UNITED
STATES
ENVIRONMENTAL
PROTECTION
AGENCY
WASHINGTON,
D.
C.
20460
OFFICE
OF
PREVENTION,
PESTICIDES
AND
TOXIC
SUBSTANCES
PC
Code
No.:
014505
DP
Barcode:
D
305863
Date:
June
21,
2005
MEMORANDUM
SUBJECT:
Environmental
Fate
and
Ecological
Risk
Assessment
for
Maneb,
Section
4
Reregistration
for
Control
of
Fungal
Diseases
on
Numerous
Crops,
Ornamental
Plantings,
and
Turf
(
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.
This
RED
document
should
be
considered
with
the
ETU
document,
the
degradate
of
concern
for
metiram.

The
following
is
an
overview
of
our
findings:

Risk
Summary
Based
on
available
data,
EFED
expects
all
maneb's
uses
to
present
potential
chronic
risks
to
birds
and
mammals.
EFED
relied
on
a
referenced
total
foliar
dissipation
half­
life
value
of
3.2
days
from
Willis
and
McDowell,
1987
to
evaluate
exposure
to
terrestrial
organisms.
Avian
chronic
LOCs
are
exceeded
for
all
use
patterns.
RQs
range
from
a
high
of
265
from
the
turf
use
to
a
low
of
0.4
from
maneb's
uses
on
collards,
turnips,
and
mustard
(
Georgia
and
Tennessee,
only).
Mammalian
chronic
LOCs
are
exceeded
for
all
uses
patterns.
RQs
range
from
a
high
of
71
from
the
turf
use
to
a
low
of
0.1
from
maneb's
uses
on
collards,
turnips,
and
mustard
(
Georgia
and
Tennessee,
only).
EFED
does
not
calculate
risk
quotients
to
conduct
risk
assessments
on
terrestrial
invertebrates.
Based
on
the
lack
of
acute
maneb
toxicity
to
honeybees,
EFED
expects
a
low
acute
risk
to
nontarget
terrestrial
1
In
this
document
three
important
abbreviations
are
used:
Parent
maneb,
maneb
complex
and
Bound
species.
Parent
maneb
is
the
polymeric
parent
maneb
present
in
the
active
ingredient.
Maneb
complex
is
a
suite
of
multi
species
residues
resulting
from
degradation
of
the
polymeric
parent
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).

2
insects.
Due
to
lack
of
data
EFED
did
not
assess
risks
to
terrestrial
plants
or
fully
assess
risks
to
aquatic
plants.
In
the
aquatic
environment,
EFED
concludes
maneb
complex
will
present
a
potential
acute
risk
to
freshwater/
estuarine/
marine
fish
and
invertebrates
as
well
as
nonvascular
aquatic
plants.
EFED
selected
representative
maneb
use
patterns
at
maximum
application
rates
and
minimum
intervals
between
applications
for
aquatic
modeling.
Maneb
is
used
on
more
than
20
different
crop
groupings.
The
representative
sites
selected
for
aquatic
modeling
were
apples,
peppers,
potatoes
(
Maine,
only)
and
tomatoes.
The
acute
RQs
exceeding
freshwater
fish
acute,
acute
restricted
use,
and
acute
endangered
species
LOCs
for
all
maneb's
modeled
uses
range
from
1.13
to
4.71.
The
acute
freshwater
invertebrates'
RQs
exceeding
acute
restricted
use,
and
acute
endangered
species
LOCs
for
all
maneb's
modeled
uses
range
from
0.40
to
1.65.
The
acute
estuarine/
marine
fish
RQs
exceed
acute
restricted
use,
and
acute
endangered
species
LOCs
for
all
maneb's
modeled
uses
with
RQs
ranging
from
0.47
to
1.1.
Estuarine/
marine
invertebrate
acute
RQs
exceed
acute,
acute
restricted
use,
and
acute
endangered
LOCs
for
all
maneb's
modeled
uses
with
RQs
ranging
from
15.87
to
65.97.
Based
on
data
for
one
surrogate
species,
maneb's
modeled
use
patterns
exceed
acute
risk
LOCs
for
nonvascular
aquatic
plants
with
acute
RQs
ranging
from
3.55
to
14.77.
EFED
did
not
assess
chronic
risks
to
freshwater
invertebrates,
estuarine/
marine
fish,
or
estuarine/
marine
invertebrates
due
to
lack
of
data.

Risk
to
the
Water
Resources
Maneb
is
non­
persistent
in
most
of
the
natural
environments.
It
is
expected
to
decompose
rapidly
(
to
<
10%
of
the
applied
within
one
day)
by
hydrolytic
reactions
in
the
main
compartments
of
the
natural
environment.
Among
the
EBDCs,
maneb
is
characterized
by
the
highest
vulnerability
to
hydrolysis
while
metiram
is
the
lowest.
The
degradate
of
concern
in
the
process
of
maneb
decomposition
is
ETU,
a
B2
carcinogen.
Therefore,
risk
assessment
for
the
water
resource
from
the
common
EBDCs
degradate
ETU
was
performed
for
the
application
of
all
EBDCs
including
maneb.
The
reader
is
referred
to
the
accompanied
ETU
chapter
for
this
assessment.

Uncertainties
(
1)
Environmental
Fate
EECs
for
parent
maneb1
were
estimated
for
water
bodies
using
hydrolysis
half­
lives.
The
same
water
hydrolysis
half­
lives
were
used
for
soils
assuming
sufficient
moisture
is
available
in
soil
pores
for
hydrolysis
to
occur
at
the
same
rate.
Uncertainty
exists
on
whether
half­
lives
used
are
applicable
because
of
uncertainty
related
to
soil
moisture
availability;
soil
moisture
level
is
expected
to
impact
resultant
EECs.
Lower
EECs
are
expected
in
irrigated
and/
or
rain­
fed
soils
with
high
water
holding
capacity
(
WHC)
and
higher
EECs
are
expected
in
low
WHC
soils
under
dry
conditions.
Given
the
3
fact
that
maneb
is
highly
vulnerable
to
hydrolysis
and
that
it
is
applied
to
growing
crops,
moisture
is
expected
to
be
available
for
parent
to
hydrolyze
at
an
adjusted
rate
near
or
just
below
that
determined
from
aqueous
hydrolysis
half­
lives.

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

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

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

(
2)
Ecological
Effects
EFED
is
uncertain
about
maneb's
acute
risk
to
nontarget
terrestrial
plants
and
needs
testing
performed
at
maneb's
maximum
rate
of
application
in
the
environment.
EFED
has
not
received
studies
to
evaluate
the
acute
risk
of
maneb
complex
to
vascular
aquatic
plants
and
is
uncertain
about
this
risk.
EFED
has
received
one
acute
study
for
1
of
4
surrogate
species
needed
to
evaluate
the
acute
risk
to
nonvascular
aquatic
plants.
This
one
study
when
compared
to
maneb
complexes'
exposure
showed
the
acute
RQs
exceeded
LOCs.
EFED
needs
testing
performed
on
3
more
surrogate
species
to
evaluate
fully
the
acute
risk
to
nonvascular
aquatic
plants.
EFED
has
no
data
to
evaluate
the
chronic
risks
to
freshwater
invertebrates
or
estuarine/
marine
organisms
and
is
uncertain
about
these
risks.
4
Endocrine
Disruption
Maneb
toxicity
effects
noted
in
both
birds
and
mammals
could
be
a
result
of
hormonal
disruptions.
The
avian
reproductive
studies
reviewed
by
EFED
noted
reproductive
effects.
These
effects
in
mallard
duck
were
decreases
in
the
number
of
hatchlings
as
percentages
of
eggs
laid,
eggs
set,
and
live
3­
week
old
embryos,
and
a
decrease
in
the
number
of
14­
day
old
survivors
as
a
percentage
of
eggs.
For
mammals
chronic
effects
were
noted
such
as
male
parental
toxicity
resulting
in
significant
increase
in
lung
weight
(
both
generations)
and
liver
weight
(
F1
generation)
with
lesions
noted
on
these
organs
in
the
F1
generation.
Chronic
testing
in
freshwater
fish
showed
decreased
hatchability,
fish
survival
and
length
of
fry.
When
the
appropriate
screening
and
or
testing
protocols
being
considered
under
the
Agency's
Endocrine
Disruptor
Screening
Program
have
been
developed,
maneb
may
be
subjected
to
additional
screening
and
or
testing
to
better
characterize
effects
related
to
endocrine
disruption.

Data
Gaps
Environmental
Fate
Complete
characterization
of
the
fate
of
maneb
complex
requires
more
information
on
the
various
species
that
constitute
its
complex
including
the
soil/
sediment
bound
species.
Information
needed
are
for
each
of
these
constituents
and
include:
their
physicochemical
properties
and
the
nature
of
their
association
with
soil/
sediment
particles.
Furthermore,
several
problems
were
identified
in
submitted
fate
studies
for
the
EBDCs
including
maneb.
These
problems
are
presented
in
detail
in
Appendix
I;
the
registrant
is
requested
to
address
these
problems.

Full
characterization
of
the
processes
involved
in
parent
maneb
dissipation
requires
additional
information
on
the
release
of
Mn
ions
from
maneb
in
order
to
evaluate
possible
environmental
risk
that
might
be
associated
with
such
release
in
specific
environmental
settings.

The
following
Table
lists
the
status
of
the
fate
data
requirements
for
maneb.
In
the
Table,
Hydrolysis,
adsorption/
desorption
and
leaching
studies
are
listed
as
supplemental
however,
no
new
studies
are
required
because
problems
found
in
these
studies
are
mostly
associated
with
the
unique
characteristics
of
this
chemical
in
aqueous
media.
Not
all
the
requirements
of
these
guideline
studies
can
be
met
due
to
the
high
susceptibility
of
this
chemical
to
hydrolysis.
In
contrast,
aerobic
soil
studies
are
classified
as
supplemental
mainly
because
of
incomplete
characterization
of
the
significant
bound
species.
Without
a
complete
characterization
of
this
bound
species,
EFED
was
only
able
to
estimate
conservative
half­
lives
based
on
complete
mineralization
of
maneb
into
CO
2
.
The
issues
of
the
bound
species
and
use
of
CS
2
data
are
presented
in
detail
elsewhere
in
this
document
(
section
IV.
b.
iv);
the
registrant
is
requested
to
address
these
issues.
A
high
tier
targeted
monitoring
study
was
submitted
for
ETU,
the
degradate
of
concern
for
all
EBDCs
including
maneb,
therefore,
no
new
terrestrial
field
dissipation
study
is
required
at
this
time.
5
Status
of
environmental
data
requirements
for
maneb
Guideline
Number
Data
Requirement
Is
Data
Needed?
MRID
Number
Study
Classification
161­
1
835.2
Hydrolysis
1
No
453936­
01
Supplemental
161­
2
835.2
Photo
Degradation
in
Water
2
No
404656­
02
Acceptable
161­
3
835.2
Photo
Degradation
on
Soil
No
404656­
03
Acceptable
162­
1
835.4
Aerobic
Soil
Metabolism
Reserved
405852­
01
Supplemental
451452­
02
162­
2
835.4
Anaerobic
Soil
No
3
405852­
02
Not
Acceptable
162­
3
835.4
Anaerobic
Aquatic
Metabolism
No
001633­
35
Acceptable
162­
4
835.4
Aerobic
Aquatic
Metabolism
No
Studies
submitted
163­
1
835.1230
Adsorption/
Desorption
4
No
050011­
90
Supplemental
835.1240
Leaching
5
No
405852­
03
Supplemental
400472­
01
455959­
01
455959­
02
163­
2
Laboratory
Volatility
Waived;
although
a
study
was
submitted
(
MRID
001549­
86;
No
DER)

164­
1
835.6
Terrestrial
Field
Dissipation
6
No
000889­
23
Supplemental
417430­
01
417430­
02
201­
1
840.1
Droplet
Size
Spectrum
A
study
was
submitted
(
MRID
424343­
01;
No
DER)

165­
4
850.2
Accumulation
in
Fish
Waived
1
Two
studies
were
rejected
(
Accession
No.
2552­
29
and
MRID
420701­
01).
One
study
was
considered
to
contain
Ancillary
information
(
MRID
404656­
01).
One
article
on
hydrolysis
was
submitted
under
MRID
000889­
17.
2
MRID
420701­
02
was
rejected.
Two
articles
on
photolysis
were
submitted
under
MRIDs
000889­
17
and
001540­
26.
3
The
study
was
rejected
but
requirement
was
satisfied
by
submitting
an
anaerobic
aquatic
study
(
MRID
001633­
35).
4
The
same
study
was
submitted
under
MRID
000658­
59.
5
No
DER
was
found
for
one
study
submitted
under
two
MRIDs
001428­
87
and
001428­
88.
6
No
DER
was
found
for
a
study
submitted
under
MRID
001619­
35.
6
Ecotoxicity
EFED
is
uncertain
about
maneb's
acute
risk
to
aquatic
and
terrestrial
plants
because
EFED
lacks
toxicity
data
for
some
or
all
surrogate
species
representing
these
groups.
Because
EFED
lacks
chronic
maneb
toxicity
data,
EFED
is
uncertain
about
the
chronic
risks
to
freshwater
invertebrates
and
estuarine/
marine
organisms.
EFED
needs
studies
to
evaluate
these
uncertainties.
EFED
needs
whole
sediment
acute
toxicity
testing
on
freshwater
and
estuarine/
marine
invertebrates
because
maneb
residue
is
toxic
to
aquatic
invertebrates,
binds
to
sediment
,
and
may
persist
on
sediment
surfaces.
In
some
risk
evaluations
EFED
has
used
supplemental
studies
to
make
a
risk
determination.
EFED
needs
core
studies
to
confirm
these
findings.

The
following
Table
lists
the
status
of
the
ecological
data
needs
for
maneb.

Status
of
ecological
data
needs
for
Maneb.

Date:
December
14,
2001
Case
No:
0643
Chemical
No:
014505
MANEB
DATA
NEEDS
FOR
THE
ENVIRONMENTAL
FATE
AND
EFFECTS
DIVISION
Data
Requirement
Composition1
Use
Pattern1
Does
EPA
Have
Data
To
Satisfy
This
Need?
Bibliographic
Citation
Study
Classification
Must
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
1,2,3,9,11
Yes
40657001
Core
No
71­
1(
b)
Acute
Avian
Oral,
Quail/
Duck
(
TEP)
1,2,3,9,11
No
not
applicable
not
applicable
No
71­
2(
a)
Acute
Avian
Diet,
Quail
TGAI
1,2,3,9,11
Yes
00104264
Supplemental
No
71­
2(
b)
Acute
Avian
Diet,
Duck
TGAI
1,2,3,11
Yes
40657002
00098561
Core
Supplemental
No
71­
3
Wild
Mammal
Toxicity
1,2,3,9,11
No
not
applicable
not
applicable
No
71­
4(
a)
Avian
Reproduction
Quail
TGAI
1,2,3,11
Yes
43586501
Supplemental
No
71­
4(
b)
Avian
Reproduction
Duck
TGAI
1,2,3,11
Yes
43586502
Core
No
71­
5(
a)
Simulated
Terrestrial
Field
Study
1,2,3,9,11
No
not
applicable
not
applicable
No
71­
5(
b)
Actual
Terrestrial
Field
Study
1,2,3,9,11
No
not
applicable
not
applicable
No
72­
1(
a)
Acute
Fish
Toxicity
Bluegill
TGAI
1,,
2,3,11
Yes
40749401
00097240
00090291
Core
Supplemental
Supplemental
No
72­
1(
b)
Acute
Fish
Toxicity
Bluegill
(
TEP)
1
Yes
40749401
00052557
Core
Supplemental
No2
Date:
December
14,
2001
Case
No:
0643
Chemical
No:
014505
MANEB
DATA
NEEDS
FOR
THE
ENVIRONMENTAL
FATE
AND
EFFECTS
DIVISION
Data
Requirement
Composition1
Use
Pattern1
Does
EPA
Have
Data
To
Satisfy
This
Need?
Bibliographic
Citation
Study
Classification
Must
Additional
Data
Needed
Under
FIFRA
3(
c)(
2)(
B)?

7
72­
1(
c)
Acute
Fish
Toxicity
Rainbow
Trout
TGAI
1,2,3,9,11
Supplemental
40706001
Supplemental
Yes3
72­
1(
d)
Acute
Fish
Toxicity
Rainbow
Trout
(
TEP)
1
Supplemental
40706001
Supplemental
Yes2,3
72­
2(
a)
Acute
Aquatic
Invertebrate
TGAI
1,2,3,9,11
Yes
40749402
Core
No
72­
2(
b)
Acute
Aquatic
Invertebrate
(
TEP)
1
Yes
40749402
Core
No2
850.1735
Whole
Sediment
Acute
Toxicity
Freshwater
Invertebrates)
TGAI
1,2,3,9,11
No
Not
applicable
Not
applicable
Yes
72­
3(
a)
Acute
Est/
Mar
Toxicity
Fish
TGAI
1,2,3,11
Yes
40943101
Core
No
72­
3(
b)
Acute
Est/
Mar
Toxicity
Mollusk
TGAI
1,2,3,11
Yes
41000001
Core
No
72­
3(
c)
Acute
Est/
Mar
Toxicity
Shrimp
TGAI
1,2,3,11
Supplemental
41000002
Supplemental
Yes4
850.1740
Whole
Sediment
Acute
Toxicity
Invertebrates,
Est/
Mar
TGAI
1,2,3,11
No
Not
applicable
Not
applicable
Yes
72­
3(
d)
Acute
Est/
Mar
Toxicity
Fish
(
TEP)
1
Yes
40943101
Core
No2
72­
3(
e)
Acute
Est/
Mar
Toxicity
Mollusk
(
TEP)
1
Yes
41000001
Core
No2
72­
3(
f)
Acute
Est/
Mar
Toxicity
Shrimp
(
TEP)
1
Supplemental
41000002
Supplemental
Yes2,4
72­
4(
a)
Early
Life
Stage
Fish
(
Freshwater)
TGAI
1,2,3,11
Yes
41346301
Core
No
72­
4(
a)
Early
Life
Stage
Fish
(
Estuarine)
TGAI
1,2,3,11
No
Not
applicable
Not
applicable
Yes
72­
4(
b)
Life
Cycle
Invertebrate
(
Freshwater)
TGAI
1,2,3,11
No
Not
applicable
Not
applicable
Yes
72­
4(
b)
Life
Cycle
Aquatic
Invertebrate
(
Estuarine)
TGAI
1,2,3,11
No
Not
applicable
Not
applicable
Yes
72­
5
Life
Cycle
Fish
TGAI
1,2,3,11
No
Not
applicable
Not
applicable
Yes
freshwater
Reserved
Date:
December
14,
2001
Case
No:
0643
Chemical
No:
014505
MANEB
DATA
NEEDS
FOR
THE
ENVIRONMENTAL
FATE
AND
EFFECTS
DIVISION
Data
Requirement
Composition1
Use
Pattern1
Does
EPA
Have
Data
To
Satisfy
This
Need?
Bibliographic
Citation
Study
Classification
Must
Additional
Data
Needed
Under
FIFRA
3(
c)(
2)(
B)?

8
72­
6
Aquatic
Organism
Accumulation
TGAI
72­
7(
1)
Simulated
Aquatic
Field
Study
1,2,3,9,11
No
not
applicable
not
applicable
No
72­
7(
b)
Actual
Aquatic
Field
Study
1,2,3,9,11
No
not
applicable
not
applicable
No
§
158.540
PLANT
PROTECTION
122­
1(
a)
Seed
Germ./
Seedling
Emerg.­
Tier
I
(
TEP)
1,2,3,11
No
not
applicable
not
applicable
Recommended
122­
1(
b)
Vegetative
Vigor­
Tier
I
(
TEP)
1,2,3,11
No
not
applicable
not
applicable
Recommended
122­
2
Aquatic
Plant
Growth­
Tier
I
(
TEP)
1,2,3,11
No
not
applicable
Not
applicable
Yes6
123­
1(
a)
Seed
Germ./
Seedling
Emerg.­
Tier
II
(
TEP)
1,2,3,11
No
not
applicable
not
applicable
Reserved
123­
1(
b)
Vegetative
Vigor­
Tier
II
(
TEP)
1,2,3,11
No
not
applicable
not
applicable
Reserved
123­
2
Aquatic
Plant
Growth­
Tier
II
(
TEP)
1,2,3,11
Partial
40943501
Core
Yes5
124­
1
Terrestrial
Field
Study
1,2,3,9,11
No
not
applicable
not
applicable
No
124­
2
Aquatic
Field
Study
1,2,3,9,11
No
not
applicable
not
applicable
No
§
158.490
NONTARGET
INSECT
TESTING
141­
1
Honey
Bee
Acute
Contact
not
reported
1,2,3,11
Yes
00036935
Core
No
141­
2
Honey
Bee
Residue
on
Foliage
(
TEP)
1,2,3,11
No
not
applicable
not
applicable
No
141­
5
Fueld
Test
for
Pollinators
(
TEP)
1,2,3,11
No
not
applicable
not
applicable
No
FOOTNOTES:

1.
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
Fod;
14=
Indoor
Medicinal;
15=
Indoor
Residential.
TGAI=
Technical
grade
of
the
active
ingredient;
PAIRA=
Pure
active
ingredient,
radiolabeled;
TEP=
Typical
end­
use
product
2.
TEP
testing
was
required
to
support
the
cranberry
use
(
1988
Maneb
Registration
Standard).
The
registrant
requested
that
testing
of
the
80%
WP
formulation
satisfy
both
TEP
and
TGAI
testing
requirements
because
1)
the
TGAI
was
only
87%
pure
and
not
soluble
in
water;
(
2)
the
80
WP
formulated
product
was
80%
pure
and
suspendable
in
water.
EFED
agreed
to
allow
testing
with
the
80%
WP
to
satisfy
both
TEP
and
TGAI
tsting
9
requirements.

3.
Study
was
classified
supplemental
because
of
high
variability
in
measured
test
concentrations,
weights
of
fish
not
given;
O
2.
less
than
recommended;
study
should
have
been
conducted
as
a
flow­
through.
Study
must
be
repeated.

4.
Study
was
classified
supplemental
because
of
high
variability
in
measured
concentrations;
also
analytical
procedures
were
not
able
to
detect
concentrations
below
5
ppb.
Study
must
be
repeated.

5.
Suplemental
study.
Results
were
based
on
nominal
which
averaged
15%
of
nominal
at
120
hours.
Five
species
need
to
be
tested.

6.
Tier
I
or
Tier
II
aquatic
plant
growth
testing
needs
to
be
submitted
for
duckweed
(
Lemna
gibba),
marine
diatom
(
Skeletonema
costatum),
bluegreen
algae
(
Anabaena
flos­
aquae),
and
a
freshwater
diatom
for
maneb.

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

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

This
pesticide
is
toxic
to
aquatic
organisms.

Label
statements
for
spray
drift
management
AVOIDING
SPRAY
DRIFT
AT
THE
APPLICATION
SITE
IS
THE
RESPONSIBILITY
OF
THE
APPLICATOR.
The
interaction
of
many
equipment­
and­
weather­
related
factors
determine
the
potential
for
spray
drift.
The
applicator
is
responsible
for
considering
all
these
factors
when
making
decisions.
Where
states
have
more
stringent
regulations,
they
should
be
observed.
UNITED
STATES
ENVIRONMENTAL
PROTECTION
AGENCY
WASHINGTON,
D.
C.
20460
OFFICE
OF
PREVENTION,
PESTICIDES,
AND
TOXIC
SUBSTANCES
Environmental
Fate
and
Ecological
Risk
Assessment
for
the
Reregistration
of
Maneb
[[
1,2­
Ethanediylbis
[
carbamodithioato]]­(
2­)]
manganese
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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.
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.
1
II.
Introduction
.
.
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.
.
4
a.
Use
Characterization
.
.
.
.
.
.
.
.
.
.
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.
.
.
.
.
.
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.
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.
.
.
4
b.
Approach
to
Risk
Assessment
.
.
.
.
.
.
.
.
.
.
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.
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.
6
III.
Integrated
Environmental
Risk
Characterization
.
.
.
.
.
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.
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.
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.
.
.
.
.
.
12
a.
Overview
of
Environmental
Risk
.
.
.
.
.
.
.
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.
.
.
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.
.
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.
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.
.
.
12
b.
Key
Issues
of
Uncertainty
.
.
.
.
.
.
.
.
.
.
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.
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.
.
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.
.
.
.
.
.
.
.
13
i.
Environmental
Fate
.
.
.
.
.
.
.
.
.
.
.
.
.
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.
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.
.
.
.
.
.
.
.
13
ii.
Ecological
Effects
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
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.
.
.
.
.
.
.
14
c.
Endangered
Species
Conclusions
.
.
.
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.
.
.
.
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.
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.
.
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.
.
.
17
d.
Endocrine
Disruption
Concerns
.
.
.
.
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.
.
.
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.
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.
.
.
.
.
.
.
18
IV.
Environmental
Fate
Assessment
.
.
.
.
.
.
.
.
.
.
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.
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.
.
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.
.
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.
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.
.
.
.
.
.
.
.
19
a.
Chemical
Identity
and
Physicochemical
Properties
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
19
b.
Fate
Processes
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
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.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
20
i.
Aqueous
Solutions
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
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.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
21
ii.
Soil
.
.
.
.
.
.
.
.
.
.
.
.
.
.
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.
.
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.
.
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.
.
.
.
.
.
.
22
iii.
Sediment/
Water
Systems
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
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.
.
.
.
.
.
.
.
23
iv.
Bound
Species,
CS
2
­
data
and
Half­
life
Determination
for
EBDCs
.
.
.
.
.
.
.
.
23
c.
Mobility
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
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.
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.
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.
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.
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.
.
.
.
.
.
.
.
26
d.
Field
Dissipation
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
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.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
26
e.
Bio­
accumulation
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
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.
.
.
.
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.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
27
V.
Water
Resource
Assessment
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
28
a.
Surface
Water
Monitoring
and
Modeling
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
28
b.
Ground
Water
Monitoring
and
Modeling
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
29
c.
Drinking
Water
Assessment
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
29
VI.
Aquatic
Exposure
and
Risk
Assessment
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
30
a.
Hazard
Summary
(
Acute/
Chronic)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
30
b.
Exposure
and
Risk
Quotients
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
32
c.
Aquatic
Risk
Assessment
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
34
i.
Incidents
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
35
ii.
Endocrine
Disruptors
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
36
iii
Endangered
Species
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
36
VII.
Terrestrial
Exposure
and
Risk
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
37
a.
Hazards
Summary
(
Acute/
Chronic)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
37
iii
b.
Exposure
Summary
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
38
c.
Risk
Quotients
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
38
d.
Terrestrial
Risk
Assessment
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
43
i.
Incidents
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
50
ii.
Endocrine
Disruptors
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
50
iii.
Endangered
Species
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
50
APPENDIX
I:
Notes
on
Fate
Studies
and
Modeling
&
Additional
Fate
Data
.
.
.
.
.
.
.
.
.
.
.
.
.
.
51
a.
Notes
on
Fate
Studies
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
51
i.
Aqueous
medium
studies
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
51
ii.
Soil/
sediment
studies
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
51
b.
Notes
on
Modeling
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
54
i.
EECs
for
Parent
maneb
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
54
ii.
Background
Information
on
the
PRZM
and
EXAMS
models
&
the
Index
Reservoir
Scenario
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
54
iii.
Background
Information
on
SCIGROW
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
55
c.
Additional
Fate
Data
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
55
APPENDIX
II:
Hoerger­
Kenaga
Estimates
&
Fate
v.
5.0
Model
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
59
a.
Hoerger­
Kenaga
Estimates
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
59
b.
Fate
v.
5.0
Model
Terrestrial
Exposure
Values
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
60
c.
Fate
v.
5.0
Model
Sample
Outputs
for
Maneb
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
61
APPENDIX
III:
Ecological
Hazards
Assessment
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
63
a.
Overview
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
63
b.
Toxicity
to
Terrestrial
Animals
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
63
i.
Birds,
Acute,
Subacute
and
Chronic
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
63
ii.
Mammals,
Acute
and
Chronic
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
66
1.
Acute
Oral
Toxicity
Testing
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
66
2.
Acute
Dermal
and
Inhalation
Toxicity
Testing
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
66
3.
Mammalian
Feeding,
Reproductive
and
Developmental
Toxicity
Testing
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
67
iii.
Insect
Acute
Contact
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
68
iv.
Insect
Residual
Contact
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
69
v.
Terrestrial
Field
Testing
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
69
c.
Aquatic
Organism
Toxicity
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
69
i.
Toxicity
to
Freshwater
Animals
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
69
1.
Freshwater
Fish,
Acute
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
69
2.
Freshwater
Fish,
Chronic
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
70
3.
Freshwater
Invertebrates,
Acute
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
71
4.
Freshwater
Invertebrate,
Chronic
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
72
5.
Freshwater
Field
Studies
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
72
ii.
Toxicity
to
Estuarine
and
Marine
Animals
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
72
iv
1.
Estuarine
and
Marine
Fish,
Acute
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
72
2.
Estuarine
and
Marine
Fish,
Chronic
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
73
3.
Estuarine
and
Marine
Invertebrates,
Acute
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
73
4.
Estuarine
and
Marine
Invertebrate,
Chronic
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
74
5.
Estuarine
and
Marine
Field
Studies
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
74
iii.
Toxicity
to
Plants
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
74
1.
Terrestrial
Plants
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
74
2.
Terrestrial
Plant
Field
Studies
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
75
3.
Aquatic
Plants
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
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75
4.
Aquatic
Plant
Field
Studies
.
.
.
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.
76
APPENDIX
IV:
Environmental
Exposure
Assessment
.
.
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.
77
a.
Overview
of
Risk
Quotients
(
RQs)
.
.
.
.
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.
77
b.
Exposure
and
Risk
to
Terrestrial
Animals
.
.
.
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.
79
i.
Birds
.
.
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79
ii.
Mammals
.
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.
84
iii.
Insects
.
.
.
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.
89
c.
Aquatic
Organisms
.
.
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.
89
i.
Overview
.
.
.
.
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89
ii.
Freshwater
Fish
.
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90
iii.
Freshwater
Invertebrates
.
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.
91
iv.
Estuarine/
Marine
Fish
.
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.
92
v.
Estuarine/
Marine
Invertebrates
.
.
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.
93
d.
Exposure
and
Risk
to
Non­
target
Plants:
Aquatic
Plants
.
.
.
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.
.
.
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.
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.
94
e.
Endangered
Species
.
.
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.
95
f.
Ecological
Incidents
.
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95
APPENDIX
V:
US
EPA
Ecological
Incident
Information
System
.
.
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.
97
APPENDIX
VI:
EBDC
Aquatic
Studies
.
.
.
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.
99
APPENDIX
VII:
Maneb
Revised
Risk
Quotients
for
Almonds
&
Turf
Uses
.
.
.
.
.
.
.
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.
.
.
.
.
102
REFERENCES
.
.
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104
1
I.
Executive
Summary
There
are
potential
chronic
risks
to
birds
and
mammals,
acute
risks
to
freshwater
fish
and
estuarine/
marine
animals,
and
acute
risks
to
aquatic
nonvascular
plants.
These
potential
risks
occur
for
all
or
some
of
maneb's
uses.
Because
EFED
lacks
data,
EFED
is
uncertain
about
maneb's
potential
acute
risk
to
terrestrial
plants,
chronic
risks
to
freshwater
invertebrates,
chronic
risks
to
estuarine/
marine
animals
and
acute
risks
to
aquatic
vascular
plants.

Based
on
available
data,
EFED
expects
all
maneb's
uses
present
potential
chronic
risks
to
birds
and
mammals.
EFED
relied
on
a
referenced
total
foliar
dissipation
half­
life
value
of
3.2
days
to
evaluate
exposure
to
terrestrial
organisms
(
Willis
and
McDowell,
1987).
Avian
chronic
LOCs
are
exceeded
for
all
use
patterns.
RQs
range
from
a
high
of
265
from
the
turf
use
to
a
low
of
0.4
from
maneb's
uses
on
collards,
turnips,
and
mustard
(
Georgia
and
Tennessee,
only).
Mammalian
chronic
LOCs
are
exceeded
for
all
uses
patterns.
RQs
range
from
a
high
of
71
from
the
turf
use
to
a
low
of
0.1
from
maneb's
uses
on
collards,
turnips,
and
mustard
(
Georgia
and
Tennessee,
only).
EFED
used
a
mallard
duck
reproductive
study
to
calculate
the
RQs
for
this
assessment.
EFED
based
birds
chronic
reproductive
effects
on
decreases
in
the
number
of
hatchlings
as
percentages
of
eggs
laid,
eggs
set,
and
live
3­
week
old
embryos,
and
a
decrease
in
the
number
of
14­
day
old
survivors
as
a
percentage
of
eggs..
EFED
based
mammal
reproductive
effects
on
a
2­
generation
study
in
rats.
These
mammal
effects
were
male
parental
toxicity
resulting
in
significant
increase
in
lung
weight
(
both
generations)
and
liver
weight
(
F1
generation)
with
lesions
noted
on
these
organs
in
the
F1
generation.
EFED
does
not
calculate
risk
quotients
to
conduct
risk
assessments
on
terrestrial
invertebrates.
Based
on
the
lack
of
acute
maneb
toxicity
to
honeybees,
EFED
expects
a
low
acute
risk
to
nontarget
terrestrial
insects.
Due
to
lack
of
data
EFED
did
not
assess
risks
to
terrestrial
plants
or
fully
assess
risks
to
aquatic
plants.
In
the
aquatic
environment,
EFED
concludes
maneb
will
present
a
potential
acute
risk
to
freshwater/
estuarine/
marine
fish
and
invertebrates
as
well
as
nonvascular
aquatic
plants.
EFED
selected
representative
maneb
use
patterns
at
maximum
application
rates
and
minimum
intervals
between
applications
for
aquatic
modeling.
Maneb
is
used
on
more
than
20
different
crop
groupings.
The
representative
sites
selected
for
aquatic
modeling
were
apples,
peppers,
potatoes
(
Maine,
only)
and
tomatoes.
The
acute
RQs
exceeding
freshwater
fish
acute,
acute
restricted
use,
and
acute
endangered
species
LOCs
for
all
maneb's
modeled
uses
range
from
1.13
to
4.71.
The
acute
freshwater
invertebrates'
RQs
exceeding
acute
restricted
use,
and
acute
endangered
species
LOCs
for
all
maneb's
modeled
uses
range
from
0.40
to
1.65.
The
acute
estuarine/
marine
fish
RQs
exceed
acute
restricted
use,
and
acute
endangered
species
LOCs
for
all
maneb's
modeled
uses
with
RQs
ranging
from
0.47
to
1.1.
Estuarine/
marine
invertebrate
acute
RQs
exceed
acute,
acute
restricted
use,
and
acute
endangered
LOCs
for
all
maneb's
modeled
uses
with
RQs
ranging
from
15.87
to
65.97.
Based
on
data
for
one
surrogate
species,
maneb's
modeled
use
patterns
exceed
acute
risk
LOCs
for
nonvascular
aquatic
plants
with
acute
RQs
ranging
from
3.55
to
14.77.
EFED
did
not
assess
chronic
risks
to
freshwater
invertebrates,
estuarine/
marine
fish,
or
estuarine/
marine
invertebrates
due
to
lack
of
data.

Maneb
is
a
non­
systematic
fungicide
applied
to
foliage
and
as
a
seed
treatment
for
the
control
of
fungal
diseases
on
numerous
crops,
ornamental
plantings,
and
turf.
The
maximum
application
rates
for
the
major
crops
are16.0,
16.8,
9.6,
and
14.4
lbs
a.
i/
acre/
crop
cycle
for
potatoes,
tomatoes,
lettuce,
2
In
this
document
three
important
abbreviations
are
used:
Parent
maneb,
maneb
complex
and
Bound
species.
Parent
maneb
is
the
polymeric
parent
maneb
present
in
the
active
ingredient.
Maneb
Complex
is
a
suite
of
multi
species
residues
resulting
from
degradation
of
the
polymeric
parent
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).

2
and
peppers;
and
18.0
and
25.6
lbs
a.
i/
acre/
year
for
sweet
corn
and
almonds,
respectively.
Maneb
is
applied
as
a
broadcast
treatment
using
both
air
and
ground
equipment
and
has
numerous
seed
treatment
uses.

Maneb
is
a
polymer
or
a
highly
coordinated
salt
complex,
in
which
the
EBDC
(
ethylene
bis
dithio
carbamate)
ligand
present
in
coordination
with
Mn+
2.
Foliar
application
of
maneb
cause
it
to
reach
plant/
soil
surfaces
directly
and
air/
water
bodies
by
drift.
In
the
air,
maneb
will
eventually
be
deposited
onto
soil/
plant/
water
bodies
with
minimal
change.
On
plant
surfaces,
it
is
affected
by
physical
washoff
and
abiotic
hydrolytic
decomposition
given
time
and
water
availability.
Fate
of
maneb
reaching
the
soil
and
water/
sediment
systems
is
mainly
controlled
by
hydrolytic
decomposition
and
soil/
sediment
adsorption.

