UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON, D.C.  20460

  SEQ CHAPTER \h \r 1 	

	OFFICE OF

PREVENTION, PESTICIDES AND TOXIC SUBSTANCES



Date: February 03, 2006

Chemical: ADBAC/DDAC

PC Codes: 069105/069149

Barcode: D322872/D325481 

MEMORANDUM

SUBJECT:	Ecological Risk Assessment in Support of the Antimicrobials
Division’s Reregistration of ADBAC and DDAC

FROM:		Brian D. Kiernan, Biologist

		  SEQ CHAPTER \h \r 1 Marietta Echeverria, Environmental Scientist

		  SEQ CHAPTER \h \r 1 Environmental Risk Branch IV

		Environmental Fate and Effects Division (7507C)

THRU:		Elizabeth Behl, Branch Chief

		Environmental Risk Branch IV

		Environmental Fate and Effects Division (7507C)

TO:		Jacqueline Campbell-McFarlane

		Tracy Lantz

		Chemical Review Managers

		Antimicrobials Division (7510)

Risk Assessment Summary and Conclusions

The Environmental Fate and Effects Division has completed its ecological
risk assessment for the outdoor uses of ADBAC and DDAC in support of the
Antimicrobials Division Reregistration Eligibility Decision (RED) for
these chemicals.  DDAC is an active ingredient in only one of the
formulations assessed, and it does not appear to pose high risk to
wildlife when used according to the label.  Several ADBAC uses pose
acute and chronic risk to aquatic and terrestrial wildlife.  Risk to
terrestrial and aquatic plants cannot be evaluated due to a lack of
data, but risk is presumed.  Based on this screening-level assessment,
risk to Federally listed species also cannot be precluded.  Further work
is necessary to develop a refined risk assessment evaluating endangered
species.  Although primarily used as antimicrobial agents, uses which
are not assessed in this document, outdoor applications of ADBAC and
DDAC included in this assessment were ornamental nurseries, residential
and commercial turf, mosquito larvicide and algacide in ornamental pools
and puddles.

Data gaps identified include chronic toxicity studies of
estuarine/marine fish and invertebrates, as well as avian wildlife.  The
toxicity of ADBAC to terrestrial and aquatic nontarget plants is not
assessed either, due to lack of data.



1	Problem Formulation

Stressor Source and Distribution

The Environmental Fate and Effects Division (EFED) has evaluated the
outdoor uses of the quaternary ammonium compounds being considered for
reregistration by the Antimicrobial Division (AD).  The compounds being
considered are alkyl dimethyl benzyl ammonium chlorides (ADBAC) and
didecyl ammonium chlorides (DDAC).  ADBAC and DDAC are used primarily as
disinfectants, sanitizers, and microbiocides/microbiostats.  They are
also used as algaecides, bacteriocides/bacteriostats,
fungicides/fungistats, insecticides, miticides, virucides, and feeding
suppressants.  Use sites for ADBAC and DDAC include agricultural
premises and equipment, food handling equipment, commercial, industrial
and institutional settings, residential areas or areas of public access,
pets and kennels, medical facilities, swimming pools, aquatic areas, and
industrial water systems.  Although primarily used as antimicrobial
agents for these diverse uses, several labeled outdoor uses are being
assessed by EFED because of the potential for environmental exposures
and ecological effects.  Specifically, ADBAC uses include ornamental
plants and shrubs in nurseries, residential lawns and commercial turf
(not sod farms) and golf course greens, tees and fairways.  Both ADBAC
and DDAC are labeled for use in puddles and decorative pools to control
algae.  ADBAC is also labeled for use as mosquito larvicide in standing
waters, including decorative ponds and pools, inactive spas and hot
tubs, as well as ‘old tires, empty tin cans, puddles and water drains
around buildings’ (RD 20 label).  Only the ADBAC and DDAC uses that
appear likely to result in environmental exposures and effects are being
evaluated in this assessment (Table 1.1).

Table 1.1.  ADBAC and DDAC products and uses being evaluated.

Class	Trade Name	Reg. #	% ai	Agricultural/Outdoor Uses

DDAC	TC 192	499-482	12	Decorative ponds, pools, puddles

ADBAC	TC 192	499-482	8	Decorative ponds, pools, puddles

ADBAC	Consan	58044-3	20	Nursery/ornamentals





Turf, golf courses

ADBAC	RD 20	53642-1	20	Decorative ponds, pools, puddles





Nursery/ornamentals,





Turf, golf courses,





Mosquito control

ADBAC	Timsen	507-3	40	Nursery/ornamentals

ADBAC	PT 2000	499-368	20	Decorative ponds, pools, puddles



Receptors 

Ecological effect endpoints are derived from registrant-submitted
guideline studies as required for registration under the Federal
Insecticide, Fungicide and Rodenticide Act (FIFRA; 40 CFR Part 158), as
well as a review of acceptable open literature (ECOTOX), when available.
 The most sensitive endpoints (described below) from each study of
surrogate species are used to estimate risk to the taxonomic group(s)
represented by the surrogate tested.  Toxicity testing reported in this
document represents all terrestrial and aquatic organisms.  However,
only a few surrogate species for both freshwater fish and birds are used
to represent all freshwater fish (2000+) and bird (680+) species in the
United States.  In addition, neither reptiles nor amphibians are tested.
 Birds are used as surrogates for reptiles and terrestrial-phase
amphibians; fish are used as surrogates for aquatic-phase amphibians. 
The Norway rat is typically the surrogate for all mammal species.

  SEQ CHAPTER \h \r 1 

  SEQ CHAPTER \h \r 1 Identification of Assessment Endpoints

Assessment endpoints are defined, per Agency guidelines, as “explicit
expressions of the actual environmental value that is to be protected”
which are “operationally defined by an ecological entity and its
attributes” (USEPA, 2004).  The ecological entity can be a species, a
functional group of species, a community, an ecosystem, or another
entity of importance or concern.  An attribute is the characteristic of
the entity that is important to protect and is potentially at risk.  

Defining an assessment endpoint involves two steps: 1) identifying the
valued attributes of the environment that are considered to be at risk,
and 2) operationally defining the assessment endpoint in terms of an
ecological entity (e.g., a community of fish and aquatic invertebrates)
and its attributes (i.e., survival and reproduction).  Therefore,
selection of the assessment endpoints is based on valued entities (i.e.,
ecological receptors), the ecosystems potentially at risk and the routes
by which ecological receptors are exposed to pesticide-related
contamination.  The selection of clearly defined assessment endpoints is
important because they provide direction and boundaries in the risk
assessment for addressing risk management issues of concern.

Typical assessment endpoints for screening-level pesticide ecological
risk assessments include reduced survival and/or reproductive impairment
for both aquatic and terrestrial animal species from direct acute or
direct chronic exposures.  Aquatic animal groups that are typically
characterized in the risk assessment include: freshwater fish and
invertebrates, estuarine/marine fish and invertebrates.  Terrestrial
animal groups include birds, mammals, and beneficial insects.  All
assessment endpoints are characterized at the individual level in order
to protect threatened and endangered species.  However, risks to higher
biological levels (i.e., populations and communities) can be inferred
from this approach (e.g., pesticide effects on individual survival and
fecundity may impact both population stability, growth, and habitat
carrying capacity).  Indirect effects to listed species and critical
habitat must also be characterized in a species-specific assessment
conducted after the screening-level risk assessment is completed.  

For terrestrial and semi-aquatic plants, the screening assessment
endpoint is the perpetuation of populations of non-target species (crops
and non-crop plant species).  Existing testing requirements only
evaluate emergence of seedlings and vegetative vigor of annuals. 
Although it is recognized that the endpoints of seedling emergence and
vegetative vigor may not address all terrestrial and semi-aquatic plant
life cycle components, it is assumed that impacts on plant emergence
and/or on active growth have the potential to impact individual
competitive ability and reproductive success, from which population
effects can be inferred.

For aquatic plants, the assessment endpoint is the maintenance and
growth of standing crop or biomass.  Measurement endpoints for this
assessment endpoint focus on algal and vascular plant (i.e., duckweed)
growth rates and biomass measurements. 

The ecological relevance of the assessment endpoints assumes that
complete exposure pathways exist for these receptors, that the receptors
may be sensitive to pesticides in affected media and/or forage items and
that the receptors could potentially inhabit areas where pesticides are
applied, or areas where runoff and/or spray drift may impact the sites
because suitable habitat is available.

Ecological measurement endpoints for this screening-level risk
assessment are based on a suite of registrant-submitted toxicity studies
performed on a limited number of organisms, supplemented by the open
literature where applicable, in the following broad groupings:

Birds (bobwhite quail), also used as surrogate species for
terrestrial-phase amphibians and reptiles,

Mammals (laboratory rat),

Freshwater Fish (bluegill sunfish, rainbow trout and fathead minnow),
also used as a surrogate for aquatic-phase amphibians,

Freshwater invertebrates (Daphnia magna),

Estuarine/marine fish (sheepshead minnow, inland silverside),

Estuarine/marine invertebrates (Mysidopsis bahia, Eastern oyster),

Terrestrial plants (no data available)

Algae and aquatic plants (no data available).

Within each of these very broad taxonomic groups, an acute and chronic
endpoint is selected from the available test data.  The selection is
made from the most sensitive species tested within a particular
surrogate group.  If additional toxicity data are available from other
sources, the selection of an endpoint may not be limited to the
surrogate species listed above, but may be expanded to include those
data for other groups or species which has been deemed of sufficient
quality by OPP scientists for use in the risk assessment.  

Conceptual Model 

In order for a chemical to pose an ecological risk, it must reach
ecological receptors in biologically significant concentrations. 
Exposure pathways are defined as the means by which a contaminant moves
in the environment from a source to an ecological receptor.  For an
ecological exposure pathway to be complete, it must have a source, an
environmental transport medium, a point of exposure for ecological
receptors, and a feasible route of exposure.  

Ecological receptors that may potentially be exposed to ADBAC include
terrestrial and semiaquatic wildlife (i.e., mammals, birds, amphibians
and reptiles), terrestrial and semi-aquatic plants, and terrestrial soil
and aquatic sediment invertebrates.  Additionally, aquatic organisms
(i.e., freshwater and estuarine/marine fish and invertebrates,
amphibians, and aquatic plants) are potential receptors in adjacent
water bodies through the off-site transport of ADBAC from the
application site through runoff, erosion and spray drift.  The primary
route of wildlife exposure to DDAC appears to be through drinking
treated water, though amphibians may be at risk from these applications.

Risk Hypothesis 

	

	  SEQ CHAPTER \h \r 1 At maximum application rates for the previously
described uses exposure of terrestrial, aquatic and semi-aquatic
wildlife and plants to ADBAC and/or DDAC may be sufficiently high to
result in direct effects (i.e., mortality due to acute exposure or
impaired reproduction, growth, or survival from chronic exposure). 
Additionally, endangered and threatened species may be indirectly
affected by ADBAC and/or DDAC due to a loss of food resources and/or
changes to critical habitat resulting from proposed uses.

Analysis Plan 

This screening level ecological risk assessment characterizes the
environmental fate and transport of ADBAC to assess the extent to which
non-target organisms may be exposed through the current proposed uses of
these pesticides.  EFED relied on AD’s evaluation of the environmental
fate and transport of ADBAC and DDAC, which can be found in the AD RED
document.  The toxicity of ADBAC is also characterized, based primarily
on registrant-submitted guideline toxicity tests and additional
information from open literature available through the Agency’s ECOTOX
database (  HYPERLINK "http://www.epa.gov/ecotox/" 
http://www.epa.gov/ecotox/ ), and evaluated by AD scientists.  Estimated
exposure and effects are integrated to calculate risk quotients (RQs)
for non-target Federally listed endangered/threatened and other
non-target animals and plants.  RQs are compared to pre-determined
levels-of-concern (LOCs) to screen out those taxa to which ADBAC is not
likely to pose unacceptable risk.  Because of the limited use and low
expected exposure of wildlife to DDAC, as detailed later in this
document, ADBAC is primarily considered in this document.		

	Although risk, in the context intended here, is often defined as the
likelihood and magnitude of adverse ecological effects, the risk
quotient-based approach does not provide a quantitative estimate of
likelihood and/or magnitude of adverse effects.  Such estimates may be
possible through a more refined, probabilistic assessment.  However,
this is beyond the scope of this screening-level assessment.

1.6	Routes of Exposure

Routes of exposure to terrestrial and aquatic organisms can occur from
direct deposition, spray drift and/or runoff.  Exposure may be through
ingestion of contaminated food or water sources, dermal contact or
absorption, and inhalation.  The Agency assumes terrestrial organisms
are present and feeding on the use site.  All routes of aquatic exposure
are assumed to be accounted for.

	This assessment does not take into account atmospheric transport in
estimating environmental concentrations, nor does it account for
ingestion of ADBAC or DDAC residues by animals in contaminated grit,
ingestion through preening activities, or uptake through inhalation or
dermal absorption by terrestrial animals.  Exposure to terrestrial
animals is based primarily on dietary consumption of foliar residues
and, in this case, drinking water.  Aquatic assessments assume that all
potential routes of direct exposure are accounted for.  While ADBAC and
DDAC are registered for use in greenhouses, this use is typically
conducted indoors and, thus, exposure to non-target animals is limited
and is therefore not considered in this assessment.

Analysis

Use Characterization

ADBAC and DDAC are used primarily as antimicrobial agents; evaluation of
these uses can be found in the Antimicrobials Division risk assessment
in support of the reregistration eligibility decision (RED) for these
compounds.  Additionally, ADBAC is used on ornamental plants and shrubs,
residential lawns and commercial turf and golf course greens, tees and
fairways.  Both ADBAC and DDAC are labeled for use in puddles and
decorative pools to control algae.  ADBAC is also labeled for use as
mosquito larvicide in standing waters, including decorative ponds and
pools, inactive spas and hot tubs, as well as ‘old tires, empty tin
cans, puddles and water drains around buildings’ (RD20® label).  Only
the ADBAC/DDAC uses which could result in potential environmental
exposures and effects are being evaluated in this assessment.  These
uses are described below.

Puddles, Ornamental Ponds and Pools

Three products are labeled for the control of algae in puddles and
ornamental ponds and pools, RD20®, TC192® and PT2000®.  All three
products contain ADBAC; TC192 also contains DDAC (the only DDAC use
considered in this assessment).  These uses are labeled for direct
application to water with a target maximum concentration of 5 ppm for
the first application.  Subsequent applications can be made weekly at
concentrations of 2.5 ppm.  There are no label limits on the number of
applications that can be made in a year.  These applications can be a
source of exposure to terrestrial wildlife making use of the water for
drinking or bathing, as well as amphibians making use of these
waterbodies for all or part of their lifecycle.  Because the product is
applied directly into the water, exposure via forage items is not
expected (emergent vegetation is assumed not to be present).  The labels
specifically state that application should not be made where fish are
present; therefore exposure to fish is not expected when used in
accordance with the label.  However, because there is no explicit
prohibition on the labels, exposure to amphibians is possible,
especially during the aquatic phase.  Because of the persistence of
ADBAC and DDAC, the weekly maintenance applications could, at least in
some instances, result in increased concentrations throughout the year,
leading to the potential for exposure at concentrations greater than 5
ppm.  This assessment assumes, as suggested on the labels, that the
target waterbodies are ornamental or periodic and disconnected from the
larger watershed.  The label should be more explicit regarding this
assumption.  Further work would need to be done to evaluate potential
wildlife exposure if the registrants do not support this assumption. 

Mosquito control

The mosquito control uses (RD20® product label) specify that treated
bodies of all sizes receive an initial treatment at a target
concentration of 200 ppm and allow weekly maintenance dose at a
concentration of 100 ppm.  There are no label limits on the number of
applications that can be made in a year.  Because of the types of
standing waters indicated on the label (from empty tin cans to
decorative ponds), this use could be a source of exposure to terrestrial
wildlife making use of the water for drinking or bathing, or by
amphibians for completion of a lifecycle phase, such as tadpoles.  Since
the product is applied directly into the water, exposure via forage
items is not expected (emergent vegetation is assumed not to be
present).  The label specifically states that application should not be
made where fish are present; therefore, exposure to fish is not expected
when used in accordance with the label.  However, because there is no
explicit prohibition on the labels, exposure to amphibians is possible,
especially during the aquatic phase.  Because of the persistence of
ADBAC, the weekly maintenance applications could, at least in some
instances, result in increased concentrations throughout the year,
leading to the potential for exposure at doses far greater than 200 ppm
for other wildlife.  This assessment assumes, as suggested on the label,
that the target waterbodies are ornamental or periodic and disconnected
from the larger watershed.  The label should be more explicit regarding
this assumption.  Further work would need to be done to evaluate
potential wildlife exposure if the registrants do not support this
assumption.

