UNITED
STATES
ENVIRONMENTAL
PROTECTION
AGENCY
WASHINGTON
D.
C.,
20460
OFFICE
OF
PREVENTION,
PESTICIDES
AND
TOXIC
SUBSTANCES
October
25,
2005
PC
Code:
109702
DP
Barcode:
D293410
MEMORANDUM
Subject:
Revised
EFED
Risk
Assessment
for
the
Reregistration
Eligibility
Decision
(
RED)
on
Cypermethrin
After
30­
Day
"
Error
Only"
Comment
Period
To:
Veronique
LaCapre,
Chemical
Review
Manager
Yan
Donovan,
Chemical
Review
Manager
Margaret
Rice,
Branch
Chief
Reregistration
Branch
II
Special
Review
and
Reregistration
Division
(
7505C)

From:
Miachel
Rexrode,
Ph.
D.,
Fishery
Biologist
José
Luis
Meléndez,
Chemist
Environmental
Risk
Branch
V
Environmental
Fate
and
Effects
Division
(
7507C)

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

The
registrants
of
cypermethrin,
Valent
BioSciences
Corporation,
FMC
Corporation
and
Syngenta
Crop
Protection
provided
error
correction
comments
on
the
Draft
of
the
EFED
Chapter
of
the
Reregistration
Elegibility
Document
(
RED)
for
Cypermethrin.
The
purpose
of
this
memorandum
is
to
address
those
comments.
The
revised
science
chapter
and
appendices
are
issued
under
DP
Barcode
D293412.

In
general,
the
EFED
addressed
the
errors
only
comments.
Those
from
FMC
Corporation
and
Syngenta
Crop
Protection,
were
addressed
first,
using
the
original
comments
that
they
provided
in
a
table
format,
with
the
responses
added.
Valent
BioSciences
Corporation
provided
a
one­
page
table
with
comments
(
image
provided
in
this
review).
Those
comments
are
addressed
at
the
end
of
this
document.
2
FMC
Corporation
and
Syngenta
Crop
Protection
Error
Correction
Comments
and
Responses:

Note:
Typographical
errors
were
noted
in
a
separate
pdf
file.
They
are
not
listed
in
this
review.

Header
pdf
Version
Page
#;
Paragraph
#
Comments
Uncertainties:
Environmental
Fate
Page
iii,
4
The
paragraph
describes
model
uncertainty.
Please
reword
the
second
sentence
for
clarity.
"
The
results
of
a
simplistic
analysis
of
spray
drift
and
buffer
zones 
indicated
that
the
concentrations
resulting
from
actual
applications
of
cypermethrin
could
be
higher
or
lower
depending
upon
actual
application
practices."
RESPONSE:
THE
SENTENCE
WAS
MODIFIED
SLIGHTLY
FOR
CLARITY,
BUT
NOT
ACCORDING
TO
THE
REGISTRANT'S
RECOMMENDATION.
Table
of
Contents
General
comments
1)
Supplementary
tables
are
not
listed
in
the
Table
of
Contents.
2)
Most
of
the
Figures
are
not
listed
in
the
table
of
contents.
3)
The
table
of
contents
needs
to
be
updated
to
reflect
actual
page
numbers
in
the
document.
RESPONSE:
THESE
WERE
CORRECTED.
Page
vi,
leachingadsorption
desorption
MRID
42129002
RESPONSE:
AGREE,
CORRECTED.
Table
I­
1,
Cypermethrin
Table
of
Environmental
Fate
Data
Requirements
Page
vi,
aquatic
field
dissipation
MRID
44876107­
needs
to
be
added
to
references.
RESPONSE:
AGREE,
ADDED.
Page
x.
72­
4,
MRID
89047
is
a
21­
day
daphnia
magna
not
a
marine
study
but
freshwater
study
RESPONSE:
AGREED,
THIS
HAS
BEEN
CHANGED
Page
x,
aquatic
invertebrate
life­
cycle
(
freshwater)
MRID
45121822­
needs
to
be
referenced
RESPONSE:
CORRECTED
Table
I­
2,
Ecological
Effects
Data
Requirements
for
Cypermethrin
Page
xi
MRID
40274001­
residues
on
foliage
honeybee
toxicity
test
needs
to
be
referenced
RESPONSE:
CORRECTED
Table
of
Contents
iii,
B.
1.
d
Page
xiii
`
d.'
should
be
bioaccumulation
and
`
e'
should
be
Field
Studies.
RESPONSE:
AGREE,
CORRECTED.
Table
of
Contents
IV,
A.
1.
C.
Page
xiv
`
c.'
should
be
`
use
of
buffer
zones'
and
`
d.'
should
be
aquatic
plants
RESPONSE:
AGREE,
CORRECTED.
Table
of
Contents
IV,
B.,
5.,
e.
Page
xv
Co­
occurrence
Analysis
­
These
sections
do
not
appear
to
be
in
the
text:
(
2)
Probit
dose
Response
Relationship,
(
3).
Data
Related
to
Under­
represented
Taxa
and
(
4).
Implications
of
Sublethal
Effects
and
c
Indirect
Effects
Analysis.
RESPONSE:
AGREE,
THEY
WERE
DELETED
FROM
THE
TABLE
OF
CONTENTS.
3
Header
pdf
Version
Page
#;
Paragraph
#
Comments
B.
Potential
Risk
to
Non­
target
Organisms
Page
1;
2
Where
is
the
Tier
I
evaluation
of
the
six
crop
scenarios?
Using
GENEEC
for
NC
cotton
yields
EECs
less
than
the
Tier
II
PRZM/
EXAMS
EECs.
RESPONSE:
THIS
COMMENT
IS
NOT
AN
ERROR,
IT
WILL
BE
ADDRESSED
IN
A
SUBSEQUENT
PHASE.
Page
2,
paragraph
1
of
this
section
1
st
bullet,
parenthesis
should
also
include
a
category
of
marine/
estuarine
fish.
RESPONSE:
CORRECTED
Risk
to
Aquatic
Organisms
Page
2,
paragraph
2
of
this
section
2
nd
bullet,
there
is
a
typo,
the
sentence
should
read
" 
exceed
the
LOC
for
freshwater
and
marine/
estuarine
fish,
and
marine/
estuarine
invertebrates".
RESPONSE:
CORRECTED
C.
Conclusions­
Exposure
Characterizations
Page
3,
paragraph
1­
3
Page
4,
paragraph
2
Please
utilize
the
following
e­
fate
parameter
when
assessing
exposure
from
here
and
throughout
the
entire
document
in
Tables
and
verbiage:
 
161­
1
Aqueous
Photolysis
value
is
30.1
days.
 
161­
3
Soil
Photolysis
value
is
165
days.
 
162­
1
Aerobic
Soil
Metabolism
value
is
39.2
days
[
mean
+
confidence
limit
(
CL)].
 
162­
2
Anaerobic
Soil
Metabolism
value
is
165
days
[
mean
+
CL].
 
162­
4
Aerobic
Aquatic
Metabolism
value
is
10.6
days
[
mean
+
CL].
 
162­
3
Anaerobic
Aquatic
Metabolism
value
is
22.2
days
[
mean
+
CL].
 
163­
1
The
Koc
value
is
310,000.
 
165­
4
The
bioconcentration
factor
based
on
fish
whole­
body
analysis
is
597.
Reference:
Laskowski,
D.
2002.
Reviews
of
Environmental
Contamination
and
Toxicity.
Volume
174.
RESPONSE:
THIS
IS
NOT
AN
ERROR,
THIS
COMMENT
WILL
BE
ADDRESSED
IN
A
SUSEQUENT
PHASE.
Header
pdf
Version
Page
#;
Paragraph
#
Comments
C.
Conclusions­
Exposure
Characterizations
Page
4;
5
According
the
cypermethrin
label,
the
risk
assessment
should
only
be
conducted
with
the
following
buffers:
The
label
of
cypermethrin
requires
the
following
buffer
zones:
25
ft
for
ground
applications;
150
ft
for
aerial
applications;
and
450
ft
for
ultra
low
volume
(
ULV)
aircraft
application.
A
vegetative
filter
strip
is
also
required
(
10
ft)
to
protect
any
aquatic
area
from
runoff.
RESPONSE:
THE
SENTENCE
WAS
MODIFIED
TO
INDICATE
THAT
A
150
ft
BUFFER
ZONE
IS
IMPOSED
(
AS
OPPOSED
TO
"
PROPOSED"),
FOR
AERIAL
APPLICATIONS.
D.
Conclusions
Page
5.
Last
sentence
in
1
st
paragraph
in
section,
does
not
seem
to
belong,
delete
entire
sentence.
RESPONSE:
CORRECTED
4
Last
sentence
on
page,
add
"
LOAEC"
before
0.33
ug
ai/
L.
RESPONSE:
CORRECTED
Page
6
1
st
string
of
words
on
page;
complete
the
sentence
by
including
­
 