Parent
maneb2
(
complete
polymeric
chains)
is
non­
persistent
as
it
is
expected
to
decompose
rapidly
(
reach
<
10%
of
the
applied
within
one
day)
by
hydrolytic
reactions
in
the
main
compartments
of
the
natural
environment.
Initial
hydrolytic
decomposition
of
maneb
appears
to
be
a
complex
process
and
may
involve
its
breakdown
into
variable/
low
molecular
weight
polymeric
chains
(
i.
e
polymer
fragments),
monomeric
species,
EBDC
ligand
in
association
with
metal
ions,
and
degradates.
The
final
product
of
hydrolytic
decomposition
of
parent
maneb
in
water/
soil
pore
water
is
a
multi
species
residue
hereinafter
is
refer
to
as
the
"
maneb
complex".
Parent
maneb
is
not
expected
to
partition
into
the
air
from
soil
and
water
surfaces
due
to
low
vapor
pressure
and
low
Henry's
Law
constant.
Low
K
ow
values
are
reported
for
maneb,
therefore
the
chemical
will
not
be
significantly
bioconcentrated
by
aquatic
organisms
such
as
fish.

In
contrast,
Maneb
Complex
consists
of
transient
species
and
degradates
including
the
degradate
of
concern,
ETU
and
its
degradates.
In
aqueous
media,
transient
species
are
short­
lived
while
ETU
is
persistent;
unless
it
is
subjected
to
rapid
degradation
by
microbial
action
and/
or
indirect
photolysis.
In
soils/
sediments,
a
significant
portion
of
the
complex
partitions
into
the
soil/
sediment
particles
(
reached
70
to
90%
of
the
applied
parent
within
one
week).
In
these
systems,
species
identified
in
the
liquid/
extractable
phase
were
similar
in
identity
(
differ
in
concentration)
to
those
identified
in
aqueous
media.
Species
bound
to
soil/
sediment
were
poorly
characterized
and
claimed,
by
the
registrant,
to
be
dominated
by
ethylene
diamine
(
EDA).
In
the
absence
of
experimental
proof
of
EDA
or
complete
characterization
of
these
bound
species,
EFED
is
concerned
about
the
bound
species
as
it
is
persistent
and
could
contain
precursors
for
ETU.

Conversion
of
parent
maneb
into
its
complex
by
hydrolytic
decomposition
appears
to
be
eminent
and
3
rapid
even
at
concentrations
higher
than
those
expected
to
reach
the
environment
by
application.
Therefore,
parent
applied
is
expected
to
be
found
as
residue,
the
maneb
complex,
in
most
natural
environments.
Maneb
complex
species
in
association
with
soil/
sediment,
appear
to
bio­
degrade
at
a
very
slow
rate
producing
maneb
degradates
including
ETU.
Residue
species
left
in
the
liquid
phase
may
continue
to
be
affected
by
hydrolytic
decomposition
along
with
microbial
activity
(
if
present)
producing
degradates
including
ETU.

Submitted
fate
data
are
adequate
to
characterize
the
environmental
fate
and
transport
of
the
"
multi
species
residue"
of
maneb
as
a
whole.
Based
on
submitted
fate
data,
most
of
the
constituents
of
this
complex
are
immobile
and
highly
persistent
in
the
environment,
with
aerobic
soil
metabolism
being
the
major
route
of
its
slow
dissipation.
As
maneb
and
its
complex
dissipate
in
aquatic
and
soil/
terrestrial
environments,
degradation
products
are
produced
including
ETU.

EFED
relied
on
a
referenced
total
foliar
dissipation
half­
life
value
of
3.2
days
(
Willis
and
McDowell,
1987)
to
evaluate
exposure
to
terrestrial
organisms.
The
stressor
in
this
case
is
parent
maneb
although
hydrolytic
reactions
on
foliage
may
result
in
dominance
of
maneb
complex
over
the
parent.
Terrestrial
exposure
was
quantified
as
Estimated
Environmental
Concentrations
(
EECs)
by
modeling
for
the
maximum
application
rates.
For
the
aquatic
environment,
the
main
stressor
is
the
maneb
complex
and
its
EECs
were
estimated
using
tier
2
PRZM/
EXAMS
modeling
for
the
various
crop
scenarios.
Drinking
water
assessment
was
performed
only
for
ETU
(
refer
to
the
accompanied
ETU
document);
the
degradate
of
concern
present
in
the
complex.

EFED
is
uncertain
about
maneb's
risk
to
non­
target
terrestrial
plants.
EFED
needs
testing
performed
at
maneb's
maximum
rate
of
application
in
the
environment
to
evaluate
this
risk.
EFED
expects
the
potential
chronic
risks
to
birds
and
mammals
from
maneb's
uses.
RQs
exceed
chronic
LOCs
for
all
maneb's
uses
for
both
birds
and
mammals.
EFED
expects
maneb's
uses
to
present
a
low
acute
risk
to
birds,
mammals,
and
nontarget
insects
because
maneb
is
practically
nontoxic
to
these
organisms
and
historically
there
has
been
no
incident
data
documenting
adverse
effects
to
these
organisms.

In
the
aquatic
environment,
maneb
complex
presents
a
potential
acute
risk
to
freshwater
fish,
freshwater
invertebrates,
estuarine/
marine
fish,
estuarine/
marine
invertebrate,
and
nonvascular
aquatic
plants
with
LOCs
exceeded.
The
chronic
maneb
complex
risk
to
freshwater
fish
is
low
with
no
LOCs
exceeded.
The
data
filed
and
reviewed
to
characterize
maneb
complexes'
potential
acute
risk
to
aquatic
animals
and
aquatic
nonvascular
plants
is
satisfactory.
EFED
has
no
data
to
evaluate
maneb
complexes'
chronic
risks
to
freshwater
invertebrates
or
estuarine/
marine
organisms
and
is
seeking
data
to
evaluate
these
risks.
EFED
has
not
received
studies
to
evaluate
the
risk
of
the
maneb
complex
to
vascular
aquatic
plants
and
needs
studies
presented
to
evaluate
this
risk.
EFED
needs
testing
performed
on
more
aquatic
nonvascular
plant
taxa
to
evaluate
fully
the
risk
to
nonvascular
aquatic
plants.
4
II.
Introduction
Maneb
is
a
broad
spectrum
fungicide
belonging
to
a
chemical
class
of
polymeric
dithiocarbamate
and
a
group
classified
as
ethylene
bisdithiocarbamate
(
EBDC)
fungicides.
Maneb
is
classified
as
a
nonsystemic
contact
fungicide
with
preventive
activity.
Maneb
is
marketed
by
several
companies
under
varied
names
and
formulations.
Formulation
types
include
dusts,
water
dispersible
granules
(
dry
flowables),
emulsifiable
concentrates,
flowable
concentrates,
wettable
powders,
and
liquid­
ready
to
use.

a.
Use
Characterization
Maneb
is
applied
to
foliage
and
as
seed
protectant
for
the
control
of
fungal
diseases
on
numerous
crops,
ornamental
plantings
(
trees,
herbaceous
plants,
non
flowering
plants,
woody
shrubs
and
vines),
and
turf
(
commercial/
industrial,
golf
course,
sod
farm,
recreational,
and
residential).
It
is
applied
as
a
broadcast
treatment
using
both
air
and
ground
equipment
and
has
numerous
seed
treatment
uses.
There
are
36
products
registered
containing
maneb:
2
manufacturing­
use
product,
33
end­
use
products
and
1
special
local
need
(
24­
c)
registration
(
OPP
REFs
data
August,
2000).
There
are
both
multiple
and
single
active
ingredient
products.
A
synopsis
of
the
use
pattern
for
this
chemical
is
provided
below
in
Table
II­
1.

Table
II­
1.
Maneb
use
patterns.

Crop
Maximum
Application
Rate
Number
of
Applications
Minimum
Application
Interval
(
days)
Per
Treatment
In
Total
Almonds
6.4
lbs
a.
i/
acre
25.6
lbs
a.
i/
acre/
crop
cycle
4
7
Apples
4.8
lbs
a.
i/
acre
19.2
lbs
a.
i/
acre/
year
4
7
Bananas
2.4
lbs
a.
i/
acre
24
lbs
a.
i/
acre/
crop
cycle
10
14
Barley,
Rice,
Rye,
Sorghum,
Soybean
&
Wheat
0.2
lbs
a.
i/
100
lbs
seed
(
Seed
treatment)
1
NA
Beans
(
dried)
1.6
lbs
a.
i/
acre
9.6
lbs
a.
i/
acre/
crop
cycle
6
5
Broccoli,
Brussel
Sprouts,
Cabbage
a
1.6
lbs
a.
i/
acre
9.6
lbs
a.
i/
acre/
crop
cycle
6
7
Collards
&
Turnip
(
GA
&
TN
only)
1.2
lbs
a.
i/
acre
3.6
lbs
a.
i/
acre/
crop
cycle
3
14
Corn
(
field),
Cotton
&
Oats
0.3
lbs
a.
i/
100
lbs
seed
(
Seed
treatment)
1
NA
Corn
(
pop
&
sweet),
East
of
the
Mississippi
River
b
1.2
lbs
a.
i/
acre
18.0
lbs
a.
i/
acre/
year
15
3
Corn
(
pop
&
sweet),
West
of
the
Mississippi
River
c
1.2
lbs
a.
i/
acre
6.0
lbs
a.
i/
acre/
year
5
3
Cranberry
4.8
lbs
a.
i/
acre
14.4
lbs
a.
i/
acre/
year
3
7
Cucumber,
Melons,
Pumpkin
&
Squash
1.6
lbs
a.
i/
acre
12.8
lbs
a.
i/
acre/
crop
cycle
8
7
Eggplant
&
Sugar
Beets
1.6
lbs
a.
i/
acre
11.2
lbs
a.
i/
acre/
crop
cycle
7
7
Fig
2.4
lbs
a.
i/
acre
2.4
lbs
a.
i/
acre/
year
1
NA
Flax
0.4
lbs
a.
i/
100
lbs
seed
(
Seed
treatment)
1
NA
Grapes
(
East
of
the
Rocky
Mountains)
3.2
lbs
a.
i/
acre
19.2
lbs
a.
i/
acre/
crop
cycle
6
7
Grapes
(
West
of
the
Rocky
Mountains)
2.0
lbs
a.
i/
acre
6.0
lbs
a.
i/
acre/
crop
cycle
3
7
Crop
Maximum
Application
Rate
Number
of
Applications
Minimum
Application
Interval
(
days)
Per
Treatment
In
Total
5
Kale
1.6
lbs
a.
i/
acre
3.2
lbs
a.
i/
cutting
2/
cutting
7
Mustard
(
GA
and
TN
only)
1.2
lbs
a.
i/
acre
2.4
lbs
a.
i/
acre/
crop
cycle
2
14
Onion
&
Garlic
2.4
lbs
a.
i/
acre
24.0
lbs
a.
i/
acre/
crop
cycle
10
7
Onion
(
green)
&
Tomatoes
(
East
of
the
Mississippi
R)
2.4
lbs
a.
i/
acre
16.8
lbs
a.
i/
acre/
crop
cycle
7
7
Papaya
2.0
lbs
a.
i./
acre
28.0
lbs
a.
i/
acre/
crop
cycle
14
14
Peanuts
0.8
lbs
a.
i/
100
lbs
seed
(
Seed
treatment)
1
NA
Pepper
(
East
of
the
Mississippi
River)
2.4
lbs
a.
i/
acre
14.4
lbs
a.
i/
acre/
crop
cycle
6
7
Pepper
(
West
of
the
Mississippi
River)
1.6
lbs
a.
i/
acre
9.6
lbs
a.
i/
acre/
crop
cycle
6
7
Potatoes
(
Maine
only)
1.6
lbs
a.
i/
acre
16.0
lbs
a.
i/
acre/
crop
cycle
10
5
Potatoes
1.6
lbs
a.
i/
acre
11.2
lbs
a.
i/
acre/
crop
cycle
7
5
Safflower
0.1
lbs
a.
i/
100
lbs
seed
(
Seed
treatment)
1
NA
Sunflower
0.4
lbs
a.
i/
100
lbs
seed
(
Seed
treatment)
1
NA
Tomatoes
(
West
of
the
Mississippi
River)
1.6
lbs
a.
i/
acre
6.4
lbs
a.
i/
acre/
crop
cycle
4
7
Ornamentals
d
1.2
lbs
a.
i/
100
gal
Not
specified
7
Turf
e
17.4
lbs
a.
i/
acre
Not
specified
7
NA=
Not
applicable;
a=
including
Cauliflower,
Endive,
Kohlrabi
&
Lettuce
b=
including
AR
&
LA;
c=
excluding
AR
&
LA;
d=
Trees,
Herbaceous
plants,
Nonflowering
plants
&
Woody
shrubs
and
Vines;
e=
Residential,
Commercial/
Industrial,
Gulf
Course,
Sod
farm
&
Recreational.

Figure
II­
1,
below,
shows
the
general
use
areas
for
maneb
across
the
US
(
USGS
data
1990
­
1993
and
1995).

EFED
utilized
OPP's
Label
Use
Information
System
(
LUIS)
for
maneb
labels
registered
as
of
10/
31/
2001,
OPP's
Reference
Files
System
(
REFS),
the
Maneb
Use
Closure
Memo,
and
spot
6
checking
of
currently
registered
maneb
labels
to
determine
what
maneb
use
patterns
posed
the
most
significant
risk
to
the
environment.
EPA
use
data
(
BEAD's
Quantitative
Usage
Analysis
for
Maneb
dated
November
1,
2002)
for
the
period
1992
through
2001
shows
that
41%
of
the
lettuce,
34%
of
the
bell
peppers,
34%
of
the
sweet
peppers,
39%
of
the
pumpkins
and
25%
of
the
cabbage
grown
in
the
US
are
treated
with
maneb.

b.
Approach
to
Risk
Assessment
Maneb
is
a
polymer
or
a
highly
coordinated
salt
complex,
with
unique
properties.
It
is
expected
to
be
introduced
to
the
environment
at
application
rates
resulting
in
soil
concentration
levels
of
<
10
ppm
and
much
lower
concentrations
in
water
bodies.
When
parent
maneb
is
introduced
into
water
bodies,
by
drift,
at
the
expected
low
concentrations,
it
decomposes
rapidly
into
the
maneb
complex
including
the
degradate
of
concern
ETU.
In
contrast,
when
parent
maneb
is
introduced
into
soil
or
water/
sediment
systems,
similar
rapid
decomposition
occurs
with
most
of
the
constituents
of
maneb
complex
partitioning
into
soil/
sediment
particles.
Parent
maneb
terrestrial
EECs
were
calculated
using
a
spread
sheet
based
on
the
slope
of
the
1st
order
hydrolysis
half­
lives.
However,
Parameters
determined
from
environmental
fate
studies
and
information
on
physicochemical
properties
were
used
in
estimating
aquatic
EECs
of
the
resultant
maneb
complex.
The
major
degradate
of
concern,
ETU,
was
considered
in
the
fate
and
exposure
assessment
in
a
separate
RED
document
with
consideration
to
all
EBDCs
(
metiram,
mancozeb
and
maneb).
Normally,
EFED
would
evaluate
the
risk(
s)
posed
by
a
chemical's
degradate(
s)
of
concern
within
the
risk
assessment
document
for
the
chemical.
However,
since
ethylene
thiourea
(
ETU)
is
a
common
degradate
for
all
the
EBDCs
(
mancozeb,
maneb
and
metiram)
it
was
decided
to
address
the
environmental
risk
posed
by
ETU
in
a
separate
document
and
avoid
repetitive
references
in
the
risk
assessments
for
each
of
the
EBDC
chemicals.
This
approach
to
risk
assessment
was
necessary
because
maneb
decomposes
very
quickly,
by
hydrolytic
reactions
in
water,
into
"
multi
species
maneb
complex".
Therefore,
hydrolysis
is
the
dominant
factor
in
controlling
parent
maneb
concentration
and
calculated
hydrolysis
half­
lives
are
the
parameter
of
choice
for
determining
its
fate.
Measured
parameters
in
fate
studies
were
actually
for
maneb
complex
and
were
used
to
estimate
the
EECs
for
that
complex.

To
evaluate
the
potential
risk
to
aquatic
and
terrestrial
organisms
from
the
use
of
maneb,
risk
quotients
(
RQs)
are
calculated
from
the
ratio
of
estimated
environmental
concentrations
(
EECs)
to
ecotoxicity
values
(
see
Appendix
IV).
EECs
are
based
on
the
maximum
application
rate
of
maneb
for
the
use
patterns
currently
registered.
These
RQs
are
then
compared
to
the
levels
of
concern
(
LOC)
(
see
Appendix
IV
for
these
values)
criteria
used
by
EFED
for
determining
potential
risk
to
non­
target
organisms
and
the
subsequent
need
for
possible
regulatory
action.

When
possible,
sites
having
similar
use
patterns
(
application
rates,
timings,
methods,
number
of
applications,
and
intervals
between
applications)
were
grouped
to
evaluate
the
risks.
Although
maneb
has
numerous
seed
treatment
uses
(
see
Table
1,
above)
the
RQs
from
these
seed
treatment
uses
were
not
calculated
in
this
RED.
Numerous
seed
treatment
uses
of
mancozeb
were
evaluated
in
the
mancozeb
RED
and
no
LOCs
were
exceeded.
The
avian
acute
LD
50
of
maneb
(
Bobwhite
quail
LD50
>
2,150
mg/
kg)
is
practically
nontoxic
to
birds
and
was
greater
than
the
avian
acute
LD50
for
7
mancozeb
(
English
sparrow
LD50
.1,500
mg/
kg).
Since
maneb
is
less
toxic
to
birds
on
an
acute
basis
than
mancozeb
and
the
exposure
(
rates
of
application)
from
these
seed
treatment
uses
are
similar
for
maneb
and
mancozeb,
EFED
expects
the
acute
risks
to
birds
from
eating
maneb
treated
seeds
is
low.
Since
maneb
is
practically
nontoxic
to
birds
on
an
acute
dietary
basis
(
mallard
duck
LC50
>
5,000
ppm
and
bobwhite
quail
LC50
>
10,000
ppm)
the
acute
dietary
risks
to
birds
eating
food
items
exposed
to
spray
applications
of
maneb
is
also
expected
to
be
low.
Because
of
this
EFED
did
not
calculate
RQs
for
acute
dietary
exposure.
It
should
also
be
noted
that
maneb
assessments
for
chronic
risk
to
plants,
acute/
chronic
risks
to
non­
target
insects,
or
chronic
risk
from
granular/
bait
formulations
to
birds
and
mammals
have
not
been
evaluated
because
scenarios
for
evaluating
these
risks
have
not
been
developed.

EFED
evaluated
terrestrial
exposure
using
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
initial
concentrations
on
plant
surfaces
based
on
Kenaga
predicted
maximum
and
mean
residues
as
modified
by
Fletcher
et
al.
(
1994)
and
assumes
1st
order
dissipation.
Kenaga
estimates
and
an
explanation
of
the
model
with
sample
output
are
presented
in
Appendix
II.
EFED
used
a
3.2­
day
half­
life
as
the
total
foliar
dissipation
half­
life
for
maneb.
EFED
selected
this
half­
life
from
the
highest
value
provided
in
the
half­
life
listing
of
Willis
and
McDowell,
1987
for
maneb.
This
half­
life
value
is
based
on
total
foliar
residues
not
dislodgeable
foliar
residues
and
was
determined
in
a
study
by
Rhodes,
1977
performed
on
tomatoes.
Willis
and
McDowell,
1987
also
showed
a
maneb
total
foliar
residue
half­
life
of
2.8
days
for
snap
beans
(
Rhodes,
1977).
These
studies,
conducted
in
Florida,
received
16.5
mm
(
0.6
inch)
of
rainfall
during
the
measurement
period.
EFED
uses
the
halflife
listing
values
provided
in
Willis
and
McDowell,
1987
for
modeling
purposes
to
estimate
total
foliar
residues
half­
lives.

EFED
needs
total
foliar
dissipation
residue
or
total
foliar
residue
(
TFR)
half­
life
information
as
a
modeling
input
value
to
estimate
terrestrial
wildlife
exposure.
TFR
is
the
total
pesticide
residue
contained
both
on
the
surface
and
absorbed
into
treated
leaves.
EFED
has
no
requirements
for
submitting
such
data
now
and
relies
on
available
half­
life
data
chiefly
from
Willis
and
McDowell
(
1987).
Since
maneb
TFR
half­
life
information
was
limited
from
Willis
and
McDowell
(
1987),
EFED
reviewed
half­
life
information
from
HED.
EFED
was
initially
drawn
to
explore
HED's
information
because
TFR
half­
life
information
was
unavailable
in
Willis
and
McDowell
(
1987)
for
metiram,
mancozeb,
and
ETU.
HED
receives
dislodgeable
foliar
residue
(
DFR)
dissipation
half­
life
data
(
guideline
875.2100)
to
estimate
exposures
to
individuals
from
working
in
an
environment
that
has
been
treated
with
a
pesticide
(
also
referred
to
as
reentry
exposure).
DFR
is
the
pesticide
residue
on
treated
leaves'
surface.
For
maneb
and
mancozeb
HED
(
Dole
and
Dawson,
2003
and
2003b)
provided
the
following
(
Table
II­
2)
with
MRID
Nos.
The
Mancozeb
Task
Force
provided
the
Newsome
study
through
a
literature
submission
(
Ollinger,
2005).

Table
II­
2.
Summary
of
Maneb
DFR
and
TFR
Data
for
Crops
MRID
(
Year)
CROP
(
Location)
Application
Method
lb
ai/
Acre
*
Number
of
Applications
DFR
Half
Life
TFR
Half
Life
420449­
04(
90)
CA
Grapes
Airblast
3.2
*
3
(
30­
day
intervals)
32.8
(
day)
Not
available
Table
II­
2.
Summary
of
Maneb
DFR
and
TFR
Data
for
Crops
MRID
(
Year)
CROP
(
Location)
Application
Method
lb
ai/
Acre
*
Number
of
Applications
DFR
Half
Life
TFR
Half
Life
8
415117­
01(
88)
451946­
01(
99)
451946­
01(
99)
NY
Apples
NY
Apples
WA
Apples
Airblast
Airblast
Airblast
8.0
*
10
(
7­
day
intervals)
4.8
*
2
(
7­
day
intervals)
4.8
*
2
(
7­
day
intervals)
17.8
(
days)
7.2
(
days)
23.6
(
days)
Not
available
Not
available
Not
available
419615­
01(
90)
420449­
02(
91)
420449­
03(
91)
Newsome,
1976
Rhodes,
1977
CA
Tomatoes
FL
Site
1
Tomatoes
FL
Site
2
Tomatoes
Canada
Tomatoes
FL
Tomatoes
Ground
boom
Ground
boom
Ground
boom
Groundboom
not
available
2.4
*
3
(
10­
day
intervals)
2.4
*
9
(
7­
day
intervals)
1.9
*
9
(
7­
day
intervals)
2.4
*
7
(
7
days)
not
available
7.5
(
days)
19.1
(
days)
9.9
(
days)
Not
available
not
available
Not
available
Not
available
Not
available
7.31,2
3.23
Rhodes,
1977
FL
Snap
beans
not
available
not
available
not
available
2.83
Mancozeb
Study
With
Both
DFR
and
TFR
Data
411339­
01(
86)
411339­
01(
86)
CA
Grapes
(
Madera)
CA
Grapes
(
Fresno)
Airblast
Airblast
3.2
*
3
3.2
*
3
15.2
(
days)
9.6
(
days)
14.9
(
days)
9.3
(
days)

Note
1
­
Half­
life
values
calculated
by
EFED
from
the
data
provided
in
the
study.
Note
2
­
TFR
was
from
homogenized
samples
of
the
tomato
fruit,
only,
submitted
by
the
Mancozeb
Task
Force
(
Ollinger,
2005)
Note
3
­
Source:
Willis
and
McDowell
(
1987)

There
were
eight
mancozeb,
one
metiram
and
six
maneb
DFR
studies
presented.
Based
on
a
review
of
all
the
EBDC
DFR
studies
filed,
EFED
would
expect
a
variation
in
DFR
half­
life
values.
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
climate
effect
was
a
greater
effect
than
the
effect
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).

Most
DFR
studies
used
the
standard
dislodging
technique.
The
1986
mancozeb
study
on
grapes
at
Madera
and
Fresno,
California
(
MRID
411339­
01)
also
used
the
total
extraction
method
(
T.
Dole,
per.
com.,
9/
13/
01).
Based
on
this
mancozeb
study
EFED
expects
the
EBDC's
DFR
half­
life
would
be
comparable
to
the
EBDC's
TFR
half­
life
since
the
1986
mancozeb
study
on
grapes
at
Madera
and
Fresno,
California
showed
similar
DFR
and
TFR
half­
lives.
EFED
might
not
expect
such
a
likeness
if
the
pesticide
showed
systemic
activity
but
none
of
the
EBDCs
are
systemic.

Maneb's
DFR
half­
lives
range
from
7.2
to
32.8
days
based
on
the
studies
available
from
HED.
Willis
and
McDowell
(
1987)
shows
2
TFR
maneb
half­
life
values
for
2
crops
(
that
is,
snap
beans
and
tomatoes)
.
Given
this
limited
information
EFED
feels
it
would
be
reasonable
to
use
a
33­
day
TFR
half­
life
for
maneb
as
a
conservative
upper­
bound
estimate
in
this
screening
level
assessment.
EFED
routinely
uses
the
upper
limit
of
TFR
half­
life
values
(
that
is,
35
days)
provided
in
Willis
and
McDowell
(
1987)
to
perform
screening
level
risk
assessments.
EFED
expects
maneb's
DFR
half­
life
would
be
comparable
to
the
maneb's
TFR
half­
life
for
most
crops.
The
highest
DFR
value
shown
in
Table
II­
2
is
32.8
days.
It
is
reasonable
to
use
this
high­
end
estimate
(
that
is,
33
days)
in
this
screening
level
assessment.
It
is
reasonable
because
it
is
the
highest,
most
conservative,
half­
life
value
and
the
data
available
is
limited.
Maneb
is
used
on
more
than
20
crop
grouping
(
see
Table
II­
1)
or
more
than
40
crops.
The
maneb
DFR
studies
in
Table
II­
2
provide
half­
life
information
on
4
crops
(
that
is,
grapes,
apples,
tomatoes,
and
turf)
and
TFR
half­
life
information
on
3
crops
(
that
is,
grapes,
9
snap
beans,
and
tomatoes).

EFED
didn't
find
half­
life
values
for
metiram
and
mancozeb
in
Willis
and
McDowell,
1987.
Because
of
this,
EFED
consulted
HED
for
DFR
half­
life
information.
EFED
wanted
to
decide
if
the
high­
end
half­
life
value
(
35
days)
in
Willis
and
McDowell,
1987
was
a
reasonable
foliar
half­
life
estimate
for
metiram
and
mancozeb.
The
metiram
DFR
data
from
HED
was
limited.
One
study
(
MRID
No.
41339901,
1988)
on
California
apples
showed
a
31.4­
day
DFR
half­
life.
Given
this
limited
data,
EFED
used
a
35­
day
TFR
half­
life
value
for
metiram's
terrestrial
EEC
modeling.
The
mancozeb
DFR
and
TFR
half­
life
data
were
more
robust.
HED
provided
15
DFR
half­
life
values
for
4
crops
and
2
TFR
half­
life
values
for
1
crop.
The
high­
end
value
for
these
mancozeb
DFR
and
TFR
half­
lives
was
35.4
days
from
a
DFR
half­
life
study
done
on
California
grapes
(
MRID
No.
41836901,
1991).
As
a
result,
EFED
used
a
35­
day
TFR
half­
life
value
for
mancozeb's
terrestrial
EEC
modeling.

EFED
used
35­
day
TFR
half­
life
values
for
mancozeb's
and
metiram's
terrestrial
EEC
modeling
as
high­
end,
conservative
half­
life
values.
EFED
used
a
3.2­
day
TFR
half­
life
value
for
maneb
chiefly
because
this
value
was
listed
in
Willis
and
McDowell,
1987.
EFED
uses
Willis
and
McDowell,
1987
as
a
standard
source
of
TFR
values
for
risk
assessments.
However,
in
retrospect,
EFED
should
have
included
a
33­
day
TFR
half­
life
for
maneb's
terrestrial
EEC
modeling
as
a
conservative
upper­
bound
estimate
in
this
screening
level
assessment.
EFED
intends
to
include
these
extra
calculations
in
the
next
revision
of
this
RED.
These
new
calculations
for
terrestrial
EEC
modeling
will
also
require
revisions
to
the
RQ
calculations.
The
RQs
will
increase
because
of
these
new
calculations,
using
a
33­
day
TFR
half­
life
value,
because
the
exposure
to
wildlife
will
be
greater.
However,
maneb's
potential
chronic
risk
to
birds
and
mammals
will
remain
unchanged.
All
maneb's
uses
exceed
bird
and
mammal
chronic
LOCs
using
the
3.2
day
TFR
half­
life
value.

EFED
assumed
3
applications
of
maneb
to
ornamentals
and
turf
per
crop
cycle
since
the
labeling
did
not
show
the
number
of
applications
that
could
be
made.
If
the
number
of
applications
applied
to
ornamental
and
turf
sites
is
greater
than
3
applications
then
the
risk
to
nontarget
organisms
would
increase.
The
assumption
of
100
gallons
of
finished
spray
per
acre
treated
was
also
an
assumption
made
for
maneb
applications
to
ornamentals.
If
lower
finished
spray
rates
are
used
then
the
pounds
of
maneb
applied
per
acre
are
even
greater
than
assumed
which
would
increase
the
risk
to
nontarget
organisms.

Monitoring
data
from
field
locations
are
not
available
for
maneb.
Because
of
this,
EFED
based
maneb
aquatic
EECs
on
screening
models.
EFED
modeled
maneb's
surface
water
concentrations
using
the
Pesticide
Root
Zone
Model
version
3.1.2
beta
(
Carsel
et
al.,
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
EBDC
usage
on
turf.
Mancozeb
and
Maneb
both
include
turf
on
their
labels,
but
the
actual
usage
is
small
relative
to
other
crops.
Use
of
fungicides
is
generally
minimal
on
sod
farms
with
mancozeb
applied
to
2600
acres
(
about
4
square
miles)
or
about
0.9
percent
of
all
sod
grown
in
the
United
States.
The
average
number
of
fungicide
applications
is
1.9
nationally
with
a
maximum
use
rate
of
about
15
lbs
a.
i/
acre
applied
in
situations
when
either
severe
pest
pressure
conditions
exist,
or
curative
applications
are
utilized.
Typical
application
rates
are
10
lower.
Additionally,
the
non­
systematic
EBDCs
serve
as
a
rotational
partner
for
the
other
systemic
fungicides
used
in
the
pest
management
program.
Therefore,
risk
associated
with
turf
use
pattern
was
not
assessed
for
aquatic
environments
at
this
screening
level
risk
assessment.

Conclusions
based
on
this
approach
to
the
screening
level
risk
assessment
are
summarized
in
Figure
II­
2.
11
Figure
II­
2.
Summary
of
the
screening
level
risk
assessment
for
maneb
in
terrestrial
and
aquatic
systems.
12
III.
Integrated
Environmental
Risk
Characterization
a.
Overview
of
Environmental
Risk
Based
on
available
data,
maneb
use
is
expected
to
pose
potential
chronic
risks
to
terrestrial
birds
and
mammals.
In
the
aquatic
environment,
it
is
concluded
that
maneb
will
present
potential
acute
risk
to
freshwater/
estuarine/
marine
fish
and
invertebrates
as
well
as
nonvascular
aquatic
plants.
These
potential
risks
occur
for
all
or
some
of
maneb's
uses.
Because
EFED
lacks
data,
EFED
is
uncertain
about
maneb's
potential
acute
risk
to
terrestrial
plants,
chronic
risks
to
freshwater
invertebrates,
chronic
risks
to
estuarine/
marine
animals
and
acute
risks
to
aquatic
vascular
plants.

Parent
maneb
is
insoluble
in
water
but
is
expected
to
decompose
rather
quickly,
by
hydrolytic
reactions,
into
a
multi
species
residue
(
maneb
complex)
consisting
of
transient
species
and
degradates
including
the
degradate
of
concern
ETU.
In
dry
conditions
and
in
soils
with
very
low
water
holding
capacity
parent
maneb
decomposition
is
slow.
Maneb
has
low
octanol/
water
partition
coefficients
(
K
ow
)
suggesting
that
it
would
not
be
significantly
bio­
concentrated
by
aquatic
organisms.
Furthermore,
maneb
has
a
very
low
vapor
pressure,
thus
indicating
that
volatilization
is
not
an
important
dissipation
pathway.
Due
to
rapid
hydrolytic
decomposition,
parent
maneb
is
expected
to
exist
in
the
natural
environment
for
a
short
duration
(<
1
day).
This
rate
is
largely
dependent
on
moisture
availability
and
therefore
in
dry
conditions
and
in
soils
with
very
low
water
holding
capacity
parent
maneb
will
persist.

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

Based
on
available
data,
EFED
expects
all
maneb's
uses
to
present
potential
chronic
risks
to
birds
and
mammals.
EFED
relied
on
a
referenced
total
foliar
dissipation
half­
life
value
of
3.2
days
to
evaluate
exposure
to
terrestrial
organisms
(
Willis
and
McDowell,
1987).
Maneb's
DFR
half­
lives
range
from
7.2
to
32.8
days
based
on
the
studies
available
from
HED.
However,
all
maneb's
uses
exceeded
bird
and
mammal
chronic
LOCs
using
the
3.2
day
TFR
half­
life
value.
Avian
chronic
LOCs
are
exceeded
for
all
uses
patterns.
RQs
range
from
a
high
of
265
from
the
turf
use
to
a
low
of
0.4
from
maneb's
uses
on
collards,
turnips,
and
mustard
(
Georgia
and
Tennessee,
only).
Mammalian
chronic
LOCs
are
exceeded
for
all
uses
patterns.
RQs
range
from
a
high
of
71
from
the
turf
use
to
a
low
of
0.1
from
maneb's
uses
on
collards,
turnips,
and
mustard
(
Georgia
and
Tennessee,
only).
EFED
does
not
calculate
risk
quotients
to
conduct
risk
assessments
on
terrestrial
invertebrates.
Based
on
the
lack
of
acute
maneb
toxicity
to
honeybees,
EFED
expects
a
low
acute
risk
to
nontarget
terrestrial
insects.
Due
to
lack
of
data
EFED
did
not
assess
risks
to
terrestrial
plants
or
fully
assess
risks
to
aquatic
plants.
EFED
is
uncertain
about
maneb's
risk
to
non­
target
terrestrial
plants
and
needs
testing
performed
at
maneb's
maximum
rate
of
application
in
the
environment.
In
the
aquatic
environment,
EFED
concludes
maneb
will
present
potential
acute
risk
to
freshwater/
estuarine/
marine
fish
and
invertebrates
as
well
as
nonvascular
aquatic
plants.
EFED
selected
representative
maneb
use
patterns
at
maximum
application
rates
and
minimum
intervals
3
Marshall,
W.
D.
1977.
J.
Agri.
Food
Chem.
25
(
2),
357­
361
13
between
applications
for
aquatic
modeling.
Maneb
is
used
on
more
than
20
different
crop
groupings.
The
representative
sites
selected
for
aquatic
modeling
were
apples,
peppers,
potatoes
(
Maine,
only)
and
tomatoes.
The
acute
RQs
exceeding
freshwater
fish
acute,
acute
restricted
use,
and
acute
endangered
species
LOCs
for
all
maneb's
modeled
uses
range
from
1.13
to
4.71.
The
acute
freshwater
invertebrates'
RQs
exceeding
acute
restricted
use,
and
acute
endangered
species
LOCs
for
all
maneb's
modeled
uses
range
from
0.40
to
1.65.
The
acute
estuarine/
marine
fish
RQs
exceed
acute
restricted
use,
and
acute
endangered
species
LOCs
for
all
maneb's
modeled
uses
with
RQs
ranging
from
0.47
to
1.1.
Estuarine/
marine
invertebrate
acute
RQs
exceed
acute,
acute
restricted
use,
and
acute
endangered
LOCs
for
all
maneb's
modeled
uses
with
RQs
ranging
from
15.87
to
65.97.
Based
on
data
for
one
surrogate
species,
maneb's
modeled
use
patterns
exceed
acute
risk
LOCs
for
nonvascular
aquatic
plants
with
acute
RQs
ranging
from
3.55
to
14.77.
EFED
has
not
received
studies
to
evaluate
the
risk
of
maneb
complex
to
vascular
aquatic
plants
and
needs
testing
performed
on
more
aquatic
nonvascular
plants
to
evaluate
fully
the
risk
to
aquatic
plants.
EFED
did
not
assess
chronic
risks
to
freshwater
invertebrates,
estuarine/
marine
fish,
or
estuarine/
marine
invertebrates
due
to
lack
of
data.

b.
Key
Issues
of
Uncertainty
i.
Environmental
Fate
EECs
for
parent
maneb
were
estimated
for
water
bodies
using
hydrolysis
half­
lives.
The
same
water
hydrolysis
half­
lives
were
used
for
soils
assuming
sufficient
moisture
is
available
in
soil
pores
for
hydrolysis
to
occur
at
the
same
rate.
Uncertainty
exists
on
whether
half­
lives
used
are
applicable
because
of
uncertainty
related
to
soil
moisture
availability
as
soil
moisture
level
is
expected
to
impact
resultant
EECs.
Lower
EECs
are
expected
in
irrigated
and/
or
rain­
fed
soils
with
high
water
holding
capacity
(
WHC)
and
higher
EECs
are
expected
in
low
WHC
soils
under
dry
conditions.
Giving
the
fact
that
maneb
is
applied
to
growing
crops,
moisture
is
expected
to
be
available
for
parent
to
hydrolyze
at
an
adjusted
rate
near
or
just
below
that
determined
from
aqueous
hydrolysis
half­
lives.
Other
factors
that
are
known
to
affect
hydrolytic
stability
of
maneb
include:
particle
size;
molecular
weight
distribution;
aqueous
media
pH
and
concentrations
of
O
2
3;
and
metal
ions
that
are
capable
of
exchanging
structural
Mn.
However,
the
very
low
hydrolytic
stability
of
parent
maneb
render
consideration
of
such
factors
un­
important.

