RE-REGISTRATION ELIGIBILITY DOCUMENT

ENVIRONMENTAL FATE AND EFFECTS SCIENCE CHAPTER

Environmental Fate and Ecological Risk Assessment

for

Mefluidide (PC Code 114001)

                                                 CAS # 53780-34-0 

AND

  Mefluidide-DEA (PC Code 114002)

CAS # 53780-36-2

AND

Mefluidide-K  (PC Code 114003) 

CAS #83601-83-6

Environmental Fate and Effects Division Team Members

Marie Janson, Environmental Scientist

James Hetrick, Senior Chemist

Branch Reviewers

Ed Odenkirchen, Senior Biologist

 

Branch Chief Approval

Nancy Andrews, Branch Chief  

Date of Approval:  6/07/07

 TABLE OF CONTENTS 

 TOC \f 

1	EXECUTIVE SUMMARY                                                     
                                 

1.1	Nature of Chemical
Stressor……………………………………………………....
4	

1.2	Potential Risks to Non-target
Organisms…………………………………...	…….5

1.3	Conclusions - Exposure
Characterization…………………………………………9	

1.4	Conclusions - Effects
Characterization…………………………………………..10 

1.5	Uncertainties and Data
Gaps……………………………………………………..12 

2	PROBLEM FORMULATION                                                   
                           

2.1	Stressor Source and
Distribution…………………………………………...........1
3

2.1.1	Environmental Fate
Summary…………………………………………...14

2.1.2	Pesticide Type, Class and Mode of
Action………………………………14	

2.1.3	Use
Characterization………………………………………………
……..14

2.2	Assessment
Endpoints………………………………………………………
…...15

2.2.1	Ecosystems at
Risk……………………………………………………....15	

2.2.2	Ecological
Effects………………………………………………………..
16

2.3	 Conceptual
Model…………………………………………………………
…….18

    2.3.1	  Conceptual Model
Diagram…………………………………………….18

2.3.2	  Terrestrial
Environment………………………………………………...20

2.3.3	  Aquatic
Environment…………………………………………………...2
0	

2.4  Risk
Hypotheses..............................................................
.....................................................21

3	ANALYSIS                                                              
                                                

3.1	Use
Characterization………………………………………………
……………. 22	 

3.2	Exposure
Characterization………………………………………………
……….22	

3.2.1	Environmental Fate
Summary…………………………………………...22

3.2.2	Measures of Aquatic
Exposure…………………………………………..24

3.2.2.1	Aquatic Exposure
Modeling……………………………………………………..24

3.2.3	Measures of Terrestrial
Exposure………………………………………..27

3.2.3.1	Terrestrial Exposure
Modeling…………………………………………………..28

3.3	Ecological Effects
Characterization……………………………………………..32

3.3.1	Aquatic and Terrestrial Effects
Characterization………………………..32

 3.3.1.1 Aquatic
Animals………………………………………………………
……...35

 3.3.1.2 Terrestrial
Animals………………………………………………………
…...39

4	RISK CHARACTERIZATION                                                 
                           

4.1	Risk Estimation - Integration of Exposure and Effects
Data…………………....46

4.1.1	Non-target Aquatic Animals and
Plants………………………………...49

4.1.1.1	 Freshwater Fish and
Invertebrates……………………………………………   50

4.1.1.2	Estuarine/Marine Fish and
Invertebrates………………………………………..50

4.1.1.3 Aquatic
Plants…………………………………………………………
……   51

4.1.2	Non-target Terrestrial
Animals………………………………………… 52

4.1.2.1
Birds…………………………………………………………
………………..53

4.1.2.2
Mammals………………………………………………………
……………...55

4.1.2.3 Plants  
………………………………………………………………
………..58

4.1.3	RQs Based on Mean Kenaga
Residues………………………………….61

4.2	Risk Description- Interpretation of Direct
Effects……………………………....62

4.2.1	Risks to Aquatic Organisms and
Plants………………………………....62

4.2.2	Risks to Terrestrial Organisms and
Plants……………………………....62

4.2.4	Federally Threatened and Endangered (Listed)
Species………………..68

4.2.4.1 Action Area
………………………………………………………………
….68

4.2.4.2	Taxonomic Groups Potentially at
Risks………………………………………..68

4.3	Description of Assumptions, Limitations, Uncertainties, and Data
Gaps……...74

4.3.1 Assumptions and Limitations Related to Exposure for all
Taxa…………....76

4.3.2 Assumptions and Limitations Related to Exposure for Aquatic
Species …..76

4.3.2 Assumptions and Limitations Related to Exposure for Terrestrial
Species...77

References……………………………………………………
………………………...84

APPENDIX A. Data Requirements for
Mefluidide……………………………………85 

APPENDIX B.  Bibliography for Environmental Fate and  Chemical
Structures……..86

APPENDIX C.  Aquatic Exposure Modeling Assessment - PRZM/EXAMS
Outputs..87

APPENDIX D. Terrestrial Exposure Modeling Assessment- TREX and
TerrPlant…..99

APPENDIX E.  Ecological Effects Characterization for
Mefluidide………………...114 

APPENDIX F.  Guideline Sequence Bibliography for Ecological
Effects…………..134  

APPENDIX G.  Risk Quotient
Method……………………………………………....138

APPENDIX H. ECOTOX
Results……………………………………………………140

 1.	Executive Summary

1.1	Nature of Stressor 

             Mefluidide is a post-emergent, anilide growth regulator
used to control ornamental and non-ornamental woody plants, ground
cover, hedges trees, turf grasses, grass and broadleaf weeds.  It is
also registered for growth control of low maintenance turf on
rights-of-ways, airports, and industrial sites.  It is formulated as the
mefluidide, diethanolamine salt of mefluidide (mefluidide-DEA), and
potassium salt of mefluidide (mefluidide-K).  Based on the ionic nature
of mefluidide-K and mefluidide-DEA and two unreviewed dissociation
studies, mefluidide-K and mefluidide-DEA will dissociate rapidly and
completely to form mefluidide acid.  The two unreviewed dissociation
studies (MRIDs 422833-01 and 42282001) indicated mefluidide-K completely
dissociated in 7 minutes and mefluidide-DEA completely dissociated in 3
minutes.  Mefluidide acid is in equilibrium with mefluidide (Figure 1). 
In order to assess the environmental fate and effects of mefluidide-K,
mefluidide-DEA, mefluidide, the risk assessment strategy was to bridge
the environmental fate and ecological toxicity data for the mefluidide,
mefluidide-K, and mefluidide-DEA to the formation of mefluidide acid. 
For purposes of this assessment, mefluidide acid will be used as an
analog for mefluidide, mefluidide-DEA and mefluidide-K.

 

	Figure 1.   Enol-Keto Equilibrium of  Mefluidide-K and Mefluidide 

              

 The acetamide functional group in mefluidide exhibits in a enol-keto
equilibrium with mefluidide acid .  This equilibrium is expected to
favor the formation of the keto form (mefluidide) over the enol form
(mefluidide acid) (Morrison and Boyd, 1976).   

Potential Risk to Non Target Organisms

   SEQ CHAPTER \h \r 1 This screening-level (Level I) risk assessment
focused on the use of mefluidide-K, mefluidide-DEA, and mefluidide on
ornamental and turf areas. Results suggest that levels of mefluidide in
the environment, when compared with measured toxicity for the most
sensitive  organisms of selected taxa, are likely to result in direct
risks to listed and non-listed species from several different taxa. 
Indirect risks are also identified for listed and non-listed non-target
organisms.

	For the aquatic assessment, estimated environmental concentrations
(EECs) in surface water were calculated for mefluidide acid using the
Tier II  PRZM/EXAMS models and employing maximum label application rates
for mefluidide, mefluidide-K, mefluidide-DEA.  Turf application
scenarios in Florida and Pennsylvania were modeled for the exposure
assessment.  

              This screening level risk assessment shows that use of
mefluidide is below the Agency’s level of concern for direct acute
(listed and non-listed) and chronic toxic exposure to aquatic freshwater
and estuarine marine organisms and acute aquatic plants. In contrast,
the use of mefluidide is above the Agency’s level of concern for
direct acute (listed and nonlisted) and chronic toxic exposure to
mammals, birds and acute (listed and nonlisted) exposure to terrestrial
and semi aquatic plants. 

 The following toxicity data was not available for Agency review3: 

Chronic freshwater fish (72-5)

Chronic freshwater invertebrates (72-4 b) 

Chronic estuarine marine fish (72-4 a)

Chronic estuarine marine invertebrates (72-4 b)

Seedling emergence (123-1 a)

Chronic bird (74-1)

(EC05 or NOAEC) was not provided for vascular and nonvascular plants
(123-2)

In the absence of data, EFED:

Used available toxicity data of propanil a structurally similar anilide
herbicide

Assumed that EC25 toxicity values for terrestrial plants (vegetative
vigor) are equivalent to (seedling emergence) measurement endpoints

Used available data from mefluidide mammal toxicity data to evaluate
chronic toxicity to birds. 

            

           The Tier I terrestrial plant model, TERRPLANT, was used to
assess risks to terrestrial and semi-aquatic plants.  LOCs were exceeded
for both terrestrial and semi-aquatic plants (monocots and dicots) for
both spray and granular applications.   All the above modeled scenarios
with T-REX and TERRPLANT are summarized in APPENDIX D. Specific direct
risks of concern to non-target terrestrial organisms are summarized as
follows: 

Mammalian Acute Listed LOCs  were exceeded for 15 g and 35 g  mammals
exposed to application rates for mefluidide-DEA and mefluidide-K (1.0 lb
ae/A at 3 applications) consuming short grass, broadleaf plants, or
small insects and 1000 g mammals that consume short grass.   

Mammalian Acute Listed LOCs were exceeded for the LD50s/sq-ft for 15g
and 35 g mammals based on one granular application of mefluidide at 0.5
lbs ae/acre. 

Mammalian Acute Restricted Use LOCs were exceeded for 15 g and 35 g
mammals that consume short grass exposed to application rates for
mefluidide-DEA and mefluidide-K ( 1.0 lb ae/A at 3 applications).

Mammalian Acute Restricted Use LOCs were exceeded for the LD50s/sq-ft
for small and medium-sized mammals based on one granular application of
mefluidide at 0.5lbs ae/acre.

Mammalian Chronic LOCs (dose-based) were exceeded for 15 g mammals that
consume short grass exposed to  application rates for mefluidide-DEA and
mefluidide-K (1.0 lb ae/A at 3 applications) 

Avian Acute Listed   LOCs were exceeded for  20 g  birds that  consume
short grass, tall grass and broadleaf plants and small insects and 100 g
birds that consume short grass for the  1.0 lb ae/A  modeled scenario.
Non-definitive toxicity endpoints do not allow for calculations of
definitive RQs, however the ratio of non- definitive endpoints (EECs) in
this case results in acute RQs ranging from <0.0 to <0.25.

Avian Acute Listed   LOCs were exceeded for the LD50s/sq-ft for 20 g
birds based on one granular application of mefluidide at 0.5 lbs
ae/acre. 

Avian Acute Restricted Use LOCs were exceeded for 20 g birds that
consume short grass for the 1.0 lba ae/A application rate modeled
scenario. Non-definitive toxicity endpoints do not allow for
calculations of definitive RQs, however the ratio of non- definitive
endpoints (EECs) in this case results in acute RQs of < 0.25. 

Avian Acute Restricted Use LOCs were exceeded for the LD50s/sq-ft for 20
g birds based on one granular application of mefluidide at 0.5 lbs
ae/acre. 

Avian Chronic LOCs (dietary-based) exceedances occurred for birds for
the 1.0 lb ae/A modeled scenario. Non-definitive toxicity endpoints do
not allow for calculations of definitive RQs, however the ratio of non-
definitive endpoints (EECs) in this case results in acute RQs ranging
from 2.9 to 6.32.   

Terrestrial and Semi-aquatic Plants (Listed Species and Non-Listed
Species) LOCs were exceeded for monocots and dicots with the 1.0 lb ae/A
spray applications of mefluidide-K and mefluidide-DEA. LOCs were
exceeded for dicots and monocots (granular applications) with 0.5 lb
ae/acre of mefluidide. Dicots demonstrated more sensitivity than
monocots in all application scenarios. 

