental
gavage
study
done
on
pregnant
laboratory
rats
for
ETU
showed
maternal
and
developmental
toxicity
at
an
LOAEL
of
50
mg/
kg/
day.
The
study
did
not
fix
a
NOAEL
because
this
study
used
only
one
50
mg/
kg/
day
concentration.
At
this
one
dose
concentration,
developmental
effects
caused
by
ETU
were
gross
developmental
defects,
central
nervous
system
defects,
skeletal
deficiencies,
cryptorchidism19,
and
decreased
fetal
weight.
Other
developmental
effects
caused
by
ETU
were
defects
of
the
brain
(
exencephaly,
dilated
ventricles,
and
hypoplastic
cerebellum)
in
rats
(
MRID
No.
45937601).
In
this
study,
ETU
was
administered
to
rats
by
gavage.
This
study,
in
rats,
resulted
in
a
NOAEL
of
5
mg/
kg/
day
and
a
LOAEL
of
10
mg/
kg/
day
based
on
developmental
toxicity.
No
maternal
toxicity
was
noted
in
this
study.
To
assess
the
chronic
risks
to
mammals,
EFED
used
MRID
No.
45937601.
In
a
2­
generation
reproduction
study
(
MRID
42391701),
ETU
was
administered
to
rats
(
25/
sex/
dose
group)
in
diet
at
nominal
dietary
dose
levels
of
0,
2.5,
25,
or
125
ppm.
The
F0
generation
was
treated
for
70
days
before
mating
and
the
F1
generation
was
treated
126
days
before
mating.
EFED
did
not
list
or
use
this
study
because
there
was
variability
in
dietary
concentrations,
feed
spillage,
stability
problems
with
the
test
material,
and
unknown
feed
consumption.
These
uncertainties
made
calculating
intake
on
a
mg/
kg/
day
basis
impossible.
There
were
also
missing
pups
unaccounted
for
during
the
lactation
period.
The
HIARC
report
(
2003)
classified
this
study
as
unacceptable.
41
Table
VII­
1:
Mammalian
Toxicity
Mammalian
Acute
Oral
Toxicity
­
ETU
Species
%
ai
LD
50
(
mg
ai/
kg)
Toxicity
Category)
Endpoints
Affected
MRID
or
Accession
(
AC)
No.

laboratory
mouse
(
Mus
musculus)
98.0
2,300
(
female)
practically
nontoxic
mortality
not
reported
Mammalian
Developmental
Chronic
Toxicity
­
ETU
Species/
Study
Duration
%
ai
Test
Type
NOAEL/
LOAEL
Toxicity
Value
(
mg/
kg/
day)
Endpoints
Affected
MRID
or
Accession
(
AC)
No.

laboratory
rat
(
Rattus
norvegicus)
/
not
reported
99.0
Developmental
not
determined/
50
mat.
­
decreased
body
wt.
gain
dev.
­
gross
developmental
defects,
central
nervous
system
defects,
skeletal
defects,
cryptorchidism,
and
decreased
fetal
weight
00246663
laboratory
rat
(
Rattus
norvegicus)
/
not
reported/
not
reported
not
reported
Developmental
5/
10
mat.
­
No
maternal
toxicity
was
noted
in
this
study
dev.
­
Based
on
developmental
defects
of
the
brain
(
exencephaly,
dilated
ventricles,
and
hypoplastic
cerebellum).
45937601
Khera,
K.
S.;
Teratology
7:
243­
252.
1973
EFED
is
not
requiring
insect
testing
of
the
degradate,
ETU.
The
parent
EBDCs
are
practically
nontoxic
to
honeybees
from
short­
term
contact
exposure
(
Guideline
141­
1)
and
significant
ETU
exposure
to
honeybees
in
flight
or
while
foraging
on
plants
is
unlikely.
EFED
believes
any
acute
contact
toxicity
from
ETU
would
have
been
expressed
in
the
guideline
testing
of
the
parent
EBDCs.

EFED
has
no
toxicological
data
to
settle
the
toxicity
of
ETU
to
terrestrial
plants
and
limited
data
on
the
parent
EBDC
compounds.
For
the
parent
EBDC
compounds,
EFED
has
reviewed
one
core
study
(
MRID
No.
44283401)
which
showed
there
was
no
phytotoxicity
concerns.
This
study
was
an
MAI
TEP
with
mancozeb
being
one
of
two
active
ingredients.
EFED
is
seeking
an
SAI
TEP
Tier
I
seedling
emergence
[
guideline
122­
1(
a)]
and
vegetative
vigor
[
guideline
122­
1(
b)]
for
the
parent
EBDC
compounds
(
mancozeb,
metiram
and
maneb).
Now,
until
EFED
receives
and
reviews
the
testing
results
on
the
parent
compounds,
EFED
is
reserving
the
testing
needs
for
the
metabolite,
ETU.

Table
VII­
2:
Toxicological
Endpoints
Used
to
Determine
Risk
Quotients
(
RQs)
for
ETU
Type
of
Toxicity
Organism
Species
Toxicological
Endpoint
Chronic
Mammal
laboratory
rat
(
Rattus
norvegicus)
NOAEL
=
5
mg/
kg/
day1
1
LOAEL
due
to
defects
of
the
brain
(
exencephaly,
dilated
ventricles,
and
hypoplastic
cerebellum)
in
rats
b.
Exposure
Summary
42
EFED
evaluated
terrestrial
exposure
using
estimated
environmental
concentrations
(
EECs)
produced
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
early
concentrations
on
plant
surfaces
based
on
Kenaga
predicted
maximum
and
mean
residues
as
adjusted
by
Fletcher
and
others.
(
1994)
and
assumes
1st
order
dissipation.
Kenaga
estimates
and
an
explanation
of
the
model
with
sample
production
are
in
Appendix
II.
The
EECs
modeled
for
ETU
assumes
1.6
percent
conversion
on
foliage
of
mancozeb
to
ETU
as
an
estimate
of
exposure.
EFED
based
the
ETU
EECs
on
the
maximum
application
rate
of
mancozeb
for
the
use
patterns
currently
registered.
EFED
also
assumed
a
35­
day
total
foliar
residue
dissipation
half­
life
for
ETU
in
predicting
EECs.

c.
Risk
Quotients
Below
(
figures
VII­
1
through
VII­
3)
are
graphs
representing
ETU's
chronic
risks
to
mammals.
These
graphs
show
the
chronic
RQs
expected
from
mammals
feeding
on
the
food
items
listed.
EFED
calculated
these
chronic
RQs
from
EECs
based
on
the
maximum
Hoerger
and
Kenaga
(
1972)
as
modified
by
Fletcher
and
others
(
1994)
residue
estimates
(
see
Appendix
II)
of
ETU
on
these
food
items
following
mancozeb's
applications
to
various
sites
shown.
ETU's
RQs
exceeded
chronic
LOCs
for
all
mancozeb's
uses.
For
small
mammals
(
15­
gram)
feeding
on
short
grass,
the
chronic
RQs
range
from
a
high
of
37
from
mancozeb
turf
applications
to
2
from
mancozeb
citrus
applications.
For
medium
sized
mammals
(
35­
gram)
feeding
on
short
grass,
ETU's
chronic
RQ
range
from
26
for
turf
applications
of
mancozeb
to
1
on
citrus.
For
large
mammals
(
1,000
gram)
feeding
on
short
grass,
the
RQs
range
from
6
on
turf
to
1
on
bananas.
There
are
no
ETU
chronic
LOC
exceedances
to
large
mammals
from
mancozeb's
use
on
potato
&
sugar
beet,
fennel,
peanuts,
forestry
(
douglas
fir),
Christmas
tree
plantations,
tobacco,
cotton,
asparagus,
garlic
&
shallot,
ornamentals,
the
barley
crop
grouping.,
vegetables
or
citrus.
Because
of
this,
Figure
VII­
3
does
not
show
any
bar
charts
for
these
sites
since
all
the
RQs
are
below
the
chronic
LOC
of
1.
The
RQs
provided
in
figures
VII­
1
through
VII­
3
represents
ETU's
risk
to
various
sized
herbivore
and
insectivore
mammals.
EFED
also
calculated
the
RQs
for
granivore
mammals.
For
mammalian
granivores,
no
chronic
LOC
for
ETU
from
mancozeb's
uses
was
exceeded
(
see
Appendix
IV,
Table
4a
for
details).

EFED
calculated
the
EECs
for
ETU's
terrestrial
exposure
based
on
mancozeb's
use
pattern.
EFED
could
have
calculated
RQs
based
on
the
use
patterns
of
the
other
two
parent
compounds
for
ETU,
metiram
and
maneb.
EFED
decided
not
to
make
these
extra
calculations
since
expected
results
would
be
the
same
and
would
only
further
confirm
ETU's
chronic
risk
to
mammals.
Also,
mancozeb
has
the
broadest
use
pattern
(
most
sites
of
application)
and
EFED
expected
mancozeb's
uses
would
provide
a
more
comprehensive
view
of
the
risks
posed
by
ETU.

ETU
effects
triggering
this
chronic
risk
were
based
on
developmental
defects
of
the
brain
(
that
is,
exencephaly,
dilated
ventricles,
and
hypoplastic
cerebellum)
in
rats
from
MRID
45937601.
EFED
used
NOAELs
from
mammalian
reproductive
studies
to
calculate
the
chronic
mamalian
RQs
for
the
parent
EBDCs.
These
NOAELs
resulted
from
dietary
doses
administered
to
rats.
EFED
used
the
NOAEL
from
a
developmental
study
(
MRID
45937601)
to
calculate
ETU's
chronic
risk
to
mammals.
In
this
study,
ETU
was
administered
to
rats
by
gavage.
As
a
result,
EFED
needed
to
convert
the
NOAEL
from
this
ETU
developmental
study
to
a
dietary
dose
to
estimate
the
ETU's
chronic
risk
to
mammals
from
mancozeb's
use
pattern.
EFED
calculated
the
RQs
for
three
separate
weight
classes
of
mammals
(
15,35,
and
1000
g)
listed
below
(
figures
VII­
1
through
VII­
3)
using
the
following
equation:
43
RQ
=
EEC
(
mg/
kg)/[
NOAEL
(
mg/
kg­
bw/
day)/
%(
decimal)
Body
Weight
Consumed
(
bw/
day)]

For
more
details
and
calculations
of
the
ETU's
chronic
mammalian
RQs,
please
see
Appendix
IV.
44
1
10
100
Risk
Quotient
Turf
Ornamen
Turf
(
g
Papaya
Apples,
Grapes
Onion,
Cranber
Cucumbe
Melons
Tomato
Corn
(
E
Bananas
Corn
(
W
Potato
Fennel
Peanuts
Forestr
Christm
Tobacco
Grapes
Cotton
Asparag
Ornamen
Barley,
Vegetab
Citrus
Mancozeb
Application
Sites
Mammals
Feeding
on
Short
Grass
Mammals
Feeding
on
Forage
&
Small
Inse
Mammals
Feeding
on
Large
Insects
ETU's
Chronic
Mammalian
Risk
Risk
to
Small
Mammals
(
15
grams)

Figure
VII­
1­
ETU
Chronic
Risk
to
Mammalian
Herbivores
&
Insectivores
RQ
greater
or
equal
to
1
exceeds
chronic
LOCs.
Assumes
degradation
using
Fate
version
5.0
program
with
an
ETU
total
foliar
residue
half­
life
of
35
days
and
mancozeb
to
ETU
conversion
rate
of
1.6%
45
1
10
100
Risk
Quotient
Turf
Ornamen
Turf
(
g
Papaya
Apples,
Grapes
Onion,
Cranber
Cucumbe
Melons
Tomato
Corn
(
E
Bananas
Corn
(
W
Potato
Fennel
Peanuts
Forestr
Christm
Tobacco
Grapes
Cotton
Asparag
Ornamen
Barley,
Vegetab
Citrus
Mancozeb
Application
Sites
Mammals
Feeding
on
Short
Grass
Mammals
Feeding
on
Forage
&
Small
Inse
Mammals
Feeding
on
Large
Insects
ETU's
Chronic
Mammalian
Risk
Risk
to
Medium
Size
Mammals
(
35
grams)

Figure
VII­
2­
ETU
Chronic
Risk
to
Mammalian
Herbivores
&
Insectivores
RQ
greater
or
equal
to
1
exceeds
chronic
LOCs.
Assumes
degradation
using
Fate
version
5.0
program
with
an
ETU
total
foliar
residue
half­
life
of
35
days
and
mancozeb
to
ETU
conversion
rate
of
1.6%
46
1
10
100
Risk
Quotient
Turf
Ornamen
Turf
(
g
Papaya
Apples,
Grapes
Onion,
Cranber
Cucumbe
Melons
Tomato
Corn
(
E
Bananas
Corn
(
W
Potato
Fennel
Peanuts
Forestr
Christm
Tobacco
Grapes
Cotton
Asparag
Ornamen
Barley,
Vegetab
Citrus
Mancozeb
Application
Sites
Mammals
Feeding
on
Short
Grass
Mammals
Feeding
on
Forage
&
Small
Inse
Mammals
Feeding
on
Large
Insects
ETU's
Chronic
Mammalian
Risk
Risk
to
Large
Mammals
(
1,000
grams)

Figure
VII­
3­
ETU
Chronic
Risk
to
Mammalian
Herbivores
&
Insectivores
RQ
greater
or
equal
to
1
exceeds
chronic
LOCs.
Assumes
degradation
using
Fate
version
5.0
program
with
an
ETU
total
foliar
residue
half­
life
of
35
days
and
mancozeb
to
ETU
conversion
rate
of
1.6%
47
The
acute
risk
from
ETU
exposure
to
terrestrial
mammals,
because
of
mancozeb's
use,
is
expected
to
be
a
low
risk
since
ETU
is
practically
nontoxic
to
mammals
(
mouse
acute
oral
LD
50
=
2,300
mg/
kg).
EFED
did
not
calculate
ETU
acute
RQs
for
mammals
because
of
this
low
toxicity.
For
a
more
detailed
listing
and
explanation
of
ETU's
risk
to
mammals,
see
Appendix
IV.

d.
Terrestrial
Risk
Assessment
Where
will
the
ETU
exposure
come
from
when
applicators
treat
plants
with
the
parent
EBDCs?
ETU
exposure
will
result
from
direct
exposure
on
application
because
ETU
is:
°
in
the
formulation
because
of
particle
size
decreases
during
the
wet
or
dry
milling;
°
in
the
formulation
as
a
result
moisture
exposure
from
unfavorable
storage
conditions;
°
in
the
tank
mix
because
of
product
dilution;
or
°
all
three.
ETU
will
also
form
from
biodegradation
when
the
EBDC
parents
meet
with
the
soil.
However,
EFED
expects
the
hydrolysis
of
the
parent
EBDCs
will
produce
the
greatest
share
of
ETU
before
the
EBDCs'
complex
binds
to
the
soil
particles.
The
parent
EBDCs
last
briefly
in
the
environment
as
shown
in
calculated
half­
lives
from
registrant­
submitted,
hydrolysis,
studies.
Except
for
applications
to
dry
soils
in
dry
environments,
EFED
expects
a
rapid
change
of
the
parent
EBDCs
into
EBDC
complex,
including
ETU;
which
is
subjected
to
rapid
degradation
in
aerobic
soil
systems.

How
often
will
ETU
exposure
occur
from
the
parent
EBDCs'
applications
to
plants?
EFED
presumes
applications
of
the
parent
EBDC
fungicides
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
parent
EBDC
applications
will
result
in
rapid
degradation
of
these
parent
EBDCs
to
ETU
on
plant
surfaces.
EFED
figures
the
hydrolysis
of
the
parent
EDBCs
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
be
either
wet
during
the
application
or
shortly
after
a
parent
EBDC
application.
The
frequent
applications
of
the
parent
EBDCs,
in
wet
conditions,
would
provide
a
continuous
exposure
to
EBDC
complex
including
ETU.
Physical
wash
off
by
rain
and/
or
irrigation
is
expected
to
play
an
important
role
in
reducing
exposure
to
the
ETU
part
of
the
complex
because
of
its
high
solubility.

Mammals
are
likely
to
be
found
in
and
around
all
mancozeb
labeled
sites.
For
example,
producers
grow
tomatoes
throughout
the
US,
on
both
a
commercial
and
noncommercial
basis.
Pesticide
applicators
apply
around
860,000
lbs
of
mancozeb
yearly
to
49
%
of
the
US
planted,
fresh
tomatoes.
(
EPA
use
data
from
1992
through
2001)(
BEAD's
Quantitative
Usage
Analysis
for
Mancozeb
dated
November
1,
2002).
Cottontail
rabbits,
deer,
raccoons,
opossums,
skunks,
woodchucks,
muskrats,
and
groundhogs
all
feed
on
tomato
plants.
As
well
as
feeding,
some
of
these
animals
use
areas
in
and
around
tomatoes
for
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
(
in
late
summer
or
early
fall)
which
coincides
with
the
timing
of
the
mammal
pursuits
mentioned.
EFED
expects
mammalian
exposure
to
ETU
to
be
continuous
during
this
time
period.
Even
though
EFED
expects
a
continuous
exposure
to
mammals
from
ETU,
the
developmental
study
used
for
ETU's
chronic
assessment
endpoint
results
from
a
short­
term
exposure.
This
means
that
even
a
single
application
could
result
in
a
potential
chronic
toxicity
risk
to
mammals
from
ETU
exposure.
48
i.
Incidents
Based
on
information
available
in
the
Ecological
Incident
Information
System
(
EIIS),
the
Office
of
Pesticide
Programs
(
OPP)
has
not
received
any
incident
reports
about
adverse
wildlife
exposure
to
ETU.
However,
since
ETU
is
a
degradate
of
the
EDBCs
and
not
a
pesticide,
it
is
unlikely
that
OPP
would
receive
incident
reports
for
ETU.
Filed
incident
reports
would
most
likely
be
for
one
of
the
parent
EDBCs,
not
specifically
for
ETU.
See
Appendix
VI
for
description
and
background
of
EIIS.

ii.
Endocrine
Disruptors
The
Federal
Food,
Drug,
and
Cosmetic
Act
(
FFDCA)
requires
EPA,
as
amended
by
the
Food
Quality
Protection
Act
(
FQPA),
to
develop
a
screening
program.
This
program
is
to
decide
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
there
was
scientific
basis
for
including,
as
part
of
the
program,
the
androgen
and
thyroid
hormone
systems,
as
well
as
the
estrogen
hormone
system.
EPA
also
adopted
EDSTAC's
recommendation
including
in
the
Program
evaluations
of
potential
effects
in
wildlife.
For
pesticide
chemicals,
EPA
will
use
FIFRA
and
FFDCA
authority
to
require
the
wildlife
evaluations.
EPA
will
use
FFDCA
authority
to
evaluate
effects
in
wildlife
from
tests
that
Food
and
Drug
Administration
uses
to
discover
effects
in
humans.
As
the
science
develops
and
allows,
EPA
may
add
screening
of
more
hormone
systems
to
the
Endocrine
Disruptor
Screening
Program
(
EDSP).