EECs
for
maneb
complex
were
estimated
using
the
physicochemical
properties
and
hydrolysis
halflives
of
parent
maneb
in
addition
to
aerobic
soil
metabolism
half­
lives
and
sorption
coefficients
which
were
assigned
to
this
complex
rather
than
the
parent.
In
all
aerobic
soil
studies
two
separate
sets
of
experiments/
determinations
were
conducted:
the
first
was
to
obtain
data
for
calculating
half­
lives
using
the
CS
2
­
method
to
quantify
the
parent
while
the
second
was
to
characterize
the
degradation
process.
EFED
believes
that
half­
lives
calculated
from
the
first
set
of
experiments/
determinations
represent
hydrolytic
decomposition
of
parent
maneb
rather
than
bio­
degradation.
Rapid
degradation
of
parent
maneb
produces
a
complex,
the
maneb
complex,
which
appears
to
be
affected
by
slow
14
degradation
as
indicated
by
production
of
CO
2
.
Part
of
this
complex
may
contain
precursor(
s)
for
the
degradate
of
concern,
ETU.
Therefore,
EFED
used
the
second
set
of
experiments/
determinations
(
radioactivity
data)
for
calculating
half­
lives
and
assigned
it
to
the
maneb
complex.
Uncertainty
exists
in
these
complex
half­
lives
as
they
are
affected
by
the
validity
of
the
assumption
that
the
only
bio­
degradation
of
the
complex
was
represented
by
evolved
CO
2
.
Data
obtained
on
degradates
were
not
used
as
it
were
affected
by
impurities
in
the
test
materials,
hydrolytic
reactions
and
possible
artificial
degradation
during
extraction.

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

In
the
degradation
process
for
maneb
Mn
ions/
salts
are
expected
to
dissipate
into
the
environment.
No
data
were
presented
to
evaluate
the
risk
that
might
be
associated
with
this
release
and
therefore,
uncertainty
exists
in
this
aspect
of
risk
assessment.

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

Additional
information
is
presented
in
the
Appendix
(
Table
I­
B,
Appendix
I)
detailing
major
problems
in
maneb
fate
studies
which
adds
a
degree
of
uncertainty
for
estimated
fate
parameters
for
parent
maneb
and
maneb
complex,
resultant
EECs,
and
surface
and
groundwater
modeling
results.

ii.
Ecological
Effects
How
does
EFED
expect
maneb
to
act
in
the
environment
after
it
is
applied?
Maneb
is
applied
to
over
20
different
crop
groupings,
with
ornamental
and
turf
uses
(
see
Table
II­
1,
p.
6)
to
control
plant
diseases.
Maneb
has
broad
uses
in
the
US
and
because
of
this
EFED
expects
maneb
to
come
in
contact
with
non­
target
organisms
across
many
taxa.
EFED
presumes
applications
of
the
maneb
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
maneb
applications
will
result
in
degradation
of
maneb
to
maneb
complex
including
ETU
on
plant
surfaces.
EFED
figures
the
hydrolysis
of
the
maneb
will
be
variable
but
rather
fast,
that
is,
about
1­
day.
Except
for
applications
to
dry
soils
in
dry
environments,
EFED
4
Dry
conditions
is
one
circumstance
that
may
explain
the
high­
end
(>
30
days)
foliar
dissipation
half­
life
values
for
the
EBDCs
in
general.
EFED
expects
differences
in
application
methods
such
as
application
rates,
differences
crops
such
as
morphology,
and
regional
differences
such
as
weather
also
affect
the
foliar
dissipation.
Another
reason
that
may
cause
longer
foliar
dissipation
half­
lives
is
sample
analysis.
Measurements
quantifying
the
foliar
dissipation
half­
life
routinely
use
measurements
of
the
evolved
CS2
in
the
headspace
of
a
sealed
vial.
Such
measurements
quantify
the
sulfur
from
both
the
parent
EBDC
and
the
EBDC
complex
in
the
sample.
This
means
the
EBDC's
foliar
dissipation
half­
lives
result
from
the
presence
over
time
of
both
the
parent
EBDC
and
the
EBDC
complex.

15
expects
a
rapid
change
of
maneb
into
maneb
complex,
including
ETU.
4
What
effect
does
EFED
expect
maneb
to
have
on
non­
target
terrestrial
species?
From
a
short­
term
or
acute
exposure
EFED
expects
maneb
is
a
low
risk
to
mammals
and
birds.
This
expectation
is
supported
by
toxicological
studies
and
the
lack
of
incident
data.
There
are
no
incidents
for
maneb
listed
in
the
Ecological
Incident
Information
System
(
EIIS)
database
dealing
with
adverse
effects
to
terrestrial
non­
target
organisms.
EFED
expects
maneb's
long­
term
or
chronic
effects
on
birds
and
mammals
to
be
a
potential
concern.
This
belief
is
supported
by
toxicological
studies.
.
EFED
expects
chronic
problems
that
affect
wildlife
from
the
use
of
maneb
would
be
largely
unnoticed
in
the
field
and
thus
EFED
would
not
expect
incident
reports,
from
adverse
chronic
exposure.
Maneb's
uses
exceeds
chronic
LOCs
for
terrestrial
animals
(
birds
and
mammals)
for
all
maneb
use
patterns
for
all
food
categories
in
birds
and
for
all
food
categories
in
mammals
except
for
some
seed
categories.
These
exceedances
occur
on
all
terrestrial
bird
and
mammal
food
items
(
that
is,
short
grass,
tall
grass,
broadleaf
forage,
insects,
fruits,
pods,
and
seeds).
These
chronic
exceedances
extend
throughout
the
application
periods
for
all
uses
ranging
from
16
days
for
figs
to
197
days
for
papayas
(
see
Section
VII,
Terrestrial
Risk
Assessment,
subsection
d.
Terrestrial
Risk
Assessment).
In
other
words,
there
are
potential
reproductive
risks
to
birds
and
mammals
from
the
first
application
through
the
last
application
and
beyond
for
all
maneb's
uses.

EFED
used
maneb's
use
on
potatoes
as
an
example
(
see
Section
VII,
Terrestrial
Risk
Assessment,
subsection
d.
Terrestrial
Risk
Assessment).
Currently
in
Maine,
up
to
10
applications
of
maneb
are
allowed
to
be
applied
to
potatoes
every
5
days
during
the
growing
season.
Pheasant,
partridge,
pigeon,
dove,
duck,
geese,
songbirds,
antelope,
and
cottontail
rabbits
feed
in
potato
fields.
These
animals
feed
on
insects,
vegetation
in
the
treated
area,
or
on
the
potato
plants
throughout
the
potato
growing
season
(
Gusey
and
Maturdo,
1972)
which
lasts
90­
140
days
(
depending
on
the
potato
variety)
from
late
Spring
to
early
Fall.
For
birds
feeding
on
short
grass
this
potential
chronic
risk
begins
on
Day1
and
continues
through
Day
46
for
a
total
exposure
risk
period
of
46
days.
For
mammals,
this
same
potential
chronic
risk
from
feeding
on
short
grass
also
begins
on
Day1
and
continues
through
Day
40
for
a
total
potential
chronic
exposure
risk
period
of
40
days
(
see
Section
VII,
Terrestrial
Risk
Assessment,
subsection
d.
Terrestrial
Risk
Assessment,
Figure
VII­
5).
For
about
31
days
after
the
first
application
to
potatoes,
there
would
be
potential
reproductive
risks
to
birds
and
mammals
feeding
on
short
grass,
broadleaf
or
forage
plants,
tall
grass,
and
small
insects.
EFED
used
a
mallard
duck
reproductive
study
to
calculate
the
RQs
for
this
assessment.
EFED
based
birds
chronic
reproductive
effects
on
decreases
in
the
number
of
hatchlings
as
percentages
of
eggs
laid,
eggs
set,
and
live
3­
week
old
embryos,
and
a
decrease
in
the
number
of
14­
day
old
survivors
as
a
percentage
of
eggs..
EFED
based
mammal
reproductive
effects
on
a
2­
generation
study
in
rats.
5
Based
on
green
algae,
(
Pseudokirchneriella
subcapitata)
testing.

6
The
highest
ETU
RQ
is
0.00014
(
see
EFED's
ETU
chapter).

16
These
mammal
effects
were
male
parental
toxicity
resulting
in
significant
increase
in
lung
weight
(
both
generations)
and
liver
weight
(
F1
generation)
with
lesions
noted
on
these
organs
in
the
F1
generation.

Maneb
is
practically
nontoxic
to
the
honeybee
from
acute
contact
exposure.
EFED
does
not
perform
risk
quotient
assessments
for
terrestrial
insects.
Based
on
the
lack
of
acute
maneb
toxicity
to
honeybees,
EFED
expects
a
low
acute
risk
to
non­
target
terrestrial
insects.
EFED
is
uncertain
about
maneb's
risk
to
non­
target
terrestrial
plants
and
needs
testing
performed
at
maneb's
maximum
rate
of
application
in
the
environment.

What
effect
does
EFED
expect
maneb
to
have
on
non­
target
aquatic
species?
EFED
expects
maneb
to
reach
aquatic
environments
through
drift
and
runoff
since
maneb
is
not
labeled
for
direct
application
to
aquatic
environments.
Maneb's
solubility
was
reported
to
range
from
range
6
to
200
ppm.
EFED
expects
maneb
to
decompose
rather
quickly,
by
hydrolytic
reactions,
into
a
multispecies
residue
(
maneb
complex)
consisting
of
transient
species
and
degradates
including
the
degradate
of
concern
ETU.
Once
maneb
reaches
the
aquatic
environment
EFED
believes
the
maneb
complex
will
be
the
portion
of
maneb
that
is
biologically
available
to
aquatic
organisms.
EFED
expects
most
of
the
transient
species
present
in
the
maneb
complex
to
partition
into
the
sediment
particles
with
varied
strength
of
bonding.
Over
time
ETU
is
an
important
transformation
product
of
the
maneb
complex.
In
aqueous
media,
transient
species
do
not
last
long
while
ETU
is
persistent;
unless
it
is
subjected
to
rapid
degradation
by
microbial
and/
or
indirect
photolysis.

Based
on
laboratory
studies
and
modeled
EECs,
calculated
RQs
show
that
maneb
complex
is
an
acute
risk
to
freshwater
fish,
freshwater
invertebrates,
estuarine/
marine
fish,
estuarine/
marine
invertebrate,
and
nonvascular
aquatic
plants.
EFED
estimated
the
highest
maneb
complex
aquatic
EEC
expected
from
drift
and
runoff
would
be
197.9
ppb.
Based
on
this
residue
level
and
individual
laboratory
studies
EFED
estimated
the
likelihood
of
adverse
maneb
complex
effects
to
individual
organisms
across
taxa.
These
chance
estimates
show
there
is
high
likelihood
(
that
is,
57
to
100%)
of
potential
adverse
acute
effects
to
individual
freshwater
and
estuarine/
marine
aquatic
organisms
from
maneb
complex
(
see
section
VI).
Aquatic
Exposure
and
Risk
Assessment,
subsection
c.
Aquatic
Risk
Assessment).
EFED
has
no
data
to
evaluate
the
chronic
effects
to
freshwater
invertebrates
or
estuarine/
marine
organisms.
No
chronic
LOCs
are
exceeded
for
freshwater
fish
from
maneb's
uses.
The
study
used
to
calculate
the
freshwater
fish
chronic
RQs
for
this
assessment
are
based
on
the
following
chronic
effects:
decreased
hatchability;
fish
survival;
and
length
of
fry.

In
the
aquatic
media,
ETU
is
expected
to
be
an
important
transformation
product
of
all
the
EBDCs
and
can
persist
unless
it
is
subjected
to
rapid
degradation
by
microbial
and/
or
indirect
photolysis.
The
ETU
acute
RQs
for
nonvascular
aquatic
plants5,
freshwater
fish
and
freshwater
invertebrates
were
well
below6
the
lowest
LOC
(
endangered
species
LOC
=
0.05)
for
aquatic
organisms.
EFED
does
not
know
how
acutely
toxic
ETU
is
to
estuarine/
marine
fish
or
invertebrates
because
no
data
has
been
17
reviewed
for
evaluating
this
hazard.
This
means
the
maneb
complex,
other
than
ETU,
is
responsible
for
the
acute
toxicity
to
freshwater
fish,
freshwater
invertebrates,
and
nonvascular
aquatic
plants.
EFED
expects
the
acute
toxicity
to
freshwater
fish,
freshwater
invertebrates,
estuarine/
marine
fish
and
nonvascular
aquatic
plants,
from
exposure
to
the
maneb
complex,
will
not
last
long.
The
acute
fish
studies
have
a
duration
of
96
hours,
while
the
acute
invertebrate
studies
last
48
hours
and
the
nonvascular
aquatic
plant
studies
are
120
hours
in
duration.
Acceptable
aquatic
half­
life
data
is
unavailable
for
most
products
of
the
maneb
complex.
EFED
expects
maneb
to
hydrolyze
quickly
(
that
is,
within
hours)
to
its
residues.
Based
on
this
information,
EFED
expects
the
maneb
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
residues
degrade
to
ETU.
However,
EFED
expects
there
will
still
be
enough
maneb
complex
to
present
an
acute
risk
to
estuarine/
marine
invertebrates.
EFED
expects
the
acute
risk
to
estuarine/
marine
invertebrates
will
persist
because
maneb
complexes
are
very
highly
toxic
to
these
organisms
(
mysid
shrimp
EC
50
=
3
ppb).
Modeled
maneb
complex
EECs
for
selected
sites
range
from
2.1
to
9.2
ppb
21
days
after
maneb
applications
(
see
section
V.
Water
Resource
Assessment,
Table
V.
2).
This
combination
of
exposure
and
toxicity
suggests
acute
LOCs
would
still
be
triggered
for
estuarine/
marine
invertebrates
21
days
after
maneb
is
applied.

EIIS
reported
maneb
in
three
fish
kill
incidents
(
see
Section
VI,
Incidents).
One
incident
occurred
in
1973,
another
in
June,
1994
and
the
latest
occurred
in
August,
1994.
In
the
1973
and
June,
1994
incidents,
EFED
classified
maneb
as
unlikely
to
have
been
responsible
for
the
these
fish
kills.
The
final
maneb
related
incident,
occurring
in
August,
1994,
was
reported
by
the
Maine
Department
of
Agriculture.
In
this
incident
roughly
10,000
newly
released
brook
trout
were
killed
in
a
pond
that
borders
New
Brunswick,
Canada
and
Maine.
Three
pesticides
(
maneb,
esfenvalerate,
and
chlorothalonil)
recently
applied
to
potatoes
surrounding
this
pond
were
suspected
in
this
fish
kill.
Tissue
samples
of
the
fish
confirmed
the
presence
of
all
three
pesticides
(
maneb
at
169
ppb,
esfenvalerate
at
4.2
ppb,
and
chlorothalonil
at
20
ppb)
in
the
fish.
These
fish
samples
were
taken
from
both
the
pond
and
brooks
feeding
the
pond.
All
three
of
these
pesticides
are
very
highly
toxic
to
freshwater
fish.
Maneb's
rainbow
trout
LC
50
is
42.0
ppb,
esfenvalerate's
rainbow
trout
LC
50
is
0.26
ppb
(
Hicks,
L.
May,
1995)
and
chlorothalonil's
rainbow
trout
LC
50
is
42.3
ppb
(
US
EPA.
1998)].
The
submitter
of
the
incident
report
pointed
out
there
were
severe
thunderstorms
in
the
area
preceding
the
fish
kill
which
suggest
pesticide
runoff
was
a
cause
in
this
kill.
Based
on
sampling
evidence,
EFED
believes
maneb
was
a
contributory
cause
in
this
fish
kill.

c.
Endangered
Species
Conclusions
Based
on
available
screening
level
information
there
is
a
concern
for
maneb's
potential
acute
effects
on
listed
freshwater
and
estuarine/
marine
animals
and
potential
chronic
effects
on
listed
birds
and
mammals
should
exposure
actually
occur.
EFED
expects
maneb
poses
a
low
acute
risk
to
nontarget
insects
because
maneb
is
practically
nontoxic
to
honeybees,
(
acute
contact
LD
50
>
12
µ
g/
bee).
Also,
there
is
no
incident
data
reporting
adverse
effects
to
honeybees
from
maneb's
use.
However,
EFED
does
not
assess
risk
to
bees
using
RQs
because
a
screening
level
RQ
assessment
method
for
estimating
the
risk
to
bees
is
not
available.
EFED
has
not
developed
an
exposure
design
for
bees
to
estimate
the
risk
using
a
risk
quotient
method.
The
Agency
does
not
currently
have
enough
data
to
perform
a
screening
level
assessment
for
maneb's
effects
on
listed
nontarget
terrestrial
plants
or
18
vascular
aquatic
plants.
EFED
did
not
assess
chronic
risks
to
freshwater
invertebrates,
or
estuarine/
marine
fish
due
to
lack
of
data.
There
are
no
nonvascular
aquatic
plants
or
estuarine/
marine
invertebrate
species
on
the
endangered
species
list.

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).

When
the
appropriate
screening
and
or
testing
protocols
being
considered
under
the
Agency's
Endocrine
Disruptor
Screening
Program
have
been
developed,
maneb
may
be
subjected
to
additional
screening
and
or
testing
to
better
characterize
effects
related
to
endocrine
disruption.
The
avian
reproductive
studies
reviewed
by
EFED
noted
reproductive
effects.
These
effects
in
mallard
duck
were
decreases
in
the
number
of
hatchlings
as
percentages
of
eggs
laid,
eggs
set,
and
live
3­
week
old
embryos,
and
a
decrease
in
the
number
of
14­
day
old
survivors
as
a
percentage
of
eggs.
For
mammals
chronic
effects
were
noted
such
as
male
parental
toxicity
resulting
in
significant
increase
in
lung
weight
(
both
generations)
and
liver
weight
(
F1
generation)
with
lesions
noted
on
these
organs
in
the
F1
generation.
See
Appendix
III
for
a
detailed
listing
of
the
studies
and
results.
These
effects
noted
in
both
birds
and
mammals
could
be
a
result
of
hormonal
disruptions.
Chronic
testing
in
freshwater
fish
showed
decreased
hatchability,
fish
survival
and
length
of
fry.
See
Appendix
III
for
a
detailed
listing
of
the
studies
and
results.
These
effects
noted
in
freshwater
species
may
be
a
result
of
hormonal
disruptions.

EFED
recommends
that
when
appropriate
screening
and/
or
testing
protocols
being
considered
under
the
Agency's
EDSP
have
been
developed,
maneb
be
subjected
to
more
definitive
testing
to
better
characterize
effects
related
to
its
potential
endocrine
disruptor
activity.
EFED
bases
this
recommendation
on
the
the
potential
chronic
effects
in
freshwater
fish,
birds
and
mammals.
19
IV.
Environmental
Fate
Assessment
The
fate
of
parent
maneb
was
evaluated
by
considering
data
on
its
hydrolytic
stability.
Practically,
parent
maneb
is
short­
lived,
therefore
it
was
important
to
evaluate
the
fate
and
transport
of
resultant
maneb
complex
by
its
degradation
processes
in
aqueous
phases
as
well
as
soil
and
field
environments.
Transformation
products
identified
in
fate
studies
were
also
given
the
required
emphasis
here
and
in
the
accompanied
RED
chapter
for
ETU.

a.
Chemical
Identity
and
Physicochemical
Properties
Maneb
is
a
high
molecular
weight
coordination
polymer
or
a
highly
coordinated
salt
complex
that
is
usually
represented
by
one
unit
of
the
polymer;
a
monomeric
Mn+
2
ethylene
bis­
dithiocarbamate
(
EBDC).
For
maneb
and
related
chemicals,
the
metal
is
bonded,
by
bridging,
to
the
EBDC
ligand
through
the
sulfur
atoms.
Information
pertaining
to
the
chemical
identity
of
maneb
and
its
physicochemical
characteristics
are
listed
in
table
IV­
1.
Maneb
water
solubility
was
reported
to
range
from
range
6
to
200
ppm
resulting
in
complete
hydrolytic
destruction
of
maneb
into
its
multi
species
complex.
Variations
in
reported
solubilities
were
reported,
by
the
registrant,
to
be
related
to
uncertainties
associated
with
each
specific
analytical
procedure
used
for
its
determination
(
e.
g.
efficiency
of
sampling,
energy
supplied
to
promote
solubilization
and
filtration
procedure).

Volatilization
from
water
and/
or
dry/
moist
soil
surfaces
is
not
expected
to
be
an
important
dissipation
process
based
upon
vapor
pressure
and
calculated
Henry's
Law
constant.
Maneb
has
a
low
K
ow
suggesting
that
it
will
not
be
significantly
bio­
concentrated
by
aquatic
organisms
such
as
fish
or
aquatic
invertebrates.

Table
IV­
1.
Nomenclature
and
physical
chemical
identity
of
the
maneb
complex
and
ETU.

CAS
[[
1,2­
Ethanediylbis
[
carbamodithioato]]­(
2­)]
manganese
Structure
of
Maneb
and
its
Main
Degradate
ETU
CAS
Registry
No.
12427­
38­
2
PC
Code
014505
Molecular
Weight
265.28
(
C4­
H6­
Mn­
N2­
S4;
monomeric
unit)

Formulated
Products
liquid
flowable;
flowable
suspension;
wettable
powder
K
OW
5;
based
on
its
reported
log
of
0.69
Vapor
Pressure
<
9.97x10­
11
atm
@
20
0C
1
Water
Solubility
Rapidly
decomposes
in
water
2
1
US
Dept
Agric;
The
Pesticide
Properties
Database:
http://
wizard.
arsusda.
gov/
rsml/
textfiles/
Maneb
2
Registrant
reported
solubility
in
water
to
range
frm
150
to
200
ppm
(
Pennwalt
Corporation
data
with
no
MRID
number
assigned);
Also
reported
to
be
200
ppm
(
MRID
455959­
01).
In
a
new
hydrolysis
study
(
MRID
453936­
01),
no
solubility
data
was
submitted
but
the
authors
described
maneb
to
be
"
a
polymer
that
is
insoluble
in
a
wide
variety
of
non­
polar
and
polar
solvents,
including
water".
This
contradicts
with
the
150­
200
ppm
values
reported
earlier
by
the
registrant.
In
another
reference
an
"
estimated
water
solubility"
was
reported
to
equal
6
ppm
(
Wauchope
R.
D
et
al.
1991.
Res
Environ
Contam.
Toxicol.
123:
1­
36).
20
b.
Fate
Processes
Table
IV­
2
contains
a
summary
of
data
obtained
from
guideline
studies
conducted
on
maneb.
Submitted
guideline
studies
suggest
that
under
typical
application
rates
into
natural
environment,
parent
maneb
is
expected
to
decompose
(
within
one
day)
by
hydrolytic
reactions
and
resists
both
water/
soil
photolysis
or
volatilization.
Therefore,
hydrolytic
reactions
are
extremely
important
in
the
fate
of
parent
maneb
and
its
decomposition
to
maneb
complex.

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

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

Table
IV­
2.
Environmental
fate
data
summary
for
maneb.

Parameter
Value
Source
(
MRID
)

Hydrolysis
Half­
lives,
for
the
process
of
decomposition
by
hydrolytic
reactions
in
water,
depends
on
the
pH
of
the
aqueous
media
as
follows:
Acidic:
t1/
2=
4
Hours
@
pH
5;
Neutral:
t1/
2=
3
Hours
@
pH
7;
Basic:
t1/
2=
3
Hours
@
pH
9.
453936­
01
Photo
lysis
Not
important
in
water
(
direct
photolysis),
No
data
for
indirect
photolysis
404656­
02
Not
important
on
soil
404656­
03
Aerobic
Soil
Metabolism
Half­
lives
were
calculated
by
EFED
based
on
evolved
CO2:
t1/
2=
145
days
Speyer
loamy
sand
soil;
Germany
(
54%
sand,
41%
silt,
5%
clay,
pH
5.7,
2.11%
organic
carbon,
and
CEC
of
9
meq/
100g
soil).
t1/
2=
075
days
Speyer
sandy
loam
soil;
Germany
(
37%
sand,
57%
silt,
6%
clay,
pH
5.8,
0.82%
organic
carbon,
and
CEC
of
7
meq/
100g
soil).
t1/
2=
270
days
Collamer
silt
loam,
a
silt
loam
soil
(
29%
sand,
61%
silt,
10%
clay,
pH
6.1,
2.09%
organic
carbon,
and
CEC
of
13
meq/
100g
soil).
405852­
01
405852­
01
451452­
02
Parameter
Value
Source
(
MRID
)

21
Anaerobic
Soil;
Aerobic
Aquatic
Metabolism;
and
Bio­
accumulation
Factor
:
No
acceptable
studies.

Anaerobic
Aquatic
Metabolism
Complete
degradation
within
one
Hour
for
parent
maneb;
The
sediment
bound
part
of
maneb
complex
appears
to
be
persistent
and
maneb
complex
appears
to
be
practically
stable
based
on
evolved
CO2
(
Maximum
of
2.75%
at
275
days)
001633­
35
Adsorption
Coefficients
for
maneb
complex*
(
L
Kg­
1)
Loamy
Sand:
Kd
=
35.70
and
KOC
=
1,692
(
a.
i.
used)

Sand:
Kd
=
7.46
and
KOC
=
6,412
(
a.
i.
used)
Sandy
Loam:
Kd
=
9.10
and
KOC=
978
(
a.
i.
used)
Clay
Loam:
Kd
=
6.97
and
KOC
=
428
(
a.
i.
used)
Silt
Loam:
Kd
=
2.23
and
KOC
=
400
(
a.
i.
used)

Sand:
Kd
=
3.18
and
KOC
=
454
(
a.
i.
used)

Sand:
Kd
=
10.21
and
KOC
=
1,459
(
formulation
used)
Loamy
Sand:
Kd=
25.96
and
KOC
=
1,133
(
formulation
used)
Sandy
Loam:
Kd=
13.72
and
KOC=
1,024
(
formulation
used)
405852­
03
400472­
01
455959­
01
455959­
02
*
A
suite
of
maneb
degradation
products
and
transient
species.

i.
Aqueous
Solutions
Maneb
is
a
non­
homogenous
or
a
highly
coordinated
salt
complex,
with
variable
molecular
weight.
When
suspended
in
water
it
decomposes
rapidly
by
hydrolytic
reactions
into
transient
species
and
degradates
including
ETU.
The
amount
affected
by
hydrolytic
reactions
appears
to
depend
on
particle
size
distribution
and
molecular
weight
distribution
of
the
maneb
polymer
as
well
as
temperature,
metal
ions
present,
and
available
oxygen.
Hydrolytic
decomposition
results
from
detachment
of
the
coordinated
EBDC
ligand
from
the
metal
by
oxidation.
In
turn,
the
water
soluble
free
ligand
reacts
with
water
to
produce
predominantly
transient
species
and
ETU.

Two
supplemental
hydrolysis
studies
were
submitted
for
maneb.
In
the
first
study,
14C­
maneb
was
used
at
levels
of
22­
40
ppm
while
in
the
second
study
the
concentration
level
was
10
ppm.
In
the
first
study
(
MRID
404656­
01),
the
parent
decomposes
rather
quickly
(
preventing
determination
of
halflives
resulting
in
EBIS
(
5,6­
Dihydro­
3H­
imidazo[
2,1­
c]­
1,2,4­
dithiazole­
3­
thione;
a
transient
species),
un­
identified
degradate,
ETU
(
4,5­
Dihydro­
1H­
imidazol­
2­
thione),
EU
(
2­
Imidazolidinone)
and
low
quantities
of
glycine
(
only
at
pH
3).
The
second
study
consisted
of
two
identical
hydrolysis
experiments:
one
was
for
identifying/
quantifying
degradation
products
while
the
other
was
for
calculating
hydrolysis
kinetics
(
MRID
453936­
01).
Major
identified
degradates,
at
all
pHs,
included
the
transient
EBIS
and
the
degradates
ETU,
EU
and
one
unknown
compound.
Minor
degradates
were
Jaffe's
base
"
J.
B=
[
3­(
2­
Imidzaolin­
2­
yl)­
2­
imidazolidinethione]"
and
un­
identified
others.
Registrant
calculated
first
order
half­
lives
at
25
OC
were
4,
3,
and
3
hours
at
pH
5,
7,
and
9,
respectively.
22
Direct
photolysis
studies
on
maneb
were
complicated
by
its
rapid
degradation
upon
suspension
in
water
at
concentration
levels
used
(
22
ppm
in
MRID
404656­
02
and
10
ppm
in
MRID
420701­
02).
Identified
degradation
products
were
similar
to
those
formed
in
hydrolysis
studies
with
the
exception
of
formation
of
minor
amounts
of
ETT
(
4,5­
Dihydro­
1H­
imidazol­
2­
thione­
1­
thiocarboxamide).
It
appears
that
although
the
degradation
of
maneb
suspensions
in
water
is
primarily
dominated
by
hydrolysis,
there
is
a
small
contribution
of
photo­
reactions
likely
to
be
linked
to
reactions
related
to
transient
chemical
species.

ii.
Soil
A
30­
day
photo­
degradation
study
on
a
loamy
sand
soil
showed
no
significant
difference
between
samples
exposed
to
simulated
sunlight
and
those
kept
in
the
dark
in
the
product
pattern,
the
relative
amounts
of
degradation
products
and
their
formation/
decline
(
MRID
404656­
03).
Although
maneb
was
never
detected
(
14C­
maneb
used
was
8.6
ppm),
a
suite
of
degradates
were
detected
in
the
extractable
fraction
(
24­
19%
of
the
applied
radioactivity
by
methanol
and
9­
14%
of
the
applied
radioactivity
by
water)
included
EU,
ETU,
EBIS,
carbimid,
and
an
un­
identified
polar
fraction.
This
indicates
that
photolysis
appear
not
to
be
an
important
processes
in
dissipation
of
maneb
in
soils.

Two
supplemental
aerobic
soil
studies
were
submitted
for
maneb
(
MRID
451452­
02
and
405852­
01).
Many
reasons
were
sited
for
the
assigned
classification
for
these
studies.
Some
of
these
reasons
are
related
to
the
nature
of
the
test
substance
(
may
not
be
able
to
control)
including:
impurity
(
purity
~
84.8%)
and
instability
of
the
test
substance
(
in
the
rejected
study
parent
was
never
detected
even
at
time
zero).
However,
reasons
that
may
have
controlled
included:
non­
determination
of
mass
balance,
exclusion
of
un­
extracted
bound
species,
incomplete
characterization
of
degradation
products,
insufficient
duration
(
for
example,
on
day
60,
81%
of
the
total
residues
remained
in
the
soil
with
substantial
degradation
appeared
to
start
between
days
30
and
60),
and
inadequacy/
uncertainty
of
the
procedures
used
in
quantifying
the
parent
maneb
and
degradates
(
CS
2
and
TLC
methods).

One
soil
was
used
in
the
first
study
with
fortification
level
of
15­
21
ppm
(
MRID
451452­
02)
while
two
soils
were
used
in
the
second
study
with
fortification
level
of
9
ppm
of
14C
maneb
(
MRID
405852­
01).
DT
50
of
<
1
day
was
estimated
for
the
first
soil
(
MRID
451452­
02)
while
parent
was
never
detected
in
the
other
two
soils
(
MRIDs
405852­
01).
As
shown
for
EBDCs,
parent
degradation
in
aerobic
soils
can
be
attributed
to
chemical
hydrolysis
rather
than
bio­
degradation.
Furthermore,
EFED
suggests
a
second
process
to
be
involved
in
maneb
degradation
in
aerobic
soil;
a
very
slow
biodegradation
occurring
in
parallel
with
the
first
very
rapid
hydrolysis.
In
this
scheme,
the
first
process
transforms
parent
maneb
into
a
multi
species
residue
(
maneb
complex)
while
the
second
process
transforms
maneb
complex
into
further
degradates
and
CO
2
.
Therefore,
a
second
set
of
half­
lives
were
calculated
by
EFED
for
the
maneb
complex
as
species
present
in
this
complex
can
be
precursors
for
the
degradate
of
concern,
ETU.
For
this
purpose,
EFED
used
the
mass
balance
data
(
radioactivity
data)
from
both
studies
and
assumed
that
the
only
bio­
degradation
of
the
complex
was
represented
by
evolved
CO
2
.
EFED
calculated
first
order
half­
lives
for
maneb
complex
are
summarized
in
Table
IV­
2
and
indicate
that
the
complex
is
moderately
persistent
(
half­
lives
in
the
range
of
75­
270
days).
It
is
important
to
note
that
these
estimated
half­
lives
are
conservative
as
it
is
based
on
complete
mineralization
of
the
maneb
complex
into
CO
2
.
7
Clark,
D.
G.,
Bauam,
H.,
Stanley,
E.
L.,
and
Hester,
W.
F.
1951.
Anal.
Chem.
23,
1842.
Lowen,
W.
K.
1951.
Anal.
Chem.
23,
1846­
1850.
And
in
1953.
J.
AOAC
36,
484­
492.
Pease,
JL.
1957.
J.
AOAC
40,
1113­
1118.

8
Gordon,
C.
F.,
Schuckert,
R.
J.
and
Bornal,
W.
E.
1967.
AOAC
50
(
5),
1102­
1108.
Bighi,
C.
J.
1961.
J.
Chromatog.
14,
348­
354.
Bighi,
C.
J.
1961.
J.
Chromatog.
17,
13­
22.
McLeod,
H.
A.
and
McCulley,
K.
A.
1969.
AOAC
52
(
5),
1226.

23
Transformation
products
in
the
supplemental
aerobic
soil
study
(
MRID
451452­
02)
were
identified/
quantified
only
in
the
basified
acetonitrile:
water
extract
by
HPLC/
MS.
The
list
of
metabolites
included:

ETU
(
Ethylenethiourea;
2­
imidazolidinethione):
was
5­
6%
of
the
applied
at
time
0,
a
maximum
7­
8%
at
1
day
post­
treatment,
2­
3%
at
4
days,
and
<
1%
at
30
days.

EBIS
or
DIDT
(
5,6­
dihydro­
3H­
imidazo­[
2,1,­
c]­
1,2,4­
dithiazole­
3­
thione):
was
14­
18%
of
the
applied
at
time
0,
10­
11%
at
2
days,
5­
6%
at
4
days,
and
<
1
at
30
days.

EU
(
Ethyleneurea;
2­
imidazolidone):
was
a
maximum
of
1%
of
the
applied
at
2
days
and
decreased
to
<
1%
at
30
days.

iii.
Sediment/
Water
Systems
In
an
anaerobic
aquatic
soil
study
(
MRID
001633­
35),
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.
Maneb
was
never
identified,
however,
radioactivity
partitioned
into
the
water
and
the
sediment
with
the
latter
being
mainly
non­
extractable.
Total
radioactivity
partitioned
into
the
soil
increased
steadily
to
reach
a
plateau
of
nearly
70%
within
100
days
of
application
with
most
being
bound
un­
extractable.
Under
the
aquatic
anaerobic
conditions
of
the
experiment,
maneb
degraded
by
hydrolysis
into
the
transient
EBIS,
two
major
degradates
ETU
and
EU,
and
one
minor
un­
identified
degradate.
Although
EBIS
was
equally
divided
between
the
soil
extractable
and
water
phases,
both
ETU
and
EU
were
more
prominent
in
the
water
phase
reflecting
their
high
solubility
compared
to
EBIS.
No
aerobic
aquatic
metabolism
studies
have
been
submitted.

iv.
Bound
Species,
CS
2
­
data
and
Half­
life
Determination
for
EBDCs
The
registrant
claims
that
the
CS
2
­
method
quantitatively
determines
sulfur
containing
dithiocarbamates
(
parent
EBDCs
and
EBDCs
species
formed
by
hydrolytic
reactions)
in
aqueous
media,
soil
and
water/
sediment
systems
including
bound
species
to
soil/
sediment.
In
support,
the
registrant
stated
that
CS
2
based
methods
were
used
early
in
the
discovery
of
EBDCs
7
and
later
with
improvements
in
safety
and
methods
employed
in
CS
2
determination
8.
It
was
also
argued
that
9
Marshall,
W.
D.
1977.
J.
Agri.
Food
Chem.
25(
2):
357­
361.