Turf and Golf Courses

Two ADBAC products (Consan® and RD20®) are labeled for use on
residential lawns, commercial turf and golf courses.  These uses control
algal build-up and fungal diseases such as fusarium blight (Fusarium
spp.) and brown patch (Rhizoctonia spp.).  Smaller use sites, such as
residential lawns, are labeled for a concentration of 790 ppm which is
equivalent to a rate of 6.8 lb ai/A.  This rate is also used for golf
courses and commercial (nonagricultural) turf unless a commercial power
sprayer is used.  If a commercial power sprayer is used, the application
rate is reduced to 512 ppm (0.82 lb ai/A).  Presumably, as implied on
the labels, smaller areas would be treated at the higher rate, while
larger-scale applications would be treated at the lower rate.  However,
this assumption is not fully clear from the label and should be
explicitly expressed.  Further assessment would be required if this
assumption is not supported.

The product labels do not specify seasonal or yearly limits on the
maximum number of applications or pounds per acre.  The label does
specify 10-14 days between applications.  The label states applications
should be made during the warm growing season, so the number of
applications may vary depending on the geographic area where it is used.
 Without a limit, a hypothetical Florida golf course could apply ADBAC
every ten days all year long.  Without data indicating otherwise, this
seems plausible given the wide range of target organisms for which ADBAC
controls (semi-terrestrial alga species, numerous species of fungi). 
These organisms are generally a greater problem under warm wet
conditions, so some use sites may need appreciably fewer applications to
achieve desired control.  However, it is unclear what a typical number
of applications would be; maximum applications per year should be
explicitly stated on the labels.

Terrestrial wildlife exposure could occur from these uses, whether
through foraging in the treated area or by feeding on organisms affected
by spray drift, runoff and or erosion.  Aquatic organisms could be
affected by spray drift, runoff and/or erosion.  This assessment
evaluates these potential routes of exposure.

Nursery Uses (bedding plants, ornamental shrubs and trees)

The products Timsen®, Consan® and RD20® are all labeled for nursery
uses to control various fungal and bacterial pathogens that can cause
damage to ornamental plants.  The uses appear to be limited to spray and
drench applications, and are assessed accordingly.  However, the
intended application methods should be explicitly stated on the labels. 
In 2002, there were 68,214 acres of floriculture (bedding/garden plants,
cut flowers and cut florist greens, foliage plants, and potted flowering
plants) grown in 14,579 outdoor nurseries in the US (  HYPERLINK
"http://www.nass.usda.gov/census/"  www.nass.usda.gov/census/ ).  The
labels allow for use on a variety of herbaceous annuals, such as fuchsia
and snapdragons, as well as larger perennials such as ash and sycamore
trees.  Because different ornamental species have different pathogen
pressures, different rates are recommended for each pathogen targeted. 
For instance, palms needing protection from heart rot and penicillium
leaf base rot are treated with Consan® at a concentration of 1563 ppm
while crepe myrtle and fruit trees being treated for fireblight are
treated at a concentration of 781 ppm.  Differences in amount of product
that will potentially be available for exposure to non-target organisms
depends on the quantity of solution applied.  The palm treatment uses a
small amount of solution poured into the ‘cup’ formed at the base of
the leaves; this treatment is repeated weekly until control is achieved.
 For fireblight control, the entire tree is sprayed at two-week
intervals, with some phenological limitations (e.g., early spring and
fall after harvest; Consan® label only).  For some larger ornamentals,
such as ash or sycamore, the label states that 50-60 gallons of solution
(528 ppm) may be required to achieve full coverage.  These applications
can be repeated up to three times, at intervals determined by leaf
emergence and development.  These treatments are equivalent to
application of 0.25 lbs ai/tree/treatment.  If 40 gallons is assumed to
be required for adequate coverage of somewhat smaller trees, such as
fruit trees (781 ppm), the mass applied is also 0.25 lbs
ai/tree/treatment.  Wildlife could be exposed through runoff or drift
contaminating food or water sources, or foraging on either the treated
plant or nontarget plants in the vicinity of the treatment.  

 

2.2	Exposure Characterization

2.2.1	Environmental Fate and Transport Characterization

  SEQ CHAPTER \h \r 1 ADBAC is immobile and persistent; while it is not
likely to leach in to groundwater, it may enter surface water through
erosion.  The available soil mobility study shows that ADBAC has a
strong tendency to bind to sediment/soil with Freundlich Kads values of
6,172 for sand soil, 10,797 for silt loam, 5,123 for sandy loam soil,
and 32,429 for clay loam.  The corresponding Koc values are 6,171,657
for sand soil, 2,159,346 for silt loam, 640,389 for sandy loam soil, and
1,663,039 for clay loam (MRID 424148-01).  There are no guideline data
for aerobic soil degradation of ADBAC.  Because of its strong adsorption
to soils, the potential to reach aquatic water bodies via runoff or
leaching is limited.  ADBAC may, however, be transported off-site to
aquatic water bodies as entrained sediment or via spray drift during
aerial or ground spray applications.  Once in aquatic environments,
ADBAC is hydrolytically stable under abiotic and buffered conditions
over the pH 5-9 range (MRID 408356-02).  ADBAC is also stable to
photodegradation in pH 7 buffered aqueous solutions (MRID 408356-03).  

	Aquatic metabolism studies under aerobic and anaerobic conditions
indicate that ADBAC is stable to microbial degradation.  ADBAC did not
degrade in flooded sand loam soil that was incubated at 24-27°C in the
dark for up to 30 days in an aerobic aquatic metabolism study (MRID
408356-04).  Under anaerobic conditions, ADBAC was found to be very
resistant to degradation with a calculated half-life of 1,815 days (MRID
424151-01).      

	

	Bioaccumulation of ADBAC in freshwater fish is not likely to occur. 
Maximum bioconcentration factors (BCF) were 33X for edible tissues
(muscle, skin), 160X for nonedible tissues (viscera, head, carcass), and
79X for whole fish tissues (MRID 410268-01).  ADBAC is not expected to
pose a concern for bioconcentration in aquatic organisms.	

	Major degradates were not identified in any of the available studies. 
The environmental fate and physical-chemical properties, based on
submitted guideline studies, are summarized in Table 2.1.  Details of
individual studies can be found in the ADBAC Environmental Fate
Assessment conducted by the AD.  

Table 2.1 General fate and physical-chemical data for ADBAC.

Parameter	Value	Source

Molecular Weight	368.05	Product chemistry

Solubility (25º C)	18.44 mg/L	Product chemistry

Vapor Pressure (25º C)	3.53 x 10-12 torr	Product chemistry

Hydrolysis Half-life (25º C)

  pH 5

  pH 7

  pH 9	

150 d

183 d

379 d	MRID 42242601

Aqueous Photolysis Half-life	stable	MRIDs 408356-03, 424152-01

Soil Photolysis Half-life	no data

	Aerobic Soil Metabolism Half-life	no data

	Aerobic Aquatic Metabolism Half-life	stable (sand loam)	MRIDs
408356-04, 424149-01

Anaerobic Aquatic Metabolism Half-life	1,815 d (sandy loam)	MRIDs
424151-01, 424150-02

Organic Carbon Partitioning Coefficient (Koc, L/kgoc)	  SEQ CHAPTER \h
\r 1 6.2 x 106, 2.2 x 106, 6.4 x 105, 1.7 x 106	MRID 424148-01

Soil Partitioning Coefficient (kd, L/kg)	  SEQ CHAPTER \h \r 1 6172,
10797, 5123, 32429	MRID 424148-01

Bioconcentration Factors (BCF)

  Edible tissue

  Nonedible tissue

  Whole fish tissue	

33X

160X

79X	MRID 410268-01



2.2.2	Measures of Aquatic Exposure

  SEQ CHAPTER \h \r 1 This assessment involves Tier II modeling
(PRZM/EXAMS) for selected scenarios representing all proposed outdoor
uses.  Monitoring data were not considered because national-scale
monitoring studies were not identified.  For Tier II, two models are
used in tandem.  The Pesticide Root Zone Model, (PRZM, Carsel et al.,
1997) simulates fate and transport on the agricultural field.  The
version of PRZM used was PRZM 3.12 beta dated May 24, 2001.  The water
body is simulated with Exposure Analysis Modeling System (EXAMS),
version 2.98, dated July 18, 2002 (Burns, 1997).  Simulations are run
for multiple (usually 30) years and the estimated environmental
concentrations (EECs) represent peak values that are expected once every
ten years based on the thirty years of daily values generated during the
simulation.

For aquatic endpoints, the exposure is estimated for the maximum
application pattern to a 10-ha field bordering a 1-ha pond, 2-m deep
(20,000 m3) with no outlet.  Exposure estimates generated using this
standard pond are intended to represent a wide variety of vulnerable
water bodies that occur at the top of watersheds including prairie pot
holes, playa lakes, wetlands, vernal pools, man-made and natural ponds,
and intermittent and first-order streams.  As a group, there are factors
that make these water bodies more or less vulnerable than the standard
surrogate pond.  Static water bodies that have larger ratios of drainage
area to water body volume would be expected to have higher peak EECs
than the standard pond.  These water bodies will be either smaller in
size or have large drainage areas.  Smaller water bodies tend to have
limited storage capacity and thus tend to overflow and carry pesticide
in the discharge whereas the standard pond has no discharge.  As
watershed size increases beyond 10-ha, it becomes increasingly unlikely
that the entire watershed is planted with a non-major single crop that
is all treated with the pesticide.  Headwater streams can also have peak
concentrations higher than the standard pond, but they tend to persist
for only short periods of time and are then carried downstream.

OPP standard PRZM crop or orchard scenarios, which consist of soils,
weather and cropping practices that are location-specific, are used in
the simulations to represent labeled uses of ADBAC. These scenarios are
developed to represent high-end exposure sites in terms of vulnerability
to runoff and erosion and subsequent off-site transport of pesticide.  

2.2.2.1	Aquatic exposure modeling

  SEQ CHAPTER \h \r 1 Tier II EECs are estimated using EFED’s aquatic
models PRZM and EXAMS (described in previous section).  PRZM is used to
simulate pesticide transport as a result of runoff, erosion and spray
drift from a 10-ha agricultural field and EXAMS considers environmental
fate and transport of pesticides in surface water and predicts EECs in a
standard pond (10,000-m2 pond, 2-m deep), with the assumption that the
small field is cropped at 100%.  Simulations are carried out with the
linkage program shell, PE4V01.pl (dated 8/13/2003), which incorporates
the standard crop and orchard scenarios developed by EFED.  Additional
information on these models can be found at:     HYPERLINK
"http://www.epa.gov/oppefed1/models/water/index.htm" 
http://www.epa.gov/oppefed1/models/water/index.htm .

All horticultural or aquatic ADBAC/DDAC uses are considered in this
assessment (puddles, ornamental ponds and pools; mosquito control; turf
and golf courses; ornamental shrubs and trees).  For aquatic exposures,
it is assumed that the direct applications to puddles, ornamental ponds
and pools and the mosquito control uses result in minimal exposure to
aquatic environments since the labels specify that applications should
not be made where fish are present and it is implied on the label that
the application sites are ornamental or periodic and disconnected from
the greater watershed.  However, even small, ephemeral puddles can be
used wildlife for drinking water and, as in the case of amphibians, for
critical life stages.  Labels need to explicitly state any restrictions.
 For the turf and golf course uses, two standard scenarios were used for
PRZM/EXAMS modeling, FL turf and PA turf.  For the ornamental uses, two
standard scenarios were used as surrogates for ornamental trees, OR Xmas
tree and GA pecan.  A summary of the crop scenarios used to estimate
ADBAC concentrations in the aquatic systems for ecological risk
assessment are listed in Table 2.2, along with some characterization of
why the scenario was chosen.  

Table 2.2.  Summary of crop scenarios used in estimating EECs.

ADBAC Uses (EPA Reg. #)	Crop Scenario	MLRA/ Met Station	Scenario
Characterization 

Turf and golf courses (58044-3, 53642-1)	FL turf: Osceola County,

Adamsville sand	MLRA 156A;  W12834	Selected based on geographical
location, agricultural practices, and use patterns.  

	PA turf: York County,

Glenville silt loam	MLRA 148;  W14737

	Ornamental trees 

(58044-3, 53642-1, 507-3)	OR Xmas tree: Benton County, Pilchuck fine
sand	MLRA A2; W24232	Selected as a surrogate for ornamental trees in
Pacific northwest

	GA pecan: Mitchell County; Greenville fine sandy loam	MLRA 133A; W93805
Selected as a surrogate for ornamental trees in the southeast



  SEQ CHAPTER \h \r 1 PRZM/EXAMS modeling of ADBAC uses four PRZM
scenarios identified in Table 2.2 at the current maximum label rate,
maximum number of applications per year and the minimum application
interval of the ADBAC use represented by each scenario.  For the
turf/golf course uses application rates for use with a commercial
sprayer and for more limited residential use are both modeled at 0.8 and
6.8 lbs ai/A, respectively).  The maximum number of applications per
year is currently not specified on product labels for the turf/golf
course use.  Therefore a number of application scenarios, ranging from 1
application per year to 26 applications per year (Table 2.3), are
simulated to cover the range of possibilities.  Although, the label
specifies a maximum of 3 applications per year for the ornamentals use,
the minimum application interval is not specified.  A minimum
application interval of 7 days is assumed (Table 2.3).  The modeled
application rate for the ornamental use (302 lbs ai/A) assumes a tree
spacing of 6’ x 6’ and a maximum application of 60 gallons (0.25 lbs
a) per tree.  For both the ornamental and residential turf uses the
default 10 ha (25 A) field scenario is modeled in addition to a number
of smaller fields (10, 1, and 0.5 A) since it is possible that these
uses are limited in area and the default 25-A scenario may result in
unrealistically high exposure concentrations.     

Where applicable, modeling input parameters are selected according to
current guidance (Guidance for Selecting Input Parameters in Modeling
the Environmental Fate and Transport of Pesticides Version II, EFED,
February 28, 2002).  Application-specific and chemical-specific input
parameters for PRZM/EXAMS modeling are listed in Table 2.3 and Table
2.4, respectively.  All scenarios simulate aerial spray applications
(PRZM chemical application method, CAM = 2), with corresponding
application efficiency and drift fractions equal to 0.95 and 0.05,
respectively.  The condition for disposition of the pesticide remaining
on foliage after harvest (PRZM variable IPSCND) is set to 1 (pesticide
remaining on foliage is converted to surface application) for all uses
consistent with turf and nursery practices.  Application dates are
chosen based on the label information when available.

A soil organic carbon partitioning coefficient (Koc) of 2.7 x 106
L/kgoc, the mean of four soils, is used.  The aerobic soil metabolism is
assumed stable since there are no available guideline studies.  The
aquatic metabolism and aerobic aquatic metabolism are assumed stable as
indicated by the submitted guideline studies.  Since there is only one
study for the anaerobic aquatic metabolism, three times the half-life
was used to account for variability in the environment (5445 days).  The
hydrolysis half-life of 183 days is used since the ecological water body
is a constant pH 7.  

Table 2.3 PRZM/EXAMS application-specific input parameters.  

ADBAC Use(s) (EPA Reg. #)	PRZM scenarios	Maximum app. rate (lbs a.i./A)
No. of app.  per year/ interval (d)1	App. method 

drift/ app. efficiency	Application timing	First application date

Turf and golf courses (58044-3, 53642-1)	FL turf

PA turf	0.8	26/10

10/10

5/10

1	aerial spray

0.05/ 0.95	Warm growing season	June 1

Ornamental trees 

(58044-3, 53642-1, 507-3)	OR Xmas tree

GA Pecans	302	3/7	aerial spray

0.05/ 0.95	Not specified	May 10

1 Number of applications not specified on label for turf uses; four
scenarios considered: 26, 10, 5 and 1 application per year.  Minimum
interval between applications not specified on labels for ornamental
uses; a 7 day interval was assumed. 

Table 2.4 Chemical-specific PRZM/EXAMS inputs.

Parameter	Value	Source (MRID # or citation)	Comment

Soil Partition Coefficient (Koc mL/g)	2.7 x 106	MRID 424148-01	average
value

Aerobic Soil Metabolism Half-life (days)	0	no data	stable to aerobic
soil metabolism

Molecular Weight (g/mol)	368.05	Product chemistry

	Vapor Pressure (torr)	3.53 x 10-12	Product chemistry

	Henry’s Law Constant (atm-m3-mol)	7.76 x 10-13	Product chemistry

	Solubility in Water at 25oC (ppm)	184.4	Product chemistry	10X
solubility

Aerobic Aquatic Metabolism Half-life (days)	0	MRIDs 408356-04, 424149-01
stable to aerobic aquatic metabolism

Anaerobic Aquatic Metabolism Half-life (days)	5445	MRIDs 424151-01,
424150-02	one study: 3x 1,815 d

Hydrolysis Half-life @ pH 7 (days)	183	MRID 42242601	water body constant
pH 7

Aquatic Photolysis Half-life (days)	0	MRIDs 408356-03, 424152-01	stable
to aquatic photolysis

Foliar extraction	0.5	default

	Foliar decay rate	0	default	stable to foliar degradation



Simulated EECs for all scenarios are presented in Table 2.5.  Copies of
the input and output files are in Appendix A.  Acute EECs range from
0.67 - 1473 µg/L, 21-day chronic EECs range from 0.37 - 920 µg/L and
60-day average EECs range from 0.36 - 903 µg/L.

Table 2.5 Estimated Aquatic Exposure Concentrations Calculated with
PRZM/EXAMS.