The
mammalian
feeding
studies
for
ETU
performed
on
rats
and
dogs
ranged
in
time
from
3
to
4
months.
These
feeding
studies
found
the
following
effects:
changes
in
thyroid
hormones;
changes
in
liver
enzymes;
microscopic
changes
in
the
liver
and
thyroids;
increased
thyroid
weights;
and
increased
relative
liver
weights.
HED
reviewed
a
one­
dose
developmental
gavage
study
done
on
pregnant
laboratory
rats.
This
study
determined
that
treatment­
related
developmental
effects
caused
by
ETU
involved
gross
developmental
defects,
central
nervous
system
defects,
skeletal
deficiencies,
cryptorchidism
(
failure
of
one
or
more
testes
to
descend
into
the
scrotum),
and
decreased
fetal
weight.
See
Appendix
III
for
a
detailed
listing
of
the
studies
and
results.
These
effects
noted
in
mammals
could
be
a
result
of
hormonal
disruptions
and
might
suggest
that
ETU
may
be
an
endocrine
disruptor.
Based
on
these
effects
in
mammals,
EFED
recommends
that
when
EPA
develops
suitable
screening
and
testing
protocols,
considered
under
the
Agency's
EDSP,
ETU
be
subjected
to
more
definitive
testing
to
better
characterize
effects
related
to
its
endocrine
disruption.

iii.
Endangered
Species
Based
on
available
screening
level
information
there
is
a
potential
concern
for
chronic
ETU
effects
on
listed
mammals
should
exposure
actually
occur.
Chronic
ETU
RQs
exceed
LOCs
for
endangered
and
threatened
species
of
mammals
(
see
Section
c.
Risk
Quotients,
above,
for
details).
The
Agency
does
not
currently
have
data
on
which
to
evaluate
the
toxicity
of
ETU
to
endangered
or
threatened
birds
or
terrestrial
plants.
Because
of
this,
the
risks
to
endangered
or
threatened
species
of
birds
and
terrestrial
plants
from
ETU
exposure
is
uncertain.
EFED
is
requiring
the
data
to
assess
the
risk
to
endangered
or
threatened
species
of
birds
through
this
document.
EFED
is
reserving
the
terrestrial
plant
ETU
data
need
awaiting
a
review
of
the
parent
EBDC's
toxicity
to
terrestrial
plants.
49
50
APPENDIX
I:
Additional
Fate
Data
&
Background
for
Models
Used
Adsorption/
desorption
Data
K
ads
data
for
ETU
were
also
extracted
from
a
laboratory
technical
report
submitted
by
the
registrant
under
MRID
number
000971­
58
(
Table
IV­
4).
Data
indicate
high
to
medium
mobility
for
ETU
in
most
soils
except
Sassafras
sandy
loam
and
Cecil
clay
(
K
oc
ranges
from
783
to
855)
indicating
low
mobility.

Table
IV­
4.
K
ads
and
K
oc
and
characteristics
of
the
soils
used
in
the
adsorption/
desorption
study
(
MRID
000971­
58)

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
Kads
ETU
5
9
2
3
2
29
Koc
ETU
54
276
783
165
855
464
Kads
Mancozeb3
32
49
18
4
50
101
Koc
Mancozeb3
365
1,591
7,826
202
21,739
1,608
1
Montmorillonite
Clay;
2
Kaolinite
clay;
3
Mancozeb
Study
(
MRID
00888­
22).

Background
on
Models
Used
in
the
Assessment
Refer
to
Water
MEMO
(
Appendix
VI)
51
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
analyzes,
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).

b.
Fate
v.
5.0
Model
Terrestrial
Exposure
Values
52
EFED
calculated
the
exposure
estimates
of
ETU
to
be
a
fraction
of
the
exposure
estimates
for
mancozeb.
EFED
modeled
mancozeb
labeled
rates
using
FATE
version
5.0
then
multiplied
the
EECs
by
the
1.6%
conversion
rate.

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
=
Cie­
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
*

c.
Fate
v.
5.0
Model
Sample
Output
for
ETU
Residues
from
Mancozeb's
Use
RUN
No.
1
FOR
MANCOZEB
ON
APPLES,
ETC
***
INPUT
VALUES
***
­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­
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
53
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
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
54
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
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
55
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
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
56
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
57
APPENDIX
III:
Ecological
Hazards
Assessment
a.
Review
ETU
is
a
degradate
of
toxicological
concern
in
mammals.
Because
ETU
is
a
common
degradate
of
mancozeb,
metiram,
and
maneb,
EFED
is
providing
the
hazards
assessment
for
ETU
in
this
section
rather
than
providing
redundant
information
in
each
of
the
REDs
for
mancozeb,
metiram,
and
maneb.

b.
Toxicity
to
Terrestrial
Animals
i.
Birds,
Acute,
Subacute
and
Chronic
EFED
does
not
have
any
acute,
subacute
or
chronic
toxicity
data
to
evaluate
ETU's
toxicity
to
birds.
Because
of
this,
EFED
needs
the
Avian
Acute
Oral,
Avian
Acute
Dietary,
and
Avian
Reproduction
studies
[
guidelines
71­
1(
a),
71­
2
(
a
and
b),
and
71­
4
(
a
and
b),
respectively]
for
the
TGAI
of
ETU.

ii.
Mammals,
Acute
and
Chronic
1.
Acute
Oral
EFED
needs
for
wild
mammal
testing
depends
on
the
results
of
lower
tier
laboratory
mammalian
studies,
intended
use
pattern
and
environmental
fate
characteristics.
Usually,
rat
or
mouse
toxicity
values
received
from
the
Agency's
Health
Effects
Division
(
HED)
substitute
for
wild
mammal
testing.
EFED
took
the
toxicity
values
used
in
this
assessment
(
see
tables
that
follow)
from
HED.
This
assessment
used
HED's
Tox
One­
Liner,
preliminary
draft
reports
received
in
October,
1999
and
the
final
Hazard
Identification
Assessment
Review
Committee
(
HIARC)
reports
on
ETU
dated
November
16,
1999,
December
18,
2001,
and
May
28,
2003.
This
assessment
will
use
the
toxicity
values
(
LD
50
and
NOAEL)
appearing
in
the
shaded
areas
of
the
tables
to
calculate
the
acute
and
chronic
mammalian
risk
quotients
(
RQ's)
in
later
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
show
that
ETU
is
practically
nontoxic
to
mammals
from
acute
oral
exposure
(
Table
1).

Table
1:
Mammalian
Acute
Oral
Toxicity
­
ETU
Species
%
ai
LD
50
(
mg
ai/
kg)
Toxicity
Category)
Endpoints
Affected
MRID
or
Accession
(
AC)
No.

laboratory
mouse
(
Mus
musculus)
98.0
2,300
(
female)
practically
nontoxic
mortality
not
reported
20
The
failure
of
one
or
more
testes
to
descend
into
the
scrotum.

58
2.
Acute
Dermal
and
Inhalation
Toxicity
Testing
The
HED
reports
provided
no
acute
dermal
or
inhalation
endpoints
for
ETU.

3.
Mammalian
Subchronic
Toxicity
Testing
Table
2
shows
various
mammalian
subchronic
feeding
studies.
The
96.8%
ai
listing
in
Table
2
shows
a
3­
month
dietary
exposure
to
ETU
at
a
25
ppm
level
will
cause
thyroid
hyperplasia
in
mammals.
Thyroid
hyperplasia
is
an
increase
in
the
number
of
thyroid
cells
causing
and
enlargement
of
the
thyroid.

Table
2:
Mammalian
Subchronic
Toxicity
­
ETU
Surrogate
Species/
%
ai
NOAEL/
LOAEL
(
mg/
kg/
day)
LOAEL
Endpoints
MRID
or
Accession
(
AC)
No.

Laboratory
rat
(
Rattus
norvegicus)/
feeding­
3
months
99.8
not
determined/
14.28
(
n/
a/
250
ppm)
1
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
Domestic
dog
(
Canis
familiaris)/
feeding­
13
weeks
98.0
6.25/
66.23
(
150.0/
2000.0
ppm)
1
severe
thyroid
and
pituitary
hypertrophy
(
and
death
of
two
males);
increased
cholesterol
and
reduced
T4/
T3
in
both
sexes
not
reported
Laboratory
rat
(
Rattus
norvegicus)/
feeding­
4
months
not
reported
<
50.0/
50.0
ppm1
increased
thyroid
weights
not
reported
Laboratory
rat
(
Rattus
norvegicus)/
feeding­
3
months
96.8
5.0/
25.0
ppm1
thyroid
hyperplasia
not
reported
Laboratory
rat
(
Rattus
norvegicus)/
feeding­
3
months
not
reported
<
60.0/
60.0
ppm1
hepatoctic
cellular
atypia
(
abnormal
liver
cells)
AC259905
Laboratory
mouse
(
Mus
musculus)/
feeding­
3
months
not
reported
1.72/
18.18
(
10/
100
ppm)
1
thyroid
follicular
cell
hypertrophy
or
hyperplasia
AC2598882
1
ppm
results
provided
in
study
2
HED
classified
this
study
"
unacceptable/
guideline."
This
study
does
not
satisfy
guideline
requirements
for
a
subchronic
oral
study
in
mice
with
ethylene
thiourea
because
the
authors
failed
to
report
the
%
purity
and
dietary
concentrations
of
ETU.
An
upgrade
in
the
study
classification
of
the
ethylene
thiourea
portion
of
the
study
is
achievable
if
the
authors
report
these
data.

4.
Mammalian
Reproductive
&
Developmental
Toxicity
Testing
The
HIARC
report
(
2003)
concluded
there
were
data
gaps
for
a
developmental
toxicity
study
in
rabbits
and
a
2­
generation
reproduction
toxicity
in
rats.

Developmental
effects
caused
by
ETU
were
gross
developmental
defects,
central
nervous
system
defects,
skeletal
deficiencies,
cryptorchidism20,
and
decreased
fetal
weight
(
see
MRID
No.
00246663).
This
particular
study
also
determined
endpoints
for
the
parent,
mancozeb
(
see
Appendix
III
for
mancozeb
RED).
Although
mancozeb
and
ETU
caused
many
of
the
same
developmental
effects,
ETU
59
caused
these
effects
at
a
much
lower
level
(
50
mg/
kg/
day
or1000
ppm)
compared
to
mancozeb
(
512
mg/
kg/
day
or10,240
ppm).
In
this
rat
developmental
study,
the
authors
gave
50
mg/
kg/
day
of
ETU
to
a
single
dose
group
of
pregnant
rats
by
gavage
from
days
6­
15
of
gestation.
The
affected
endpoints
occurred
at
this
one
dose
level,
resulting
in
an
indecisive
NOAEL.
Other
developmental
effects
caused
by
ETU
were
defects
of
the
brain
(
exencephaly,
dilated
ventricles,
and
hypoplastic
cerebellum)
in
rats
(
MRID
No.
45937601).
In
this
study,
ETU
was
administered
to
rats
by
gavage
at
doses
of
0,
5,
10,
20,
40,
or
80
(
group
II
only)
mg/
kg/
day.
There
were
3
treatment
groups:
Group
I
was
treated
from
21­
42
days
before
mating
until
gestation
day
(
GD)
15,
Group
II
was
treated
from
GD
6­
15,
and
Group
III
from
GD
7­
20.
No
maternal
toxicity
was
noted
in
this
study
and
the
NOAEL
for
maternal
toxicity
is
80
mg/
kg/
day,
the
highest
dose
tested.
The
LOAEL
for
maternal
toxicity
was
not
determined.
The
NOAEL
for
developmental
toxicity
is
5
mg/
kg/
day
and
the
LOAEL
is
10
mg/
kg/
day
based
on
developmental
defects
of
the
brain
(
exencephaly,
dilated
ventricles,
and
hypoplastic
cerebellum).
To
assess
the
chronic
risks
to
mammals,
EFED
will
be
using
MRID
No.
45937601.

In
a
2­
generation
reproduction
study
(
MRID
42391701),
ETU
was
administered
to
rats
(
25/
sex/
dose
group)
in
diet
at
nominal
dietary
dose
levels
of
0,
2.5,
25,
or
125
ppm.
The
F0
generation
was
treated
for
70
days
before
mating
and
the
F1
generation
was
treated
126
days
before
mating.
EFED
did
not
list
or
use
this
study
because
there
was
variability
in
dietary
concentrations,
feed
spillage,
stability
problems
with
the
test
material,
and
unknown
feed
consumption.
These
uncertainties
made
calculating
intake
on
a
mg/
kg/
day
basis
impossible.
There
were
also
missing
pups
unaccounted
for
during
the
lactation
period.
The
HIARC
report
(
2003)
classified
this
study
as
unacceptable.

A
long­
term
(
1­
year)
feeding
study
on
dogs
resulted
in
decreased
body
weight
gain,
enlarged
thyroid
with
follicular
dilation
and
hypertrophy
at
a
50
ppm
ETU
exposure
level.
At
a
5.0
ppm
exposure
level,
ETU
effects
in
rats,
from
1­
2
year
feeding
studies,
resulted
in
enlarged
thyroids.

Table
3:
Mammalian
Feeding,
Developmental
and
Reproductive
Chronic
Toxicity
­
ETU
Species/
Study
Duration
%
ai
Test
Type
NOAEL/
LOAEL
Toxicity
Value
(
mg/
kg/
day)
Endpoints
Affected
MRID
or
Accession
(
AC)
No.

laboratory
rat
(
Rattus
norvegicus)
/
not
reported
99.0
Developmental
not
determined/
50
(
not
determined/
1000
ppm)
1
(
maternal
&
developmental)
extrapolated
NOAEL=
0.05
mg/
kg/
day
or
1
ppm1
using
UFs
mat.
­
decreased
body
wt.
gain
dev.
­
gross
developmental
defects,
central
nervous
system
defects,
skeletal
defects,
cryptorchidism,
and
decreased
fetal
weight
00246663
laboratory
rat
(
Rattus
norvegicus)
/
not
reported/
not
reported
not
reported
Developmental
5/
10
(
100/
200
ppm)
1
mat.
­
No
maternal
toxicity
was
noted
in
this
study
dev.
­
Based
on
developmental
defects
of
the
brain
(
exencephaly,
dilated
ventricles,
and
hypoplastic
cerebellum).
45937601
Khera,
K.
S.;
Teratology
7:
243­
252.
1973
Domestic
dog
(
Canis
familiaris)/
1­
year
98.0
Feeding
0.185/
1.89
(
5.0/
50.0
ppm)
2
decreased
body
weight
gain,
enlarged
thyroid,
accompanied
by
follicular
dilation
and
hypertrophy
42338101
Laboratory
rat
(
Rattus
norvegicus)
/
1­
year
not
reported
Feeding
<
5.0/
5.0
ppm
increased
vascularity
of
the
thyroid
AC259905
Table
3:
Mammalian
Feeding,
Developmental
and
Reproductive
Chronic
Toxicity
­
ETU
Species/
Study
Duration
%
ai
Test
Type
NOAEL/
LOAEL
Toxicity
Value
(
mg/
kg/
day)
Endpoints
Affected
MRID
or
Accession
(
AC)
No.

60
laboratory
rat
(
Rattus
norvegicus)
/
2­
year
96.2
Feeding
0.17
/
0.37
(
male)
2.5/
5.0
ppm2
diffuse
follicular
hyperplasia
of
the
thyroid
gland
and
round
cell
infiltration
of
the
lungs
in
males
at
week
52
not
reported
laboratory
rat
(
Rattus
norvegicus)
/
2­
year
not
reported
Feeding
<
5.0/
5.0
ppm
thyroid
follicular
cell
hyperplasia
AC259905
1
ppm
conversion
based
on:
1
mg/
kg/
day
=
20
ppm
in
adult
rats.
(
Nelson,
1975)
2
ppm
results
provided
in
study
iii.
Insect
Acute
Contact
EFED
is
not
requiring
insect
testing
of
the
degradate,
ETU.
The
parent
EBDCs
are
practically
nontoxic
to
honeybees
from
short­
term
contact
exposure
(
Guideline
141­
1)
and
significant
ETU
exposure
to
honeybees
in
flight
or
while
foraging
on
the
nectar
or
pollen
producing
parts
of
plants
is
unlikely.
ETU
results
from
both
the
initial
rapid
hydrolysis
of
parent
EBDCs
and
the
slow,
continuous
degradation
of
the
parent
EBDCs
in
soil
and
sediment.

iv.
Terrestrial
Field
Testing
EFED
is
not
needing
terrestrial
field­
testing
for
ETU
and
registrants
have
not
filed
any
ETU
terrestrial
field
studies
for
review.

c.
Toxicity
to
Aquatic
Organism
Preface
EFED
has
limited
acute
toxicity
data
to
evaluate
ETU's
toxicity
to
aquatic
organisms.
EFED
is
requiring
submission
of
or
reserving
the
need
for
the
following
guidelines
studies:

72­
1(
a)
Acute
Fish
Toxicity
Bluegill
a
freshwater
fish
dwelling
in
warm
waters
72­
3(
a)
Acute
Estuarine/
Marine
Toxicity
Fish
72­
3(
b)
Acute
Estuarine/
Marine
Toxicity
Mollusk
72­
3(
c)
Acute
Estuarine/
Marine
Toxicity
Shrimp
72­
4(
a)
Early
Life­
Stage
Fish
for
freshwater
and
estuarine/
marine
species
72­
4(
b)
Life­
Cycle
Aquatic
Invertebrate
for
freshwater
and
estuarine/
marine
species
EFED
needs
submission
of
these
studies
for
the
TGAI
of
ETU.
The
first
study
listed
above
[
72­
1(
a)]
is
a
basic
study
need
for
all
pesticides.
EFED
is
requiring
this
study
for
ETU
because
ETU
is
a
degradate
toxic
to
mammals
which
may
be
toxic
to
aquatic
wildlife.
The
next
three
studies
[
72­
3(
a,
b,
and
c)],
deal
with
the
acute
toxicity
to
estuarine
and
marine
species.
EFED
needs
these
studies
because
of
the
EBDCs'
use
in
coastal
counties
where
EFED
expects
estuarine
or
marine
exposure
to
the
EBDCs
and
their
common
degradate,
ETU.
The
next
two
studies
[
72­
4(
a
and
b)]
deal
with
chronic
61
toxicity
to
aquatic
fish
and
aquatic
invertebrate
species.
EFED
reserves
the
need
for
these
studies
pending
completed
ETU
acute
toxicity
testing
of
freshwater
and
estuarine
marine
organisms.
ETU
has
not
triggered
any
risk
based
on
acute
freshwater
fish
and
invertebrate
testing
with
no
LOCs
exceeded
for
freshwater
fish
and
invertebrates.
EFED
evaluated
this
ETU
risk
based
on
mancozeb's
use
pattern.
ETU
does
not
appear
to
be
persistent
in
the
aquatic
environment.
Quantities
of
ETU
that
reach
or
form
in
natural
surface
water
are
expected
to
be
stable
to
hydrolysis/
direct
photolysis,
however,
it
was
reported
that
ETU
can
be
removed
rather
quickly
from
these
waters
by
indirect
photolysis
(
half­
lives
of
1­
4
days)
(
Sue
XU,
2000).
EFED
is
reserving
the
requirement
for
Life
Cycle
Fish
studies
for
both
freshwater
and
estuarine
or
marine
fish
species
(
guideline
72­
5)
awaiting
the
results
of
the
Early
Life­
Stage
testing
(
guideline
72­
4a),
if
this
study
is
needed.

i.
Toxicity
to
Freshwater
Animals
1.
Freshwater
Fish,
Acute
The
Agency
requires
two
freshwater
fish
toxicity
studies
using
the
TGAI
to
find
out
the
toxicity
of
ETU
to
fish.
The
preferred
test
species
are
rainbow
trout
(
a
cold
water
fish,
Guideline
72­
1c)
and
bluegill
sunfish
(
a
warm
water
fish;
Guideline
72­
1a).
Tabulated
below,
are
results
of
the
rainbow
trout
test.
The
toxicity
category
descriptions
for
freshwater
and
estuarine
or
marine
fish
and
aquatic
invertebrates,
are
below
in
parts
per
million
(
ppm),
the
standard
units
of
measure
(
Brooks,
1973).
EFED
will
use
the
toxicity
values
(
LC
50
)
appearing
in
the
shaded
area
of
the
tables
to
calculate
the
acute
aquatic
risk
quotients
(
RQ's).

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.

Based
on
acute
exposure,
ETU
is
practically
nontoxic
to
cold
water
fish
(
rainbow
trout
LC
50
>
502
ppm
based
on
measured
samples)
(
see
Table
4,
below).
MRID
No.
45910401
(
duplicate
MRID
No.
46020903)
fulfills
the
guideline
72­
1(
c)
need.
EFED
needs
a
core
freshwater
fish
study
for
a
warm
water
fish
to
fulfill
guideline
72­
1(
a).