produced
NOAEC
at
0.78ng
ai/
L
based
on
1
st
generation
mortality,
a
NOEC
of
1.5
ng
ai/
L
was
observed
based
on
survival
and
reproduction.
RESPONSE:
CORRECTED
Page
6,
2
nd
full
paragraph
States
avian
repro
studies
were
incomplete
because
LOAEC
was
not
determined
however
on
page
E­
61
both
studies
are
classified
as
Acceptable
and
in
the
4
th
line
above
the
table
it
is
stated
that
"
The
guideline
(
71­
4)
is
fulfilled."
RESPONSE:
CORRECTED
AND
CHANGED
TO
SUMMENTAL.
AVIAN
REPORDUCTION
STUDY
MUST
BE
REPEATED
IN
ORDER
TO
ESTABLISH
LOAEC.
Page
7.
Section
II.
A.
1
Source
and
Intensity.
This
assessment
only
addressed
the
risks
from
agricultural
uses
of
cypermethrin.
RESPONSE:
THIS
COMMENT
IS
NOT
AN
ERROR;
THE
FIRST
SENTENCE
OF
SECTION
IB
ALREADY
STATES
THAT
THE
FOCUS
OF
THE
ASSESSMENT
IS
ON
AGRICULTURAL
APPLICATIONS.
Page
8
1
st
sentence
in
section,
RED
should
cite
Koc
of
310000
(
based
on
extensive
work
from
PWG)
RESPONSE:
THIS
ISSUE
WAS
ADDRESSED
PREVIOUSLY,
PLEASE
SEE
ABOVE
(
pp.
3­
4).
Problem
Formulation
Page
8.
Section
II.
A.
2
("
Physical/
Chemical/
fate
and
transport
properties").
EFED
refer
to
a
Koc
value
of
20,800.
As
EFED
are
aware,
there
is
a
published
peer
reviewed
review
of
pyrethroid
fate
properties,
including
those
of
cypermethrin
(
Laskowski,
MRID
45169501)
containing
all
the
quality
ranked
data
on
soil
sorption.
The
Laskowski
publication
provides
a
thorough
assessment
of
soil
sorption
properties
and
proposes
that
best
estimate
for
the
Koc
of
cypermethrin
is
310,000,
indicating
that
the
value
referred
to
by
EFED
is
an
underestimate.
RESPONSE:
THIS
ISSUE
WAS
ADDRESSED
PREVIOUSLY,
PLEASE
SEE
ABOVE
(
pp.
3­
4).
Header
pdf
Version
Page
#;
Paragraph
#
Comments
Problem
Formulation
Page
9,
Table
1
Log
Kow
should
be
6.54
not
6.4
RESPONSE:
AGREE,
CORRECTED.
5
Page
12.
Section
II.
B.
3
("
Ecosystems
at
Risk")
Reiterates
ecological
effects
and
tries
to
justify
assessment
endpoints,
but
doesn't
say
anything
about
which
ecosystems
are
potentially
at
risk,
nor
about
the
protection
goals
for
those
ecosystems.
In
the
first
paragraph
it
is
stated
"
in
order
to
protect
threatened
and
endangered
species,
all
assessment
endpoints
are
measured
at
the
individual
level
and
provide
insight
about
risks
at
higher
levels
of
biological
organization
(
e.
g.,
populations
and
communities)."
Does
this
sentence
apply
only
to
T&
E
species 
i.
e.,
protection
is
applied
at
the
individual
level?
RESPONSE:
CORRECTED.
This
applies
to
engangered
and
threatened
species. 
Or
is
this
intended
to
link
the
individual­
based
measures
of
effect
to
the
population
and
community­
based
assessment
endpoints
for
non­
T&
E
species
as
well?
The
statement,
"
pesticide
effects
on
individual
survivorship
have
important
implications
for
 
habitat
carrying
capacity"
is
questionable;
habitat
carrying
capacity
sets
the
limit
to
population
abundance,
but
how
is
the
habitat's
carrying
capacity
for
a
population
influenced
by
individual
survivorship
within
that
population?
RESPONSE:
AGREED
AND
CHANGED.
10
4.
Overview 
2
nd
paragraph
(
last
in
section),
clarify
the
bifenthrin
RED
reference
and
update
reference
section.
RESPONSE:
THIS
SENTENCE
WAS
INACURATE
AND
WAS
DELETED.
Header
pdf
Version
Page
#;
Paragraph
#
Comments
Page
13.
Section
II.
C
("
Assessment
Endpoints"
of
Table
3).
The
attributes
listed
in
the
left
column
aren't
clearly
defined
assessment
endpoints.
For
example,
item
1
is
"
abundance
(
i.
e.,
survival,
reproduction,
and
growth)
of
individuals
and
populations
of
birds."
First,
is
there
a
difference
between
abundance
of
individuals
and
abundance
of
populations?
Second,
survival,
reproduction,
and
growth
are
not
equivalent
to
population
abundance
(
the
"
i.
e."
is
inappropriate);
rather
they
are
factors
that
may
influence
population
abundance,
and
in
this
case
are
also
used
as
measures
of
effect.
Why
is
"
abundance"
shown
as
the
assessment
endpoint
for
birds,
mammals,
and
earthworms,
but
only
"
survival
and
reproduction"
for
fish
and
invertebrates
and
"
survival
of
 
populations"
for
beneficial
insects?
This
is
an
attempt
to
fulfill
the
Guidelines
by
categorizing
the
potential
effects
of
concern,
but
it
is
vague
and
inconsistent
about
actual
endpoints
and
doesn't
say
anything
specific
about
protection
goals.
?
RESPONSE:
AGREED
AND
CHANGED.
6
Header
pdf
Version
Page
#;
Paragraph
#
Comments
E.
Analysis
Plan
Page
18
2
nd
sentence,
reference
USEPA
1998
missing
in
Ref
list
and
the
name
of
the
document
(
Guidance
for
Ecological
Risk
Assessment)
is
missing
from
the
text.
RESPONSE:
CORRECTED.
c.
Measures
of
ecosystem 
Page
21
Last
sentence
 
delete
the
word
"
small"
birds.
Since
3
sizes
of
birds
are
being
represented,
not
just
the
small
ones.
RESPONSE:
CORRECTED.
Analysis
(
Section
III)
Page
22
As
EFED
are
aware,
the
Pyrethroid
Working
Group
is
progressing
a
program
of
work
agreed
with
EFED
including
the
development
of
refined
exposure
estimates
based
on
the
best
available
usage
data,
generation
of
additional
acute
and
chronic
ecotoxicity
data
for
sediment
dwellers
and
the
compilation
of
a
comprehensive
ecotoxicity
data
review
for
the
synthetic
pyrethroids.
These
new
data
and
assessments,
which
will
be
available
over
the
coming
months,
will
be
relevant
to
the
environmental
risk
assessment
for
cypermethrin.
RESPONSE:
AGREED.
AT
THE
TIME
THAT
THE
DOCUMENT
WAS
BEING
PRODUCED
THIS
DATA
WAS
NOT
AVAILABLE.
HOWEVER,
THE
ACUTE
SEDIMENT
STUDIES
HAVE
BEEN
COMPLETED
AND
ARE
BEING
REVIEWED
BY
EPA
.
Head
Lettuce
(
interval
not
specified
rather
than
7
days).
RESPONSE:
AGREE.
Table
4
Page
22
The
Leafy
Brassica
listing
should
be
as
follows:
includes
broccoli
Raab,
collards,
kale,
mustard
greens,
mustard
spinach,
and
rape
greens.
RESPONSE:
IN
ADDITION,
CHINESE
CABAGGE.
Figures
L­
2
 
L­
5
Pages
25­
30
Figures
are
not
legible.
RESPONSE:
THE
FIGURES
ARE
CLEAR
IN
THE
ORIGINAL
COPIES
ISSUED
BY
THE
EFED.
IT
IS
POSSIBLE
THAT
THE
TRANSFERENCE
FROM
WORD
PERFECT
TO
PDF
FORMAT
COULD
HAVE
CAUSED
THE
PROBLEM.
THE
EFED
DEFERS
THE
ISSUE
TO
THE
SRRD,
TO
PROVIDE
HARD
COPIES
TO
THE
REGISTRANT.
Page
27
Page
is
blank.
RESPONSE:
THIS
COULD
BE
CAUSED
BY
THE
USE
OF
A
DIFFERENT
PRINTER
THAN
THE
ONE
FROM
WHICH
THE
DOCUMENT
IS
PRODUCED.
THE
EFED
WILL
TAKE
PRECAUTIONS
TO
AVOID
THE
PROBLEM
IN
THIS
PHASE.
Page
29
Page
is
blank.
RESPONSE:
SAME
AS
ABOVE.
7
Header
pdf
Version
Page
#;
Paragraph
#
Comments
Page
31.
We
question
why
the
Agency
has
taken
some
of
the
representative
properties
values
for
cypermethrin
from
the
review
by
(
Laskowski,
MRID
45169501)
but
ignored
others,
e.
g.
kinetic
parameters,
Koc
and
BCF.
If
EFED
plans
to
include
any
modeling,
it
is
important
that
they
cover
available
published
peer
reviewed
papers
 
including
data
from
the
Laskowski
publication.
RESPONSE:
THIS
IS
A
SUBSTANTIVE
ISSUE,
NOT
AN
"
ERROR
ONLY,"
IT
WILL
BE
ADDRESSED
IN
THE
NEXT
PHASE.

Also,
although
the
risk
assessment
includes
estuarine
and
marine
ecosystems,
there
is
no
attempt
to
derive
an
EEC
for
estuarine
and
marine
habitats.
Use
of
the
high­
exposure
farmpond
scenario
as
a
surrogate
for
estuarine
and
marine
environments
is
extremely
conservative.
RESPONSE:
THIS
IS
CORRECT.
HOWEVER,
THIS
IS
A
SUBSTANTIVE
CORRECTION
AND
WILL
BE
ADDRESSED
LATER.

Page
32.
Soil
adsorption:
Table
5
shows
results
of
just
one
batch
equilibrium
adsorption
study
with
cypermethrin
(
MRID
42129003,
Froelich,
1991).
For
the
PRZM/
EXAMS
runs,
EFED
used
the
value
of
141,700
for
Koc,
which
is
claimed
to
be
the
average
Koc
from
the
four
values
reported
by
Froleich,
1991.
Laskowski
(
2002)
finds
that
a
more
recent
sorption
study
(
Goggin
et
al.,
1996)
is
more
reliable
than
that
of
Froelich
1991.
This
is
because
the
presence
of
cosolvent
in
the
Froelich
study
could
have
resulted
in
an
underestimation
of
cypermethrin
sorption
in
this
case.
RESPONSE:
THIS
IS
A
SUBSTANTIVE
ISSUE,
IT
WILL
BE
ADDRESSED
IN
A
SUBSEQUENT
REVISION
PHASE.
Exposure
Characterization
(
Section
III
B)

Page
32.
Section
1.
a.
Environmental
Fate
and
Transport
Characterization.
First
sentence
" 
zeta­
cypermethrin,
one
of
the
isomers
of
cypermethrin."
This
is
incorrect.
Zetacypermethrin
is
made
up
of
the
same
eight
isomers
that
define
cypermethrin,
except
they
are
in
different
ratios
for
the
two
products.
RESPONSE:
THE
PARAGRAPH
WAS
SIMPLIFIED,
TO
AVOID
CONFUSION.
Header
pdf
Version
Page
#;
Paragraph
#
Comments
8
Page
32.
Section
1.
a.
Environmental
Fate
and
Transport
Characterization/
Summary
of
Empirical
Data.
It
is
stated
here
that
"
If
released
to
water,
cypermethrin
will
rapidly
partition
to
the
sediment
compartment
which
acts
as
an
environmental
sink
for
this
compound."
In
natural
water
bodies,
cypermethrin
will
rapidly
partition
into
organic
matter
containing
substrates,
which
in
addition
to
bed
sediment,
include
phytoplankton,
other
suspended
particles
and
aquatic
plants
in
the
water
column.
The
relative
extent
to
which
cypermethrin
reaching
surface
water
will
partition
to
sediment
will
depend
on
the
relative
densities
of
these
other
substrates
in
the
water
body.
RESPONSE:
THIS
IS
NOT
AN
ERROR
ONLY;
HOWEVER,
A
BRIEF
SENTENCE
WAS
ADDED
TO
ADDRESS
THE
MATTER.
9
Exposure
Characterization
(
Section
III
B)
Page
34.
Section
1.
e.
Field
Studies.
No
mentioned
is
made
here
of
the
aquatic
field
studies
with
cypermethrin,
although
two
of
these
studies
are
referred
to
in
Section
C.
Ecological
Effects
Characterization.
For
example,
the
following
field
aquatic
studies
area
available:

Crossland
(
1982).
Aquatic
toxicology
of
cypermethrin.
II.
Fate
and
biological
effects
in
pond
experiments.
Aquatic
Toxicol.
2:
205­
222.

