1
UNITED
STATES
ENVIRONMENTAL
PROTECTION
AGENCY
WASHINGTON
D.
C.,
20460
MEMORANDUM
PC
Code:
109901
DP
Barcode:
D325054
SUBJECT:
Environmental
Fate
and
Effects
Division
Error­
only
corrections
and
revised
Triadimefon
RED
FROM:
Michelle
Rau
Embry,
Ph.
D.
Jonathan
Angier,
Ph.
D.
Environmental
Risk
Branch
II
Environmental
Fate
and
Effects
Division
(
7507C)

TO:
John
Pates,
Jr.
Chemical
Review
Manager
Reregistration
Division
(
7508C)

THROUGH:
Dana
Spatz,
RAPL
Tom
Bailey,
Ph.
D.,
Branch
Chief
Environmental
Risk
Branch
II
Environmental
Fate
and
Effects
Division
(
7507C)

DATE:
January
19,
2006
The
following
are
the
Environmental
Fate
and
Effects
Division
(
EFED)
responses
to
Bayer's
Error
Correction
Comments
dated
December
28,
2005.

13.
Triadimefon
Ecological
Risk
Assessment,
Page
12,
Paragraph
3,
Lines
22­
23
EPA
Statement:
"
Although
another
triadimefon
degradate
is
formed,
triazole,
no
toxicity
data
are
available
and
therefore
it
is
not
considered
in
this
assessment"

Bayer's
response:
"
Data
is
available
for
the
triazole
metabolite
and
has
been
submitted
to
the
Agency
under
the
US
Triazole
Task
Force.
The
triazole
risk
assessment
is
being
performed
under
a
separate
analysis.
BCS
recommends
the
Agency
to
revise
the
statement
to
accurately
reflect
the
status
of
the
triazole
data
and
assessment."
2
EPA
response:
The
statement
has
been
changed
to
read,
"
1,2,4­
triazole
is
also
formed
as
a
degradate
of
triadimefon;
however,
this
compound
is
not
addressed
in
this
risk
assessment
and
will
be
examined
in
a
future
separate
risk
assessment
by
the
Agency."

14.
Triadimefon
Ecological
Risk
Assessment,
Page
12,
Paragraph
4,
Lines
2­
4
EPA
statement:
"
Additionally,
aquatic
environment
exposure
is
a
major
focus,
due
to
the
large
runoff
potential
resulting
from
triadimefon
use
on
golf
courses,
residential
lawns,
and
other
turf
area "

Bayer's
response:
"
The
assessment
appears
to
be
quite
comprehensive,
with
equal
weighting
given
to
both
terrestrial
and
aquatic
risks."

EPA
response:
Although
this
assessment
does
give
equal
focus
to
both
terrestrial
and
aquatic
risks,
the
aforementioned
paragraph
is
simply
discussing
the
triadimefon
use
(
turf)
that
contributed
most
heavily
to
the
overall
triadimefon
risk
picture.

15.
Triadimefon
Ecological
Risk
Assessment,
Page
19,
Paragraph
4,
Lines
3­
6
EPA
statement:
"
EPA
re­
iterates
that
there
is
no
data
available
for
the
triazole
metabolite."

Bayer
response:
"
As
mentioned
above,
this
statement
should
be
corrected
to
accurately
reflect
the
status
of
the
triazole
data
and
assessment."

EPA
response:
The
wording
of
the
aforementioned
paragraph
was
changed
to,
"
1,2,4­
triazole
is
also
formed
as
a
degradate
of
triadimefon;
however,
this
compound
is
not
addressed
in
this
risk
assessment
and
will
be
examined
in
a
future
separate
risk
assessment
by
the
Agency."

16.
Triadimefon
Ecological
Risk
Assessment,
Page
19,
Paragraph
4,
Lines
3­
6
EPA
statement:
"
The
fathead
minnow
study
demonstrated
a
NOAEL
of
1700
ppb
based
on
adult
survival
(
MRID
41922103)

Bayer's
response:
"
The
NOAEL
from
the
cited
study
should
be
170
ppb
(
0.170
ppm)

EPA
response:
The
correction
was
made
to
the
text.
All
tables
and
RQ
calculations
in
the
original
document
were
made
using
the
correct
(
170
ppb)
value.

17.
Triadimefon
Ecological
Risk
Assessment,
Page
49,
Paragraph
5,
Lines
1­
2
3
EPA
statement:
"
The
acute
oral
toxicity
of
triadimefon
(
TGAI)
to
14­
day
old
mallard
ducks
(
Anas
platyrhynchos)
was
assessed
over
8
days
(
MRID
50070)."

Bayer
response:
"
There
is
no
avian
study
listed
in
Appendix
C
with
this
MRID
number.
The
number
provided
in
Appendix
C
(
page
170)
may
be
the
CDL
number
(
see
citation
below).
Either
the
text
on
page
49
or
Appendix
C
needs
to
be
corrected.
The
correct
MRID
according
to
NPIRS
is
00050070.