ADBAC Uses/EPA Reg. #	Scenario	App. Rate (lbs ai/A)	# Apps.	Interval
Area treated (A)	Acute (g/L)	21-day Chronic (g/L)	60-day Chronic
(g/L)

Turf	FL turf	0.8*	26	10	25**	15.6	9.4	9.1



	10	10

6.0	3.6	3.5



	5	10

3.1	1.8	1.8



	1	--

0.67	0.37	0.36

Turf	PA turf	0.8*	26	10	25**	20.6	10.9	10.6



	10	10

7.8	4.2	4.1



	5	10

3.9	2.1	2.0



	1	--

0.80	0.43	0.41

Turf	Fl turf	6.8***	10	10	25**	49.2	26.5	25.5





	10	19.7	10.6	10.2





	1	1.97	1.06	1.02





	0.5	0.98	0.53	0.51

Turf	PA turf	6.8***	10	10	25**	62.5	30.3	29.3





	10	25.0	12.1	11.7





	1	2.50	1.21	1.17





	0.5	1.25	0.61	0.59

Ornamental	GA pecan	302**** 	3	7	25**	1473	920	903





	10	589	368	361





	1	58.9	36.8	36.1





	0.5	29.5	18.4	18.1

Ornamental	OR Christmas tree	302****	3	7	25**	557	361	339





	10	223	144	136





	1	22.3	14.4	13.6





	0.5	11.2	7.2	6.8

* Golf course tees, greens and fairways and commercial turf applications
 

** Standard default scenario, 10 ha field, 100% treated

*** Residential turf applications

**** Assumes 6’ x 6’ spacing of trees, 0.25 lbs ai/tree

2.2.2.2	Aquatic exposure monitoring data

No monitoring data are identified for either ADBAC or DDAC.

2.2.3	  SEQ CHAPTER \h \r 1 Terrestrial Exposure Assessment

	Application methods for ADBAC include spray and drench treatments of
individual plants and flats as well as turf spray.  Both ADBAC and DDAC
are labeled for direct application into small waterbodies, such as
puddles, ornamental ponds, old tires, etc.  The combination of many uses
and assorted application methods can potentially result in various
routes of non-target exposure to terrestrial organisms.  However, the
only use of DDAC is labeled for 5 ppm formulated product (3 ppm ai
DDAC).  

	The EEC values used for terrestrial exposure from direct application
are calculated using the TREX model (Version 1.2.3), and are derived
from the Kenaga nomograph, as modified by Fletcher et al. (1994), based
on a large set of actual field residue data. The upper limit values from
the nomograph represent the 95th percentile of residue values from
actual field measurements (Hoerger and Kenaga, 1972).  The Fletcher et
al. (1994) modifications to the Kenaga nomograph are based on measured
field residues from 249 published research papers, including information
on 118 species of plants, 121 pesticides, and 17 chemical classes. 
These modifications represent the 95th percentile of the expanded data
set.  Risk quotients are based on the most sensitive LC50 and NOAEC for
birds (in this instance, bobwhite quail) and LD50 for mammals (based on
lab rat studies).  Dietary EECs, unadjusted for organism type or size,
range from 42 ppm on fruits/pods/large insects for turf application,
five times per year at 10-day intervals to 180,814 ppm on short grass
for ornamental applications three times per year at 10-day intervals
(Table 2.6).  Since the labels do not limit the number of applications
for most uses, modeled exposure scenarios may not represent the most
conservative assumptions.  More scenarios are considered in the Risk
Description section of this document.

Table 2.6.  Unadjusted dietary-based EECs for two possible application
scenarios.

Use Pattern	Forage Item	Upper bound EEC (ppm)

Turf	Short Grass 	1062

0.8 lbs ai/A	Tall Grass 	487

26 applications/year	Broadleaf plants/sm insects	598

10 day interval	Fruits/pods/seeds/lg insects	66





Ornamentals	Short Grass 	180713

302 lbs ai/A	Tall Grass 	82827

3 applications/year	Broadleaf plants/sm insects	101651

10 day interval	Fruits/pods/seeds/lg insects	11295



Since direct application to small waterbodies is prescribed for some
uses, drinking water is likely to be a route of exposure for wildlife of
various sizes.  Therefore drinking water exposure is estimated using
allometric equations (Appendix C) from The Wildlife Exposure Factors
Handbook (USEPA 1994).  Because birds and mammals have different water
requirements, estimates of exposure are considered separately (Table
2.7).  The modeled concentrations are those resulting from initial
direct application of ADBAC/DDAC to small waterbodies according to the
labels.  Additionally, amphibians may be exposed at critical stages in
their lifecycle.  Exposure may be greater following subsequent
applications due to the persistence of the chemicals.  

Table 2.7.  Estimated exposure to total active ingredient to wildlife
through drinking water.

	Avian Daily Exposure Estimate (mg/kg-bw)

Concentration (ppm)	20g	100g	1000g

5* 	1.1	0.6	0.3

200	43	25	12

	Mammalian Daily Exposure Estimate (mg/kg-bw)

	15g	35g	1000g

5* 	0.8	0.7	0.5

200	30	28	20

*Formulation is 12% DDAC, 8% ADBAC

3	Ecotoxicity

The ecotoxicological endpoints used in this assessment are those used by
AD in their assessment.  The endpoints are summarized and briefly
described here.  Greater detail is provided in Appendix B.  Only ADBAC
is considered in this section, as DDAC endpoints were not provided. 
However, a previous EFED assessment of DDAC (  SEQ CHAPTER \h \r 1
Review of Data Submitted to Support the New Use of BARDAC MOLLUSCICIDE®
(Didecyl dimethyl ammonium chloride) for Salt Water Cooling Systems;  
SEQ CHAPTER \h \r 1 DP Barcode: D215429) suggests similar toxicity to
wildlife.  Nevertheless, the toxicity of DDAC remains an uncertainty in
this assessment.  As described in other parts of this document, wildlife
exposure to DDAC is expected to be limited.

3.1	Toxicity to Terrestrial Animals

3.1.1	Avian, Acute and Chronic

	An acute toxicity study was conducted with Bobwhite quail (Colinus
virginianus; MRID 428859-01).  The results of one acute oral toxicity
study, submitted for ADBAC established an LD50 of 136 mg/kg-bw.  The
results from the acceptable study indicate that ADBAC is moderately
toxic to avian species on an acute oral basis.  The study fulfills
guideline requirements.  No data are available to assess the toxicity of
ADBAC on a subacute dietary exposure basis though and this represents a
data gap.

	No data are available regarding the chronic toxicity of ADBAC to birds.
 Chronic risk to avian species cannot be precluded in the absence of
data; chronic risk to birds is presumed.

	

3.1.2	Mammals, Acute and Chronic Toxicity

The endpoints used in this risk assessment were chosen by AD and used
without details of the studies available.  The acute LD50 for rats
exposed to ADBAC is 430 mg/kg-bw (MRID 232269).  Based on these data,
ADBAC is classified as slightly toxic to mammals on an acute oral
exposure basis.  The NOAEL, from a chronic toxicity study with rats
(MRID 41947501), is 44 mg/kg/day (880 ppm).

3.2	Toxicity to Aquatic Animals

The Agency requested that aquatic toxicity studies be conducted with
ADBAC since, under typical use conditions, it may be introduced into the
aquatic environment.

3.2.1	Freshwater Fish, Acute

The most sensitive result from freshwater fish acute studies submitted
for ADBAC established an LC50 of 280 µg a.i./L (fathead minnow; MRID
437401-03).  The results indicate that ADBAC is highly toxic to on an
acute exposure basis.  

3.2.2	Freshwater Invertebrates, Acute

	An acceptable study (MRID 419472-03) with the freshwater invertebrate,
Daphnia magna, established an LC50 of 5.9 µg a.i./L.  Results of the
studies indicate that ADBAC is very highly toxic to freshwater
invertebrates on an acute exposure basis.  The guideline requirement has
been fulfilled.

3.2.3	Estuarine and Marine Organisms, Acute

	The most sensitive estuarine/marine fish to acute exposure to ADBAC was
the inland silverside (Menidia beryllina), selected from open literature
(Dobbs, M.G. et al., 1995), with an LC50 = 310 µg a.i./L.  The most
sensitive invertebrate was the Eastern oyster (Crassostrea virginica),
with an EC50  = 55 µg a.i./L (MRID 424795-03).

3.2.4	Aquatic Organisms, Chronic

The results from an early life stage study with the warmwater fathead
minnow (Pimephales promelas) indicate that exposure to ADBAC on a
chronic basis results in measurable effects at a concentration of 32.2
µg a.i./L (MRID 423021-02).  This study fulfills guideline requirements
for a fish early life stage chronic test (72-4(a)/OPPTS 850.1400).  In a
chronic study with the waterflea (Daphnia magna), no measurable effects
were noted at a concentration of 4.15 µg/L (MRID 423021-01).  However,
an MATC could not be determined in this study.  Therefore, the study was
classified as supplemental and does not fulfill guideline requirements
for an aquatic invertebrate life cycle test (72-4b/OPPTS 850.1300).  The
lack of chronic toxicity data on ADBAC represents a data gap.

No data on the chronic toxicity of ADBAC on estuarine/marine organisms
are available for this assessment.  The potential chronic toxicity of
ADBAC is uncertain; therefore, chronic toxicity is presumed.

	

3.2.5	Non-target Plants

		No data regarding the toxicity of ADBAC to non-target plants were
available for review.

4	Risk Characterization

4.1	Risk Estimation

	In a screening-level deterministic (point estimate) approach to
evaluating potential risk to non-target organisms from the proposed uses
of ADBAC, risk quotients (RQs) are calculated from the ratio of
estimated environmental concentrations (EECs) to ecotoxicity values. 
RQs are then compared to levels of concern (LOCs) used by OPP to
indicate potential risk to non-target organisms and the need to consider
regulatory action.  For studies on taxa where no effects are observed
(with no endpoint established), the highest dose tested is used in RQ
calculation.  As discussed in other sections, DDAC is not expected to
occur at biologically relevant concentrations in the environment when
applied according to the label directions, IF the toxicity of DDAC is
similar to ADBAC.  

Chronic risk to estuarine/marine organisms, chronic risk to birds and
risk to non-target plants cannot be estimated due to lack of data.  When
data are absent, risk to the organism in question in presumed.

Nursery Ornamentals

	Use of ADBAC on ornamentals can lead to wildlife exposure via direct
ingestion of contaminated food items, drift exposure to food items or
water sources, and through runoff to adjacent waterbodies.  Therefore,
exposure is possible to both aquatic and terrestrial organisms.  The
maximum label rate, calculated assuming a 6’ x 6’ spacing of trees,
is 302 lbs ai/A.  There are annual limits on some applications; some
applications have no annual limits.  It is beyond the scope of this
document to assess all possible exposure scenarios; therefore risk to
wildlife for this use may be underestimated. 

	Aquatic Risk	

	

	Acute RQs are calculated by dividing the peak EEC by the LC50/EC50 for
the most sensitive species tested.  Acute risk LOCs (0.5) are exceeded
by four- to 500-fold for both freshwater and estuarine/marine fish and
invertebrates for both scenarios modeled (Table 4.1.). The LOC for acute
risk to endangered species (RQ>0.05) is exceeded by factors as high as
5,000X.  

Table 4.1.  Acute RQs for aquatic organisms resulting from use of ADBAC
on nursery ornamentals at the maximum rate of 302 lb ai/A, applied three
times at seven day intervals, assuming entire 10-ha area is treated. 
All RQs exceed LOCs.

Scenario	FW fish	FW invert	Est/Mar fish	Est/Mar invert

GA pecan	5.26	249.66	4.75	26.78

OR Christmas tree	1.99	94.41	1.80	10.13



	Chronic RQs are calculated by dividing the 21-day EEC (for
invertebrates) or the 60-day EEC (for fish) by the LC50/EC50 for the
most sensitive species tested.  Chronic LOCs (1.0) are exceeded by 10-
to over 200-fold for freshwater organisms for both scenarios modeled
(Table 4.2).  Due to lack of data on the chronic toxicity of ADBAC to
estuarine/marine organisms, risk cannot be estimated and therefore
chronic risk to estuarine/marine organisms is presumed.

Table 4.2.  Chronic RQs for aquatic organisms resulting from use of
ADBAC on nursery ornamentals at the maximum rate of 302 lb ai/A, applied
three times at seven day intervals.  All RQs exceed LOCs.

Scenario	chronic FW fish	chronic FW invert	chronic Est/Mar fish	chronic
Est/Mar invert

GA pecan	28.04	221.69	unknown	unknown

OR Christmas tree	10.53	86.99	unknown	unknown



	Terrestrial Risk-Avian

	The avian acute LOC (0.5) is exceeded 38- to 4200-fold for all forage
items for all size birds (Table 4.3).  Chronic risk to birds cannot be
estimated due to lack of toxicity data.  In the absence of data, chronic
risk to birds is presumed.

Table 4.3.  Acute RQs for avian wildlife resulting from use of ADBAC on
nursery ornamentals at the maximum rate of 302 lb ai/A, applied three
times at 10 day intervals.

	20 g	100 g	1000 g

Short Grass	2101	941	298

Tall Grass	963	431	137

Broadleaf plants/sm insects	1182	529	168

Fruits/pods/seeds/lg insects	131	59	19

Exceeds acute risk LOC (0.5) 

Exceeds restricted use LOC (0.2)

Exceeds listed spp LOC (0.1)

	Terrestrial Risk-Mammalian

	The acute LOC (0.5) for mammals is exceeded 3- to 360-fold in all size
classes for all forage items.  The chronic LOC (1.0) is exceeded for
mammals in all size classes for all forage items 10- to 1780-fold (Table
4.4).

Table 4.4.  Acute and chronic dose-based RQs for mammalian wildlife
resulting from use of ADBAC on nursery ornamentals at the maximum rate
of 302 lb ai/A, applied three times at 10-day intervals.

	15 g mammal	35 g mammal	1000 g mammal









	Acute	Chronic	Acute   	Chronic	Acute   	Chronic

Short Grass 	182	1782	156	1522	83	816

Tall Grass	84	817	71	698	38	374

Broadleaf plants/sm insects	103	1002	88	856	47	459

Fruits/pods/lg insects	11	111	9.73	95	5.22	51

Seeds	2.5	25	2.2	21	1.2	11

Exceeds acute risk LOC (0.5) 

Exceeds restricted use LOC (0.2)

Exceeds listed spp LOC (0.1) or chronic risk LOC (1.0)

Turf and Golf Courses

	Use of ADBAC on turf and golf courses can lead to wildlife exposure via
direct ingestion of contaminated food items, drift exposure to food
items or water sources, and through runoff to adjacent waterbodies. 
Therefore, exposure is possible to both aquatic and terrestrial
organisms.  The maximum label rate for ground commercial power spray
application is 0.8 lbs ai/A.  A higher rate is allowed for
non-commercial sprayers (6.8 lbs ai/A) and is presumably intended for
smaller areas such as residential lawns.  

	Aquatic Risk	

	

	Acute RQs are calculated by dividing the peak EEC by the LC50/EC50 for
the most sensitive species tested.  Acute risk LOC (RQ>0.5) is exceeded
for freshwater invertebrates for both scenarios modeled (Table 4.5.),
and for estuarine/marine invertebrates for the higher rate.  The acute
risk to endangered species LOC (RQ>0.05) is exceeded for freshwater fish
in both scenarios and the restricted use LOC (0.1) is exceeded at the
higher rate for both freshwater and estuarine/marine fish.

Table 4.5.  Acute RQs for aquatic organisms resulting from use of ADBAC
on golf courses and turf applied 26 times at 10 day intervals for the
0.8 lbs ai/A rate and 10 times at 10 day intervals for the 6.8 lb ai/A
rate.

Scenario	FW fish	FW invert	Est/Mar fish	Est/Mar invert

FL turf (0.8 lbs ai/A)	0.06	2.64	0.05	0.28

PA turf (0.8 lbs ai/A)	0.07	3.49	0.07	0.37

FL turf (6.8 lbs ai/A)	0.18	8.34	0.16	0.89

PA turf (6.8 lbs ai/A)	0.22	10.59	0.20	1.14

Exceeds acute risk LOC (0.5) 

Exceeds restricted use LOC (0.1)

Exceeds listed spp LOC (0.05) or chronic risk LOC (1.0)

	Chronic LOCs (1.0) are exceeded for freshwater invertebrates for both
scenarios modeled and for freshwater fish at the higher application rate
(Table 4.6).  Due to lack of data on the chronic toxicity of ADBAC to
estuarine/marine organisms, risk cannot be estimated and is therefore
presumed.

Table 4.6.  Chronic RQs for aquatic organisms resulting from use of
ADBAC on golf courses and turf applied 26 times at 10 day intervals for
the 0.8 lbs ai/A rate and 10 times at 10 day intervals for the 6.8 lb
ai/A rate.