Table
4:
Freshwater
Fish
96­
hr
Acute
Toxicity
­
ETU
Technical
Species/
Flow­
through
or
Static/
Duration
%
ai
LC50
/
(
ppm
ai)/
(
measured/
nominal)
Toxicity
Category
MRID
/
Accession
No./
Author/
Year
Study
Classification1
Rainbow
Trout
(
Oncorhynchus
mykiss)/
static/
96­
hour
99.9
>
502
(
measured)
practically
nontoxic
45910401
or
46020903/
Zok,
S./
2001
Core
2.
Freshwater
Invertebrates,
Acute
The
Agency
requires
a
freshwater
aquatic
invertebrate
toxicity
test
using
the
TGAI
to
find
out
the
acute
toxicity
of
ETU
to
aquatic
invertebrates.
The
preferred
test
organism
is
Daphnia
magna,
but
early
instar
amphipods,
stoneflies,
mayflies,
or
midges
are
also
acceptable.
A
core
acute
daphnid
study
(
MRID
No.
45910402)
shows
ETU's
freshwater
aquatic
invertebrates
EC
50
value
is
26.9
ppm
based
on
measured
samples.
Tabulated
below
(
Table
5)
are
the
results
of
this
test.
MRID
No.
45910402
62
(
duplicate
MRID
No.
46020901)
fulfills
the
guideline
72­
2(
a)
need.

Table
5:
Freshwater
Invertebrate
Acute
Toxicity
­
Metiram
Technical
Species/
Static
or
Flowthrough
Duration
%
ai
LC50/
EC50
(
ppm)/
(
nominal/
measured)
Toxicity
Category
MRID/
Accession
(
AC)
No.
Author/
Year
Study
Classification1
Daphnid
(
Daphnia
magna)/
static
(
48
hr.)
99.6
26.9
(
measured)
slightly
toxic
45910402
or
46020901/
Hisgen/
2000
Core
1
Core
(
study
satisfies
guideline).
Supplemental
(
study
is
scientifically
sound,
but
does
not
satisfy
guideline)

ii.
Aquatic
Field
Studies
EFED
reviewed
a
draft
freshwater
simulated
aquatic
field
study
(
MRID
No.
44944401)
in
February
2000.
The
Mancozeb
RED
contains
a
shortened
review
of
this
field
study.
The
authors
of
the
study
initially
tried
to
base
the
results
on
measured
concentrations
of
ETU
since
they
expected
a
2
to
14­
hour
mancozeb
half­
life
in
an
aquatic
environment.
The
authors
were
unable
to
base
their
results
on
measured
concentrations
of
ETU
because
they
could
not
analytically
detect
ETU
at
the
low
levels
needed.
Because
of
this,
the
authors
based
the
results
of
the
study
on
nominal
concentrations
of
mancozeb.
This
study
did
not
provide
any
useful
information
on
the
toxicological
effects
of
ETU
in
a
freshwater
ecosystem.

d.
Toxicity
to
Plants
i.
Terrestrial
Plants
EFED
has
no
toxicological
data
to
settle
the
toxicity
of
ETU
to
terrestrial
plants
and
limited
data
on
the
parent
EBDC
compounds.
For
the
parent
EBDC
compounds,
EFED
has
reviewed
one
core
study
(
MRID
No.
44283401)
which
showed
there
was
no
phytotoxicity
concerns.
This
study
was
an
MAI
TEP
with
mancozeb
being
one
of
two
active
ingredients.
EFED
is
seeking
an
SAI
TEP
Tier
I
seedling
emergence
[
guideline
122­
1(
a)]
and
vegetative
vigor
[
guideline
122­
1(
b)]
for
the
parent
EBDC
compounds
(
mancozeb,
metiram
and
maneb).
Now,
until
EFED
receives
and
reviews
the
testing
results
on
the
parent
compounds,
EFED
is
reserving
the
testing
needs
for
the
metabolite,
ETU.

ii.
Aquatic
Plants
ETU
does
not
appear
to
be
persistent
in
the
aquatic
environment.
Quantities
of
ETU
that
reach
or
form
in
natural
surface
water
are
expected
to
be
stable
to
hydrolysis/
direct
photolysis,
however,
it
was
reported
that
ETU
can
be
removed
rather
quickly
from
these
waters
by
indirect
photolysis
(
half­
lives
63
of
1­
4
days)
(
Sue
XU,
2000).
However
ETU
is
the
major
degradate
of
all
three
EBDC
compounds,
and
the
EBDCs
rapidly
breakdown
to
ETU
in
aquatic
environments.
Because
of
this,
EFED
is
recommending
Tier
I
(
guideline
122­
2)
or
Tier
II
(
guideline
123­
2)
aquatic
plant
testing
for
ETU.
Tier
I
aquatic
plant
testing
is
a
maximum
dose
test
designed
to
evaluate
the
toxic
effects
to
the
test
species
in
growth
and
reproduction.
The
result
of
Tier
I
testing
decides
the
need
for
more
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
at
the
Tier
I
level.
Tier
II
testing
fixes
the
harmful
effect
levels
of
the
chemical
on
the
aquatic
plants
which
showed
a
greater
than
50%
damaging
effect
in
Tier
I
testing.

For
ETU,
EFED
reviewed
one
Tier
II
supplemental
study
for
Pseudokirchneriella
subcapitata
(
formerly
Selenastrum
capricornutum),
a
freshwater
green
alga.
EFED
tabulated
results
of
Tier
II
toxicity
testing
on
the
technical
material
in
Table
6,
below.
The
EC
50
for
Pseudokirchneriella
subcapitata
was
23.0
ppm
a.
i.
based
on
a
decline
in
cell
density;
the
NOAEC
was
12.5
ppm.
EFED
classified
MRID
No.
45910403
(
duplicate
MRID
No.
46020902)
as
supplemental
because
the
test
duration
was
only
72
hours
and
the
guidelines
require
the
test
duration
to
be
120
hours.
EFED
will
use
the
toxicity
value
(
EC
50
)
appearing
in
the
shaded
area
of
the
table
to
calculate
the
acute
risk
quotients
(
RQ's)
in
later
sections.
EFED
still
needs
core
studies
to
evaluate
ETU's
toxicity
to
aquatic
plants.
EFED
needs
core
Tier
I
or
Tier
II
aquatic
plant
growth
studies
for
duckweed
(
Lemna
gibba),
marine
diatom
(
Skeletonema
costatum),
blue­
green
algae
(
Anabaena
flos­
aquae),
freshwater
green
alga
(
Selenastrum
capricornutum),
and
a
freshwater
diatom.

Table
6:
Nontarget
Aquatic
Plant
Toxicity
(
Tier
II)
­
ETU
Species/
duration
%
A.
I.
EC50/
NOAEC
(
ppm
ai)
MRID
No.
Author/
year
Classification1
Nonvascular
Plants
freshwater
green
algae
(
Pseudokirchneriel
la
subcapitata)
/
72
hrs.
99.6
23.0/
12.5
(
measured)
45910403
or
46020902/
Reuschenbach/
2000
Supplemental
1
Core
(
study
satisfies
guideline).
Supplemental
(
study
is
scientifically
sound,
but
does
not
satisfy
guideline).

iii.
Aquatic
Plant
Field
Studies
EFED
is
not
seeking
aquatic
plant
field­
testing
for
ETU
and
registrants
have
not
filed
any
ETU
aquatic
plant
field
studies
for
review.
64
APPENDIX
IV:
Environmental
Exposure
Assessment
a.
Review
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
nontarget
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
nontarget
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;
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
nontarget
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
nontarget
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
as
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
drawn
from
the
calculation
either
exceeds
a
fixed
LOC
or
does
not
exceed
it.
(
US
EPA.
June
30,
1995).
65
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
b.
Exposure
and
Risk
to
Terrestrial
Animals
i.
Birds
EFED
is
unable
to
assess
the
acute
or
chronic
risk
to
birds
because
the
toxicity
of
ETU
to
these
organisms
is
unknown.
EFED
is
requiring
that
studies
to
provide
this
toxicity
information
through
this
66
document
(
see
appendices
III
and
V).

ii.
Mammals
As
identified
in
Appendix
III,
ETU
is
practically
nontoxic
(
mouse
acute
oral
LD
50
=
2,300
mg/
kg)
to
mammals.
Because
of
this,
EFED
expects
ETU
to
present
a
low
acute
risk
to
mammals
so
EFED
did
not
calculate
RQs
for
acute
exposure.

Tabulated
below,
in
tables
4
and
4a,
are
the
chronic
mammalian
risk
quotients
of
ETU
for
multiple
broadcast
applications
of
nongranular
mancozeb
products.
The
EECs
modeled
for
ETU
assumes
1.6
percent
conversion
of
mancozeb
to
ETU
as
an
estimate
of
exposure.
EFED
also
assumed
a
35­
day
total
foliar
residue
dissipation
half­
life
for
ETU
in
predicting
EECs.
The
RQs
produced
for
ETU
in
this
table
are
the
RQs
that
EFED
would
expect
from
the
use
patterns
for
mancozeb.
EFED
could
have
created
similar
RQs
based
on
the
use
patterns
of
the
other
two
parent
compounds
for
ETU,
metiram
and
maneb.
EFED
chose
not
to
perform
more
calculations
for
metiram
and
maneb,
since
further
RQ
calculations
would
be
comparable
confirming
ETU's
chronic
risk
to
mammals.
In
addition,
mancozeb,
of
the
three
EBDC
fungicides,
has
the
broadest
use
pattern
(
most
sites
of
application)
and
thus
EFED
expected
mancozeb
to
provide
a
more
comprehensive
view
of
the
chronic
risks
posed
by
ETU.
ETU's
RQs
exceeded
chronic
LOCs
for
all
mancozeb's
uses.
For
small
mammals
(
15­
gram)
feeding
on
short
grass,
the
chronic
RQs
range
from
a
high
of
37.79
from
mancozeb
turf
applications
to
1.73
from
mancozeb
citrus
applications.
For
medium
sized
mammals
(
35­
gram)
feeding
on
short
grass,
ETU's
chronic
RQ
range
from
26.25
for
turf
applications
of
mancozeb
to
1.2
on
citrus.
For
large
mammals
(
1,000
gram)
feeding
on
short
grass,
the
RQs
range
from
5.97
on
turf
to
1.07
on
bananas.
There
are
no
ETU
chronic
LOC
exceedances
to
large
mammals
from
mancozeb's
use
on
potato
&
sugar
beet,
fennel,
peanuts,
forestry
(
douglas
fir),
Christmas
tree
plantations,
tobacco,
cotton,
asparagus,
garlic
&
shallot,
ornamentals,
barley,
etc.,
vegetables
or
citrus.
EFED
also
calculated
the
RQs
for
granivore
mammals.
For
mammalian
granivores,
no
chronic
LOC
for
ETU
from
mancozeb's
uses
was
exceeded
(
see
Table
4a
for
details).
ETU
effects
triggering
this
chronic
risk
were
based
on
developmental
defects
of
the
brain
(
that
is,
exencephaly,
dilated
ventricles,
and
hypoplastic
cerebellum)
in
rats.
67
Table
4:
Mammalian
(
Herbivore/
Insectivore)
Chronic
Risk
Quotients
From
ETU
Exposure
for
Multiple
Applications
of
Mancozeb
Nongranular
(
Broadcast)
Using
a
NOAEL
of
5
mg/
kg/
day
for
Mancozeb's
Metabolite,
ETU,
based
on
developmental
defects
of
the
brain
(
exencephaly,
dilated
ventricles,
and
hypoplastic
cerebellum)
in
a
study
on
labaratory
rats
(
Rattus
norvegicus).

Maximum
Application
Rate
Chronic
RQ
Maximum
EEC
(
mg/
kg)
Maximum
(
lbs
ai/
A)/

Chronic
RQ
Forage
&
Chronic
RQ
EEC
(
mg/
kg)
Forage
&
EEC
(
mg/
kg)
%
Body
Body
Number
of
Large
Small
Short
Large
Small
Short
Weight
Weight
Applications/
Site/

Insects
2,3
Insects
2,3
Grass
2,3
Insects
1
Insects
1
Grass1
Consumed
(
grams)
Interval
Application
Method/

0.72
6.48
11.52
4
34
61
95
15
4.8/
4
Apples,
Cranapple,

0.50
4.50
8.00
4
34
61
66
35
7­
day
interval
Pear,
&
Quince
0.11
1.02
1.82
4
34
61
15
1000
ground
&
aerial
0.22
2.00
3.56
1
11
19
95
15
1.6/
4
Asparagus
0.15
1.39
2.47
1
11
19
66
35
10­
day
interval
ground
&
aerial
0.04
0.32
0.56
1
11
19
15
1000
0.42
3.81
6.78
2
20
36
95
15
2.4/
10
Bananas
&
Plantain
0.29
2.65
4.71
2
20
36
66
35
14­
day
interval
ground
&
aerial
0.07
0.60
1.07
2
20
36
15
1000
0.19
1.73
3.07
1
9
16
95
15
1.6/
3
Barley,
Oats,
Rye,

0.13
1.20
2.13
1
9
16
66
35
7­
day
interval
Triticale,
&
Wheat
0.03
0.27
0.48
1
9
16
15
1000
ground
&
aerial
0.11
0.97
1.73
1
5
9
95
15
0.9/
3
a
Citrus
0.07
0.67
1.20
1
5
9
66
35
7­
day
interval
ground
&
aerial
0.02
0.15
0.27
1
5
9
15
1000
0.50
4.50
7.99
3
24
42
95
15
1.2/
15
Corn
(
unspecified)

0.35
3.12
5.55
3
24
42
66
35
4­
day
interval
(
E.
of
Miss.
River)

0.08
0.71
1.26
3
24
42
15
1000
ground
&
aerial
0.39
3.54
6.29
2
19
33
95
15
1.2/
10
Corn
(
unspecified)

0.27
2.46
4.37
2
19
33
66
35
4­
day
interval
(
W.
of
Miss.
River)

0.06
0.56
0.99
2
19
33
15
1000
ground
&
aerial
0.22
2.00
3.56
1
11
19
95
15
1.6/
4
Cotton
0.15
1.39
2.47
1
11
19
66
35
10­
day
interval
ground
&
aerial
0.04
0.32
0.56
1
11
19
15
1000
0.58
5.18
9.20
3
27
48
95
15
4.8/
3
Cranberry
0.40
3.60
6.39
3
27
48
66
35
7­
day
interval
ground
&
aerial
0.09
0.82
1.45
3
27
48
15
1000
68
Table
4:
Mammalian
(
Herbivore/
Insectivore)
Chronic
Risk
Quotients
From
ETU
Exposure
for
Multiple
Applications
of
Mancozeb
Nongranular
(
Broadcast)
Using
a
NOAEL
of
5
mg/
kg/
day
for
Mancozeb's
Metabolite,
ETU,
based
on
developmental
defects
of
the
brain
(
exencephaly,
dilated
ventricles,
and
hypoplastic
cerebellum)
in
a
study
on
labaratory
rats
(
Rattus
norvegicus).

Application
Rate
Chronic
RQ
EEC
(
mg/
kg)
(
lbs
ai/
A)/

Chronic
RQ
Forage
&
Chronic
RQ
EEC
(
mg/
kg)
Forage
&
EEC
(
mg/
kg)
%
Body
Body
Number
of
Large
Small
Short
Large
Small
Short
Weight
Weight
Applications/
Site/

Insects
2,3
Insects
2,3
Grass
2,3
Insects
1
Insects
1
Grass1
Consumed
(
grams)
Interval
Application
Method/

0.57
5.10
9.06
3
27
48
95
15
2.4/
8
Cucumber
0.39
3.54
6.30
3
27
48
66
35
7­
day
interval
ground
&
aerial
0.09
0.81
1.43
3
27
48
15
1000
0.38
3.40
6.04
2
18
32
95
15
1.6/
8
Fennel
0.26
2.36
4.20
2
18
32
66
35
7­
day
interval
ground
&
aerial
0.06
0.54
0.95
2
18
32
15
1000
0.64
5.73
10.19
3
30
54
95
15
3.2/
6
Grapes
0.44
3.98
7.08
3
30
54
66
35
7­
day
interval
(
E.
of
Rocky
Mtns.)

0.10
0.90
1.61
3
30
54
15
1000
ground
&
aerial
0.24
2.16
3.84
1
11
20
95
15
2.0/
3
Grapes
0.17
1.50
2.66
1
11
20
66
35
7­
day
interval
(
W.
of
Rocky
Mtns.)

0.04
0.34
0.61
1
11
20
15
1000
ground
&
aerial
0.57
5.10
9.06
3
27
48
95
15
2.4/
8
Melons
&
Squash
0.39
3.54
6.30
3
27
48
66
35
7­
day
interval
ground
&
aerial
0.09
0.81
1.43
3
27
48
15
1000
0.63
5.71
10.15
3
30
53
95
15
2.4/
10
Onion,
Garlic,
&
Shallot
0.44
3.96
7.05
3
30
53
66
35
7­
day
interval
ground
&
aerial
0.10
0.90
1.60
3
30
53
15
1000
0.97
8.71
15.48
5
46
81
95
15
4.0/
7
Papaya
0.67
6.05
10.75
5
46
81
66
35
5­
day
interval
ground
&
aerial
0.15
1.37
2.44
5
46
81
15
1000
0.38
3.40
6.04
2
18
32
95
15
1.6/
8
Peanuts
0.26
2.36
4.20
2
18
32
66
35
7­
day
interval
ground
&
aerial
0.06
0.54
0.95
2
18
32
15
1000
69
Table
4:
Mammalian
(
Herbivore/
Insectivore)
Chronic
Risk
Quotients
From
ETU
Exposure
for
Multiple
Applications
of
Mancozeb
Nongranular
(
Broadcast)
Using
a
NOAEL
of
5
mg/
kg/
day
for
Mancozeb's
Metabolite,
ETU,
based
on
developmental
defects
of
the
brain
(
exencephaly,
dilated
ventricles,
and
hypoplastic
cerebellum)
in
a
study
on
labaratory
rats
(
Rattus
norvegicus
).

Application
Rate
Chronic
RQ
EEC
(
mg/
kg)
(
lbs
ai/
A)/

Chronic
RQ
Forage
&
Chronic
RQ
EEC
(
mg/
kg)
Forage
&
EEC
(
mg/
kg)
%
Body
Body
Number
of
Large
Small
Short
Large
Small
Short
Weight
Weight
Applications/
Site/

Insects
2,3
Insects
2,3
Grass
2,3
Insects
1
Insects
1
Grass1
Consumed
(
grams)
Interval
Application
Method/

0.39
3.48
6.19
2
18
33
95
15
1.6/
7
Potato
&
Sugar
Beet
0.27
2.42
4.30
2
18
33
66
35
5­
day
interval
ground
&
aerial
0.06
0.55
0.98
2
18
33
15
1000
0.25
2.24
3.98
1
12
21
95
15
2.0/
3
a
Tobacco
0.17
1.55
2.76
1
12
21
66
35
5­
day
interval
ground
&
aerial
0.04
0.35
0.63
1
12
21
15
1000
0.53
4.73
8.40
3
25
44
95
15
2.4/
7
Tomato
0.36
3.28
5.84
3
25
44
66
35
7­
day
interval
ground
&
aerial
0.08
0.75
1.33
3
25
44
15
1000
0.18
1.62
2.88
1
9
15
95
15
1.5/
3
a
Vegetablesb
0.12
1.12
2.00
1
9
15
66
35
7­
day
interval
ground
&
aerial
0.03
0.26
0.45
1
9
15
15
1000
0.34
3.06
5.45
2
16
29
95
15
3.2/
3
a
Forestry
(
Douglas
Fir)

0.24
2.13
3.78
2
16
29
66
35
14­
day
interval
ground
&
aerial
0.05
0.48
0.86
2
16
29
15
1000
0.34
3.06
5.45
2
16
29
95
15
3.2/
3
a
Ornamental
Trees
c
0.24
2.13
3.78
2
16
29
66
35
14­
day
interval
ground
&
aerial
0.05
0.48
0.86
2
16
29
15
1000
0.19
1.73
3.07
1
9
16
95
15
1.6/
3
a
Ornamentals
d
0.13
1.20
2.13
1
9
16
66
35
7­
day
interval
ground
&
aerial
0.03
0.27
0.48
1
9
16
15
1000
2.22
19.96
35.48
12
105
187
95
15
13.9/
5
Ornamentals
1.54
13.86
24.65
12
105
187
66
35
10­
day
interval
(
pachysandra
groundcover)

0.35
3.15
5.60
12
105
187
15
1000
ground
2.16
19.47
34.61
11
102
182
95
15
17.4/
3
a
Turf
(
golf
course)

1.50
13.52
24.04
11
102
182
66
35
5­
day
interval
ground
0.34
3.07
5.46
11
102
182
15
1000
2.36
21.26
37.79
12
112
199
95
15
19.0/
3
a
Turf
e
1.64
14.77
26.25
12
112
199
66
35
5­
day
interval
ground
&
aerial
0.37
3.36
5.97
12
112
199
15
1000
1
Assumes
degradation
using
FATE
version
5.0
program
with
an
ETU
total
foliar
residue
half­
life
of
35
days
and
mancozeb
to
ETU
conversion
rate
of
1.6%.