EPA
response:
Both
Appendix
C
and
the
text
MRID
numbers
were
corrected
to
00050070
(
Lamb,
1977).

18.
Triadimefon
Ecological
Risk
Assessment,
Page
49,
Paragraph
5,
Lines
2­
3
EPA
statement:
"
The
8­
day
acute
oral
LD50
exceeded
the
highest
does
tested
(>
5000
mg
ai/
kg
bw)."

Bayer
response:
"
As
noted
in
Appendix
C
(
page
172),
the
acute
oral
LD50
for
mallard
ducks
is
>
4000
mg
ai/
kg
bw.

EPA
response:
The
text
was
corrected
to
reflect
an
acute
oral
LD50
value
of
>
4000
mg
ai/
kg
bw
for
mallard
ducks.

19.
Triadimefon
Ecological
Risk
Assessment,
Page
50,
Paragraph
1,
Line
3
EPA
statement:
EPA
provides
the
MRID
number
for
the
northern
bobwhite
quail
study
as
50067.

Bayer
response:
"
The
MRID
number
for
the
northern
bobwhite
quail
study
is
00050066."

EPA
response:
The
MRID
number
was
corrected
to
00050066.

20.
Triadimefon
Ecological
Risk
Assessment,
Page
50,
Paragraph
2,
Line
2
EPA
statement:
"
The
acute
oral
(
LC50)
toxicity
of
triadimenol "

Bayer
response:
"
The
parenthetical
statement
should
read
(
LD50)."

EPA
response:
The
parenthetical
statement
was
corrected
to
read
(
LD50).

21.
Triadimefon
Ecological
Risk
Assessment,
Page
60,
Table
23
Heading
4
EPA
statement:
EPA
provided
the
endpoint
used
in
the
acute
risk
characterization,
but
not
the
chronic.

Bayer
response:
"
BCS
recommends
that
the
chronic
endpoint
of
interest
be
added
to
the
heading
table."

EPA
response:
The
chronic
endpoint
(
NOAEC
of
50mg/
kg
diet)
was
added
to
the
table
heading.

22.
Triadimefon
Ecological
Risk
Assessment,
Page
170,
Table
Toxicity
of
the
degradate,
triadimenol,
to
birds
­
acute
EPA
statement:
Second
study
listed
 
Mallard
duck
LD50>
5000
MRID
071469
Lamb
Bayer
response:
"
BCS
believes
the
study
being
cited
is
an
avian
dietary
subacute
(
LC50)
for
the
triadimenol
metabolite.
In
the
study,
the
LC50
values
for
both
bobwhite
quail
and
mallard
duck
were
>
5000
ppm
(
see
citation
below).
The
table
should
be
corrected,
a
new
table
for
LC50
values
prepared.
Additionally,
earlier
in
the
document
(
e.
g.,
page
46
(
Table
18),
page
50
(
2nd
paragraph),
and
perhaps
elsewhere)
the
chapter
notes
that
dietary
data
is
not
available
for
the
metabolite.
These
statements
should
be
corrected.

00126277
Lamb
D.;
Toll,
P.;
Mallicoat,
D.;
et
al.
(
1981)
Acute
Dietary
LC50
of
Techinical
Triadimenol
(
Baytan)
to
Mallard
Ducks
and
Bobwhite
Quail:
Study
No.
80­
175­
09
and
80­
175­
05.
(
Unpublished
study
received
Mar
11,
1983
under
3125­
346;
submitted
by
Mobay
Chemical
Corp.,
Kansas
City,
MO;
CDL:
071469­
F)

EPA
response:
The
subacute
dietary
study
(
MRID
00126277)
was
added
to
the
toxicity
tables
in
Appendix
C,
as
well
as
page
46,
Table
2.
It
is
noted
throughout
the
chapter
that
dietary
data
is
available
for
the
triadimefon
metabolite,
triadimenol.

23.
Triadimefon
Ecological
Risk
Assessment,
Page
171,
Table
Toxicity
of
triadimefon
to
birds
 
subacute
dietary
EPA
statement:
Fourth
study
listed
 
Mallard
duck
LC50>
4650
MRID
00050067
Fink/
1977
Bayer
response:
"
In
the
study
with
the
MRID
00050067,
no
birds
died
at
the
highest
level
tested
(
10,000
ppm).
Therefore
the
LC50
should
be
>
10,000
ppm
EPA
response:
The
LC50
was
corrected
to
>
10,000ppm.

24.
Triadimefon
Ecological
Risk
Assessment,
Page
171,
Table
Mammalian
Toxicity
of
Triadimenol
5
Bayer
comment:
"
The
table
has
no
entries.
Bayer
recommends
that
the
table
be
completed."

EPA
response:
The
table
has
been
completed.

25.
Triadimefon
Ecological
Risk
Assessment,
Page
57,
Last
line
EPA
statement:
"
No
RQ
values
were
calculated
for
estuarine/
marine
fish
and
invertebrates
because
to
toxicity "

Bayer
response:
"
The
statement
should
read,
 
because
no 

EPA
response:
The
sentence
was
corrected.