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

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

24
classical
chemistry
suggests
that
the
dithiocarbamate
functionality
would
not
be
stable
under
the
acid
hydrolytic
conditions
used
by
the
CS
2
­
method
to
release
CS
2
.
Many
literature
examples
were
cited
to
indicate
method
reliability
including:
demonstration
of
rapid
EBDCs
degradation
at
elevated
temperatures
and
acidic
conditions
in
aqueous
media9;
recommendation,
after
careful
review,
of
a
similar
method
for
analysis
of
dithiocarbamate
residues
by
a
Panel
set
up
by
the
Committee
for
Analytical
Methods
for
Residues
of
Pesticides
and
Veterinary
Products
in
Foodstuffs
of
the
Ministry
of
Agriculture,
Fisheries,
and
Food
(
MAFF)
in
197710;
obtaining
a
recovery
of
98.0
±
15.8%
for
mancozeb
in
freshly
fortified
control
soil
samples11;
and
the
extensive
use
of
the
method
for
over
10
years
with
the
greatest
effort
towards
crop
residue
analysis.
Therefore,
the
registrant
argues
that
the
appropriate
method
for
calculating
half­
lives
of
EBDCs
in
fate
studies
is
the
use
of
CS
2
­
method
data
rather
than
the
evolved
CO
2
­
data.
Half­
lives
obtained
for
parent
EBDCs
are
expected
to
be
conservative
due
to
the
fact
that
CS
2
is
expected
to
evolve
not
only
from
parent
but
also
from
EBDC
species/
degradates
containing
structural
sulfur
(
e.
g
EBIS
and
ETU).

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

In
few
of
the
submitted
fate
studies,
only
limited
data
were
provided
on
the
significant
bound
species
found
in
soil
and
water/
sediment
studies.
Fractionation
of
the
bound
species
was
performed
into
fulvic
and
humic
fractions
with
no
further
determination
of
identity/
quantity
of
species
present.
Without
presenting
direct
evidence,
the
registrant
stated
that
consistent
with
current
mechanistic
studies,
"
bound
EBDC'
is
significantly
comprised
of
short­
chain
polar
degradates
such
as
12
Marshall,
W.
D.
1977.
J.
Agri.
Food
Chem.
25(
2):
357­
361.

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

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

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

25
ethylenediamine
"
EDA".
In
support
of
this
suggestion,
the
registrant
stated
that
EBDCs
may
degrade
via
two
different12,
routes
with
both
routes
eventually
forming
EDA,
which
in
turn
transformed
into
glycine13.
Other
cited
literature
include:
a
report
that
the
EDA
has
a
Freundlich
adsorption
coefficient
range
of
15­
238
suggesting
that
it
binds
strongly
to
soil14;
and
low
levels
of
EDA
were
identified
in
soil
samples
from
at
least
one
cropped
field
treated
with
maneb,
at
normal
commercial
rates,
in
Ottawa,
Canada15.

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

In
order
to
solve
the
problem
of
the
identity
of
bound
species,
EFED
proposes
that
the
registrant
conduct
one
complete
aerobic
soil
study.
In
the
proposed
study,
greater
efforts
should
be
exercised
to
try
to
characterize
bound
species.
In
addition,
EDA;
and
ETU,
EBIS,
and
all
types
of
sulfur
bearing
compounds
should
be
tracked
(
possibly
by
labeling
structural
sulfur
in
parent
EBDC).
A
sterile
soil
treatment
should
also
be
included
in
order
to
determine
the
relative
importance
of
the
active
dissipation/
degradation
processes
in
aerobic
soils
(
binding
to
soil/
hydrolysis
compared
to
biodegradation
26
c.
Mobility
Mobility
in
soil
studies
were
complicated
by
the
instability
of
the
parent
as
maneb
was
not
identified
at
time
zero
in
the
TLC
procedure
nor
after
aging
in
soil
column
leaching.
Therefore,
mobility
as
indicated
by
R
f
or
K
d
/
K
oc
values
do
not
represents
maneb
but
rather
maneb
complex
formed
as
a
result
of
the
observed
rapid
hydrolysis.
Five
studies
were
submitted
on
mobility
of
maneb
(
MRIDs
00658­
59,
405852­
03,
400472­
01,
455959­
01
and
455959­
02)
and
all
were
classified
as
supplemental
due
to
non­
detection
of
maneb
(
fortification
in
the
range
of
9
to
24
ppm)
and
non­
characterization
of
the
test
substance
at
time
zero,
use
of
wettable
powder
formulations
as
source
for
radiolabeled
parent,
incomplete
identification/
quantification
of
the
degradates,
and
the
use
of
unacceptable
methods
for
the
analysis
of
parent
(
i.
e
bioassay).
Most
of
the
listed
procedural
deficiencies
are
probably
related
to
parent
instability
and
may
not
be
possible
to
avoid,
however,
some
may
contribute
to
uncertainty
in
the
results.
For
example,
the
use
of
formulation
instead
of
pure
active
ingredient
increased
estimated
K
oc
for
the
same
sandy
soil
from
454
to
1,459;
formulated
products
were
used
to
increase
stability.

In
TLC
plates,
determined
R
f
values
ranged
from
0.0
to
0.43
(
Table
IV­
2).
These
values
were
taken
to
indicate
immobility
to
medium
mobility
of
maneb
complex
in
a
muck
soil
and
four
soils
with
varied
clay
and
organic
matter
content.
Results
from
soil
column
leaching
studies
were
similar
as
it
indicated
immobility
to
medium
mobility
from
estimated
K
d
/
K
oc
with
no
apparent
relationship
between
estimated
mobility
and
clay
or
organic
carbon
contents.
Furthermore,
column
leaching
profiles
indicated
that
most
of
the
radioactivity
remained
in
the
top
3­
4"
of
the
soil
column
(
65­
93%).
Leached
radioactivity
varied
from
<
5%
in
half
of
the
soil
column
while
it
ranged
from
10­
32%
in
the
other
half
with
no
apparent
relationship
to
soil
texture
or
organic
matter.
It
is
interesting
to
note
that
leached
radioactivity
were
<
5%
in
soils
fortified
with
wettable
powder
formulations.
Leached
radioactivity
increased
from
4%
to
12%
when
one
of
these
soils
were
fortified
with
the
active
ingredient.

In
submitted
studies,
soil
residues
were
not
fully
characterized
as
data
were
only
reported
for
some
soils.
Reported
data
show
no
parent
was
present
and
that
the
dominant
constituents
of
the
residue
were
ETU,
EBIS
and
carbimid
in
the
soil
column
and
ETU
and
EU
in
the
leachate.

d.
Field
Dissipation
Field
dissipation
for
14C­
parent
maneb,
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
51"
of
rainfall
(
MRID
000889­
23).
Half
life
of
1­
2
months
(
DT
50
.
48
days)
was
estimated
from
the
"
total
radioactivity"
remained
in
the
whole
12"
soil
column.
EFED
calculated
first
order
halflife
from
the
same
data
gave
a
t
½
of
301
days
(
R2=
0.73).
This
terrestrial
dissipation
t
½
is
not
far
from
the
aerobic
soil
t
½
of
270
days
(
r2=
0.9595)
determined
for
maneb
complex
based
on
evolved
CO
2
.
The
study
was
classified
as
"
supplemental"
because
it
was
not
conducted
under
actual
use
conditions,
test
substance
was
not
a
typical
end
use
product,
half­
life
was
based
on
radioactive
residues,
radioactive
residues
were
not
characterized
(
i.
e.
maneb
was
never
identified),
degradation
27
products
were
not
addressed
and
field
test
data
were
not
reported.

Two
terrestrial
field
dissipation
studies
were
conducted
using
maneb
flowable
formulation
applied
in
seven
applications
of
2.4
lb
a.
i/
acre
each
in
one­
week
intervals.
According
to
the
study
authors
maneb
dissipated
with
a
calculated
first
order
half­
life
(
t
1/
2
)
of
12
days
in
Hanford
loamy
sand
plots
planted
with
tomatoes
in
California
(
MRID
417430­
01)
and
40
days
in
a
Norfolk
sandy
loam
plots
planted
with
snap
beans
in
Georgia
(
MRID
417430­
02).
Although,
problems
were
associated
with
these
two
studies,
the
results
indicate
that
substantial
amounts
of
maneb
can
be
intercepted/
persist
on
plant
surfaces.
Disc
incorporation
of
tomato
plant
residues
into
the
top
6"
one
month
after
the
last
application
returned
enough
maneb
residue
to
raise/
sustain
the
concentration
of
maneb
in
the
top
3"
of
the
soil
for
more
than
two
months.
Determined
levels
of
maneb
in
the
top
3"
of
the
soil
increased
to
levels
higher
than
any
single
soil
concentration
determined
after
each
of
the
seven
applications.
In
these
studies,
the
only
monitored
degradate
was
ETU
which
was
detected
mainly
during
the
application
period
in
the
top
3"
of
the
soil
and
in
the
range
of
0.01
and
0.053
ppm
(
near
its
detection
limit
of
0.01
ppm
which
corresponds
to
degradation
of
only
1%
of
the
applied
parent).
In
California,
ETU
was
detected
too
infrequently
and
at
a
maximum
level
of
0.015
ppm
(
corresponds
to
degradation
of
only
1.6%
of
the
applied
parent).
In
contrast,
ETU
levels
in
Georgia
ranged
from
0.014
to
0.053
ppm
corresponding
to
degradation
of
only
1.5
to
5.5%
of
the
applied
parent.
Parent
depth
profile
suggested
evidence
of
leaching
to
a
maximum
depth
of
6"
following
the
first
application
in
California
plots
and
to
a
maximum
depth
of
24"
following
the
first
and
second
applications
in
Georgia
plots;
leaching
to
24"
was
attributed
to
vegetative
matter
being
disked
under.
At
the
analytical
sensitivity
of
the
method
().
01
ppm),
ETU
showed
no
evidence
of
leaching
below
the
top
3"
of
the
soil
in
either
California
or
Georgia.

e.
Bio­
accumulation
The
fish
bio­
accumulation
study
was
waived
based
on
reported
low
Kow
value
of
5
for
maneb.
Kow
value
indicates
low
potential
for
bio­
concentration
in
aquatic
organisms
such
as
fish.
28
V.
Water
Resource
Assessment
Parent
maneb
is
not
expected
to
be
present
in
significant
amounts
in
the
environment
except
for
short
duration
because
it
will
hydrolyze
rather
quickly
into
its
complex.
More
details
about
parent
maneb
EECs
are
presented
in
Appendix
I
(
section
b.
i).

This
water
resource
assessment
is
for
maneb
complex;
the
resultant
complex
from
expected
rapid
hydrolysis
of
parent
maneb
in
the
natural
environment.
Maneb
complex
was
determined
to
consist
of
a
suite
of
chemical
species:
transient
species
(
EBIS,
carbimid
and
TDIT),
ETU,
ETU
degradates
(
EU,
hydantoine
and
others),
and
the
significant
unknown
bound
species
(
suspected
of
containing
persistent
precursors
for
ETU).
Among
the
constituents
of
maneb
complex,
ETU
is
the
species
of
concern.
Therefore,
a
complete
water
resource
assessment
was
performed
for
ETU
while
only
surface
water
modeling
was
necessary
for
maneb
complex.
The
resultant
EECs
were
used
in
the
ecological
risk
assessment
of
maneb
complex.

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

Screening
assessments
for
maneb
complex
were
completed
using
the
linked
PRZM
and
EXAMS
models.
PRZM/
EXAMS
input
values
are
listed
in
Table
V­
1
and
the
results
in
Table
V­
2.
This
data
were
used
for
estimating
EECs
necessary
for
the
ecological
risk
assessment
of
maneb
complex.

Table
V­
1.
PRZM/
EXAMS
Input
Parameters
for
maneb
complex*.

Input
Parameter
Value
Reference
Molecular
Weight
(
grams)
265.36
Registrant
data
Vapor
Pressure
(
torr)
7.577
e­
8
Registrant
data
Bacterial
Bio­
lysis
in
the
water
column
(
days)
0
(
Stable)
Guidance**
because:
No
aerobic
aquatic
metabolism
study/
significant
hydrolysis
Bacterial
Bio­
lysis
in
benthic
sediment
(
days)
0
(
Stable)
MRID
001633­
35
Aerobic
Soil
Metabolism
Half­
life
(
days)
271
Upper
confidence
bound
on
the
mean
for
three
soils
(
MRIDs
405852­
01
and
451452­
02).

Application
Method
Aerial
Product
Label
Depth
of
Incorporation
(
inches)
0
Product
Label
Application
Efficiency
(
fraction)
0.95
Guidance**

Spray
Drift
(
fraction)
0.05
Guidance**
Input
Parameter
Value
Reference
29
Solubility
(
mg/
L
or
ppm)
150
Registrant
data
Koc
(
L
Kg­
1)
946
Average
for
eight
soils
(
MRIDs
405852­
03,
400472­
01,
455959­
01,
and
455959­
02)

pH
7
Hydrolysis
Half­
life
(
days)
0.13
MRID
453936­
01
Photolysis
Half­
life(
days)
0
(
Stable)
MRID
404656­
02
*
Parent
maneb
Parameters
for
Molecular
Weight
(
grams);
Vapor
Pressure
(
torr);
Solubility
(
mg/
L
or
ppm);
and
pH
7
Hydrolysis
Half­
life
were
used.
**
Guidance
for
Chemistry
and
Management
Practice
Input
Parameters
For
Use
in
Modeling
the
Environmental
Fate
and
Transport
of
Pesticides,
Version
2/
November
7,
2000.

Table
V.
2.
PRZM/
EXAMS
output
EECs
for
maneb
complex*

Crop
Rate
(
lbs/
Acre)
Number
of
Applications
Interval
Peak
96
Hour
21
Day
60
Day
Annual
Average
Apples
(
NC)
4.8
4
7
84.0
14.4
4.1
1.8
0.3
Peppers
(
FL)
1.6
6
7
113.0
16.7
5.4
2.1
0.4
Potatoes
(
ME)
1.6
7
5
47.6
6.7
2.1
1.0
0.2
Tomatoes
(
FL)
1.6
7
7
197.9
31.6
9.2
4.0
0.7
b.
Ground
Water
Monitoring
and
Modeling
EFED
is
not
aware
of
ground
water
monitoring
data
for
maneb.
Monitoring
data
were
submitted
to
the
Agency
by
the
EBDC
only
for
the
degradate
of
concern
ETU,
this
data
will
be
discussed
separately
in
the
accompanied
RED
chapter
for
ETU.
No
ground
water
modeling
was
performed
for
maneb
complex
because
the
only
species
of
concern
is
ETU
for
which
modeling
can
be
found
in
the
accompanied
ETU
RED
chapter.

c.
Drinking
Water
Assessment
Assessments
for
surface/
ground
drinking
water
were
only
performed
for
the
degradate
of
concern,
ETU.
This
assessment
can
be
found
in
the
accompanied
chapter
for
ETU.
30
VI.
Aquatic
Exposure
and
Risk
Assessment
a.
Hazard
Summary
(
Acute/
Chronic)

Acutely,
maneb
is
very
highly
toxic
to
cold
water
(
freshwater)
fish
(
LC
50
=
42
ppb),
highly
toxic
to
slightly
toxic
to
warm
water
(
freshwater)
fish
(
LC
50
=
170
­
68,000
ppb)
and
highly
toxic
to
estuarine/
marine
fish
(
LC
50
=
180
ppb).
Early
life­
stage
chronic
freshwater
fish
NOAEC
and
LOAEC
values
were
determined
to
be
6.1
and
12
ppb,
respectively,
with
reduced
hatchability,
fish
survival
and
length
of
fry
being
the
endpoints
affected.
EFED
needs
a
freshwater
fish
life
cycle
test
using
the
TGAI
for
maneb.
EFED
needs
this
testing
because
the
end­
use
product
is
expected
to
be
transported
to
water
from
the
intended
use
site
and
EECs
are
greater
than
one­
tenth
of
the
NOAEC
in
the
fish
early
life­
stage.
The
PRZM­
EXAMS
modeled
peak
EECs
for
selected
sites
in
maneb's
current
use
patterns
range
from
47.6
ppb
for
potato
applications
to
197.9
ppb
for
tomato
applications.
Acute
toxicity
values
for
aquatic
invertebrates
suggest
that
maneb
is
highly
toxic
to
freshwater
invertebrates
(
Daphnia
EC
50
=
120
ppb)
and
highly
to
very
highly
toxic
to
estuarine/
marine
invertebrates
(
oyster
EC
50
=
280
ppb
and
mysid
shrimp
EC
50
=
3
ppb).
No
acceptable
data
has
been
filed
to
assess
the
chronic
effects
of
maneb
to
freshwater
invertebrates,
estuarine/
marine
invertebrates,
or
estuarine/
marine
fish.
EFED
needs
toxicity
tests
to
fulfill
these
needs
(
see
Appendix
III).
A
supplemental
Tier
II
aquatic
plant
growth
study
reviewed
on
maneb
showed
the
EC
50
was
13.4
ppb
and
the
NOAEC
was
5
ppb.
The
endpoint
affected
was
growth
inhibition.
The
test
species
in
the
study
was
green
algae
(
Selenastrum
capricornutum),
a
freshwater
nonvascular
plant.
There
was
no
data
filed
to
evaluate
the
affects
maneb
has
on
the
additional
aquatic
test
species:
duckweed
(
Lemna
gibba),
marine
diatom
(
Skeletonema
costatum),
blue­
green
algae
(
Anabaena
flos­
aquae),
and
a
freshwater
diatom.
Also,
EFED
needs
a
core
study
for
a
freshwater
green
alga
(
Selenastrum
capricornutum).
Aquatic
plant
growth
studies
at
the
Tier
I
or
Tier
II
level
(
guidelines
123­
1
or
123­
2,
respectively)
needs
to
be
submitted
for
these
species
(
see
Appendix
III).
Toxicological
Endpoints
Used
to
Determine
Aquatic
Risk
Quotients
(
RQs)
for
Maneb
are
presented
in
Table
VI­
1.

Table
VI­
1:
Toxicological
Endpoints
Used
to
Determine
Aquatic
Risk
Quotients
(
RQs)
for
Maneb
Type
of
Toxicity
Organism
Species
Toxicological
Endpoint
Acute
Freshwater
fish
rainbow
trout
(
Oncorhynchus
mykiss)
LC
50
=
42
ppb
Chronic
fathead
minnow
(
Pimephales
promelas)
NOAEC
=
6.1
ppb1
Acute
Freshwater
invertebrate
waterflea
(
Daphnia
magna)
LC
50
=
120
ppb
Chronic
no
data
no
data
Acute
Estuarine/
marine
fish
Atlantic
silverside
(
Menidia
menidia)
LC
50
=
180
ppb
Chronic
no
data
no
data
1.
Based
on
hatchability,
fish
survival
and
length
of
fry
2.
Estimated
level
because
of
high
variability
in
measured
concentrations;
analytical
procedures
were
not
able
to
detect
maneb
below
5
ppb.
31
The
EDBCs
(
metiram,
mancozeb,
and
maneb),
unlike
most
pesticide
active
ingredients
are
not
welldefined
monomeric
substances.
The
EBDCs
are
polymeric
complexes
and
are
nearly
insoluble
in
water
with
a
high
affinity
to
adsorption
by
soil
or
sediment
particles.
The
EBDC
portion
that
dissolves
in
water
and
breaks
up
into
a
suite
of
transient
species
and
degradates,
is
the
EBDC
complex.
This
complex
is
not
the
parent
material
by
itself.
Over
time
ETU
is
the
dominant
transformation
product
of
the
EDBCs.

Studies
provided
estimates
of
the
Parent
EBDC
material
in
test
concentrations
used
for
evaluating
the
toxicity
to
aquatic
organisms.
These
studies
showed
low
recoveries
of
the
test
substance.
For
example,
measuring
carbon
disulfide
(
CS
2
)
containing
residues,
using
gas
chromatography,
one
study
found
roughly
a
40%
±
10%
average
of
nominal
levels
of
the
"
parent
complexes".
Through
filtering
and
measuring
the
treatment
water,
the
recovery
of
"
parent
complexes"
was
around
15%
±
10%
average
of
nominal
levels
(
MRID
No.
43525001).
Filtering
of
the
test
solution
before
analytical
measurement
increases
the
accurate
measurement
of
the
test
material
in
solution
because
this
removes
the
undissolved
material
in
the
solution.
This
remaining,
soluble
portion
of
the
chemical
is
more
biologically
available
to
aquatic
organisms
and
represents
a
more
conservative
estimate
of
the
toxicity
to
these
organisms.
These
filtered
and
measured
"
parent
complexes",
is
the
portion
of
the
parent
material
that
is
available
to
aquatic
organisms
in
the
environment
(
see
Figure
VI­
1).

The
EPA's
Rejection
Rate
Analysis
determined
that
studies,
testing
materials
having
poor
water
solubility,
were
to
use
measured
as
opposed
to
nominal
concentrations.
Studies
were
to
use
measured
concentrations
for
fixing
aquatic
toxicological
endpoints
for
compounds
with
poor
32
solubility
(
US
EPA.
December,
1994).
EFED
believes
filtered
and
measured
samples
provide
a
more
conservative
estimate
of
the
EBDCs'
toxicity
to
aquatic
organisms.
Also,
EFED
believes
the
filtered
and
measured
samples
provide
a
more
true
estimate
of
aquatic
organism
exposure
to
the
EBDC
complexes
in
the
environment.

Modeling
estimates
using
PRZM­
EXAMS
are
also
estimating
EBDC
complexs
by
predicting
the
EECs
using
the
physicochemical
properties
of
the
EBDC,
parent
aerobic
soil
metabolism
half­
lives
and
sorption
coefficients.
Appendix
VI
shows
the
toxicity
to
aquatic
organisms
found
from
the
various
EBDC
aquatic
toxicological
studies.
These
endpoints
are
an
estimate
of
the
EBDC
complex
that
fixes
the
toxicities
(
that
is,
LC
50
s,
EC
50
s,
and
NOAECs).
The
modeling
EECs
are
also
estimates.
Influences
such
as
particle
size,
conditions
of
storage,
degree
of
decomposition,
pH,
and
the
presence
of
other
cations
(
see
Figure
VI­
1)
would
always
cause
difficulty
in
providing
definite
aquatic
toxicological
endpoints
for
the
EBDCs.

b.
Exposure
and
Risk
Quotients
Tier
II
modeling
(
PRZM/
EXAMS)
was
performed
for
selected
sites
for
which
EFED
currently
has
modeling
scenarios.
EFED
decided
to
perform
Tier
II
modeling
for
maneb
to
remain
consistent
with
the
modeling
platform
used
for
the
other
EBDCs
and
their
common
degradate,
ETU.
Also,
EFED
expects
Tier
II
modeling
provides
a
more
refined
EEC
estimate.
Below
(
Figure
VI­
2)
are
graphs
representing
maneb
complexes'
aquatic
risks
to
non­
target
organisms.
EFED
selected
representative
maneb
use
patterns
at
maximum
application
rates
and
minimum
intervals
between
applications.
For
a
more
detailed
listing
and
explanation
of
maneb's
risk,
see
Appendix
IV.
EFED
does
not
have
a
method
to
evaluate
chronic
risks
to
non­
target
aquatic
plants.

The
results
show:
1)
The
acute
RQs
exceed
freshwater
fish
acute,
acute
restricted
use,
and
acute
endangered
species
LOCs
for
all
maneb
uses
(
acute
RQ
ranges
from
1.13
to
4.71).
No
chronic
LOCs
are
exceeded
for
freshwater
fish
from
maneb's
uses..
2)
The
freshwater
invertebrates'
acute
RQs
exceed
acute,
acute
restricted
use,
and
acute
endangered
species
LOCs
for
maneb's
use
on
apples,
tomatoes
and
peppers.
Restricted
use
and
acute
endangered
species
LOCs
are
exceeded
for
all
maneb
uses
(
acute
RQ
ranges
from
0.4
to
1.65).
3)
The
estuarine/
marine
fish
acute
RQs
exceed
acute,
acute
restricted
use,
and
acute
endangered
species
LOCs
for
maneb
uses
on
tomatoes
and
peppers.
Restricted
use
and
acute
endangered
species
LOCs
are
exceeded
for
all
maneb
uses
(
acute
RQ
ranges
from
0.26
to
1.1).
4)
The
estuarine/
marine
invertebrate
acute
RQs
exceed
acute,
acute
restricted
use,
and
acute
endangered
LOCs
for
all
maneb
uses
(
acute
RQ
ranges
from
15.87
to
65.97).
There
are
currently
no
estuarine/
marine
invertebrates
listed
as
endangered
species.
5)
All
maneb's
use
patterns
exceed
acute
risk
LOCs
for
nonvascular
aquatic
plants
(
acute
RQ
ranges
from
3.55
to
14.77).
There
are
no
nonvascular
aquatic
plants
listed
as
endangered
species.
33
0.01
0.1
1
10
100
Risk
Quotient
Potato
(
Maine,
only)
Apples
Pepper
(
a)
Tomato
(
b)

Sites
Estuarine/
Marine
Fish
Acute
Freshwater
Invertebrates
Acute
Freshwater
Fish
Acute
Aquatic
Non­
Vascular
Plants
Acute
Estuarine/
Marine
Invertebrates
Acute
Freshwater
Fish
Chronic
Maneb
Aquatic
Risks
Based
on
PRZM­
EXAMS
Modeling
Figure
VI­
2
RQ
greater
or
equal
to
1.0
exceeds
aquatic
plant
acute
and
acute
endangered
species
LOCs.
RQ
greater
or
equal
to
0.5
exceeds
aquatic
animal
acute,
acute
restricted
use
and
acute
endangered
species
LOCs.
RQ
greater
or
equal
to
0.1
exceeds
aquatic
animal
acute
restricted
use
and
acute
endangered
species
LOCs
RQ
greater
or
equal
to
0.05
exceeds
aquatic
animal
acute
endangered
species
LOCs
RQ
greater
or
equal
to
1
exceeds
aquatic
animal
chronic
LOCs.
There
are
currently
no
estuarine/
marine
invertebrates
or
non­
vascular
aquatic
plant
species
listed
as
endangered
species.
a
East
of
the
Mississippi
River
(
1.6
lb
ai/
A
is
a
W.
of
Miss.
R.
rate
for
peppers.
2.4
lb
ai/
A
6
times
every
7
days
is
the
E.
of
Miss.
R.
rate
 
the
scenario
is
FL)
b
East
of
the
Mississippi
River
34
c.
Aquatic
Risk
Assessment
Dose/
response
slope
values
for
the
toxicological
endpoints
(
see
Table
V­
1)
used
to
calculate
aquatic
RQs
for
maneb
complex
were
reported
in
the
studies
used
to
determine
these
endpoints.
EFED
estimated
the
highest
maneb
complex
aquatic
EEC
expected
from
drift
and
runoff
would
be
197.9
ppb.
Based
on
this
residue
level
and
individual
laboratory
studies
EFED
estimated
the
likelihood
of
adverse
maneb
complex
effects
to
individual
organisms
across
taxa.
These
chance
estimates
show
there
is
high
likelihood
(
that
is,
57
to
100%)
of
adverse
acute
effects
to
individual
freshwater
and
estuarine/
marine
aquatic
organisms
from
maneb
complex.
EFED
calculated
this
range
using
Equation
VI­
1.
For
the
highest
peak
maneb
complex
the
results
show:

1)
The
acute
RQs
exceed
freshwater
fish
acute,
acute
restricted
use,
and
acute
endangered
species
LOCs
for
all
maneb
uses
(
acute
RQ
ranges
from
1.13
to
4.71).
The
highest
peak
maneb
complex
aquatic
EEC
expected
from
drift
and
runoff
is
197.9
ppb.
This
value
is
the
estimated
aquatic
concentrations
based
on
maneb's
applications
to
tomatoes.
At
this
concentration
the
likelihood
of
adverse
maneb
complex
effects
to
individual
freshwater
fish
is
1
in
1
or
100%.
EFED
calculated
this
chance
estimate
using
a
freshwater
fish
acute
LC
50
=
42
ppb
and
slope
=
2.8
from
MRID
No.
40706001
and
LC
k
=
197.9
ppb
using
equation
VI­
1.
No
chronic
LOCs
are
exceeded
for
freshwater
fish
from
maneb's
uses.

2)
The
freshwater
invertebrates'
acute
RQs
exceed
acute,
acute
restricted
use,
and
acute
endangered
species
LOCs
for
maneb's
use
on
apples,
tomatoes
and
peppers.
Restricted
use
and
acute
endangered
species
LOCs
are
exceeded
for
all
maneb
uses
(
acute
RQ
ranges
from
0.4
to
1.65).
At
the
peak
maneb
complex
aquatic
EEC
expected
from
drift
and
runoff
of
197.9
ppb,
the
likelihood
of
adverse
maneb
complex
effects
to
individual
freshwater
invertebrates
is
4
in
5
or
80%.
EFED
calculated
this
chance
estimate
using
a
freshwater
invertebrate
acute
LC
50
=
120
ppb
and
slope
=
4.2
from
MRID
No.
40749402
and
LC
k
=
197.9
ppb.

3)
The
estuarine/
marine
fish
acute
RQs
exceed
acute,
acute
restricted
use,
and
acute
endangered
species
LOCs
for
maneb
uses
on
tomatoes
and
peppers.
Restricted
use
and
acute
endangered
species
LOCs
are
exceeded
for
all
maneb
uses
(
acute
RQ
ranges
from
0.26
to
1.1).
At
the
peak
maneb
complex
aquatic
EEC
expected
from
drift
and
runoff
of
197.9
ppb,
the
likelihood
of
adverse
maneb
complex
effects
to
individual
estuarine/
marine
fish
is
more
than
1
in
2
or
57%.
EFED
calculated
this
chance
estimate
using
a
estuarine/
marine
fish
acute
LC
50
=
180
ppb
and
slope
=
4.2
from
MRID
No.
40943101
and
LC
k
=
197.9
ppb.

4)
The
estuarine/
marine
invertebrate
acute
RQs
exceed
acute,
acute
restricted
use,
and
acute
endangered
LOCs
for
all
maneb
uses
(
acute
RQ
ranges
from
15.87
to
65.97).
There
are
currently
no
estuarine/
marine
invertebrates
listed
as
endangered
species.
At
the
peak
maneb
complex
aquatic
EEC
expected
from
drift
and
runoff
of
197.9
ppb,
the
likelihood
of
adverse
maneb
complex
effects
probit
k
=
(
log
LC
­
log
LC
)
*
slope
+
probit
50%

k
=
new
percentage
mortality
k
50
Equation
VI­
1
35
to
individual
estuarine/
marine
invertebrate
is
1
in
1
or
100%.
EFED
calculated
this
chance
estimate
using
a
estuarine/
marine
invertebrate
acute
LC
50
=
3
ppb
and
slope
=
3.5
from
MRID
No.
41000002
and
LC
k
=
197.9
ppb.

5)
All
maneb's
use
patterns
exceed
acute
risk
LOCs
for
nonvascular
aquatic
plants
(
acute
RQ
ranges
from
3.55
to
14.77)..
There
are
no
nonvascular
aquatic
plants
listed
as
endangered
species.
At
the
peak
maneb
complex
aquatic
EEC
expected
from
drift
and
runoff
of
197.9
ppb,
the
likelihood
of
adverse
maneb
complex
effects
to
individual
nonvascular
aquatic
plants
is
1
in
1
or
100%.
EFED
calculated
this
chance
estimate
using
a
nonvascular
aquatic
plants
LC
50
=
13.4
ppb;
LC
k
=
197.9
ppb;
and
slope
=
4.8
from
MRID
No.
40943501.

These
chance
estimates
show
there
is
high
likelihood
(
that
is,
$
57
%)
of
adverse
acute
effects
to
individual
freshwater
and
estuarine/
marine
aquatic
organisms.
EFED
expects
adverse
effects
to
these
aquatic
organisms
at
maximum
predicted
maneb
complex
aquatic
exposure
levels.
Incident
reported
data
supports
this
expectation
in
at
least
one
report
from
EIIS
(
see
below).
EFED
does
not
have
acute
toxicity
data
to
estimate
the
likelihood
of
adverse
effects
to
vascular
aquatic
plants.

i.
Incidents
The
Ecological
Incident
Information
System
(
EIIS)
(
see
Appendix
V
for
background
information)
reported
maneb
in
three
fish
kill
incidents.
An
incident
(
Incident
No.
B000­
223),
occurring
in
August,
1973,
reported
by
the
Oregon
Department
of
Agriculture
showed
some
fish
in
a
15
acre
pond
had
been
killed.
Presumably
drift
from
an
aerial
application
of
maneb
and
endosulfan
to
potatoes
caused
the
kill.
No
analyzes
of
the
dead
fish
was
provided.
Both
maneb
and
endosulfan
are
very
highly
toxic
to
freshwater
fish
[
maneb
rainbow
trout
LC50
=
42.0
ppb
and
endosulfan
rainbow
trout
LC50
=
0.37
ppb
(
US
EPA.
2001)]
and
both
pesticides
could
have
been
responsible
for
the
fish
kill,
if
in
fact
the
kill
was
pesticide
related.
However,
the
inadequate
information
provided
with
this
reported
incident
and
the
lack
of
laboratory
analyzes
makes
it
difficult
to
charge
this
fish
kill
to
either
pesticide.

The
second
maneb
related
incident
(
Incident
No.
I003826­
030)
occurred
in
June,
1994
and
was
reported
by
the
North
Carolina
Department
of
Agriculture.
The
owner
of
a
2.5
acre
commercial
fishpond
filed
a
complaint
of
a
fish
kill
in
the
pond
because
of
drift
from
applications
of
maneb,
trifluralin,
imazaquin,
pendimethalin,
and
acephate
aerially
applied
to
corn
and
soybean
fields
near
the
pond.
The
owner
felt
the
fish
kill
was
a
result
of
drift
from
these
pesticides.
The
North
Carolina
Department
of
Agriculture
investigated
this
complaint
and
took
samples
for
analyzes
but
the
sampling
evidence
did
not
confirm
the
presence
of
maneb
or
the
other
pesticides
listed
in
the
samples
taken.
Based
on
the
investigation
and
the
analysis
of
samples,
it
is
unlikely
that
maneb
contributed
to
this
fish
kill.

The
final
maneb
related
incident
(
Incident
Nos.
I002200­
001
and
I003596­
001),
occurring
in
August,
1994,
was
reported
by
the
Maine
Department
of
Agriculture.
In
this
incident
roughly
10,000
newly
released
brook
trout
were
killed
in
a
pond
that
borders
New
Brunswick,
Canada
and
Maine.
Three
pesticides
(
maneb,
esfenvalerate,
and
chlorothalonil)
recently
applied
to
potatoes
surrounding
this
36
pond
were
suspected
in
this
fish
kill.
Tissue
samples
of
the
fish
confirmed
the
presence
of
all
three
pesticides
(
maneb
at
169
ppb,
esfenvalerate
at
4.2
ppb,
and
chlorothalonil
at
20
ppb)
in
the
fish.
These
fish
samples
were
taken
from
both
the
pond
and
brooks
feeding
the
pond.
Again,
as
in
the
first
incident,
all
three
of
these
pesticides
are
very
highly
toxic
to
freshwater
fish.
Maneb's
rainbow
trout
LC50
is
42.0
ppb,
esfenvalerate's
rainbow
trout
LC50
is
0.26
ppb
(
Hicks,
L.
May,
1995)
and
chlorothalonil's
rainbow
trout
LC50
is
42.3
ppb
(
US
EPA.
1998)].
The
submitter
of
the
incident
report
pointed
out
there
were
severe
thunderstorms
in
the
area
preceding
the
fish
kill
which
suggest
pesticide
runoff
was
a
cause
in
this
kill.
Based
on
sampling
evidence,
EFED
believes
maneb
was
contributory
cause
in
this
fish
kill.

ii.
Endocrine
Disruptors
Chronic
testing
in
freshwater
fish
showed
reduced
hatchability,
fish
survival
and
length
of
fry
being
the
endpoints
affected
in
fathead
minnow.
See
Appendix
III
for
a
detailed
listing
of
the
study
and
results.
These
effects
noted
in
a
freshwater
fish
species
may
be
a
result
of
hormonal
disruptions.
Based
on
these
effects
in
freshwater
fish,
EFED
recommends
maneb
be
subjected
to
more
definitive
testing
to
better
characterize
effects
related
to
its
potential
endocrine
disruption.
This
testing
should
occur
when
EPA
develops
suitable
screening
and
testing
protocols,
considered
under
the
Agency's
EDSP.

iii
Endangered
Species
Based
on
available
screening
level
information
there
is
a
potential
concern
for
maneb's
acute
effects
on
listed
freshwater
and
estuarine/
marine
animals
should
exposure
actually
occur.
There
are
no
nonvascular
aquatic
plant
or
estuarine/
marine
invertebrate
species
on
the
endangered
species
list.
EFED
does
not
have
toxicological
data
to
evaluate
the
chronic
endangered/
threatened
species
risk
to
freshwater
invertebrates
or
estuarine/
marine
fish
from
maneb's
use.
Based
on
EFED's
maneb
complex
calculated
RQs,
EFED
expects
the
chronic
risks
to
endangered
and
threatened
species
of
freshwater
fish
to
be
low.
The
highest
freshwater
fish
chronic
RQ
calculated
is
0.66
which
is
below
the
chronic
LOC
of
1.
37
VII.
Terrestrial
Exposure
and
Risk
a.
Hazards
Summary
(
Acute/
Chronic)

Maneb
is
categorized
as
practically
nontoxic
to
avian
species
on
an
acute
oral
basis
(
Northern
bobwhite
quail
LD
50
>
2,150
mg/
kg).
Avian
subacute
dietary
tests
were
conducted
using
Northern
bobwhite
quail
and
mallard
duck
as
test
species.
The
maneb
dietary
LC
50
for
birds
ranged
from
greater
than
5,000
ppm
in
mallard
ducks
to
greater
than
10,000
ppm
in
bobwhite
quails.
This
categorizes
maneb
as
practically
nontoxic
to
avian
species
on
a
subacute
dietary
basis.
In
a
maneb
avian
reproduction
study
using
the
mallard
duck,
chronic
toxic
effects
were
seen
which
included:
a
reduction
in
the
number
of
hatchlings
as
percentages
of
eggs
laid,
eggs
set,
and
live
3­
week
old
embryos,
and
a
reduction
in
the
number
of
14­
day
old
survivors
as
a
percentage
of
eggs
set.
The
reproduction
NOAEC/
LOAEC
is
20/
100
ppm.
A
Northern
bobwhite
quail
reproduction
study
was
classified
as
supplemental
because
a
LOAEC
was
not
determined.
At
the
highest
dose
tested
(
500
ppm)
no
adverse
effects
were
noted.
Collectively,
the
mallard
is
the
more
sensitive
species
for
the
EBDC's,
and
will
be
used
for
risk
assessment
purposes.
Mallard
duck
reproduction
NOAECs
for
mancozeb
and
metiram
are
10
ppm
and
50
ppm,
respectively.
Bobwhite
quail
NOAECs
for
mancozeb
and
metiram
are
125­
300
ppm
and
>
500
ppm,
respectively.