2
RQ
=
EEC
(
mg/
kg)/[
NOAEL
(
mg/
kg­
bw/
day)/
%(
decimal)
Body
Weight
Consumed
(
bw/
day)]
3
RQ
greater
or
equal
to
1.0
exceeds
chronic
risk
LOCs.

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
70
Table
4a:
Mammalian
(
Granivore)
Chronic
Risk
Quotients
From
ETU
Exposure
for
Multiple
Applications
of
Mancozeb
Nongranular
(
Broadcast)
Using
a
NOAEL
of
5
mg/
kg/
day
for
Mancozeb's
Metabolite,
ETU,
based
on
developmental
defects
of
the
brain
(
exencephaly,
dilated
ventricles,
and
hypoplastic
cerebellum)
in
a
study
on
labaratory
rats
(
Rattus
norvegicus).

Application
Rate
(
lbs
ai/
A)/

Maximum
%
Body
Body
Number
of
Chronic
RQ
EEC
(
mg/
kg)
Weight
Weight
Applications/
Site/

Seeds
2,3
Seeds1
Consumed
(
grams)
Interval
Application
Method/

0.16
4
21
15
4.8/
4
Apples,
Cranapple,

0.11
4
15
35
7­
day
interval
Pear,
&
Quince
0.02
4
3
1000
ground
&
aerial
0.05
1
21
15
1.6/
4
Asparagus
0.04
1
15
35
10­
day
interval
ground
&
aerial
0.01
1
3
1000
0.09
2
21
15
2.4/
10
Bananas
&
Plantain
0.07
2
15
35
14­
day
interval
ground
&
aerial
0.01
2
3
1000
0.04
1
21
15
1.6/
3
Barley,
Oats,
Rye,

0.03
1
15
35
7­
day
interval
Triticale,
&
Wheat
0.01
1
3
1000
ground
&
aerial
0.02
1
21
15
0.9/
3
a
Citrus
0.02
1
15
35
7­
day
interval
ground
&
aerial
0.00
1
3
1000
0.11
3
21
15
1.2/
15
Corn
(
unspecified)

0.08
3
15
35
4­
day
interval
(
E.
of
Miss.
River)

0.02
3
3
1000
ground
&
aerial
0.09
2
21
15
1.2/
10
Corn
(
unspecified)

0.06
2
15
35
4­
day
interval
(
W.
of
Miss.
River)

0.01
2
3
1000
ground
&
aerial
0.05
1
21
15
1.6/
4
Cotton
0.04
1
15
35
10­
day
interval
ground
&
aerial
0.01
1
3
1000
0.13
3
21
15
4.8/
3
Cranberry
0.09
3
15
35
7­
day
interval
ground
&
aerial
0.02
3
3
1000
71
Table
4a:
Mammalian
(
Granivore)
Chronic
Risk
Quotients
From
ETU
Exposure
for
Multiple
Applications
of
Mancozeb
Nongranular
(
Broadcast)
Using
a
NOAEL
of
5
mg/
kg/
day
for
Mancozeb's
Metabolite,
ETU,
based
on
developmental
defects
of
the
brain
(
exencephaly,
dilated
ventricles,
and
hypoplastic
cerebellum)
in
a
study
on
labaratory
rats
(
Rattus
norvegicus).

Application
Rate
(
lbs
ai/
A)/

%
Body
Body
Number
of
Chronic
RQ
EEC
(
mg/
kg)
Weight
Weight
Applications/
Site/

Seeds
2,3
Seeds1
Consumed
(
grams)
Interval
Application
Method/

0.13
3
21
15
2.4/
8
Cucumber
0.09
3
15
35
7­
day
interval
ground
&
aerial
0.02
3
3
1000
0.08
2
21
15
1.6/
8
Fennel
0.06
2
15
35
7­
day
interval
ground
&
aerial
0.01
2
3
1000
0.14
3
21
15
3.2/
6
Grapes
0.10
3
15
35
7­
day
interval
(
E.
of
Rocky
Mtns.)

0.02
3
3
1000
ground
&
aerial
0.05
1
21
15
2.0/
3
Grapes
0.04
1
15
35
7­
day
interval
(
W.
of
Rocky
Mtns.)

0.01
1
3
1000
ground
&
aerial
0.13
3
21
15
2.4/
8
Melons
&
Squash
0.09
3
15
35
7­
day
interval
ground
&
aerial
0.02
3
3
1000
0.14
3
21
15
2.4/
10
Onion,
Garlic,
&
Shallot
0.10
3
15
35
7­
day
interval
ground
&
aerial
0.02
3
3
1000
0.21
5
21
15
4.0/
7
Papaya
0.15
5
15
35
5­
day
interval
ground
&
aerial
0.03
5
3
1000
0.08
2
21
15
1.6/
8
Peanuts
0.06
2
15
35
7­
day
interval
ground
&
aerial
0.01
2
3
1000
72
Table
4a:
Mammalian
(
Granivore)
Chronic
Risk
Quotients
From
ETU
Exposure
for
Multiple
Applications
of
Mancozeb
Nongranular
(
Broadcast)
Using
a
NOAEL
of
5
mg/
kg/
day
for
Mancozeb's
Metabolite,
ETU,
based
on
developmental
defects
of
the
brain
(
exencephaly,
dilated
ventricles,
and
hypoplastic
cerebellum)
in
a
study
on
labaratory
rats
(
Rattus
norvegicus
).

Application
Rate
(
lbs
ai/
A)/

%
Body
Body
Number
of
Chronic
RQ
EEC
(
mg/
kg)
Weight
Weight
Applications/
Site/

Seeds
2,3
Seeds1
Consumed
(
grams)
Interval
Application
Method/

0.09
2
21
15
1.6/
7
Potato
&
Sugar
Beet
0.06
2
15
35
5­
day
interval
ground
&
aerial
0.01
2
3
1000
0.05
1
21
15
2.0/
3a
Tobacco
0.04
1
15
35
5­
day
interval
ground
&
aerial
0.01
1
3
1000
0.12
3
21
15
2.4/
7
Tomato
0.08
3
15
35
7­
day
interval
ground
&
aerial
0.02
3
3
1000
0.04
1
21
15
1.5/
3a
Vegetablesb
0.03
1
15
35
7­
day
interval
ground
&
aerial
0.01
1
3
1000
0.08
2
21
15
3.2/
3a
Forestry
(
Douglas
Fir)

0.05
2
15
35
14­
day
interval
ground
&
aerial
0.01
2
3
1000
0.08
2
21
15
3.2/
3a
Ornamental
Treesc
0.05
2
15
35
14­
day
interval
ground
&
aerial
0.01
2
3
1000
0.04
1
21
15
1.6/
3a
Ornamentalsd
0.03
1
15
35
7­
day
interval
ground
&
aerial
0.01
1
3
1000
0.49
12
21
15
13.9/
5
Ornamentals
0.35
12
15
35
10­
day
interval
(
pachysandra
groundcover)

0.07
12
3
1000
ground
0.48
11
21
15
17.4/
3a
Turf
(
golf
course)

0.34
11
15
35
5­
day
interval
ground
0.07
11
3
1000
0.52
12
21
15
19.0/
3a
Turfe
0.37
12
15
35
5­
day
interval
ground
&
aerial
0.07
12
3
1000
1
Assumes
degradation
using
FATE
version
5.0
program
with
an
ETU
total
foliar
residue
half­
life
of
35
days
and
mancozeb
to
ETU
conversion
rate
of
1.6%

2
RQ
=
EEC
(
mg/
kg)/[
NOAEL
(
mg/
kg­
bw/
day)/
%(
decimal)
Body
Weight
Consumed
(
bw/
day)]
3
RQ
greater
or
equal
to
1.0
exceeds
chronic
risk
LOCs.

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
73
c.
Aquatic
Organisms
i.
Review
The
industry
EBDC
task
force
collected
targeted,
surface
water
recording
data
(
MRID
No.
46145401).
In
two
years
of
sampling,
at
sites
selected
to
be
the
most
vulnerable
nationally,
monitoring
data
failed
to
showed
concentration
values
above
the
method
detection
limit
for
ETU
(
that
is,
0.1
ppb).
The
industry
collected
samples
only
every
two
weeks
during
the
EBDC
use
season
and
it
could
be
this
sampling
missed
daily
concentration
values
above
the
detection
limit.
However,
In
two
years
of
sampling,
at
sites
selected
to
be
the
most
vulnerable
nationally,
monitoring
data
failed
to
showed
concentration
values
above
the
method
detection
limit
for
ETU
(
that
is,
0.1
ppb).
EFED
based
the
surface
water
exposure
EECs
for
ETU
on
the
results
of
screening
models
to
provide
the
preliminary
EEC
estimates.
EFED
calculated
surface
water
concentrations
of
ETU
using
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)
for
Tier
II
estimates
(
see
section
V.
Water
Resource
Assessment,
for
detailed
explanation)..
EFED
used
the
peak
EECs
to
assess
the
acute
risks
to
aquatic
organisms
from
multiple
applications.
74
Table
5:
ETU
Acute
Risk
Quotients
for
Freshwater
Fish
Based
On
a
Rainbow
Trout
(
Oncorhynchus
mykiss)
LC50
of
>
502
ppm.
Application
Rate
(
lbs
ai/
A)/
Number
of
Acute
RQ
Applications/
Site/
(
Peak
EEC/
LC50)
2
EEC
Peak
(
ppb)
1
Interval
Application
Method/

2.2E­
05
11.2
4.8/
4
Apples
7­
day
interval
ground
&
aerial
1.7E­
05
8.6
2.4/
10
Onion
7­
day
interval
ground
&
aerial
2.5E­
05
12.3
1.6/
6
Peppers
7­
day
interval
ground
&
aerial
8.6E­
06
4.3
1.6/
10
Potatoes
5­
day
interval
ground
&
aerial
2.2E­
05
11.0
1.2/
15
Sweet
Corn
4­
day
interval
ground
&
aerial
2.2E­
05
10.9
2.4/
7
Tomato
7­
day
interval
ground
&
aerial
6.4E­
05
31.8
17.4/
3
Turf
7­
day
interval
ground
&
aerial
4.4E­
06
2.2
1.6/
3
Wheat
7­
day
interval
ground
&
aerial
1
Based
on
PRZM
version
3.12/
EXAMS
version
2.97.5
modeling.
Application
rates
in
this
table
are
parent
EBDC
label
rates.
Rates
in
all
ETU
simulations
are
pre­
multiplied
by
the
molar
conversion
rate
of
0.385
2
RQ
greater
or
equal
to
0.5
exceeds
acute
high
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.
ii.
Freshwater
Fish
Tabulated
below,
in
Table
5,
are
ETU's
acute
risk
quotients
for
freshwater
fish.
The
results
show
that
no
acute
risk
exceed
LOCs.
75
Table
6:
ETU
Acute
Risk
Quotients
for
Freshwater
Invertebrates
Based
On
a
Waterflea
(
Daphnia
magna
)
LC50
of
26.9
ppm.
Application
Rate
(
lbs
ai/
A)/
Number
of
Acute
RQ
Applications/
Site/
(
Peak
EEC/
LC50)
2
EEC
Peak
(
ppb)
1
Interval
Application
Method/

4.2E­
04
11.2
4.8/
4
Apples
7­
day
interval
ground
&
aerial
3.2E­
04
8.6
2.4/
10
Onion
7­
day
interval
ground
&
aerial
4.6E­
04
12.3
1.6/
6
Peppers
7­
day
interval
ground
&
aerial
1.6E­
04
4.3
1.6/
10
Potatoes
5­
day
interval
ground
&
aerial
4.1E­
04
11.0
1.2/
15
Sweet
Corn
4­
day
interval
ground
&
aerial
4.1E­
04
10.9
2.4/
7
Tomato
7­
day
interval
ground
&
aerial
1.2E­
03
31.8
17.4/
3
Turf
7­
day
interval
ground
&
aerial
8.2E­
05
2.2
1.6/
3
Wheat
7­
day
interval
ground
&
aerial
1
Based
on
PRZM
version
3.12/
EXAMS
version
2.97.5
modeling.
Application
rates
in
this
table
are
parent
EBDC
label
rates.
Rates
in
all
ETU
simulations
are
pre­
multiplied
by
the
molar
conversion
rate
of
0.385
2
RQ
greater
or
equal
to
0.5
exceeds
acute
high
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.
iii.
Freshwater
Invertebrates
Tabulated
in
Table
6,
are
ETU's
acute
risk
quotients
for
freshwater
invertebrates.
The
results
point
to
no
acute
risk
LOCs
exceedances.
76
Table
7:
ETU
Acute
Risk
Quotients
for
Aquatic
Non­
Vascular
Plants
Based
Upon
a
Freshwater
Green
Algae
(
Pseudokirchneriella
subcapitata
)
EC50
of
23
ppm
Application
Rate
(
lbs
ai/
A)/

Number
of
Acute
RQ
Applications/
Site/

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

4.9E­
04
11.2
4.8/
4
Apples
7­
day
interval
ground
&
aerial
3.7E­
04
8.6
2.4/
10
Onion
7­
day
interval
ground
&
aerial
5.3E­
04
12.3
1.6/
6
Peppers
7­
day
interval
ground
&
aerial
1.9E­
04
4.3
1.6/
10
Potatoes
5­
day
interval
ground
&
aerial
4.8E­
04
11.0
1.2/
15
Sweet
Corn
4­
day
interval
ground
&
aerial
4.7E­
04
10.9
2.4/
7
Tomato
7­
day
interval
ground
&
aerial
1.4E­
03
31.8
17.4/
3
Turf
7­
day
interval
ground
&
aerial
9.6E­
05
2.2
1.6/
3
Wheat
7­
day
interval
ground
&
aerial
1
Based
on
PRZM
version
3.12/
EXAMS
version
2.97.5
modeling.
Application
rates
in
this
table
are
parent
EBDC
label
rates.
Rates
in
all
ETU
simulations
are
pre­
multiplied
by
the
molar
conversion
rate
of
0.385
2
RQ
greater
or
equal
to
1.0
exceeds
acute
risk
LOCs.
iv.
Exposure
and
Risk
to
Nontarget
Plants:
Aquatic
Plants
Exposure
to
nontarget
aquatic
plants
may
occur
through
runoff
or
spray
drift
from
bordering
treated
sites.
EFED
uses
the
surrogate
species,
duckweed
(
Lemna
gibba)
to
make
a
risk
determination
for
aquatic
vascular
plants.
EFED
performs
nonvascular,
aquatic
plant
acute
risk
assessments
using
either
algae
or
a
diatom,
whichever
is
the
most
sensitive
species.
There
are
no
known
nonvascular
plant
species
on
the
endangered
species
list.
EFED
models
runoff
and
drift
exposure
from
PRZMEXAMS
EFED
calculates
risk
quotient
by
dividing
ETU's
peak
concentration
in
water
by
the
plant
EC
50
value.

Table
7
shows
the
acute
risk
quotients
for
freshwater,
nonvascular
green
alga
(
Pseudokirchneriella
subcapitata)
plants.
The
results
show
no
acute
risk
LOCs
exceedances.
77
d.
Endangered
Species
Based
on
available
screening
level
information
there
is
a
potential
concern
for
chronic
ETU
effects
on
listed
mammals
should
exposure
actually
occur.
Chronic
ETU
RQs
exceed
LOCs
for
endangered
and
threatened
species
of
mammals.
The
Agency
does
not
currently
have
data
on
which
to
evaluate
the
toxicity
of
ETU
to
endangered
or
threatened
birds,
estuarine/
marine
fish,
or
aquatic
vascular
plants.
Thus,
risks
to
endangered
or
threatened
species
of
birds,
estuarine/
marine
fish,
or
aquatic
vascular
plants
from
ETU
exposure
is
uncertain.
EFED
is
requiring
the
data
to
assess
the
potential
risk
to
endangered
or
threatened
species
of
birds,
estuarine/
marine
fish,
or
aquatic
vascular
plants
through
this
document.
EFED
is
reserving
the
terrestrial
plant
ETU
data
needs
until
EFED
receives
and
completes
review
of
the
parent
EBDC's
toxicity
to
terrestrial
plants.

e.
Ecological
Incidents
The
USEPA
Ecological
Incident
Information
System
(
EIIS)
(
see
Appendix
VI
for
description
and
background),
did
not
provide
any
ETU
incident
reports.
78
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
use
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
as
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
79
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)
APPENDIX
VI.
HED
Memorandum
on
Surface/
Ground
water
EDWCs
U.
S.
ENVIRONMENTAL
PROTECTION
AGENCY
WASHINGTON,
DC
20460
OFFICE
OF
PREVENTION,
PESTICIDES
AND
TOXIC
SUBSTANCES
DP
Barcode:
D290057
Date:
August
26,
2004
MEMORANDUM
SUBJECT:
Revision
No.
2:
Estimated
Drinking
Water
Concentrations
of
Ethylenebisdithiocarbamate
(
EBDC)
Degradate
Ethylenethiourea
(
ETU)
for
the
Use
in
Human
Health
Risk
Assessment
FROM:
Ronald
Parker,
Senior
Environmental
Engineer,
Ph.
D.
Environmental
Risk
Branch
V
Environmental
Fate
and
Effects
Division
(
7507C)

Mohammed
Ruhman,
Agronomist,
Ph.
D.
Environmental
Risk
Branch
V
Environmental
Fate
and
Effects
Division
(
7507C)

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

TO:
Anthony
Britten
Tawanda
Spears
Chemical
Review
Manager
Registration
Division
AND
Christina
Swartz
Health
Effects
Division
Summary
This
is
a
revised
memo
presenting
the
Estimated
Drinking
Water
Concentrations
(
EDWCs)
for
the
EBDC
degradate
ETU
for
use
in
an
FQPA
human
health
risk
assessment.
The
EBDC
fungicides,
Metiram,
Maneb
and
Mancozeb
are
very
short
lived
in
soil
and
in
water
and
would
not
themselves
be
expected
to
remain
in
surface
water
long
enough
to
reach
a
location
that
would
supply
water
for
human
consumption
whether
from
surface
or
groundwater.
81
Ethylenethiourea
(
ETU)
is
a
common
metabolite
of
all
of
the
EBDC
fungicides
and
may
reach
both
surface
and
groundwater
under
some
conditions.
This
assessment
addresses
exposure
to
ETU
only.
The
chronic
EDWC
for
surface
water
is
0.1
ppb
and
is
based
on
a
monitoring
study
conducted
by
the
EBDC
Task
Force.
A
range
of
acute
EDWCs
is
established
with
a
lower
limit
of
0.1
ppb
(
based
on
monitoring)
and
an
upper
limit
of
25.2
ppb
(
based
on
environmental
fate
and
transport
simulation
modeling
using
the
linked
EPA
PRZM
and
EXAMS
models).
The
ground
water
EDWC
is
0.21
ppb
(
based
on
a
targeted
monitoring
study).

The
currently
approved
version
of
PRZM
is
only
capable
of
simulating
pesticide
metabolites
through
use
of
simplifying
assumptions.
The
level
of
uncertainty
in
the
estimated
ETU
concentration
values
is
therefore
relatively
high.
The
targeted
surface
water
monitoring
study
provides
a
lower
bound
for
the
drinking
water
exposure
estimate.
No
concentration
values
above
the
ETU
limit
of
detection
of
0.1
ppb
were
found
in
this
study.
However,
acute
peak
values
could
have
been
missed
as
a
result
of
the
14­
day
sampling
intervals.