Scenario	FW fish	FW invert	Est/Mar fish	Est/Mar invert

FL turf (0.8 lbs ai/A)	0.28	2.27	unknown	unknown

PA turf (0.8 lbs ai/A)	0.33	2.63	unknown	unknown

FL turf (6.8 lbs ai/A)	0.79	6.39	unknown	unknown

PA turf (6.8 lbs ai/A)	0.91	7.30	unknown	unknown

Exceeds acute risk LOC (0.5) 

Exceeds restricted use LOC (0.1)

Exceeds listed spp LOC (0.05) or chronic risk LOC (1.0)

	Terrestrial Risk-Avian

	At the 0.8 lb ai/A rate, the avian acute risk LOC is exceeded for all
forage items for all size birds (Table 4.7), except for the 1000g size
class foraging on fruits/pods/large insects.  Chronic risk to birds
cannot be estimated due to lack of toxicity data.  In the absence of
data, chronic risk to birds is presumed.

Table 4.7.  Acute RQs for avian wildlife resulting from use of ADBAC on
nursery ornamentals at the maximum rate of 0.8 lb ai/A, applied 26 times
at 10 day intervals.

	20 g	100 g	1000 g

Short Grass	12.35	5.53	1.75

Tall Grass	5.66	2.54	0.80

Broadleaf plants/sm insects	6.95	3.11	0.99

Fruits/pods/seeds/lg insects	0.77	0.35	0.11

Exceeds acute risk LOC (0.5) 

Exceeds restricted use LOC (0.2)

Exceeds listed spp LOC (0.1)

At the 6.8 lb ai/A rate, the avian acute risk LOC is exceeded for all
forage items for all size birds (Table 4.8).  Chronic risk to birds
cannot be estimated due to lack of toxicity data.  In the absence of
data, chronic risk to birds is presumed.

Table 4.8.  Acute RQs for avian wildlife resulting from use of ADBAC on
lawns/turf at the maximum rate of 6.8 lb ai/A, applied 10 times at 10
day intervals.

	20 g	100 g	1000 g

Short Grass	91.02	40.77	12.92

Tall Grass	41.72	18.69	5.92

Broadleaf plants/sm insects	51.20	22.93	7.27

Fruits/pods/seeds/lg insects	5.69	2.55	0.81

Exceeds acute risk LOC (0.5) 

Exceeds restricted use LOC (0.2)

Exceeds listed spp LOC (0.1)

	Terrestrial Risk-Mammalian

	At the 0.8 lbs ai/A rate, the acute LOC is exceeded for mammals in the
15g and 35g size classes foraging on short grass and broadleaf
plants/small insects (Table 4.9).  The acute risk to endangered species
LOC is exceeded for all mammal size classes foraging on short grass,
tall grass and broadleaf plant/small insects.  The chronic risk LOC is
exceeded for all mammal size classes on the short grass, tall grass and
broadleaf plant/small insect forage items.

Table 4.9.  Acute and chronic dose-based RQs for mammalian wildlife
resulting from use of ADBAC on turf/golf courses at the maximum rate of
0.8 lb ai/A, applied 26 times at 10 day intervals.

	15 g mammal	35 g mammal	1000 g mammal









	Acute	Chronic	Acute   	Chronic	Acute   	Chronic

Short Grass 	1.07	10.47	0.92	8.95	0.49	4.80

Tall Grass	0.49	4.80	0.42	4.10	0.22	2.20

Broadleaf plants/sm insects	0.60	5.89	0.52	5.03	0.28	2.70

Fruits/pods/lg insects	0.07	0.65	0.06	0.56	0.03	0.30

Seeds	0.01	0.15	0.01	0.12	0.01	0.07

Exceeds acute risk LOC (0.5) 

Exceeds restricted use LOC (0.2)

Exceeds listed spp LOC (0.1) or chronic risk LOC (1.0)

	At the 6.8 lbs ai/A rate, the acute risk LOC is exceeded for mammals in
all size classes foraging on short grass, tall grass and broadleaf
plants/small insects (Table 4.10).  The acute risk to endangered species
LOC is exceeded for all mammal size classes foraging on short grass,
tall grass and broadleaf plant/small insects.  The chronic risk LOC is
exceeded for all mammal size classes foraging on any of the food items
evaluated, except medium and large size classes foraging on seeds.

Table 4.10.  Acute and chronic dose-based RQs for mammalian wildlife
resulting from use of ADBAC on nursery ornamentals at the maximum rate
of 6.8 lb ai/A, applied 10 times at 10 day intervals.

	15 g mammal	35 g mammal	1000 g mammal









	Acute	Chronic	Acute   	Chronic	Acute   	Chronic

Short Grass 	7.90	77.20	6.75	65.94	3.62	35.35

Tall Grass	3.62	35.38	3.09	30.22	1.66	16.20

Broadleaf plants/sm insects	4.44	43.42	3.80	37.09	2.03	19.88

Fruits/pods/lg insects	0.49	4.82	0.42	4.12	0.23	2.21

Seeds	0.11	1.1	0.09	0.92	0.05	0.49

Exceeds acute risk LOC (0.5) 

Exceeds restricted use LOC (0.2)

Exceeds listed spp LOC (0.1) or chronic risk LOC (1.0)

Mosquito control

	For mosquito control uses, drinking water is presumed to be the most
likely route of exposure to wildlife.  At the labeled rate of 200 ppm in
the target waterbody, RQs exceed the acute risk to endangered species
LOC for birds in the 20g and 100g size classes (Table 4.11.).  The
restricted use LOC (0.2) is exceeded for 20g birds.  Due to lack of data
on chronic toxicity of ADBAC to birds, chronic RQs cannot be calculated
and chronic effects are assumed.  Neither acute nor chronic mammalian
RQs are exceeded.  Equations are included in Appendix C.

	Since it is possible that amphibians would use many of the potentially
treated waterbodies for at least their reproductive stage, RQs were
calculated using the most sensitive freshwater fish endpoint.  Assuming
a concentration of 200 ppm, RQs were 0.71 for acute risk and 6.2 for
chronic risk, both of which exceed the LOCs.  It is possible that, due
to additional applications indicated on the label, concentrations
greater than 200 ppm may be attained.  In such instances, RQs would be
higher.

Table 4.11.  Wildlife drinking water RQs for ADBAC use in mosquito
control applications.

Birds	20g	100g	1000g

DWIRa	0.004	0.013	0.059

DPEb	42.91	25.23	11.80

RQc	0.32	0.19	0.09





	Mammals	15g	35g	1000g

DWIRa	0.002	0.005	0.099

DPEb	30.13	27.69	19.80

RQc	0.07	0.06	0.05





	aDWIR-drinking water ingestion rate (L/day)

bDPE-daily pesticide exposure (mg/kg-bw/day)

cRQ-risk quotient

Puddles, Ornamental Ponds and Pools

	For the of ADBAC/DDAC in puddles, ornamental ponds and pools, drinking
water is presumed to be the most likely route of exposure to terrestrial
wildlife.  At the labeled rate of 5 ppm in the target waterbody, acute
avian and mammalian RQs are all below 0.01, using toxicity endpoints
from ADBAC.  The acute risk LOC for terrestrial animals is 0.5 and the
acute endangered LOC is 0.1.  The RQs were calculated using the total
active ingredient.  The formulations for these applications are 12% DDAC
and 8% ADBAC.  Unless the wildlife endpoints for DDAC are more than 10
times more sensitive than for ADBAC, acute environmental risk from this
use appears to be unlikely.  Mammalian chronic risk quotients are also
all below the LOC of 1.0; chronic risk to birds cannot be estimated due
to lack of data.  Chronic risk to birds cannot be precluded.

	Since it is possible that amphibians would use many of the potentially
treated waterbodies for at least their reproductive stage, RQs were
calculated using the most sensitive freshwater fish endpoint.  Assuming
a concentration of 5 ppm, RQs were 0.02 for acute risk and 0.2 for
chronic risk, neither of which exceed the LOCs.  It is possible that,
due to additional applications indicated on the label, concentrations
greater than 5 ppm may be attained.  In such instances, RQs would be
higher.

4.2	Risk Description

	As presented in the previous section, LOCs are exceeded for several of
the outdoor uses of ADBAC.  The one outdoor use of DDAC appears to
result in low exposure to wildlife.  It is not possible to evaluate
whether this exposure results in risk to organisms due to the lack of
toxicity data.  However, DDAC toxicity would need to be considerably
greater than that of ADBAC to pose a risk to wildlife based on this
screening-level assessment, and further discussion of DDAC is not
warranted included in this document.  Risk from the various uses of
ADBAC, as estimated in the previous section, is highly dependant on the
assumption of the model.  In the risk estimation section, conservative
assumptions are used to provide a protective assessment.  Because the
labels for these uses are not explicitly directive, a variety of
assumptions were explored to give the risk manager a better sense of the
range of possible exposure, and therefore risk, to wildlife species
under the current labels.

Nursery Ornamentals

	

	This use has the highest application rates of any outdoor uses, and
subsequently results in the highest RQs.  Because the labels have no
restrictions on the amount of product applied per unit area per year,
several assumptions are made.  The RQs vary with differing assumptions. 
For this document, it is assumed that large- and medium-sized
shrubs/trees represent the greatest use of the products, that the trees
are treated with 0.25 lbs ai each, for each application.  Though the
concentration in ppm varies among tree/shrub, the volume needed for
adequate coverage is assumed to be less for smaller trees (higher
concentration), thus the 0.25 lbs ai/tree is used to calculate RQs. 
Many of the applications are limited to three per year, i.e., the number
used in the modeling.  It is possible that, in some instances, more
applications will be made.  It is also assumed that the shrubs/trees
were evenly spaced at 6’x6’; however, changing the spacing would
affect the maximum application rate (lbs ai/A).  

	Aquatic

	

	Aquatic RQs from nursery uses exceed the acute risk LOC for freshwater
fish by a factor of four to 10, and exceed the acute risk LOC for
estuarine marine fish by a similar magnitude.  The acute risk LOC is
exceeded by up to 500-fold for freshwater invertebrates, and up to
54-fold for estuarine/marine invertebrates.  Chronic risk LOCs for
freshwater organisms are exceeded factors ranging from 10 to over
200-fold.  While data on chronic toxicity to estuarine/marine organisms
were not available for review, the lines of evidence strongly suggest
potential chronic risk to these animals.  These RQs are based on EECs
derived from standard scenarios that assume 25 acres treated.  It may
not be realistic to assume 25 acres of treated shrubs and trees in a
given nursery are treated at the same time, so RQs assuming 10, one and
0.5 acres are also calculated (Table 4.12).  These adjustments assume a
linear relationship between EEC and area treated.  If only one acre were
treated, following the stated assumptions, the acute risk to endangered
species LOC would still be exceeded for fish in both PRZM/EXAMS
scenarios and the restricted use LOC would still be exceeded in the GA
pecan scenario.  The freshwater chronic risk LOC would still be exceeded
in the GA pecan scenario.  If only a half acre were treated, the
restricted use LOC would still be exceeded for fish in the GA pecan
scenario.  The freshwater invertebrate acute and chronic risk LOCs are
exceeded regardless of the size of the treated area.  The
estuarine/marine invertebrate acute risk LOC is exceeded for treated
areas of all sizes in the GA pecan scenario, and the restricted use LOC
is exceeded for treated areas of all sizes in the OR Christmas tree
scenario.

Table 4.12.  Aquatic RQs adjusted for area treated.

Scenarios	Area treated

(acres)	acute FW fish	chronic FW fish	acute FW invert	chronic FW invert
acute Est/Mar fish	acute Est/Mar invert

GA pecan	25	5.26	28.04	249.66	221.69	4.75	26.78

	10	2.10	11.21	99.83	88.67	1.90	10.71

	1	0.21	1.12	9.98	8.87	0.19	1.07

	0.5	0.11	.0.56	5.00	4.43	0.10	0.54

OR Christmas tree	25	1.99	10.53	94.41	86.99	1.80	10.13

	10	0.80	4.22	37.80	34.70	0.72	4.05

	1	0.08	0.42	3.78	3.47	0.07	0.41

	0.5	0.04	0.21	1.90	1.73	0.04	0.20

Exceeds acute risk LOC (0.5) 

Exceeds restricted use LOC (0.1)

Exceeds listed spp LOC (0.05) or chronic risk LOC (1.0)

	Terrestrial

	Acute avian RQs are exceeded from this use, by a minimum of 38-fold,
and both acute and chronic risk LOCs mammalian RQs are exceeded 10- to
1700-fold, and even a single application results in LOC exceedances
four- to 1400-fold.  Chronic RQs for birds cannot be calculated due to
lack of data and is therefore presumed.  The labels do make some effort
to minimize wildlife exposure, by limiting applications to before and
after fruit production, though the flowers and foliage would remain
potentially attractive forage.  Even at an application rate of one half
of one percent of the modeled rate (0.5%; 1.5 lbs ai/A), an amount less
than is typically modeled for off-site drift, there are exceedances for
almost all size classes and forage items for birds and most mammal size
categories.  It is presumed that nursery ornamentals are not intended to
present forage, and that efforts are made by operators to make the
plants unappealing to wildlife.  However, non-target plants may receive
unintentional exposure and may be used by wildlife as forage.  While the
areal extent of ADBAC application in nurseries is not known, these uses
may present a risk to wildlife in proximity to nurseries.

Turf and Golf Courses

	These uses have two considerably different maximum application rates. 
The type of sprayer used determines which maximum rate can be used.  For
commercial power sprayers, presumably used on golf course fairways and
larger commercial lawns, the label allows a rate of 0.8 lbs ai/A.  For
other sprayers, the labels allow a rate of 6.8 lbs ai/A.  The
distinction between these types of sprayers is not further delineated,
which presumably leaves interpretation to the applicator.

	Because the labels lack limits on the number of applications that can
be made per year, the scenarios presented in the Risk Estimation section
of this document represent high-end usage patterns, though not
necessarily the maximum allowable.  For example, the 0.8 lbs ai/A rate
is modeled assuming 26 applications at 10 day intervals, the minimum
allowable interval for this use on the label.  However, there could be
situations where 36 applications could occur, since there is no
restriction on the maximum number of applications.  Since many of the
target pathogens thrive in warm humid weather, applicators in areas with
such climatic conditions year round could choose to apply ADBAC at the
limit.  In such situations, the RQs for all wildlife would increase by
about 25%.  In areas where growth conditions for the target pathogens
are less ideal, fewer applications may be necessary, with an associated
decrease in the RQs for wildlife.

Aquatic

	As the number of applications decline, so do the aquatic RQs.  At 26
applications at the 0.8 lbs ai/A rate, acute RQs meet or exceed the
acute risk to endangered species LOC for freshwater and estuarine/marine
fish.  Applications of ten, five and one per year were also modeled
(Table 4.13) and the LOC is not exceeded.  The same pattern of
decreasing RQs is found for invertebrates, but exceedances are not fully
mitigated by limiting the number of applications.  Acute freshwater
invertebrate RQs remain above the acute risk LOC at five applications
and the acute risk to endangered species LOC is exceeded after a single
application.  Acute estuarine/marine RQs remain above the restricted use
LOC at after 10 applications, and above the acute risk to endangered
species LOC after five applications.

Table 4.13.  Acute and chronic RQs from different numbers of
applications per year, assuming a rate of 0.8 lbs ai/A over 25 acres.

Scenario	Number of App. 	acute FW fish	chronic FW fish	acute FW invert
chronic FW invert	acute Est/Mar fish	acute Est/Mar invert

FL turf	26	0.06	0.48	2.64	2.27	0.05	0.28

 	10	0.02	0.19	1.02	0.87	0.02	0.11

 	5	0.01	0.10	0.53	0.43	0.01	0.06

 	1	0.00	0.02	0.11	0.09	0.00	0.01

PA turf	26	0.07	0.64	3.49	2.63	0.07	0.37

 	10	0.03	0.24	1.32	1.01	0.03	0.14

 	5	0.01	0.12	0.66	0.51	0.01	0.07

 	1	0.00	0.02	0.14	0.10	0.00	0.01

Exceeds acute risk LOC (0.5) 

Exceeds restricted use LOC (0.1)

Exceeds listed spp LOC (0.05) or chronic risk LOC (1.0)

	At the 6.8 lbs ai/A rate, allowed by the label if the applicator is not
using ‘commercial power sprayers’, RQs exceed the restricted use and
chronic risk LOCs for fish and both the acute and chronic LOCs for
invertebrates.  These RQs are calculated assuming 10 applications per
year, though the label doesn’t limit the number of applications per
year.  Therefore, if additional applications are made, the RQs would be
higher.  However, there is uncertainty about how much area will actually
be treated at this rate.  Several different application areas are
modeled to explore the effect area treated would have on the RQs,
assuming a linear relationship between area applied and EEC (Table
4.14).  It is conceivable that aggregate use in a community could
approach 25 acres treated in a given area, and a half acre treated is
considered a reasonable low-end assumption.  Like the previous scenario,
RQs are greatest for aquatic invertebrates, where even at the smallest
treatment area, the restricted use LOC is exceeded.

Table 4.14.  Acute and chronic RQs from different size areas treated,
assuming a rate of 6.8 lbs ai/A and 10 applications per year.