            A summary of the potential for direct and indirect effects
to listed species, summarized by taxonomic group, is provided in Table
1.1. 

The results of this risk assessment suggest that the patterns of
mefluidide use are such that they coincide in time and space to areas
frequented by avian and mammalian wildlife. These areas have been
demonstrated as use by wildlife as sources of food and cover. The
potentially problematic wildlife food items suggested by this risk
assessment are likely to be present in and around the treated areas. In
addition, there is potential for indirect effects to all taxonomic
groups due to changes in habitat caused by vegetation changes. Some uses
of mefluidide may not pose a threat for avian and mammalian wildlife,
such as industrial sites that are not frequented by wildlife

Table 1. 1 Listed Species Risks Associated With Direct or Indirect
Effects Due to Applications of Mefluidide

Listed Taxonomy	Direct Effects	Indirect Effects

Terrestrial and semi-aquatic plants – monocots	Yes	Yes c

Terrestrial and semi-aquatic plants – dicots	Yes	Yes c

Terrestrial invertebrates	None	Yes c

Birds	Yes (acute estimated values), Yes(chronic estimated values),	Yes
c,d, e 

Terrestrial phase amphibians	Yes (acute estimated values), Yes(chronic
estimated values), 	Yes c,  e

Reptiles	Yes (acute estimated values), Yes(chronic estimated values), 
Yes c,d, e

Mammals	Yes (acute and chronic)	Yes c, d, e

Aquatic vascular plants	None Acute and None (EC05 estimated values) 	Yes
c

Aquatic non-vascular plants a	None Acute and None (EC05 estimated
values)	Yes c

Freshwater fish	None(acute), None(chronic estimated values)	Yes c

Aquatic phase amphibians	None(acute), Unknown(chronic) b	Yes c

Freshwater crustaceans	None (acute), None (chronic estimated values)	Yes
c

Mollusks	None (acute), None chronic estimated values	Yes c

Marine/estuarine fish	None (acute), None  (chronic estimated values)	Yes
c

a At the present time no aquatic non-vascular plants are included in
Federal listings of threatened and listed species.  The taxonomic group
is included here for the purposes of evaluating potential contributions
to indirect effects to other taxonomy and as a record of exceedances
should future listings of non-vascular aquatic plants warrant additional
evaluation of Federal actions.

b Terrestrial phase amphibians and reptiles estimated using birds as
surrogates.  Aquatic amphibians estimated using freshwater fish as
surrogates.

c Listed and Non-listed LOC exceeded for terrestrial and semi-aquatic
plants.

d Listed, Restricted Use, and Acute LOC exceeded for some feeding guilds
and size classes of birds.

e Listed, Restricted Use, and Chronic LOC exceeded for some feeding
guilds and size classes of mammals.



Conclusions Exposure Characterization

 at pH~7, with 50% or greater dissociation at pHs ≤ 4.6.  Mefluidide
acid is in equilibrium with mefluidide (Figure 1).  The only degradation
product identified for mefluidide was
5-amino-2,4-dimethyltrifluoromethanesulfonilide. Mefluidide is
moderately persistent and mobile in soil.    SEQ CHAPTER \h \r 1
Estimated environmental concentrations (EECs) in surface water were
calculated for mefluidide acid using the Tier II PRZM/EXAMS models with
the maximum proposed application rates for mefluidide, mefluidide-K, and
mefluidide-DEA on turf.  Estimated concentrations are expressed in acid
equivalence because mefluidide acid is a common intermediate compound
among mefluidide, mefluidide-K, and mefluidide-DEA.  Peak
(1-in-10 year) surface water EECs were approximately 7.054 μg ae/L and
10.573 μg ae/L for the Pennsylvania Turf and Florida turf scenarios,
respectively.

	Routes of exposure evaluated in this risk assessment focused on runoff
and spray drift from ground spray with mefluidide applied at application
rates of mefluidide-K and mefluidide-DEA and runoff from granular
applications with mefluidide. 

          For the terrestrial assessment, EECs for mefluidide were
calculated using the terrestrial Tier I model T-REX using the maximum
application rate for mefluidide, mefluidide-K, and mefluidide-DEA.
Modeling was based on a foliar half-life of 4 days, 3 applications per
season and 42 day interval. Upper bound dietary EECs for mefluidide-DEA
and mefluidide-K application rate of 1.0 lb ae/A (spray application)
were 240.17 mg ae /kg  on short grass, 110.08 mg ae /kg on tall grass,
135.09 mg ae /kg on broadleaf plants, or small insects and 15.01 mg ae
/kg for fruits, pods, seeds, and large insects. 

   

           For a single granular application of mefluidide at the
maximum application rate, 0.5 lbs ae/acre, the EEC was calculated as
5.21 mg ae/sq ft. This LD50 / sq ft approach can only be applied for
single applications. Since the chemical is not incorporated into the
soil immediately after application, it is assumed that 100% of the
material is available to birds and mammals (USEPA 1992).

1.4           Conclusions Effects Characterization

The risk assessment strategy is designed to bridge the environmental
fate and effects data for the mefluidide-K and mefluidide-DEA,
mefluidide to mefluidide acid.  Therefore, the most sensitive endpoint
for the three mefluidide compounds (mefluidide, mefluidide-K,
mefluidide-DEA) was selected to represent all mefluidide compounds for
aquatic and terrestrial organisms in each category.  Most of the
toxicity endpoints are within one order of magnitude when comparing the
mefluidide and mefluidide-DEA.  There was an incomplete toxicity
database on mefluidide-K to allow for comparisons of toxicity. 

Table 1.2, 1.3 and 1.4 provides a summary of acute and chronic toxicity
data used for risk quotient calculation for mefluidide-K, mefluidide-DEA
and mefluidide application.

Table 1.2: Summary of endpoints (LC50 or EC50, mg ae/L) for Aquatic
Toxicity used in RQ calculations for Mefluidide 1



TAXONOMIC GROUP	Acute endpoint  	Chronic endpoint	MRID/

Estimated value



Acute freshwater fish	>68.47*

Rainbow Trout

MRID

418937-02



Chronic freshwater fish

>0.2672	Estimated value acute to chronic ratio



Acute freshwater inverts	>77.25*

Daphnid

MRID

418937-03



Chronic freshwater inverts

>5.542	Estimated value acute to chronic ratio



Acute estuarine/marine fish	>84.75*

Sheepshead minnow

MRID

425623-03



Chronic estuarine/marine fish

>0.2672	Estimated value acute to chronic ratio



Acute estuarine/marine inverts	67*

Eastern oyster

MRID

425624-01



Chronic estuarine/marine inverts

>5.542	Estimated value acute to chronic ratio

            1For terrestrial plants data evaluating  mefluidide-K, 
mefluidide-DEA and mefluidide  have been  bridged for 

             the  terrestrial risk assessment. *most sensitive species
tested

                       2 acute to chronic ratio from propanil
extrapolation

 

Table 1.3: Summary of endpoints (LC50 or EC50, mg ae/L aquatic
organisms) for Plant Toxicity used in RQ calculations for  Mefluidide1



TAXONOMIC GROUP	Acute endpoint  	NOAEC or EC05

	

Acute  vascular plant	0.515*

Lemna

MRID 435266-01

Tier I (8% growth stimulation)  

Used this value as EC50                                  

Vascular plant(EC05)

>0.292	Estimated value acute to chronic ratio



Acute  non-vascular plant	0.629*

Navicula

MRID 435266-05

Tier I (11.5% growth reduction)

Used this value as  EC50                                  

 Non-vascular plant(EC05)

>0.7862	Estimated value acute to chronic ratio

 Terrestrial Plant: 

Vegetative Vigor 

	Monocot:* Sorghum

EC25 0.105 lb ae/A

 Dicot:* Mustard  EC25  0.0054 lb ae/A	Monocot:* Sorghum

NOAEC 0.045 lb ae/A

Dicot:* Mustard     

NOAEC 0.0029 lb ae/A	MRID 435496-01

   

  Terrestrial Plant: 

Seedling Emergence 

	Monocot:

Sorghum

EC25 0.105 lb ae/A

 Dicot:* Mustard  EC25  0.0054 lb ae/A	Monocot: Sorghum

NOAEC 0.045 lb ae/A

Dicot:* Mustard     

NOAEC 0.0029 lb ae/A	Estimated value from  vegetative vigor  study MRID
435496-01

   

 1For terrestrial plants data evaluating  mefluidide-K,  mefluidide-DEA
and mefluidide have been  bridged for  the  terrestrial risk assessment.

   2 acute to chronic ratio from propanil extrapolation

 *most sensitive species tested

Table 1.4: Summary of endpoints (LD50  or LC50 mg ae/kg) for Terrestrial
Toxicity  data used in RQ calculations for Mefluidide1



TAXONOMIC GROUP	Acute endpoint  	Chronic endpoint

	Acute Avian  	>1500*

Bobwhite quail

MRID 416019-01

Used this non-definitive endpoint as LD50

Chronic Avian 

38	Estimated value acute to chronic ratio based on mefluidide mammal
data

Acute Dietary Avian 	>3750*



Acute mammal	829.8*

mouse

MRID 00047116



Chronic mammal



102*

rat	MRID 00082748



 1For terrestrial plants data evaluating mefluidide-K, mefluidide-DEA
and mefluidide have been  bridged for the terrestrial risk assessment.

2 acute to chronic ratio from propanil extrapolation

*most sensitive species tested

    Uncertainties, Assumptions, Limitations, and Data Gaps

Ecotoxicity data for chronic risks to birds exposed to mefluidide were
not available. Therefore, EFED calculated estimates for measurement
endpoints for chronic toxicity to birds by evaluating the available data
from mammal toxicity data (acute and chronic) and extrapolating the
findings to available data for mefluidide, mefluidide-DEA and
mefluidide-K to estimate possible effects measurement endpoints.  These
extrapolated endpoints are uncertain and are not considered complete
substitutes for missing effects data. Additional information on these
estimated values are provided in Appendix E.   Submission of a chronic
bird study would quantify risks associated with exposure of mefluidide
to birds.

The magnitude of toxicity to terrestrial plants is uncertain because
only one terrestrial vegetative vigor plant study was available and
conducted on fresh weight and not dry weight as required by EPA
guidelines.  To estimate possible effects measurement endpoints for
seedling emergence, EFED assumed that EC25 toxicity values for
terrestrial plants (vegetative vigor) are equivalent to (seedling
emergence) measurement endpoints for mefluidide, mefluidide-DEA and
mefluidide-K. These estimated endpoints are uncertain and are not
considered complete substitutes for missing effects data. Additional
information on these estimated values are provided in Appendix E.
Submission of seedling emergence toxicity data based on dry weight will
quantify risks associated with exposure of mefluidide to terrestrial
plants.

The available dietary toxicity studies on avian species failed to
established definitive acute LD50 values (i.e., the lethality values
exceed the highest dose tested).  Therefore,   SEQ CHAPTER \h \r 1 use
of this value adds uncertainty and may overestimate risk to avian
species. Submission of a acute bird study with definitive LD50 values
would quantify risks associated with exposure of mefluidide to birds.

Exposure estimates for this screening level risk assessment focused on
the mefluidide, mefluidide-K and mefluidide-DEA. Information or data is
not available to evaluate degradates as a potentially significant
contributor to aquatic risk and which may affect the outcome of risk
conclusions are not considered in this risk characterization. Therefore,
this assessment may require further analysis to evaluate degradates as a
potential contributor to aquatic risk.

In all cases, EFED concluded that resulting estimated risk quotients,
had they been based on definitive effects measurement endpoints, would
not trigger concerns for acute or chronic risks to  freshwater fish,
chronic estuarine marine fish, chronic estuarine marine invertebrates,
chronic freshwater invertebrates, vascular plants (EC05 or NOAEC) and 
non-vascular plants (EC05 or NOAEC). In contrast, EFED concluded that
resulting estimated risk quotients for terrestrial organisms would
trigger concerns for chronic risks to birds and (listed and nonlisted)
terrestrial and semi aquatic plants.  