The
PRZM/
EXAMS
simulation
modeling
was
performed
for
22
crop
scenarios.
The
use
patterns
for
all
EBDCs
were
considered
and
the
highest
application
rate/
lowest
application
intervals
were
chosen
for
modeling.
Results
indicate
that
the
highest
one­
in­
ten
year
acute
surface
water
EDWC
was
found
to
be
25.2
ppb
from
the
Florida
pepper
scenario
with
the
lowest
value
being
4.5
ppb
from
the
North
Dakota
wheat
scenario.
The
highest
chronic
concentration
value
was
1.9
ppb
from
the
California
onion
scenario
with
the
lowest
value
being
0.2
ppb
from
the
North
Dakota
wheat
scenario.
All
these
acute
and
chronic
values
include
adjustment
by
the
national
maximum
default
percent
cropped
area
(
PCA)
value
of
0.87.
Use
of
the
maximum
regional
PCA
values
resulted
in
a
reduction
of
acute/
chronic
EDWCs
and
in
changes
in
scenarios
giving
the
lowest/
highest
values.
In
this
case,
the
highest
one­
in­
ten
year
acute
surface
water
EDWCs
was
13.9
ppb
from
California
onions
scenario
with
the
lowest
being
1.4
ppb
from
Maine
potatoes
scenario.
Both
the
national
and
the
regional
PCA
values
represent
the
maximum
area
planted
in
any
crop.
The
calculation
assumes,
not
models,
very
rapid
degradation
of
the
parent
pesticide
to
ETU
using
the
maximum
observed
conversion
of
parent
to
ETU
in
the
aerobic
soil
systems
of
9.6%
and
23.6%
in
the
water/
sediment
systems.

Targeted
ETU
monitoring
study
showed
no
surface
water
concentrations
above
the
detection
limit
of
0.1
ppb
in
samples
taken
pre
and
post
treatment
at
vulnerable
use
sites
at
community
drinking
intakes
in
several
states.
Samples
were
take
every
14
days
during
the
application
season
for
two
years.
While
such
sampling
could
have
missed
an
acute
peak
value,
the
Agency
believes
that
it
did
demonstrate
that
long­
term
average
chronic
values
would
not
exceed
the
detection
limit.

For
the
purposes
of
this
assessment,
the
range
of
acute
EDWC
values
for
surface
water
at
the
national
level
is
expected
to
be
between
0.1
ppb
(
the
detection
limit)
and
25.2
ppb
(
the
highest
peak
value
from
modeling
after
adjustment
by
the
0.87
national
PCA).
The
highest
value
in
this
national
level
range
can
be
reduced
to
13.9
ppb
(
the
highest
peak
value
from
modeling
after
adjustment
by
the
0.56
California
PCA).
Both
the
chronic/
non­
cancer
and
the
chronic/
cancer
values
are
set
conservatively
at
the
0.1
ppb
detection
limit.
The
groundwater
EDWC
concentration
is
0.21
ppb
and
is
derived
from
a
community
water
system
intake
concentration
measured
during
the
targeted
82
monitoring
study
conducted
by
the
EBDC
Task
Force
from
2001
to
2003.
In
this
respect,
it
is
noted
that
ETU
was
not
detected
in
any
of
the
treated
community
drinking
water
in
any
of
the
sampled
84
sites
even
when
it
was
detected
in
the
raw
water.
The
registrant
claims
that
the
absence
of
ETU
in
potable
water
from
community
water
supplies
is
related
to
its
rapid
degradation
resulting
from
aeration
and
chemical
treatment
(
i.
e.
chlorination).
Home
filters
containing
stages
for
water
softening
and
particulate
removal
were
reported
to
be
ineffective
at
removing
ETU
Both
these
surface
and
groundwater
values
represent
upper­
bound
conservative
estimates
of
the
total
ETU
residual
concentrations
that
might
be
found
in
drinking
water
derived
from
either
surface
water
and
groundwater
sources
due
to
the
use
of
the
EBDC
fungicides.

Estimating
Drinking
Water
Exposure
from
Surface
Water
Sources
i.
Combined
Monitoring/
Modeling
Approach
A
monitoring
program
was
conducted
by
the
EBDC
Task
Force
from
2001­
2003.
In
this
program,
raw
and
associated
treated
surface
water
were
sampled
every
two
weeks
during
the
three
months
historical
EBDC­
application
season
and
quarterly
for
the
remaining
three
quarters
of
each
year
for
a
period
of
two
years
(
18
sampling
events).
A
total
of
22
sites
were
chosen
to
represent
vulnerable
and
high
historic
EBDC­
use
sites
in
the
states
of
Maine
(
5
sites/
potatoes),
New
York
(
5
sites/
apples),
Michigan
(
total=
6
sites:
3
sites/
apples
and
3
sites/
mixed
grapes/
apples
&
nursery
plants),
Minnesota
(
2
sites/
potatoes),
and
Washington
(
4
sites/
apples).
The
results
from
this
targeted
monitoring
program
were
used
to
assign
the
chronic
and
the
lower
limit
of
the
acute
EDWCs
for
drinking
water
from
surface
water.
Samples
were
take
every
14
days
during
the
application
season
and
acute
values
may
have
been
missed.
Therefore,
a
range
of
acute
EDWCs
is
established
with
a
lower
limit
based
on
monitoring
and
an
upper
limit
based
on
environmental
fate
and
transport
simulation
modeling
using
the
linked
EPA
PRZM
and
EXAMS
models.
The
Agency
therefore
used
a
combined
approach
to
exposure
assessment
based
on
both
targeted
surface
water
monitoring
and
computer
simulation
to
bracket
the
expected
acute
exposure
level.

1.
Targeted
monitoring
component
Targeted
surface
water
monitoring
data
was
collected
by
the
industry
EBDC
Task
Force.
In
two
years
of
sampling
at
sites
selected
to
be
the
most
vulnerable
nationally,
no
concentration
values
were
measured
above
the
method
detection
limit
for
ETU
of
0.1
ppb.
EFED
used
GIS
(
Attachment
1)
to
confirm
relevance
of
surface/
groundwater
sites
to
EBDCs
use
patterns,
vulnerability
and
spatial
distribution
of
the
national
drinking
water
intakes.
Samples
were
collected
only
every
two
weeks
during
the
usage
season
and
it
is
possible
that
daily
concentration
values
above
the
detection
limit
may
have
been
missed.
The
agency
does
believe,
however,
that
the
sampling
confirms
that
long­
term
average
chronic
values
above
the
detection
limit
will
not
occur.

The
Agency
has
been
unable
to
locate
other
surface
water
monitoring
data
for
the
EBDC
fungicides
or
for
ETU.
These
chemicals
were
not
included
in
the
US
Geological
Survey
NAWQA
sampling
program
because
the
test
methods
are
incompatible
with
the
methods
used
by
that
program.
NAWQA
measurements
are
frequently
the
best
national
source
of
pesticide
monitoring
data.
The
USGS
is
currently
planning
to
begin
method
development
and
limited
EBDC/
ETU
monitoring
in
late
83
2004.

2.
Modeling
Component
The
monitoring­
based
chronic
EDWC
of
0.1
ppb
may
represent
the
low
limit
of
an
acute
range
of
values.
Higher
acute
values
can
not
be
ruled
out
because
monitoring
was
based
on
a
14­
day
sampling
interval.
Therefore,
tier
II
drinking
water
estimates
for
ETU
in
surface
water
were
calculated
using
the
linked
USEPA
PRZM
and
EXAMS
simulation
models.
Modeling
results
were
first
used
to:
(
1)
Assign
a
high
limit
to
the
acute
EDWC
range;

(
2)
Compare
chronic
values
obtained
from
modeling
to
the
0.1
ppb
value
assigned
based
on
monitoring;
and
(
3)
Compare
acute/
chronic
values
obtained
for
monitored
areas
to
other
areas
of
the
country
where
surface
water
monitoring
was
not
conducted
in
order
to
characterize
the
relevance
of
EDWC
values
obtained
from
monitoring
22
surface
water
sites
for
use
at
the
national
level.

Modeling
Inputs
This
calculation
assumes
very
rapid
and
complete
degradation
of
the
parent
pesticide
to
ETU.
ETU
rate
was
not
based
on
the
molar
conversion
of
38.5%
but
rather
on
the
maximum
conversion
rate
of
9.6%
observed
in
the
laboratory
aerobic
soil
studies
for
parent
entering
the
soil
system
upon
application
and
23.6%
for
amounts
entering
the
aquatic
system
by
drift.
These
conversion
rates
were
arrived
at
as
a
result
of
examination
of
fate
and
transport
data
of
parent
EBDCs
which
indicate
that
ETU
is
their
major
transformation
product
resulting
from
abiotic
and
biotic
degradation
processes
in
both
field
and
laboratory
studies.
Reported
laboratory
data
on
degradation
of
EBDCs
and
the
maximum
ETU
produced
are
summarized
in
Table
1.

Table
1.
Maximum
ETU
produced
in
fate
studies
for
parent
EBDCs.

Type
of
Study
Parent
EBDCs
Used
as
a
Test
Substance
(
Number
of
Studies)
Maximum
ETU
Formed
As
%
Parent
Equivalent
As
%
ETU*

Aqueous
Hydrolysis
Maneb
(
1);
Metiram
(
1)
93.0%
35.8%

Aero/
Anaerobic
Aquatic
Metiram
(
2);
Maneb
(
1)
61.4%
23.6%

Aerobic
Soil
Metiram
(
4);
Mancozeb
(
3);
Maneb
(
3)
24.8%
09.6%

*
%
ETU=
%
Parent
Equivalent
multiplied
by
Molar
ratio
of
ETU
to
Parent
(
38.5%).
For
example
the
maximum
for
hydrolysis
studies=
93%
x
0.385
=
35.8%.

Examination
of
data
indicate
that
the
maximum
observed
conversion
of
parent
to
ETU
is
expected
to
be
the
highest
in
water
systems
(
35.8%)
followed
by
water/
sediment
systems
(
23.6%)
and
the
lowest
in
aerobic
soil
systems
(
9.6%).
Although
these
values
represent
the
maximum
found
in
the
laboratory,
higher
or
lower
conversion
rates
may
occur
in
the
natural
environment
depending
on
the
characteristics
of
the
systems
(
e.
g.
availability
of
moisture
and
biological
activity).
This
is
considered
as
an
uncertainty
along
with
the
assumption
that
conversion
to
ETU
occurs
at
application.
In
this
respect,
it
is
noted
that
the
maximum
ETU
attained
in
the
natural
environment
is
a
result
of
two
major
21
This
value
is
calculated
as
follows:
Parent
rate
(
kg/
ha)=
5.38
arrived
at
by
multiplying
the
parent
rate
of
4.8
(
lb/
a)
by
1.121
ETU
rate
(
kg/
ha)=
0.52
arrived
at
by
multiplying
the
parent
rate
of
5.38
(
kg/
ha)
by
0.096
84
processes
formation
and
degradation.
This
maximum
is
expected
to
occur
shortly
after
the
parent
reaches
the
aquatic
system
by
drift
and
much
longer
after
foliar
applied
parent
reaches
the
soil
system.

In
assigning
the
value
for
ETU
application
rate
for
modeling,
EFED
used
the
parent/
ETU
conversion
value
of
9.6%
for
ETU
expected
to
form
(
from
applied
parent)
in
the
soil
system.
This
value
(
equal
to
0.52
kg
a.
i./
ha
for
apples21)
was
assigned
to
be
the
parent
equivalent
ETU
rate.
PRZM/
EXAMS
will
use
this
value
to
calculate
drift
by
multiplying
0.52
by
0.16
(
16%
drift).
This
drift
value
is
accurate
only
for
the
soil
system
and
needs
to
be
corrected
for
the
aquatic
system.
Therefore,
a
correction
factor
of
2.458
was
used
and
was
affected
by
changing
the
drift
from
0.16
(
the
default
value)
to
0.393.
Changing
the
drift
fraction
by
the
stated
factor
will
result
in
an
exact
account
for
the
observed
23.6%
parent/
ETU
conversion
expected
to
form
(
from
parent
drift)
in
aquatic
systems.

Other
inputs
used
for
modeling
are
the
fate
and
transport
parameters
determined
for
the
EBDC
metabolite/
degradate
ETU.
As
shown
in
Table
2,
ETU
has
an
aerobic
soil
half­
life
of
about
3
days;
in
the
absence
of
data,
the
aquatic
aerobic
metabolism
half­
life
was
assumed
to
be
about
6
days,
or
double
the
soil
half
life.
The
measured
anaerobic
aquatic
metabolism
half­
life,
however,
is
substantially
longer
(
149
days)
possibly
leading
to
the
periodic
detections
in
groundwater.
It
is
highly
soluble
in
water
(
20,000
ppm);
highly
vulnerable
to
indirect
photolysis
(
half­
life=
1
day),
and
moderately
mobile
(
288
L/
kg).
It
also
has
a
relatively
high
vapor
pressure
but
high
solubility
reduces
the
possibility
of
losses
from
surface
water
due
to
volatilization.

Table
2.
PRZM/
EXAMS
Input
Parameters
for
ETU.

Input
Parameter
Value
Reference
Molecular
Weight
(
grams)
102.2
Product
chemistry
submission
Vapor
Pressure
(
torr)
9.728e­
1
Registrant
data
Aerobic
Soil
Metabolism
Half­
life
(
days)
3.14
Upper
confidence
bound
on
the
mean
for
three
soils
(
MRID
452251­
01)

Bacterial
Bio­
lysis
in
the
water
column
(
days)
(
Aerobic
Aquatic
metabolism
half­
life)
6.28
Aerobic
soil
t
½
x2:
No
aerobic
aquatic
metabolism
study/
No
significant
hydrolysis
(
Guidance)
1
Bacterial
Bio­
lysis
in
benthic
sediment
(
days)
(
Anaerobic
Aquatic
metabolism
half­
life)
447
Only
one
value
is
available=
149
days
(
MRID
001633­
35);
use
149x3=
447
days
(
Guidance)
1
Application
Rate
Varies
by
crop
and
calculated
from
parent
rate
as
described
above.
Refer
to
Attachment
2
for
a
complete
list
of
application
rates/
dates
used
in
modeling
Application
Method
Aerial
Product
Label
Depth
of
Incorporation
(
inches)
0
Product
Label
National
Percent
Crop
Area
"
PCA"
(
fraction)
0.87
(
Guidance)
1
Input
Parameter
Value
Reference
85
Spray
Drift
(
fraction)
0.393
This
value
is
increased
from
the
default
value
of
0.16
by
a
factor
of
2.458
2.
This
was
necessary
to
account
for
the
difference
in
maximum
conversion
of
(
parent
to
ETU)
between
the
soil
system
(
9.6%)
and
the
aquatic
system
(
23.6%)

Solubility
(
mg/
L
or
ppm)
20,000
Product
chemistry
submission
Koc
(
L
Kg­
1)
288
Average
for
ten
soils
(
MRIDs
002588­
96&
000971­
58)

pH
7
Hydrolysis
Half­
life
(
days)
Stable
MRID
404661­
03
Photolysis
Half­
life(
days)
1
This
is
the
indirect
photolysis
half­
life
reported
for
ETU;
ETU
is
stable
to
direct
photolysis
(
MRID
404661­
02)

1
Guidance
for
Chemistry
and
Management
Practice
Input
Parameters
For
Use
in
Modeling
the
Environmental
Fate
and
Transport
of
Pesticides,
Version
2/
November
7,
2000.

2
This
2.458
correction
factor
was
arrived
at
by
dividing
23.6%
(
conversion
of
parent
to
ETU
in
aquatic
systems)
by
9.6%
(
conversion
of
parent
to
ETU
in
the
soil
systems
which
was
used
as
the
ETU
application
rate).

Modeling
Outputs
The
PRZM/
EXAMS
simulation
modeling
was
performed
for
22
crop
scenarios
to
cover
the
extensive
use
patterns
for
all
EBDCS.
A
Tier
II
EDWC
for
a
particular
crop
or
use
is
based
on
a
single
index
reservoir
site
that
represents
a
high
exposure
scenario
for
use
on
the
crop.
The
scenarios
are
indexed
to
a
vulnerable
former
drinking
water
reservoir
located
in
Shipman,
Illinois.
Weather
and
agricultural
practices
are
simulated
at
the
site
for
30
years
to
estimate
the
probability
of
exceeding
a
given
concentration
(
maximum
concentration
or
average
concentration)
in
a
single
year.
Maximum
EDWCs
are
calculated
so
that
there
is
a
10%
probability
that
the
maximum
concentration
in
a
given
year
will
exceed
the
EDWC
at
the
site.
Based
on
variability
of
weather,
this
can
also
be
expressed
as
an
expectation
that
water
concentrations
will
exceed
EDWCs
once
every
10
years.
The
results
for
all
model
runs
are
summarized
below
and
background
on
the
model
along
with
complete
results,
additional
inputs
and
sample
outputs
are
attached
for
reference
(
Attachment
2).

Table
3
summarizes
results
obtained
for
the
highest
peak
values
after
adjustment
by
the
national
PCA
of
0.87
and
the
regional
PCA
of
0.56
(
California).
86
Table
3.
PRZM/
EXAMS
highest
peak
values
for
the
EDWCs
of
ETU
from
surface
water.

Crop
Scenario
PCA
Rates
in
kg/
ha
(
Number
of
applications)
EDWC
(
ppb)

Parent
ETU
Acute
Peppers
(
Florida)
0.87
2.69
(
6)
0.26
(
6)
25.2
Almonds
(
California)
0.56
7.17
(
4)
0.69
(
4)
13.9
Data
indicated
that
the
highest
peak
value
from
modeling
is
25.2
ppb
(
FL
peppers
scenario)
after
adjustment
by
the
0.87
national
PCA.
This
value
is
assigned
to
be
the
high
limit
to
the
acute
EDWC
range;
therefore
the
range
is
0.1
ppb
(
from
monitoring)
to
25.2
ppb
(
from
modeling).
It
is
noted
however,
that
the
high
limit
of
the
range
is
reduced
from
25.2
to
13.9
ppb
(
CA
almonds
scenario)
after
adjustment
by
associated
regional
PCA.

Table
4
summarizes
modeling
results
for
all
runs,
at
both
the
national
and
regional
scales,
for
scenarios
representing
monitored
and
non­
monitored
areas
of
the
country.

Table
4.
PRZM/
EXAMS
values
for
the
EDWCs
of
ETU
from
surface
water.