Scenario	Acres treated 	acute FW fish	chronic FW fish	acute FW invert
chronic FW invert	acute Est/Mar fish	acute Est/Mar invert

FL turf	25	0.18	1.53	8.34	6.39	0.16	0.89

 	10	0.07	0.61	3.34	2.55	0.06	0.36

 	1	0.01	0.06	0.33	0.26	0.01	0.04

 	0.5	0.00	0.03	0.17	0.13	0.00	0.02

PA turf	25	0.22	1.94	10.59	7.30	0.20	1.14

 	10	0.09	0.78	4.24	2.92	0.08	0.45

 	1	0.01	0.08	0.42	0.29	0.01	0.05

 	0.5	0.00	0.04	0.21	0.15	0.00	0.02

Exceeds acute risk LOC (0.5) 

Exceeds restricted use LOC (0.1)

Exceeds listed spp LOC (0.05) or chronic risk LOC (1.0)

Terrestrial

The avian and mammalian model, TREX assumes wildlife is present and
foraging on the treated area; therefore no area adjustment is necessary.
 For these scenarios, drift is not considered for exposure; it would be
some fraction of the application rate but is not routinely considered in
screening-level assessments.  The terrestrial RQ values are based on
upper bound exposure estimates.  The mean exposure values are somewhat
lower; however, 50% of the time, exposure values would be expected to
exceed the means.  Where multiple applications are considered, the
default foliar half-life of 35 days is used.  If data were submitted to
show that the actual foliar half-life were shorter than the default
value, the RQs would be somewhat lower.

Avian

	While ADBAC is classified as moderately toxic to birds on an acute
exposure basis, the avian acute LOC was exceed by two- to 24-fold for
most forage items at the 0.8 lbs ai/A rate, assuming 26 applications at
10 day intervals.  The acute risk to endangered species LOC is exceeded
for all size birds foraging on all of the feed items evaluated.  Several
alternate numbers of applications are explored to see the effect on the
RQs (Table 4.15).  Reducing the number of applications to just one still
results in RQs exceeding the acute risk to endangered species LOC for
all categories except 100g and 1000g birds foraging on fruit/pods/large
insects.  Avian reproduction studies were not submitted for ADBAC,
therefore chronic avian risk cannot be assessed.  In the absence of
data, risk is presumed.  

Table 4.15.  Acute avian RQs resulting from different numbers of
applications pre year.

 	App rate	Number	Forage	Dose-based RQs

Use	lb ai/A	apps	Item(s)	20g	100g	1000g

Turf	0.8	10	short grass	10.71	4.80	1.52

 	 	 	tall grass	4.91	2.20	0.70

 	 	 	bdlf/sm ins	6.02	2.70	0.86

 	 	 	Fr/pods/lg ins	0.67	0.30	0.10

 	 	5	short grass	7.81	3.50	1.11

 	 	 	tall grass	3.58	1.60	0.51

 	 	 	bdlf/sm ins	4.39	1.97	0.62

 	 	 	Fr/pods/lg ins	0.49	0.22	0.07

 	 	1	short grass	2.23	1.00	0.32

 	 	 	tall grass	1.02	0.46	0.15

 	 	 	bdlf/sm ins	1.26	0.56	0.18

 	 	 	Fr/pods/lg ins	0.14	0.06	0.02

Exceeds acute risk LOC (0.5) 

Exceeds restricted use LOC (0.2)

Exceeds listed spp LOC (0.1) 

	

	For the 6.8 lbs ai/A application rate, at the assumed 10 applications
per year at 10 day intervals, the acute risk LOC is exceeded for all
size birds for all forage items.  Since the label does not limit the
number of applications, these RQs may not be indicative of actual risk,
as more applications would increase the RQ values.  To establish a
base-line, one application is modeled at this rate (Table 4.16).  One
application of ADBAC at the label rate of 6.8 lbs ai/A results in
exceedances of the acute risk LOC for all forage items and all size
birds, except 1000g birds foraging on fruits/pods/large insects.  That
exception still exceeds the acute risk to endangered species LOC though.
 While RQs cannot be calculated for chronic risk to birds, chronic risk
is presumed.

Table 4.16.  Acute RQs for avian wildlife resulting from use of ADBAC on
lawns/turf at the maximum rate of 6.8 lb ai/A, applied once per year.

	20 g	100 g	1000 g

Short Grass	18.97	8.50	2.69

Tall Grass	8.69	3.89	1.23

Broadleaf plants/sm insects	10.67	4.78	1.51

Fruits/pods/seeds/lg insects	1.19	0.53	0.17

Exceeds acute risk LOC (0.5) 

Exceeds restricted use LOC (0.2)

Exceeds listed spp LOC (0.1)

Mammals

	As seen in the Risk Estimation section of this document, there are
acute and chronic risk LOC exceedances for all size classes and most
forage items when the 0.8 lbs ai/A rate is modeled assuming 26
applications at 10 day intervals.  Again, since it possible to have more
than 26 applications in a given year, those RQs are not entirely
conservative.  However, to provide a sense of perspective, RQs resulting
from a single application are modeled (Table 4.17).  One application
results in acute risk to endangered species LOC exceedances for 15g and
35g mammals foraging on short grass, 15g mammals foraging on broadleaf
plants/small insects; additionally, the chronic risk LOC is exceeded for
those same categories.  Given the nature of the target pathogens, it
does not seem likely that one application would be sufficient to achieve
control.  Therefore, five applications at 10 day intervals are also
modeled (Table. 4.18).  Resulting RQs increase approximately three-fold
and many more LOCs are exceeded.  The typical number of applications at
this rate is unknown for these products.

Table 4.17.  Acute and chronic dose-based RQs for mammalian wildlife
resulting from use of ADBAC on turf/golf courses at the maximum rate of
0.8 lb ai/A, applied once (exceedances in bold).

	15 g mammal	35 g mammal	1000 g mammal









	Acute	Chronic	Acute   	Chronic	Acute   	Chronic

Short Grass 	0.19	1.89	0.17	1.62	0.09	0.87

Tall Grass	0.09	0.87	0.08	0.74	0.04	0.40

Broadleaf plants/sm insects	0.11	1.06	0.09	0.91	0.05	0.49

Fruits/pods/lg insects	0.01	0.12	0.01	0.10	0.01	0.05

Exceeds acute risk LOC (0.5) 

Exceeds restricted use LOC (0.2)

Exceeds listed spp LOC (0.1)

Table 4.18.  Acute and chronic dose-based RQs for mammalian wildlife
resulting from use of ADBAC on turf/golf courses at the maximum rate of
0.8 lb ai/A, applied five times with a 10 day interval.

	15 g mammal	35 g mammal	1000 g mammal









	Acute	Chronic	Acute   	Chronic	Acute   	Chronic

Short Grass 	0.68	6.62	0.58	5.66	0.31	3.03

Tall Grass	0.31	3.04	0.27	2.59	0.14	1.39

Broadleaf plants/sm insects	0.38	3.72	0.33	3.18	0.17	1.71

Fruits/pods/lg insects	0.04	0.41	0.04	0.35	0.02	0.19

Exceeds acute risk LOC (0.5) 

Exceeds restricted use LOC (0.2)

Exceeds listed spp LOC (0.1)

	At the higher application rate (6.8 lbs ai/A), the acute risk LOC is
exceeded four- to 16-fold for all size class mammals foraging on short
grass, tall grass and broadleaf plants/small insects.  The restricted
use LOC is exceeded for all size classes foraging on fruits/pods/large
insects.  The chronic risk LOC is exceeded for all size classes and
forage items.  These exceedances result from 10 applications at 10 day
intervals.  However, if only five applications are made, there would
still be exceedances of acute and chronic LOCs for all forage items and
all size classes.  In fact, at the 6.8 lbs ai/A rate, there would still
be acute, restricted use and acute risk to endangered species LOC
exceedances for all categories except the 35g and 1000g size classes
foraging on fruits/pods/large insects.  Chronic RQs would also exceed
the LOC in the same categories.

Mosquito control

Since ADBAC is applied directly to target waterbodies, disconnected from
the greater watershed, limited exposure to non-target aquatic wildlife
is expected; however, ephemeral pools and ornamental ponds often play an
important role in the lifecycle of amphibians.  The label does not
preclude potential exposure to these organisms and therefore these uses
may pose a significant risk to amphibians.  EFED uses freshwater fish as
surrogate for aquatic-phase amphibians.  At the initial concentration of
200 ppm, the acute RQ would be 0.71, which exceeds LOC.  The chronic RQ,
based on a concentration of 200 ppm would be 6.1, which also exceeds the
LOC.  

As stated previously, drinking water is presumed to be the most likely
route of exposure to terrestrial wildlife from these uses.  Terrestrial
wildlife exposure via forage items is also expected to be low, due to
the application method and the limited scale of the target waterbody. 
Estimated exposure via drinking water is based on allometric equations,
specific to birds and mammals (Appendix C), that are used to calculate
daily pesticide exposure, assuming the animal gets 100% of its water
from the treated water.  However, it is possible that to small (15-g)
mammals feeding on short grasses, an ephemeral pond could represent a
sizable area in which to forage.  Grasses may preferentially grow along
or within these areas and attract these animals.

At the labeled rate of 200 ppm in the target waterbody, RQs exceed the
acute risk to endangered species LOC for birds in the 20g and 100 g size
classes.  The restricted use LOC is exceeded for 20g birds.  An increase
in concentration to 220 ppm in the drinking water source would elevate
the RQ for 1000g birds above the acute risk to endangered species LOC. 
Due to lack of data on chronic toxicity of ADBAC to birds, chronic RQs
cannot be calculated and chronic risk is assumed.  

Neither acute nor chronic mammalian RQs are exceeded at 200 ppm.  The
acute RQ for 15g mammals would exceed the acute risk to endangered
species LOC at a concentration of 280 ppm.  The acute RQs for mammals of
all size classes exceed the acute risk to endangered species LOC at a
concentration of 450 ppm, though at this concentration, restricted use
LOC is not exceeded.  The chronic risk LOC for 15g mammals would be
exceeded at a concentration of 300 ppm and exceeded for mammals of all
size classes at a concentration of 450 ppm.  

The fate of the initial concentrations of ADBAC is unknown, and
therefore subsequent weekly ‘maintenance’ applications of 100 ppm
may result in cumulative concentration greater than the initial 200 ppm.
 If each application were wholly cumulative (i.e. no dissipation), the
concentration in any given treated waterbody after five weeks would be
600 ppm.  The likelihood of reaching these concentrations from these
labeled uses is not known; it is clear that at such a concentration,
calculable RQs would exceed LOCs for wildlife many-fold.

The labels should state specific limitations, such as size of target
waterbodies and application timing, which could mitigate potential
exposure to non-target organisms.  Due to the lack of explicit
limitations on the labels, risk to non-target organisms may be
under-estimated in this assessment.

Puddles, Ornamental Ponds and Pools

	The risk to terrestrial wildlife from this use appears to be minimal,
based on the initial target concentration of 5 ppm.  Calculable RQs all
fall below 0.01, and the most conservative LOC for terrestrial animals
is 0.1, for threatened and endangered species.  Exposure to fish and
non-target populations of aquatic invertebrates is likely to be minimal,
based on label descriptions; specific limitations in number of
applications and size of target waterbody should be stated on the
labels.  However, ephemeral waterbodies play an important role in the
lifecycle of amphibians.  The label does not preclude potential exposure
to these organisms and therefore these uses may pose a risk to
amphibians.  EFED uses freshwater fish as surrogate for aquatic-phase
amphibians.  At the initial concentration of 5 ppm, both the acute and
chronic RQs are well below the LOCs.  The acute listed species LOC is
exceeded at 15 ppm and the chronic LOC is exceeded at 35 ppm.  Thus,
multiple applications, as allowed by the label, may result in acute
and/or chronic risk to listed amphibians.

Since this use is the only one identified as of concern to EFED
containing DDAC, it appears that ADBAC and DDAC are of low concern for
terrestrial wildlife exposure for these uses.  DDAC would be of concern
if avian or mammalian endpoints were significantly more sensitive (>10X)
than for ADBAC; however, since toxicity of DDAC is unavailable for this
assessment, potential risk due to DDAC remains an uncertainty.  This use
would also be of concern if concentrations in target waterbodies
increase due to repeated applications.

The fate of the initial applications of ADBAC and DDAC is unknown. 
Since the label allows weekly application of 2.5 ppm, after the initial
5 ppm application, it is possible a cumulative concentration of greater
than 5 ppm may occur.  If each application were cumulative (i.e. no
dissipation), the concentration in any given treated waterbody after
five weeks would be 20 ppm.  The LOC for listed mammals in the 15g size
class is exceeded at concentrations greater than 280 ppm and for listed
birds in the 20g size class at >65 ppm.  The likelihood of reaching
these concentrations from these labeled uses it uncertain; however,
given the chemical’s persistence and immobility, it is likely that
concentrations would increase with repeatedly applications. 

	Additionally, the lack of data on the chronic toxicity of ADBAC and
DDAC on birds makes quantified chronic risk estimation impossible

5	Threatened and Endangered Species Concerns

5.1	  SEQ CHAPTER \h \r 1 Action Area

For listed species assessment purposes, the action area is considered to
be the area affected directly or indirectly by the Federal action and
not merely the immediate area involved in the action.  At the initial
screening-level, the risk assessment considers broadly described
taxonomic groups and so conservatively assumes that listed species
within those broad groups are co-located with the pesticide treatment
area.  This means that terrestrial plants and wildlife are assumed to be
located on or adjacent to the treated site and aquatic organisms are
assumed to be located in a surface water body adjacent to the treated
site.  The assessment also assumes that the listed species are located
within an assumed area that has the relatively highest potential
exposure to the pesticide, and that exposures are likely to decrease
with distance from the treatment area. 

	If the assumptions associated with the screening-level action area
result in RQs that are below the listed species LOCs, a "no effect"
determination conclusion is made with respect to listed species in that
taxa, and no further refinement of the action area is necessary. 
Furthermore, RQs below the listed species LOCs for a given taxonomic
group indicate no concern for indirect effects upon listed species that
depend upon the taxonomic group covered by the RQ as a resource. 
However, in situations where the screening assumptions lead to RQs in
excess of the listed species LOCs for a given taxonomic group, a
potential for a "may affect" conclusion exists and may be associated
with direct effects on listed species belonging to that taxonomic group
or may extend to indirect effects upon listed species that depend upon
that taxonomic group as a resource.  In such cases, additional
information on the biology of listed species, the locations of these
species, and the locations of use sites could be considered to determine
the extent to which screening assumptions regarding an action area apply
to a particular listed organism.  These subsequent refinement steps
could consider how this information would impact the action area for a
particular listed organism and may potentially include areas of exposure
that are downwind and downstream of the pesticide use site.

5.2	Taxonomic Groups Potentially at Risk

	  SEQ CHAPTER \h \r 1 Based on available screening level information,
it is possible that ADBAC may have acute and/or chronic toxic effects on
endangered or threatened aquatic or terrestrial organisms.    SEQ
CHAPTER \h \r 1 Should estimated exposure levels occur in proximity to
listed resources, the available screening level information suggests a
potential concern for effects on some listed species associated with the
outdoor use of ADBAC.  This screening assessment is based on the initial
assumption that listed species within the taxonomic groups of concern
are actually present in areas for which the estimated exposure levels
used for RQ calculation can be expected to occur.  A specific
determination of “may affect” for any RQ in excess of listed species
LOCs cannot be made without further refinement of the co-occurrence of
listed species in ADBAC use areas.

The LOCATES database was used to identify those U.S. counties that have
nurseries and have Federally listed endangered or threatened species.  A
count summary of listed taxa that have been known to occur in those
areas is presented in Appendix D, by State.  Further refinements to the
risk assessment must be made for the Agency to be in compliance with the
Endangered Species Act and to determine the need for consultation with
the Services.  There is no general scenario for determining the
co-occurrence of turf or golf courses with listed species.

Appendix A. PRZM/EXAMS Input Files

FL Turf (0.8 lbs ai/A; 26 applications/year)

Inputs generated by pe4.pl - 8-August-2003

Data used for this run:

Output File: FLturf26

Metfile:	w12834.dvf

PRZM scenario:	FLturfC.txt

EXAMS environment file:	pond298.exv

Chemical Name:	ADBAC

Description	Variable Name	Value	Units	Comments

Molecular weight	mwt	368.05	g/mol

Henry's Law Const.	henry	7.76e-13	atm-m^3/mol

Vapor Pressure	vapr	3.53e-12	torr

Solubility	sol	184.4	mg/L

Kd	Kd		mg/L

Koc	Koc	2.7e6	mg/L

Photolysis half-life	kdp	0	days	Half-life

Aerobic Aquatic Metabolism	kbacw	0	days	Halfife

Anaerobic Aquatic Metabolism	kbacs	5445	days	Halfife

Aerobic Soil Metabolism	asm	0	days	Halfife

Hydrolysis:	pH 7	183	days	Half-life

Method:	CAM	2	integer	See PRZM manual

Incorporation Depth:	DEPI		cm

Application Rate:	TAPP	0.9	kg/ha

Application Efficiency:	APPEFF	.95	fraction

Spray Drift	DRFT	.05	fraction of application rate applied to pond

Application Date	Date	2-1	dd/mm or dd/mmm or dd-mm or dd-mmm

Interval 1	interval	10	days	Set to 0 or delete line for single app.