Problem Formulation  

  Problem formulation is used to establish the direction and scope of an
ecological risk assessment.  According to the Guidelines for Ecological
Risk Assessment (USEPA, 1998), problem formulation consists of defining
the problem and purpose for the assessment, and developing a plan for
analyzing and characterizing risk.  The critical components of the
problem formulation are selection of the assessment endpoints,
formulation of risk hypotheses and the conceptual model, and development
of an analysis plan.  The analysis plan and supporting rationale are
aimed at determining whether the uses of mefluidide as a growth
regulator to control ornamental and non-ornamental woody plants, ground
cover, hedges trees, turf grasses, grass and broadleaf weeds, turf on
rights-of-ways, airports, and industrial sites could result in exposures
that cause unreasonable adverse effects (risk) to non-target organisms
including those federally listed as threatened or endangered (hereafter
referred to as “listed”).  The maximum application rate for
mefluidide applied as ground spray is 1.0 lb ae/A for mefluidide-K and
mefluidide-DEA.  The maximum application rate for mefluidide, as a
granular formulation, is 0.5 lb ae/A.  Mefluidide, mefluidide-K,
mefluidide-DEA can be applied 3 times per season.

            2.1	Stressor Source and Distribution          

Environmental Fate Summary

           Based on the review of the environmental fate data,
mefluidide is moderately persistent and mobile in terrestrial
environments.  Possible routes of dissipation for mefluidide are
photodegradation on soil surfaces, microbial mediated degradation,
leaching, and runoff.  There are no aerobic aquatic metabolism data to
assess the environmental fate of mefluidide in aquatic environments.  

          Because a bridging strategy was employed to link mefluidide-K,
mefluidide-DEA, mefluidide to mefluidide acid, exposure estimates for
this screening level risk assessment focused on mefluidide acid.
Environmental fate data were not available to evaluate exposure for
mefluidide degradation products. 

2.1.2	Pesticide Type, Class and Mode of Action

          Mefluidide is an herbicide in the anilide chemical class. The
mode of action is through inhibiting plant cell division, stem
elongation and seed head development. 

2.1.3	Use Characterization

          Mefluidide is used to control ornamental and non-ornamental
woody plants, ground cover, hedges trees, turf grasses, grass and
broadleaf weeds.  It is also registered for growth control of low
maintenance turf on rights-of-ways, airports, and industrial sites. 
There are multiple active ingredient products that contain an additional
plant growth regulator and herbicides such as, paclobutrazol, imazapyr,
and imazethapyr.  Current formulations include; granular, liquid-ready
to use, and soluble concentrate/liquid.   Mefluidide can be applied as a
band treatment, broadcast, spot treatment, and spray.  The equipment
used to apply mefluidide includes; backpack sprayer, boom sprayer,
ground equipment, hand held sprayer, handgun, hose-end sprayer, power
sprayer, pressure sprayer, and spreader. 

        

 The highest use areas for mefluidide include South Carolina, North
Carolina, Virginia, West Virginia, California, Nevada, Arizona, and New
Mexico.  The maximum application rate for mefluidide applied as ground
sprays is 1.0 lb ae/A for mefluidide-K and  mefluidide-DEA.  The maximum
application rate for mefluidide, as a granular formulation, is 0.5 lb
ae/A.  Mefluidide, mefluidide-K, mefluidide-DEA can be applied 3 times
per season.  

          The uses that will be included in the re-registration
assessment are;  agricultural/farm structures/buildings and equipment,
agricultural/nonagricultural uncultivated areas/soils, airports/landing
fields, commercial industrial lawns, commercial institutional/industrial
premises/equipment (indoor/outdoor), golf course turf, hospitals/medical
institutions premises (human veterinary), household domestic dwellings
outdoor premises, industrial areas (outdoor), nonagricultural outdoor
buildings/structures, nonagricultural rights-of-way/fencerows/hedgerows,
ornamental and or shade trees, ornamental ground cover, ornamental
herbaceous plants, ornamental lawns and turf, ornamental non-flowering
plants, ornamental woody shrubs and vines,  paths/patios, paved area
(private roads/sidewalks), recreational areas, and residential lawns. 

2.2	Assessment Endpoints

           2.2.1	Ecosystems Potentially at Risk 

            Ecosystems potentially at risk are expressed in terms of the
selected assessment endpoints.  The typical assessment endpoints for
screening-level pesticide ecological risks are reduced survival and
reproductive and growth impairment for both aquatic and terrestrial
animal species.  Aquatic animal species of potential concern include
freshwater fish and invertebrates, estuarine/marine fish and
invertebrates, and amphibians.  Terrestrial animal species of potential
concern include birds, mammals, and beneficial insects.  For both
aquatic and terrestrial animal species, direct acute and direct chronic
exposures are considered.  In order to protect threatened and listed
species, all assessment endpoints are measured at the individual level. 
Although endpoints are measured at the individual level, they provide
insight about risks at higher levels of biological organization (e.g.
populations and communities).  For example, pesticide effects on
individual survivorship have important implications for both population
rates of increase and habitat carrying capacity.  

           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 have the capacity to evaluate emergence of seedlings and
vegetative vigor. The endpoints of seedling emergence (estimated
endpoint) and vegetative vigor may not address all terrestrial and
semi-aquatic plant life cycle components, it is assumed that impacts at
emergence and in active growth have the potential to impact individual
ability to compete and reproductive success. 

           For aquatic plants, the assessment endpoint is the
maintenance and growth of standing crop or biomass. Measurement
endpoints for this assessment endpoint focus on vascular plants (Lemna
gibba) and non-vascular plants (i.e., green algae) growth rates and
biomass measurements. 

          The ecological relevance of selecting the above-mentioned
assessment endpoints is as follows: (1) complete exposure pathways exist
for these receptors; (2) the receptors may be potentially sensitive to
pesticides in affected media and in residues on plants, seeds, and
insects; and (3) 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.  

	2.2.2	Ecological Effects

Each assessment endpoint requires one or more “measures of ecological
effect,” which are defined as changes in the attributes of an
assessment endpoint itself or changes in a surrogate entity or attribute
in response to exposure to a pesticide. Ecological measurement endpoints
for the screening level risk assessment are based on a suite of
registrant-submitted toxicity studies performed on a limited number of
organisms in the following broad groupings:

Birds (mallard duck and bobwhite quail), also used as a surrogate

            for terrestrial phase amphibians and  reptiles (no chronic
data submitted on birds), 

Mammals (chronic data on laboratory rat, acute data on laboratory
mouse),

Freshwater Fish (bluegill sunfish and rainbow trout), also used as a
surrogate

            for aquatic phase amphibians. (no chronic data submitted on
freshwater fish)

Freshwater invertebrates (waterflea) (no chronic data submitted on
freshwater

            invertebrates),

Estuarine/marine fish (no chronic data on estuarine/marine fish
submitted),

Estuarine/marine invertebrates (no chronic data on estuarine/marine
invertebrates

              submitted),    

Aquatic plants (freshwater and estuarine/marine).   

Terrestrial Plants ( vegetative vigor, no data submitted on seedling
emergence) 

Within each of these very broad taxonomic groups, an acute and chronic
endpoint is selected from the available test data, as the data sets
allow.  Additional ecological effects data were available for other taxa
and have been incorporated into the risk characterization as other lines
of evidence, including acute contact and oral toxicity on honeybees and
acute risk to earthworm.

	

A complete discussion of all toxicity data available for this risk
assessment and the resulting measurement endpoints selected for each
taxonomic group are included in Section 3 of this document.  A summary
of the assessment and measurement endpoints selected to characterize
potential ecological risks associated with exposure to mefluidide is
provided in Table 2.2.

Table 2.2  Summary of Assessment Endpoints and Measures of Effect for 
Mefluidide, Mefluidide-DEA1 and Mefluidide-K1

Assessment Endpoint	Measures of Effect

1.  Abundance (i.e., survival, reproduction, and growth) of individuals
and populations of birds 	1a.  Bobwhite quail acute oral LD50

1b.  Bobwhite quail and mallard duck subacute dietary LC50

1c. NOAEC estimated value

2.  Abundance (i.e., survival, reproduction, and growth) of individuals
and populations of mammals 	2a.  Laboratory mouse acute oral LD50

2b. Laboratory  rat LD50 

2c.  Laboratory rat chronic NOAEC  

3.  Survival of individuals and communities of freshwater fish and
invertebrates 	3a.  Rainbow trout and bluegill sunfish acute LC50

3b.  Water flea acute EC50

3.  NOAEC estimated values

4.  Survival of individuals and communities of estuarine/marine fish and
invertebrates 	4 a. Sheepshead minnow LC50

4 b. Eastern oyster  EC50

4 d.  NOAEC estimated values

5.  Survival of beneficial insect populations	5a.  Honeybee acute
contact LD50

6.  Maintenance and growth of individuals and populations of aquatic
plants from standing crop or biomass	6a.  Vascular plant (i.e., Lemna)
EC50 values for growth rate and biomass measurements

6b.  Non-vascular plant (i.e., Navicula) EC50 values for growth rate and
biomass measurements 

6c.EC05s estimated values for vascular and non-vascular plants

7.  Maintenance and growth of individuals and populations of terrestrial
plants from standing crop or biomass	7a.   Vegetative Vigor EC25 values
for growth rate and biomass measurements

  7.   Seedling Emergence EC25  estimated values for growth rate and
biomass measurements



LD50 = Lethal dose to 50% of the test population.

LC50 = Lethal concentration to 50% of the test population.

EC50/EC25 = Effect concentration to 50%/25% of the test population.

NOAEC = No observed adverse effect level.

LOAEC = Lowest observed adverse effect level.

1 The risk assessment strategy is designed to bridge the environmental
fate and effects data for the mefluidide-K and mefluidide-DEA to
mefluidide.  Therefore, the most sensitive endpoint for the three
mefluidide compounds (mefluidide, mefluidide-K, mefluidide-DEA) was
selected to represent all mefluidide compounds for aquatic and
terrestrial organisms in each category.  

                      Conceptual Model

	

          In order for a chemical to pose an ecological risk, it must
reach ecological receptors in biologically significant concentrations. 
An exposure pathway is 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, a release
mechanism, an environmental transport medium, a point of exposure for
ecological receptors, and a feasible route of exposure. In addition, the
potential mechanisms of transformation (i.e., which degradates may form
in the environment, in which media, and how much) must be known,
especially for a chemical whose metabolites/degradates are of greater
toxicological concern.  In this assessment, mefluidide is only assessed.
The assessment of ecological exposure pathways, therefore, includes an
examination of the source and potential migration pathways for
constituents, and the determination of potential exposure routes (e.g.,
ingestion, inhalation, and dermal absorption).  

         The source and mechanism of release of mefluidide and its salts
is ground application (spray and granular)  and is an herbicide growth
regulator used to control ornamental and non-ornamental woody plants,
ground cover, hedges trees, turf grasses, grass and broadleaf weeds.  It
is also registered for growth control of low maintenance turf on
rights-of-ways, airports, and industrial sites. The conceptual model and
subsequent analysis of exposure and effects are all based on mefluidide.
 Surface water runoff from the areas of application is assumed to follow
topography.  Additional release mechanisms include spray drift, and wind
erosion, which may potentially transport site-related contaminants to
the surrounding air.  Potential emission of volatile compounds is not
considered as a viable release mechanism for mefluidide of because of a
low Henry’s Constant (2.27E-7 atm m3/mol).  The conceptual model shown
in Figure 2.1 generically depicts the potential source of mefluidide,
release mechanisms, abiotic receiving media, and biological receptor
types.

      tc \l3 "2.	Diagram:     

           2.3.1	Conceptual Model Diagram 

                 tc \l3 "2.	Diagram:   The conceptual model employs a
bridging strategy to account for the dissociation of mefluidide-K and
mefluidide-DEA with the formation of form mefluidide acid. 
Additionally, mefluidide is in a keto-enol equilibrium with mefluidide
acid.  Therefore, the conceptual model is focused on the fate and
disposition of mefluidide acid in the environment, and mode of
application (e.g., ground spray and granular application).  A conceptual
model (Figure 2.1) was developed that represents the possible
relationships between the stressor, ecological endpoints, and the
measurement endpoints. Risk to non-target animals is also possible from
dermal contact or inhalation, but because these are not considered in
the risk assessment, they are not shown in the diagram below.  