Maneb
is
practically
nontoxic
to
small
mammals
on
an
acute
oral
basis
with
LD
50
>
5,000
mg/
kg
in
tests
done
on
laboratory
rats.
Results
from
chronic
2­
generation
reproduction
study
for
maneb
show
a
parental
and
fetal
toxicity
at
a
LOAEL
of
300
ppm
(
NOAEL
=
75
ppm)
with
paternal
parental
toxicity
resulting
in
significant
increase
in
lung
weight
(
both
generations)
and
liver
weight
in
F1
(
one
generation
removed
from
the
original
parent
generation)
and
an
increased
incidence
of
diffuse
follicular
epithelial
hypertrophy/
hyperplasia
(
lesions
on
the
organs'
surfaces)
in
F1.
Fetal
toxicity,
at
this
test
concentration
(
300
ppm),
was
also
noted
based
on
a
slight
delay
in
the
startle
response
in
the
offspring
(
NOAEL
=
75
ppm).

Currently,
EFED
does
not
assess
risk
to
non­
target
insects
using
risk
quotient
methodology.
Results
of
acceptable
studies
are
used
for
recommending
appropriate
label
precautions.
Since
maneb
was
determined
to
be
practically
nontoxic
to
honey
bees
(
LD
50
>
12
µ
g/
bee)
no
bee
precautionary
labeling
is
required
on
maneb
product
labeling.

EFED
has
not
received
any
non­
target
terrestrial
plant
studies
and
is
unable
to
assess
the
risk
to
nontarget
terrestrial
plants
as
a
result
of
maneb's
uses.
The
submission
of
Tier
I
seedling
emergence
and
vegetative
vigor
studies
for
a
TEP
are
being
recommended
to
evaluate
this
risk.

For
a
more
detailed
listing
and
explanation
of
maneb's
hazards
to
all
terrestrial
organisms,
see
Appendix
III.
38
Table
VII­
1:
Toxicological
Endpoints
Used
to
Determine
Risk
Quotients
(
RQs)
for
Maneb
Type
of
Toxicity
Organism
Species
Toxicological
Endpoint
Chronic
Bird
mallard
duck
(
Anas
platyrhynchos)
NOAEC
=
20
ppm
Chronic
Mammal
laboratory
rat
(
Rattus
norvegicus)
NOAEL
=
75
ppm
b.
Exposure
Summary
Terrestrial
exposure
was
evaluated
using
estimated
environmental
concentrations
generated
from
the
FATE
version
5.0
model
that
calculates
the
decay
of
a
chemical
applied
to
foliar
surfaces
for
single
or
multiple
applications.
The
model
assumes
initial
concentrations
on
plant
surfaces
based
on
Kenaga
predicted
maximum
and
mean
residues
as
modified
by
Fletcher
et
al.
(
1994)
and
assumes
1st
order
dissipation.
Kenaga
estimates
and
an
explanation
of
the
model
with
sample
output
are
presented
in
Appendix
II.
A
3.2­
day
half­
life
was
used
as
the
foliar
dissipation
half­
life
for
maneb.
The
selection
of
this
half­
life
was
based
on
the
highest
value
provided
in
the
half­
life
listing
of
Willis
and
McDowell,
1987
for
maneb.
This
half­
life
value
is
based
on
total
foliar
residues
not
dislodgeable
foliar
residues
and
was
determined
in
a
study
by
Rhodes,
1977
performed
on
tomatoes.
EFED
use
the
half­
life
listing
values
provided
in
Willis
and
McDowell,
1987
for
modeling
purposes
to
estimate
total
foliar
residues
half­
lives.

c.
Risk
Quotients
The
acute
risk
to
terrestrial
animals
from
maneb's
use
are
a
low
risk
concern
since
maneb
has
been
determined
to
be
practically
nontoxic
to
birds
and
mammals
on
an
acute
basis.
Acute
RQs
were
not
generated
for
birds
or
mammals.
Chronic
concerns
to
terrestrial
animals
are
exceeded
when
the
RQ
reaches
1.0.
Below
(
figures
VII­
1
through
VII­
4)
are
graphs
representing
maneb's
potential
chronic
risks
to
non­
target
terrestrial
birds
and
mammals.
These
graphs
show
the
chronic
RQs
EFED
expects
from
terrestrial
animals
feeding
on
the
food
items
listed.
39
1
10
100
1,000
Risk
Quotient
(
RQ)

Turf
Almonds
Apples
Cranberry
Grapes
Onion
&
Garlic
Onion
(
green)/
Tomato
PepperGrapes
Bananas
Corn
(
pop
&
sweet)

Sites
Mean
for
Fruits,
Pods,
Seeds,
and
Large
Insects
Max.
for
Fruits,
Pods,
Seeds,
and
Large
Insects
Mean
for
Tall
grass
Mean
for
Broadleaf/
Forage
Plants
&
Small
Insects
Mean
for
Short
grass
Max.
for
Tall
grass
Max.
for
Broadleaf/
Forage
Plants
&
Sma
Max.
for
Short
grass
Maneb
Avian
Chronic
Risk
Maximum
and
Mean
Risk
Figure
VII­
1
40
1
10
100
Risk
Quotient
(
RQ)

Potato
(
Maine,
only)
Potato
Beans
(
dried)
Corn
(
pop
&
sweet)
Fig
Papaya
Cucumber,
etc.
Eggplant/
Sugar
Beets
Pepper
Broccoli,
etc.
Tomato
Kale
Ornamentals
Collards/
Turnip
Mustard
(
GA
&
TN,
only)

Sites
Mean
for
Fruits,
Pods,
Seeds,
and
Large
Insects
Max.
for
Fruits,
Pods,
Seeds,
and
Large
Insects
Mean
for
Tall
grass
Mean
for
Broadleaf/
Forage
Plants
&
Small
Insects
Mean
for
Short
grass
Max.
for
Tall
grass
Max.
for
Broadleaf/
Forage
Plants
&
S
Max.
for
Short
grass
Maneb
Avian
Chronic
Risk
Maximum
and
Mean
Risk
Figure
VII­
2
These
chronic
RQs
are
derived
from
EECs
based
on
the
maximum
and
mean
residue
estimates
(
see
Appendix
II)
EFED
expects
on
these
food
items
following
maneb's
applications
to
various
sites
shown.
For
example,
the
chronic
RQ
for
birds
feeding
on
short
grass
as
a
result
of
maneb
being
applied
to
turf
is
over
200
at
maximum
residue
levels
and
over
90
at
mean
residue
levels
(
see
figure
VII­
1).
As
can
be
seen
from
these
graphs,
all
maneb's
uses
exceed
chronic
LOCs
for
birds
and
for
mammals.
As
a
result
of
maneb's
applications
to
turf,
the
chronic
exceedances
to
birds
range
from
a
high
RQ
of
265
(
figure
VII­
1)
from
birds
feeding
on
short
grass
low
of
8
(
figure
VII­
1)
from
birds
feeding
on
fruits,
pods,
seeds
and
large
insects.
41
1
10
100
Risk
Quotient
(
RQ)

Turf
Almonds
Apples
Cranberry
Grapes
Onion
&
Garlic
Onion
(
green)/
Tomato
PepperGrapes
Bananas
Corn
(
pop
&
sweet)

Sites
Mean
for
Fruits,
Pods,
Seeds,
and
Large
Insects
Max.
for
Fruits,
Pods,
Seeds,
and
Large
Insects
Mean
for
Tall
grass
Mean
for
Broadleaf/
Forage
Plants
&
Small
Insects
Mean
for
Short
grass
Max.
for
Tall
grass
Max.
for
Broadleaf/
Forage
Plants
&
Smal
Max.
for
Short
grass
Maneb
Mammalian
Chronic
Risk
Maximum
and
Mean
Risk
Figure
VII­
3
For
mammals,
the
range
of
RQ
exceedances,
from
maneb
turf
applications,
is
from
a
high
of
71
(
figure
VII­
3)
from
birds
feeding
on
short
grass
to
a
low
of
2
(
figure
VII­
3)
from
birds
feeding
on
fruits,
pods,
seeds
and
large
insects.
These
potential
risks
are
based
on
maneb's
current
use
patterns
at
maximum
application
rates
and
minimum
intervals
between
applications.
It
should
also
be
noted
that
the
applications
of
maneb
to
ornamentals
and
turf
assumed
3
applications
per
crop
cycle
since
the
labeling
did
not
indicate
the
number
of
applications
that
could
be
made.
Even
at
this
relatively
low
number
of
applications
chronic
LOC
exceedances
are
high.
42
1
10
Risk
Quotient
(
RQ)

Potato
(
Maine,
only)
Potato
Beans
(
dried)
Corn
(
pop
&
sweet)
Fig
Papaya
Cucumber,
etc.
Eggplant/
Sugar
Beets
PepperBroccoli,
etc.
Tomato
Kale
Ornamentals
Collards/
Turnip
Mustard
(
GA
&
TN,
only)

Sites
Mean
for
Fruits,
Pods,
Seeds,
and
Large
Insects
Max.
for
Fruits,
Pods,
Seeds,
and
Large
Insects
Mean
for
Tall
grass
Mean
for
Broadleaf/
Forage
Plants
&
Small
Insects
Mean
for
Short
grass
Max.
for
Tall
grass
Max.
for
Broadleaf/
Forage
Plants
&
Smal
Max.
for
Short
grass
Maneb
Mammalian
Chronic
Risk
Maximum
and
Mean
Risk
Figure
VII­
4
The
assumption
of
100
gallons
of
finished
spray
per
acre
treated
was
also
an
assumption
made
for
the
application
of
maneb
to
ornamentals.
If
lower
finished
spray
rates
are
used
then
the
pounds
of
maneb
applied
per
acre
are
even
greater
than
assumed
which
would
increase
the
potential
risk
to
nontarget
organisms.
For
some
sites,
there
are
geographic
limitations
on
the
use
pattern.
For
example,
the
charts
(
figures
VII­
1
through
VII­
4)
will
provide
two
use
patterns
for
maneb's
application
to
grapes.
One
use
pattern
pertains
to
applications
of
maneb
to
grapes
east
of
the
Rocky
Mountains
at
higher
application
rates
providing
greater
risk
and
the
other
listing
of
grapes
pertains
to
maneb
applications
west
of
the
Rocky
Mountains.
Please
refer
to
Table
II­
1,
above,
for
additional
geographic
limitations.

For
a
more
detailed
listing
and
explanation
of
maneb's
risk
to
all
terrestrial
organisms,
see
Appendix
IV.
43
Maneb's
Residue
from
Potato
Use
Based
on
Fate
v.
5.0
Modeling
0
100
200
300
400
500
600
1
4
7
10
13
16
19
22
25
28
31
34
37
40
43
46
49
52
55
58
61
64
Day
ppm
Maneb's
Avian
NOAEC
=
20
ppm
Maneb's
Mammalian
NOAEL
=
75
ppm
Maximum
Residue
on
Short
Grass
Maximum
Residue
on
Broadleaf
/
Forage
Plants
&
Small
Insects
Maximum
Residue
on
Tall
grass
Mean
Residue
on
Short
grass
Mean
Residue
on
Broadleaf
/
Forage
Plants
&
Small
Insects
Mean
Residue
on
Tall
grass
Maximum
Residue
on
Fruits,
Pods,
Seeds,
and
Large
Insects
Mean
Residue
on
Fruits,
Pods,
Seeds,
and
Large
Insects
Figure
VII­
5
d.
Terrestrial
Risk
Assessment
The
annual
estimate
of
maneb
total
domestic
usage
averaged
approximately
2,500,000
pounds
active
ingredient
(
a.
i.)
for
over
600,000
US
acres
treated.
Approximately
550,000
lbs
ai
of
maneb
is
applied
annually
to
120,000
acres
of
US
potatoes.
(
EPA
use
data
1987­
1996)
(
BEAD's
Quantitative
Usage
Analysis
for
Maneb
dated
10/
1/
1998).
Maneb
can
be
applied
at
the
maximum
rate
of
1.6
lb
ai/
A,
7
times
per
season
every
5
days
during
the
foliar
stages
of
potatoes.
In
the
state
of
Maine,
maneb
can
be
applied
at
the
maximum
rate
of
1.6
lb
ai/
A,
10
times
per
season
every
5
days
during
the
foliar
stages
of
potatoes
(
see
table
1,
above).
Pheasant,
partridge,
pigeon,
dove,
duck,
geese,
songbirds,
antelope,
and
cottontail
rabbits
feed
in
potato
fields
on
insects,
vegetation
in
the
treated
area,
or
on
the
potato
plants
throughout
the
potato
growing
season
(
Gusey
and
Maturdo,
1972)
which
lasts
90­
140
days
(
depending
upon
the
potato
variety)
from
late
Spring
to
early
Fall.
Figure
VII­
5,
based
on
the
maximum
application
rate
of
1.6
lb
ai/
A,
applied
7
times
per
season
every
5
days,
represents
an
example
of
the
maneb
residues
that
can
be
expected
on
various
avian
and
mammalian
food
items
over
time
after
an
initial
maneb
application
to
potatoes
on
Day
1
and
six
subsequent
application
at
5
day
intervals.
Maneb's
avian
and
mammalian
reproductive
NOAEC
(
20
ppm)
and
NOAEL
(
75
ppm),
respectively,
are
also
indicated
in
Figure
VII­
5
as
horizontal
lines.
Residue
levels
above
these
lines
pose
a
potential
risk
of
adverse
reproductive
effects
to
the
birds
and/
or
mammals
feeding
on
these
food
items.
For
birds
feeding
on
short
grass
this
potential
risk
begins
on
Day1
44
(
maneb
residues
=
384
ppm)
and
continues
through
Day
46
(
maneb
residues
=
23
ppm)
for
a
total
exposure
risk
period
of
46
days.
For
mammals,
this
same
potential
risk
from
feeding
on
short
grass
also
begins
on
Day1
and
continues
through
Day
40
(
maneb
residues
=
83
ppm)
for
a
total
chronic
exposure
risk
period
of
40
days.

Maneb's
use
on
potatoes
is
one
example
of
the
potential
chronic
risk
posed
by
maneb's
use
to
wildlife.
Figure
VII­
6
provides
the
potential
chronic
risk
to
birds
and
mammals
from
maneb's
use
on
turf
which
can
be
applied
at
a
maximum
single
application
rate
of
17.4
lb
ai/
A
(~
11
times
higher
than
the
potato
rate)
every
7
days.
The
number
of
applications
of
maneb
to
turf
is
not
specified
on
the
labeling
and
as
a
result
an
assumption
of
3
applications
per
season
is
being
made
although
this
could
be
an
under
estimate.
For
birds
feeding
on
short
grass
this
potential
risk
begins
on
Day1
(
maneb
residues
=
4,176
ppm)
and
continues
through
Day
40
(
maneb
residues
=
24
ppm)
for
a
total
exposure
risk
period
of
40
days.
For
mammals,
this
same
potential
risk
from
feeding
on
short
grass
also
begins
on
Day1
and
continues
through
Day
34
(
maneb
residues
=
86
ppm)
for
a
total
exposure
risk
period
of
34
days.
45
Maneb's
Residue
from
Turf
Use
Based
on
Fate
v.
5
Modeling
0.1
1
10
100
1000
10000
1
3
5
7
9
11
13
15
17
19
21
23
25
27
29
31
33
35
37
39
41
Day
ppm
Maneb's
Avian
NOAEC
=
20
ppm
Maneb's
Mammalian
NOAEL
=
75
ppm
Maximum
Residue
on
Short
Grass
Maximum
Residue
on
Broadleaf
/
Forage
Plants
&
Small
Insects
Maximum
Residue
on
Tall
grass
Mean
Residue
on
Short
grass
Mean
Residue
on
Broadleaf
/
Forage
Plants
&
Small
Insects
Mean
Residue
on
Tall
grass
Maximum
Residue
on
Fruits,
Pods,
Seeds,
and
Large
Insects
Mean
Residue
on
Fruits,
Pods,
Seeds,
and
Large
Insects
Figure
VII­
6
16
Rate
reductions
determined
by
randomly
imputing
application
rates
into
ELL­
Fate
spreadsheet
program
until
the
avian
chronic
risk
to
birds
from
maneb
residues
on
short
grass
is
less
than
or
equal
to
1.

46
Although
potatoes
and
turf
are
used
as
examples
of
the
wildlife
exposure
that
can
be
expected
from
maneb's
registered
uses,
all
the
sites
maneb
is
currently
being
used
on
(
see
Table
II­
1)
would
have
comparable
exposure
levels
with
similar
potential
risks
to
wildlife.

In
this
screening
level
assessment,
maneb's
high
application
rates
combined
with
repeat
applications
are
a
major
reason
why
avian
and
mammalian
LOCs
are
exceeded.
Single
application
rates
range
from
1.2
lb
ai/
A
on
collards,
turnips,
and
mustard
to
17.4
lb
ai/
A
on
turf.
Labeling
allows
repeat
applications
at
these
maximum
rates
for
all
maneb's
uses.
These
high
applications
rates
with
repeat
applications
increases
the
exposure
of
maneb
to
nontarget
organism.
High
exposure
is
the
reason
for
high
RQs.
One
way
to
grasp
the
impact
of
the
high
exposure
is
to
use
modeling
to
estimate
the
reductions
needed
to
reduce
the
EECs
below
the
LOCs.
Using
modeling
to
calculate
EECs
below
LOCs
is
simply
a
rough
estimate
but
does
provide
some
insight
into
the
extent
maneb's
application
rates
contributes
to
potential
chronic
risk
to
birds
and
mammals.

To
reduce
the
exposure
risk
to
birds
and
mammals
from
manebs's
use
on
potatoes,
the
maximum
single
application
rate
would
need
to
be
reduced
from
the
current
1.6
lb
ai/
A
to
0.05
lb
ai/
A
(
see
figure
VII­
7)
16.
This
calls
for
a
32­
fold
decrease
in
the
maximum
application
rate
of
maneb
on
potatoes.
A
combination
of
rate
drops
with
a
decrease
in
the
number
of
applications
per
growing
season
could
also
be
used
to
lessen
the
EECs.
However,
to
reduce
the
potential
chronic
EEC
exposure
risk,
essentially
only
1
maneb
application
could
be
made
to
potatoes
at
a
maximum
application
rate
of
0.08
lb
ai/
A
(
see
figure
VII­
8).
This
translates
to
a
20­
fold
application
rate
decrease
and
cuts
out
all
multiples
applications.
Current
labeling
allows
seven
maneb
applications
on
potatoes.
47
Maneb
Chemical
Name:
Potatoes
Use
non­
granular
Formulation
Inputs
lbs
a.
i./
acre
0.05
Application
Rate
days
3.2
Half­
life
days
5
Application
Interval
7
Maximum
#
Apps./
Year
Outputs
56
Day
Average
Maximum
Concentration
Concentration
(
PPM)
(
PPM)
7.70
18.13
Short
Grass
3.53
8.31
Tall
Grass
4.33
10.20
Broadleaf
plants/
Insects
0.48
1.13
Seeds
5000
Acute
LC50
(
ppm)
Avian
20
Chronic
NOAEC
(
ppm)

Chronic
RQ
Acute
RQ
(
Max.
res.
mult.
apps.)
0.91
0.00
Short
Grass
0.42
0.00
Tall
Grass
0.51
0.00
Broadleaf
plants/
Insects
0.06
0.00
Seeds
5000
Acute
LD50
(
mg/
kg)
Mammalian
75
Chronic
NOAEL
(
mg/
kg)

1000
g
mammal
35
g
mammal
15
g
mammal
Chronic
RQ
Chronic
RQ
Chronic
RQ
(
Max.
res.
)
Acute
RQ
(
Max.
res.
)
Acute
RQ
(
Max.
res.
)
Acute
RQ
mult.
apps.)
(
mult.
apps)
mult.
apps.)
(
mult.
apps)
mult.
apps.)
(
mult.
apps)
0.04
0.00
0.16
0.00
0.23
0.00
Short
Grass
0.02
0.00
0.07
0.00
0.11
0.00
Tall
Grass
0.02
0.00
0.09
0.00
0.13
0.00
Broadleaf
plants/
Insects
0.00
0.00
0.01
0.00
0.01
0.00
Seeds
Figure
VII­
7:
Maneb
Estimated
Reduction
in
Application
Rate
to
Potatoes.
(
Libelo.
1999)
48
Maneb
Chemical
Name:
Potatoes
Use
non­
granular
Formulation
Inputs
lbs
a.
i./
acre
0.08
Application
Rate
days
3.2
Half­
life
days
5
Application
Interval
1
Maximum
#
Apps./
Year
Outputs
56
Day
Average
Maximum
Concentration
Concentration
(
PPM)
(
PPM)
1.76
19.20
Short
Grass
0.81
8.80
Tall
Grass
0.99
10.80
Broadleaf
plants/
Insects
0.11
1.20
Seeds
5000
Acute
LC50
(
ppm)
Avian
20
Chronic
NOAEC
(
ppm)

Chronic
RQ
Acute
RQ
(
Max.
res.
mult.
apps.)
0.96
0.00
Short
Grass
0.44
0.00
Tall
Grass
0.54
0.00
Broadleaf
plants/
Insects
0.06
0.00
Seeds
5000
Acute
LD50
(
mg/
kg)
Mammalian
75
Chronic
NOAEL
(
mg/
kg)

1000
g
mammal
35
g
mammal
15
g
mammal
Chronic
RQ
Chronic
RQ
Chronic
RQ
(
Max.
res.
)
Acute
RQ
(
Max.
res.
)
Acute
RQ
(
Max.
res.
)
Acute
RQ
mult.
apps.)
(
mult.
apps)
mult.
apps.)
(
mult.
apps)
mult.
apps.)
(
mult.
apps)
0.04
0.00
0.17
0.00
0.24
0.00
Short
Grass
0.02
0.00
0.08
0.00
0.11
0.00
Tall
Grass
0.02
0.00
0.10
0.00
0.14
0.00
Broadleaf
plants/
Insects
0.00
0.00
0.01
0.00
0.02
0.00
Seeds
Figure
VII­
8:
Maneb
Estimated
Reduction
in
Application
Rate
and
Number
of
Applications
to
Potatoes.
(
Libelo.
1999)
49
Temporal
Chronic
Risk
Exceedances
from
Maneb
Residue
on
Short
Grass
1
15
29
43
57
71
85
99
113
127
141
155
169
183
197
Papaya
Bananas
Onion
&
Garlic
Cucumber,
etc.

Potato
(
Maine,
only)

Onion
(
green)/
Tomato
C
orn
(
pop
&
sweet)
(
East
of...

Eggplant/
Sugar
Beets
Grapes
(
East
of
the
Rocky
...

Pepper
(
East
of
the
Mississip..
Broccoli,
etc.

Pepper
(
West
of
the
Mississip..
Potato
Almonds
Apples
Collards/
Turnip
(
GA
&
TN,
...

Beans
(
dried)
Turf
Tomato
(
West
of
the
Missis...
Cranberry
Grapes
(
West
of
the
Rocky...
Ornamentals
Corn
(
pop
&
sweet)(
West
of...

Mustard
(
GA
&
TN,
only)
Kale
Fig
Sites
Days
Birds
(
NOAEC
=
20
ppm)
Mammals
(
NOAEL
=
75
ppm)

Figure
VII­
9
In
addition
to
maneb's
use
on
potatoes,
maneb
is
also
use
on
numerous
other
sites
(
see
Table
II­
1,
above).
Each
of
these
groupings
represent
a
unique
use
pattern
based
on
rates
of
application,
number
of
applications
allowed
per
crop
cycle
or
season,
and
minimum
intervals
between
applications.
The
above
risk
assessment,
using
potatoes
as
an
example,
could
be
extended
to
each
of
these
separate
crop
groupings
but
the
conclusions
for
these
other
crop
groupings
would
be
similar
to
the
conclusions
drawn
from
the
example
of
maneb's
use
on
potatoes.
In
other
words,
all
maneb's
uses
represent
an
extended
potential
chronic
risk
to
birds
and
mammals
and
maneb's
exposure
in
the
environment
is
a
major
part
of
this
risk
concern.

As
another
example,
showing
the
potential
temporal
chronic
risks
to
birds
and
mammals
from
maneb's
current
uses
is
provided
in
Figure
VII­
9.
Figure
VII­
9
shows
the
number
of
days
maneb
residues
on
short
grass
would
exceed
chronic
LOCs
for
birds
and
mammals.
For
example,
the
maneb
residues
on
short
grass
resulting
from
maneb's
use
pattern
on
potatoes
would
present
a
potential
chronic
risk
to
birds
feeding
on
short
grass
for
46
days
after
the
first
application.
This
same
potato
use
would
present
a
potential
chronic
risk
for
40
days
to
mammals
feeding
on
short
grass.
50
i.
Incidents
There
are
no
incidents
for
maneb
listed
in
the
Ecological
Incident
Information
System
(
EIIS)
data
base
dealing
with
adverse
effects
to
terrestrial
non­
target
organisms.
Even
though
maneb,
on
an
acute
basis,
appears
to
pose
a
low
risk
to
terrestrial
animals,
the
chronic
LOCs
for
terrestrial
animals
(
birds
and
mammals)
are
exceeded
for
all
maneb
use
patterns.
The
incident
reports
submitted
to
EPA
primarily
deal
with
field
mortality
of
wildlife.
Chronic
problems
that
affect
wildlife
from
the
use
of
maneb
and
it's
degradate,
ETU,
would
be
expected
to
be
largely
unnoticed
in
the
field
and
thus
incident
reports,
as
a
result
of
chronic
exposure,
would
not
be
anticipated.

ii.
Endocrine
Disruptors
The
avian
reproductive
studies
reviewed
by
EFED
noted
maneb
reproductive
effects.
EFED
noted
effects
such
as
a
decreases
in
the
number
of
hatchlings
as
percentages
of
eggs
laid,
eggs
set,
and
live
3­
week
old
embryos,
and
a
decrease
in
the
number
of
14­
day
old
survivors
as
a
percentage
of
eggs.
HED
noted
maneb
mammalian
effects,
from
a
reproductive
study.
Effects
noted
in
rats
were
male
parental
toxicity
resulting
in
significant
increase
in
lung
weight
(
both
generations)
and
liver
weight
(
F1
generation)
with
lesions
noted
on
these
organs
in
the
F1
generation.
These
effects
noted
in
both
birds
and
mammals
may
be
a
result
of
hormonal
disruptions.
Based
on
these
effects
in
birds
and
mammals,
EFED
recommends
subjecting
maneb
to
more
definitive
testing
to
better
characterize
effects
related
to
its
potential
endocrine
disruptor
activity
when
the
Agency's
EDSP
develops
screening
and
testing
methods.

iii.
Endangered
Species
Based
on
available
screening
level
information
there
is
a
potential
concern
for
maneb's
chronic
effects
on
listed
birds
and
mammals
should
exposure
actually
occur.
EFED
expects
maneb
poses
a
low
acute
risk
to
nontarget
insects
because
maneb
is
practically
nontoxic
to
honeybees,
(
acute
contact
LD
50
>
12
µ
g/
bee).
Also,
there
is
no
incident
data
reporting
adverse
effects
to
honeybees
from
maneb's
use.
However,
EFED
does
not
assess
risk
to
bees
using
RQs
because
a
screening
level
RQ
assessment
method
for
estimating
the
risk
to
bees
is
not
available.
EFED
has
not
developed
an
exposure
design
for
bees
to
estimate
the
risk
using
a
risk
quotient
method.
The
Agency
does
not
currently
have
enough
data
to
perform
a
screening
level
assessment
for
maneb's
effects
on
listed
nontarget
terrestrial
plants.
Tier
I
seedling
emergence
[
guideline
122­
1(
a)]
and
vegetative
vigor
[
guideline
122­
1(
b)]
studies
have
not
been
submitted
for
a
maneb.
EFED
recommends
these
studies
be
submitted
for
review
to
evaluate
the
acute
toxicity
of
maneb
to
endangered/
threatened
species
of
terrestrial
plants.
Currently,
EFED
does
not
perform
assessments
for
chronic
risk
to
plants.
51
APPENDIX
I:
Notes
on
Fate
Studies
and
Modeling
&
Additional
Fate
Data
a.
Notes
on
Fate
Studies
i.
Aqueous
medium
studies
Guidance
for
hydrolysis
and
aqueous
photolysis
require
Parent
EBDC
to
be
applied
at
concentrations
within
the
solubility
range.
It
was
established
that
any
part
of
Parent
EBDC
that
goes
into
solution
will
completely
decompose,
by
hydrolytic
reactions,
into
a
suite
of
multi
species
residue;
the
EBDC
complex.
Reported
levels
of
Parent
EBDCs
that
decompose
in
water
were
near
2
ppm
for
metiram
and
in
the
range
of
6­
22
ppm
for
mancozeb
and
6­
200
ppm
for
maneb.
Additionally,
particle
size
reduction
(
i.
e.
sonication)
is
believed
to
cause
an
increase
in
the
level
susceptibility
of
parent
EBDCs
to
decomposition.
In
most
studies,
levels
used
in
aqueous
media
studies
were
near
this
critical
range
of
susceptibility,
parent
was
determined
by
CS
2
and
suspensions
were
prepared
using
ultrasonic.
Therefore,
calculated
hydrolysis
and/
or
photolysis
half­
lives
are
affected
by:

(
1)
Occurrence
of
hydrolytic
decomposition
during
preparation
of
stock
solution;
indicated
by
the
presence
of
high
concentrations
of
transient
species
and
degradates
at
time
zero.
Use
of
accurately
measured
nominal
concentration
can
overcome
this
problem
as
it
can
be
considered
as
time­
zero
concentration
of
the
test
substance.

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

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

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

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

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

(
2)
Extraction
systems
(
i.
e.,
acetonitrile/
water
or
methanol/
water)
appear
to
affect
the
integrity
of
52
0
5
10
15
20
25
30
Time
(
days)
30.0%
40.0%
50.0%
60.0%
70.0%
80.0%
90.0%
100.0%

%
of
Applied
Radioactivity
Sandy
Loam
Soil
Loamy
Sand
Soil
Silty
Loam
Soil
Approximation
0
10
20
30
40
50
60
Time
(
days)
30.0%
40.0%
50.0%
60.0%
70.0%
80.0%
90.0%
100.0%

%
of
Applied
Radioactivity
Sandy
Loam
Soil
Loamy
Sand
Soil
Silty
Loam
Soil
Approximation
the
parent.
Therefore,
resultant
suite
of
EBDC
complex(
in
the
extraction
solution)
was
at
least
partly
artificial
and
can
not
be
used
to
represent
the
suite
that
might
form
in
the
environment.
The
use
of
different
extraction
systems
made
it
difficult
to
compare
results
obtained
from
different
soils.

(
3)
EBDC
complex
has
high
affinity
to
soil
and
no
characterization
was
conducted
for
the
resultant
bound
species.
Therefore,
bound
species
are
suspicious
of
containing
active
species
that
can
be
precursors
for
the
degradate
of
concern
ETU.
For
example,
In
maneb
aerobic
soil
studies,
bound
species
degraded
after
reaching
a
plateau
in
the
range
of
70­
90%.
Production
of
degradates
and
CO
2
,
increased
after
the
bound
species
reach
the
described
plateau.
Figure
1
shows
bound
radioactivity
distribution
with
time
as
reported
for
soils
in
three
aerobic
soil
studies.
Definitive
trend
for
degradation
of
the
bound
species
is
not
apparent
and
is
probably
related
to
the
short
duration
of
the
experiments.

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

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

Figure
1.
Change
of
bound
radioactivity
with
time
in
four
aerobic
soils
treated
with
maneb.
53
After
considering
the
difficulties
stated
above,
it
is
expected
that
species
present
in
fate
studies
are
those
shown
in
Figure
2.
Consequently,
species
expected
to
be
present
in
compartments
of
the
natural
environment
are
those
shown
in
Figure
3.
54
0
7
14
21
28
35
42
Time
(
days);
Four
Applications
at
days:
0,
7,
14
and
21
0
1
2
3
4
5
6
7
8
EECs
for
Maneb
Parent
(
ppm)

EECs
for
Parent
based
on
Hydrolysis
halflife
of
0.1
day
b.
Notes
on
Modeling
i.
EECs
for
Parent
maneb
EECs
for
Parent
maneb
are
presented
in
the
Figure
4.
Data
for
EECs
were
calculated
using
the
slope
of
the
line
for
0.1
day
(
Table
IV.
2);
the
estimated
hydrolysis
half.
Other
assumptions
included:

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

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

­
Enough
moisture
is
present
to
complete
hydrolytic
reactions.

Data
indicate
that
soil
EECs
of
parent
maneb
are
expected
to
be
below
0.1
ppm
(.
1.4%
of
the
applied)
within
one
day
of
the
first
application
and
to
completely
degrade
just
before
the
second
application.
The
same
is
repeated
after
each
of
the
four
application
with
negligible
amounts
being
left
within
one
day
from
the
last
application.
This
data
are
believed
to
represent
concentrations
in
soil
environments
where
most
of
the
pesticide
is
applied.
However,
higher
EECs
is
expected
in
dry
conditions
and
in
soils
with
very
low
water
holding
capacity.

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

Figure
4.
EECs
for
parent
maneb
following
four
applications
of
4.8
lbs
a.
i/
acre
applied
four
times
at
7­
day
intervals.

ii.
Background
Information
on
the
PRZM
and
EXAMS
models
&
the
Index
Reservoir
Scenario
The
linked
PRZM
and
EXAMS
models
are
used
in
this
case
as
a
second
tier
screen
designed
to
estimate
the
pesticide
concentrations
found
in
water
for
use
in
drinking
water
assessments.
They
provide
high­
end
values
on
the
concentrations
that
might
be
found
in
a
small
drinking
water
reservoir
55
due
to
the
use
of
pesticide.
The
Drinking
Water
Index
Reservoir
scenario
includes
a
427
acres
field
immediately
adjacent
to
a
13
acres
reservoir,
9
feet
deep,
with
continuous
site­
specific
flow.
This
amount
can
be
reduced
due
to
degradation
in
field
and
the
effect
of
binding
to
soil.
Spray
drift
is
equal
to
6.4%
of
the
applied
concentration
from
the
ground
spray
application
and
16%
for
aerial
applications.

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

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

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

c.
Additional
Fate
Data
The
following
are
additional
fate
data
maneb
complex
mobility:

First
study
(
MRID
000658­
59):

14C­
maneb
mobility
was
investigated
by
the
TLC
method
in
which
determined
R
f
values
ranged
from
0.0
to
0.43
(
Table1).
These
values
were
taken
to
indicate
immobility
to
medium
mobility
of
the
test
56
substance
which
is
believed
to
be
a
mixture
of
maneb
degradation
products
(
maneb
was
not
identified
even
at
time
zero).

Table
1.
Soil
characteristics
and
the
adsorption
parameters
of
the
soils
used
in
the
1st
adsorption/
desorption
study.