Interval 2	interval	10	days	Set to 0 or delete line for single app.

Interval 3	interval	10	days	Set to 0 or delete line for single app.

Interval 4	interval	10	days	Set to 0 or delete line for single app.

Interval 5	interval	10	days	Set to 0 or delete line for single app.

Interval 6	interval	10	days	Set to 0 or delete line for single app.

Interval 7	interval	10	days	Set to 0 or delete line for single app.

Interval 8	interval	10	days	Set to 0 or delete line for single app.

Interval 9	interval	10	days	Set to 0 or delete line for single app.

Interval 10	interval	10	days	Set to 0 or delete line for single app.

Interval 11	interval	10	days	Set to 0 or delete line for single app.

Interval 12	interval	10	days	Set to 0 or delete line for single app.

Interval 13	interval	10	days	Set to 0 or delete line for single app.

Interval 14	interval	10	days	Set to 0 or delete line for single app.

Interval 15	interval	10	days	Set to 0 or delete line for single app.

Interval 16	interval	10	days	Set to 0 or delete line for single app.

Interval 17	interval	10	days	Set to 0 or delete line for single app.

Interval 18	interval	10	days	Set to 0 or delete line for single app.

Interval 19	interval	10	days	Set to 0 or delete line for single app.

Interval 20	interval	10	days	Set to 0 or delete line for single app.

Interval 21	interval	10	days	Set to 0 or delete line for single app.

Interval 22	interval	10	days	Set to 0 or delete line for single app.

Interval 23	interval	10	days	Set to 0 or delete line for single app.

Interval 24	interval	10	days	Set to 0 or delete line for single app.

Interval 25	interval	10	days	Set to 0 or delete line for single app.

Record 17:	FILTRA	

	IPSCND	1

	UPTKF	

Record 18:	PLVKRT	

	PLDKRT	

	FEXTRC	0.5

Flag for Index Res. Run	IR	Pond

Flag for runoff calc.	RUNOFF	none	none, monthly or total(average of
entire run)

FL Turf (0.8 lbs ai/A; 10 applications/year)

Inputs generated by pe4.pl - 8-August-2003

Data used for this run:

Output File: FLturf10

Metfile:	w12834.dvf

PRZM scenario:	FLturfC.txt

EXAMS environment file:	pond298.exv

Chemical Name:	ADBAC

Description	Variable Name	Value	Units	Comments

Molecular weight	mwt	368.05	g/mol

Henry's Law Const.	henry	7.76e-13	atm-m^3/mol

Vapor Pressure	vapr	3.53e-12	torr

Solubility	sol	184.4	mg/L

Kd	Kd		mg/L

Koc	Koc	2.7e6	mg/L

Photolysis half-life	kdp	0	days	Half-life

Aerobic Aquatic Metabolism	kbacw	0	days	Halfife

Anaerobic Aquatic Metabolism	kbacs	5445	days	Halfife

Aerobic Soil Metabolism	asm	0	days	Halfife

Hydrolysis:	pH 7	183	days	Half-life

Method:	CAM	2	integer	See PRZM manual

Incorporation Depth:	DEPI		cm

Application Rate:	TAPP	0.9	kg/ha

Application Efficiency:	APPEFF	.95	fraction

Spray Drift	DRFT	.05	fraction of application rate applied to pond

Application Date	Date	1-4	dd/mm or dd/mmm or dd-mm or dd-mmm

Interval 1	interval	10	days	Set to 0 or delete line for single app.

Interval 2	interval	10	days	Set to 0 or delete line for single app.

Interval 3	interval	10	days	Set to 0 or delete line for single app.

Interval 4	interval	10	days	Set to 0 or delete line for single app.

Interval 5	interval	10	days	Set to 0 or delete line for single app.

Interval 6	interval	10	days	Set to 0 or delete line for single app.

Interval 7	interval	10	days	Set to 0 or delete line for single app.

Interval 8	interval	10	days	Set to 0 or delete line for single app.

Interval 9	interval	10	days	Set to 0 or delete line for single app.

Record 17:	FILTRA	

	IPSCND	1

	UPTKF	

Record 18:	PLVKRT	

	PLDKRT	

	FEXTRC	0.5

Flag for Index Res. Run	IR	Pond

Flag for runoff calc.	RUNOFF	none	none, monthly or total(average of
entire run)

FL Turf (0.8 lbs ai/A; 5 applications/year)

Inputs generated by pe4.pl - 8-August-2003

Data used for this run:

Output File: FLturf5

Metfile:	w12834.dvf

PRZM scenario:	FLturfC.txt

EXAMS environment file:	pond298.exv

Chemical Name:	ADBAC

Description	Variable Name	Value	Units	Comments

Molecular weight	mwt	368.05	g/mol

Henry's Law Const.	henry	7.76e-13	atm-m^3/mol

Vapor Pressure	vapr	3.53e-12	torr

Solubility	sol	184.4	mg/L

Kd	Kd		mg/L

Koc	Koc	2.7e6	mg/L

Photolysis half-life	kdp	0	days	Half-life

Aerobic Aquatic Metabolism	kbacw	0	days	Halfife

Anaerobic Aquatic Metabolism	kbacs	5445	days	Halfife

Aerobic Soil Metabolism	asm	0	days	Halfife

Hydrolysis:	pH 7	183	days	Half-life

Method:	CAM	2	integer	See PRZM manual

Incorporation Depth:	DEPI		cm

Application Rate:	TAPP	0.9	kg/ha

Application Efficiency:	APPEFF	.95	fraction

Spray Drift	DRFT	.05	fraction of application rate applied to pond

Application Date	Date	1-4	dd/mm or dd/mmm or dd-mm or dd-mmm

Interval 1	interval	10	days	Set to 0 or delete line for single app.

Interval 2	interval	10	days	Set to 0 or delete line for single app.

Interval 3	interval	10	days	Set to 0 or delete line for single app.

Interval 4	interval	10	days	Set to 0 or delete line for single app.

Record 17:	FILTRA	

	IPSCND	1

	UPTKF	

Record 18:	PLVKRT	

	PLDKRT	

	FEXTRC	0.5

Flag for Index Res. Run	IR	Pond

Flag for runoff calc.	RUNOFF	none	none, monthly or total(average of
entire run)

FL Turf (0.8 lbs ai/A; 1 applications/year)

Inputs generated by pe4.pl - 8-August-2003

Data used for this run:

Output File: FLturf1

Metfile:	w12834.dvf

PRZM scenario:	FLturfC.txt

EXAMS environment file:	pond298.exv

Chemical Name:	ADBAC

Description	Variable Name	Value	Units	Comments

Molecular weight	mwt	368.05	g/mol

Henry's Law Const.	henry	7.76e-13	atm-m^3/mol

Vapor Pressure	vapr	3.53e-12	torr

Solubility	sol	184.4	mg/L

Kd	Kd		mg/L

Koc	Koc	2.7e6	mg/L

Photolysis half-life	kdp	0	days	Half-life

Aerobic Aquatic Metabolism	kbacw	0	days	Halfife

Anaerobic Aquatic Metabolism	kbacs	5445	days	Halfife

Aerobic Soil Metabolism	asm	0	days	Halfife

Hydrolysis:	pH 7	183	days	Half-life

Method:	CAM	2	integer	See PRZM manual

Incorporation Depth:	DEPI		cm

Application Rate:	TAPP	0.9	kg/ha

Application Efficiency:	APPEFF	.95	fraction

Spray Drift	DRFT	.05	fraction of application rate applied to pond

Application Date	Date	1-4	dd/mm or dd/mmm or dd-mm or dd-mmm

Record 17:	FILTRA	

	IPSCND	1

	UPTKF	

Record 18:	PLVKRT	

	PLDKRT	

	FEXTRC	0.5

Flag for Index Res. Run	IR	Pond

Flag for runoff calc.	RUNOFF	none	none, monthly or total(average of
entire run)

FL Turf (6.8 lbs ai/A; 10 applications/year)

Inputs generated by pe4.pl - 8-August-2003

Data used for this run:

Output File: FLturfRES

Metfile:	w12834.dvf

PRZM scenario:	FLturfC.txt

EXAMS environment file:	pond298.exv

Chemical Name:	ADBAC

Description	Variable Name	Value	Units	Comments

Molecular weight	mwt	368.05	g/mol

Henry's Law Const.	henry	7.76e-13	atm-m^3/mol

Vapor Pressure	vapr	3.53e-12	torr

Solubility	sol	184.4	mg/L

Kd	Kd		mg/L

Koc	Koc	2.7e6	mg/L

Photolysis half-life	kdp	0	days	Half-life

Aerobic Aquatic Metabolism	kbacw	0	days	Halfife

Anaerobic Aquatic Metabolism	kbacs	5445	days	Halfife

Aerobic Soil Metabolism	asm	0	days	Halfife

Hydrolysis:	pH 7	183	days	Half-life

Method:	CAM	2	integer	See PRZM manual

Incorporation Depth:	DEPI		cm

Application Rate:	TAPP	7.62	kg/ha

Application Efficiency:	APPEFF	.99	fraction

Spray Drift	DRFT	.01	fraction of application rate applied to pond

Application Date	Date	1-4	dd/mm or dd/mmm or dd-mm or dd-mmm

Interval 1	interval	10	days	Set to 0 or delete line for single app.

Interval 2	interval	10	days	Set to 0 or delete line for single app.

Interval 3	interval	10	days	Set to 0 or delete line for single app.

Interval 4	interval	10	days	Set to 0 or delete line for single app.

Interval 5	interval	10	days	Set to 0 or delete line for single app.

Interval 6	interval	10	days	Set to 0 or delete line for single app.

Interval 7	interval	10	days	Set to 0 or delete line for single app.

Interval 8	interval	10	days	Set to 0 or delete line for single app.

Interval 9	interval	10	days	Set to 0 or delete line for single app.

Record 17:	FILTRA	

	IPSCND	1

	UPTKF	

Record 18:	PLVKRT	

	PLDKRT	

	FEXTRC	0.5

Flag for Index Res. Run	IR	Pond

Flag for runoff calc.	RUNOFF	none	none, monthly or total(average of
entire run)

PA Turf (0.8 lbs ai/A; 26 applications/year)

Inputs generated by pe4.pl - 8-August-2003

Data used for this run:

Output File: PAturf26

Metfile:	w14737.dvf

PRZM scenario:	PAturfC.txt

EXAMS environment file:	pond298.exv

Chemical Name:	ADBAC

Description	Variable Name	Value	Units	Comments

Molecular weight	mwt	368.05	g/mol

Henry's Law Const.	henry	7.76e-13	atm-m^3/mol

Vapor Pressure	vapr	3.53e-12	torr

Solubility	sol	184.4	mg/L

Kd	Kd		mg/L

Koc	Koc	2.7e6	mg/L

Photolysis half-life	kdp	0	days	Half-life

Aerobic Aquatic Metabolism	kbacw	0	days	Halfife

Anaerobic Aquatic Metabolism	kbacs	5445	days	Halfife

Aerobic Soil Metabolism	asm	0	days	Halfife

Hydrolysis:	pH 7	183	days	Half-life

Method:	CAM	2	integer	See PRZM manual

Incorporation Depth:	DEPI		cm

Application Rate:	TAPP	0.9	kg/ha

Application Efficiency:	APPEFF	.95	fraction

Spray Drift	DRFT	.05	fraction of application rate applied to pond

Application Date	Date	2-1	dd/mm or dd/mmm or dd-mm or dd-mmm

Interval 1	interval	10	days	Set to 0 or delete line for single app.

Interval 2	interval	10	days	Set to 0 or delete line for single app.

Interval 3	interval	10	days	Set to 0 or delete line for single app.

Interval 4	interval	10	days	Set to 0 or delete line for single app.

Interval 5	interval	10	days	Set to 0 or delete line for single app.

Interval 6	interval	10	days	Set to 0 or delete line for single app.

Interval 7	interval	10	days	Set to 0 or delete line for single app.

Interval 8	interval	10	days	Set to 0 or delete line for single app.

Interval 9	interval	10	days	Set to 0 or delete line for single app.

Interval 10	interval	10	days	Set to 0 or delete line for single app.

Interval 11	interval	10	days	Set to 0 or delete line for single app.

Interval 12	interval	10	days	Set to 0 or delete line for single app.

Interval 13	interval	10	days	Set to 0 or delete line for single app.

Interval 14	interval	10	days	Set to 0 or delete line for single app.

Interval 15	interval	10	days	Set to 0 or delete line for single app.

Interval 16	interval	10	days	Set to 0 or delete line for single app.

Interval 17	interval	10	days	Set to 0 or delete line for single app.

Interval 18	interval	10	days	Set to 0 or delete line for single app.

Interval 19	interval	10	days	Set to 0 or delete line for single app.

Interval 20	interval	10	days	Set to 0 or delete line for single app.

Interval 21	interval	10	days	Set to 0 or delete line for single app.

Interval 22	interval	10	days	Set to 0 or delete line for single app.

Interval 23	interval	10	days	Set to 0 or delete line for single app.

Interval 24	interval	10	days	Set to 0 or delete line for single app.

Interval 25	interval	10	days	Set to 0 or delete line for single app.

Record 17:	FILTRA	

	IPSCND	1

	UPTKF	

Record 18:	PLVKRT	

	PLDKRT	

	FEXTRC	0.5

Flag for Index Res. Run	IR	Pond

Flag for runoff calc.	RUNOFF	none	none, monthly or total(average of
entire run)

PA Turf (0.8 lbs ai/A; 10 applications/year)

Inputs generated by pe4.pl - 8-August-2003

Data used for this run:

Output File: PAturf10

Metfile:	w14737.dvf

PRZM scenario:	PAturfC.txt

EXAMS environment file:	pond298.exv

Chemical Name:	ADBAC

Description	Variable Name	Value	Units	Comments

Molecular weight	mwt	368.05	g/mol

Henry's Law Const.	henry	7.76e-13	atm-m^3/mol

Vapor Pressure	vapr	3.53e-12	torr

Solubility	sol	184.4	mg/L

Kd	Kd		mg/L

Koc	Koc	2.7e6	mg/L

Photolysis half-life	kdp	0	days	Half-life

Aerobic Aquatic Metabolism	kbacw	0	days	Halfife

Anaerobic Aquatic Metabolism	kbacs	5445	days	Halfife

Aerobic Soil Metabolism	asm	0	days	Halfife

Hydrolysis:	pH 7	183	days	Half-life

Method:	CAM	2	integer	See PRZM manual

Incorporation Depth:	DEPI		cm

Application Rate:	TAPP	0.9	kg/ha

Application Efficiency:	APPEFF	.95	fraction

Spray Drift	DRFT	.05	fraction of application rate applied to pond

Application Date	Date	1-5	dd/mm or dd/mmm or dd-mm or dd-mmm

Interval 1	interval	10	days	Set to 0 or delete line for single app.

Interval 2	interval	10	days	Set to 0 or delete line for single app.

Interval 3	interval	10	days	Set to 0 or delete line for single app.

Interval 4	interval	10	days	Set to 0 or delete line for single app.

Interval 5	interval	10	days	Set to 0 or delete line for single app.

Interval 6	interval	10	days	Set to 0 or delete line for single app.

Interval 7	interval	10	days	Set to 0 or delete line for single app.

Interval 8	interval	10	days	Set to 0 or delete line for single app.

Interval 9	interval	10	days	Set to 0 or delete line for single app.

Record 17:	FILTRA	

	IPSCND	1

	UPTKF	

Record 18:	PLVKRT	

	PLDKRT	

	FEXTRC	0.5

Flag for Index Res. Run	IR	Pond

Flag for runoff calc.	RUNOFF	none	none, monthly or total(average of
entire run)

PA Turf (0.8 lbs ai/A; 5 applications/year)

Inputs generated by pe4.pl - 8-August-2003

Data used for this run:

Output File: PAturf5

Metfile:	w14737.dvf

PRZM scenario:	PAturfC.txt

EXAMS environment file:	pond298.exv

Chemical Name:	ADBAC

Description	Variable Name	Value	Units	Comments

Molecular weight	mwt	368.05	g/mol

Henry's Law Const.	henry	7.76e-13	atm-m^3/mol

Vapor Pressure	vapr	3.53e-12	torr

Solubility	sol	184.4	mg/L

Kd	Kd		mg/L

Koc	Koc	2.7e6	mg/L

Photolysis half-life	kdp	0	days	Half-life

Aerobic Aquatic Metabolism	kbacw	0	days	Halfife

Anaerobic Aquatic Metabolism	kbacs	5445	days	Halfife

Aerobic Soil Metabolism	asm	0	days	Halfife

Hydrolysis:	pH 7	183	days	Half-life

Method:	CAM	2	integer	See PRZM manual

Incorporation Depth:	DEPI		cm

Application Rate:	TAPP	0.9	kg/ha

Application Efficiency:	APPEFF	.95	fraction

Spray Drift	DRFT	.05	fraction of application rate applied to pond

Application Date	Date	1-5	dd/mm or dd/mmm or dd-mm or dd-mmm

Interval 1	interval	10	days	Set to 0 or delete line for single app.

Interval 2	interval	10	days	Set to 0 or delete line for single app.