Figure 2.1) Conceptual Model1

	

	

1 Shaded areas in the conceptual model are not assessed in the risk
assessment.

 

2.3.2	  SEQ CHAPTER \h \r 1 Terrestrial Environment

           The highest mefluidide residue levels are expected to be
located on the surface soil and on foliage (e.g., short and tall
grasses, broadleaf weeds), seeds, and insects on the treated agriculture
field immediately following ground spraying.

         While spray drift may result in transport of mefluidide to
off-target field surface soil, foliage, and insects, the highest
concentrations for these media are still expected to be those in the
treated field.  Birds, mammals, reptiles, and amphibians that ingest
foliage, insects and/or soil invertebrates from either the treated area
or from spray drift impacted areas are potentially exposed to mefluidide
residues in their diet.  Endpoints were included that represented
reduced survival, growth, and reproduction in these taxonomic groups
from dietary exposure.  Because toxicity data for reptiles and
terrestrial-phase amphibians are rarely available, risk assessment
results for birds were used as surrogates to assess risks to reptiles
and terrestrial-phase amphibians (USEPA 2004).

          These animals may also be exposed to mefluidide by other
exposure routes not accounted for in this risk assessment, such as
incidental ingestion of the soil; dermal contact with the surface of the
foliage or soil, direct impingement of sprayed material on the body at
time of application , residues on dust particulates; and/or ingestion of
residues in drinking water sources such as dew that form on plants and
soil, puddles on the field or in spray drift impacted areas at the time
of application or which form after a rain event, and/or surface water in
spray drift and runoff impacted areas.   Because of the low
octanol/water partitioning coefficient (log Kow=1.97; Kow=94.5) and a
low Henry’s Constant of (2.27E-7 atm m3/mol)  concerns for dermal and
inhalation exposure would be minimal.  Additional exposure pathways and
routes following application includes uptake of mefluidide by plants
from soil which can then be ingested by wildlife and which can then be
ingested by other wildlife (i.e., food chain transfer).   

         Mefluidide may reach off-field terrestrial or riparian/wetland
vegetation environments in spray drift at the time of application. 
Following a rain event mefluidide,  may also reach off-field terrestrial
or riparian/wetland vegetation environments in sheet and channel flow
runoff.   

2.3.3	Aquatic Environment

          Direct application of mefluidide to streams, lakes, and ponds
is forbidden by the product label.   The highest mefluidide residue
levels are expected to be located in surface waters adjacent to treated
agricultural fields at the time of application due to spray drift and/or
from runoff after a rain event.

	Because mefluidide is moderately persistent in soils and has a low
soil: water partition coefficient, there is high likelihood of transport
by runoff.  Exposure estimates for this screening level risk assessment
focused on mefluidide.  Information or data was not available to
evaluate degradates as a potentially significant contributor to aquatic
risk and is not considered in this risk characterization.  Fish,
amphibians, and aquatic invertebrates that live in aquatic environments
are potentially exposed to mefluidide residues in surface water by
direct contact of their integument (covering of the body or a part such
skin, gill membranes, cuticle, etc.) and via uptake through their gills
or integument.  Assessment endpoints were selected to assess reduced
survival, growth, and reproduction in these taxonomic groups from
combined direct contact with integument and uptake across the gill or
integument.  Because toxicity data for amphibians are rarely available,
addressing risks for fish were used as a surrogate to assess risks to
amphibians (USEPA 2004). Aquatic plants may be potentially exposed by
contact with mefluidide residues in surface water or through sorption
and uptake through roots from water compartments or across cell walls.  

         Leaching (infiltration/percolation) may result in transport of
mefluidide through the soil column into groundwater which may, in some
circumstances, flow into a surface water body.  However, groundwater and
surface water interactions are not in the exposure estimates for
evaluating ecological risks.

	Bioaccumulation of mefluidide in fish tissue is not expected due to a
low octanol water partitioning coefficient (log Kow=1.97; Kow=94.5). 
Mefluidide was not found to substantially accumulate (BCF = 0 to 1.11)
in catfish tissues during bioconcentration studies (Accession Number
226851).

2.4	Risk Hypothesis

Terrestrial vertebrates (birds, mammals, reptiles, terrestrial-phase
amphibians) are subject to adverse direct effects such as reduced
survival, growth, and reproduction when exposed to mefluidide residues
as a result of labeled use of the pesticide. 

Non-target terrestrial plants are subject to adverse effects such as
reductions in vegetative vigor and seedling emergence when exposed to
mefluidide residues as a result of labeled use of the pesticide. 

Aquatic invertebrates, fish, and amphibians in surface waters
(freshwater or saltwater) receiving spray drift or runoff from treated
fields following  mefluidide application are subject to adverse effects
such as reduced reproduction, growth, and survival when exposed to
mefluidide residues as a result of labeled use of the pesticide. 
Aquatic plants may be potentially exposed by contact with mefluidide
residues in surface water or through sorption and uptake through roots
from water compartments or across cell walls. 

3	ANALYSIS 

3.1	Use Characterization

 

         Mefluidide is used to control ornamental and non-ornamental
woody plants, ground cover, hedges trees, turf grasses, grass and
broadleaf weeds.  It is also registered for growth control of low
maintenance turf on rights-of-ways, airports, and industrial sites. 
There are multiple active ingredient products that contain an additional
plant growth regulator and herbicides such as, paclobutrazol, imazapyr,
and imazethapyr.  Current formulations include; granular, liquid-ready
to use, and soluble concentrate/liquid.   Mefluidide can be applied as a
band treatment, broadcast, spot treatment, and spray.  The equipment
used to apply mefluidide includes; backpack sprayer, boom sprayer,
ground equipment, hand held sprayer, hose-end sprayer, power sprayer,
pressure sprayer, and spreader. 

         The highest use areas for mefluidide include South Carolina,
North Carolina, Virginia, West Virginia, California, Nevada, Arizona,
and New Mexico.  The maximum application rate for mefluidide applied as
ground spray is 1.0 lb ae/A for mefluidide-K and mefluidide-DEA.  The
maximum application rates for mefluidide, as a granular formulation, is
0.5 lb ae/A.  Mefluidide, mefluidide-K and mefluidide-DEA can be applied
3 times per season.  

        The uses that will be included in the reregistration assessment
are: agricultural/farm structures/buildings and equipment,
agricultural/nonagricultural uncultivated areas/soils, airports/landing
fields, commercial industrial lawns, commercial institutional/industrial
premises/equipment (indoor/outdoor), golf course turf, hospitals/medical
institutions premises (human veterinary), household domestic dwellings
outdoor premises, industrial areas (outdoor), nonagricultural outdoor
buildings/structures, nonagricultural rights-of-way/fencerows/hedgerows,
ornamental and or shade trees, ornamental ground cover, ornamental
herbaceous plants, ornamental lawns and turf, ornamental non-flowering
plants, ornamental woody shrubs and vines,  paths/patios, paved area
(private roads/sidewalks), recreational areas, and residential lawns. 

3.2	Exposure Characterization

 

3.2.1	Environmental Fate and Transport Characterization 

          

          The risk assessment strategy is designed to bridge the
environmental fate data for the mefluidide-K, mefluidide-DEA, mefluidide
to mefluidide acid. Based on the ionic nature of mefluidide-K and
mefluidide-DEA and two unreviewed dissociation studies, mefluidide-K and
mefluidide-DEA will dissociate rapidly and completely to form mefluidide
acid.  The two unreviewed dissociation studies (MRIDs 422833-01 and
42282001) indicated mefluidide-K completely dissociated in 7 minutes and
mefluidide-DEA completely dissociated in 3 minutes.   The reported pKa
for mefluidide acid is 4.6. These data suggest complete dissociation of
mefluidide acid is expected to occur at pH~7 (Figure 2), with 50% or
greater dissociation at pHs ≤ 4.6.   Mefluidide exhibits an enol-keto
equilibrium with mefluidide acid (Figure 1).

Figure 2:  Fraction of Undissociated Mefluidide as a Function of pH

 

          Possible routes of dissipation for mefluidide are
photodegradation on soil surfaces, microbial mediated degradation,
leaching, and runoff.   Mefluidide is not prone to abiotic hydrolysis or
photolysis in sterile buffer solutions within the environmentally
relevent pH range of 4 to 9 (Accession No. 226846, MRID 42935401). 
There are data showing mefluidide undergoes rapid photodegradation (t1/2
= 2 to 3 days) in natural well water (Accession No. 226851).  On soil
surfaces, mefluidide photodegraded with a half-life of 

4.85 days.  Nine unidentified photodegradation products were detected in
the soil (MRID 43040801).   

        Mefluidide in aerobic soils degraded with a half-life of 12 days
(MRID 43162201).  The only degradation product was
5-amino-2,4-dimethyltrifluoromethanesulfonilide.  It was found at a
maximum daily concentration of 2.8% of applied mefluidide at 22 days
post-treatment. Diethanolamine is a degradation product of
mefluidide-DEA.  Non-extractable radiolabeled mefluidide residues
accounted for 32 to 37% are 366 days post-treatment.  Evolved CO2
accounted for 20.9% at 366 days posttreatment mefluidide was stable (t
1/2 > 1 year) in anaerobic environments (MRID 43120001).  

          Mefluidide has Freundlich adsorption coefficients of 0.22
(1/n=0.35) in sand, 0.14 (1/n=0.95) in silt loam soil, 0.083 (1/n=1.3)
in clay soil, and 0.11 (1/n=1.0) in sand sediment (MRID 42998201). 
There was no relationship of soil OC content and Kd.   Aged residues of
mefluidide were detected in the leachate of aged residue soil column
leaching studies (MRID 43020801). 

	Mefluidide dissipated with a half-life of 2.0 to 3.3 days in
warm-season turf soil in Georgia and 1.2 to 1.4 days in cool-season
grass soil in Missouri (MRID 43276802 and 43276801).  It was not
detected in soil samples at depths greater than 6 inches. Degradation
products were not evaluated in the field dissipation studies. 
Mefluidide dissipated from grass foliage at half-lives of 1.7 to 6.91
days (upper 90th percentile of mean half-life=4.0414 day, k=0.1715
days-1).   

         Bioaccumulation of mefluidide in fish tissue is not expected
due to a low octanol water partitioning coefficient (log Kow=1.97;
Kow=94.5).  It also was not found to substantially accumulate (BCF = 0
to 1.11) in catfish tissues during bioaccumulation studies (Accession
Number 226851). 

	 There are no environmental fate data on 5-amino-2,
4-dimethyltrifluoro-methane-sulfonilide.  Diethanolamine (DEA) degrades
rapidly (t1/2= 1.7 to 5.8 days) in aerobic soil and water environments
(MRID 43685901, 43685902, 44439401).  In contrast, DEA is persistent
(t1/2= 990 days) in anaerobic aquatic environments (MRID 43882901). 
Degradation products of diethanolamine are glycine, ethanolamine, and
CO2.

     3.2.2	Measures of Aquatic Exposure 

            3.2.2.1            Aquatic Exposure Modeling

          PRZM (3.12 beta) and EXAM (2.97.5) using PE4V01.pl (August 13,
2003) were used to estimate mefluidide residue concentrations in surface
water.  Because mefluidide use is associated with turf, the aquatic
exposure assessment was conducted using the PA and FL turf scenarios. 
These use scenarios were selected to represent of rights-of-way,
residential turf, industrial areas with turf (i.e., airports, etc.), and
golf courses.  It is important to note that all mefluidide uses (i.e.,
spot treatments, etc.) were expressed on a lbs ae/A basis.  This
approach is expected to be conservative because it assumes 100% of the
watershed is treated with mefluidide.  Application rates of mefluidide
are expressed in acid equivalence to address the bridging of
mefluidide-K, mefluidide-DEA, mefluidide to the assigned stressor (the
two forms of mefluidide: enol/keto; same molecular weight). Table 3.4
contains a summary of the various labled application rates which
suggests that the maximum rate is that of mefluidide-DEA. Foliar
dissipation half-lives for mefluidide were estimated from field
dissipation studies for warm-season and cool season grasses (MRID
43276801 and MRID 43276802).  PRZM /EXAMS input parameters for
mefluidide are shown in Table 3.1.   Estimated environmental
concentrations are shown in Table 3.2.