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
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%

R
f
0.00
0.10
0.17
0.42
Mobility
Class
Immobile
Slight
Medium
Second
study
(
MRID
405852­
03):

A
30­
day
aged
14C­
maneb
complexs
were
slightly
mobile
in
a
column
(
30­
cm
length,
5­
cm
diameter)
of
loamy
sand
soil
leached
with
51
cm
(
20
inches,
1
L)
of
water
for
24
hours.
The
radioactivity
profile
was
used,
for
this
RED,
to
calculate
K
d
(
35.7)
and
K
oc
(
1,692).
Only
2.6%
of
the
applied
radioactivity
was
recovered
in
the
leachate.
ETU
and
EU
(
present
in
the
30­
day
aged
soil
in
un­
quantified
amounts)
exhibited
mobility
and
were
the
major
components
in
the
leachate;
ETU,
EU,
and
three
unidentified
degradates
were
isolated
in
the
leachate
at
1.8,
0.2,
and
<
0.6%
of
the
radioactivity
applied
to
the
soil
column,
respectively.
The
majority
of
the
radioactivity
(
93.3%
of
radioactivity
applied
to
the
column)
remained
in
the
upper
10
cm
(
4
inches)
of
the
soil
column.
In
the
soil
column,
ETU,
EBIS,
carbimid,
and
five
unidentified
degradates
were
isolated.

Third
study
(
MRID
400472­
01):

14C­
maneb
complex
exhibited
variable
mobility
in
four
different
texture
soils
in
columns
(
12"
long,
3''
diameter)
leached
with
constant/
simulated
20"
rainfall
using
de­
ionized
water.
The
radioactivity
profile
was
used,
for
this
RED,
to
calculate
the
K
d
and
K
oc
values
presented
in
Table2.
Data
indicate
that
maneb
complexes
(
a
mixture
of
degradates
not
parent)
can
be
classified
as
immobile,
low,
and
medium
mobile
in
sand,
sandy
loam,
and
clay
loam/
silty
loam,
respectively.
The
radioactivity
depth
profile
showed
that
most
of
the
applied
radioactive
residues
were
found
at
the
top
one
inch
segment
of
the
soil
columns.
Radioactivity
found
in
the
leachate
ranged
from
9.5
to
32%
of
the
applied.
Neither
maneb
nor
its
known
two
degradate
ETU/
EU
were
identified
in
any
of
the
leachates
as
radioactivity
in
these
leachates
were
left
unidentified.
57
Table
2.
Soil
characteristics
and
the
adsorption
parameters
of
the
soils
used
in
the
3rd
study.

Source
Georgia
Georgia
Pennsylvania
Mississippi
Soil
Textural
Class
Sand
Sandy
Loam
Clay
Loam
Silt
Loam
Clay
4%
14%
28%
10%

pH
(
water)
6.5
5.8
7.0
7.7
Field
Capacity
7.8%
14.1%
29.1%
17.4%

C.
E.
C
(
meq/
100
g)
3.8
9.1
15.7
7.6
Organic
Carbon
0.12%
0.93%
1.63%
0.58%

K
ad
7.46
9.10
6.97
2.23
K
oc
6,412
978
428
400
Mobility
Class
Immobile
Low
Medium
Fourth/
fifth
study
(
MRID
455959­
01/
02):

In
the
4th
study,
14C­
maneb,
aged
for
five
hours
in
the
application
solution,
was
studied
in
duplicate
Speyer
2.1
soil
columns
that
were
leached
with
200
mm
(
393
ml)
of
water
over
a
period
of
two
days.
Each
30
cm.
soil
column
was
purged
with
CO
2
to
remove
oxygen
and
was
fortified
with
0.621
mg
of
the
aged
14C­
maneb.
Total
14C­
residues
were
not
identified
but
were
nearly
54%
of
the
applied
radioactivity
in
the
top
6
cm
soil
layer
and
ranged
from
9­
2%,
in
the
four
segments
below
the
top
layer.
Total
[
14C]
residues
recovered
in
the
leachate
accounted
for
nearly
13%
of
the
applied.
In
this
leachate,
14C­
maneb
was
not
detected
but
two
of
its
transformation
products
EU
(
3.5­
3.8%)
and
ETU
(
0.1­
0.2%)
were
identified.
Additionally,
five
unknown
radioactive
fractions
were
detected
in
the
leachate,
with
the
metabolite
with
the
highest
concentration
totaling
2.7­
2.9%
of
the
applied.
None
of
the
other
four
degradates
exceeded
1.0%
of
the
applied.
Estimated
K
ad
/
K
oc
and
related
soil
characteristics
for
this
soil
are
included
in
Table
3.

Soil
column
leaching
experiments
were
conducted
in
the
5th
study
using
three
soils
(
Speyer
2.1/
2.2
and
2.3)
and
the
same
procedure
used
in
the
fourth
study.
However,
the
source
of
14C­
maneb
was
from
the
active
ingredient
of
a
wettable
powder
formulation
(
MRID
455959­
02).
Following
leaching,
total
[
14C]
residues
in
the
soil
(
all
layers)
ranged
from
76.6
to
84.3%
of
the
applied
from
each
duplicate
soil
column
and
total
[
14C]
residues
in
the
leachate
ranged
from
1.5
to
4.7%.

In
the
Speyer
2.1
soil,
total
[
14C]
residues
were
71.6­
73.8%
of
the
applied
radioactivity
in
the
top
6
cm
soil
layer
and
were
4.9%,
2.7­
3.0%,
1.4­
1.7%,
and
0.9­
1.2%,
respectively,
in
the
four
segments
below
the
top
layer
proceeding
from
top
to
bottom.
[
14C]
Residues
in
the
soil
were
not
identified.
A
total
of
3.4­
4.7%
of
the
applied
was
recovered
in
the
leachate.
Radioactivity
detected
in
the
leachate
was
comprised
of
seven
unknown
fractions,
with
no
single
fraction
detected
at
greater
than
58
1.5%
of
the
applied.
The
material
balance
was
85.3%
and
89.0%
of
the
applied
for
the
duplicate
columns.

In
the
Speyer
2.2
soil,
total
[
14C]
residues
were
70.5­
74.5%
of
the
applied
radioactivity
in
the
top
6
cm
soil
layer
and
were
2.5­
4.2%,
1.1­
1.2%,
0.4­
0.6%,
and
0.3%,
respectively,
in
the
four
segments
below
the
top
layer
proceeding
from
top
to
bottom.
[
14C]
Residues
in
the
soil
were
not
identified.
A
total
of
1.5­
1.6%
of
the
applied
was
recovered
in
the
leachate.
Radioactivity
detected
in
the
leachate
was
comprised
of
seven
unknown
fractions,
with
no
single
fraction
detected
at
greater
than
0.6%
of
the
applied.
The
material
balance
was
78.2%
and
80.5%
of
the
applied
for
the
duplicate
columns.

In
the
Speyer
2.3
soil,
total
[
14C]
residues
were
67.5­
67.9%
of
the
applied
radioactivity
in
the
top
6
cm
soil
layer
and
were
4.8­
6.9%,
3.5­
4.4%,
1.6­
2.4%,
and
0.8­
1.7%,
respectively,
in
the
four
segments
below
the
top
layer
proceeding
from
top
to
bottom.
[
14C]
Residues
in
the
soil
were
not
identified.
A
total
of
2.1­
3.9%
of
the
applied
was
recovered
in
the
leachate.
Radioactivity
detected
in
the
leachate
was
comprised
of
seven
unknown
fractions,
with
no
single
fraction
detected
at
greater
than
2.5%
of
the
applied.
The
material
balance
was
83.3%
and
84.1%
of
the
applied
for
the
duplicate
columns.

Estimated
K
ad
/
K
oc
and
related
soil
characteristics
for
the
three
German
soils
are
included
in
Table
3.

Table
3.
Soil
characteristics
and
the
adsorption
parameters
of
the
soils
used
in
the
4th/
5th
studies.

Soil
Name
Speyer
2.1
Speyer
2.2
Speyer
2.3
Soil
Textural
Class
Sand
Loamy
sand
Sandy
loam
14C­
maneb
source
Pure
a.
i
(
a.
i)
from
a
wettable
powder
formulation
Clay
4%
5%
8%

pH
(
water)
6.1
6.0
6.9
C.
E.
C
(
meq/
100
g)
4.9
9.7
9.5
Organic
Carbon
0.70%
2.29%
1.34%

K
ad
3.18
10.21
25.96
13.72
K
oc
454
1,459
1,133
1,024
Mobility
Class
Medium
Low
59
APPENDIX
II:
Hoerger­
Kenaga
Estimates
&
Fate
v.
5.0
Model
a.
Hoerger­
Kenaga
Estimates
EFED
uses
Hoerger
and
Kenaga
estimates
(
1972)
as
changed
by
Fletcher
and
other
researchers
(
1994)
to
estimate
the
residues
on
plants
and
insects.
Hoerger­
Kenaga
categories
represent
preferred
foods
of
various
terrestrial
vertebrates.
Upland
game
birds
prefer
fruits
and
bud
and
shoot
tips
of
leafy
crops.
Hares
and
hoofed
mammals
consume
leaves
and
stems
of
leafy
crops.
Rodents
consume
seeds,
seedpods
and
grasses;
and
various
birds,
mammals,
reptiles
and
terrestrial­
phase
amphibians
consume
insects.
Terrestrial
vertebrates
also
may
contact
pesticides
applied
to
soil
by
swallowing
pesticide
granules
or
pesticide­
laden
soil
when
foraging.
Rich
in
minerals,
soil
comprises
5
to
30%
of
dietary
intake
by
many
wildlife
species
(
Beyer
and
Conner).

Hoerger
and
Kenaga
based
pesticide
environmental
concentration
estimates
on
residue
data
correlated
from
more
than
20
pesticides
on
more
than
60
crops.
These
estimates
are
representative
of
many
geographic
regions
(
7
states)
and
a
wide
array
of
cultural
practices.
Hoerger­
Kenaga
estimates
also
considered
differences
in
vegetative
yield,
surface
to
mass
ratio
and
interception
causes.
In
1994,
Fletcher,
Nellessen
and
Pfleeger
reexamined
the
Hoerger­
Kenaga
simple
linear
model
(
y=
B1x,
where
x=
application
rate
and
y=
pesticide
residue
in
ppm)
to
decide
whether
the
terrestrial
EEC's
were
accurate.
They
compiled
a
data
set
of
pesticide
day­
0
and
residue­
decay
data
involving
121
pesticides
(
85
insecticides,
27
herbicides,
and
9
fungicides
from
17
different
chemical
classes)
on
118
species
of
plants.
After
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).
60
b.
Fate
v.
5.0
Model
Terrestrial
Exposure
Values
The
model
assumes
a
first
order
decay
to
fix
the
concentration
at
each
day
after
first
application
based
on
the
concentration
resulting
from
the
first
and
more
applications.
The
model
calculates
decay
from
the
first
order
rate
equation:

CT
=
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
*

The
model
calculates
maximum
and
mean
EECs
based
on
the
maximum
and
mean
Kenaga­
Fletcher
values
listed
in
Table
1
above.
These
EECs
are
the
maximum
amounts
collecting
on
each
day
during
the
interval
chosen.
The
model
calculates
these
EECs
for
the
different
food
item
groupings.
61
c.
Fate
v.
5.0
Model
Sample
Outputs
for
Maneb
RUN
No.
2
FOR
maneb
ON
apples
***
INPUT
VALUES
***
­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­
RATE(#/
AC)
APPLICATIONS
HALF­
LIFE
AVIAN(
ppm)
MAMMALIAN(
mg/
kg)
ONE(
MAX)
NO.­
INTERVAL
(
DAYS)
LC50
NOAEC
LD50
NOAEL
­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­
4.800(
6.136)
4
7
3.2
*******
20.000
*******
75.000
MAXIMUM
&
58
DAY
AVERAGE
KENAGA/
FLETCHER
RESIDUES:
95th%
(
mean)
in
ppm
­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­
SHORT
BROADLEAF
TALL
SEED
GRASS
&
INSECTS
GRASS
FRUIT
____________________
________________
________________
________________
MAX1472.61(
521.55)
828.34(
276.11)
674.95(
220.89)
92.04(
42.95)
____________________
________________
________________
________________
AVE
144.46(
229.44)
76.48(
186.95)
61.18(
25.49)
11.90(

ENDPOINT
SHORT
GRASS
RQ
BR
LEAF&
INS
RQ
TALL
GRASS
RQ
SEED
FRUIT
RQ
________
_______________
_______________
_______________
______________
AV
CHRON
73.63(
26.08)
41.42(
13.81)
33.75(
11.04)
4.60(
2.15)
MA
CHRON
19.63(
6.95)
11.04(
3.68)
9.00(
2.95)
1.23(
.57)

Below
are
lists
of
daily
Kenaga­
Flether
pesticide
residue
values
for
four
avian/
mammalian
food
groupings
for
maneb
use
on
turf
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
4176.00
1479.00
2349.00
783.00
1914.00
626.40
261.00
121.80
2
3362.70
1190.96
1891.52
630.51
1541.24
504.41
210.17
98.08
3
2707.80
959.01
1523.14
507.71
1241.08
406.17
169.24
78.98
4
2180.44
772.24
1226.50
408.83
999.37
327.07
136.28
63.60
5
1755.79
621.84
987.63
329.21
804.74
263.37
109.74
51.21
6
1413.84
500.74
795.29
265.10
648.01
212.08
88.37
41.24
7
1138.49
403.22
640.40
213.47
521.81
170.77
71.16
33.21
8
5092.76
1803.69
2864.68
954.89
2334.18
763.91
318.30
148.54
9
4100.92
1452.41
2306.77
768.92
1879.59
615.14
256.31
119.61
10
3302.25
1169.55
1857.51
619.17
1513.53
495.34
206.39
96.32
11
2659.12
941.77
1495.75
498.58
1218.76
398.87
166.19
77.56
12
2141.24
758.36
1204.45
401.48
981.40
321.19
133.83
62.45
13
1724.23
610.66
969.88
323.29
790.27
258.63
107.76
50.29
14
1388.42
491.73
780.99
260.33
636.36
208.26
86.78
40.50
15
5294.02
1874.97
2977.89
992.63
2426.43
794.10
330.88
154.41
16
4262.99
1509.81
2397.93
799.31
1953.87
639.45
266.44
124.34
17
3432.75
1215.77
1930.92
643.64
1573.34
514.91
214.55
100.12
18
2764.20
978.99
1554.87
518.29
1266.93
414.63
172.76
80.62
19
2225.86
788.33
1252.05
417.35
1020.19
333.88
139.12
64.92
20
1792.36
634.80
1008.21
336.07
821.50
268.85
112.02
52.28
21
1443.29
511.17
811.85
270.62
661.51
216.49
90.21
42.10
62
22
1162.20
411.61
653.74
217.91
532.68
174.33
72.64
33.90
23
935.86
331.45
526.42
175.47
428.94
140.38
58.49
27.30
24
753.60
266.90
423.90
141.30
345.40
113.04
47.10
21.98
25
606.83
214.92
341.34
113.78
278.13
91.02
37.93
17.70
26
488.65
173.06
274.86
91.62
223.96
73.30
30.54
14.25
27
393.48
139.36
221.33
73.78
180.35
59.02
24.59
11.48
28
316.85
112.22
178.23
59.41
145.22
47.53
19.80
9.24
29
255.14
90.36
143.52
47.84
116.94
38.27
15.95
7.44
30
205.45
72.76
115.57
38.52
94.16
30.82
12.84
5.99
31
165.44
58.59
93.06
31.02
75.83
24.82
10.34
4.83
32
133.22
47.18
74.94
24.98
61.06
19.98
8.33
3.89
33
107.27
37.99
60.34
20.11
49.17
16.09
6.70
3.13
34
86.38
30.59
48.59
16.20
39.59
12.96
5.40
2.52
35
69.56
24.64
39.13
13.04
31.88
10.43
4.35
2.03
36
56.01
19.84
31.51
10.50
25.67
8.40
3.50
1.63
37
45.10
15.97
25.37
8.46
20.67
6.77
2.82
1.32
38
36.32
12.86
20.43
6.81
16.65
5.45
2.27
1.06
39
29.25
10.36
16.45
5.48
13.40
4.39
1.83
.85
40
23.55
8.34
13.25
4.42
10.79
3.53
1.47
.69
41
18.96
6.72
10.67
3.56
8.69
2.84
1.19
.55
42
15.27
5.41
8.59
2.86
7.00
2.29
.95
.45
43
12.30
4.35
6.92
2.31
5.64
1.84
.77
.36
44
9.90
3.51
5.57
1.86
4.54
1.49
.62
.29
45
7.97
2.82
4.48
1.49
3.65
1.20
.50
.23
46
6.42
2.27
3.61
1.20
2.94
.96
.40
.19
47
5.17
1.83
2.91
.97
2.37
.78
.32
.15
48
4.16
1.47
2.34
.78
1.91
.62
.26
.12
49
3.35
1.19
1.89
.63
1.54
.50
.21
.10
50
2.70
.96
1.52
.51
1.24
.40
.17
.08
51
2.17
.77
1.22
.41
1.00
.33
.14
.06
63
APPENDIX
III:
Ecological
Hazards
Assessment
a.
Overview
The
toxicity
testing
required
does
not
test
all
species
of
birds,
fish,
mammals,
invertebrates,
and
plants.
EFED
uses
only
two
surrogate
species
for
birds
(
Bobwhite
quail
and
mallard
ducks)
to
represent
all
bird
species
(
over
900
in
the
US).
EFED
uses
three
species
of
freshwater
fish
(
rainbow
trout,
bluegill
sunfish
and
fathead
minnow)
to
act
as
surrogate
test
species
for
all
freshwater
fish
species
(
over
900
in
the
US).
One
estuarine
fish
species
(
sheepshead
minnow)
serves
as
surrogate
for
all
estuarine
and
marine
fish
(
over
300
in
the
US).
The
surrogate
species
for
terrestrial
invertebrates
is
the
honeybee.
For
freshwater
invertebrates
the
surrogate
species
is
usually
the
waterflea
(
Daphnia
magna).
For
estuarine
and
marine
invertebrates
the
surrogate
species
are
mysid
shrimp
and
eastern
oyster.
EFED
uses
these
four
species
to
represent
all
invertbrates
species
(
over
10,000
in
the
US).
For
plants,
there
are
ten
surrogate
species
used
for
all
terrestrial
plants
and
five
surrogate
species
used
for
all
aquatic
plants.
There
are
over
20,000
plant
species
in
the
US
which
includes
flowering
plants,
conifers,
ferns,
mosses,
liverworts,
hornworts
and
lichens.
There
are
over
27,000
species
of
algae
worldwide.

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

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

If
the
LD50
is
less
than
10
mg
a.
i./
kg,
then
the
test
substance
is
very
highly
toxic.
If
the
LD50
is
10­
to­
50
mg
a.
i./
kg,
then
the
test
substance
is
highly
toxic.
If
the
LD50
is
51­
to­
500
mg
a.
i./
kg,
then
the
test
substance
is
moderately
toxic.
If
the
LD50
is
501­
to­
2,000
mg
a.
i./
kg,
then
the
test
substance
is
slightly
toxic.
64
If
the
LD50
is
greater
than
2,000
mg
a.
i./
kg,
then
the
test
substance
is
practically
nontoxic.

Study
results
are
in
the
table
below.

Table
1.
Avian
Acute
Oral
Toxicity
­
Maneb
Species
%
ai
LD50
(
mg/
kg)
Toxicity
Category
MRID/
Author/
Year
Classification
Northern
bobwhite
(
Colinus
virginianus)
86
(
doses
were
adjusted
to
100%
ai)
>
2,150
practically
nontoxic
40657001/
D.
Fletcher/
1988
Core
The
avian
acute
oral
toxicity
of
maneb
is
>
2150
mg/
kg,
categorizing
maneb
as
slightly
to
practically
nontoxic
to
birds.
The
guideline
71­
1(
a)
is
fulfilled
(
MRID
40657001).

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

If
the
LC50
is
less
than
50
ppm
a.
i.,
then
the
test
substance
is
very
highly
toxic.
If
the
LC50
is
50­
to­
500
ppm
a.
i.,
then
the
test
substance
is
highly
toxic.
If
the
LC50
is
501­
to­
1,000
ppm
a.
i.,
then
the
test
substance
is
moderately
toxic.
If
the
LC50
is
1001­
to­
5,000
ppm
a.
i.,
then
the
test
substance
is
slightly
toxic.
If
the
LC50
is
greater
than
5,000
ppm
a.
i.,
then
the
test
substance
is
practically
nontoxic.

Study
results
are
tabulated
below.

Table
2.
Avian
Subacute
Dietary
Toxicity
­
Maneb
Species
%
ai
LC50
(
ppm)
Toxicity
Category
MRID/
Author/
Year
Study
Classification
Bobwhite
Quail
(
Colinus
virginianus)
assumed
to
be
100%
>
10,000
practically
nontoxic
00104264/
R.
Fink/
1975
Supplemental1
Mallard
Duck
(
Anas
platyrhynchos)
assumed
to
be
100%
>
10,000
practically
nontoxic
00098561/
Truslow
Farms,
Inc../
1975
Supplemental2
Mallard
Duck
(
Anas
platyrhynchos)
86
(
doses
were
adjusted
to
100%
ai)
>
5,000
practically
nontoxic
40657002/
D.
Fletcher/
1988
Core
1
Although
classified
supplemental,
the
study
was
found
to
fulfill
the
guideline
requirement
(
see
Maneb
1988
Registration
Standard).
2
Study
was
classified
supplemental,
but
upgradeable
if
growth
data
and
dose
mortality
could
be
provided.
65
With
LC50
values
ranging
from
greater
than
5,000
ppm
for
mallard
ducks
to
greater
than
10,000
ppm
for
bobwhite
quail,
maneb
is
considered
to
be
practically
nontoxic
to
birds.
Guideline
71­
2(
a)
for
bobwhite
is
fulfilled
(
MRID
00104264).
Guideline
71­
2(
b)
for
mallard
duck
is
also
considered
fulfilled
(
MRID
40657002).

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

Table
3.
Avian
Reproduction
­
Maneb
Species/
Study
Duration
%
ai
NOAEC/
LOAEC
(
ppm)
LOAEC
Endpoints
MRID/
Author/
Year
Classification
Northern
bobwhite
(
Colinus
virginianus)
/
22
weeks
91.0
>
500
(
highest
dose
tested)/
LAOEC
not
determined
not
determined
43586501/
Beavers
et.
al./
1995
Supplemental1
Mallard
Duck
(
Anas
platyrhynchos)
/
22
weeks
91.0
20/
100
Reduction
in
the
number
of
hatchlings
as
percentages
of
eggs
laid,
eggs
set,
and
live
3­
week
old
embryos,
and
a
reduction
in
the
number
of
14­
day
old
survivors
as
a
percentage
of
eggs
set.
43586502/
Beavers
et.
al./
1995
Core
1
study
was
classified
supplemental
because
a
NOAEC
was
not
established.

The
avian
reproduction
study
using
mallard
duck
resulted
in
a
LOAEC
of
100
ppm
based
on
a
reduction
in
the:
(
1)
number
of
hatchlings
as
percentages
of
eggs
laid,
(
2)
number
of
eggs
set;
(
3)
number
of
live
3­
week
old
embryos;
and
(
4)
number
of
14­
day
old
survivors
as
a
percentage
of
eggs
set
when
compared
to
the
control.
The
NOAEC
is
20
ppm.
The
guideline
71­
4(
b)
is
fulfilled
(
MRID
43586502).

The
avian
reproduction
study
using
bobwhite
resulted
in
a
NOAEC
greater
than
500
ppm,
the
highest
dose
tested.
This
study
was
classified
supplemental
because
an
NOAEC
was
not
established.
Although
a
core
study
is
not
available,
the
mallard
has
been
shown
to
be
more
the
more
sensitive
of
the
two
species,
and
will
be
used
for
risk
assessment
purposes.
Additional
reproductive
testing
is
not
required.
Guideline
71­
4(
a)
is
considered
fulfilled
(
MRID
43586501).
66
ii.
Mammals,
Acute
and
Chronic
1.
Acute
Oral
Toxicity
Testing
Wild
mammal
testing
is
required
on
a
case­
by­
case
basis,
depending
on
the
results
of
lower
tier
laboratory
mammalian
studies,
intended
use
pattern
and
pertinent
environmental
fate
characteristics.
In
most
cases,
rat
or
mouse
toxicity
values
obtained
from
the
Agency's
Health
Effects
Division
(
HED)
substitute
for
wild
mammal
testing.
The
toxicity
values
used
in
this
assessment
were
taken
from
HED's
Tox
One­
Liner,
and
the
final
Hazard
Identification
Assessment
Review
Committee
(
HIARC)
reports
on
maneb
(
dated
11/
15/
99
and
11/
27/
01).
The
results
indicate
that
maneb
is
practically
nontoxic
to
mammals
on
an
acute
oral
basis
with
LD
50
value
greater
than
5,000
mg
/
kg
(
see
Table
4,
below).
The
toxicity
values
(
LD
50
and
NOAEL)
appearing
in
the
shaded
areas
of
the
tables
will
be
used
to
calculate
the
acute
and
chronic
mammalian
risk
quotients
(
RQ's)
in
subsequent
sections.
Toxicity
category
descriptions
are
the
following
(
Brooks,
1973):

If
the
LD50
is
less
than
10
mg
a.
i./
kg,
then
the
test
substance
is
very
highly
toxic.
If
the
LD50
is
10­
to­
50
mg
a.
i./
kg,
then
the
test
substance
is
highly
toxic.
If
the
LD50
is
51­
to­
500
mg
a.
i./
kg,
then
the
test
substance
is
moderately
toxic.
If
the
LD50
is
501­
to­
2,000
mg
a.
i./
kg,
then
the
test
substance
is
slightly
toxic.
If
the
LD50
is
greater
than
2,000
mg
a.
i./
kg,
then
the
test
substance
is
practically
nontoxic.

Table
4.
Mammalian
Acute
Toxicity
­
Maneb
Species
%
ai
Test
Type
LD50
(
mg/
kg)
Toxicity
Category)
Affected
Endpoints
MRID
Technical
laboratory
rat
(
Rattus
norvegicus)
laboratory
not
reported
oral
­
single
dose
>
5,000
practically
nontoxic
mortality
41975601
2.
Acute
Dermal
and
Inhalation
Toxicity
Testing
In
addition
to
acute
oral
routes
of
exposure,
terrestrial
vertebrates
entering
treatment
area
may
be
acutely
exposed
to
maneb
through
other
routes
of
exposure.
Results
of
toxicological
testing
indicate
maneb
is
a
Category
III
toxicant
to
rats
via
the
inhalation
route
(
LC50>
1.3
mg/
L;
MRID
41975603)
and
to
rabbits
via
the
dermal
route
of
exposure
(
LD50
>
2000
mg/
kg;
MRID
41975602).

Toxicity
category
descriptions
associated
with
inhalation
routes
of
exposure
include
the
following
(
US
EPA
CFR.
Part
156):

If
the
LC50
is
less
than
or
equal
to
0.05
mg/
liter,
then
the
test
substance
is
in
Toxicity
Category
I.
If
the
LC50
is
greater
than
0.05
mg/
liter
through
0.5
mg/
liter,
then
the
test
substance
is
in
Toxicity
Category
II.
If
the
LC50
is
greater
than
0.5
mg/
liter
through
2.0
mg/
liter,
then
the
test
substance
is
in
Toxicity
Category
III
If
the
LC50
is
greater
than
2.0
mg/
liter,
then
the
test
substance
is
in
Toxicity
Category
IV.
67
Toxicity
category
descriptions
associated
with
dermal
routes
of
exposure
include
the
following
(
US
EPA
CFR.
Part
156):

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

3.
Mammalian
Feeding,
Reproductive
and
Developmental
Toxicity
Testing
Based
on
a
13­
week
maneb
feeding
study
in
rats
(
see
Table
5),
thyroid
effects,
namely,
increased
thyroid
weights
and
follicular
cell
hyperplasia
(
abnormal
increase)
in
males
and
decreased
thyroxine
(
a
thyroid
hormone)
levels
in
both
sexes
were
noted
at
a
LOAEL
of
400
ppm
(
NOAEL
=
80
ppm)
(
MRID
No.
40982601).
In
a
maneb
developmental
study
on
rats,
treatment­
related
developmental
effects
caused
by
maneb
resulted
in
increased
post­
implantation
(
embedding
of
fertilized
egg
in
uterine
lining)
loss,
increased
resorption
(
total
and
resorption
per
dam),
and
decreased
fetal
viability
at
a
LOAEL
of
1,000
ppm
(
NOAEL
=
200
ppm)
(
MRID
No.
42520001).
A
two­
generation
reproductive
study
on
rats
using
maneb
provided
a
LOAEL
of
300
ppm
(
NOAEL
=
75
ppm)
for
paternal
toxicity
causing
an
increase
in
lung
weight
in
both
generations
(
F0,
parent
and
F1,
first
generation
of
offspring)
and
liver
weight
in
F1.
An
increased
incidence
of
diffuse
follicular
epithelial
hypertrophy/
hyperplasia
was
also
noted
in
F1.
Fetal
effects
based
on
slight
delay
in
the
startle
response
in
the
offspring
were
also
noted
at
a
LOAEL
of
300
ppm
(
NOAEL
=
75
ppm)
in
this
twogeneration
reproductive
study
(
MRID
No.
42049401).
68
Table
5.
Mammalian
Feeding,
Developmental
and
Reproductive
Chronic
Toxicity
­
Maneb
Technical
Species/
Study
Duration
%
ai
Test
Type
NOAEL/
LOAEL
Toxicity
(
mg/
kg/
day)
Affected
Endpoints
MRID
laboratory
rat
(
Rattus
norvegicus)
/
13
weeks
77.9
Feeding
5/
24
(
80/
400
ppm)
male
6/
30
(
80/
400
ppm)
female
Based
on
thyroid
effects
(
increased
thyroid
weights
and
follicular
cell
hyperplasia
in
males)
and
decreased
T
4
(
thyroxine,
a
thyroid
hormone).
40982601
laboratory
rat
(
Rattus
norvegicus)
/
gestation
(
days
6­
15)
90.4
Developmental
20/
100
(
400/
2,000
ppm)
1
(
maternal)
20/
100
(
200/
1,000
ppm)
1
(
developmental)
mat.
­
based
on
increased
clinical
signs
(
soft
stool),
decreased
body­
weight
gain
and
decreased
food
consumption
dev.
­
based
on
increased
post­
implantation
(
embedding
of
fertilized
egg
in
uterine
lining)
loss,
increased
resorption
(
total
and
resorption
per
dam),
and
decreased
fetal
viability
42520001
laboratory
rat
(
Rattus
norvegicus)
/
2­
generation
87.3
Reproductive
(
75/
300
ppm)
2
(
parental)
(
300/
1,200
ppm)
2
(
reproductive)
(
75/
300
ppm)
2
(
fetal)
parental
(
paternal)
­
based
on
a
significant
increase
in
lung
(
both
generations)
and
liver
(
F1)
weight
and
an
increased
incidence
of
diffuse
follicular
epithelial
hypertrophy/
hyperplasia
(
F1)
parental
(
maternal)
­
based
on
decreased
body
weight/
body­
weight
gain
and
food
consumption
reproductive
­
based
on
delayed
vaginal
opening
in
the
F1
female
offspring
fetal
­
based
on
slight
delay
in
the
startle
response
in
the
offspring
42049401
1
ppm
conversion
based
on:
1
mg/
kg/
day
=
20
ppm
in
adult
rats,
and
10
ppm
in
younger
rats.
(
Nelson,
1975)
2
ppm
value
provided
in
study
review
iii.
Insect
Acute
Contact
A
honey
bee
acute
contact
study
using
the
TGAI
is
required
for
maneb
because
its
outdoor
use
will
result
in
honey
bee
exposure.
The
acute
contact
LD
50
,
using
the
honey
bee,
Apis
mellifera,
is
an
acute
contact,
single­
dose
laboratory
study
designed
to
estimate
the
quantity
of
toxicant
required
to
cause
50%
mortality
in
a
test
population
of
bees.
The
TGAI
is
administered
by
one
of
two
methods:
whole
body
exposure
to
technical
pesticide
in
a
nontoxic
dust
diluent;
or,
topical
exposure
to
technical
pesticide
via
micro­
applicator.
The
median
lethal
dose
(
LD
50
)
is
expressed
in
micrograms
of
active
ingredient
per
bee
(:
g
a.
i./
bee).
Toxicity
category
descriptions
are
as
follows:

If
the
LD50
is
less
than
2
:
g
a.
i./
bee,
then
the
test
substance
is
highly
toxic.
If
the
LD50
is
2
to
less
than
11
:
g
a.
i./
bee,
then
the
test
substance
is
moderately
toxic.
If
the
LD50
is
11
:
g
a.
i./
bee
or
greater,
then
the
test
substance
is
practically
nontoxic
Study
results
are
tabulated
below.
69
Table
6.
Non­
target
Insect
Acute
Contact
Toxicity
­
Maneb
Species
%
ai
LD50
(
µ
g/
bee)
Toxicity
Category
MRID/
Author/
Year
Study
Classification
Honey
bee
(
Apis
mellifera)
not
reported
>
12.09
practically
nontoxic
00036935/
Atkins
et.
al./
1975
Core
The
LD
50
for
maneb
is
greater
than
12.09
:
g
per
bee,
classifying
maneb
as
practically
nontoxic
to
bees.
Guideline
(
141­
1)
is
fulfilled
(
MRID
00036935).

iv.
Insect
Residual
Contact
Honey
bee
toxicity
of
residues
on
foliage
study
is
required
on
an
end­
use
product
for
any
pesticide
intended
for
outdoor
application
when
the
proposed
use
pattern
indicates
that
honey
bees
may
be
exposed
to
the
pesticide
and
when
the
formulation
contains
one
or
more
active
ingredients
having
an
acute
contact
honey
bee
LD
50
which
falls
in
the
moderately
toxic
or
highly
toxic
range.
Since
maneb
is
practically
nontoxic
to
honey
bees
a
honey
bee
toxicity
of
residues
on
foliage
(
Guideline
141­
2)
is
not
required.

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

c.
Aquatic
Organism
Toxicity
i.
Toxicity
to
Freshwater
Animals
1.
Freshwater
Fish,
Acute
Two
freshwater
fish
toxicity
studies
using
the
TGAI
are
required
to
establish
the
toxicity
of
maneb
to
fish.
The
preferred
test
species
are
rainbow
trout
(
a
coldwater
fish;
Guideline
72­
1c)
and
bluegill
sunfish
(
a
warmwater
fish;
Guideline
72­
1a).
End­
use
product
testing
was
required
to
support
the
cranberry
use
(
see
Maneb
1988
Registration
Standard).
EFED
subsequently
allowed
TEP
testing
(
with
80%
WP)
to
fulfill
TGAI
testing
requirements.
Justification
provided
by
the
registrant
was
that
the
end­
use
product
had
greater
solubility
in
water
than
the
TGAI..
The
toxicity
values
(
LC
50
)
appearing
in
the
shaded
area
of
the
tables
will
be
used
to
calculate
the
acute
aquatic
risk
quotients
(
RQ's)
in
subsequent
sections.
Toxicity
category
descriptions
are
as
follows
(
Brooks,
1973):

If
the
LC50
is
less
than
0.1
ppm
a.
i.,
then
the
test
substance
is
very
highly
toxic.
If
the
LC50
is
0.1­
to­
1.0
ppm
a.
i.,
then
the
test
substance
is
highly
toxic.
If
the
LC50
is
greater
than
1
and
up
through
10
ppm
a.
i.,
then
the
test
substance
is
moderately
toxic.
If
the
LC50
is
greater
than
10
and
up
through
100
ppm
a.
i.,
then
the
test
substance
is
slightly
toxic.
If
the
LC50
is
greater
than
100
ppm
a.
i.,
then
the
test
substance
is
practically
nontoxic.

Study
results
are
tabulated
below.
70
Table
7.
Freshwater
Fish
96­
hr
Acute
Toxicity
­
Maneb
Species/
Flow­
through
or
Static
%
ai
LC50
(
ppm)/
(
measured/
nominal)
Toxicity
Category
MRID
/
Author/
Year
Study
Classification
End­
Use
Product
Bluegill
sunfish
(
Lepomis
macrochirus)
/
static
80.0
WP
0.27
(
mean
measured)
0.17
(
lowest
measured
highly
toxic
40749401/
R.
Sugatt/
1988
Core
Rainbow
Trout
(
Oncorhynchus
mykiss)
/
static
80.0
WP
0.052
(
lowest
measured
0.042
(
based
on
active
ingredient)
slope
=
2.8
(
p
<
0.05)
very
highly
toxic
40706001/
R.
Sugatt/
1988
Supplemental1
Bluegill
sunfish
(
Lepomis
macrochirus)
/
static
80.0
(
Dithane
M­
22)
0.979
(
nominal)
highly
toxic
00097240/
McCann.
&
Pitcher/
1973
Supplemental2
Bluegill
sunfish
(
Lepomis
macrochirus)
/
static
5.6
Tide
Maneb
68
(
nominal)
slightly
toxic
00052557/
J.
McCann/
1968
Supplemental2
Bluegill
sunfish
(
Lepomis
macrochirus)
/
static
80.0
(
DuPont
Mannate)
0.99
(
nominal)
highly
toxic
00090291/
McCann
&
Pitcher/
1973
Supplemental2
1
Study
classified
supplemental
because
high
variability
in
measured
concentrations;
weights
of
fish
not
given;
O2
less
than
recommended;
study
should
have
been
flow­
through.
2
The
McCann
studies
were
not
conducted
according
to
acceptable
protocols:
the
toxicity
end
points
were
not
based
on
measured
concentrations
and/
or
the
information
was
provided
as
a
reference
source
with
no
supporting
data
or
statistical
analysis.