State
Crop
Number
of
monitored
Sites
\
Representative
Crop
Scenario
EDWCs
(
ppb)
Adjusted
by
the
National
PCA
of
0.87
EDWCs
(
ppb)
Adjusted
by
the
Regional
PCA
1
Acute
Chronic/
Non­
cancer
Chronic/
Cancer
Acute
Chronic/
Non­
cancer
Chronic/
Cancer
I.
Monitored
EBDCs
Use
Patterns
(
Areas/
Crops)

ME
Potatoes
5
ME
potatoes
8.9
0.9
0.8
1.4
0.1
0.1
NY
Apples
5
PA
apples
18.3
1.3
1.1
9.7
0.7
0.6
MI
Apples
3
Mixed
grapes/
apples
(
two
sites)
and
mixed
grapes/
nursery
plants
(
one
site):
No
Scenarios
are
available
MN
Potatoes
2
ME
potatoes
8.9
0.9
0.8
1.4
0.1
0.1
ID
potatoes
6.0
0.7
0.6
4.4
0.5
0.4
WA
Apples
4
OR
apples
16.0
1.2
1.1
11.6
0.9
0.8
Overall
06­
18
0.7­
1.3
0.6­
1.1
01­
12
0.1­
0.9
0.1­
0.8
I.
Un­
monitored
EBDCs
Use
Patterns
(
Areas/
Crops)

PRZM/
EXAMS
Scenarios
(
States/
Use
Patterns)
EDWCs
(
ppb)
Adjusted
by
the
National
PCA
of
0.87
EDWCs
(
ppb)
Adjusted
by
the
Regional
PCA
1
Acute
Chronic/
Non­
cancer
Chronic/
Cancer
Acute
Chronic/
Non­
cancer
Chronic/
Cancer
87
(
1)
Highest
values:
FL
peppers;
NC
apples;
FL
sweet
corn,
tomatoes
&
turf;
CAalmonds;
PA
tomatoes;
CA
onions;
NC
peanuts;
CA
grapes;
and
FL
cabbage.
10­
25
0.7­
1.9
0.5­
1.8
04­
14
0.3­
1.2
0.2­
1.1
(
3)
Lowest
values:
MN
sugar
beet;
TX
wheat;
CA
tomatoes;
OR
sweet
corn
&
wheat;
and
ND
wheat.
05­
09
0.2­
0.9
0.2­
0.8
01­
09
0.1­
0.7
0.1­
0.6
Overall
05­
25
0.2­
1.9
0.2­
1.8
01­
14
0.1­
1.2
0.1­
1.1
As
shown
in
Table
4,
PRZM/
EXAMS
runs
predicted
EDWCs
for
ETU
to
be
between
5­
25
ppb
and
chronic
values
between
0.2­
1.9
ppb
whereas
two
years
targeted
monitoring
fails
to
show
any
detection
over
the
detection
limit
of
0.1
ppb.
Compared
to
the
monitoring
based
single
0.1
ppb
chronic/
non­
cancer
and
chronic/
cancer
value,
modeling
results
indicate
that
the
range
of
national
scale
chronic
values
is
0.2­
1.9
ppb
for
chronic/
non­
cancer
and
0.2­
1.8
ppb
for
chronic/
cancer.
The
range
for
these
two
values
are
reduced,
at
the
regional
level
to
0.1­
1.2
ppb
for
chronic/
non­
cancer
and
0.1­
1.1
ppb
for
chronic/
cancer.

As
shown
in
the
attached
GIS
maps
(
Attachment
1),
not
all
possible
surface
water
sites
were
monitored.
Therefore,
acute/
chronic
values
obtained
for
monitored
areas
were
compared
to
other
areas
of
the
country
where
surface
water
monitoring
was
not
conducted.
The
comparison
reveals
that
PRZM/
EXAMS
predicted
acute/
chronic
ETU/
EDWCs
for
scenarios
relevant
to
use
patterns
of
monitored
are
relatively
higher
than
those
for
un­
monitored
sites
(
Table
4).
In
order
to
further
examine
the
data
in
leu
of
the
non­
detection
of
ETU,
the
following
assumptions
were
made:

(
1)
The
chronic
value
of
0.1
is
an
acceptable
value
for
monitored
sites;
and
(
2)
The
change
in
chronic
long­
term
values
is
similar
to
that
of
the
acute
(
long­
term)
values.
Examination
of
the
chronic/
acute
results
for
the
22
runs
suggested
that
the
assumption
for
these
runs
is
reasonable.
A
plot
of
acute
and
chronic
concentrations
for
the
current
runs
reveals
a
linear
relationship
with
a
reasonable
R2
value
of
0.58
(
Figure
1).
88
0
5
10
15
20
25
30
Peak
EDWCs
for
ETU
(
ppb)
0
0.5
1
1.5
2
Chronic
EDWCs
for
ETU
(
ppb)

R­
square
=
0.584
#
pts
=
22
y
=
0.278
+
0.0469x
Chronic
Vs.
Peak
Values
Figure
1.
A
plot
of
the
relationship
between
acute
and
chronic
values
from
22
PRZM/
EXAMS
runs.

Based
on
these
assumptions,
the
maximum
national/
regional
acute/
chronic
values
for
monitored
areas
are
adjusted
proportionally
by
a
factor
of
0.0769
(
0.1
ppb/
1.3
ppb)
so
that
the
maximum
chronic
value
for
monitored
sites
is
equal
to
0.1
ppb.
Table
5
shows
original
and
adjusted
acute/
chronic
ETU/
EDWCs
predicted
by
PRZM/
EXAMS
for
scenarios
relevant
to
use
patterns
of
monitored
and
un­
monitored
sites.

Table
5.
Range
of
original
and
adjusted
values
for
PRZM/
EXAMS
acute/
chronic
ETU/
EDWCs.

Sites
National
EDWCs
(
ppb)
Regional
EDWCs
(
ppb)

Acute
Chronic
Peak
Chronic
(
1)
Monitored
Original
PRZM/
EXAMS
values
06­
18
0.7­
1.3
01­
12
0.1­
0.9
Adjusted
PRZM/
EXAMS
values
<
1­
01
<
0.1­
0.1
<
1­
01
<
0.1­
0.1
(
2)
Un­
monitored
Original
PRZM/
EXAMS
values
05­
25
0.2­
1.9
01­
14
0.1­
1.2
Adjusted
PRZM/
EXAMS
values
<
1­
02
<
0.1­
0.2
<
1­
01
<
0.1­
0.1
Adjusted
values
are
much
lower
than
the
original
results
from
PRZM/
EXAMS
and
the
chronic
values
from
all
runs
are
near
the
assigned
value
of
0.1
ppb.
Additionally,
the
maximum
value
of
the
assigned
bracketed
range
of
the
acute
(
0.1­
25
ppb)
becomes
one
order
of
magnitude
smaller
at
both
the
national
(
0.1­
2
ppb)
and
the
regional
scales
(
0.1­
1
ppb).

Surface
water
targeted
monitoring
fails
to
show
any
detection
of
ETU
above
the
detection
limit
0.1
ppb,
however,
ETU/
EDWCs
predicted
by
PRZM/
EXAMS
were
higher.
Reasons
that
may
be
given
to
explain
these
results
include:
22
Blazquez,
C.
H.
1973.
J.
Agric.
Food
Chem.
21
(
3),
330­
332.

89
­
Adjustment
of
PRZM/
EXAMS
estimates
using
PCA
values
higher
than
those
actually
found
for
some
crops;

­
In
modeling,
it
was
assumed
that
EBDC
parents
degrade
rapidly
and
totally
to
ETU.
This
is
because
currently
approved
version
of
PRZM
is
only
capable
of
simulating
pesticide
metabolites
through
such
simplified
assumption
giving
a
relatively
high
uncertainty
in
the
ETU
estimates.
Fate
data
for
ETU
suggest
maximum
ETU
attained
in
the
natural
environment
is
a
result
of
two
major
processes:
formation
and
degradation.
This
maximum
is
expected
to
occur
shortly
after
the
parent
reaches
the
aquatic
system
by
drift
and
much
longer
after
foliar
applied
parent
reaches
the
soil
system.

­
In
modeling,
the
maximum
observed
conversion
of
parent
to
ETU
was
used
(
23.6%
for
water/
sediment
systems
and
9.6%
for
the
aerobic
soil
systems).
Respective
observed
minimum
values
were
much
lower
(
1.0%
for
the
aerobic
soil
systems
and
14.9%
for
water/
sediment
systems);

­
The
choice
of
the
date
for
the
first
application
affects
the
concentrations
estimated
by
PRZM/
EXAMS;
EFED
selected
dates
based
on
information
present
in
the
label.
EBDCs
are
applied
as
protectant
fungicides
for
diseases
that
appear
early
and/
or
late
in
the
season.
In
most
cases,
label
application
dates
were
set
based
on
the
crop
growth
stage
which
was
used
by
EFED
to
choose
the
appropriate
window
for
the
first
application.

­
The
apparent
non­
sensitivity
of
PRZM/
EXAMS
simulations
for
the
photolysis
half­
life
of
ETU.
Indirect
photolysis
is
reported
to
be
the
main
reason
for
non­
detection
of
ETU
in
surface
waters22.
However,
changing
the
photolysis
half­
life
from
stable
to
1
day
appears
not
to
affect
resultant
concentrations
from
PRZM/
EXAMS.
For
example,
FL
peppers
photolysis
half­
life
of
1
day
gave
concentrations
of
25.2
ppb
for
the
acute,
1.1
ppb
for
the
chronic/
non­
cancer
and
0.7
ppb
for
the
chronic/
cancer.
When
photolysis
half­
life
is
changed
to
stable
the
results
were
the
same
for
chronic
values
and
almost
the
same
for
the
acute
value
(
25.4
ppb
compared
to
25.2
ppb).

ii.
Surface
Water
Conclusions
Based
on
a
combined
monitoring
and
modeling
approach,
it
is
concluded
that
the
range
of
acute
values
at
the
national
level
is
expected
to
be
between
0.1
ppb
and
25.2
ppb.
The
highest
value
in
this
national
level
range
can
be
reduced,
at
the
regional
level,
to
13.9
ppb.
Both
the
chronic/
non­
cancer
and
the
chronic
cancer
values
were
set
conservatively
at
the
0.1
ppb;
the
detection
limit
of
ETU.

The
maximum
value
at
both
the
national
and
regional
levels
are
based
on
the
currently
approved
version
of
PRZM
which
is
only
capable
of
simulating
pesticide
metabolites
through
such
simplified
assumption
giving
a
relatively
high
uncertainty.
The
assigned
acute
25.2
and
13.9
ppb
values
could
be
as
low
as
2
and
1
ppb,
respectively.
These
low
values
are
based
on
the
assumption
that
PRZM/
EXAMS
acute
estimates
can
be
corrected
proportionally
based
on
a
correction
factor
so
that
the
maximum
chronic
value
for
monitored
sites
is
equal
to
0.1
ppb.
90
0
700
148
511
Days
(
0
=
July
10/
2001)
0.1
0.18
0.12
0.16
0.2
ETU
in
Raw
Ground
Water
(
ppb)
FL
0166
(
3
detections
of
8)
FL
0176
(
1
detection
of
8)
Estimating
Drinking
Water
Exposure
from
Ground
Water
Sources
i.
Monitoring
Approach
1.
Community
Ground
Water
Systems
A
monitoring
program
was
conducted
by
the
EBDC
Task
Force
from
2001­
2003.
In
this
program,
raw
and
associated
treated
ground
water
were
sampled
quarterly
for
a
period
of
two
years
(
8
sampling
events).
A
total
of
84
sites
were
chosen
to
represent
high
historic
EBDC­
use
sites
in
the
states
of
Maine
(
7
sites/
potato
crop),
New
York
(
2
sites/
apples),
Michigan
(
total=
6
sites:
1
sites/
apples,
4
sites
mixed
grapes
&
apples,
and
1
sites/
mixed
potato
&
apples),
Minnesota
(
3
sites/
potatoes),
Washington
(
6
sites/
apples),
California
(
total=
25
sites:
19
sites/
almonds,
4
sites/
walnuts,
1
site/
almonds
&
walnuts,
1
site/
almonds
&
grapes),
and
Florida
(
total=
35
sites:
13
sites/
tomatoes
&
watermelon,
10
sites/
nursery
plants
&
peppers,
6
sites/
tomatoes
&
peppers,
3
sites/
tomatoes,
2
sites/
potatoes
&
tomatoes,
and
1
site/
potatoes).
The
results
from
this
targeted
monitoring
program
were
used
to
assign
the
Groundwater
Estimated
Drinking
Water
Concentrations
(
EDWC's)
for
the
EBDC
fungicides.

ETU
was
detected
above
the
detection
limit
intermittently
in
only
the
raw
water
from
two
ground
water
sites
(
Figure
2).
No
detection
was
observed
for
treated
water
in
any
of
the
84
community
water
sites;
including
those
two
where
ETU
was
detected
in
the
raw
water.

Figure
2.
Detected
concentrations
of
ETU
in
two
out
of
84
community
ground
water
sites.

Data
indicate
that
ETU
was
detected
only
a
few
times
with
the
highest
detected
concentration
of
0.21
ppb
which
was
measured
for
the
raw
water
at
FL0176
in
Lee
County,
Florida.
No
detection
was
observed
over
the
detection
limit
of
0.1
ppb
for
this
or
any
other
potable
water
sample.
91
0
700
148
511
Days
(
Monitoring
started
May
15
for
NY,
June
5
for
ME
and
June
18
for
IL;
0
=
July
10/
2001)
0.05
0.25
0.12
ETU
Concentration
in
Raw
Ground
Water
(
ppb)

FL
0021
(
23
detections
of
24)
FL
0022
(
24
detections
of
24)
FL
0023
(
12
detections
of
24)
FL0010
(
4
detections
of
24)
NY
0011
(
9
detections
of
24)
IL
0004
(
2
detections
of
24)
ME
0007
(
1
detection
of
24)
FL
0009
(
1
detection
of
24)
2.
Rural
Ground
Water
Wells
(
Private
Wells)
A
monitoring
program
was
conducted
by
the
EBDC
Task
Force
from
2001­
2003.
In
this
program,
raw
ground
water
was
sampled
monthly
for
a
period
of
two
years
(
24
sampling
events).
A
total
of
125
sites
were
chosen
to
represent
high
historic
EBDC­
use
sites
in
the
states
of
Maine
(
9
sites/
potato
crop),
New
York
(
9
sites/
apples),
Michigan
(
10
sites/
apples),
Minnesota
(
9
sites/
potatoes),
Washington
(
7
sites/
apples),
California
(
total=
38
sites:
21
sites/
almonds,
16
sites/
walnuts,
1
site/
apples),
Illinois
and
Iowa
(
total
5
sites:
2
sites/
corn
&
soybeans,
1
site/
soybeans
and
1
site/
corn)
and
Florida
(
total=
35
sites:
16
sites/
potatoes,
4
sites/
tomatoes,
4
sites/
squash,
3
sites
peppers,
and
8
sites
mixed).

ETU
was
detected
in
the
range
of
0.10
to
0.25
ppb
continuously
at
2
sites
in
Florida
and
intermittently
at
six
sites:
three
in
Florida
and
one
each
in
New
York,
Illinois
and
Maine
(
Figure
3).
The
highest
detected
ETU
concentration
of
0.57
ppb
was
measured
for
a
private
well
near
an
EBDC
treated
field
was
0.57
ppb
in
an
apple
growing
region
of
New
York.
No
detection
of
ETU
was
observed
in
all
the
other
117
sites.

Figure
3.
Detected
concentrations
of
ETU
in
eight
out
of
125
rural
ground
water
sites.

Data
indicates
that
ETU
concentrations
in
the
range
of
0.1
to
0.25
can
occur
in
shallow
ground
water
sources
located
within
and/
or
adjacent
to
field
treated
with
EBDCs;
especially
when
highly
permeable
materials
overlay
the
water
such
as
the
case
in
Florida.
However,
in
the
one
well
in
Illinois,
no
reason
was
given
to
the
observed
3
detections
within
the
eight
sampling
events
because
EBDCs
are
not
applied
at
fields
at
the
well
location
(
corn
and
soybeans).
The
report
did
not
give
any
reason
to
such
detections
although
the
source
may
be
related
to
recharge
areas
where
EBDCs
are
applied.

It
is
important
to
note
that
the
use
of
home
filters
containing
stages
for
water
softening
and
particulate
removal
was
reported
to
be
ineffective
at
removing
ETU.
This
was
reported
by
the
92
registrant
based
on
collecting
additional
filtered
samples
from
only
two
sites
in
Florida
(
FL
0021
and
FL
0022).

ii.
Modeling
Check
for
Groundwater
ETU/
EDWCs
The
assigned
value
of
0.21
ppb
for
ETU/
EDWC
from
ground
water,
was
evaluated
for
reasonableness
by
checking
it
against
the
high
exposure
tier
one
model
SCIGROW,
which
is
described
in
Attachment
2.
Maximum
application
amounts
used
were:
for
almonds
(
4
applications
of
6.4
lb
a.
i/
acre
EBDC=
4
applications
of
0.6144
lb/
acre
ETU;
conversion
rate
of
0.096)
and
for
papayas
(
12
applications
of
2.0
lb
a.
i/
acre
EBDC=
12
applications
of
0.192
lb/
acre
ETU;
conversion
rate
of
0.096).
Results
indicate
that
the
maximum
modeling
value
of
0.006
ppb
is
orders
of
magnitude
less
than
the
assigned
value
of
0.21
ppb
which
was
based
on
monitoring
(
Table
6).

Table
6.
SCIGROW
inputs/
outputs
based
on
maximum
application
rates
(
almonds
and
papayas);
the
average
aerobic
soil
half­
lives
and
lowest
Koc
value
for
ETU.

Papaya
SCIGROW
VERSION
2.3
ENVIRONMENTAL
FATE
AND
EFFECTS
DIVISION
OFFICE
OF
PESTICIDE
PROGRAMS
U.
S.
ENVIRONMENTAL
PROTECTION
AGENCY
SCREENING
MODEL
FOR
AQUATIC
PESTICIDE
EXPOSURE
SciGrow
version
2.3
chemical:
ETU
time
is
8/
25/
2004
13:
22:
4
­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­
Application
Number
of
Total
Use
Koc
Soil
Aerobic
rate
(
lb/
acre)
applications
(
lb/
acre/
yr)
(
ml/
g)
metabolism
(
days)
­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­
0.192
14.0
2.688
3.40E+
01
2.1
­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­
groundwater
screening
cond
(
ppb)
=
5.49E­
03
Almonds
SciGrow
version
2.3
chemical:
ETU
time
is
8/
25/
2004
13:
23:
34
­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­
Application
Number
of
Total
Use
Koc
Soil
Aerobic
rate
(
lb/
acre)
applications
(
lb/
acre/
yr)
(
ml/
g)
metabolism
(
days)
­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­
0.614
4.0
2.458
3.40E+
01
2.1
­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­
groundwater
screening
cond
(
ppb)
=
5.02E­
03
23
Beitz
H
et
al
1994.
In:
Chem
Plant
Prot.
Borner
H,
ed.
Germany:
Springer­
Verlag.
(
Pest
Surf
Ground
Water):
2­
56.

93
iii.
Ground
Water
Conclusions
In
the
targeted
monitoring
study
carried
out
by
the
EBDC
Task
Force
from
2001
through
2003
the
highest
measured
value
in
a
public
drinking
water
well
was
0.210
ppb
in
Lee
County,
Florida
and
is
used
as
the
maximum
value
for
this
assessment.
ETU
was
not
detected
over
the
detection
limit
of
0.1
in
any
potable
water
from
all
ground
water
samples
suggesting
possible
effects
of
water
treatment.

In
rural
areas,
the
highest
value
measured
by
the
EBDC
Task
Force
was
0.574
ppb
and
was
for
ground
water
from
a
private
well
near
an
EBDC
treated
field
in
an
apple
growing
region
of
New
York.
ETU
concentrations
in
the
range
of
0.1
to
0.25
were
also
measured
in
8
out
of
125
rural
wells.
Simple
home
filtration
method
was
found
to
be
ineffective
at
removing
ETU.

Therefore,
exposure
to
higher
ETU
concentrations
(
over
the
assigned
0.21
ppb)
may
occur
in
localities
using
ground
water
wells
located
in
proximity
or
at
areas
with
heavy
use
of
the
EBDC
fungicides.
In
this
respect,
higher
groundwater
concentration
values
have
been
measured
but
are
very
rare
and
are
unlikely
to
represent
ground
water
ETU
concentrations
expected
in
drinking
water
relevant
for
use
in
a
national
assessment.
A
value
of
16
ppb
was
recorded
beneath
an
Iowa
apple
orchard
which
had
been
treated
with
an
EBDC
fungicide.
This
value
far
exceeds
any
values
monitored
by
the
task
force
on
the
most
vulnerable
sites
nationally
and
is
therefore
not
believed
to
represent
a
true
level
of
risk
by
the
Agency.
In
25
years
of
monitoring
in
California,
there
has
been
only
one
ETU
detection
(
0.75
ppb).
Additionally,
ground
water
monitoring
in
Holland,
resulted
in
only
8
positive
samples
with
a
maximum
concentration
of
1.5
µ
g/
l
(
ppb)
23.
94
Attachment
1:
GIS
mapping
The
objective
of
the
targeted
monitoring
study
was
to
assess
the
extent
to
which
historic
and
concurrent
EBDCs
use
resulted
in
ETU
contamination
of
drinking
water
from
surface/
ground
water
sources.
EFED
used
GIS
maps
to
confirm
relevance
of
selected
surface/
ground
water
sites
to
EBDCs
use
patterns
(
crops
and
high
historical
use
areas)
and
vulnerability.