Table 3.1. Input Parameters for Mefluidide Acid for PRZM/EXAMS Modeling
for Aquatic Exposure Assessment

Variable Description

	Input Value 	Source of Info/Reference

Application date(s) (day/mo/yr)	15/05	Product label  

Number of Applications 	3	Label Recommendation

Application Interval (days) 	42 days	Label Recommendation

Incorporation depth (cm)	Default=0	Product label 

Application rate (kg a.e. ha-1)	Acid- 0.56

DEA salt- 1.12

K salt- 1.12

	Bead Use Closure Memorandum 

Application efficiency (fraction)	0.99	Spray Drift Task Force Data 

Spray drift fraction: For aquatic ecological exposure assessment, use
0.05 for aerial spray; 0.01 for ground spray.  For drinking water
assessment, use 0.16 for aerial 0.064 for ground spray.	0.01	Spray Drift
Task Force Data  

Foliar extraction (frac./cm rain)	0.5 is the default unless field data
is available	Default or field data 

Decay rate on foliage ( days-1)	T1/2=4.0414 days

Rate constant = 0.1715/day	Derived as 90th percentile of the mean foliar
dissipation half-life from field dissipation studies. This value also
used for terrestrial modeling (MRID 43276801 MRID 43276802).



Volatilization rate from foliage (day-1)	0.0 is the default unless field
data is available	Default or field data 

Plant uptake factor (frac. of evap)	0.0 	Default 

Aerobic soil metabolism Half-life (days)	T1/2 =36 days

Estimation = 3 X 12 days

	MRID 43162201



Anaerobic Aquatic Metabolism Half-life (days)

	Stable 	MRID 43120001



Aerobic Aquatic Metabolism Half-life (days)	72 days

Estimation= 2 X 36 days	No Data Available

Photodegradation in Water Half-life (days)	Stable	MRID 42935401

Adsorption Soil: Water Partitioning Coefficients  	0.073  (lowest
non-sand Kd)*	MRID 42998201 



Molecular Weight (grams/mole)	310.6	Calculated for Mefluidide structure

Henry’s Constant (atm m3/mol)	2.27E-7	EFED One Liner

Vapor Pressure (torr)	1E-4	EFED One Liner

Solubility (mg/L)	180	EFED One Liner

Chemical Application Method 	 2	Foliar Application

 Acid equivalence was calculated using the following equations:

Mefluidide-DEA= 310 g/mole (MW mefluidide)/415.24 g/mole (MW
mefluidide-DEA)=0.75*concentration of ai 

Mefluidide-K= 310 g/mole (MW mefluidide)/348.29 g/mole (MW
mefluidide-K)=0.89*concentration of ai

Mefluidide = 310 g/mole (MW mefluidide)/310 g/mole (MW mefluidide acid)=
1.0* concentration of ai

*there was no relationship of soil OC content.  Therefore the lowest
non-sand Kd was used.

The 1 in 10 year peak concentration for mefluidide is not expected to
exceed 10.573 μg/L. The 1 in 10 year 21-day and 60-day average
concentrations are not expected to exceed 9.623 μg/L and 8.448 μg/L,
respectively.  A major uncertainty in the assessment is the persistence
of mefluidide acid in aerobic aquatic environments.  This assessment was
conducted using an estimated aerobic aquatic half-life of  72 days
(Guidance for Chemistry and Management Practice Input Parameters for Use
in Modeling the Environmental Fate and Transport of Pesticides, Version
2, 11/7/2000).  Because this estimated half-life was designed to
approximate upper 90th percentile of the mean half-life, it is
anticipated to be a conservative estimate of mefluidide acid persistence
in aquatic environments.     

Table 3.2 Tier II Estimated Environmental Concentrations for Mefluidide
Acid

Scenario	Chemical	1 in 10 year Concentration (ug ae/L)



Peak	21 day average	60 day average

FL Turf	Mefluidide 	4.835	4.399	3.890

	  Mefluidide-DEA	10.573	9.623	8.448

	Mefluidide-K	10.573	9.623	8.448

PA Turf	 Mefluidide 	3.031	2.900	2.638

	  Mefluidide-DEA	7.054	6.738	6.265

	Mefluidide-K	7.054	6.738	6.265



 3.2.2.1            Monitoring Data

	NAWQA surface or ground water monitoring data were not found for
mefluidide, mefluidide-K and mefluidide-DEA.  

          3.2.3	Measures of Terrestrial Exposure 

 tc \l3 " Field result goes here Measures of Terrestrial Exposure 					

           The measures of exposure for terrestrial receptors in Agency
ecological risk assessments can be obtained from monitoring data, field
studies, GIS analysis, and exposure modeling.  The TREX (v.1.3.1) model
was used to generate measures of exposure for terrestrial organisms that
may come in contact with areas where mefluidide may be used. This
assessment focuses on all methods of exposure for terrestrial birds and
mammals as a result of spray and granular applications of mefluidide.
Other routes of exposure, primarily dermal, inhalation, and incidental
soil ingestion were not evaluated in this assessment.  The degree to
which these routes of exposure may be important compared to exposure
from dietary ingestion is an uncertainty.  Even though these routes of
exposure may be important to the overall risk assessment, they require
more analyses and data than those available for a screening-level
assessment.  However, inhalation is not likely to be an important
exposure pathway because of the low Henrys Constant of mefluidide
(2.27E-7 atm m3/mole).  Dermal exposure is not likely to be an important
exposure pathway because of the low octanol/water partitioning
coefficient (log Kow=1.97; Kow=94.5).   Mammalian toxicity studies for
both inhalation and dermal exposure to mefluidide indicate low acute
toxicity are summarized in Appendix E.      Incidental soil ingestion is
another possible route of exposure; available data suggests that up to
15% of the diet can consist of incidentally ingested soil depending on
the species and feeding strategy (Beyer et al, 1994).  Because
mefluidide is moderately persistent in soils, incidental soil ingestion
is a possible exposure pathway.   

          Exposure of free-ranging receptors is a function of the timing
and extent of pesticide application with respect to the location and
behavior of identified receptors.  EFED’s terrestrial exposure model
generates exposure estimates assuming that the receptor is present on
the use site at the time that pesticide levels are their highest. 

 The maximum pesticide residue concentration on food items is calculated
from both initial applications and additional applications taking into
account pesticide degradation between applications.  In this assessment,
three applications of mefluidide per season are applied as recommended
by the label.  Because mefluidide dissipates rapidly from turf foliage
(t1/2 = 4 days) and the application intervals are long (42 days), the
likelihood for carry-over of mefluidide residues between applications is
low.

          

          The current approach to screening-level terrestrial exposure
estimation does not directly relate the timing of exposure to critical
or sensitive population, community, or ecosystem processes. Therefore,
it is difficult to address the temporal and spatial co-occurrence of
mefluidide use based on application timing, application location and
sensitive ecological processes.  However, it is worth noting that
pesticides are frequently used from spring through fall, which are times
of active migrating, feeding, and reproduction for many wildlife
species.  The increased energy demands associated with these activities
(as opposed to hibernation, for example) can increase the potential for
exposure to pesticide contaminated food items since agricultural areas
can represent a concentrated source of relatively easily obtained,
high-energy food items.  In this assessment, the spatial extent of
exposure for terrestrial animal species is limited to the use area only.


         It is assumed that given the typically lower metabolic demands
of reptiles and amphibians compared to birds, exposure to birds would be
greater due to higher relative food consumption.  While this assumption
is likely true, there are no supported relationships regarding the
relative toxicity of a compound to birds and herpetofauna.  

  

                3.2.3.1	Terrestrial Exposure Modeling

 	                                             Birds and Mammals

 tc \l5 "Field result goes here Birds and Mammals 

          Estimated exposure concentrations for terrestrial receptors
were determined using

the standard screening-level exposure model, TREX (v.1.3.1)  (US
EPA,2006).  Maximum exposure levels were calculated for spray
applications of mefluidide using maximum proposed application rates,
maximum number of applications, and minimum application intervals for
all proposed uses (Table 3.3).  These exposure estimates are based on a
database of pesticide residues on wildlife food sources associated with
a specified application rate.  Essentially, for a single application,
there is a linear relationship between the amount of pesticide applied
and the amount of pesticide residue present on a given food item.  These
relationships for the various food items are determined from the Kenaga
nomogram as modified by Fletcher (Hoerger and Kenaga, 1972; Fletcher et
al., 1994). TREX (v.1.3.1) is a simulation model that, in addition to
incorporating the nomogram relationship, also includes pesticide
degradation in the estimation of EECs.   These EEC values from the TREX
model are summarized in Appendix D   

         TREX calculates pesticide residues on each type of food item on
a daily interval for one year.  A first order decay function is used to
calculate the residue concentration at each day based on the
concentrations present from both the initial and additional
applications.  The first-order rate equation is:  Ct = Cie-kt   Where Ct
is concentration at time t (days; t= 0 initially), Ci is initial
concentration after application, k is the foliar dissipation half-life,
and t is time in days.  The initial concentration, Ci, is determined by
multiplying the application rate by a constant specific to a food item. 

         

         For the ornamental turf control application for mefluidide-DEA
and mefluidide-K at 1.0 lb a.e. of pesticide per acre the upper-bound,
food item concentration (ppm) is: 240.17 for short grass, 110.08 for
tall grass, 135.09 for broadleaf plants and small insects, and 15.01 for
fruits, pods, and large insects.

   

         The dose-based EECs (mg/kg-bw) derived above are compared with
LD50 or NOAEL (mg/kg-bw) values from acceptable or supplemental toxicity
studies that are adjusted for the size of the animal tested compared
with the size of the animal being assessed (e.g., 20-gram bird).  These
exposure values are presented as mass of pesticide consumed per kg body
weight of the animal being assessed (mg/kg-bw).  EECs and toxicity
values are relative to the animal’s body weight (mg residue/kg bw)
because consumption of the same mass of pesticide residue results in a
higher body burden in smaller animals compared with larger animals.  For
birds, only acute values (LD50s) are adjusted because dose-based risk
quotients are not calculated for the chronic risk estimation.  Adjusted
mammalian LD50s and reproduction NOAELs (mg/kg-bw) are used to calculate
dose-based acute and chronic risk quotients for 15 g, 35 g, and 1000 g
mammals.  The test weight value for the acute laboratory mouse (20 g),
(Lehman,A.J.1975), replaced the (350 g) laboratory rat value in the TREX
modeled equations. Equations and calculations for adjusted LD50s
(mammals and birds) are summarized in Appendix D.   

          In many cases, an empirically determined foliar dissipation
half-life value is not available, in which case the default value of 35
days is used (Willis and McDowell, 1987).  However, a 4 day foliar
dissipation half life was estimated from field dissipation studies on
warm-season and cool season grasses (MRID 43276801 and 43276802). The
food item concentration on any given day is the sum of all
concentrations up to that day taking into account the first-order
degradation.  The initial application is on day 0 (t = 0) and runs for
365 days.  Over the 365 day run, the highest residue concentration is
used in calculations of the RQ. 

         Table 3.3 lists exposure estimates for birds and animals
obtained from TREX simulations for all the proposed uses of mefluidide
at maximum label rates.  Importantly, TREX considers exposure only in
the area where mefluidide is applied.  The underlying assumption is that
most, if not all, of the applied pesticide will settle in the use area. 
However, depending on weather conditions and type of application, spray
drift of pesticides may occur, increasing the likelihood of wildlife
exposure outside the use area.  

 

        

  Table 3.3  Estimates of Foliar residues of Mefluidide for proposed
uses (dietary based EECs)1



Use	

Application Rate lbs. ae/A

(# app / interval, days)	

Food Items	

Upper Bound EEC (mg/kg)

Ornamental Turf

Ground sprays

(Mefluidide salts only) 	1.0

3 per season

42

Day interval	

Short grass	240.17





Tall grass	110.08





Broadleaf plants/small insects	135.09





Fruits, pods, seeds, and large insects	15.01

1Predicted maximum residues for specified application rates are based on
Hoerger and Kenaga (1972) as modified by  Fletcher et al. (1994).