Since
one
of
the
LC
50
values
(
for
rainbow
trout)
falls
below
0.1
ppm,
maneb
is
characterized
very
highly
toxic
to
fish
on
an
acute
basis.
In
the
studies
conducted
by
Sugatt,
a
substantial
decrease
in
test
substance
between
the
beginning
and
the
end
of
the
tests
was
noted.
For
example,
in
the
rainbow
trout
study
the
concentration
of
maneb
decreased
as
much
as
55%
of
the
nominal
at
the
zero
hour
measurement,
and
the
final
measurements
only
averaged
13.1%
of
the
nominal
value
(
range
was
9.6%
to
22.5%).
Because
estimation
of
the
actual
exposures
of
the
fish
was
not
possible,
EFED
based
the
study
results
on
final
(
lowest)
measurement
concentrations.
Guidelines
72­
1(
a)
for
the
TGAI
and
72­
1(
b)
for
the
TEP
of
maneb
are
fulfilled
(
MRID
40749401).
Guidelines
72­
1(
c)
for
the
TGAI
and
72­
1(
d)
for
the
TEP
of
maneb
are
not
fulfilled.
A
core
study
is
required
to
fulfill
these
guideline
requirements
and,
as
mentioned
above,
testing
with
the
80%
WP
formulation
can
fulfill
the
requirements
for
both
TGAI
and
TEP
testing.

2.
Freshwater
Fish,
Chronic
A
freshwater
fish
early
life­
stage
test
using
the
TGAI
is
required
for
maneb
because
the
end­
use
product
may
be
transported
to
water
from
the
intended
use
site,
and
acute
aquatic
toxicity
values
are
less
than
1
ppm.
Acceptable
freshwater
test
species
are
rainbow
trout,
brook
trout,
coho
salmon,
Chinook,
bluegill,
brown
trout,
lake
trout,
northern
pike,
fathead
minnow,
white
sucker
and
channel
catfish.
The
fish
early
life­
stage
is
a
laboratory
test
designed
to
estimate
the
quantity
of
toxicant
required
to
adversely
effect
the
reproductive
capabilities
of
a
test
population
of
fish.
The
TGAI
is
administered
into
water
containing
the
test
species,
providing
exposure
throughout
a
critical
life
71
stage,
and
the
results
are
expressed
as
a
No
Observed
Adverse
Effect
Concentration
(
NOAEC)
and
LOAEC
(
Lowest
Observed
Adverse
Effect
Concentration).
The
toxicity
value
(
NOAEC)
appearing
in
the
shaded
area
of
the
table
will
be
used
to
calculate
the
chronic
aquatic
risk
quotients
(
RQ's)
in
subsequent
sections.
The
guideline
72­
4(
a)
for
early
life­
stage
fish
testing
is
fulfilled
(
MRID
41346301).
Testing
results
are
summarized
below.

Table
8.
Freshwater
Fish
Early
Life­
Stage
Toxicity
­
Maneb
Species/
Static
or
Flow­
through
Study
Duration
%
ai
NOAEC/
LOAEC
(
ppb)/
(
measured/
nominal)
Endpoints
Affected
MRID/
Author/
Year
Study
Classification
Fathead
minnow
(
Pimephales
promelas)
/
flowthrough
35
days
87.3
6.1/
12
(
mean
measured)
1
Hatchability,
fish
survival
and
length
of
fry
41346301/
W.
A.
McAllister./
1989
Core
1
mean
values
ranged
58
to
77%
of
the
nominal.
The
authors
reported
that
due
to
the
low
water
and
organic
solvent
solubility
of
maneb,
as
well
as
its
rapid
hydrolysis
rate,
an
electronically
controlled
toxicant
delivery
apparatus
was
developed
to
automatically
provide
fresh
test
stock
solutions
at
six
hour
intervals.

A
freshwater
fish
life­
cycle
test
using
the
TGAI
is
required
for
maneb
because
the
end­
use
product
is
expected
to
be
transported
to
water
from
the
intended
use
site
and
any
EEC
is
equal
to
or
greater
than
one­
tenth
of
the
NOAEC
in
the
fish
early
life­
stage
or
invertebrate
life­
cycle
test.
The
PRZMEXAMS
modeled
peak
EECs
for
selected
sites
in
maneb's
current
use
patterns
range
from
47.6
ppb
for
potato
applications
to
197.9
ppb
for
tomato
applications.
The
preferred
test
species
is
fathead
minnow.
The
freshwater
fish
life­
cycle
test
(
Guideline
72­
5)
has
not
been
fulfilled.
A
core
study
for
this
guideline
is
required
to
be
submitted.

3.
Freshwater
Invertebrates,
Acute
A
freshwater
aquatic
invertebrate
toxicity
test
using
the
TGAI
is
required
to
establish
the
toxicity
of
maneb
to
aquatic
invertebrates.
The
preferred
test
organism
is
Daphnia
magna,
but
early
instar
amphipods,
stoneflies,
mayflies,
or
midges
may
also
be
used.
End­
use
product
testing
was
required
to
support
the
cranberry
use
(
see
Maneb
1988
Registration
Standard).
EFED
subsequently
allowed
TEP
testing
(
with
80%
WP)
to
fulfill
TGAI
testing
requirements.
The
toxicity
value
(
EC
50
)
appearing
in
the
shaded
area
of
the
table
will
be
used
to
calculate
the
acute
risk
quotients
(
RQ's)
in
subsequent
sections.
Study
results
are
tabulated
below.
72
Table
9.
Freshwater
Invertebrate
Acute
Toxicity
­
Maneb
Species/
Static
or
Flowthrough
Duration
%
ai
EC50
(
ppm)/
(
nominal/
measured)
Toxicity
Category
MRID/
Author/
Year
Study
Classification
Daphnid
(
Daphnia
magna)/
static
(
48
hr.)
80
WP
0.31(
mean
measured)
0.12
(
lowest
measured)
slope
=
4.2
(
p
<
0.05)
highly
toxic
40749402/
R.
Sugatt/
1988
Core
Since
the
EC
50
is
less
than
1
ppm
maneb
is
categorized
very
highly
toxic
to
freshwater
aquatic
invertebrates
on
an
acute
basis.
Since
a
substantial
decrease
in
test
substance
concentration
was
noted
between
the
beginning
and
end
of
the
test
(
final
values
averaged
34%
of
nominal),
test
results
were
based
on
final
measured
concentrations.
Guideline
72­
2
(
a
and
b)
are
considered
fulfilled
(
MRID
40749402).

4.
Freshwater
Invertebrate,
Chronic
A
freshwater
aquatic
invertebrate
life­
cycle
test
using
the
TGAI
was
reserved
in
the
1988
Registration
Standard
pending
results
of
environmental
fate
data
such
as
hydrolysis,
photplysis
and
aquatic
field
dissipation
and
studies
on
technical
maneb.
This
study
is
required
because
the
end­
use
product
is
expected
to
be
transported
to
water
from
the
intended
use
site,
and
the
following
conditions
are
met:
(
1)
the
pesticide
is
intended
for
use
such
that
its
presence
in
water
is
likely
to
be
continuous
or
recurrent,
(
2)
the
aquatic
acute
LC
50
or
EC
50
is
less
than
1.0
ppm,
and
(
3)
the
EEC
in
water
is
equal
to
or
greater
than
0.01
of
any
acute
EC50
or
LC50
value.
The
preferred
test
species
is
Daphnia
magna.
The
guideline
(
72­
4)
is
not
fulfilled.

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

ii.
Toxicity
to
Estuarine
and
Marine
Animals
1.
Estuarine
and
Marine
Fish,
Acute
Acute
toxicity
testing
with
estuarine
and
marine
fish
using
the
TGAI
is
required
for
maneb
because
the
end­
use
product
is
expected
to
reach
the
marine/
estuarine
environment
because
of
its
use
in
coastal
counties.
The
preferred
test
organisms
are
the
sheepshead
minnow.
End­
use
product
testing
was
required
to
support
the
cranberry
use
(
see
Maneb
1988
Registration
Standard).
EFED
subsequently
allowed
TEP
testing
(
with
80%
WP)
to
fulfill
TGAI
testing
requirements.
Justification
provided
by
the
registrant
was
that
the
end­
use
product
had
greater
solubility
in
water
than
the
TGAI.
The
toxicity
value
(
LC
50
)
appearing
in
the
shaded
area
of
the
table
will
be
used
to
calculate
the
acute
73
risk
quotients
(
RQ's)
in
subsequent
sections.
Study
results
are
tabulated
below.

Table
10.
Summary
of
acute
96­
hr
toxicity
tests
for
Estuarine/
Marine
Fish
­
Maneb
Species/
static
or
flowthrough
%
a.
i.
LC50)
ppm/
(
measured/
nominal)
Toxicity
Category
MRID/
Author/
Year
Classification
End­
Use
Formulation
Atlantic
Silverside/
(
Menidia
menidia)/
flowthrough
84.8
(
80%
WP)
0.23(
mean
measured)
0.18
(
lowest
measured)
slope
=
4.2
highly
toxic
40943101/
S.
Manning/
1988
Core
Based
on
the
results
of
this
test,
maneb
is
categorized
highly
toxic
to
estuarine
fish.
The
study
authors
noted
that
measured
concentrations
were
variable
(
69
to
89%
of
the
nominal),
and
attributed
this
to
the
poor
solubility
of
the
test
material
in
sea
water.
The
study
fulfills
Guideline
72­
3(
a
and
d)
(
MRID
40943101).

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

3.
Estuarine
and
Marine
Invertebrates,
Acute
Acute
toxicity
testing
with
estuarine/
marine
invertebrates
using
the
TGAI
is
required
for
maneb
because
the
end­
use
product
is
expected
to
reach
the
marine/
estuarine
environment
because
of
it
use
in
coastal
counties.
The
preferred
test
species
are
mysid
shrimp
and
eastern
oyster.
End­
use
product
testing
was
required
to
support
the
cranberry
use
(
see
Maneb
1988
Registration
Standard).
EFED
subsequently
allowed
TEP
testing
(
with
80%
WP)
to
fulfill
TGAI
testing
requirements.
The
toxicity
value
(
EC
50
)
appearing
in
the
shaded
area
of
the
table
will
be
used
to
calculate
the
acute
risk
quotients
(
RQ's)
in
subsequent
sections.
Study
results
are
tabulated
below.

Table
11
.
Estuarine/
Marine
Invertebrate
Acute
Toxicity
­
Maneb
Species/
Static
or
Flow­
through
%
a.
i.
96­
hour
EC50
(
ppm)/
(
measured/
nominal)
Toxicity
Category
MRID/
Author/
Yea
r
Study
Classification
End­
Use
Formulation
Eastern
oyster
(
Crassostrea
virginica)/
flowthrough
(
shell
deposition)
84.8
(
80%
WP)
0.64
(
mean
measured)
0.28
(
lowest
measured)
highly
toxic
41000001/
S.
Manning/
1989
Core
Table
11
.
Estuarine/
Marine
Invertebrate
Acute
Toxicity
­
Maneb
Species/
Static
or
Flow­
through
%
a.
i.
96­
hour
EC50
(
ppm)/
(
measured/
nominal)
Toxicity
Category
MRID/
Author/
Yea
r
Study
Classification
74
Mysid
(
Americamysis
bahia)/
flowthrough
84.8
(
80%
WP)
0.003(
estimated)
slope
=
3.5
very
highly
toxic
41000002/
S.
Manning/
1988
Supplemental1
1
high
variability
in
measured
concentrations;
analytical
procedures
were
not
able
to
detect
maneb
below
5
ppb..

Since
the
mollusc
EC
50
is
less
than
1
ppm,
maneb
is
considered
to
be
highly
toxic
to
the
mollusc
on
an
acute
basis.
Guideline
72­
3(
b)
for
the
TGAI
acute
toxicity
to
estuarine/
marine
organism­
mollusk
is
fulfilled
(
MRID
No.
41000001).
Since
the
nominal
to
measured
concentrations
varied
significantly
in
this
test
(
authors
attributed
to
low
solubility
of
material),
EFED
based
the
study
results
on
the
lowest
measured
concentrations.
The
study
fulfills
Guideline
72­
3(
b
and
e)
(
MRID
41000001).

Based
on
a
supplemental
study
with
mysid
shrimp,
maneb
may
be
characterized
as
very
highly
toxic
to
estuarine
invertebrates.
There
was
high
variability
in
measured
concentrations
in
this
study
(
estimated
at
13
to
17%
of
nominal);
the
study
authors
attributed
this
to
the
poor
solubility
of
the
test
material.
Since
three
of
the
four
actual
measured
concentrations
were
only
estimates
(
not
verified
by
recovery
methods),
the
only
assumption
that
could
be
drawn
from
the
study
was
that
the
LC50
value
is
below
5
ppb,
and
probably
about
3
ppb.
Guideline
72­
3
(
c
and
f)
is
not
fulfilled.

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

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

iii.
Toxicity
to
Plants
1.
Terrestrial
Plants
Terrestrial
plant
Tier
I
seedling
emergence
and
vegetative
vigor
testing
of
a
maneb
TEP
is
currently
recommended
for
all
pesticides
having
outdoor
uses.
For
seedling
emergence
and
vegetative
vigor
testing
the
following
plant
species
and
groups
should
be
tested:
(
1)
six
species
of
at
least
four
75
dicotyledonous
families,
one
species
of
which
is
soybean
(
Glycine
max)
and
the
second
is
a
root
crop,
and
(
2)
four
species
of
at
least
two
monocotyledonous
families,
one
of
which
is
corn
(
Zea
mays).
Tier
I
tests
measure
the
response
of
plants,
relative
to
a
control,
at
a
test
level
that
is
equal
to
the
highest
use
rate
(
expressed
as
lbs
ai/
A).
Tier
II
studies
are
required
if
the
Tier
I
studies
indicate
any
of
the
test
species,
when
exposed
to
the
test
material,
displayed
a
$
25%
inhibition
of
various
growth
parameters
as
compared
to
the
control.
Tier
I
seedling
emergence
[
guideline
122­
1(
a)]
and
vegetative
vigor
[
guideline
122­
1(
b)]
studies
have
not
been
submitted
for
a
maneb
and
it
is
recommended
that
these
studies
be
submitted
for
review.

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

3.
Aquatic
Plants
Aquatic
plant
testing
is
recommended
for
all
pesticides
having
outdoor
uses
(
Keehner.
July
1999).
The
tests
are
performed
on
species
from
a
cross­
section
of
the
non­
target
aquatic
plant
population.
The
preferred
test
species
are
duckweed
(
Lemna
gibba),
marine
diatom
(
Skeletonema
costatum),
blue­
green
algae
(
Anabaena
flos­
aquae),
freshwater
green
alga
(
Selenastrum
capricornutum),
and
a
freshwater
diatom.
Tier
I
aquatic
plant
testing
is
a
maximum
dose
test
designed
to
quickly
evaluate
the
toxic
effects
to
the
test
species
in
terms
of
growth
and
reproduction
and
to
determine
the
need
for
additional
aquatic
plant
testing.
Tier
II
aquatic
plant
testing
is
a
multiple
dose
test
of
the
plants
species
that
showed
a
phytotoxic
effect
to
the
pesticide
being
tested
at
the
Tier
I
level.
Tier
II
testing
is
aimed
to
determine
the
detrimental
effect
levels
of
the
chemical
on
the
aquatic
plants
which
showed
a
greater
than
50%
detrimental
effect
in
Tier
I
testing.

One
study
(
see
Table
12,
below)
has
been
submitted
for
a
maneb
technical
formulation
using
the
freshwater
green
algae.
S.
capricornutum
(
MRID
40943501).
The
EC
50
for
S.
capricornutum
was
13.4
ppb
based
on
growth
inhibition;
the
NOAEC
was
5
ppb.
Results
were
based
on
nominal
concentrations,
even
though
the
study
author
reported
that
maneb
was
unstable
in
the
test
media
(
at
120
hours
it
averaged
15%
of
the
nominal).
The
toxicity
value
(
EC
50
)
appearing
in
the
shaded
area
of
the
table
will
be
used
to
calculate
the
acute
risk
quotients
(
RQ's)
in
subsequent
sections.
Guideline
123­
2
(
Tier
II)
is
not
fulfilled.
Guideline
122­
2
(
Tier
I)
or
Guideline
123­
2
(
Tier
II)
aquatic
plant
growth
testing
needs
to
be
submitted
for
duckweed
(
Lemna
gibba),
marine
diatom
(
Skeletonema
costatum),
blue­
green
algae
(
Anabaena
flos­
aquae),
and
a
freshwater
diatom.
76
Table
12:
Non­
target
Aquatic
Plant
Toxicity
(
Tier
II)
­
Maneb
Species/
duration
%
A.
I.
EC50/
NOAEC
(
ppb
ai)
MRID
No.
Author/
year
Classification1
Nonvascular
Plants
frreshwater
green
algae
(
Selenastrum
capricornutum)
/
120
hrs.
87.3
13.4/
5.0
(
nominal)
slope
=
4.8
(
p
<
0.05)
40943501/
Forbis,
A./
1988
Core
4.
Aquatic
Plant
Field
Studies
No
studies
are
available.
In
1989
EFED
recommended
a
Tier
II
study
be
conducted
based
results
of
the
green
algae
toxicity
coupled
with
expected
aquatic
EECs
resulting
in
anticipated
adverse
effects
to
freshwater
algae
from
a
typical
application.
The
study
was
subsequently
reserved.
77
APPENDIX
IV:
Environmental
Exposure
Assessment
a.
Overview
of
Risk
Quotients
(
RQs)

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

RQ
=
EXPOSURE/
TOXICITY
EFED
compares
RQs
to
OPP's
levels
of
concern
(
LOCs).
OPP
uses
these
LOCs
to
analyze
potential
risk
to
non­
target
organisms
and
the
need
to
consider
regulatory
action.
This
method
signals
that
a
pesticide
used
as
directed
has
the
potential
to
cause
adverse
effects
on
non­
target
organisms.
LOCs
currently
address
the
following
risk
presumption
categories:
(
1)
acute
risks
­
the
risks
warrant
regulatory
action
as
well
as
restricted
use
classification;
(
2)
acute
restricted
use
­
the
potential
for
acute
risk
exists,
but
the
restricted
use
classification
may
mitigate
the
risk;
(
3)
acute
endangered
species
­
the
risk
may
adversely
affect
endangered
species;
and
(
4)
chronic
risk
­
the
risk
may
warrant
regulatory
action
because
there
is
a
potential
for
chronic
risk.
Currently,
EFED
does
not
perform
assessments
for
chronic
risk
to
plants,
acute
or
chronic
risks
to
non­
target
insects,
or
chronic
risk
from
granular
or
bait
formulations
to
birds
or
mammals.

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

Risk
quotients
are
index
or
reference
values
used
to
show
potential
ecological
risk.
There
are
limits
with
the
use
of
risk
quotients
in
assessing
the
risk
to
non­
target
animals
and
plants.
The
likelihood
of
an
adverse
effect
does
not
increase
with
the
size
of
the
risk
quotient.
(
Urban,
2000).
An
LOC
defined
as
1
(
see
table
below)
provides
the
reference
point
for
estimating
the
exposure
to
toxicity
risk
(
that
is,
risk
quotient).
Values
at
or
above
this
reference
point
trigger
risk
concerns.
A
risk
quotient
value
of
100
compared
to
a
value
of
50
does
not
suggest
a
greater
risk
or
a
risk
that
is
more
likely
to
occur.
Both
these
values
are
above
the
reference
point
for
risk
of
1.
The
risk
quotient
value
of
100
reflects
an
exposure
level
that
is
twice
has
high
as
the
risk
quotient
value
of
50.
The
"
exposure"
in
the
"
RQ
=
Exposure/
Toxicity"
ratio
is
twice
has
high
for
RQ
of
100
as
for
the
RQ
of
50.
Risk
quotients
are
nonprobabilistic
and
have
numerical
and
dichotomous
results.
The
numerical
result
78
drawn
from
the
calculation
either
exceeds
a
fixed
LOC
or
does
not
exceed
it.
(
US
EPA.
June
30,
1995).

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

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

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

Risk
Presumption
RQ
LOC
Terrestrial
and
Semi­
Aquatic
Plants
Acute
Risk
EEC1/
EC
25
1
Acute
Endangered
Species
EEC/
EC
05
or
NOAEC
1
Aquatic
Plants
Acute
Risk
EEC2/
EC
50
1
Acute
Endangered
Species
EEC/
EC
05
or
NOAEC
1
1
EEC
=
lbs
ai/
A
2
EEC
=
(
ppb/
ppm)
in
water
79
b.
Exposure
and
Risk
to
Terrestrial
Animals
i.
Birds
Since
maneb
is
practically
nontoxic
to
birds
on
an
acute
basis
(
acute
oral
LD50
>
2,150
mg/
kg
and
acute
dietary
LC50
>
5,000
ppm)
the
acute
risks
to
birds
are
expected
to
be
low
from
maneb's
uses
and
acute
RQs
have
not
been
calculated.
The
chronic
RQs
for
multiple
broadcast
applications
of
nongranular
maneb
products
are
tabulated
below.
Analysis
of
the
results
indicate
that
for
multiple
applications
of
maneb
nongranular
products,
avian
chronic
LOCs
are
exceeded
for
all
uses
patterns
with
RQs
ranging
from
a
high
of
265
from
the
turf
use
to
a
low
of
0.4
from
the
maneb's
uses
on
collards,
turnips,
and
mustard
(
Georgia
and
Tennessee,
only).
80
Table
4:
Avian
Chronic
Risk
Quotients
for
Multiple
Broadcast
Applications
of
Nongranular
Maneb
based
on
a
Mallard
Duck
(
Anas
platyrhynchos)
NOAEC
of
20
ppm.

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

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

(
Mean
EEC/
NOAEC)
2
(
Max.
EEC/
NOAEC)
2
EEC
(
ppm)
1
EEC
(
ppm)
1
Food
Items
Interval
Application
Method
34.8
98
695
1,963
Short
grass
6.4/
4
Almonds
14.7
45
295
900
Tall
grass
7­
day
interval
ground
&
aerial
18.4
55
368
1,104
Broadleaf
plants/
Insects
2.9
6
57
123
Seeds
26.1
74
522
1,473
Short
grass
4.8/
4
Apples
11.0
34
221
675
Tall
grass
7­
day
interval
ground
&
aerial
13.8
41
276
828
Broadleaf
plants/
Insects
2.1
5
43
92
Seeds
10.7
30
214
605
Short
grass
2.4/
10
Bananas
4.5
14
91
277
Tall
grass
14­
day
interval
ground
&
aerial
5.7
17
113
340
Broadleaf
plants/
Insects
0.9
2
18
38
Seeds
10.3
29
205
580
Short
grass
1.6/
6
Beans
(
dried)

4.3
13
87
266
Tall
grass
5­
day
interval
ground
&
aerial
5.4
16
109
326
Broadleaf
plants/
Insects
0.8
2
17
36
Seeds
8.7
25
174
492
Short
grass
1.6/
6
Broccoli,
Brussel
Sprouts,

3.7
11
74
225
Tall
grass
7­
day
interval
Cabbage,
Cauliflower,
Endive,

4.6
14
92
277
Broadleaf
plants/
Insects
Kohlrabi,
&
Lettuce
0.7
2
14
31
Seeds
ground
&
aerial
5.4
15
107
303
Short
grass
1.2/
3
Collards
&
Turnip
2.3
7
45
139
Tall
grass
14­
day
interval
(
GA
&
TN,
only)

2.8
9
57
170
Broadleaf
plants/
Insects
ground
&
aerial
0.4
1
9
19
Seeds
10.7
30
213
603
Short
grass
1.2/
15
Corn
(
pop
&
sweet)
a
4.5
14
90
276
Tall
grass
3­
day
interval
(
including
AR
&
LA)

5.7
17
113
339
Broadleaf
plants/
Insects
ground
&
aerial
0.9
2
18
38
Seeds
10.3
29
205
579
Short
grass
1.2/
5
Corn
(
pop
&
sweet)
b
4.3
13
87
266
Tall
grass
3­
day
interval
(
excluding
AR
&
LA)

5.4
16
109
326
Broadleaf
plants/
Insects
ground
&
aerial
0.8
2
17
36
Seeds
81
Table
4
(
continued):
Avian
Chronic
Risk
Quotients
for
Multiple
Broadcast
Applications
of
Nongranular
Maneb
based
on
a
Mallard
Duck
(
Anas
platyrhynchos)
NOAEC
of
20
ppm.

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

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

(
Mean
EEC/
NOAEC)
2
(
Max.
EEC/
NOAEC)
2
EEC
(
ppm)
1
EEC
(
ppm)
1
Food
Items
Interval
Application
Method
25.9
73
517
1,460
Short
grass
4.8/
3
Cranberry
11.0
33
219
669
Tall
grass
7­
day
interval
ground
&
aerial
13.7
41
274
821
Broadleaf
plants/
Insects
2.1
5
43
91
Seeds
8.7
25
174
492
Short
grass
1.6/
8
Cucumber,
Melons,

3.7
11
74
226
Tall
grass
7­
day
interval
Pumpkin
&
Squash
4.6
14
92
277
Broadleaf
plants/
Insects
ground
&
aerial
0.7
2
14
31
Seeds
8.7
25
174
492
Short
grass
1.6/
7
Eggplant
&
Sugar
Beets
3.7
11
74
226
Tall
grass
7­
day
interval
ground
&
aerial
4.6
14
92
277
Broadleaf
plants/
Insects
0.7
2
14
31
Seeds
10.2
29
204
576
Short
grass
2.4/
1
Fig
4.3
13
86
264
Tall
grass
not
applicable
ground
&
aerial
5.4
16
108
324
Broadleaf
plants/
Insects
0.8
2
17
36
Seeds
17.4
49
348
984
Short
grass
3.2/
6
Grapesc
7.4
23
148
451
Tall
grass
7­
day
interval
ground
&
aerial
9.2
28
184
553
Broadleaf
plants/
Insects
1.4
3
29
61
Seeds
10.8
30
216
609
Short
grass
2.0/
3
Grapesd
4.6
14
91
279
Tall
grass
7­
day
interval
ground
&
aerial
5.7
17
114
342
Broadleaf
plants/
Insects
0.9
2
18
38
Seeds
8.3
23
166
468
Short
grass
1.6/
2
Kale
3.5
11
70
215
Tall
grass
7­
day
interval
ground
&
aerial
4.4
13
88
263
Broadleaf
plants/
Insects
0.7
1
14
29
Seeds
5.3
15
107
302
Short
grass
1.2/
2
Mustard
(
GA
&
TN,
only)

2.3
7
45
138
Tall
grass
14­
day
interval
ground
&
aerial
2.8
8
57
170
Broadleaf
plants/
Insects
0.4
1
9
19
Seeds
82
Table
4
(
continued):
Avian
Chronic
Risk
Quotients
for
Multiple
Broadcast
Applications
of
Nongranular
Maneb
based
on
a
Mallard
Duck
(
Anas
platyrhynchos)
NOAEC
of
20
ppm.

Application
Rate
Chronic
RQ
Chronic
RQ
(
lbs
ai/
A)/
Based
on
Based
on
Number
of
Mean
EECs
Maximum
EECs
Mean
Maximum
Applications/
Site/

(
Mean
EEC/
NOAEC)
2
(
Max.
EEC/
NOAEC)
2
EEC
(
ppm)
1
EEC
(
ppm)
1
Food
Items
Interval
Application
Method
13.1
37
261
738
Short
grass
2.4/
10
Onion
&
Garlic
5.5
17
111
338
Tall
grass
7­
day
interval
ground
&
aerial
6.9
21
138
415
Broadleaf
plants/
Insects
1.1
2
22
46
Seeds
13.1
37
261
738
Short
grass
2.4/
7
Onion
(
green)
&
Tomato
a
5.5
17
111
338
Tall
grass
7­
day
interval
ground
&
aerial
6.9
21
138
415
Broadleaf
plants/
Insects
1.1
2
22
46
Seeds
8.9
25
179
504
Short
grass
2/
14
Papaya
3.8
12
76
231
Tall
grass
14­
day
interval
ground
&
aerial
4.7
14
95
284
Broadleaf
plants/
Insects
0.7
2
15
32
Seeds
13.1
37
261
738
Short
grass
2.4/
6
Pepper
a
5.5
17
111
338
Tall
grass
7­
day
interval
ground
&
aerial
6.9
21
138
415
Broadleaf
plants/
Insects
1.1
2
22
46
Seeds
8.7
25
174
492
Short
grass
1.6/
6
Pepper
b
3.7
11
74
225
Tall
grass
7­
day
interval
ground
&
aerial
4.6
14
92
277
Broadleaf
plants/
Insects
0.7
2
14
31
Seeds
10.3
29
206
581
Short
grass
1.6/
10
Potato
(
Maine,
only)

4.4
13
87
266
Tall
grass
5­
day
interval
ground
&
aerial
5.4
16
109
327
Broadleaf
plants/
Insects
0.8
2
17
36
Seeds
83
Table
4
(
continued):
Avian
Chronic
Risk
Quotients
for
Multiple
Broadcast
Applications
of
Nongranular
Maneb
based
on
a
Mallard
Duck
(
Anas
platyrhynchos)
NOAEC
of
20
ppm.

Application
Rate
Chronic
RQ
Chronic
RQ
(
lbs
ai/
A)/
Based
on
Based
on
Number
of
Mean
EECs
Maximum
EECs
Mean
Maximum
Applications/
Site/

(
Mean
EEC/
NOAEC)
2
(
Max.
EEC/
NOAEC)
2
EEC
(
ppm)
1
EEC
(
ppm)
1
Food
Items
Interval
Application
Method
10.3
29
206
580
Short
grass
1.6/
7
Potato
4.4
13
87
266
Tall
grass
5­
day
interval
ground
&
aerial
5.4
16
109
326
Broadleaf
plants/
Insects
0.8
2
17
36
Seeds
8.7
25
174
491
Short
grass
1.6/
4
Tomato
b
3.7
11
74
225
Tall
grass
7­
day
interval
ground
&
aerial
4.6
14
92
276
Broadleaf
plants/
Insects
0.7
2
14
31
Seeds
6.5
18
129
365
Short
grass
1.2/
3
f
Ornamentals
e
2.7
8
55
167
Tall
grass
7­
day
interval
ground
3.4
10
68
205
Broadleaf
plants/
Insects
0.5
1
11
23
Seeds
93.7
265
1,875
5,294
Short
grass
17.4/
3
f
Turf
g
39.7
121
794
2,426
Tall
grass
7­
day
interval
ground
&
aerial
49.6
149
993
2,978
Broadleaf
plants/
Insects
7.7
17
154
331
Seeds
1
Assumes
degradation
using
FATE
version
5.0
program
with
a
foliar
dissipation
(
total
residue)
half­
life
of
3.2
days.

2
RQ
greater
or
equal
to
1.00
exceeds
chronic
LOC.

a
East
of
the
Mississippi
River
b
West
of
the
Mississippi
River
c
East
of
the
Rocky
Mountains
d
West
of
the
Rocky
Mountains
e
Trees,
Herbaceous
Plants,
Non
Flowering
Plants,
&
Woody
Shrubs
and
Vines
f
The
maximum
number
of
applications
per
crop
cycle
was
not
specified
on
the
labeling.

Three
(
3)
applications
per
crop
cycle
are
assumed
for
modeling
purposes.

g.
Residential,
Commercial/
Industrial,
Golf
Course,
Sod
Farm,
&
Recreational
84
Maneb
has
numerous
seed
treatment
uses
(
see
Table
1,
above)
the
RQs
from
these
seed
treatment
uses
were
not
were
calculated
in
this
RED.
Numerous
seed
treatment
uses
of
mancozeb
were
evaluated
in
the
mancozeb
RED
and
no
LOCs
were
exceeded.
The
avian
acute
LD50
of
maneb
(
Bobwhite
quail
LD50
>
2,150
mg/
kg)
is
practically
nontoxic
to
birds
and
was
greater
than
the
avian
acute
LD50
for
mancozeb
(
English
sparrow
LD50
~
1,500
mg/
kg).
Since
maneb
is
less
toxic
to
birds
on
an
acute
basis
than
mancozeb
and
the
exposure
(
rates
of
application)
from
these
seed
treatment
uses
are
similar
for
maneb
and
mancozeb,
EFED
has
determined
that
the
acute
risks
to
birds
from
eating
maneb
treated
seeds
are
low.

ii.
Mammals
As
identified
in
Appendix
III,
maneb
is
practically
nontoxic
(
rat
LD50
>
5,000
mg/
kg)
to
mammals
on
an
acute
basis.
Because
of
this,
the
acute
exposure
to
maneb
presents
a
low
risk
to
mammals
so
RQs
for
acute
exposure
were
not
determined.
The
chronic
mammalian
risk
quotients
for
multiple
broadcast
applications
of
nongranular
products
are
tabulated
below
in
table
5.
The
results
indicate
that
chronic
mammalian
LOCs
are
exceeded
for
all
maneb
use
patterns
listed.
85
Table
5:
Mammalian
Chronic
Risk
Quotients
for
Multiple
Applications
of
Maneb
Nongranular
(
Broadcast)
Based
on
a
labaratory
rats
(
Rattus
norvegicus)
NOAEL
of
75
ppm
h
Application
Rate
Chronic
RQ
Chronic
RQ
(
lbs
ai/
A)/

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

(
Mean
EEC/
NOAEC)
2
(
Max.
EEC/
NOAEC)
2
EEC
(
ppm)
1
EEC
(
ppm)
1
Food
Items
Interval
Application
Method
9.3
26
695
1,963
Short
grass
6.4/
4
Almonds
3.9
12
295
900
Tall
grass
7­
day
interval
ground
&
aerial
4.9
15
368
1,104
Broadleaf
plants/
Insects
0.8
2
57
123
Seeds
7.0
20
522
1,473
Short
grass
4.8/
4
Apples
2.9
9
221
675
Tall
grass
7­
day
interval
ground
&
aerial
3.7
11
276
828
Broadleaf
plants/
Insects
0.6
1
43
92
Seeds
2.9
8
214
605
Short
grass
2.4/
10
Bananas
1.2
4
91
277
Tall
grass
14­
day
interval
ground
&
aerial
1.5
5
113
340
Broadleaf
plants/
Insects
0.2
0.5
18
38
Seeds
2.7
8
205
580
Short
grass
1.6/
6
Beans
(
dried)

1.2
4
87
266
Tall
grass
5­
day
interval
ground
&
aerial
1.4
4
109
326
Broadleaf
plants/
Insects
0.2
0.5
17
36
Seeds
2.3
7
174
492
Short
grass
1.6/
6
Broccoli,
Brussel
Sprouts,

1.0
3
74
225
Tall
grass
7­
day
interval
Cabbage,
Cauliflower,
Endive,

1.2
4
92
277
Broadleaf
plants/
Insects
Kohlrabi,
&
Lettuce
0.2
0.4
14
31
Seeds
ground
&
aerial
1.4
4
107
303
Short
grass
1.2/
3
Collards
&
Turnip
0.6
2
45
139
Tall
grass
14­
day
interval
(
GA
&
TN,
only)

0.8
2
57
170
Broadleaf
plants/
Insects
ground
&
aerial
0.1
0.3
9
19
Seeds
2.8
8
213
603
Short
grass
1.2/
15
Corn
(
pop
&
sweet)
a
1.2
4
90
276
Tall
grass
3­
day
interval
(
including
AR
&
LA)

1.5
5
113
339
Broadleaf
plants/
Insects
ground
&
aerial
0.2
0.5
18
38
Seeds
2.7
8
205
579
Short
grass
1.2/
5
Corn
(
pop
&
sweet)
b
1.2
4
87
266
Tall
grass
3­
day
interval
(
excluding
AR
&
LA)

1.4
4
109
326
Broadleaf
plants/
Insects
ground
&
aerial
0.2
0.5
17
36
Seeds
86
Table
5
(
continued):
Mammalian
Chronic
Risk
Quotients
for
Multiple
Applications
of
Maneb
Nongranular
(
Broadcast)
Based
on
a
labaratory
rats
(
Rattus
norvegicus)
NOAEL
of
75
ppm
h
Application
Rate
Chronic
RQ
Chronic
RQ
(
lbs
ai/
A)/

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

(
Mean
EEC/
NOAEC)
2
(
Max.
EEC/
NOAEC)
2
EEC
(
ppm)
1
EEC
(
ppm)
1
Food
Items
Interval
Application
Method
6.9
19
517
1,460
Short
grass
4.8/
3
Cranberry
2.9
9
219
669
Tall
grass
7­
day
interval
ground
&
aerial
3.7
11
274
821
Broadleaf
plants/
Insects
0.6
1
43
91
Seeds
2.3
7
174
492
Short
grass
1.6/
8
Cucumber,
Melons,

1.0
3
74
226
Tall
grass
7­
day
interval
Pumpkin
&
Squash
1.2
4
92
277
Broadleaf
plants/
Insects
ground
&
aerial
0.2
0.4
14
31
Seeds
2.3
7
174
492
Short
grass
1.6/
7
Eggplant
&
Sugar
Beets
1.0
3
74
226
Tall
grass
7­
day
interval
ground
&
aerial
1.2
4
92
277
Broadleaf
plants/
Insects
0.2
0.4
14
31
Seeds
2.7
8
204
576
Short
grass
2.4/
1
Fig
1.2
4
86
264
Tall
grass
not
applicable
ground
&
aerial
1.4
4
108
324
Broadleaf
plants/
Insects
0.2
0.5
17
36
Seeds
4.6
13
348
984
Short
grass
3.2/
6
Grapesc
2.0
6
148
451
Tall
grass
7­
day
interval
ground
&
aerial
2.5
7
184
553
Broadleaf
plants/
Insects
0.4
0.8
29
61
Seeds
2.9
8
216
609
Short
grass
2.0/
3
Grapesd
1.2
4
91
279
Tall
grass
7­
day
interval
ground
&
aerial
1.5
5
114
342
Broadleaf
plants/
Insects
0.2
0.5
18
38
Seeds
2.2
6
166
468
Short
grass
1.6/
2
Kale
0.9
3
70
215
Tall
grass
7­
day
interval
ground
&
aerial
1.2
4
88
263
Broadleaf
plants/
Insects
0.2
0.4
14
29
Seeds
1.4
4
107
302
Short
grass
1.2/
2
Mustard
(
GA
&
TN,
only)

0.6
2
45
138
Tall
grass
14­
day
interval
ground
&
aerial
0.8
2
57
170
Broadleaf
plants/
Insects
0.1
0.3
9
19
Seeds
87
Table
5
(
continued):
Mammalian
Chronic
Risk
Quotients
for
Multiple
Applications
of
Maneb
Nongranular
(
Broadcast)
Based
on
a
labaratory
rats
(
Rattus
norvegicus)
NOAEL
of
75
ppm
h
Application
Rate
Chronic
RQ
Chronic
RQ
(
lbs
ai/
A)/
Based
on
Based
on
Number
of
Mean
EECs
Maximum
EECs
Mean
Maximum
Applications/
Site/

(
Mean
EEC/
NOAEC)
2
(
Max.
EEC/
NOAEC)
2
EEC
(
ppm)
1
EEC
(
ppm)
1
Food
Items
Interval
Application
Method
3.5
10
261
738
Short
grass
2.4/
10
Onion
&
Garlic
1.5
5
111
338
Tall
grass
7­
day
interval
ground
&
aerial
1.8
6
138
415
Broadleaf
plants/
Insects
0.3
0.6
22
46
Seeds
3.5
10
261
738
Short
grass
2.4/
7
Onion
(
green)
&
Tomato
a
1.5
5
111
338
Tall
grass
7­
day
interval
ground
&
aerial
1.8
6
138
415
Broadleaf
plants/
Insects
0.3
0.6
22
46
Seeds
2.4
7
179
504
Short
grass
2/
14
Papaya
1.0
3
76
231
Tall
grass
14­
day
interval
ground
&
aerial
1.3
4
95
284
Broadleaf
plants/
Insects
0.2
0.4
15
32
Seeds
3.5
10
261
738
Short
grass
2.4/
6
Pepper
a
1.5
5
111
338
Tall
grass
7­
day
interval
ground
&
aerial
1.8
6
138
415
Broadleaf
plants/
Insects
0.3
0.6
22
46
Seeds
2.3
7
174
492
Short
grass
1.6/
6
Pepper
b
1.0
3
74
225
Tall
grass
7­
day
interval
ground
&
aerial
1.2
4
92
277
Broadleaf
plants/
Insects
0.2
0.4
14
31
Seeds
2.7
8
206
581
Short
grass
1.6/
10
Potato
(
Maine,
only)

1.2
4
87
266
Tall
grass
5­
day
interval
ground
&
aerial
1.5
4
109
327
Broadleaf
plants/
Insects
0.2
0.5
17
36
Seeds
88
Table
5
(
continued):
Mammalian
Chronic
Risk
Quotients
for
Multiple
Applications
of
Maneb
Nongranular
(
Broadcast)
Based
on
a
labaratory
rats
(
Rattus
norvegicus)
NOAEL
of
75
ppm
h
Application
Rate
Chronic
RQ
Chronic
RQ
(
lbs
ai/
A)/
Based
on
Based
on
Number
of
Mean
EECs
Maximum
EECs
Mean
Maximum
Applications/
Site/

(
Mean
EEC/
NOAEC)
2
(
Max.
EEC/
NOAEC)
2
EEC
(
ppm)
1
EEC
(
ppm)
1
Food
Items
Interval
Application
Method
2.7
8
206
580
Short
grass
1.6/
7
Potato
1.2
4
87
266
Tall
grass
5­
day
interval
ground
&
aerial
1.5
4
109
326
Broadleaf
plants/
Insects
0.2
0.5
17
36
Seeds
2.3
7
174
491
Short
grass
1.6/
4
Tomato
b
1.0
3
74
225
Tall
grass
7­
day
interval
ground
&
aerial
1.2
4
92
276
Broadleaf
plants/
Insects
0.2
0.4
14
31
Seeds
1.7
5
129
365
Short
grass
1.2/
3
f
Ornamentals
e
0.7
2
55
167
Tall
grass
7­
day
interval
ground
0.9
3
68
205
Broadleaf
plants/
Insects
0.1
0.3
11
23
Seeds
25.0
71
1,875
5,294
Short
grass
17.4/
3
f
Turf
g
10.6
32
794
2,426
Tall
grass
7­
day
interval
ground
&
aerial
13.2
40
993
2,978
Broadleaf
plants/
Insects
2.1
4
154
331
Seeds
1
Assumes
degradation
using
FATE
version
5.0
program
with
a
foliar
dissipation
(
total
residue)
half­
life
of
3.2
days.