For
surface
water,
the
five
areas
selected
for
surface
water
monitoring
were
associated
with
maximum
historical
use
level
of
EBDCs
in
the
Northern
States
and
at
least
two
of
these
areas
(
areas
4
to
5)
are
associated
with
clusters
of
surface
water
intakes
(
Map
1).
All
of
these
areas
were
cropped
with
a
range
of
crops
representing
major
crops
associated
with
EBDCs
use
(
Map
2).
Examination
of
the
run­
off
potential
for
the
sites
chosen
for
surface
water
monitoring
reveals
that
most
of
these
sites
were
located
in
run­
off
vulnerable
areas
(
Map
3).
Other
potential
areas
for
surface
water
monitoring
are
indicated
in
the
map
(
Map
3,
white
circles
designated
by
the
letters
A
to
L).
However,
it
should
be
pointed
out
that
the
highly
vulnerable
areas
in
the
states
of
MS,
AR
and
TN
(
Map3,
designated
by
the
letter
J)
may
not
be
of
concern
giving
the
fact
that
cotton
use
will
be
dropped.
Deficiencies
in
the
study
include:

(
1)
Sampling
of
community
surface
water
sites
in
large
lakes
(
MI
sites
from
Lake
Michigan
and
NY
sites
from
Lake
Ontario);
dilution
effect.

(
2)
No
surface
water
sites
were
monitored
in
other
highly
vulnerable
and
high
EBDCs
use
areas
in
California
and
Florida.
Predicted
PRZM/
EXAMS
ETU/
EDWCs
for
these
un­
monitored
areas
were
compared
to
results
obtained
for
monitored
areas.
Although
values
for
few
scenarios
(
representing
un­
monitored
crops/
areas)
were
slightly
higher
than
those
associated
with
monitored
areas,
nondetection
of
ETU
in
any
of
the
monitored
areas
suggests
similar
results
may
have
been
obtained
for
these
un­
monitored
sites.

For
ground
water,
209
sites
(
community
and
rural
ground
water
wells)
were
selected
for
the
targeted
monitoring
study.
As
shown
in
Map
1,
most
of
these
sites
were
associated
with
a
relatively
high
number
of
ground
water
intakes
and
were
located
in
high
historic
EBDCs
use
areas.
Additionally,
all
of
the
major
EBDCs­
use
crops
were
represented
(
Map
2).
Association
of
ground
water
use
(
represented
by
intakes)
and
EBDCs
use
pattern
(
crops
in
Acers/
total
EBDCs
use
in
lbs)
were
examined
for
all
monitored
sites
(
Map
4
is
an
example).
Examination
reveals
that
the
monitoring
program
can
be
used
as
a
basis
for
this
assessment
for
ground
water
ETU/
EDWCs.
However,
spatial
analysis
could
have
been
improved
if
longitudes/
latitudes
were
given
for
each
well
rather
than
for
the
nearest
city.
As
shown
in
Map
4,
a
single
point
was
used
to
represent
all
of
the
sites
near
a
city.
95
Map1.
A
GIS
map
showing
the
nine
targeted
monitoring
areas
in
relation
to
historic
EBDCs
use
and
national
surface/
ground
water
intakes.
96
Map
2.
A
GIS
map
showing
total
and
individual
distribution
for
the
major
crops
and
crop
groups
associated
with
EBDCs
use.
97
Map
3.
A
GIS
map
showing
monitored/
un­
monitored
areas,
run­
off
vulnerability,
and
locations
for
PRZM/
EXAMS
scenarios
used
to
compare
modeled
ETU/
EDWCs
of
monitored
with
un­
monitored
areas.

Note:
Monitored
areas
are
represented
by
red
boxes
and
un­
monitored
areas
by
white
circles.
98
Map
4.
A
GIS
map
for
area
9
shown
as
an
example
illustrating
examined
details
(
e.
g.
surface/
groundwater
sites
and
county
level
EBDCs
use
patterns
(
Note:
many
sites
share
the
same
point
in
the
map
because
sites
longitudes/
latitudes
were
given
to
the
nearest
city).
99
Attachment
2:
Modeling
1.
PRZM/
EXAMS
Model
inputs/
Outputs
a.
Summary
of
additional
inputs
for
various
scenarios;
other
than
those
listed
in
Table
2
of
the
MEMO
PRZM/
EXAMS
Additional
input
parameters
for
various
scenarios.

Scenario
Parent
EBDC
Rate
ETU
Rate
Application
Date(
dd/
mm)
Number
of
Applications
Interval
(
Days)
(
lbs/
a)
kg/
ha
1
kg/
ha
2
Apples
NC,
Apples
PA,
and
Apples
OR
(
Metiram,
Mancozeb
and
Maneb)
4.80
5.38
0.52
07/
03
20/
03
15/
03
04
7
Tomatoes
FL,
Tomatoes
PA,
and
Tomatoes
CA
(
Mancozeb)
2.40
2.69
0.26
11/
02
06/
08
06/
07
07
7
Peppers
FL
(
Maneb)
2.40
2.69
0.26
09/
10
06
7
Sweet
Corn
FL,
and
Sweet
Corn
OR
(
Maneb)
1.20
1.35
0.13
07/
11
03/
07
15
05
3
3
Potatoes
ME,
Potatoes
ID
(
Maneb)
1.60
1.79
0.17
07/
07
15/
07
10
5
Wheat
TX,
Wheat
ND,
and
Wheat
OR
(
Mancozeb)
1.60
1.79
0.17
02/
04
24/
05
16/
04
03
7
Cabbage
FL
(
Maneb)
1.60
1.79
0.17
10/
10
01/
15
06
7
Grapes
CA
(
Mancozeb
and
Maneb)
3.2
3.59
0.34
15/
02
06
7
Almonds
CA
(
Maneb)
6.4
7.17
0.69
20/
03
04
7
Onions
CA
(
Mancozeb
and
Maneb)
2.40
2.69
0.26
15/
03
10
7
Turf
FL
(
Mancozeb
and
Maneb)
3
17.4
19.51
1.87
15/
03
01
None
Sugar
beet
CA,
and
Sugar
beet
(
Mancozeb
and
Maneb)
1.60
1.79
0.17
01/
03
01/
08
07
7
Peanuts
NC
(
Mancozeb)
1.80
2.02
0.19
21/
03
07
5
1
Parent
rate
(
kg/
ha)=
parent
rate
(
lbs
a.
i./
a)
x
1.121.
2
ETU
rate
(
kg/
ha)=
parent
rate
(
kg
a.
i./
ha)
x
0.096.
3
Label
didn't
specify
the
number
of
applications,
one
application
was
assumed
at
a
rate
of
17.4
lbs
a.
i/
acre.
However,
PRZM/
EXAMS
runs
were
also
executed
for
three
applications,
17.4
lbs
a.
i/
acre
each
applied
at
5
and
7
days
intervals.
100
b.
Summary
of
all
Outputs
and
Sample
of
selected
Outputs
PRZM/
EXAMS
modeling
results;
EDWCs
at
the
national
scale.

Scenario
National
PCA
Peak
96
hr
21
Day
60
Day
90
Day
Yearly
All
Years
FL
Peppers
0.87
25.2
20.4
12.9
6.4
4.4
1.1
0.7
NC
Apples
0.87
23.3
20.2
15.6
8.6
5.9
1.5
1.2
FL
Sweet
corn
0.87
22.6
18.3
10.4
6.2
4.1
1.2
0.8
FL
Tomatoes
0.87
22.5
17.5
8.5
5.3
3.8
0.9
0.7
FL
Turf
1
0.87
23.3
19.5
11.5
6.2
4.2
1.0
0.7
CA
Almonds
0.87
21.6
19.0
14.9
9.0
6.2
1.5
1.3
PA
Tomatoes
0.87
19.6
16.3
10.7
7.1
5.2
1.3
0.9
PA
Apples
0.87
18.3
15.9
12.8
7.4
5.0
1.3
1.1
CA
Onions
0.87
17.7
14.4
11.6
10.0
7.6
1.9
1.8
OR
Apples
0.87
16.0
14.0
11.5
6.9
4.8
1.2
1.1
NC
Peanuts
0.87
12.8
11.2
8.2
4.7
3.2
0.8
0.6
CA
Grapes
0.87
11.2
9.9
8.6
6.1
4.3
1.1
1.0
FL
Cabbage
0.87
9.8
8.6
6.1
3.8
2.7
0.7
0.5
MN
Sugar
beet
0.87
9.0
7.7
5.2
3.7
2.9
0.8
0.6
ME
Potatoes
0.87
8.9
7.6
6.0
4.4
3.3
0.9
0.8
TX
Wheat
0.87
8.1
6.4
4.0
1.7
1.2
0.3
0.2
CA
Sugar
beet
0.87
7.0
6.3
5.5
4.0
2.9
0.7
0.6
ID
Potatoes
0.87
6.0
4.9
4.3
3.4
2.5
0.7
0.6
CA
Tomatoes
0.87
5.4
4.2
3.5
2.7
1.9
0.5
0.4
OR
Sweet
corn
0.87
5.0
4.2
3.1
1.5
1.1
0.3
0.2
OR
wheat
0.87
4.5
4.0
2.9
1.6
1.1
0.3
0.3
ND
Wheat
0.87
4.5
3.7
2.7
1.3
0.9
0.2
0.2
1
These
are
the
results
for
one
application
(
17.4
lbs
a.
i/
acre).
The
results
for
three
applications
(
17.4
lbs
a.
i/
acre
each)
are
as
follows
(
ETU
in
ppb):

For
5­
day
intervals:
55.9
(
Peak);
47.1(
96
hr);
34.9
(
21
Day);
18.2
(
60
Day);
12.4
(
90
Day);
3.1
(
Yearly);
and
2.2
(
All
Years);
and
For
7­
day
intervals:
56.7
(
Peak);
55.4
(
96
hr);
35.0
(
21
Day);
18.1
(
60
Day);
12.2
(
90
Day);
3.0
(
Yearly);
and
2.2
(
All
Years).
101
PRZM/
EXAMS
modeling
results;
EDWCs
at
the
regional
scale.

Scenario
Regional
PCA
Peak
96
hr
21
Day
60
Day
90
Day
Yearly
All
Years
CA
Almonds
0.56
13.9
12.2
9.6
5.8
4.0
1.0
0.8
OR
Apples
0.63
11.6
10.1
8.3
5.0
3.5
0.9
0.8
CA
Onions
0.56
11.4
9.3
7.5
6.4
4.9
1.2
1.1
FL
Peppers
0.38
11.0
8.9
5.6
2.8
1.9
0.5
0.3
PA
Tomatoes
0.46
10.4
8.6
5.6
3.7
2.7
0.7
0.5
NC
Apples
0.38
10.2
8.8
6.8
3.8
2.6
0.6
0.5
FL
Sweet
corn
0.38
9.9
8.0
4.5
2.7
1.8
0.5
0.3
FL
Tomatoes
0.38
9.8
7.7
3.7
2.3
1.6
0.4
0.3
PA
Apples
0.46
9.7
8.4
6.8
3.9
2.7
0.7
0.6
FL
Turf
1
0.38
10.2
8.5
5.0
2.7
1.8
0.5
0.3
MN
Sugar
beet
0.83
8.6
7.4
5.0
3.5
2.7
0.7
0.6
CA
Grapes
0.56
7.2
6.3
5.5
3.9
2.8
0.7
0.7
TX
Wheat
0.67
6.2
4.9
3.1
1.3
0.9
0.2
0.1
NC
Peanuts
0.38
5.6
4.9
3.6
2.0
1.4
0.3
0.3
CA
Sugar
beet
0.56
4.5
4.1
3.5
2.6
1.8
0.5
0.4
ID
Potatoes
0.63
4.4
3.6
3.1
2.5
1.8
0.5
0.4
FL
Cabbage
0.38
4.3
3.8
2.6
1.7
1.2
0.3
0.2
OR
Sweet
corn
0.63
3.6
3.0
2.3
1.1
0.8
0.2
0.2
CA
Tomatoes
0.56
3.5
2.7
2.2
1.7
1.2
0.3
0.3
OR
wheat
0.63
3.3
2.9
2.1
1.2
0.8
0.2
0.2
ND
Wheat
0.56
2.9
2.4
1.7
0.8
0.6
0.1
0.1
ME
Potatoes
0.14
1.4
1.2
1.0
0.7
0.5
0.1
0.1
1
These
are
the
results
for
one
application
(
17.4
lbs
a.
i/
acre).
The
results
for
three
applications
(
17.4
lbs
a.
i/
acre
each)
are
as
follows
(
ETU
in
ppb):

For
5­
day
intervals:
24.4
(
Peak);
20.6
(
96
hr);
15.2
(
21
Day);
8.0
(
60
Day);
5.4
(
90
Day);
1.3
(
Yearly);
and
1.0
(
All
Years);
and
For
7­
day
intervals:
29.1
(
Peak);
24.2
(
96
hr);
15.3
(
21
Day);
7.9
(
60
Day);
5.3
(
90
Day);
1.3
(
Yearly);
and
1.0
(
All
Years).
102
lorida
peppers
scenario
Inputs
generated
by
pe4.
pl
­
8­
August­
2003
Data
used
for
this
run:
Output
File:
ETUDW
Metfile:
w12844.
dvf
PRZM
scenario:
FLpeppersC.
txt
EXAMS
environment
file:
ir298.
exv
Chemical
Name:
ETU
Description
Variable
Name
Value
Units
Comments
Molecular
weight
mwt
102.2
g/
mol
Henry's
Law
Const.
henry
atm­
m^
3/
mol
Vapor
Pressure
vapr
9.73E­
01
torr
Solubility
sol
20000
mg/
L
Kd
Kd
mg/
L
Koc
Koc
288
mg/
L
Photolysis
half­
life
kdp
1
days
Half­
life
Aerobic
Aquatic
Metabolism
kbacw
6.28
days
Halfife
Anaerobic
Aquatic
Metabolism
kbacs
447
days
Halfife
Aerobic
Soil
Metabolism
asm
3.14
days
Halfife
Hydrolysis:
pH
7
0
days
Half­
life
Method:
CAM
2
integer
See
PRZM
manual
Incorporation
Depth:
DEPI
0
cm
Application
Rate:
TAPP
0.26
kg/
ha
Application
Efficiency:
APPEFF
0.95
fraction
Spray
Drift
DRFT
0.393
fraction
of
application
rate
applied
to
pond
Application
Date
Date
10­
09
dd/
mm
or
dd/
mmm
or
dd­
mm
or
dd­
mmm
Interval
1
interval
7
days
Set
to
0
or
delete
line
for
single
app.
Interval
2
interval
7
days
Set
to
0
or
delete
line
for
single
app.
Interval
3
interval
7
days
Set
to
0
or
delete
line
for
single
app.
Interval
4
interval
7
days
Set
to
0
or
delete
line
for
single
app.
Interval
5
interval
7
days
Set
to
0
or
delete
line
for
single
app.
Record
17:
FILTRA
IPSCND
1
UPTKF
Record
18:
PLVKRT
PLDKRT
FEXTRC
0.5
Flag
for
Index
Res.
Run
IR
IR
Flag
for
runoff
calc.
RUNOFF
total
none,
monthly
or
total(
average
of
entire
run)

Outputs
stored
as
ETUDW.
out
Chemical:
ETU
PRZM
environment:
FLpeppersC.
txt
modified
Satday,
12
October
2002
at
16:
41:
28
103
EXAMS
environment:
ir298.
exv
modified
Thuday,
29
August
2002
at
15:
34:
12
Metfile:
w12844.
dvf
modified
Wedday,
3
July
2002
at
09:
04:
30
Water
segment
concentrations
(
ppb)

Year
Peak
96
hr
21
Day
60
Day
90
Day
Yearly
1961
7.7
5.74
4.839
3.173
2.142
0.5281
1962
7.703
5.699
4.228
2.898
1.971
0.4919
1963
15.02
11.21
6.364
4.25
2.882
0.7171
1964
19.61
14.79
9.273
7.331
5.039
1.248
1965
36.65
28.79
15.19
8.985
6.055
1.509
1966
10.11
7.864
5.344
3.448
2.337
0.5942
1967
11.91
8.921
5.825
3.524
2.382
0.5947
1968
13.14
10.79
7.101
4.35
2.955
0.7344
1969
12.44
9.092
7.65
4.679
3.199
0.7983
1970
6.327
5.053
3.942
2.742
1.863
0.4707
1971
13.48
11.21
7.543
4.151
2.794
0.6951
1972
55.22
42.08
18.65
8.196
5.543
1.371
1973
5.815
4.402
3.676
2.873
1.946
0.497
1974
9.919
7.623
4.724
3.692
2.535
0.6306
1975
7.429
5.699
4.35
2.914
1.977
0.4955
1976
11.26
9.591
6.419
4.213
2.883
0.7151
1977
7.135
5.475
4.491
3.433
2.386
0.5983
1978
25.5
20.22
11.59
6.121
4.148
1.032
1979
12.29
9.137
5.713
3.514
2.386
0.6012
1980
6.644
5.686
4.227
3.245
2.208
0.5505
1981
17.59
14.71
8.107
4.427
3.01
0.7496
1982
29.11
22.25
15.64
7.333
4.957
1.232
1983
22.7
17.06
10.35
5.537
3.75
0.9407
1984
28.09
23.54
10.72
6.728
4.779
1.187
1985
5.691
4.291
3.442
2.441
1.65
0.4276
1986
11.03
8.242
6.276
4.122
2.786
0.6923
1987
21.21
17.19
9.183
5.279
3.566
0.8874
1988
8.881
7.147
5.173
3.032
2.044
0.513
1989
8.347
6.427
4.909
3.288
2.221
0.5533
1990
6.274
4.55
3.563
2.525
1.703
0.4257
Sorted
results
Prob.
Peak
96
hr
21
Day
60
Day
90
Day
Yearly
0.032258065
55.22
42.08
18.65
8.985
6.055
1.509
0.064516129
36.65
28.79
15.64
8.196
5.543
1.371
0.096774194
29.11
23.54
15.19
7.333
5.039
1.248
0.129032258
28.09
22.25
11.59
7.331
4.957
1.232
0.161290323
25.5
20.22
10.72
6.728
4.779
1.187
0.193548387
22.7
17.19
10.35
6.121
4.148
1.032
0.225806452
21.21
17.06
9.273
5.537
3.75
0.9407
104
0.258064516
19.61
14.79
9.183
5.279
3.566
0.8874
0.290322581
17.59
14.71
8.107
4.679
3.199
0.7983
0.322580645
15.02
11.21
7.65
4.427
3.01
0.7496
0.35483871
13.48
11.21
7.543
4.35
2.955
0.7344
0.387096774
13.14
10.79
7.101
4.25
2.883
0.7171
0.419354839
12.44
9.591
6.419
4.213
2.882
0.7151
0.451612903
12.29
9.137
6.364
4.151
2.794
0.6951
0.483870968
11.91
9.092
6.276
4.122
2.786
0.6923
0.516129032
11.26
8.921
5.825
3.692
2.535
0.6306
0.548387097
11.03
8.242
5.713
3.524
2.386
0.6012
0.580645161
10.11
7.864
5.344
3.514
2.386
0.5983
0.612903226
9.919
7.623
5.173
3.448
2.382
0.5947
0.64516129
8.881
7.147
4.909
3.433
2.337
0.5942
0.677419355
8.347
6.427
4.839
3.288
2.221
0.5533
0.709677419
7.703
5.74
4.724
3.245
2.208
0.5505
0.741935484
7.7
5.699
4.491
3.173
2.142
0.5281
0.774193548
7.429
5.699
4.35
3.032
2.044
0.513
0.806451613
7.135
5.686
4.228
2.914
1.977
0.497
0.838709677
6.644
5.475
4.227
2.898
1.971
0.4955
0.870967742
6.327
5.053
3.942
2.873
1.946
0.4919
0.903225806
6.274
4.55
3.676
2.742
1.863
0.4707
0.935483871
5.815
4.402
3.563
2.525
1.703
0.4276
0.967741935
5.691
4.291
3.442
2.441
1.65
0.4257
0.1
29.008
23.411
14.83
7.3328
5.0308
1.2464
EDWC
for
ETU;
Fl
peppers
Average
of
yearly
averages:
0.749377
Adj
for
National
PCA
(
0.87)
25.2
20.4
12.9
6.4
4.4
1.1
0.7
Adj
for
Regional
PCA
(
0.38)
11.0
8.9
5.6
2.8
1.9
0.5
Average
of
yearly
averages:
0.3
105
California
almonds
scenario
Inputs
generated
by
pe4.
pl
­
8­
August­
2003
Data
used
for
this
run:
Output
File:
ETUDW
Metfile:
w23232.
dvf
PRZM
scenario:
CAalmondC.
txt
EXAMS
environment
file:
ir298.
exv
Chemical
Name:
ETU
Description
Variable
Name
Value
Units
Comments
Molecular
weight
mwt
102.2
g/
mol
Henry's
Law
Const.
henry
atm­
m^
3/
mol
Vapor
Pressure
vapr
9.73E­
01
torr
Solubility
sol
20000
mg/
L
Kd
Kd
mg/
L
Koc
Koc
288
mg/
L
Photolysis
half­
life
kdp
1
days
Half­
life
Aerobic
Aquatic
Metabolism
kbacw
6.28
days
Halfife
Anaerobic
Aquatic
Metabolism
kbacs
447
days
Halfife
Aerobic
Soil
Metabolism
asm
3.14
days
Halfife
Hydrolysis:
pH
7
0
days
Half­
life
Method:
CAM
2
integer
See
PRZM
manual
Incorporation
Depth:
DEPI
0
cm
Application
Rate:
TAPP
0.69
kg/
ha
Application
Efficiency:
APPEFF
0.95
fraction
Spray
Drift
DRFT
0.393
fraction
of
application
rate
applied
to
pond
Application
Date
Date
20­
03
dd/
mm
or
dd/
mmm
or
dd­
mm
or
dd­
mmm
Interval
1
interval
7
days
Set
to
0
or
delete
line
for
single
app.
Interval
2
interval
7
days
Set
to
0
or
delete
line
for
single
app.
Interval
3
interval
7
days
Set
to
0
or
delete
line
for
single
app.
Record
17:
FILTRA
IPSCND
1
UPTKF
Record
18:
PLVKRT
PLDKRT
FEXTRC
0.5
Flag
for
Index
Res.
Run
IR
IR
Flag
for
runoff
calc.
RUNOFF
total
none,
monthly
or
total(
average
of
entire
run)