Crossland
et
al.
(
1982).
Aquatic
toxicology
of
cypermethrin.
III.
Fate
and
biological
effects
of
spray
drift
deposits
in
fresh
water
adjacent
to
agricultural
land.
Aquatic
Toxicol.
2:
253­
270.

Farmer
et
al.
(
1995).
A
comparison
of
the
fate
and
effects
of
two
pyrethroid
insecticides
(
lambda­
cyhalothrin
and
cypermethrin)
in
pond
mesocosms.
Ecotoxicology,
4:
219­
244.

Shires
&
Bennett
D
(
1985).
Contamination
and
effects
in
freshwater
ditches
resulting
from
aerial
application
of
cypermethrin.
Ecotoxicol
Environ
Safety,
9:
145­
158.

Getty
et
al.
(
1983).
Cypermethrin:
effects
of
multiple
low
application
rate
applications
on
experimental
ponds.
ICI
Plant
Protection
Division,
Bracknell,
Berks,
UK.
Report
No.
RJ0182B.
MRID
152737.

Jaber
and
Hawk
(
1983).
Cypermethrin:
aquatic
ecological
effects
under
field
use
conditions
in
cotton,
Selma,
Alabama,
1980.
ICI
Americas,
Inc.,
Goldsboro,
NC.
Report
No.
TMUE0026/
B.
MRID
128704.

Palmieri
et
al.
(
1992).
An
evaluation
of
the
impact
of
cypermethrin
exposure
on
managed
aquatic
ecosystems.
FMC
Corporation
Study
No.
A89­
2847.
MRID
42148201.

Rea
et
al.
(
1988).
Cypermethrin:
evaluation
of
the
impact
of
aerially
sprayed
cypermethrin
on
the
aquatic
ecosystem
of
a
farm
pond
in
the
drainage
basin
of
a
cotton
crop;
1987.
ICI
Agrochemicals,
Bracknell,
Berks,
UK
Report
No.
RJ0629B.
MRID
40804501.

RESPONSE:
THIS
IS
A
SUBSTANTIVE
ISSUE,
NOT
AN
ERROR
CORRECTION.
IF
THESE
FIELD
STUDIES
HAVE
ENVIRONMENTAL
FATE
INFORMATION,
THEY
MAY
BE
ADDED
IN
THIS
SECTION
IN
A
SUBSEQUENT
PHASE.
10
Header
pdf
Version
Page
#;
Paragraph
#
Comments
Page
46
Last
paragraph,
last
sentence
should
read
"
These
scenarios
are
summarized
in
Supplementary
Table
A."
RESPONSE:
AGREE,
CORRECTED.
Spray
drift/
Buffer
zone
Analysis
Page
49
The
paragraph
above
Table
D
references
CA
fruits
(
stone
fruits),
which
are
not
included
in
this
assessment.
In
addition,
cypermethrin
is
not
registered
on
stone
fruits.
RESPONSE:
AGREE,
CORRECTED.
Supplementary
Tables
D
and
E
Page
49
It
is
unclear
why
higher
tiers
of
refinement
result
in
increasing
rather
than
decreasing
estimated
peak
concentrations.
The
0%
drift
peak
value
(
2.155)
is
greater
than
the
peak
value
used
in
the
5%
drift
PRZM/
EXAMS
runs
(
2.01).
To
be
consistent
(
and
follow
EFED
policy),
the
1
in
10
year
exceedence
value
should
be
used
in
Tables
D
and
E,
especially
since
RQ
values
are
calculated
and
apparently
used
in
the
assessment.
RESPONSE:
THE
PEAK
VALUE
FOR
5%
DRIFT
IS
2.385
ppb.
EFED
REVISED
ALL
THE
PEAK
VALUES
AND
FOUND
THAT
ALL
OF
THEM
WERE
CORRECTLY
REPORTED.
The
high­
end
conservative
drift
scenario
includes
a
release
height
of
15
ft.
The
Ammo
label
states
those
applications
more
than
10
ft
above
the
crop
canopy
should
be
avoided.
RESPONSE:
IT
SHOULD
BE
AVOIDED,
BUT
IT
IS
POSSIBLE
THAT
THE
APPLICATOR
WOULD
EXCEED
THIS
LIMIT.
Page
49
The
very
conservative
drift
scenario
is
unrealistic.
The
use
of
fine
droplets
with
a
wind
speed
of
15
mph
is
unlikely.
RESPONSE:
THIS
SCENARIO
IS
ALSO
POSSIBLE.
Page
51;
1,
last
sentence
Please
change
"
but
it
is
more
meaningful
for
the
high
end
drift
scenario"
to
"
but
had
a
greater
impact
for
the
high
end
drift
scenario".
RESPONSE:
THIS
IS
NOT
AN
ERROR
CORRECTION;
HOWEVER,
THE
SENTENCE
WAS
REWORDED
FOR
CLARITY,
BUT
NOT
ACCORDING
TO
THE
REGISTRANT'S
RECOMMENDATION.
Supplementary
Table
E
51,
2,
first
sentence
Please
change
"
has
certain
uncertainties"
to
"
specific
uncertainties".
RESPONSE:
AGREE.
Aq
Exposure
Monitoring
and
Field
Data
Page
52;
1,
Sentence
2
Please
insert
"
with
log
Pow
of
5.0"
after
"
cypermethrin
is
very
hydrophobic".
RESPONSE:
DISAGREE.
THIS
PHRASE
DOES
NOT
ADD
TO
THE
MESSAGE
OF
THE
PARAGRAPH.
IN
ADDITION
THE
VALUE
FOR
log
Pow
APPEARS
TO
BE
INCORRECT.
11
Header
pdf
Version
Page
#;
Paragraph
#
Comments
12
Ecological
Effects
Characterization
(
Section
III
C)
Page
54
a.
For
the
acute
and
chronic
toxicity
reference
values
for
fish
and
invertebrates,
EFED
has
selected
the
lowest
single
endpoints.
In
this
way,
EFED
are
not
taking
advantage
of
the
wealth
of
information
contained
within
the
numerous
acceptable
studies
available
with
cypermethrin
and
fish
and
invertebrate
species.
Using
geometric
means
from
all
of
the
acceptable
study
endpoints
would
provide
more
robust
endpoints
for
risk
assessment.
RESPONSE:
THIS
IS
A
SUBSTANTIVE
COMMENT
AND
WILL
BE
ADDRESSED
LATER.

b.
The
acute
fish
and
acute
freshwater
invertebrate
endpoints
selected
by
EFED
are
values
for
beta­
cypermethrin.
Beta­
cypermethrin
has
an
enhanced
isomer
composition,
with
an
increased
in
the
content
of
active
isomers
relative
to
cypermethrin.
EFED
have
not
explained
or
demonstrated
why
the
ecotoxicity
of
beta
cypermethrin
is
considered
to
be
equivalent
to
that
of
cypermethrin.
RESPONSE:
BETA
CYPERMETHRIN
INFORMATION
WAS
USED
AS
BRIDGING
DATA.
TOXICITY
IS
IN
THE
SAME
RANGE
AS
CYPERMETHRIN
c.
For
the
same
reasons
given
in
point
5.
b.
above,
some
rationale
is
needed
to
justify
EFED's
comparison
of
the
acute
fish
and
invertebrate
endpoints
from
tests
with
betacypermethrin
with
endpoints
from
tests
with
formulated
cypermethrin.

RESPONSE:
BETA
CYPERMETHRIN
INFORMATION
WAS
USED
AS
BRIDGING
DATA.
TOXICITY
IS
IN
THE
SAME
RANGE
AS
CYPERMETHRIN
d.
EFED
have
estimated
a
NOAEC
for
Daphnia
magna
to
be
compared
with
a
21
day
EEC,
based
on
the
acute
to
chronic
ratio
for
the
mysid
shrimp
(
96h
LC50/
28
d
NOAEC).
The
21
day
NOEC
for
Daphnia
magna,
available
from
the
study
by
Edwards
et
al.(
1981)
is
considered
to
be
more
reliable
than
the
estimate
obtained
by
EFED.
RESPONSE:
THIS
STUDY
WAS
NOT
AVAILABLE
TO
EPA
AND
WILL
BE
ADDRESSED
AT
A
LATER
TIME.