2
RQ
greater
or
equal
to
1.00
exceeds
chronic
LOC.

a
East
of
the
Mississippi
River
b
West
of
the
Mississippi
River
c
East
of
the
Rocky
Mountains
d
West
of
the
Rocky
Mountains
e
Trees,
Herbaceous
Plants,
Non
Flowering
Plants,
&
Woody
Shrubs
and
Vines
f
The
maximum
number
of
applications
per
crop
cycle
was
not
specified
on
the
labeling.

Three
(
3)
applications
per
crop
cycle
are
assumed
for
modeling
purposes.

g.
Residential,
Commercial/
Industrial,
Golf
Course,
Sod
Farm,
&
Recreational
h.
Reproductive
study,
based
on
parental
(
paternal)
effects
resulting
in
a
significant
increase
in
lung
(
both
generations)
and
liver
(
F1)
weight
and
an
increased
incidence
of
diffuse
follicular
epithelial
hypertrophy/
hyperplasia
(
F1)
and
fetal
effects
resulting
in
a
slight
delay
in
the
startle
response
in
the
offspring.
89
iii.
Insects
Currently,
EFED
does
not
assess
risk
to
non­
target
insects.
Results
of
acceptable
studies
are
used
for
recommending
appropriate
label
precautions.
Since
maneb
was
determined
to
be
practically
nontoxic
to
honey
bees
(
LD50
>
12
µ
g/
bee)
no
bee
precautionary
labeling
is
required
on
maneb
product
labeling.

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

The
PRZM/
EXAMS
modeling
tools
used
by
EFED
are
designed
to
be
conservative
tools;
with
90%
of
simulated
sites
expected
to
have
environmental
concentrations
lower
than
the
Tier
II
estimates.
EFED
uses
environmental
fate
and
transport
computer
models
to
calculate
refined
EECs.
PRZM
simulates
pesticide
surface
water
runoff
on
daily
time
steps,
incorporating
runoff,
infiltration,
erosion,
and
evaporation.
The
model
calculates
foliar
dissipation
and
runoff,
pesticide
uptake
by
plants,
soil
microbial
transformation,
volatilization,
and
soil
dispersion
and
retardation.
EXAMS
simulates
pesticide
fate
and
transport
in
an
aquatic
environment
(
one
hectare
body
of
water,
two
meters
deep
with
no
outlet).
The
EECs
have
been
calculated
so
in
any
given
year,
there
is
a
10%
probability
the
maximum
average
concentration
of
that
duration
in
that
year
will
equal
or
exceed
the
EEC
at
the
site.
The
Tier
II
model
uses
a
single
site
which
represents
a
high
exposure
scenario
for
the
use
of
the
pesticide
on
a
particular
crop
use
site.
The
model
simulates
weather
and
agricultural
practice
at
the
site
over
multiple
years
so
the
probability
of
an
EEC
occurring
at
that
site
can
be
estimated.
The
PRZM/
EXAMS
modeling
approach
is
an
uncertain
predictor
of
water
concentrations
in
estuarine/
marine
systems.
EFED
suspects,
though
it
hasn't
been
empirically
proved,
that
flushing
and
exchange
rates
within
these
systems
may
differ
from
those
assumed
in
the
existing
surface
water
modeling.
Sometimes,
flushing
and
exchange
may
be
greater
than
accounted
for
in
the
EXAMS
model
and
true
estuarine/
marine
water
concentrations
may
be
lower.
In
other
cases
tidal
entrapment
of
pollutants
may
contribute
to
higher
effective
pesticide
concentrations
than
predicted
by
the
model.

EFED
uses
the
EECs
for
assessing
acute
and
chronic
risks
to
aquatic
organisms.
EFED
uses
peak
EEC
values
to
calculate
acute
RQs
for
single
and
multiple
applications.
EFED
uses
21­
day
EECs
for
invertebrates
and
60­
day
EECs
for
fish
to
calculate
chronic
RQs.

EFED
selected
boundaries
used
in
Tier
II
(
PRZM/
EXAMS)
modeling
using
Agency
guidance
(
WQTT/
EFED/
OPP.
August,
2000)
and
EFED
calculated
degradation
rate
constants
from
review
of
registrant
filed
environmental
fate
studies.
90
Table
6:
Maneb
Acute
and
Chronic
Risk
Quotients
for
Freshwater
Fish
Based
On
a
Rainbow
Trout
(
Salmo
gairdneri)
LC50
of
42.0
ppb
and
a
Fathead
Minnow
(
Pimephales
promelas
)
NOAEC
of
6.1
ppb.
Application
Rate
(
lbs
ai/
A)/

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

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

0.30
2.00
1.8
84
4.8/
4
Apples
7­
day
interval
ground
&
aerial
0.34
2.69
2.1
113
1.6/
6
Pepper
a
7­
day
interval
ground
&
aerial
0.16
1.13
1
47.6
1.6/
10
Potato
(
Maine,
only)

5­
day
interval
ground
&
aerial
0.66
4.71
4
197.9
2.4/
7
Tomato
b
7­
day
interval
ground
&
aerial
1
Based
on
PRZM
version
3.12/
EXAMS
version
2.97.5
modeling.
2
RQ
greater
or
equal
to
0.5
exceeds
acute
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.

3
RQ
greater
or
equal
to
1.00
exceeds
chronic
LOC.

a
East
of
the
Mississippi
River
(
1.6
lb
ai/
A
is
a
W.
of
Miss.
R.
rate
for
peppers.
2.4
lb
ai/
A
6
times
every
7
days
is
the
E.
of
Miss.
R.
rate
 
the
scenario
is
FL)

b
East
of
the
Mississippi
River
ii.
Freshwater
Fish
Tabulated
below
in
Table
6
are
maneb's
acute
and
chronic
risk
quotients
for
freshwater
fish.
The
results
show
all
maneb
uses
exceed
acute,
acute
restricted
use,
and
acute
endangered
species
LOCs
(
acute
RQ
ranges
from
1.13
to
4.71).
No
chronic
LOCs
are
exceeded
for
freshwater
fish
from
maneb's
uses.
EFED
modeled
on
representative
maneb
uses.
EFED
has
not
developed
PRZM/
EXAMS
schemes
for
modeling
all
maneb
uses.
91
Table
7:
Maneb
Acute
Risk
Quotients
for
Freshwater
Invertebrate
Based
On
a
Waterflea
(
Daphnia
magna
)
LC50
of
120
ppb.
Application
Rate
(
lbs
ai/
A)/

Number
of
Acute
RQ
Applications/
Site/

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

0.70
84
4.8/
4
Apples
7­
day
interval
ground
&
aerial
0.94
113
1.6/
6
Pepper
a
7­
day
interval
ground
&
aerial
0.40
47.6
1.6/
10
Potato
(
Maine,
only)

5­
day
interval
ground
&
aerial
1.65
197.9
2.4/
7
Tomato
b
7­
day
interval
ground
&
aerial
1
Based
on
PRZM
version
3.12/
EXAMS
version
2.97.5
modeling.
2
RQ
greater
or
equal
to
0.5
exceeds
acute
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.

a
East
of
the
Mississippi
River
(
1.6
lb
ai/
A
is
a
W.
of
Miss.
R.
rate
for
peppers.
2.4
lb
ai/
A
6
times
every
7
days
is
the
E.
of
Miss.
R.
rate
 
the
scenario
is
FL)

b
East
of
the
Mississippi
River
iii.
Freshwater
Invertebrates
Tabulated
below
in
Table
7
are
maneb's
acute
risk
quotients
for
freshwater
invertebrates.
The
results
show
that
acute,
acute
restricted
use,
and
acute
endangered
species
RQs
exceed
LOCs
for
maneb's
use
on
apples,
tomatoes
and
peppers.
Restricted
use
and
acute
endangered
species
LOCs
are
exceeded
for
all
maneb
uses
(
acute
RQ
ranges
from
0.40
to
1.65).
92
Table
8:
Maneb
Acute
Risk
Quotients
for
Estuarine/
Marine
Fish
Based
On
a
Atlantic
silverside
(
Menidia
menidia
)
LC50
of
180
ppb.
Application
Rate
(
lbs
ai/
A)/

Number
of
Acute
RQ
Applications/
Site/

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

0.47
84
4.8/
4
Apples
7­
day
interval
ground
&
aerial
0.63
113
1.6/
6
Pepper
a
7­
day
interval
ground
&
aerial
0.26
47.6
1.6/
10
Potato
(
Maine,
only)

5­
day
interval
ground
&
aerial
1.10
197.9
2.4/
7
Tomato
b
7­
day
interval
ground
&
aerial
1
Based
on
PRZM
version
3.12/
EXAMS
version
2.97.5
modeling.
2
RQ
greater
or
equal
to
0.5
exceeds
acute
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.

a
East
of
the
Mississippi
River
(
1.6
lb
ai/
A
is
a
W.
of
Miss.
R.
rate
for
peppers.
2.4
lb
ai/
A
6
times
every
7
days
is
the
E.
of
Miss.
R.
rate
 
the
scenario
is
FL)

b
East
of
the
Mississippi
River
iv.
Estuarine/
Marine
Fish
Tabulated
below
in
Table
8
are
maneb's
acute
risk
quotients
for
esturarine/
marine
fish.
The
results
show
that
acute,
acute
restricted
use,
and
acute
endangered
species
RQs
exceed
LOCs
for
maneb's
use
on
tomatoes
and
peppers.
Restricted
use
and
acute
endangered
species
LOCs
are
exceeded
for
all
maneb
uses
(
acute
RQ
ranges
from
0.26
to
1.1).
93
Table
9:
Maneb
Acute
Risk
Quotients
for
Estuarine/
Marine
Invertebrates
Based
On
a
Mysid
Shrimp
(
Americamysis
bahia
)
LC50
of
3.0
ppb.
Application
Rate
(
lbs
ai/
A)/

Number
of
Acute
RQ
Applications/
Site/

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

28.00
84
4.8/
4
Apples
7­
day
interval
ground
&
aerial
37.67
113
1.6/
6
Pepper
a
7­
day
interval
ground
&
aerial
15.87
47.6
1.6/
10
Potato
(
Maine,
only)

5­
day
interval
ground
&
aerial
65.97
197.9
2.4/
7
Tomato
b
7­
day
interval
ground
&
aerial
1
Based
on
PRZM
version
3.12/
EXAMS
version
2.97.5
modeling.
2
RQ
greater
or
equal
to
0.5
exceeds
acute
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.

a
East
of
the
Mississippi
River
(
1.6
lb
ai/
A
is
a
W.
of
Miss.
R.
rate
for
peppers.
2.4
lb
ai/
A
6
times
every
7
days
is
the
E.
of
Miss.
R.
rate
 
the
scenario
is
FL)

b
East
of
the
Mississippi
River
v.
Estuarine/
Marine
Invertebrates
Tabulated
below
in
Table
9
are
maneb's
acute
risk
quotients
for
esturarine/
marine
invertebrates.
The
results
show
that
acute
RQs
exceed
acute,
acute
restricted
use,
and
acute
endangered
LOCs
for
all
maneb
uses
(
acute
RQ
ranges
from
15.87
to
65.97).
There
are
currently
no
estuarine/
marine
invertebrates
listed
as
endangered
species.
94
Table
10:
Maneb
Acute
Risk
Quotients
for
Aquatic
Non­
Vascular
Plants
Based
On
a
Green
Algae
(
Selenastrum
capricornutum
)
LC50
of
13.4
ppb.
Application
Rate
(
lbs
ai/
A)/

Number
of
Acute
RQ
Applications/
Site/
(
Peak
EEC/
LC50)
2
EEC
Peak
(
ppb)
1
Interval
Application
Method/

6.27
84
4.8/
4
Apples
7­
day
interval
ground
&
aerial
8.43
113
1.6/
6
Pepper
a
7­
day
interval
ground
&
aerial
3.55
47.6
1.6/
10
Potato
(
Maine,
only)

5­
day
interval
ground
&
aerial
14.77
197.9
2.4/
7
Tomato
b
7­
day
interval
ground
&
aerial
1
Based
on
PRZM
version
3.12/
EXAMS
version
2.97.5
modeling.

2
RQ
greater
or
equal
to
1.0
exceeds
acute
high
risk
LOCs.

a
East
of
the
Mississippi
River
(
1.6
lb
ai/
A
is
a
W.
of
Miss.
R.
rate
for
peppers.
2.4
lb
ai/
A
6
times
every
7
days
is
the
E.
of
Miss.
R.
rate
 
the
scenario
is
FL)

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

Shown
in
Table
10
are
the
acute
risk
quotients
for
freshwater,
nonvascular
green
alga
(
Selenastrum
capricornutum).
All
maneb's
use
patterns
exceed
acute
risk
LOCs
for
nonvascular
aquatic
plants
(
acute
RQ
ranges
from
3.55
to
14.77).
95
e.
Endangered
Species
Based
on
available
screening
level
information
there
is
a
potential
concern
for
maneb's
acute
effects
on
listed
freshwater
and
estuarine/
marine
animals
and
chronic
effects
on
listed
birds
and
mammals
should
exposure
actually
occur.
EFED
expects
maneb
poses
a
low
acute
risk
to
nontarget
insects
because
maneb
is
practically
nontoxic
to
honeybees,
(
acute
contact
LD
50
>
12
µ
g/
bee).
Also,
there
is
no
incident
data
reporting
adverse
effects
to
honeybees
from
maneb's
use.
However,
EFED
does
not
assess
risk
to
bees
using
RQs
because
a
screening
level
RQ
assessment
method
for
estimating
the
risk
to
bees
is
not
available.
EFED
has
not
developed
an
exposure
design
for
bees
to
estimate
the
risk
using
a
risk
quotient
method.
The
Agency
does
not
currently
have
enough
data
to
perform
a
screening
level
assessment
for
maneb's
effects
on
listed
nontarget
terrestrial
plants
or
vascular
aquatic
plants.
EFED
did
not
assess
chronic
risks
to
freshwater
invertebrates,
or
estuarine/
marine
fish
due
to
lack
of
data.
There
are
no
nonvascular
aquatic
plants
or
estuarine/
marine
invertebrate
species
on
the
endangered
species
list.

f.
Ecological
Incidents
The
Ecological
Incident
Information
System
(
EIIS)
(
see
Appendix
V
for
background
information)
reported
maneb
in
three
fish
kill
incidents.
An
incident
(
Incident
No.
B000­
223),
occurring
in
August,
1973,
reported
by
the
Oregon
Department
of
Agriculture
showed
some
fish
in
a
15
acre
pond
had
been
killed.
Presumably
drift
from
an
aerial
application
of
maneb
and
endosulfan
to
potatoes
caused
the
kill.
No
analyzes
of
the
dead
fish
was
provided.
Both
maneb
and
endosulfan
are
very
highly
toxic
to
freshwater
fish
[
maneb
rainbow
trout
LC50
=
42.0
ppb
and
endosulfan
rainbow
trout
LC50
=
0.37
ppb
(
US
EPA.
2001)]
and
both
pesticides
could
have
been
responsible
for
the
fish
kill,
if
in
fact
the
kill
was
pesticide
related.
However,
the
inadequate
information
provided
with
this
reported
incident
and
the
lack
of
laboratory
analyzes
makes
it
difficult
to
charge
this
fish
kill
to
either
pesticide.

The
second
maneb
related
incident
(
Incident
No.
I003826­
030)
occurred
in
June,
1994
and
was
reported
by
the
North
Carolina
Department
of
Agriculture.
The
owner
of
a
2.5
acre
commercial
fishpond
filed
a
complaint
of
a
fish
kill
in
the
pond
because
of
drift
from
applications
of
maneb,
trifluralin,
imazaquin,
pendimethalin,
and
acephate
aerially
applied
to
corn
and
soybean
fields
near
the
pond.
The
owner
felt
the
fish
kill
was
a
result
of
drift
from
these
pesticides.
The
North
Carolina
Department
of
Agriculture
investigated
this
complaint
and
took
samples
for
analyzes
but
the
sampling
evidence
did
not
confirm
the
presence
of
maneb
or
the
other
pesticides
listed
in
the
samples
taken.
Based
on
the
investigation
and
the
analysis
of
samples,
it
is
unlikely
that
maneb
contributed
to
this
fish
kill.

The
final
maneb
related
incident
(
Incident
Nos.
I002200­
001
and
I003596­
001),
occurring
in
August,
1994,
was
reported
by
the
Maine
Department
of
Agriculture.
In
this
incident
roughly
10,000
newly
released
brook
trout
were
killed
in
a
pond
that
borders
New
Brunswick,
Canada
and
Maine.
Three
pesticides
(
maneb,
esfenvalerate,
and
chlorothalonil)
recently
applied
to
potatoes
surrounding
this
pond
were
suspected
in
this
fish
kill.
Tissue
samples
of
the
fish
confirmed
the
presence
of
all
three
96
pesticides
(
maneb
at
169
ppb,
esfenvalerate
at
4.2
ppb,
and
chlorothalonil
at
20
ppb)
in
the
fish.
These
fish
samples
were
taken
from
both
the
pond
and
brooks
feeding
the
pond.
Again,
as
in
the
first
incident,
all
three
of
these
pesticides
are
very
highly
toxic
to
freshwater
fish.
Maneb's
rainbow
trout
LC50
is
42.0
ppb
,
esfenvalerate's
rainbow
trout
LC50
is
0.26
ppb
(
Hicks,
L.
May,
1995)
and
chlorothalonil's
rainbow
trout
LC50
is
42.3
ppb
(
US
EPA.
1998)].
The
submitter
of
the
incident
report
pointed
out
there
were
severe
thunderstorms
in
the
area
preceding
the
fish
kill
which
suggest
pesticide
runoff
was
a
cause
in
this
kill.
Based
on
sampling
evidence,
EFED
believes
maneb
was
contributory
cause
in
this
fish
kill.
97
APPENDIX
V:
US
EPA
Ecological
Incident
Information
System
The
Office
of
Pesticide
Programs
(
OPP)
has
tracked
incidents
reports,
given
to
EPA
since
about
1994,
by
assigning
identification
number
in
an
Incident
Data
System
(
IDS)
and
microfiching
the
reports.
The
Environmental
Fate
and
Effects
Division
(
EFED)
then
enters
the
ecological
related
incident
reports
into
a
second
database,
the
Ecological
Incident
Information
System
(
EIIS).
This
second
database
has
some
85
fields
for
potential
data
entry.
EFED
has
also
made
an
effort
to
enter
information
into
EIIS
on
incident
reports
received
before
establishment
of
current
databases.
Although
EFED
has
added
many
of
these
reports,
EIIS
does
not
yet
provide
a
listing
of
all
incident
reports
received
by
EPA.
OPP
does
not
receive
incident
reports
in
a
consistent
format.
For
example,
states
and
various
labs
usually
have
their
own
report
formats.
The
incidents
reports
may
involve
multiple
incidents
involving
multiple
chemicals
in
one
report,
and
may
report
on
only
part
of
an
incident
investigation
(
for
example,
residues).
EFED
has
made
some
progress
in
recent
years,
both
in
getting
incident
reports
sent
and
entered.
However,
there
has
never
been
enough
staff
time
and
effort
assigned
to
recording
incidents.
For
example,
the
staff
time
and
effort
assigned
to
tracking
and
reviewing
laboratory
toxicity
studies
are
greater
than
those
assigned
to
tracking
incidents.

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

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

EFED
believes
the
number
pesticide
related
incidents
reported
in
EIIS,
while
large,
are
a
small
fraction
of
pesticide
incidents.
EIIS
entered
incidents
requires
that
mortality
incidents
be
seen,
reported,
examined,
and
have
investigation
reports
sent
to
EPA.
Incidents
often
are
not
seen,
because
of
scavenger
removal
of
carcasses,
decay
in
a
field,
or
simply
because
carcasses
may
be
hard
to
see
on
many
sites.
Poisoned
wildlife
may
also
move
off­
site
to
less
visible
areas
before
dying.
Incidents
often
are
not
seen
because
few
people
are
systematically
looking.
Finders,
seeing
incidents,
may
not
report
incidents
to
suitable
authorities
to
examine
the
incident.
The
finder
may
not
know
that
it
is
important
to
report
incidents
or
may
not
know
who
to
contact.
He
or
she
may
not
feel
they
have
the
time
or
wish
to
make
a
telephone
call,
may
hesitate
to
call
because
of
their
own
involvement
in
the
98
kill,
or
the
call
may
be
long­
distance
which
may
discourage
the
caller.
Incidents
reported
may
not
get
examined
if
time
or
people
are
limited
or
may
not
get
examined
thoroughly,
with
residue
and
cholinesterase
analyzes,
for
example.
Also,
if
kills
are
not
reported
and
examined
at
once,
there
will
be
little
chance
of
documenting
the
cause,
since
tissues
and
residues
may
decay
quickly.
States
often
do
not
send
reports
of
examined
incidents
to
EPA,
since
reporting
by
states
is
voluntary
and
some
investigators
may
believe
that
they
don't
have
the
time
or
people
to
send
incident
reports
to
EPA.
(
Felkel.
2000)
99
APPENDIX
VI:
EBDC
Aquatic
Studies
EBDC
Aquatic
Studies
Used
for
Calculating
Risk
Quotients
With
Associated
Study
Parameters
­
3/
13/
2003
MRID
No.
Chemical
Species
Tested
Water
type
Water
Analysis
(
cations,
anions,

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

Test
Concentrations
Range
(
ppm)
Measured
(
filtered)

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

0.05
60
GC3
for
CS
2
LC
50
=

0.2294
96
core
44301101
metiram
water
flea
freshwater
deionized
water,

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

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

1.0
Not
applicable
Not
applicable
0.1
Not
applicable
EC
50
=

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

0.020
0.00096
­

0.012
Not
applicable
11.5
GC3
for
CS
2
NOAEC
=
0.00616
35
days
core
40749402
maneb
water
flea
freshwater
softwater
and
well
water
S
0.08
­
1.0
ND2
­
0.39
Not
applicable
0.1
GC3
for
CS
2
LC
50
=

0.126
48
core
EBDC
Aquatic
Studies
Used
for
Calculating
Risk
Quotients
With
Associated
Study
Parameters
­
3/
13/
2003
MRID
No.
Chemical
Species
Tested
Water
type
Water
Analysis
(
cations,
anions,

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

Test
Concentrations
Range
(
ppm)
Measured
(
filtered)

Test
Concentrations
Range
(
ppm)
and
Filter
Size
(
µ
m)
Test
Aquaria
Size
(
L)
Chemical
Analyses
(
Parent
or
Other?)
Toxicity
Endpoint
(
ppm)
Exposure
Time
(
hours)
Study
Categorization
100
40943101
maneb
Atlantic
silverside
Estuari
ne/
mar
ine
filtered
(
0.5
µ
m)

seawater
(
salinity
~
20%)

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

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

seawater
(
salinity
~
20%)

&
EDTA
F
0.005
­

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

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

0.040
0.0004
­

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

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

0.02
0.000236
­

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

LSC10
for
14C
NOAEC
=
0.002196
for
GC
&

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

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

0.585
48
core9
40953802
mancozeb
water
flea
freshwater
EDTA
added
F
0.003
­

0.05
0.0029
­

0.053
Not
applicable
1.0
GC3
for
CS
2
&

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

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

1.66
96
supplemental
EBDC
Aquatic
Studies
Used
for
Calculating
Risk
Quotients
With
Associated
Study
Parameters
­
3/
13/
2003
MRID
No.
Chemical
Species
Tested
Water
type
Water
Analysis
(
cations,
anions,

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

Test
Concentrations
Range
(
ppm)
Measured
(
filtered)

Test
Concentrations
Range
(
ppm)
and
Filter
Size
(
µ
m)
Test
Aquaria
Size
(
L)
Chemical
Analyses
(
Parent
or
Other?)
Toxicity
Endpoint
(
ppm)
Exposure
Time
(
hours)
Study
Categorization
101
41822901
mancozeb
mysid
shrimp
Estuari
ne/
mar
ine
filtered
seawater
with
well
water
(
salinity
~
20%)

Na
3
EDTA
added
F
0.003
­

0.04
0.0034
­

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

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

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

2.
None
detected
3.
Gas
chromatography
4.
Based
on
filtered
and
measured
concentration.

5.
Based
on
nominal
concentration.

6.
Based
on
measured
(
unfiltered)
concentration.

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

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

9.
Categorization
based
on
acceptance
in
1987
Mancozeb
Standard
EBDC
Aquatic
Studies
Used
for
Calculating
Risk
Quotients
With
Associated
Study
Parameters
­
3/
13/
2003
MRID
No.
Chemical
Species
Tested
Water
type
Water
Analysis
(
cations,
anions,

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

Test
Concentrations
Range
(
ppm)
Measured
(
filtered)

Test
Concentrations
Range
(
ppm)
and
Filter
Size
(
µ
m)
Test
Aquaria
Size
(
L)
Chemical
Analyses
(
Parent
or
Other?)
Toxicity
Endpoint
(
ppm)
Exposure
Time
(
hours)
Study
Categorization
102
10.
LSC
detection.
The
process
by
which
radioactive
decay
energy
is
converted
to
visible
light
and
measured
in
an
organic
liquid
environment
is
called
LIQUID
SCINTILLATION
COUNTING
(
LSC).
In
Liquid
Scintillation
Counting,
the
amount
of
light
produced
is
proportional
to
the
amount
of
radiation
present
in
the
sample
and
the
energy
of
the
light
produced
is
proportional
to
the
energy
of
the
radiation
that
is
present
in
he
sample.
This
makes
LSC
a
very
convenient
tool
to
measure
radioactivity.
http://
www.
sfu.
ca/~
rsafety/
APPEND9.
pdf
103
APPENDIX
VII:
Maneb
Revised
Risk
Quotients
for
Almonds
&
Turf
Uses
This
appendix
reflects
the
registrant's
proposed
use
pattern
changes
for
almonds
and
turf.
For
almonds,
the
registrant
intends
to
reduce
the
maximum
number
of
applications
per
crop
cycle
from
4
to
3.
For
turf,
the
registrant
intends
to
reduce
the
maximum
application
rate
from
17.4
lb
ai/
A
to
8.7
lb
ai/
A
and
set
the
maximum
number
of
applications
per
crop
cycle
at
4.
Tables
1
and
2
show
the
new
maneb
avian
and
mammalian
RQs
resulting
from
these
use
pattern
revisions
to
almonds
and
turf.
Although
the
RQs
are
less
they
still
exceed
chronic
LOCs
for
birds
and
mammals.

Previously
maneb's
chronic
avian
RQs
on
almond
ranged
from
98
(
maximum
EEC
exposure)
for
birds
feeding
on
short
grass
to
2.9
(
mean
EEC
exposure)
for
birds
feeding
on
seeds.
The
proposed
change
reduces
the
chronic
avian
RQs
on
almonds
ranging
from
97
(
maximum
EEC
exposure)
for
birds
feeding
on
short
grass
to
2.8
(
mean
EEC
exposure)
for
birds
feeding
on
seeds.
Previously
maneb's
chronic
avian
RQs
on
turf
ranged
from
265
(
maximum
EEC
exposure)
for
birds
feeding
on
short
grass
to
7.7
(
mean
EEC
exposure)
for
birds
feeding
on
seeds.
The
proposed
change
reduces
the
chronic
avian
RQs
on
turf
ranging
from
133
(
maximum
EEC
exposure)
for
birds
feeding
on
short
grass
to
3.9
(
mean
EEC
exposure)
for
birds
feeding
on
seeds.
Avian
chronic
LOCs
are
still
exceeded
for
maneb's
almond
and
turf
use
patterns.

Table
1:
Avian
Chronic
Risk
Quotients
for
Multiple
Broadcast
Applications
of
Nongranular
Maneb
based
on
a
Mallard
Duck
(
Anas
platyrhynchos)
NOAEC
of
20
ppm.
Application
Rate
Chronic
RQ
Chronic
RQ
(
lbs
ai/
A)/

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

(
Mean
EEC/
NOAEC)
2
(
Max.
EEC/
NOAEC)
2
EEC
(
ppm)
1
EEC
(
ppm)
1
Food
Items
Interval
Application
Method
34.5
97
690
1,947
Short
grass
6.4/
3
Almonds
14.6
45
292
892
Tall
grass
7­
day
interval
ground
&
aerial
18.3
55
365
1,095
Broadleaf
plants/
Insects
2.8
6
57
122
Seeds
47.3
133
945
2,669
Short
grass
8.7/
4
Turf
a
20.0
61
400
1,223
Tall
grass
7­
day
interval
ground
&
aerial
25.0
75
500
1,501
Broadleaf
plants/
Insects
3.9
8
78
167
Seeds
1
Assumes
degradation
using
FATE
version
5.0
program
with
a
foliar
dissipation
(
total
residue)
half­
life
of
3.2
days.

2
RQ
greater
or
equal
to
1.00
exceeds
chronic
LOC.

a.
Residential,
Commercial/
Industrial,
Golf
Course,
Sod
Farm,
&
Recreational
104
Previously
maneb's
chronic
mammalian
RQs
on
almonds
ranged
from
26
(
maximum
EEC
exposure)
for
mammals
feeding
on
short
grass
to
0.8
(
mean
EEC
exposure)
for
mammals
feeding
on
seeds.
The
proposed
change
doesn't
reduce
the
chronic
mammalian
RQs
on
almonds.
The
new
RQs
still
range
from
26
(
maximum
EEC
exposure)
mammals
feeding
on
short
grass
to
0.8
(
mean
EEC
exposure)
for
mammals
feeding
on
seeds.
Previously
maneb's
chronic
mammalian
RQs
on
turf
ranged
from
71
(
maximum
EEC
exposure)
for
mammals
feeding
on
short
grass
to
2.1
(
mean
EEC
exposure)
for
mammals
feeding
on
seeds.
The
proposed
change
reduces
the
chronic
mammalian
RQs
on
turf
ranging
from
36
(
maximum
EEC
exposure)
for
mammals
feeding
on
short
grass
to
1.0
(
mean
EEC
exposure)
for
mammals
feeding
on
seeds.
Mammalian
chronic
LOCs
are
still
exceeded
for
maneb's
almond
and
turf
use
patterns.

Table
2:
Mammalian
Chronic
Risk
Quotients
for
Multiple
Applications
of
Maneb
Nongranular
(
Broadcast)
Based
on
a
labaratory
rats
(
Rattus
norvegicus)
NOAEL
of
75
ppm
b
Application
Rate
Chronic
RQ
Chronic
RQ
(
lbs
ai/
A)/

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

(
Mean
EEC/
NOAEC)
2
(
Max.
EEC/
NOAEC)
2
EEC
(
ppm)
1
EEC
(
ppm)
1
Food
Items
Interval
Application
Method
9.2
26
690
1,947
Short
grass
6.4/
3
Almonds
3.9
12
292
892
Tall
grass
7­
day
interval
ground
&
aerial
4.9
15
365
1,095
Broadleaf
plants/
Insects
0.8
2
57
122
Seeds
12.6
36
945
2,669
Short
grass
8.7/
4
Turf
a
5.3
16
400
1,223
Tall
grass
7­
day
interval
ground
&
aerial
6.7
20
500
1,501
Broadleaf
plants/
Insects
1.0
2
78
167
Seeds
1
Assumes
degradation
using
FATE
version
5.0
program
with
a
foliar
dissipation
(
total
residue)
half­
life
of
3.2
days.

2
RQ
greater
or
equal
to
1.00
exceeds
chronic
LOC.

a.
Residential,
Commercial/
Industrial,
Golf
Course,
Sod
Farm,
&
Recreational
b.
Reproductive
study,
based
on
parental
(
paternal)
effects
resulting
in
a
significant
increase
in
lung
(
both
generations)
and
liver
(
F1)
weight
and
an
increased
incidence
of
diffuse
follicular
epithelial
hypertrophy/
hyperplasia
(
F1)
and
fetal
effects
resulting
in
a
slight
delay
in
the
startle
response
in
the
offspring.
105
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