Interval 3	interval	10	days	Set to 0 or delete line for single app.

Interval 4	interval	10	days	Set to 0 or delete line for single app.

Record 17:	FILTRA	

	IPSCND	1

	UPTKF	

Record 18:	PLVKRT	

	PLDKRT	

	FEXTRC	0.5

Flag for Index Res. Run	IR	Pond

Flag for runoff calc.	RUNOFF	none	none, monthly or total(average of
entire run)

PA Turf (0.8 lbs ai/A; 1 applications/year)

Inputs generated by pe4.pl - 8-August-2003

Data used for this run:

Output File: PAturf1

Metfile:	w14737.dvf

PRZM scenario:	PAturfC.txt

EXAMS environment file:	pond298.exv

Chemical Name:	ADBAC

Description	Variable Name	Value	Units	Comments

Molecular weight	mwt	368.05	g/mol

Henry's Law Const.	henry	7.76e-13	atm-m^3/mol

Vapor Pressure	vapr	3.53e-12	torr

Solubility	sol	184.4	mg/L

Kd	Kd		mg/L

Koc	Koc	2.7e6	mg/L

Photolysis half-life	kdp	0	days	Half-life

Aerobic Aquatic Metabolism	kbacw	0	days	Halfife

Anaerobic Aquatic Metabolism	kbacs	5445	days	Halfife

Aerobic Soil Metabolism	asm	0	days	Halfife

Hydrolysis:	pH 7	183	days	Half-life

Method:	CAM	2	integer	See PRZM manual

Incorporation Depth:	DEPI		cm

Application Rate:	TAPP	0.9	kg/ha

Application Efficiency:	APPEFF	.95	fraction

Spray Drift	DRFT	.05	fraction of application rate applied to pond

Application Date	Date	1-5	dd/mm or dd/mmm or dd-mm or dd-mmm

Record 17:	FILTRA	

	IPSCND	1

	UPTKF	

Record 18:	PLVKRT	

	PLDKRT	

	FEXTRC	0.5

Flag for Index Res. Run	IR	Pond

Flag for runoff calc.	RUNOFF	none	none, monthly or total(average of
entire run)

PA Turf (6.8 lbs ai/A; 10 applications/year)

Inputs generated by pe4.pl - 8-August-2003

Data used for this run:

Output File: PAturfRES

Metfile:	w14737.dvf

PRZM scenario:	PAturfC.txt

EXAMS environment file:	pond298.exv

Chemical Name:	ADBAC

Description	Variable Name	Value	Units	Comments

Molecular weight	mwt	368.05	g/mol

Henry's Law Const.	henry	7.76e-13	atm-m^3/mol

Vapor Pressure	vapr	3.53e-12	torr

Solubility	sol	184.4	mg/L

Kd	Kd		mg/L

Koc	Koc	2.7e6	mg/L

Photolysis half-life	kdp	0	days	Half-life

Aerobic Aquatic Metabolism	kbacw	0	days	Halfife

Anaerobic Aquatic Metabolism	kbacs	5445	days	Halfife

Aerobic Soil Metabolism	asm	0	days	Halfife

Hydrolysis:	pH 7	183	days	Half-life

Method:	CAM	2	integer	See PRZM manual

Incorporation Depth:	DEPI		cm

Application Rate:	TAPP	7.62	kg/ha

Application Efficiency:	APPEFF	.99	fraction

Spray Drift	DRFT	.01	fraction of application rate applied to pond

Application Date	Date	1-5	dd/mm or dd/mmm or dd-mm or dd-mmm

Interval 1	interval	10	days	Set to 0 or delete line for single app.

Interval 2	interval	10	days	Set to 0 or delete line for single app.

Interval 3	interval	10	days	Set to 0 or delete line for single app.

Interval 4	interval	10	days	Set to 0 or delete line for single app.

Interval 5	interval	10	days	Set to 0 or delete line for single app.

Interval 6	interval	10	days	Set to 0 or delete line for single app.

Interval 7	interval	10	days	Set to 0 or delete line for single app.

Interval 8	interval	10	days	Set to 0 or delete line for single app.

Interval 9	interval	10	days	Set to 0 or delete line for single app.

Record 17:	FILTRA	

	IPSCND	1

	UPTKF	

Record 18:	PLVKRT	

	PLDKRT	

	FEXTRC	0.5

Flag for Index Res. Run	IR	Pond

Flag for runoff calc.	RUNOFF	none	none, monthly or total(average of
entire run)

GA Pecans

Inputs generated by pe4.pl - 8-August-2003

Data used for this run:

Output File: GApecans

Metfile:	w93805.dvf

PRZM scenario:	GAPecansC.txt

EXAMS environment file:	pond298.exv

Chemical Name:	ADBAC

Description	Variable Name	Value	Units	Comments

Molecular weight	mwt	368.05	g/mol

Henry's Law Const.	henry	7.76e-13	atm-m^3/mol

Vapor Pressure	vapr	3.53e-12	torr

Solubility	sol	184.4	mg/L

Kd	Kd		mg/L

Koc	Koc	2.7e6	mg/L

Photolysis half-life	kdp	0	days	Half-life

Aerobic Aquatic Metabolism	kbacw	0	days	Halfife

Anaerobic Aquatic Metabolism	kbacs	5445	days	Halfife

Aerobic Soil Metabolism	asm	0	days	Halfife

Hydrolysis:	pH 7	183	days	Half-life

Method:	CAM	2	integer	See PRZM manual

Incorporation Depth:	DEPI		cm

Application Rate:	TAPP	339	kg/ha

Application Efficiency:	APPEFF	.95	fraction

Spray Drift	DRFT	.05	fraction of application rate applied to pond

Application Date	Date	10-5	dd/mm or dd/mmm or dd-mm or dd-mmm

Interval 1	interval	7	days	Set to 0 or delete line for single app.

Interval 2	interval	7	days	Set to 0 or delete line for single app.

Record 17:	FILTRA	

	IPSCND	1

	UPTKF	

Record 18:	PLVKRT	

	PLDKRT	

	FEXTRC	0.5

Flag for Index Res. Run	IR	Pond

Flag for runoff calc.	RUNOFF	none	none, monthly or total(average of
entire run)

OR Christmas Tree

Inputs generated by pe4.pl - 8-August-2003

Data used for this run:

Output File: ORXmasstree

Metfile:	w24232.dvf

PRZM scenario:	ORXmasTreeC.txt

EXAMS environment file:	pond298.exv

Chemical Name:	ADBAC

Description	Variable Name	Value	Units	Comments

Molecular weight	mwt	368.05	g/mol

Henry's Law Const.	henry	7.76e-13	atm-m^3/mol

Vapor Pressure	vapr	3.53e-12	torr

Solubility	sol	184.4	mg/L

Kd	Kd		mg/L

Koc	Koc	2.7e6	mg/L

Photolysis half-life	kdp	0	days	Half-life

Aerobic Aquatic Metabolism	kbacw	0	days	Halfife

Anaerobic Aquatic Metabolism	kbacs	5445	days	Halfife

Aerobic Soil Metabolism	asm	0	days	Halfife

Hydrolysis:	pH 7	183	days	Half-life

Method:	CAM	2	integer	See PRZM manual

Incorporation Depth:	DEPI		cm

Application Rate:	TAPP	339	kg/ha

Application Efficiency:	APPEFF	.95	fraction

Spray Drift	DRFT	.05	fraction of application rate applied to pond

Application Date	Date	10-5	dd/mm or dd/mmm or dd-mm or dd-mmm

Interval 1	interval	7	days	Set to 0 or delete line for single app.

Interval 2	interval	7	days	Set to 0 or delete line for single app.

Record 17:	FILTRA	

	IPSCND	1

	UPTKF	

Record 18:	PLVKRT	

	PLDKRT	

	FEXTRC	0.5

Flag for Index Res. Run	IR	Pond

Flag for runoff calc.	RUNOFF	none	none, monthly or total(average of
entire run)

Appendix B.  Ecotoxicity

The ecotoxicologic endpoints used in this assessment are those used by
AD in their assessments.  Refer to the RED details of the studies.  The
endpoints are summarized and briefly described here.  Only ADBAC is
considered in this section, as DDAC endpoints were not provided.  As
described in other parts of this document, wildlife exposure to DDAC is
expected to be limited.

A.	Toxicity to Terrestrial Animals

(1)	Avian, Acute and Chronic

	In order to establish the toxicity of ADBAC to avian species for
indoor, aquatic industrial, and wood preservative uses, the Agency
requires an acute oral toxicity study using the technical grade active
ingredient (TGAI).  The preferred-test species is either mallard duck (a
waterfowl) or bobwhite quail (an upland game bird).  The results of one
acute oral toxicity study, submitted for ADBAC, are provided in the
following table (Table 1).  The results from the acceptable study
indicate that ADBAC is moderately toxic to avian species on an acute
oral basis.  The study fulfills guideline requirements. 

Table 1.  Acute Oral Toxicity of ADBAC to Birds

Species	

Chemical,

% Active Ingredient

(a.i.)	

Endpoint

(mg/kg)	

Toxicity Category	

Satisfies Guidelines/

Comments	

Reference

(MRID No.)

Bobwhite quail

(Colinus virginianus	ADBAC 80%	LD50 = 136

NOEC = 62.5

(a.i.)	Moderately toxic	Yes

	428859-01



No data are available regarding the chronic toxicity of ADBAC to birds. 
Chronic risk to avian species cannot be precluded in the absence of
data.

	

Mammals, Acute and Chronic Toxicity

The endpoints used in this risk assessment were chosen by AD and used
without details of the studies available.  The acute LD50 for rats
exposed to ADBAC is 430 mg/kg-bw (MRID 232269).  The NOAEL, from a
chronic toxicity study with rats (MRID 41947501), is 44 mg/kg/day (1000
ppm).

B.	Toxicity to Aquatic Animals

The Agency requested that aquatic toxicity studies be conducted with
ADBAC since, under typical use conditions, it may be introduced into the
aquatic environment.

(1)	Freshwater Fish, Acute

In order to establish the acute toxicity of ADBAC to freshwater fish,
the Agency requires freshwater fish toxicity studies using the TGAI. 
The preferred test species are rainbow trout (a coldwater fish) and
bluegill sunfish (a warmwater fish).  Results of freshwater fish acute
studies, submitted for ADBAC and obtained from the open literature, are
presented in Table 3.  The results indicate that ADBAC is highly toxic
to on an acute basis.  The core studies fulfill guideline requirements.

Table 3.  Acute Toxicity of ADBAC to Freshwater Fish

	

Species	

Chemical,

% Active Ingredient

(a.i.)	

Endpoint

(ppm)	

Toxicity Category	

Satisfies Guidelines/

Comments	

Reference

(MRID No.)

Bluegill sunfish (Lepomis macrochirus)	ADBAC 30%*	LC50 = 0.515

NOEC = 0.456 

(a.i.)	Highly toxic	Yes

core study

	419472-01

Fathead minnow (Pimephales promelas)	ADBAC

80%	LC50 = 0.28

NOEC = ND

(a.i.)	Highly toxic	Yes

core study	437401-03

Rainbow Trout (Oncorhynchus mykiss)	ADBAC 30%	LC50 = 0.923

NOEC = 0.619

(a.i.)	Highly toxic	Yes

core study	419472-02

Rainbow Trout (Oncorhynchus mykiss)	ADBAC

50%	LC50 = 1.01

(a.i.)	Highly/ moderately toxic	No

open literature	Dobbs, M.G. et  al.



	(2)	Freshwater Invertebrates, Acute

The Agency requires a freshwater aquatic invertebrate study using the
TGAI to establish the acute toxicity to freshwater invertebrates.  The
preferred test species is Daphnia magna.  Results of two studies,
submitted for ADBAC and obtained from the open literature, are provided
in the following table (Table 4).  	Results of the studies indicate that
ADBAC is very highly toxic to freshwater invertebrates.  The guideline
requirement has been fulfilled.

Table 4.  Acute Toxicity of ADBAC to Freshwater Invertebrates

Species	

Chemical,

% Active Ingredient

(a.i.)	

Endpoint

(ppm)	

Toxicity Category	

Satisfies Guidelines/

Comments	

Reference

(MRID No.)

Waterflea (Daphnia magna)	ADBAC

30%*	EC50 = 0.0059

NOEC = ND (a.i.)	Very highly toxic	Yes

core study  	419472-03

Waterflea (Daphnia magna)	ADBAC

50%	LC50 = 0.02 (a.i.)	Very highly toxic	No

open literature 	Dobbs, M.G., et al.



(3)	Estuarine and Marine Organisms, Acute

Acute toxicity testing with estuarine and marine organisms using the
TGAI is required when the end-use product is intended for direct
application to the marine/estuarine environment or effluent containing
the active ingredient is expected to reach this environment.  The
preferred fish test species is sheepshead minnow.  The preferred
invertebrate test species are mysid shrimp and eastern oysters.  This
testing is required for ADBAC based on the chemical’s use in aquatic
sites such as pulp and paper mills, once-through cooling towers, oil
field recovery systems and as a wood preservative.  Results of toxicity
studies, submitted for ADBAC and obtained from the open literature, are
presented in Table 5.

Table 5.  Acute Toxicity of ADBAC to Estuarine and Marine Organisms  

Species	

Chemical,

% Active Ingredient

(a.i.)	

Endpoint

(ppm ai)	

Toxicity Category	

Satisfies Guidelines/

Comments	

Reference

(MRID No.)

Sheepshead minnow (Cyprinodon variegatus)	ADBAC 80%	LC50 = 0.86

NOEC = 0.68	Highly toxic	Yes

core study  	424795-02

Inland silverside (Menidia beryllina)	ADBAC 50% 	LC50 = 0.31	Highly
toxic	No

open literature

	Dobbs, M.G. et al.

Mysid shrimp (Mysidopsis bahia)	ADBAC 80%	LC50 = 0.092

NOEC = 0.047	Very highly toxic	Yes

core study  	424795-01 

Mysid shrimp (Mysidopsis bahia)	ADBAC 50%	LC50  = 0.08	Very highly
toxic	No

supplemental study	Dobbs, M.G. et al.

Eastern oyster (Crassostrea virginica)	ADBAC

80%	LC50  = 0.055	Very highly toxic	No

supplemental study

	424795-03



The results of the studies indicate that ADBAC is highly toxic to
estuarine/marine fish and very highly toxic to estuarine/marine
invertebrates on an acute basis.  The two core studies (MRID 424795-01
and MRID 424795-02) fulfill guideline requirements for acute toxicity
tests using estuarine/marine fish and shrimp.  However, the one study
using an estuarine/marine mollusk (MRID 424795-03) was classified as
supplemental and does not fulfill guideline requirements.

(4)	Aquatic Organisms, Chronic

Chronic toxicity testing (fish early life stage, 72-4a/OPPTS 850.1400
and aquatic invertebrate life cycle, 72-4b/OPPTS 850.1300) is required
for pesticides when certain conditions of use and environmental fate
apply.  The preferred freshwater fish test species is fathead minnow
(Pimephales promelas), but other species may be used.  The preferred
freshwater invertebrate is Daphnia magna.  This testing is required for
ADBAC.  Results of these toxicity studies, submitted for ADBAC, are
presented in Table 6.  The results indicate that exposure to ADBAC on a
chronic basis results in measurable effects on warmwater fish at a
concentration of 75.9 µg a.i./L.  This study fulfills guideline
requirements for a fish early life stage chronic test (72-4(a)/OPPTS
850.1400).  No measurable effects on freshwater invertebrates were noted
at a concentration of 4.15 µg/L.  However, an MATC could not be
determined in this study.  Therefore, the study was classified as
supplemental and does not fulfill guideline requirements for an aquatic
invertebrate life cycle test (72-4b/OPPTS 850.1300).

Table 6.  Chronic Toxicity of ADBAC to Freshwater Organisms

Species	

Chemical,

% Active Ingredient

(a.i.)	

Endpoint

(µg/L ai)	

Satisfies Guidelines/

Comments	

Reference

(MRID No.)

Fathead Minnow (Pimephales promelas)	ADBAC

30%	LOEC = 75.9 NOEC = 32.2 MATC = 49.4 	Yes

acceptable study	423021-02

Waterflea (Daphnia magna)	ADBAC

30%	LOEC = ND NOEC = 4.15 MATC = ND 	No

supplemental study  	423021-01

	

Appendix C.  Wildlife Drinking Water Exposure

Problem:  ADBAC is a antimicrobial pesticide used to control algae in
outdoor fountains, bird baths, puddles and decorative pools.  No running
water uses.

Issue is wildlife exposure via drinking water.

Assumption wildlife is using puddles and bird baths as a source of
drinking water.

Method will be based on daily oral exposure.  Daily dose is expressed as
mass of pesticide/kg-bw.