e.
EFED
have
calculated
a
10
d
LC50
in
pore
water
for
benthic
organisms
based
on
the
lowest
available
sediment
value
(
Hyalella
azteca
in
1%
o
C
sediment).
EFED
have
used
a
Koc
value
of
141,700
for
this
calculation.
As
discussed
in
points
1
and
4
b,
this
Koc
value
is
likely
to
be
an
underestimate.
JOSE
f.
EFED
have
estimated
a
chronic
endpoint
for
benthic
organisms
based
on
the
acute
to
chronic
ratio
for
the
mysid
shrimp
(
96h
LC50/
28
d
NOAEC).
As
EFED
are
aware,
the
Pyrethroid
Working
group
is
progressing
a
(
comments
continued
from
previous
page)
program
of
work
agreed
with
EFED
including
generation
of
additional
acute
and
chronic
ecotoxicity
data
for
sediment
dwellers.
These
new
data,
which
will
be
available
over
the
coming
months,
will
be
relevant
to
the
environmental
risk
assessment
for
13
Header
pdf
Version
Page
#;
Paragraph
#
Comments
Cypermethrin
Toxicity
Reference
Values
Page
57,
Table
12
Acute
rainbow
trout
96­
hr
study
(
MRID
44546027)
is
a
beta­
Cypermethrin
study
beta­
Cypermethrin
studies
should
not
be
used
in
estimating
the
risk
to
cypermethrin.
RESPONSE:
BETA
CYPERMETHRIN
INFORMATION
WAS
USED
AS
BRIDGING
DATA.
TOXICITY
IS
IN
THE
SAME
RANGE
AS
CYPERMETHRIN
Page
57
Daphnia
acute
study
MRID
44546031
is
stated
to
be
a
beta­
cypermethrin
study
in
Appendix
E
(
p­
E16).
beta­
Cypermethrin
studies
should
not
be
used
in
estimating
the
risk
to
cypermethrin.
RESPONSE:
BETA
CYPERMETHRIN
INFORMATION
WAS
USED
AS
BRIDGING
DATA.
TOXICITY
IS
IN
THE
SAME
RANGE
AS
CYPERMETHRIN
Table
12
Page
58,
estuarine/
marine
invertebrates;
Acute,
mysid
shrimp
Accession.
No.
070562
is
an
oyster
study
according
to
Table
E­
6
on
page
E­
37.
The
Reference
should
be
MRID
42444601
RESPONSE:
CORRECTED
Page
60,
1
st
sentence
Remove
0.39
ug/
L
for
trout,
that
study
(
MRID
44546027)
is
a
beta­
cypermethrin
study.
beta­
Cypermethrin
studies
should
not
be
used
in
estimating
cypermethrin
risk.
RESPONSE:
THIS
ISSUE
HAS
BEEN
ADDRESSED
EARLIER.
Page
60,
paragraph
2,
2
nd
sentence
Need
to
mention
GFU
061
(
36
%),
which
is
mentioned
in
the
next
sentence.
RESPONSE:
THIS
HAS
BEEN
CORRECTED.
Page
60,
2
nd
paragraph,
6
th
line
It
is
unclear
where
the
3.3
value
is
derived
from
in
Table
E­
1b.
RESPONSE:
CORRECTED
Page
60,
4
th
paragraph
Remove
0.42
ug/
L
for
daphnia
that
study
(
MRID
4456031)
is
a
beta­
cypermethrin
study.
beta­
Cypermethrin
studies
should
not
be
used
in
estimating
cypermethrin
risk.
RESPONSE:
BETA
CYPERMETHRIN
INFORMATION
WAS
USED
AS
BRIDGING
DATA.
TOXICITY
IS
IN
THE
SAME
RANGE
AS
CYPERMETHRIN
a.
(
1)
Acute
Effects
Page
61,
paragraph
under
Estuarine/
Marine
Fish
,
1
st
sentence
Table
E­
5
page
E­
33
list
the
Atlantic
salmon
LC50
value
as
2.0
and
the
reference
should
be
41068003
not
41968212.
RESPONSE:
CORRECTED
Page
66;
1
MRID
44546031
is
a
beta­
Cypermethrin
study.
beta­
Cypermethrin
studies
should
not
be
used
in
estimating
cypermethrin
risk.
RESPONSE:
BETA
CYPERMETHRIN
INFORMATION
WAS
USED
AS
BRIDGING
DATA.
TOXICITY
IS
IN
THE
SAME
RANGE
AS
CYPERMETHRIN
(
3)
Sublethal
Effects
66,
1
st
full
paragraph
LC50
in
rainbow
trout
should
be
mentioned
(
13
ug/
L).
Sublethal
effects
for
the
formulated
material
are
not
similar
to
the
technical
material.
There
are
not
orders
of
magnitude
differences
between
the
NOAEC
and
the
LC50
value
for
the
formulated
material.
RESPONSE:
CORRECTED.
There
was
a
units
mistake
in
table
E­
1a
14
66,
4
th
line
under
Estuarine/
Marine
Fish
­
MRID
number
44546034
is
a
beta­
cypermethrin
study.
beta­
Cypermethrin
studies
should
not
be
used
in
estimating
cypermethrin
risk.
RESPONSE:
BETA
CYPERMETHRIN
INFORMATION
WAS
USED
AS
BRIDGING
DATA.
TOXICITY
IS
IN
THE
SAME
RANGE
AS
CYPERMETHRIN
66,
first
line
under
Benthic
Organisms
Table
E­
5
should
be
E­
4.
15
Header
pdf
Version
Page
#;
Paragraph
#
Comments
Section
III
C
(
4)
field
studies
Page
67.
The
open
literature
paper
Kedwards
et
al.(
1999a)
provides
further
statistical
analyses
of
the
study
reported
by
Rea
et
al.
(
1988)
and
the
paper
Kedwards
et
al.(
1999b)
provides
further
statistical
analyses
of
the
study
reported
by
Farmer
et
al.
(
1995).
EFED
have
included
a
summary
of
the
study
by
Farmer
et
al.
(
1995)
in
Table
E­
8,
however
EFED
have
not
summarized
the
study
by
Rea
et
al.(
1988)
ICI
report
number
RJ0629B,
MRID
40804501.
RESPONSE:
THIS
IS
A
SUBSTANTIVE
COMMENT
AND
WILL
BE
ADDRESSED
LATER.
Chronic
rat
study
 
The
acceptable
MRID#
00112912
should
be
used
for
endpoint
comparisons
in
place
of
the
unacceptable
/
supplemental
study
currently
being
used
in
this
assessment
(
MRID
00090040).
Change
throughout
the
text
and
use
the
correct
endpoint
for
calculating
the
RQs
RESPONSE:
EFED
POLICY
IS
TO
USE
THE
MOST
SENATIVE
ORGANISMS.
SUPLLEMENTAL
DATA
IS
ACCEPTABLE
FOR
RISK
ASSESSMENT
DEVELOPMENT.
MRID
44546024
a
beta
study.
beta­
Cypermethrin
studies
should
not
be
used
in
estimating
cypermethrin
risk.
RESPONSE:
THIS
HAS
BEEN
ADDRESSED
PREVIOUSLY.
Table
13
Page
69
Acute
dietary
avian
the
actual
reported
LC50
was
>
20,000
ppm
rather
than
the
reported
repellent
effect
concentration
of
>
2,634
ppm
in
the
text.
Change
throughout
the
text
and
use
the
correct
endpoint
(>
20,
000)
for
calculating
the
RQs.
RESPONSE:
CORRECTED
Terrestrial
Invertebrates
Page
70
MRID
44544208
is
a
beta­
cypermethrin
study
for
honeybees
(
last
sentence
in
this
section).
beta­
Cypermethrin
studies
should
not
be
used
in
estimating
cypermethrin
risk.
RESPONSE:
BETA
CYPERMETHRIN
INFORMATION
WAS
USED
AS
BRIDGING
DATA.
TOXICITY
IS
IN
THE
SAME
RANGE
AS
CYPERMETHRIN
Page
72.
Page
is
blank.

REFER
TO
RESPONSE
TO
THIS
ISSUE
ABOVE.
16
Risk
Characterization
(
Section
IV)
Page
73
As
EFED
are
aware,
the
Pyrethroid
Working
group
is
progressing
a
program
of
work
agreed
with
EFED
including
the
development
of
refined
exposure
estimates
based
on
the
best
available
usage
data,
generation
of
additional
acute
and
chronic
ecotoxicity
data
for
sediment
dwellers
and
the
compilation
of
a
comprehensive
ecotoxicity
data
review
for
the
synthetic
pyrethroids.
These
new
data
and
assessments,
which
will
be
available
over
the
coming
months,
will
be
relevant
to
the
environmental
risk
assessment
for
cypermethrin.

RESPONSE:
THE
AGENCY
IS
AWARE
OF
PWG'S
EFFORTS,
ESPECIALLY,
THEIR
SEDIMENT
TOXICITY
STUDIES.

Header
pdf
Version
Page
#;
Paragraph
#
Comments
1.
Non­
target
aquatic 
Page
74
The
21­
day
EEC
is
being
used
solely
to
calculate
RQs
and
it
is
recommended
that
other
values
as
listed
below
be
included
in
RQ
calculations
(
i.
e.
daphnia
21
days,
fish
+
28
days).
RESPONSE:
EFED
HAS
CHANGED
THE
CHRONIC
RQ
VALUES
TO
REFLECT
THE
EEC
FOR
60
DAYS
IN
ORDER
TO
CALCULATE
CHRONIC
RQS
FOR
FISH.
Table
15
Page
76
The
freshwater
invertebrate
chronic
RQ
for
TX
cotton
should
be
0.9
and
not
1.1.
This
means
that
the
RQ
does
not
exceed
the
LOC
for
chronic
risk.
RESPONSE:
CORRECTED
Supplementary
Table
H
Page
77
The
values
used
here
should
be
the
1
in
10
year
exceedence
EECs,
just
like
those
used
for
the
RQ
calculations
previously.
RESPONSE:
THIS
ISSUE
WAS
PREVIOUSLY
ADDRESSED.
THE
CORRECT
VALUES
WERE
REPORTED.
Page
77
Should
include
a
freshwater
species
also
to
compare
buffer
zones.
RESPONSE:
THIS
IS
A
SUBSTANTIVE
ISSUE,
NOT
AN
ERROR,
IT
WILL
BE
CONSIDERED
IN
A
SUBSEQUENT
PHASE.
The
1
in
10
year
exceedence
values
should
be
used
for
RQ
comparisons.
RESPONSE
ALREADY
PROVIDED.
The
RQs
calculated
here
(
based
upon
peak
concentrations)
should
not
be
compared
to
the
LOCs
if
they
are
used
to
study
the
impact
of
spray
drift
on
concentrations.
RESPONSE:
THIS
IS
NOT
AN
ERROR
CORRECTION,
THIS
ISSUE
WILL
BE
ADDRESSED
IN
A
SUBSEQUENT
PHASE.
c.
Use
of
buffer
zones
Page
78
The
text
should
note
that
a
150­
foot
buffer
zone
is
required
by
the
label,
and
that
the
values
presented
only
take
into
account
reduction
of
spray
drift,
and
not
runoff
and
sediment
transport,
which
are
significant.
RESPONSE:
THIS
IS
NOT
AN
ERROR;
HOWEVER,
THE
EFED
ADDED
A
FOOTNOTE
IN
SUPPLEMENTARY
TABLE
I.
17
Table
17
Page
81
The
footnotes
reference
T­
REX
output
in
Appendix
D,
but
the
output
was
not
included
in
the
appendix.
(
Microsoft
Excel
spreadsheets
not
included
(
Page
D­
1)
RESPONSE:
CORRECTED
c.
Risk
to
Terrestrial
Invertebrates
Page
85
Remove
reference
to
beta
cypermethrin
10EC.
beta­
Cypermethrin
studies
should
not
be
used
in
estimating
cypermethrin
risk.
RESPONSE:
BETA
CYPERMETHRIN
INFORMATION
WAS
USED
AS
BRIDGING
DATA.
TOXICITY
IS
IN
THE
SAME
Header
pdf
Version
Page
#;
Paragraph
#
Comments
18
Risk
Description
(
Section
IV
B)
Page
85
a.
EFED
refers
to
available
field
studies
and
claims
that
these
show
that
adverse
effects
on
sediment
dwelling
populations
can
occur.
Giddings
(
1997)
carried
out
a
thorough
review
of
the
available
field
data
on
pyrethroids
(
Springborn
Report
number
97­
6­
7014)
and
this
report
we
also
published
(
Giddings
et
al.,
2001.
Probabilistic
risk
assessment
of
cotton
pyrethroids:
ii.
Aquatic
mesocosm
and
field
studies.
Environmental
Toxicology
and
Chemistry,
Vol.
20,
No.
3,
pp.
660 
668).
The
findings
of
this
review
were
that
the
abundance
of
macroinvertebrates
in
sediments
was
highly
variable
in
space
and
time
and
could
not
be
characterized
precisely
for
most
species.
Additionally,
concentrations
of
pyrethroids
in
sediments
showed
high
special
variability,
even
following
uniform
dosing
of
experimental
ponds.
The
review
revealed
that
areas
of
low
or
negligible
pyrethroid
concentration
in
the
sediment
can
serve
as
refuges
for
sediment
dwellers
and
serve
as
sources
for
population
recolonization.
Overall,
effects
of
pyrethroids
observed
in
the
mesocosms
were
correlated
with
maximum
concentrations
in
the
water
column,
not
with
concentrations
in
the
sediment.
Although
some
of
the
groups
of
organisms
affected
by
pyrethroid
application
spend
time
in
the
sediment
surface,
their
most
relevant
route
of
exposure
would
be
via
the
water
column.