 The residues or estimated environmental concentrations (EECs) on food
items may be compared directly with subacute dietary toxicity data or
converted to an ingested whole body dose (single oral dose), as is the
case for small mammals and birds. Single-oral dose estimates represent,
for many pesticides, an exposure scenario where absorption of the
pesticide is maximized over a single ingestion event. Subacute dietary
estimates provide for possible effects of the dietary matrix and more
extended time of gut exposure on pesticide absorption across the gut. 
However dietary exposure endpoints are limited in their utility because
the current food ingestion estimates are uncertain and may not be
directly comparable from laboratory conditions to field conditions. The
EEC is converted to an oral dose by multiplying the EEC by the
percentage of body weight consumed as estimated through allometric
relationships. These consumption-weighted EECs (i.e. EEC equivalent
dose) are determined for each food source and body size for mammals (15,
35, and 1000 g) and birds (20, 100, and 1000 g).. The EEC equivalent
doses, formulas and calculations for adjusted body weights for birds and
mammals based on 1.0 lb ae/A  from TREX for turf are summarized in
Appendix D. 

               

A second approach for calculation of acute RQs for birds and mammals is
the LD50 per ft2 method.  This method is used to address the exposure
from granular pesticides (i.e., mefluidide).  EECs for this approach are
calculated from the application rate (lbs ae/acre) and converted to mg
ae/sq ft using the formula:  

lbs ae/acre *  (453590 mg/lb) * (acre/43560 sq ft) = mg ae/sq ft.

Because the chemical is not incorporated into the soil immediately after
application, it is assumed that 100% of the material is available to
birds and mammals (USEPA 1992). For a single application of mefluidide
at 0.5 lbs ae/acre, the EEC was calculated at 5.21 mg ae/sq ft.  This
approach can only be applied for single applications. 

                                            Terrestrial Plants

            Terrestrial and semi-aquatic plants may be exposed to
pesticides from runoff, spray drift or volatilization.  Semi-aquatic
plants are those that inhabit low-laying wet areas that may be dry at
certain times of the year. The runoff scenario in TERRPLANT 1.2.1 is:
(1) based on a pesticide's  water solubility and the amount of pesticide
present on the soil surface and its top one centimeter, (2)
characterized as "sheet runoff" (one treated acre to an adjacent acre)
for dry areas, (3) characterized as "channel runoff" (10 acres to a
distant low-lying acre) for semi-aquatic or wetland areas, and (4) based
on percent runoff values of 0.01, 0.02, and 0.05 for water solubilities
of <10, 10-100, and >100 ppm, respectively. Spray drift is assumed as
(1) 1% for ground application, (2) 5% for aerial, airblast, forced air,
and spray chemigation applications, and (3) 0% for granular
applications. Currently, EFED derives plant exposure concentrations from
a single, maximum application rate only.  EECs are calculated using the
approach outlined in the text box below.  The EECs for terrestrial
plants for a single application of Mefluidide at the maximum label rate
for ornamental turf are presented in Table 3.4

Table 3.4 EECs for Granular and Spray Applications to Terrestrial Plants
Near Mefluidide Use Areas from TerrPlant (v 1.2.1)1.  



Application Rate, lbs a.e./A

	Application method	

EECs (lbs. a.e A)





Total Loading to Adjacent Areas (sheet runoff + drift)	

Total Loading to Semi-Aquatic Areas (channelized runoff + drift)	

Drift EEC



1.0 lb ae/A

 Turf	ground spray	0.06	0.51	0.01



0.5 lb ae/A

 Turf	granular	0.03	0.255	0.0050 

 

 1 For  terrestrial plant (seedling emergence and vegetative vigor)
toxicity assessments, data evaluating mefluidide-K, mefluidide-DEA and
mefluidide  toxicity  have been bridged.  Therefore, the most sensitive
Mefluidide endpoint was selected to represent  terrestrial plants for
all application scenarios. 

a EECs for spray turf applications in this table were calculated for the
maximum labeled application rates of (1.2 lbs ae/acre)  and  (1.0 lbs
ae/acre) for mefluidide-DEA and mefluidide-K respectively.. 

1The runoff factor of 0.05 was used  based on solubility of 180

	

          Because mefluidide is a spray applied herbicide, a more
in-depth spray drift exposure assessment utilizing Tier I AgDRIFT®
(version 2.01) modeling is also provided to better characterize
potential exposure of terrestrial plants.  AgDRIFT® utilizes empirical
data to estimate off-site deposition of aerial and ground applied
pesticides, and acts as a tool for evaluating the potential of buffer
zones to protect sensitive habitats from undesired exposures. AgDrift
provided 90th percentiles estimates based on the distribution of field
measurements at 10 to 900, feet distances from the edge of field.  Table
3.5 contains EECs at several distances from the edge of the field. 

   Table 3.5  Estimated environmental concentrations (EECs) Deposition
(lb ae./acre) at Specified Buffer Distance From Edge of Field (feet) 
from off-target terrestrial exposure to Mefluidide through spray 

     drift derived from Tier I AgDRIFT® (version 2.01) at varying
distance from the edge of field.

Buffer Distance

From Edge of Field (feet)	1.0 lb ae/A

10	0.0923

20	0.0437

40	0.0218

60	0.0149

80	0.0115

100	0.0095

140	                                                     0.007

180	0.0056

200	0.0051

250	0.0042

500	0.0021

900	0.0011

* Ground application assumed conditions of low boom, ASAE  very fine to
fine droplet size, and 90th

	3.3        Ecological Effects Characterization 

             3.3.1	Aquatic and Terrestrial Effects Characterization

	

           In screening-level ecological risk assessments, effects
characterization describes the types of effects a pesticide can produce
in an animal or plant.  This characterization is based on
registrant-submitted studies and an ECOTOX database search that describe
acute and chronic effects toxicity information for various aquatic and
terrestrial animals and plants.  In addition, a review of Ecological
Incident Information System (EIIS) was conducted to further refine the
characterization of potential ecological effects. Tables 3.6, 3.7, 3.8,
summarize the most sensitive ecological toxicity endpoints for aquatic
organisms, terrestrial organisms, and aquatic and terrestrial plants,
respectively, which were used for risk characterization.  Discussions of
the effects of mefluidide-K, mefluidide-DEA and mefluidide on aquatic
and terrestrial taxonomic groups are presented below.  Concentrations of
mefluidide are expressed in acid equivalence to address the bridging of
mefluidide-K, mefluidide-DEA, mefluidide to mefluidide acid.  

Acid equivalence was calculated using the following equations:

Mefluidide-DEA= 310 g/mole (MW mefluidide)/415.24 g/mole (MW
mefluidide-DEA)=0.75 *concentration of ai

Mefluidide-K= 310 g/mole (MW mefluidide)/348.29 g/mole (MW
mefluidide-K)=0.89 *concentration of ai

Mefluidide acid = 310 g/mole (MW mefluidide)/310 g/mole (MW mefluidide
acid)= 1.0 *concentration of ai  

          Appendix E summarizes the results of all of the
registrant-submitted toxicity studies for this risk assessment.  Also, a
search of the ECOTOX database was completed on mefluidide. Results of
Ecotox search are listed in Appendix H.   For mammals, toxicity studies
are limited to the laboratory rat.  Estuarine/marine testing is limited
to a crustacean, a mollusk, and a fish.  Also, no available data was
available for reptiles or amphibians.    The risk assessment assumes
that avian and reptilian and terrestrial-phase amphibian toxicities are
similar.  The same assumption is used for fish and aquatic-phase
amphibians. The most sensitive ecological toxicity endpoints for aquatic
organisms, terrestrial organisms, and aquatic and terrestrial plants
were used for risk characterization.

 . Table 3.6, .3.7 and 3.8 provides a summary of acute and chronic
toxicity data used for risk quotient calculation for mefluidide-K,
mefluidide-DEA and mefluidide application.

Table 3.6: Summary of endpoints (LC50 or EC50, mg ae/L) for Aquatic
Toxicity used in RQ calculations for Mefluidide 1



TAXONOMIC GROUP	Acute endpoint  	Chronic endpoint	MRID/

Estimated value



Acute freshwater fish	>68.47*

Rainbow Trout

MRID

418937-02



Chronic freshwater fish

>0.267	Estimated value acute to chronic ratio



Acute freshwater inverts	>77.25*

Daphnid

MRID

418937-03



Chronic freshwater inverts

>5.54	Estimated value acute to chronic ratio



Acute estuarine/marine fish	>84.75*

Sheepshead minnow

MRID

425623-03



Chronic estuarine/marine fish

>0.267	Estimated value acute to chronic ratio



Acute estuarine/marine inverts	67*

Eastern oyster

MRID

425624-01



Chronic estuarine/marine inverts

>5.54	Estimated value acute to chronic ratio

                                       1 For fish and invertebrates data
evaluating   mefluidide-K, mefluidide-DEA and mefluidide have been
bridged

                          for the runoff risk assessment. 

                                 * most sensitive species tested

Table 3.7: Summary of endpoints (LC50 or EC50, mg ae/L) for Plant
Toxicity used in RQ calculations for  Mefluidide1



TAXONOMIC GROUP	Acute endpoint  	 NOAEC or EC05

	

Acute  vascular plant	0.515*

Lemna

MRID 435266-01

Tier I (8% growth stimulation)  

Used this value as  EC50,                                   



Vascular plant(EC05)

>0.29	Estimated value acute to chronic ratio



Acute  non-vascular plant	0.629*

Navicula

MRID 435266-05

Tier I (11.5% growth reduction)

Used this value as EC50,                                   

Non-vascular plant(EC05)

>0.786	Estimated value acute to chronic ratio

 Terrestrial Plant: 

Vegetative Vigor 

	Monocot:* Sorghum

EC25 0.105 lb ae/A

 Dicot:* Mustard  EC25  0.0054 lb ae/A	Monocot:* Sorghum

NOAEC 0.045 lb ae/A

Dicot:* Mustard     

NOAEC 0.0029 lb ae/A	MRID 435496-01

   

  Terrestrial Plant: 

Seedling Emergence 

	Monocot:

Sorghum

EC25 0.105 lb ae/A

 Dicot:* Mustard  EC25  0.0054 lb ae/A	Monocot: Sorghum

NOAEC 0.045 lb ae/A

Dicot:* Mustard     

NOAEC 0.0029 lb ae/A	Estimated value from  vegetative vigor  study MRID
435496-01

   

1For aquatic and terrestrial plants data evaluating  mefluidide-K,
mefluidide-DEA and mefluidide have been

 bridged for the terrestrial and  runoff risk assessment. 

*most sensitive species tested

Table 3.8: Summary of endpoints (LD50  or LC50 mg ae/kg) for Terrestrial
Toxicity  data used in RQ calculations for Mefluidide1



TAXONOMIC GROUP	Acute endpoint  	Chronic endpoint

	Acute Avian  	>1500*

Bobwhite quail

MRID 416019-01

Used this non-definitive endpoint as LD50

Chronic Avian 

38	Estimated value acute to chronic ratio based on mammal data

Acute Dietary Avian 	>3750*



Acute mammal	829.8* mouse

MRID 00047116



Chronic mammal



102* rat	MRID 00082748



1For terrestrial plants data evaluating  mefluidide-K, mefluidide-DEA
and mefluidide have been  bridged for the 

terrestrial  risk assessment.

                  *most sensitive species tested

 3.3.1.1	                    Aquatic Animals	 

 

                              Acute Toxicity to Freshwater Fish

         	There are no acute toxicity studies for mefluidide-K or
mefluidide for bluegill sunfish (Lepomis macrochirus) (warm water
species) or cold water species, rainbow trout (Oncorhynchus mykiss). 

	  Mefluidide-DEA is practically non-toxic to the cold water species,
rainbow trout (Oncorhynchus mykiss), with a non-definitive 96-hour LC50
of >68.47 mg ae/L and a NOAEC of 68.47 mg ae/L (MRID 418937-02). No
mortalities or sublethal signs of toxicity in rainbow trout were
observed with test material in any of the tested concentrations. The
mean measured concentrations were 15.2, 12.5, 24.4, 45.2, and 91.3 mg ai
/L. (11.4, 9.3, 18.3, 33.9 and 68.4 mg ae/L).

        	 Mefluidide-DEA is practically non-toxic to the warm water
species, bluegill sunfish (Lepomis macrochirus ) with a non-definitive
96-hour LC50 of >70.80 mg ae/L and a NOAEC of 70.80 mg ae/L (MRID
418937-01).  No mortalities or sublethal signs of toxicity in bluegill
sunfish were observed with test material in any of the tested
concentrations. The mean measured concentrations were 14.6, 19.7, 32.4,
58.3 and 94.4 mg ai /L(10.9, 14.7, 24.3, 43.7 and 70.8 mg ae/L).