Outputs
stored
as
ETUDW.
out
Chemical:
ETU
PRZM
environment:
CAalmondC.
txt
modified
Satday,
12
October
2002
at
16:
30:
38
EXAMS
environment:
ir298.
exv
modified
Thuday,
29
August
2002
at
15:
34:
12
Metfile:
w23232.
dvf
modified
Wedday,
3
July
2002
at
09:
04:
22
Water
segment
concentrations
(
ppb)
106
Year
Peak
96
hr
21
Day
60
Day
90
Day
Yearly
1961
20.64
17.54
14.25
8.026
5.454
1.361
1962
20.73
17.6
14.41
8.088
5.497
1.379
1963
28.25
24.98
23.19
13.28
9.107
2.282
1964
20.48
17.37
14.12
7.925
5.386
1.346
1965
21.99
18.89
14.98
8.601
5.845
1.465
1966
20.03
16.79
13.85
7.597
5.143
1.287
1967
24.87
21.97
17.22
10.44
7.144
1.787
1968
20.29
17.14
13.98
7.788
5.284
1.319
1969
24.24
20.76
16.27
9.238
6.266
1.567
1970
20.94
18
14.34
8.223
5.57
1.393
1971
21.02
18.04
14.48
8.333
5.68
1.422
1972
20.38
17.34
13.9
7.859
5.333
1.331
1973
20.17
16.96
13.97
7.684
5.192
1.298
1974
21.14
18.18
14.58
8.408
5.726
1.441
1975
22.44
19.45
16.15
9.532
6.454
1.613
1976
22.73
19.43
14.75
8.427
5.694
1.42
1977
19.84
16.6
13.63
7.527
5.122
1.282
1978
21.42
18.53
14.71
8.655
5.874
1.47
1979
22.01
18.93
15.81
8.9
6.034
1.51
1980
20.6
17.47
14.29
8.012
5.445
1.36
1981
21.15
18.14
14.66
8.405
5.716
1.429
1982
37.54
33.24
22.57
12.85
8.764
2.197
1983
21.48
18.53
14.97
9.014
6.154
1.542
1984
20.01
16.94
13.54
7.554
5.102
1.272
1985
20.49
17.29
14.28
7.91
5.362
1.342
1986
20.87
17.87
14.09
8.073
5.482
1.372
1987
20.23
17.05
13.96
7.707
5.207
1.303
1988
20.53
17.53
13.99
8.628
5.881
1.467
1989
20.29
17.12
14.04
7.799
5.284
1.373
1990
20.01
16.76
13.84
7.607
5.438
1.367
Sorted
results
Prob.
Peak
96
hr
21
Day
60
Day
90
Day
Yearly
0.032258065
37.54
33.24
23.19
13.28
9.107
2.282
0.064516129
28.25
24.98
22.57
12.85
8.764
2.197
0.096774194
24.87
21.97
17.22
10.44
7.144
1.787
0.129032258
24.24
20.76
16.27
9.532
6.454
1.613
0.161290323
22.73
19.45
16.15
9.238
6.266
1.567
0.193548387
22.44
19.43
15.81
9.014
6.154
1.542
0.225806452
22.01
18.93
14.98
8.9
6.034
1.51
0.258064516
21.99
18.89
14.97
8.655
5.881
1.47
0.290322581
21.48
18.53
14.75
8.628
5.874
1.467
107
0.322580645
21.42
18.53
14.71
8.601
5.845
1.465
0.35483871
21.15
18.18
14.66
8.427
5.726
1.441
0.387096774
21.14
18.14
14.58
8.408
5.716
1.429
0.419354839
21.02
18.04
14.48
8.405
5.694
1.422
0.451612903
20.94
18
14.41
8.333
5.68
1.42
0.483870968
20.87
17.87
14.34
8.223
5.57
1.393
0.516129032
20.73
17.6
14.29
8.088
5.497
1.379
0.548387097
20.64
17.54
14.28
8.073
5.482
1.373
0.580645161
20.6
17.53
14.25
8.026
5.454
1.372
0.612903226
20.53
17.47
14.12
8.012
5.445
1.367
0.64516129
20.49
17.37
14.09
7.925
5.438
1.361
0.677419355
20.48
17.34
14.04
7.91
5.386
1.36
0.709677419
20.38
17.29
13.99
7.859
5.362
1.346
0.741935484
20.29
17.14
13.98
7.799
5.333
1.342
0.774193548
20.29
17.12
13.97
7.788
5.284
1.331
0.806451613
20.23
17.05
13.96
7.707
5.284
1.319
0.838709677
20.17
16.96
13.9
7.684
5.207
1.303
0.870967742
20.03
16.94
13.85
7.607
5.192
1.298
0.903225806
20.01
16.79
13.84
7.597
5.143
1.287
0.935483871
20.01
16.76
13.63
7.554
5.122
1.282
0.967741935
19.84
16.6
13.54
7.527
5.102
1.272
0.1
24.807
21.849
17.125
10.3492
7.075
1.7696
EDWC
for
ETU;
CA
Almonds
Average
of
yearly
averages:
1.466567
Adj
for
National
PCA
(
0.87)
21.6
19.0
14.9
9.0
6.2
1.5
1.3
Adj
for
Regional
PCA
(
0.56)
13.9
12.2
9.6
5.8
4.0
1.0
Average
of
yearly
averages:
0.8
2.
Background
Information
on
the
modeling
a.
PRZM
and
EXAMS
models
and
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
108
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.

b.
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.
109
REFERENCES
a.
Environmental
Fate
MRID:
404661­
03
M.
Carpenter
1987.
Hydrolysis
as
a
function
of
pH
at
25
oC
of
14C­
Ethylenethiourea.
Un
published
study
prepared
by
ABC
Laboratories
for
Roam
and
Haas
and
received
Jan
18,
1988
in
response
to
the
Mancozeb
Registration
Standard.

MRID:
404661­
02
M.
Carpenter
and
M.
Fennessey
1987.
Determination
of
photolysis
rate
of
14C­
Ethylenethiourea
in
pH
7
aqueous
solution.
Un
published
study
prepared
by
ABC
Laboratories
for
Roam
and
Haas
and
received
Jan
18,
1988
in
response
to
the
Mancozeb
Registration
Standard.

MRID:
404661­
01
M.
Carpenter
1987.
Determination
of
photolysis
rate
of
14C­
Ethylenethiourea
on
the
surface
of
soil.
Un
published
study
prepared
by
ABC
Laboratories
for
Roam
and
Haas
and
received
Jan
18,
1988
in
response
to
the
Mancozeb
Registration
Standard.

MRID:
40838701
Schweitzer,
M.
1988.
Response
to
the
U.
S.
Environmental
Protection
Agency
review
of
mancozeb
aerobic
soil
metabolism
study
Acc.
No.
263908.
Performed
and
submitted
by
Rohm
and
Haas
Company,
Spring
House,
PA
MRID:
45156401
and
45225101
Wright,
M.
C.
2000.
Aerobic
soil
metabolism
degradation
rate
determination
for
ethylenethiourea
(
ETU)
on
soil.
XBL
Study
No.:
XBL99045.
XBL
Report
No.:
RPT00598
(
MRID
45156401)
and
RPT00643
(
MRID
45225101).
Unpublished
study
performed
by
XenoBiotic
Laboratories,
Inc.,
Plainsboro,
NJ;
and
submitted
by
the
EDBC/
ETU
Task
Force
(
consisting
of
BASF
Corporation,
Elf
Atochem
North
America,
Inc.,
Griffin,
L.
L.
C,
and
Rohm
and
Haas
Company),
Washington,
DC.

MRID:
001633­
35
J.
Blair
1986.
Anaerobic
aquatic
metabolism
of
14C­
maneb.
Unpublished
study
prepared
by
Hazelton
Laboratories.

MRID:
000888­
20
Swan,
L.
H.
1978a
Degradation
of
Dithane
M­
45
(
mancozeb)
and
ethylenethiourea
under
anaerobic
aquatic
conditions.
Technical
report
No.
34F­
78­
6.
Includes
method
1853­
1
dated
July
19,
1973.
Unpublished
study
received
Dec.
9,
1981
under
707­
78
submitted
by
Rohm
and
Haas
Company,
Philadelphia,
PA.
CDL:
070528­
A.
110
MRID:
402582­
03
Swan,
L.
H.
1978b.
Supplemental
to
the
Degradation
of
Dithane
M­
45
(
MRID
000888­
20)
and
ETU
under
anaerobic
aquatic
conditions.
Laboratory
project
ID
TR
34­
78­
06
submitted
by
Rohm
and
Haas
Company,
Spring
House,
PA.

MRID:
002588­
96
(
Also
submitted
under
Accession
No.
402229­
02)
Yeh,
S.
M.
1986a.
Batch
soil
adsorption/
desorption.
Technical
Report
No.
310­
86­
63.
Laboratory
Project
ID:
Biospherics
No.
86E205AD.
Prepared
by
Biospherics,
Incorporated
for
Rohm
and
Haas
Company,
Philadelphia,
PA.

MRID:
000971­
58
A
laboratory
technical
report
submitted
by
the
registrar.

No
MRID
No.
(
Accession
No.
255229)
Helling,
C.
S.
and
S.
M.
Thompson
1973.
Azide
and
ethylenethiourea
mobility
in
soils.
Soil
Sci.
Soc.
Am.
Proc.
38:
79­
85.
Submitted
by
E.
I.
de
Pont
de
Nemours
and
company.

MRID:
405883­
01
Daly,
D.
1988a.
Leaching
characteristics
of
soil
incorporated
ethylenethiourea
following
aerobic
aging.
Prepared
by
Analytical
Bio­
Chemistry
Laboratories,
Columbia,
Missouri,
and
submitted
by
Rohm
and
Haas,
Philadelphia,
PA
No
MRID
No.
(
Accession
No.
255229)
Blazquez,
C.
H.
1973.
Residue
determination
of
ethylenethiourea
(
2­
imidiazoli­
dinethions)
from
tomato
foliage,
soil
and
water.
J.
Agric.
Food
Chem.
21
(
3):
330­
333.
Submitted
by
E.
I.
de
Pont
de
Nemours
and
company.

MRID:
000889­
23
Rhodes,
R.
C.
1977.
Studies
with
manganese­
14C
ethylenebis
(
dithiocarbamate)(
14C­
maneb)
fungicide
and
14C
ethylenethiourea
(
14C­
ETU)
in
plants,
soil,
and
water.
J.
Agric.
Food
Chem.
25
(
3):
328­
533.
Also
in
unpublished
submission
received
Dec.
9,
1981
under
707­
78.
Submitted
by
Rohm
&
Haas
Co.,
Philadelphia,
PA;
CDL:
070525­
1.

MRID:
448804­
01
G.
Bruns
et
al.
1999.
Validation
of
the
Method
of
Analysis
for
Ethylenethiourea
(
ETU)
in
Water
by
LC/
MS/
MS.
Unpublished
study
conducted
by
Enviro­
Test
Laboratories
(
ETL),
9936­
67
Avenue,
Edmonton,
Alberta
T6E
OP5
Canada.
111
112
b.
Ecological
Effects
Beyer,
W.
N..
and
E.
E.
Connor,
"
Estimates
of
Soil
Ingestion
by
Wildlife,"
U.
S.
Fish
and
Wildlife
Service,
Patuxent
Wildlife
Research
Center
at
Laurel,
MD
and
S.
Gerould,
U.
S.
Geological
Survey,
Reston,
VA.

Biswas,
S.
K.
and
K.
Banerjee,
S.
K.
Handa.
2003.
Metabolic
fate
of
mancozeb
in
tomato
(
Lycopersicon
esculentum).
Toxicol.
And
Environ.
Chem.
85(
1­
3):
33­
38.

Brooks,
H.
L.
et
al.
1973.
Insecticides.
Cooperative
Extension
Service.
Kansas
State
Univ.
Manhattan,
Kansas.

Burns,
L.
A.
1997.
EXAMS
2.97.5
Users
Manual.
National
Exposure
Research
Lab,
Office
of
Research
and
Development,
U.
S.
Environmental
Protection
Agency.
Athens,
Georgia.

Carsel,
R.
F.,
Imhoff,
J.
C.,
Hummel,
P.
R.,
Cheplick,
J.
M.
and
Donigan,
A.
S.
1997.
PRZM
3.1
Users
Manual.
National
Exposure
Research
Lab,
Office
of
Research
and
Development,
U.
S.
Environmental
Protection
Agency.
Athens,
Georgia.

Dole,
Tim
and
Jeff
Dawson.
Issued:
5/
15/
2003.
Mancozeb:
Occupational
and
Residential
Exposure
Assessment
and
Recommendations
for
the
Reregistration
Eligibility
Decision
Document.
PC
Code
014504;
DP
Barcode:
D286871.

Dole,
Tim
and
Jeff
Dawson.
Issued:
12/
05/
2003a.
Metiram:
Occupational
and
Residential
Exposure
Assessment
and
Recommendations
for
the
Reregistration
Eligibility
Decision
Document.
PC
Code
014601;
DP
Barcode:
D287664.

Dole,
Tim
and
Jeff
Dawson.
Issued:
5/
14/
2003b.
Maneb:
Occupational
and
Residential
Exposure
Assessment
and
Recommendations
for
the
Reregistration
Eligibility
Decision
Document.
PC
Code
014505;
DP
Barcode:
D251404.

DÇtzer,
R.
1994.
Statement
on
the
Analytical
Determination
of
Polyram
DF
(
Active
Ingredient:
Metiram)
in
Water
for
Ecotoxicological
Tests.
Attachment
to
MRID
No.
43522501:
Acute
Toxicity
Study
on
the
Rainbow
Trout
of
BAS
222
28
F
in
a
Flow­
Through
System
for
96
Hours:
Lab
Project
Numbers:
94/
10920:
PCP03089:
94/
161.
Unpublished
study
prepared
by
BASF
Aktiengesellschaft.

Felkel,
J.
2000.
Reregistration
Eligibility
Document
(
RED)
for
Diazinon.
US
EPA,
OPP,
EFED
Fletcher,
J.
S.,
J.
E.
Nellessen,
and
T.
G.
Pfleeger.
1994.
Literature
review
and
evaluation
of
the
EPA
food­
chain
(
Kenaga)
nomogram,
an
instrument
for
estimating
pesticide
residues
on
plants.
Environ.
113
Toxicol.
Chem.
13:
1383­
1391.

Gusey,
W.
F.
and
Z.
D.
Maturgo.
April,
1973.
Wildlife
Utilization
of
Croplands.
Environmental
Affairs.
Shell
Oil
Co.
Houston,
TX.

Hoerger,
F.
and
E.
E.
Kenaga.
1972.
Pesticide
residues
on
plants:
Correlation
of
representative
data
as
a
basis
for
estimation
of
their
magnitude
in
the
environment.
In
F.
Coulston
and
F.
Korte
(
eds),
Environmental
Quality
and
Safety:
Chemistry,
Toxicology
and
Technology.
Georg
Thieme
Publishers,
Stuttgart,
pp.
9­
28.

MRID
No.
46145401.
Bedosky,
S.
2003.
EBDC/
ETU
Task
Force
National
Drinking
Water
Monitoring
Survey:
Final
Report.
Project
Number:
ETU/
2000/
01,
ETU/
0301,
004/
06942/
04.
Unpublished
study
prepared
by
Levine­
Fricke,
Inc.,
Enviro­
Test
Laboratories
(
ETL),
and
Morse
Laboratories.
572
p.

Nelson,
A.
N.
1975.
Appraisal
of
the
Safety
of
Chemicals:
Approximate
Relation
of
Parts
Per
Million
in
Diet
to
Mg/
Kg/
Day.
Quarterly
Report
to
the
Editor
on
Topics
of
Current
Interest.
Association
of
Food
and
Drug
Officials
of
the
United
States.

Ollinger,
J.
Mar.
7,
2005.
Literature
supporting
revised
mancozeb
and
ETU
half­
lives.
Mancozeb
Task
Force 
Cerexagri,
Inc;
Dow
AgroSciences,
LLC;
and
Griffin
LLC
(
a
DuPont
Company).
Washington,
DC
Urban,
Douglas
J.
2000.
Guidance
for
Conducting
Avian
Risk
Assessments
for
Spray
Applications
of
Pesticides.
Environmental
Fate
&
Effects
Division.
Office
of
Pesticide
Programs.
U.
S.
Environmental
Protection
Agency.
Washington,
D.
C.

US
EPA.
April,
1998.
Guidelines
for
Ecological
Risk
Assessment.
Risk
Assessment
Forum.
Washington,
DC.
EPA/
630/
R­
95/
002F
US
EPA.
Oct.
6,
1997.
Announcement
of
the
Draft
Drinking
Water
Contaminant
List.
FR
Vol.
62,
No.
193.
pp
52193­
52219
°
URL:
http://
www.
epa.
gov/
ogwdw000/
ccl/
dwccl.
html
US
EPA.
June
30,
1995.
EEB
Guidance
Document
Number
A­
02.
What
Are
Our
Levels
of
Concern
and
How
Are
They
Used.
Office
of
Pesticide
Programs.
Environmental
Fate
&
Effects
Division.
Washington,
D.
C.

US
EPA
December,
2002.
TXR#
0050408.
Ethylenebisdithiocarbamates
(
EBDCs):
Mancozeb,
Maneb,
and
Metiram.
Outcome
of
the
HED
Metabolism
Assessment
Review
Committee
(
MARC)
114
Meeting.
Office
of
Pesticide
Programs.
Health
Effects
Division.
Washington,
D.
C.

Willis,
G.
and
L.
McDowell.
1987.
Pesticide
Persistance
on
Foliage.
Review
of
Environmental
Contamination
and
Toxicology,
Volume
100.
Springer­
Verlag,
New
York.
pp.
24­
73