b.
EFED
express
concerns
about
the
potential
for
bioaccumulation
in
aquatic
organisms
and
trophic
transfer.
The
PWG
carried
out
a
program
of
work
to
investigate
the
partitioning,
bioavailability
and
toxicity
of
cypermethrin
on
aquatic
systems
(
PWG
Report
number
RC0007;
MRID
44074407).
This
work
was
also
published
(
Maund
et
al.,
2002.
Partitioning,
bioavailability
and
toxicity
of
the
pyrethroid
insecticide
cypermethrin
in
sediments.
Environmental
Toxicology
and
Chemistry,
Vol.
21
(
1),
pp.
9­
15).
These
studies
showed
that
in
watersediment
systems
the
vast
majority
of
the
cypermethrin
(>
99%)
is
sorbed
to
the
sediment.
However,
the
concentration
of
cypermethrin
in
the
sediment
is
not
a
good
predictor
of
the
amount
that
is
bioavailable.
The
best
predictor
of
the
bioavailable
fraction
was
the
concentration
in
the
pore
water,
supporting
the
equilibrium
partitioning
theory.
Bioconcentration
factors
for
Daphnia
and
Chironomus,
based
on
the
extractable
concentration
of
cypermethrin
in
sediment
were
similar
and
very
low
(<
1),
indicating
that
the
proportion
of
the
cypermethrin
adsorbed
to
the
sediment
that
is
available
to
aquatic
organisms
is
very
low,
for
both
water
column
and
benthic
organisms.
Header
pdf
Version
Page
#;
Paragraph
#
Comments
19
Page
88,
paragraph
2
Hill
et
al
1973
and
Dianne
(
change
to
Dionne)
1998
are
incomplete
references
and
are
not
in
the
reference
section
on
page
113.
RESPONSE:
THIS
IS
NOT
AN
ERROR
CORRECTION.
THE
ISSUE
WILL
BE
CONSIDERED
IN
A
SUBSEQUENT
PHASE.
b.
Aquatic
Animals
(
Water )

Page
89,
1
st
partial
paragraph,
8
th
line
from
bottom
The
sentence
beginning
with
"
effects
include"
is
confusing
and
contains
incomplete
MRID
#
15.
RESPONSE:
CORRECTED
c.
Aquatic
Animals
(
Sediment )
Page
88,
1
st
sentence
in
last
paragraph
Refer
to
Table
E­
8
(
page
E­
46)
here.
RESPONSE:
CORRECTED
E.
Other
special 
Page
89,
last
sentence
that
extends
to
page
90
The
sentence
is
confusing.
Please
reword.
RESPONSE:
EVEN
THOUGH
THIS
IS
NOT
AN
ERROR
CORRECTION,
THE
REVIEWER
MODIFIED
THE
SENTENCE
FOR
CLARITY.
Page
90;
1
"
All
scenarios
showed
that
the
RQ
exceeded
by
far
all
the
LOCs."
It
is
suggested
that
sentence
be
omitted.
The
exercise
was
to
look
at
the
impact
of
drift
on
EECs.
The
EECs
from
the
drift
exercise
were
higher
than
those
with
the
standard
5%
drift.
RESPONSE:
THIS
IS
NOT
AN
ERROR
CORRECTION.
THE
ISSUE
WILL
BE
CONSIDERED
IN
A
SUBSEQUENT
PHASE.
e.
Other
Special
Considerations
for
Evaluating
Aquatic
Risk
(
Buffer
Zones)

Page
90;
3
This
entire
paragraph
should
be
amended
to
not
include
RQ
values
since
this
was
not
the
purpose
of
the
drift
evaluation.
SAME
RESPONSE
AS
ABOVE.
Summary
of
Risk
to
Aquatic
Systems
(
IV.
B.
1.
f)
Pages
90­
91.
The
final
section
of
the
aquatic
risk
assessment
is
entirely
speculative
and
out
of
place
as
the
summary
of
a
careful
quantitative
screening­
level
risk
assessment.
None
of
the
toxicological
or
ecological
phenomena
invoked
here
is
specific
to
cypermethrin
or
indeed
to
pesticides
in
general.
For
example,
EFED
states,
"
Possible
chronic
effects
to
aquatic
life
may
also
be
a
concern
where
an
initial
permethrin
exposure
may
be
affective
[
sic]
in
causing
reproductive
effects
21
days
to
60
days
later."
The
potential
for
latent
effects
is
a
source
of
uncertainty
in
most
chemical
risk
assessments.
Another
example:
"
Toxic
exposure
of
cypermethrin
in
the
sediment
can
present
a
more
far
reaching
impact
to
a
multitude
of
organisms
than
impact
from
the
water
column"
because
many
aquatic
species
interact
with
the
sediment
or
with
sediment­
dwelling
organisms.
Or:
"
Chronic
toxicant
loads
in
sediments
may
drive
populations
toward
a
limited
set
of
tolerant
genotypes
over
time."
Such
speculations
are
boundless;
one
can
use
basic
ecological
mechanisms
to
hypothesize
about
indirect
effects,
which
are
rarely,
if
ever,
observed
in
field
experiments.
None
of
the
factors
mentioned
in
this
paragraph
are
supported
or
suggested
by
the
findings
of
the
Science
Chapter
 
they
should
have
been
addressed
in
the
Problem
Formulation.
RESPONSE:
THIS
IS
NOT
AN
ERROR
CORRECTION.
THE
ISSUE
WILL
BE
CONSIDERED
IN
A
SUBSEQUENT
PHASE.
20
Header
pdf
Version
Page
#;
Paragraph
#
Comments
3.
Review
of
Incident
Data
Page
93,
1
st
full
sentence
EPA
lists
5
categories
here,
but
on
pages
J1
and
J2
the
Agency
lists
6
categories
in
the
certainty
index.
Category
3
(
probably)
 
may
need
to
be
eliminated.
RESPONSE:
CORRECTED
a.
Incidents
Involving
Aquatic
Organisms.
Page
93,
3
rd
sentence
Related
to
above
comment.
Table
J­
1
on
page
J2
does
not
reflect
what
is
stated
here.
Footnote
a
(
certainty
index)
has
a
3
as
probably.
This
throws
the
tally
in
this
sentence
off.
If
probably
is
removed
from
the
table,
the
number
of
various
incidents
reflects
what
is
stated
in
this
sentence
RESPONSE:
CORRECTED
b.
Incidents
Involving
Terrestrial
Organisms
Page
93,
3
rd
sentence
Similar
to
above
comment.
Table
J­
1
on
page
J­
1
has
the
`
probably'
in
the
footnote
that
makes
this
sentence
inaccurate.
Footnote
in
table
J­
1
needs
to
be
corrected.
RESPONSE:
CORRECTED
4.
Endocrine
effects
Page
93­
94
Current
EFED
work
is
ongoing
to
determine
potential
endocrine
effects
from
pesticides.
Conclusions
about
potential
effects
at
this
point
are
premature
for
cypermethrin.
RESPONSE:
THE
AGENCY
CONCLUDES
THAT
AT
THIS
SCREENING
LEVEL
CYPERMETHRIN
MAY
HAVE
THE
POTENTIAL
FOR
ENDOCRINE
EFFECTS
(
E.
G.,
REPRODUCTION
EFFECTS
IN
AQUATIC
ORGANISMS.
WHEN
APPROPRIATE
SCREENING
AND
TESTING
PROTOCOLS
ARE
DEVELOPED
CYPERMETHRIN
MAY
BE
SUBJECTED
TO
ADDITIONAL
SCREENING.
Endocrine
Effects
Page
93
a.
EFED
states
that
observed
reproductive
effects
in
aquatic
species
are
considered
evidence
of
detrimental
effects
on
the
endocrine
system.
The
science
behind
this
assumption
is
not
revealed.
RESPONSE:
THIS
HAS
BEEN
REVISED
TO
SHOW
THAT
CYPERMETHRIN
MAY
HAVE
EFFECTS
ON
THE
ENDROCRINE
SYSTEM.