        

	 The most conservative non-definitive LC50 of > 68.47 mg ae/L for
mefluidide was determined from the rainbow trout fish study with
mefluidide-DEA.  Both studies were classified as acceptable based on
guidelines §72-1(a) and §72-1(c) testing requirements. These results
are summarized in Table E1. 

             The non-definitive LC50 of >68.47 mg ae/L was selected for
evaluating freshwater fish for the runoff risk assessment of
mefluidide-K, mefluidide-DEA and mefluidide.   

                                Acute Toxicity to Estuarine/ Marine Fish

          Mefluidide is practically non-toxic to sheepshead minnow
(Cyprinodon variegatus), with a non-definitive 96-hour LC50 of >130 mg
ae/L and a NOAEC of 130 mg ae/L (MRID 425624-03). No mortalities or
sublethal signs of toxicity in sheephead minnow were observed with test
material in any of the tested concentrations. The mean measured
concentrations were 19, 28, 45, 80, and 130 mg ae /L.

         Mefluidide-DEA is practically non-toxic to sheepshead minnow
(Cyprinodon variegatus), with a non-definitive 96-hour LC50 of >84.75 mg
ae/L and a NOAEC of 84.75 mg ae/L (MRID 425623-03). No mortalities or
sublethal signs of toxicity in sheephead minnow were observed with test
material in any of the tested concentrations. The mean measured
concentrations were 16, 28, 34, 68, and 113 mg ai /L (12, 21, 25.5, 51
and 84.7 mg ae/L).

	  

         The non-definitive LC50 of >84.75 mg ae/L was selected for
evaluating estuarine marine fish exposed to mefluidide-K, mefluidide-DEA
and mefluidide for the runoff risk assessment .   

                    

                  Chronic Toxicity to Freshwater Fish and
Estuarine/Marine Fish

           No studies evaluating the chronic toxicity of mefluidide to
freshwater or estuarine/marine fish have been submitted to the Agency. 
Due to lack of submitted chronic studies for freshwater fish estimated
acute to chronic ratios (ACRs) were derived from the propanil analog. 
Therefore, the chronic NOAEC of > 0.267 mg ae/L value for freshwater
fish was estimated from the propanil analog. Calculations and endpoints
used to determine ACRs are summarized in Appendix E

        Mefluidide is practically non-toxic to estuarine marine fish and
slightly toxic to estuarine marine invertebrates on an acute basis.  The
lowest acute LC50 values reported for estuarine marine fish and
invertebrates are >84.75 and (57.75 and 67 mg ae/L), respectively. 

There are insufficient data to establish a definitive toxicity endpoint
for estuarine/marine fish and invertebrate chronic effects for
mefluidide and DEA salt acid equivalents for mefluidide. There is also
little available data to compare to other anilide herbicides for this
taxonomic group   For the purposes of this risk assessment, it was
assumed that estuarine marine fish were at least as sensitive as
freshwater fish  in terms of chronic toxicity.  Therefore, the
estimated endpoint for freshwater fish (NOAEC >0.267 mg ae/L) was used
to estimate a chronic effects endpoint for estuarine/marine fish.  The
multiple assumptions involving extrapolations across species (fathead
minnow and rainbow trout), data from a single analog (propanil) and
across freshwater and estuarine/marine conditions suggests that this
estimate maybe highly uncertain.  (For more information, please see
source data in Appendix E for other anilide herbicide).

                              Acute Toxicity to Freshwater Invertebrates

	Mefluidide-DEA is practically non-toxic to the waterflea (Daphnia
magna), with a non-definitive 48-hr EC50 >77.25mg ae/L and a NOAEC of
77.25mg ae/L (MRID 418937-03).  Mean measured concentrations were 16.2,
28.0, 41.8, 68.0 and 103 mg ai/L. (12.1, 21, 31.3, 51 and 77.2 mg ae/L).
 One mortality for freshwater invertebrates occurred at the 51mg ae/L.
This death was not considered treatment related due to 100% survival in
the 77.2 mg ae/L concentration.  This study is classified as acceptable
according to the §72-2 guideline requirements.

           The non-definitive LC50 of  77.25 mg ae/L was selected for
evaluating freshwater invertebrates exposed to mefluidide-K,
mefluidide-DEA, and mefluidide for the runoff risk assessment.  

The results of these tests are summarized in Appendix E, Table E2.   

      

            

                             Acute Toxicity to Estuarine/ Marine
Invertebrates

	Mefluidide is practically non-toxic to the estuarine marine mysid
(Mysidopsis bahia), with a 96-hr EC50 133 mg ae/L and a NOAEC of 47 mg
ae/L (MRID 425624-02). Mean measured concentrations were 16.2, 28.0, 47,
80 and 133 mg ae/L.  One mortality for estuarine marine invertebrates
occurred at the 28 mg ae/L treatment level. However, this death was not
considered treatment related.  By the end of the study 50% mortality had
occurred in the 133 mg ae/L treatment group.  This study is classified
as acceptable according to the §72-3 guideline requirements.

           Mefluidide-DEA is practically non-toxic to the estuarine
marine mysid (Mysidopsis bahia), with a 96-hr EC50 >94.5mg ae/L and a
NOAEC of 31.5 mg ae/L (MRID 425623-02). Mean measured concentrations
were 15, 26, 42, 75 and 126 mg ai/L

(11.25, 19.5, 31.5, 56.2 and 94.5 mg ae/L).  One mortality to estuarine
marine mysid occurred at the 52.2 mg ae/L treatment level and 2
mortalities occurred in the 94.5 mg ae/L treatment level.  No other
mortalities or sublethal effects occurred during the test. This study is
classified as acceptable according to the §72-3 guideline requirements.


 

           Mefluidide is practically slightly toxic to the estuarine
marine eastern oyster (Crassostrea virginica ) for shell deposition,
with a 96-hr EC50 67  mg ae/L and a NOAEC of <12 mg ae/L (MRID
425624-01). Mean measured concentrations were 12, 21, 34, 55 and 99 mg
ae/L.   There were no mortalities or observations of sublethal effects
during the test.  The length measurements indicated shell growth
inhibition ranging from 16.7% in the 12 mg ae/L group to 73% in the 99
mg ae/L This study is classified as acceptable according to the §72-3
guideline requirements.

           Mefluidide-DEA is slightly toxic to the estuarine marine
eastern oyster (Crassostrea virginica) for shell deposition with a 96-hr
EC50 57.75 mg ae/L and a NOAEC of <10.5 mg ae/L (MRID 425623-01). Mean
measured concentrations were 14, 23, 37, 61 and 98 mg ai/L.(10.5, 17.25,
27.75, 45.75 and  73.5 mg ae/L). The length measurements indicated shell
growth inhibition ranging from 11% in the 10.5 mg ae/L group to 71% in
the 73.5 mg ae/L. This study had 3 study deficiencies which results in a
supplemental study.  There was less than the recommended shell growth in
the control animals, contamination was present in the control groups and
the flow rate in the test chambers was less than recommended. However,
adequate dose response occurred in the study. Contamination of the
control solutions was evident, but this contamination was intermittent
and well below the NOEC.  Also the results of the study correlate well
with the oyster shell deposition study done with TGAI (MRID 425624-01). 
 This study is classified as supplemental according to the §72-3
guideline requirements.   

      

           The EC50 of 67 mg ae/L was selected for evaluating estuarine
marine invertebrates exposed to mefluidide-K, mefluidide-DEA and
mefluidide for the runoff risk assessment.   The most sensitive endpoint
EC50 57.75 mg ae/L was not selected due to study deficiencies as
described above.

 

The results of these tests are summarized in Appendix E, Table E2.

                             Chronic Toxicity to Estuarine/Marine
Invertebrates

           No studies were submitted to the Agency evaluating the
chronic toxicity of  mefluidide-DEA, mefluidide-K and mefluidide to
freshwater and estuarine marine invertebrates.   Due to lack of
submitted chronic studies for freshwater invertebrates estimated acute
to chronic ratios (ACRs) were derived from the Propanil analog. 
Therefore, the chronic NOAEC of >5.54 mg ae/L value for freshwater
invertebrates was estimated from the propanil analog. Calculations and
endpoints used to determine ACRs are summarized in Appendix D

There are insufficient data to establish a definitive toxicity endpoint
for estuarine/marine invertebrate chronic effects for the acid and DEA
salt acid equivalents for mefluidide. There is also little available
data to compare to other anilide herbicides for this taxonomic group  
For the purposes of this risk assessment, it was assumed that estuarine
marine invertebrates were at least as sensitive as freshwater
invertebrates  in terms of chronic toxicity.  Therefore, the estimated
endpoint for freshwater invertebrates (NOAEC >5.54 mg ae/L) was used to
estimate a chronic effects endpoint for estuarine/marine invertebrates. 
The multiple assumptions involving extrapolations with data from a
single analog (Propanil) and across freshwater and estuarine/marine
conditions suggests that this estimate maybe highly uncertain (see
source data in Appendix E for other anilide herbicide). 

                              Aquatic Plant Toxicity

 

No studies were submitted to the Agency evaluating the acute toxicity of
mefluidide-K and mefluidide to aquatic plants.   For mefluidide-DEA, the
dosage tested for Lemna gibba (freshwater vascular plant) was 0.515 mg
ae/L with stimulation of 8%  frond growth for a  Tier I study (MRID
435266-05).  The dosage tested for Selenastrum capricornutum was 0.561
mg ae/L caused an 8% growth reduction in the exposed algal population
for a Tier I study  (MRID 435266-03). For the other two species of
freshwater non-vascular plants (i.e., Navicula pelliculosa and Anabaena
flos-aquae), Tier I studies resulted in (0.629 mg ae/L) 11.5% growth
reduction and (0.543 mg ae/L) 4.3% growth reduction, respectively (MRIDs
435266-01 and 435266-04).  For the estuarine/marine non-vascular plant
(Skeletonema costatum), the dosage tested was 0.575 mg ae/L which
resulted in no adverse effects for this Tier I study (MRID 4435266-02).
All of the above Tier I studies are classified as acceptable according
to the 122-2 guideline requirements.  

           

	The experimental procedures and dose calculation procedures for the
range finding tests, for the above Tier I studies are basically the same
as are those for the final or definitive studies. The results of the
definitive or final aquatic plant tests are one order of magnitude more
toxic than the range finding tests.  The results for both sets of
studies do not show any inhibition levels above 50%.  

Due to lack of submitted aquatic plant studies for vascular and
non-vascular plants, NOAEC or EC05 values were estimated acute to
chronic ratios (ACRs) from the propanil analog.  An EC05 was estimated
at >0.029 value for vascular plants and >0.786 mg ae/L for non-vascular
plants. The multiple assumptions involving extrapolations with data from
a single analog (propanil) suggests that this estimate maybe highly
uncertain.  Calculations and endpoints used to determine ACRs are
summarized in Appendix E.  

Peak EECs from the PRZM/EXAMS turf modeled scenarios ranged from
0.003031 mg ae/L to 0.010573 mg ae/L.  The Tier I study for Navicula
pelliculosa resulted in (0.629 mg ae/L) 11.5% growth reduction.  In
contrast, the Tier I study for Lemna gibba resulted in (0.515 mg ae/L)
8% frond growth.      

The results of the above studies and the range-finding tests are
provided in Table E4.

	 

Terrestrial Animals

      Acute oral gavage bird 

	For mefluidide, an acute single-dose oral toxicity study was performed
using the bobwhite quail (Colinus virginianus). The 58.2% ai compound
was adjusted to 100% ai at dosing. Thirty birds were used at one dose
level of 2000 mg ae/ kg.    The LD50 value was >2000mg ae/kg-bw.  The
results of this study categorize mefluidide as practically non-toxic to
birds on a acute oral basis. However, this study is classified as
Supplemental for an avian dietary LD 50 study because it is unclear what
material (TGAI, formulated product, or formulation intermediate) was
tested.   No statistics were performed due to lack of mortality and no
signs of toxicity were observed. (MRID 416021-01) 

	For mefluidide-DEA, an acute single-dose oral toxicity study was
performed using the bobwhite quail (Colinus virginianus). The 21.5% ai
compound was adjusted to 100% ai at dosing. Thirty birds were used at
one dose level of 1500 mg ae/ kg.    The LD50 value was >1500mg
ae/kg-bw. The results of this study categorize mefluidide-DEA as
practically non-toxic to birds on an acute oral basis. However, this
study does not fulfill the requirement in support of registration and is
classified as Supplemental for an avian dietary LD 50 study because it
is unclear what material (TGAI, formulated product, or formulation
intermediate) was tested.   No statistics were performed due to lack of
mortality and no signs of toxicity were observed (MRID 416019-01).