Inputs needed:

Concentration of pesticide in water source:  labeled rate is 5 and 200
mg/L

Body weight of target species:  	Avian 20g,  100g,  1000 g

					Mammalian  15, 35, 1000 g

Calculations:

Drinking water intake rate (IRw): EPA (1994)   intake L/day = 0.059(bw
kg)^0.67 (birds)

				          		     intake L/day = 0.099(bw kg)^0.90 (mammals)

Daily pesticide exposure (Water dose mg/kg-bw) = [(Cwater mg/L)(IRw
L)]/bw kg

Caveats :

1. Does not consider additional exposure from dermal contact nor from
preening after bathing events

2. Chronic exposures are likely over estimated as concentration is based
on target concentration at time of application.

Acute RQ =  (Water dose mg/kg-bw)/(LD50 mg/kg-bw)

Source:  Wildlife Exposure Factors Handbook, USEPA, 1994.

Appendix D.  Endangered Species

	Species Taxa Count Report for Crops

	foliage plants

	No species were excluded

	Minimum of 1 Acre.

	AL, AK, AZ, AR, CA, CO, CT, DE, DC, FL, GA, HI, ID, IL, IN, IA, KS, KY,
LA, ME, MD, 

	MA, MI, MN, MS, MO, MT, NE, NV, NH, NJ, NM, NY, NC, ND, OH, OK, OR, PA,
PR, 

	RI, SC, SD, TN, TX, UT, VT, VA, WA, WV, WI, WY

	Alabama

	The taxa Amphibian has 1 species affected by indicated crops.

	The taxa Bird has 4 species affected by indicated crops.

	The taxa Bivalve has 20 species affected by indicated crops.

	The taxa Dicot has 6 species affected by indicated crops.

	The taxa Fish has 8 species affected by indicated crops.

	The taxa Gastropod has 9 species affected by indicated crops.

	The taxa Mammal has 4 species affected by indicated crops.

	The taxa Monocot has 1 species affected by indicated crops.

	The taxa other has 2 species affected by indicated crops.

	The taxa Reptile has 5 species affected by indicated crops.

	Arizona

	The taxa Amphibian has 1 species affected by indicated crops.

	The taxa Bird has 7 species affected by indicated crops.

	The taxa Bivalve has 1 species affected by indicated crops.

	The taxa Dicot has 9 species affected by indicated crops.

	The taxa Fish has 9 species affected by indicated crops.

	The taxa Gastropod has 1 species affected by indicated crops.

	The taxa Mammal has 6 species affected by indicated crops.

	The taxa Monocot has 1 species affected by indicated crops.

	The taxa Reptile has 1 species affected by indicated crops.

	Arkansas

	The taxa Bird has 3 species affected by indicated crops.

	The taxa Bivalve has 4 species affected by indicated crops.

	The taxa Crustacean has 1 species affected by indicated crops.

	The taxa Dicot has 1 species affected by indicated crops.

	The taxa Insect has 1 species affected by indicated crops.

	The taxa Mammal has 3 species affected by indicated crops.

	California

	The taxa Amphibian has 6 species affected by indicated crops.

	The taxa Bird has 15 species affected by indicated crops.

	The taxa Crustacean has 7 species affected by indicated crops.

	The taxa Dicot has 135 species affected by indicated crops.

	The taxa Fish has 24 species affected by indicated crops.

	The taxa Gastropod has 1 species affected by indicated crops.

	The taxa Insect has 19 species affected by indicated crops.

	The taxa Mammal has 21 species affected by indicated crops.

	The taxa Monocot has 14 species affected by indicated crops.

	The taxa other has 2 species affected by indicated crops.

	The taxa Reptile has 8 species affected by indicated crops.

	Colorado

	The taxa Bird has 2 species affected by indicated crops.

	The taxa Dicot has 1 species affected by indicated crops.

	The taxa Mammal has 1 species affected by indicated crops.

	Connecticut

	The taxa Bird has 1 species affected by indicated crops.

	The taxa Bivalve has 1 species affected by indicated crops.

	The taxa Fish has 1 species affected by indicated crops.

	Florida

	The taxa Bird has 10 species affected by indicated crops.

	The taxa Bivalve has 1 species affected by indicated crops.

	The taxa Crustacean has 1 species affected by indicated crops.

	The taxa Dicot has 41 species affected by indicated crops.

	The taxa Fish has 3 species affected by indicated crops.

	The taxa Gastropod has 1 species affected by indicated crops.

	The taxa Insect has 1 species affected by indicated crops.

	The taxa Mammal has 11 species affected by indicated crops.

	The taxa Monocot has 2 species affected by indicated crops.

	The taxa other has 1 species affected by indicated crops.

	The taxa Reptile has 10 species affected by indicated crops.

	Georgia

	The taxa Bird has 5 species affected by indicated crops.

	The taxa Bivalve has 13 species affected by indicated crops.

	The taxa Dicot has 5 species affected by indicated crops.

	The taxa Fish has 7 species affected by indicated crops.

	The taxa Mammal has 3 species affected by indicated crops.

	The taxa Monocot has 3 species affected by indicated crops.

	The taxa other has 3 species affected by indicated crops.

	The taxa Reptile has 2 species affected by indicated crops.

	Hawaii

	The taxa Arachnid has 1 species affected by indicated crops.

	The taxa Bird has 32 species affected by indicated crops.

	The taxa Crustacean has 1 species affected by indicated crops.

	The taxa Dicot has 233 species affected by indicated crops.

	The taxa Gastropod has 39 species affected by indicated crops.

	The taxa Insect has 1 species affected by indicated crops.

	The taxa Mammal has 2 species affected by indicated crops.

	The taxa Monocot has 22 species affected by indicated crops.

	The taxa other has 12 species affected by indicated crops.

	The taxa Reptile has 2 species affected by indicated crops.

	Idaho

	The taxa Bird has 1 species affected by indicated crops.

	The taxa Fish has 3 species affected by indicated crops.

	Illinois

	The taxa Bird has 3 species affected by indicated crops.

	The taxa Dicot has 3 species affected by indicated crops.

	The taxa Fish has 1 species affected by indicated crops.

	The taxa Insect has 2 species affected by indicated crops.

	The taxa Mammal has 2 species affected by indicated crops.

	The taxa Monocot has 1 species affected by indicated crops.

	Indiana

	The taxa Bird has 1 species affected by indicated crops.

	The taxa Dicot has 2 species affected by indicated crops.

	The taxa Insect has 2 species affected by indicated crops.

	The taxa Mammal has 1 species affected by indicated crops.

	The taxa Reptile has 1 species affected by indicated crops.

	Iowa

	The taxa Bird has 3 species affected by indicated crops.

	The taxa Dicot has 2 species affected by indicated crops.

	The taxa Fish has 1 species affected by indicated crops.

	The taxa Mammal has 1 species affected by indicated crops.

	The taxa Monocot has 2 species affected by indicated crops.

	Kentucky

	The taxa Bird has 3 species affected by indicated crops.

	The taxa Bivalve has 9 species affected by indicated crops.

	The taxa Mammal has 2 species affected by indicated crops.

	Louisiana

	The taxa Bird has 4 species affected by indicated crops.

	The taxa Bivalve has 2 species affected by indicated crops.

	The taxa Fish has 2 species affected by indicated crops.

	The taxa Mammal has 2 species affected by indicated crops.

	The taxa other has 1 species affected by indicated crops.

	The taxa Reptile has 7 species affected by indicated crops.

	Maine

	The taxa Bird has 3 species affected by indicated crops.

	The taxa Fish has 2 species affected by indicated crops.

	The taxa Monocot has 1 species affected by indicated crops.

	Maryland

	The taxa Bird has 2 species affected by indicated crops.

	The taxa Bivalve has 1 species affected by indicated crops.

	The taxa Dicot has 1 species affected by indicated crops.

	The taxa Fish has 1 species affected by indicated crops.

	The taxa Insect has 1 species affected by indicated crops.

	The taxa Mammal has 2 species affected by indicated crops.

	The taxa Monocot has 1 species affected by indicated crops.

	The taxa Reptile has 1 species affected by indicated crops.

	Massachusetts

	The taxa Bird has 4 species affected by indicated crops.

	The taxa Dicot has 1 species affected by indicated crops.

	The taxa Fish has 1 species affected by indicated crops.

	The taxa Mammal has 1 species affected by indicated crops.

	The taxa Monocot has 1 species affected by indicated crops.

	The taxa Reptile has 1 species affected by indicated crops.

	Michigan

	The taxa Bird has 3 species affected by indicated crops.

	The taxa Bivalve has 1 species affected by indicated crops.

	The taxa Dicot has 1 species affected by indicated crops.

	The taxa Insect has 2 species affected by indicated crops.

	The taxa Mammal has 1 species affected by indicated crops.

	The taxa Monocot has 2 species affected by indicated crops.

	The taxa Reptile has 1 species affected by indicated crops.

	Minnesota

	The taxa Bird has 2 species affected by indicated crops.

	The taxa Bivalve has 2 species affected by indicated crops.

	The taxa Dicot has 1 species affected by indicated crops.

	The taxa Insect has 1 species affected by indicated crops.

	The taxa Mammal has 2 species affected by indicated crops.

	Mississippi

	The taxa Amphibian has 1 species affected by indicated crops.

	The taxa Bird has 5 species affected by indicated crops.

	The taxa Bivalve has 6 species affected by indicated crops.

	The taxa Fish has 1 species affected by indicated crops.

	The taxa Mammal has 1 species affected by indicated crops.

	The taxa other has 1 species affected by indicated crops.

	The taxa Reptile has 7 species affected by indicated crops.

	Missouri

	The taxa Bird has 3 species affected by indicated crops.

	The taxa Bivalve has 2 species affected by indicated crops.

	The taxa Dicot has 4 species affected by indicated crops.

	The taxa Fish has 3 species affected by indicated crops.

	The taxa Insect has 2 species affected by indicated crops.

	The taxa Mammal has 2 species affected by indicated crops.

	Montana

	The taxa Bird has 1 species affected by indicated crops.

	The taxa Dicot has 1 species affected by indicated crops.

	The taxa Fish has 3 species affected by indicated crops.

	The taxa Mammal has 2 species affected by indicated crops.

	Nebraska

	The taxa Bird has 4 species affected by indicated crops.

	The taxa Fish has 1 species affected by indicated crops.

	The taxa Insect has 1 species affected by indicated crops.

	The taxa Monocot has 1 species affected by indicated crops.

	Nevada

	The taxa Bird has 1 species affected by indicated crops.

	The taxa Dicot has 8 species affected by indicated crops.

	The taxa Fish has 7 species affected by indicated crops.

	The taxa Insect has 1 species affected by indicated crops.

	The taxa Reptile has 1 species affected by indicated crops.

	New Hampshire

	The taxa Bird has 1 species affected by indicated crops.

	The taxa Insect has 1 species affected by indicated crops.

	The taxa Mammal has 1 species affected by indicated crops.

	The taxa Monocot has 1 species affected by indicated crops.

	New Jersey

	The taxa Bird has 2 species affected by indicated crops.

	The taxa Dicot has 2 species affected by indicated crops.

	The taxa Fish has 1 species affected by indicated crops.

	The taxa Mammal has 1 species affected by indicated crops.

	The taxa Monocot has 2 species affected by indicated crops.

	The taxa Reptile has 1 species affected by indicated crops.

	New Mexico

	The taxa Amphibian has 1 species affected by indicated crops.

	The taxa Bird has 7 species affected by indicated crops.

	The taxa Crustacean has 1 species affected by indicated crops.

	The taxa Dicot has 1 species affected by indicated crops.

	The taxa Fish has 1 species affected by indicated crops.

	The taxa Gastropod has 2 species affected by indicated crops.

	The taxa Mammal has 1 species affected by indicated crops.

	New York

	The taxa Bird has 3 species affected by indicated crops.

	The taxa Dicot has 4 species affected by indicated crops.

	The taxa Fish has 1 species affected by indicated crops.

	The taxa Mammal has 1 species affected by indicated crops.

	The taxa Monocot has 1 species affected by indicated crops.

	The taxa other has 1 species affected by indicated crops.

	The taxa Reptile has 1 species affected by indicated crops.

	North Carolina

	The taxa Arachnid has 1 species affected by indicated crops.

	The taxa Bird has 4 species affected by indicated crops.

	The taxa Bivalve has 8 species affected by indicated crops.

	The taxa Dicot has 15 species affected by indicated crops.

	The taxa Fish has 3 species affected by indicated crops.

	The taxa Mammal has 5 species affected by indicated crops.

	The taxa Monocot has 4 species affected by indicated crops.

	The taxa other has 1 species affected by indicated crops.

	The taxa Reptile has 5 species affected by indicated crops.

	Ohio

	The taxa Bird has 2 species affected by indicated crops.

	The taxa Bivalve has 1 species affected by indicated crops.

	The taxa Dicot has 2 species affected by indicated crops.

	The taxa Insect has 1 species affected by indicated crops.

	The taxa Mammal has 1 species affected by indicated crops.

	The taxa Monocot has 1 species affected by indicated crops.

	Oklahoma

	The taxa Bird has 4 species affected by indicated crops.

	The taxa Fish has 1 species affected by indicated crops.

	The taxa Insect has 1 species affected by indicated crops.

	The taxa Monocot has 1 species affected by indicated crops.

	Oregon

	The taxa Bird has 5 species affected by indicated crops.

	The taxa Dicot has 6 species affected by indicated crops.

	The taxa Fish has 18 species affected by indicated crops.

	The taxa Insect has 2 species affected by indicated crops.

	The taxa Mammal has 1 species affected by indicated crops.

	The taxa Monocot has 1 species affected by indicated crops.

	Pennsylvania

	The taxa Bird has 2 species affected by indicated crops.

	The taxa Bivalve has 2 species affected by indicated crops.

	The taxa Mammal has 1 species affected by indicated crops.

	The taxa Monocot has 1 species affected by indicated crops.

	The taxa Reptile has 1 species affected by indicated crops.

	Rhode Island

	The taxa Bird has 1 species affected by indicated crops.

	The taxa Dicot has 1 species affected by indicated crops.

	The taxa Fish has 1 species affected by indicated crops.

	The taxa Insect has 1 species affected by indicated crops.

	South Carolina

	The taxa Amphibian has 1 species affected by indicated crops.

	The taxa Bird has 5 species affected by indicated crops.

	The taxa Bivalve has 1 species affected by indicated crops.

	The taxa Dicot has 9 species affected by indicated crops.

	The taxa Fish has 1 species affected by indicated crops.

	The taxa Mammal has 7 species affected by indicated crops.

	The taxa Monocot has 3 species affected by indicated crops.

	The taxa Reptile has 4 species affected by indicated crops.

	Tennessee

	The taxa Bird has 2 species affected by indicated crops.

	The taxa Bivalve has 22 species affected by indicated crops.

	The taxa Crustacean has 1 species affected by indicated crops.

	The taxa Dicot has 9 species affected by indicated crops.

	The taxa Fish has 10 species affected by indicated crops.

	The taxa Gastropod has 1 species affected by indicated crops.

	The taxa Mammal has 2 species affected by indicated crops.

	The taxa Monocot has 1 species affected by indicated crops.

	Texas

	The taxa Amphibian has 4 species affected by indicated crops.

	The taxa Arachnid has 4 species affected by indicated crops.

	The taxa Bird has 12 species affected by indicated crops.

	The taxa Crustacean has 1 species affected by indicated crops.

	The taxa Dicot has 16 species affected by indicated crops.

	The taxa Fish has 3 species affected by indicated crops.

	The taxa Insect has 5 species affected by indicated crops.

	The taxa Mammal has 5 species affected by indicated crops.

	The taxa Monocot has 2 species affected by indicated crops.

	The taxa Reptile has 5 species affected by indicated crops.

	Utah

	The taxa Bird has 1 species affected by indicated crops.

	The taxa Dicot has 2 species affected by indicated crops.

	The taxa Fish has 1 species affected by indicated crops.

	The taxa Monocot has 1 species affected by indicated crops.

	Virginia

	The taxa Bird has 2 species affected by indicated crops.

	The taxa Bivalve has 2 species affected by indicated crops.

	The taxa Dicot has 5 species affected by indicated crops.

     The taxa Fish has 2 species affected by indicated crops.

	The taxa Insect has 2 species affected by indicated crops.

	The taxa Mammal has 2 species affected by indicated crops.

	The taxa Monocot has 2 species affected by indicated crops.

	The taxa Reptile has 1 species affected by indicated crops.

	Washington

	The taxa Bird has 3 species affected by indicated crops.

	The taxa Dicot has 3 species affected by indicated crops.

	The taxa Fish has 17 species affected by indicated crops.

	The taxa Mammal has 4 species affected by indicated crops.

	West Virginia

	The taxa Amphibian has 1 species affected by indicated crops.

	The taxa Bivalve has 4 species affected by indicated crops.

	The taxa Dicot has 2 species affected by indicated crops.

	The taxa Gastropod has 1 species affected by indicated crops.

	The taxa Mammal has 3 species affected by indicated crops.

	Wisconsin

	The taxa Bird has 2 species affected by indicated crops.

	The taxa Bivalve has 1 species affected by indicated crops.

	The taxa Dicot has 2 species affected by indicated crops.

	The taxa Insect has 1 species affected by indicated crops.

	The taxa Mammal has 2 species affected by indicated crops.

	The taxa Monocot has 1 species affected by indicated crops.

*	Comparable to typical ADBAC Manufacturing Use Product (MUP) 80% with
regard to actual

	composition of ADBAC and its impurities

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