b.
Reproductive
effects
were
observed
only
for
M.
bahia,
based
on
the
toxicity
data
presented
in
Appendix
E.
This
estuarine/
marine
invertebrate
was
the
most
sensitive
species
to
cypermethrin.
However,
for
M.
bahia
the
lowest
chronic
endpoint
was
reduced
growth
in
the
males.
RESPONSE:
REPRODUCTIVE
EFFECTS
(
GROWTH,
ETC)
ARE
CONSIDERED
AS
REFLECTIVE
OF
POSSIBLE
EFFECTS
TO
THE
ENDOCRINE
SYSTEM.
5.
Threatened
&
Endangered .,
b.
Taxonomic
Groups 
thru
to
d.
Critical
Habitat
Pages
94­
98
There
appears
to
be
several
sections
missing
including,
(
2)
Probit
Dose
Response
Relationship,
(
3)
Data
Related
to
Under­
represented
Taxa
and
(
4).
Implications
of
Sublethal
Effects.
Also
c.
Indirect
Effects
Analysis.
RESPONSE:
AGREE,
THESE
WERE
DELETED
21
FROM
THE
TABLE
OF
CONTENTS.
Threatened
and
Endangered
Species
Page
94
Syngenta
and
FMC
acknowledge
the
data
requirement
for
endangered
species
to
provide
information
on
the
proximity
of
federally
listed
endangered
species
to
pesticide
use
sites.
Syngenta,
FMC
and
other
registrants
responding
to
this
data
requirement
should
provide
this
endangered
species
information
using
the
FIFRA
Endangered
Species
Task
Force
(
FESTF)
Information
Management
System
(
IMS).
FESTF
has
developed
the
IMS
to
assist
its
member
companies
in
meeting
legal
obligations
to
submit
data
required
by
EPA­
OPP
under
FIFRA
(
as
described
in
Pesticide
Registration
Notice
2000­
2)
to
support
the
members'
registration
and
reregistration
actions.
The
purpose
of
the
IMS
is
to
meet
the
data
requirements
in
a
manner
that
significantly
improves
the
consistency,
quality,
availability
and
use
of
existing
information
on
threatened
and
endangered
species
and
pesticide
use.
On
March
01,
2005
FESTF
submitted
the
work
products
detailed
in
PR
Notice
2000­
2,
including
IMS
2.0
and
access
to
NatureServe
data
on
endangered
species
in
response
to
the
requirements
described
in
that
notice1.
Use
of
the
IMS
by
registrants
in
response
to
their
endangered
species
data
requirement
for
cypermethrin
will
provide
a
means
of
conserving
EPA­
OPP
resources
and
providing
documentation
and
consistency
throughout
to
produce
a
high
quality
effects
determination
for
cypermethrin.

EPA
has
provided
an
explanation
of
the
trigger
for
the
endangered
species
data
requirement,
i.
e.,
LOCs
for
endangered
species
that
are
exceeded
in
screening­
level
risk
assessments.
However,
EPA
does
not
clearly
articulate
the
data
requirement
for
endangered
species.
RESPONSE:
THERE
ARE
NO
SPECIFIC
ENDANGERED
SPECIES
DATA
REQUIREMENTS.
THE
AGENCY
USES
AVAILABLE
DATA
AND
EXTRAPOLATED
INFORMATION
TO
SCREEN­
OUT
THE
LIKELYHOOD
OF
NO
EFFECT.
EXCEEDANCE
OF
THE
ENDANGERED
LOC
TRIGGERS
SCREENING
LEVEL
CONCERNS
THAT
ARE
IDENTIFIED.

Participation
in
FESTF
through
membership
or
citation
to
FESTF
work
products
provides
a
registrant
with
access
to
excellent
tools
necessary
to
complete
a
high
quality
endangered
species
assessment
but
does
not
provide
specific
information
on
the
proximity
of
listed
species
to
cypermethrin
uses.
EPA
needs
to
provide
better
(
comments
continued
from
previous
page)
22
guidance
on
what
the
registrants
need
to
deliver.

EPA
needs
to
outline
its
plans
for
refinements
to
the
screening­
level
risk
assessment
for
cypermethrin.
Refinements
to
the
screening­
level
assessment
that
reduce
the
scope
of
the
effects
determination
for
endangered
species
should
be
a
high
priority
(
e.
g.,
terrestrial
vertebrates).

EPA
needs
to
clarify
exactly
what
taxonomic
groups
of
relevance
to
Federally
listed
species
trigger
a
species­
specific
refinement.
RESPONSE:
THIS
IS
NOT
AN
ERROR
CORRECTION.
THE
ISSUE
WILL
BE
CONSIDERED
IN
A
SUBSEQUENT
PHASE.
Footnote:
1
1)
The
development
and
submission
by
FESTF
of
an
Information
Management
System
(
IMS)
that
EPA
can
use
to
screen
pesticide
applications
when
their
applications
trigger
potential
endangered
species
issues;
2)
funding
by
the
FESTF
through
a
Cooperative
Research
and
Development
Agreement
(
CRADA)
of
a
state
by
state
species
access
program
to
be
undertaken
by
EPA
that
will
enable
EPA
to
access
high
quality
species
locality
data
to
validate
the
IMS
(
replaced
by
FESTF's
direct
contract
with
NatureServe
for
EPA's
access
to
these
data);
and
3)
a
quality
test
of
the
IMS,
based
in
part
upon
information
collected
by
EPA
pursuant
to
the
CRADA
(
NatureServe
data).
Header
pdf
Version
Page
#;
Paragraph
#
Comments
b.
(
1)
Discussion
of
RQ
Page
95
Last
sentence
is
misleading.
Should
read
instead
as
" 
level
I
screening
assessment
show
that
listed
species
for
several
taxa
are
located
in
regions
where
cypermethrin
may
be
used
based
on
crop
location."
Misleading
to
state
that
the
RQs
are
above
the
LOC,
because
this
appears
to
exaggerate
the
RQs
from
terrestrial
species
(
only
a
potential
"
short
grass"
risk).
RESPONSE:
AGENCY
DISAGREES.
THE
STATEMENT
IS
GENERAL
AND
STATES
THAT
THE
EXCEEDANCE
OF
THE
LISTED
LOC
SUGGESTS
THAT
SEVERAL
LISTED
TAXA
MAY
BE
AT
RISK.
Probit
Slope
Analysis
Page
97
It
was
unclear
how
the
results
of
the
probit
analysis
were
calculated.
Provide
an
example
so
that
the
calculations
can
be
verified.
Urban
and
Cook
1986
is
not
in
the
reference
section.
RESPONSE:
CORRECTED
Based
on
the
information
provided,
it
is
not
possible
to
determine
how
the
slopes,
mortality
probabilities,
or
their
respective
bound
estimates
were
calculated.
The
Agency
should
provide
the
data
used
for
this
analysis
to
improve
the
transparency
of
the
document.
23
d.
Critical
Habitats
Page
98,
2
nd
paragraph,
1
st
sentence
It
appears
that
invertebrate
and
vertebrate
are
inverted
in
the
sentence.
RESPONSE:
APPENDIX
GIVES
AN
EXAMPLE
CALCULATION
FOR
FRESHWATER
FISH.

The
EPA
should
refine
the
risk
assessment
for
those
groups
where
potential
concerns
have
been
identified
prior
to
conducting
any
indirect
effects
analysis
on
critical
habitat.
RESPONSE:
THIS
RED
IS
A
SCREENING
LEVEL
ASSESSMENT.
2.
Assumptions.
for
Aquatic
Species
Page
99,
2
of
this
section
"
There
are
no
monitoring
studies
for
cypermethrin
in
freshwater
or
marine, "
Should
this
end
with
"
the
marine
environment".
RESPONSE:
CORRECTED
24
Header
pdf
Version
Page
#;
Paragraph
#
Comments
Section
C.
Description
of
Assumptions,
Uncertainties,
Strengths
and
Limitations
Page
99
Presumably
this
section
is
a
place­
holder
 
many
obvious
and
significant
assumptions
and
uncertainties
are
not
yet
described.
This
section
needs
to
be
put
into
the
context
of
the
entire
risk
characterization.
For
example
some
routes
of
exposure
are
significantly
more
probable
and
therefore
important
to
the
risk
characterization
than
others
e.
g.,
water
column
for
aquatics
and
dietary
for
terrestrial
animals.
This
should
be
addressed
in
the
Problem
Formulation
stage.
Rather
than
a
discussion
on
endless
sources
of
uncertainty
many
of
which
may
not
be
significantly
important
in
the
risk
characterization,
EFED
should
constructively
address
its
plans
to
refine
the
screening­
level
risk
assessment
presented.
Refinements
to
the
screening­
level
assessment
that
reduce
the
scope
of
the
effects
determination
for
endangered
species
should
be
a
high
priority
e.
g.,
terrestrial
vertebrates.
RESPONSE:
THIS
IS
NOT
AN
ERROR
CORRECTION.
THE
ISSUE
WILL
BE
CONSIDERED
IN
A
SUBSEQUENT
PHASE.
Header
pdf
Version
Page
#;
Paragraph
#
Comments
Environmental
Fate
MRID
Studies 
Page
106
Froelich
study
should
be
MRID
42129003
and
Curry
study
should
be
MRID
42129002.
MRID
42868203
should
be
Giroir
and
Stuerman,
not
Sherman.
RESPONSE:
AGREE.
V.
Literature
Cited.
Ecological
Effects
MRID
Studies
Submitted
to
EPA.
Page
108.
Clarification
on
cited
MRID
62793:
MRID
62793.
Edwards,
P.
J.,
Brown,
S.
M.,
and
A.
S.
Sapiets.
(
February
1980).
Cypermethrin
(
PP383):
Toxicity
of
technical
and
formulated
material
to
first
instar
Daphnia
magna.
ICI
Plant
Protection
Division.
RJ011OB.

MRID
92027014
Hamer,
M.
(
1990)
ICI
Americas
Inc.
Phase
3
Summary
of
MRID
00062793.
Cypermethrin
(
PP383):
Toxicity
of
Technical
and
Formulated
Material
to
First
Instar
Daphnia
magna:
Report
No.:
RJ011OB;
Study
No.:
PP383/
CN/
01.
Prepared
by
ICI
Agrochemicals,
Jealott's
Hill
Research
Station
17
p.
RESPONSE:
CORRECTED
V.
Literature
Cited.
Ecological
Effects
MRID
Studies
Submitted
to
EPA.
Page
109.
Correct
date
for
MRID
90040:
delete
"
1972?"
and
replace
with
"
February
1979".
RESPONSE:
CORRECTED
Appendix
A
161­
2
Aqueous
Photolysis
Page
A­
1
Aqueous
Photolysis
value
is
30.1
days.
Reference:
Laskowski,
D.
2002.
Reviews
of
Environmental
Contamination
and
Toxicity.
Volume
174.
pp
52.
RESPONSE:
THIS
ISSUE
WAS
PREVIOUSLY
ADDRESSED.
25
Appendix
A
161­
3
Soil
Photolysis
Page
A­
1
Soil
Photolysis
value
is
165
days.
Reference:
Laskowski,
D.
2002.
Reviews
of
Environmental
Contamination
and
Toxicity.
Volume
174.
pp
52.
RESPONSE:
THIS
ISSUE
WAS
PREVIOUSLY
ADDRESSED.
Appendix
A
162­
1
Aerobic
Soil
Metabolism
Page
A­
2
Aerobic
Soil
Metabolism
value
is
39.2
days
[
mean
+
confidence
limit
(
CL)].
Reference:
Laskowski,
D.
2002.
Reviews
of
Environmental
Contamination
and
Toxicity.
Volume
174.
pp
92
RESPONSE:
THIS
ISSUE
WAS
PREVIOUSLY
ADDRESSED.
Appendix
A
162­
2
Anaerobic
Soil
Metabolism
Page
A­
2
Anaerobic
Soil
Metabolism
value
is
165
days
[
mean
+
CL].
Reference:
Laskowski,
D.
2002.
Reviews
of
Environmental
Contamination
and
Toxicity.
Volume
174.
pp
93.
RESPONSE:
THIS
ISSUE
WAS
PREVIOUSLY
ADDRESSED.
Header
pdf
Version
Page
#;
Paragraph
#
Comments
Appendix
A
162­
4
Aerobic
Aquatic
Metabolism
Page
A­
3
Aerobic
Aquatic
Metabolism
value
is
10.6
days
[
mean
+
CL].
Reference:
Laskowski,
D.
2002.
Reviews
of
Environmental
Contamination
and
Toxicity.
Volume
174.
pp
94.
RESPONSE:
THIS
ISSUE
WAS
PREVIOUSLY
ADDRESSED.
Appendix
A
162­
3
Anaerobic
Aquatic
Metabolism
Page
A­
3
Anaerobic
Aquatic
Metabolism
value
is
22.2
days
[
mean
+
CL].
Reference:
Laskowski,
D.
2002.
Reviews
of
Environmental
Contamination
and
Toxicity.
Volume
174.
pp
95.
RESPONSE:
THIS
ISSUE
WAS
PREVIOUSLY
ADDRESSED.
Header
pdf
Version
Page
#;
Paragraph
#
Comments
Appendix
A
163­
1
Mobility
 
Leaching
and
Ad/
Des
Page
A­
4
The
Koc
value
is
310,000.
Reference:
Laskowski,
D.
2002.
Reviews
of
Environmental
Contamination
and
Toxicity.
Volume
174.
pp
52.
RESPONSE:
THIS
ISSUE
WAS
PREVIOUSLY
ADDRESSED.
Appendix
A
Pages
A1­
A7
Aerobic
Aq,
Anaerobic
Aq
Metabolism
and
Aq
Field
Dissipation
studies
support
a
zetacypermethrin
rice
registration.
These
studies
are
not
relevant
for
cypermethrin.
RESPONSE:
THIS
IS
NOT
AN
ERROR
CORRECTION.
THE
ISSUE
WILL
BE
CONSIDERED
IN
A
SUBSEQUENT
PHASE
Page
A
15.
Page
is
blank.
RESPONSE:
THIS
ISSUE
WAS
PREVIOUSLY
ADDRESSED.
26
Appendix
A
165­
4
Bioaccumulation
in
Fish
Page
A­
8
The
bioconcentration
factor
based
on
fish
wholebody
analysis
is
597.
Reference:
Laskowski,
D.
2002.
Reviews
of
Environmental
Contamination
and
Toxicity.
Volume
174.
pp
52
&
85.
RESPONSE:
THIS
ISSUE
WAS
PREVIOUSLY
ADDRESSED.
Page
B­
1
The
use
of
the
1­
in­
10
year
probability
is
a
very
conservative
and
protective
methodology.
However,
it
is
most
appropriate
to
chose
the
1
 
in­
10
year
distributional
value
that
corresponds
to
the
toxicology
end
point
study
length,
i.
e.
96­
hour,
21­
day,
etc.
as
opposed
to
the
peak
value.
RESPONSE:
The
Agency
does
point
estimates
in
the
Tier
I
Risk
Assessment.
We
also
use
the
concentration
corresponding
to
the
particular
endpoint
of
concern
(
e.
g.
peak
for
acute,
21
day
for
invertebrate
chronic,
and
65­
days
for
fish
chronic.
The
use
of
peak
values
is
more
protective.
This
is
a
policy
issue,
not
an
error.
Appendix
B
1.
1
 
in­
10
year
Probability
Page
B1
Helsel
and
Hirsch
1993
reference
missing
from
any
reference
list.
RESPONSE:
REFERENCE
WAS
ADDED.
Page
C2.
Page
is
blank.
RESPONSE:
THIS
ISSUE
WAS
PREVIOUSLY
ADDRESSED.
Appendix
B
2.
PRZM/
EXAMS
Modeling
Results
Pages
B­
2
through
B­
51
Please
use
the
appropriate
e­
fate
inputs
as
corrected
by
registrants
in
Appendix
A
for
all
modeling
runs.
RESPONSE:
THIS
ISSUE
WAS
PREVIOUSLY
ADDRESSED.
Page
D­
1
Please
provide
the
attached
Microsoft
Excel
spreadsheets
as
indicated
in
the
IRED.
°
Cypermethrin_
T­
REX_
cotton_
v1.12.
xls
°
Cypermethrin_
T­
REX_
lettuce_
v1.12.
xls
°
Cypermethrin_
T­
REX_
pecans_
v1.12.
xls
Rape
is
not
registered
­
remove
Cypermethrin_
TREX
rape_
v1.12.
xls
 
Page
D­
4
Please
add
the
T­
REX
model
to
the
reference
list.
Appendix
D
T­
REX
Model
Inputs,
Results,
Output
Page
D­
4
1
st
paragraph
 
provide
the
graphs.
Header
pdf
Version
Page
#;
Paragraph
#
Comments
Page
E­
3,
1
st
full
paragraph,
2
nd
line
%
ai
for
GFU
061
is
36%.
Update
the
(%
ai
not
reported)
in
the
text
to
reflect
this
change.
RESPONSE:
CORRECTED
Page
E­
3­,
1
st
full
paragraph,
5
th
sentence­­­"
Based
on
these
results .
The
sentence
appears
to
be
incomplete.
Also,
formations
should
be
formulations.
RESPONSE:
CORRECTED
Page
E8
MRID
44546027
is
a
beta­
cypermethrin.
beta­
Cypermethrin
studies
should
not
be
used
in
estimating
cypermethrin
risk.
RESPONSE:
DISCUSSED
PREVIOUSLY
Appendix
E
Ecological
Effects
Database
Page
E­
14,
1
st
full
sentence
The
sentence
appears
to
be
incomplete.
Also,
formations
should
be
formulations.
RESPONSE:
CORRECTED
27
Page
E­
27.
"???"
in
percent
a.
i.
column:
Radio­
labeled
technical,
therefore
"???"
should
read
"
Technical".
RESPONSE:
CORRECTED
Page
E16
MRID
44546031
is
a
beta­
cypermethrin
study.
beta­
Cypermethrin
studies
should
not
be
used
in
estimating
cypermethrin
risk.
RESPONSE:
PREVIOUSLY
DISCUSSED.
Page
E­
31,
line
6
of
1st
paragraph
4.3
ug
ai/
L
should
be
3.42
ug
ai/
L
RESPONSE:
CORRECTED
Page
E­
31
MRID
is
41068003
not
41968212.
RESPONSE:
CORRECTED
Page
E­
39
Table
E­
6,
MRID
070562
mysid
shrimp,
the
24
hr
LC50
is
=
44.7
pptr
not
>
24
pptr
RESPONSE:
CORRECTED
Page
E­
39­
40
MRID
44561209
­
beta­
cypermethrin
studies
should
not
be
used
in
estimating
cypermethrin
risk.
RESPONSE:
PREVIOUSLY
DISCUSSED.
Page
E41
Table
E7,
study
MRID
070562,
chronic
mysid
shrimp,
the
MATC
is
greater
than
0.44
ng/
L
but
less
than
0.64
ng/
L.
This
is
not
captured
within
the
table
descriptions.
RESPONSE:
CORRECTED
Page
E44
MRID
44546035
is
a
beta­
cypermethrin
study.
beta­
Cypermethrin
studies
should
not
be
used
in
estimating
cypermethrin
risk.
RESPONSE:
PREVIOUSLY
DISCUSSED
Page
E56.
Page
is
blank.
Page
E57
Endpoints
need
correcting
 
LD50
male
is
>
10,248
not
>
9520
mg
ai/
kg
bw;
female
LD50
is
>
12,085
not
>
11,
227
mg
ai/
kg
bw.
RESPONSE:
CORRECTED
Page
E57­
58
MRID
44546024
is
a
beta­
cypermethrin
study.
Beta­
Cypermethrin
studies
should
not
be
used
in
estimating
cypermethrin
risk.
RESPONSE:
PREVIOUSLY
DISCUSSED
Header
pdf
Version
Page
#;
Paragraph
#
Comments
Page
E­
58,
paragraph
below
table,
7
th
sentence
MRID
445460261­
should
read
MRID
44546026
RESPONSE:
CORRECTED
Acute
dietary
avian
studies,
MRID
90071
and
90072,
LC50
is
>
20,000
ppm
for
both
not
>
2,634
ppm
and
>
3,951
ppm.
RESPONSE:
CORRECTED
Page
E59
MRID
90071
and
90072
toxic
category
ids
"
practically
non­
toxic"
not
"
slightly
toxic".
RESPONSE:
CORRECTED
Appendix
E
Ecological
Effects
Database
Page
E60
Remove
referenced
beta­
cypermethrin
studies
from
the
list
(
MRID
44546025
and
MRID
44546026).
RESPONSE:
BETA
CYPERMETHRIN
INFORMATION
WAS
USED
AS
BRIDGING
DATA.
TOXICITY
IS
IN
THE
SAME
28
Page
E65
MRID
44544208
studies
are
beta­
cypermethrin
studies.
Beta­
Cypermethrin
studies
should
not
be
used
in
estimating
cypermethrin
risk.
RESPONSE:
BETA
CYPERMETHRIN
INFORMATION
WAS
USED
AS
BRIDGING
DATA.
TOXICITY
IS
IN
THE
SAME
Page
E66
Two
studies
listed,
the
purity
is
36.8%
not
37.2%.
RESPONSE:
CORRECTED
Appendix
F
The
Risk
Quotient 
Concern
s
Page
F­
1
The
RQ
equation
is
superimposed
on
the
text
in
both
the
electronic
and
paper
copies.
RESPONSE:
CORRECTED
Appendix
G
Table
G­
4
Page
G­
3
The
21­
day
EEC
for
TX
cotton
is
0.060
ug/
L,
which
also
changes
the
chronic
RQ
to
0.9,
below
the
LOC.
RESPONSE:
CORRECTED
Appendix
G
Table
G­
6
Page
G­
5
The
21­
day
EEC
for
TX
cotton
is
0.060
ug/
L.
RESPONSE:
CORRECTED
Appendix
G
Table
G­
9
Page
G­
7
The
peak
EEC
for
CA
lettuce
is
30.5
ug/
kg.
RESPONSE:
CORRECTED
Appendix
G
Table
G­
10
Page
G­
8
The
peak
EEC
for
TX
cotton
is
0.0073
ug/
L.
RESPONSE:
CORRECTED
Appendix
G
Page
G­
9
The
page
is
blank.
RESPONSE:
THIS
ISSUE
WAS
PREVIOUSLY
ADDRESSED.
Appendix
G
Tables
G­
13
to
G­
24
Pages
G­
12
to
G­
20
The
T­
REX
output
was
not
included
in
Appendix
D,
so
the
RQs
could
not
be
checked.

Appendix
H
Page
H1
Please
provide
an
anticipated
timeline
for
the
ES
assessment
(
if
available).
Response:
The
Agency
will
not
be
providing
a
list
of
species
relative
to
use
sites,
at
this
time.
Page
H2.
Page
is
blank.
RESPONSE:
THIS
ISSUE
WAS
PREVIOUSLY
ADDRESSED.
Header
pdf
Version
Page
#;
Paragraph
#
Comments
29
Table
I­
1,
Page
I­
1
 
161­
1
Aqueous
Photolysis
value
is
30.1
days.
 
161­
3
Soil
Photolysis
value
is
165
days.
 
162­
1
Aerobic
Soil
Metabolism
value
is
39.2
days
[
mean
+
confidence
limit
(
CL)].
 
162­
2
Anaerobic
Soil
Metabolism
value
is
165
days
[
mean
+
CL].
 
162­
4
Aerobic
Aquatic
Metabolism
value
is
10.6
days
[
mean
+
CL].
 
162­
3
Anaerobic
Aquatic
Metabolism
value
is
22.2
days
[
mean
+
CL].
 
163­
1
The
Koc
value
is
310,000.
 
165­
4
The
bioconcentration
factor
based
on
fish
whole­
body
analysis
is
597.
Reference:
Laskowski,
D.
2002.
Reviews
of
Environmental
Contamination
and
Toxicity.
Volume
174.
RESPONSE:
THIS
ISSUE
WAS
PREVIOUSLY
ADDRESSED.

MRID
42124002­
is
a
typo
42129002
(
ad/
des)
RESPONSE:
AGREE.
Appendix
I
Data
Requirement
Tables
 
Environmental
Fate
and
Effects
Pages
I3,
I5,
I6
It
is
unclear
why
one
entry
is
highlighted
in
blue.
RESPONSE:
CORRECTED
Page
I5,
72­
3(
d)
It
is
unclear
why
one
entry
is
highlighted
in
blue.
RESPONSE:
CORRECTED
Page
I5
72­
4,
MRID
89047
is
a
21­
day
daphnia
magna
not
a
marine
study
but
freshwater
study.
RESPONSE:
CORRECTED
Appendix
I
Data
Requirement
Tables
(
Ecological
Effects)

Page
I6,
72­
7
It
is
unclear
why
one
entry
is
highlighted
in
blue.
RESPONSE:
CORRECTED
Page
J­
1
Certainty
Index,
remove
zeros
after
the
decimal.
RESPONSE:
CORRECTED
Appendix
J
Page
J­
1
J1
(
J2?);
the
Certainty
Index
do
not
match
those
listed
on
p­
93
RESPONSE:
CORRECTED
Appendix
K
Page
K­
1
Provide
Excel
files
 
they
are
not
attached.
Which
10
publications?
Provide
list.

Header
pdf
Version
Page
#;
Paragraph
#
Comments
Pages
L­
1
through
L­
8
Numbers
are
very
difficult
to
read
on
both
electronic
and
paper
copies.
RESPONSE:
THIS
ISSUE
WAS
PREVIOUSLY
ADDRESSED.
Page
L­
2
Page
is
unreadable.
Map
is
cutoff
and
text
is
overlapping
on
both
electronic
and
paper
copies.
Pages
L­
4
and
L­
6.
Pages
are
blank.
RESPONSE:
THIS
ISSUE
WAS
PREVIOUSLY
ADDRESSED.
Appendix
L
Use
Characterization
Maps
Page
L­
8
Text
is
overlapping
base
map
on
both
electronic
and
paper
copies.
Figure
6
and
figure
7
embedded
on
each
other.
One
of
the
figures
is
missing.
RESPONSE:
CORRECTED
Appendix
M
Equilibrium
Partitioning
and
Page
M­
1
Please
define
benthos
(
as
the
bottom
of
a
pond)
for
the
general
public.
RESPONSE:
CORRECTED
30
Page
M­
3
Cannot
find
Table
3.7
in
this
document.
This
reference
should
be
Tables
7­
9
(
pages
42­
44).
RESPONSE:
CORRECTED
Page
M­
3
The
range
of
EECs
in
benthic
pore
water
by
PRZM/
EXAMS
is
0.0044
­
0.0304
ug/
L.
The
highest
EECs
are
for
the
NC
Cotton
scenario.
RESPONSE:
CORRECTED
Page
M­
4
There
are
two
appendices
titled
Appendix
N.
The
Environmental
Fate
bibliography
is
on
pages
M­
4
to
M­
7
in
the
second
Appendix
N.
Rename
appendices
and
renumber
pages
as
appropriate.
RESPONSE:
CORRECTED.
Page
M­
6
For
MRID
42868203,
the
authors
are
E.
Giroir
and
L.
Stuerman,
not
L.
Sherman.
RESPONSE:
AGREE,
CORRECTED.
Appendix
N.
Environmental
Fate
and
Monitoring
Bibliography
Page
M­
6
For
MRID
44876105,
the
author
is
A.
Ramsey
and
the
report
date
is
1998.
For
clarity,
the
Lab
study
number
is
194E2697E1,
and
the
report
number
is
P­
3329.
RESPONSE:
THE
STUDY
AUTHOR
WAS
CORRECTED.
Appendix
N.
Ecological
Effects
MRID
Studies
Submitted
to
EPA
Page
N
1
Reference
Accession
No.
070562:
Replace
with
full
reference:
"
Stephenson,
R.
R.;
Sherwood,
C.
M.;
Bennett,
D.;
et
al.
(
1980)
The
Acute
Toxicity
of
WL
43467
to
Some
Freshwater
Invertebrates
in
Static
Water
Tests:
Group
Research
Report
TLGR.
80.040.
(
Un­
published
study
received
Dec
30,
1981
under
10182­
64;
prepared
by
Shell
Research,
Ltd.,
England,
submitted
by
ICI
Americas,
Inc.,
Wilmington,
Del.;
CDL:
070562­
F)".
RESPONSE:
CORRECTED
Page
N
2
Clarify
MRID
62793
as
follows:

MRID
62793.
Edwards,
P.
J.,
Brown,
S.
M.,
and
A.
S.
Sapiets.
(
February
1980).
Cypermethrin
(
PP383):
Toxicity
of
technical
and
formulated
material
to
first
instar
Daphnia
magna.
ICI
Plant
Protection
Division.
RJ011OB.

MRID
92027014
Hamer,
M.
(
1990)
ICI
Americas
Inc.
Phase
3
Summary
of
MRID
00062793.
Cypermethrin
(
PP383):
Toxicity
of
Technical
and
Formulated
Material
to
First
Instar
Daphnia
magna:
Report
No.:
RJ011OB;
Study
No.:
PP383/
CN/
01.
Prepared
by
ICI
Agrochemicals,
Jealott's
Hill
Research
Station
17
p.
RESPONSE:
CORRECTED
Page
N
3
Correct
MRID
65812
as
follows:
Delete
author
ICI
and
replace
with
"
Hill,
R.
W.".;
insert
report
number
"
ICI
Brixham
BL/
B/
2011".
RESPONSE:
CORRECTED
Page
N
5
Correct
date
for
MRID
90040:
delete
"
1972?"
and
replace
with
"
February
1979".
RESPONSE:
CORRECTED
31
Pages
N
10
 
N11
References
for
beta­
cypermethrin
are
listed.
beta­
Cypermethrin
studies
should
not
be
used
in
estimating
cypermethrin
risk.
RESPONSE:
BETA
CYPERMETHRIN
INFORMATION
WAS
USED
AS
BRIDGING
DATA.
TOXICITY
IS
IN
THE
SAME
Valent
BioScience
Error
Correction
Comments:
32
EFED
Responses:

xii;
xvi;
45;
1st
paragraph;
46,
3rd
paragraph,
last
sentence;
A­
11
thru
A­
14;
A­
15;
G­
9;
H­
2;
L­
2;
L­
4,
L­
6;
L­
8
­
Responses
to
these
items
were
provided
earlier
in
this
report
(
refer
to
comments
and
responses
above).

47,
Footnote
­
Font
in
the
footnote
is
different
 
this
comment
is
not
an
error.
33
86
thru
remaining
text
 
It
was
found
that
the
same
font
and
font
size
were
used,
the
difference
was
the
line
height.
This
minor
problem
was
resolved.

95,
Table
20
 
Table
was
corrected.

E­
20
 

H­
1
 

M­
4;
M­
4
thru
M­
7;
N­
1;
N­
7
to
N­
8,
N­
9
to
N­
10;
O­
1
 
Various
comments
 
All
these
problems
were
corrected.
The
EFED
will
try
to
avoid
confusion
with
the
printouts
of
the
maps.
The
numbering
of
the
appendices
was
corrected.