The above studies are summarized in Table E5.

                    Sub acute (dietary) Toxicity to Birds	

	For mefluidide, one dietary toxicity study was performed using the
mallard duck (Anas platyrhynchos). The 58.2% ai compound was adjusted to
100% ai at dosing. Thirty birds were used at one dose level of 5000 mg
ae/ kg diet.   In the mallard duck study, the non-definitive LC50 was
>5000 mg ae/kg diet.  The results of this study categorize mefluidide as
practically non-toxic to birds on a dietary basis. However, this study
is classified as Supplemental for an avian dietary LC50 study because it
is unclear what material (TGAI, formulated product, or formulation
intermediate) was tested. No statistics were performed due to lack of
mortality and no signs of toxicity were observed. (MRID416021-03) 

	For mefluidide, one dietary toxicity study was performed using the
bobwhite quail (Colinus virginianus). The 58.2% ai compound was adjusted
to 100% ai at dosing. Thirty birds were used at one dose level of 5000
mg ae/ kg diet.  In the bobwhite quail study, the non-definitive LC50
was >5000 mg ae/kg diet.   The results of this study categorize
mefluidide as practically non-toxic to birds on a dietary basis.
However, this study is classified as Supplemental for an avian dietary
LC50 study because it is unclear what material (TGAI, formulated
product, or formulation intermediate) was tested.  No statistics were
performed due to lack of mortality and no signs of toxicity were
observed. (MRID 416021-02).

For mefluidide-DEA, one dietary toxicity study was performed using the
mallard duck (Anas platyrhynchos). The 21.5% ai compound was adjusted to
100% ai at dosing. Thirty  birds were used at one dose level of 3750mg
ae/ kg diet.    In the mallard duck study, the non-definitive LC50 was
>3750 mg ae/ kg diet.  The results of this study categorize mefluidide
as practically non-toxic to birds on a dietary basis. However, this
study is classified as Supplemental for an avian dietary LC50 study
because it is unclear what material (TGAI, formulated product, or
formulation intermediate) was tested. No statistics were performed due
to lack of mortality and no signs of toxicity were observed.
(MRID416019-03) 

	For mefluidide-DEA, one dietary toxicity study was performed using the
bobwhite quail (Colinus virginianus). The 21.5% ai compound was adjusted
to 100% ai at dosing. Thirty birds were used at one dose level of 3750
mg ae/ kg diet.     In the bobwhite quail study, the non-definitive LC50
was >5000 mg ae/ kg diet.  The results of this study categorize
mefluidide-DEA as practically non-toxic to birds on a dietary basis.
However, this study is classified as Supplemental for an avian dietary
LC50 study because it is unclear what material (TGAI, formulated
product, or formulation intermediate) was tested. No statistics were
performed due to lack of mortality and no signs of toxicity were
observed. (MRID416019-02) 

      

    The LC50 of 3750 mg ae/kg diet was selected for evaluating birds on
a sub acute dietary basis exposed to mefluidide-K, mefluidide-DEA and
mefluidide for the terrestrial risk assessment.

	The above studies were classified as supplemental according to
Guideline §71-2 requirement for subacute avian dietary testing and are
summarized in Table E6.

                              Chronic Toxicity to Birds 

           No studies were submitted to the Agency evaluating the
chronic toxicity of mefluidide-DEA, mefluidide-K and mefluidide to
birds.  There are insufficient data to establish a definitive toxicity
endpoint for chronic effects to birds for the acid and DEA salt acid
equivalents for mefluidide. There is also no available chronic avian
data from other anilide herbicides for this taxonomic group to
extrapolate acute to chronic ratios.   For the purposes of this risk
assessment, it was assumed that birds are similar in toxicity responses
as mammals in terms of chronic toxicity.  Therefore, acute to chronic
ratios (ACRs) were derived from mefluidide laboratory rat and laboratory
mouse data to determine the estimated chronic NOAEC of 38 mg ae/kg value
for birds. Calculations and endpoints used to determine ACRs are
summarized in Appendix E.  The assumptions involving extrapolations with
data from different terrestrial species suggests that this estimate
maybe highly uncertain. 

                              Acute Oral Toxicity to Mammals    

	Wild mammal testing is required on a case-by-case basis, depending on
the results of lower tier laboratory mammalian studies, intended use
pattern and pertinent environmental fate characteristics.  In most
cases, rat or mouse toxicity values obtained from the Agency's Health
Effects Division (HED) substitute for wild mammal testing.

  An acute oral toxicity study with the laboratory mouse for mefluidide
resulted in a LD50 value of 829.8 ae mg/kg bw (MRID 00047116).  This
study is acceptable and satisfies guideline requirements for acute oral
toxicity in rodents (81-1).  Mefluidide is toxicity Category II. The
data are summarized in Table E9. 

Additional acute oral toxicity studies  with the laboratory mouse and
laboratory rat  resulted in LD50 values based on mefluidide ranged from
1920.2 ae mg/kg bw to >4000 ae mg/kg bw. Mefluidide toxicity was
classified as Category III .

The LD50 of 829.8 mg ae/kg bw was selected for evaluating mammals on a
acute dietary basis exposed to mefluidide-K, mefluidide-DEA and
mefluidide for the terrestrial risk assessment.  

 The data are summarized in Table E9. 

                 Subchronic and Developmental/Chronic Toxicity to
Mammals

 Multi-Generation Reproduction Laboratory Rat Toxicity Study 

           In a three-generation reproduction study (MRID 00082748), MBR
12325 (Mefluidide; 93% a.i., Lot #25) was administered in the diet to 20
male and 40 female Charles River CD® rats/dose group at dose levels of
0, 600, 1800, or 6000 ppm (equivalent to Males/Females - 0/0, 34/60,
102/183, and 346/604 mg ae/kg bw/day) 

There were no effects on food consumption, organ weights, gross
pathology, or histopathology.  Numerous absolute and relative (to bw)
organ weights in the 6000 ppm parents were significantly (p<0.05)
different from the controls, however, none of these differences were
corroborated by any macroscopic or microscopic findings indicating these
decreases were most likely not related to treatment.  Thus, it is likely
that they were attributable to decreased body weights at this dose. 

         The only deaths included one 6000 ppm F1 female, one 6000 ppm
F2 male, and one 1800 ppm F2 female.  It was stated that macroscopic and
microscopic findings in these animals were unremarkable.  Therefore,
these deaths were considered incidental and were not treatment related. 
At 6000 ppm, body weights were decreased by 1-8% in males and 1-12% in
females throughout the study in the P generation, attaining significance
(p<0.05) at Week 18 in the males and Weeks 8, 18, 19, and 27 in the
females.  In the F1 generation at this dose, body weights were decreased
throughout the study in the males (decr. 13-21%) and females (decr.
10-21%), attaining significance (p<0.01) at Weeks 27, 37, and 56 in both
sexes.  Similarly in the F2 generation, body weights were decreased
throughout the study in the 6000 ppm males (decr. 14-21%) and females
(decr. 11-23%), attaining significance (p<0.01) at Weeks 57, 66, and 85
in both sexes. At 1800 ppm, only minor and infrequent decreases in body
weights were noted.  There were no treatment-related findings at 600
ppm.

          The parental systemic LOAEL is 6000 ppm (346/604 mg ae/kg
bw/day in males/females), based on decreased body weights in both sexes
in all generations.  The parental systemic NOAEL is 1800 ppm (102/183 mg
ae/kg bw/day in males/females). This study is acceptable/guideline and
satisfies the guideline requirement for a three-generation reproductive
study (OPPTS 870.3800; OECD 416) in rats.

Developmental Toxicity Study in Laboratory Rats:

	    In a developmental toxicity study (MRID 42026102), mefluidide-DEA
(28.78% a.i. Lot # JB0624)) in distilled water was administered to
pregnant Sprague Dawley Crl:CD BR VAF/Plus (25/dose) by gavage at dose
levels of 0, 50, 200 or 400 mg/kg bw/day (adjusted doses for 100 %
purity were 0, 14, 58, or 115 mg/kg/day, respectively) from days 6
through 15 of gestation. Animals were checked daily for clinical signs,
mortality.  Body weights were measured on gestation day 0, 6, 9, 12, 16
and 20.  Unscheduled deaths, scheduled sacrifice and c-sections were
subjected to gross necropsy examination. Each fetus was examined for
external/visceral/skeletal anomalies, sexed and then weighed. 	Evidence
of maternal toxicity included transient clinical signs (tremors, dark
material around the nose, urine stain and reddish vaginal discharge),
decreased body weight gain (11-61%), decreased food consumption and
mortality (2/25 females) observed at the 400 mg ai/kg/day levels  No
external malformations or developmental variations were observed
associated with any fetus. Fetal toxicity was manifested by increase in
the number of early resorptions which resulted in increase in mean
postimplantation loss at 400 mg ai/kg/day dose. 

	       The maternal NOAEL was 200 mg ai/kg/day (adjusted to 58
mg/kg/day) and the LOAEL at 400 mg ai/kg/day (adjusted to 115 mg/kg/day)
based on clinical signs (tremors, dark material around the nose, urine
stain and reddish vaginal discharge), decreased body weight gain,
decreased food consumption and mortality (2/25 females).  	

	      The developmental toxicity NOAEL was 200 mg/kg/day (adjusted to
58 mg/kg/day), the LOAEL was 400 mg ai/kg/day (adjusted to 115
mg/kg/day) based on increase in the number of early resorptions and
increase in mean postimplantation loss. 

The NOAEC of 102 mg ae/kg bw was selected for evaluating mammals on a
chronic/reproductive basis exposed to mefluidide-K, mefluidide-DEA and
mefluidide for the terrestrial risk assessment.  

	  This developmental toxicity study is classified acceptable/Guideline
and it does satisfy the guideline requirement for a developmental
toxicity study (OPPTS 870.3700; OECD 414) in the rat.

                                   Acute Toxicity to Non-target Insects
(Honey Bee)

          Acute contact toxicity of mefluidide-DEA on the honey bee
(Apis mellifera) was tested and the data are summarized in Table E8.  In
the acute contact test, the non-definitive LD50 value was >18.75 µg
ae/bee and the NOAEC was 9.37µg ae/bee. Mortality ranged between 6 and
14% with doses 1.6, 3.1, 6.3, 12.5 and 25 ug ai/bee (1.2, 2.3, 4.7, 9.3,
and 18.75 ug ae /bee).  Mortality at the four lowest test levels was
determined to be non-treatment related.  Mortality at the highest level
was 14%.  Mefluidide-DEA is categorized as practically non-toxic to
honeybees on an acute contact basis. This study is classified as
acceptable according to guideline 141-1 (MRID 425628-01). 

          Acute contact toxicity of mefluidide-K on the honey bee (Apis
mellifera) was tested and the data are summarized in Table E8.  In the
acute contact test, the non-definitive LD50 value was >22.25µg ae/bee
and the NOAEC was 22.25µg ae/bee. Mortality ranged between 6 and 14%
with doses 1.6, 3.1, 6.3, 12.5, 25 ug ai/bee (1.4, 2.7, 5.6, 11.1 and
22.25 ug ae/bee).  Mortality at all treatment levels was determined not
to be treatment related since clinical observations were similar between
control and treated bees and the surviving bees at the lowest dosage
appeared normal throughout the test.  Mefluidide-K is categorized as
practically non-toxic to honeybees on an acute contact basis. This study
is classified as acceptable according to guideline 141-1 (MRID
425628-02).

                                   Terrestrial Plant

            SEQ CHAPTER \h \r 1  A Tier II vegetative vigor study was
conducted for ten species using mefluidide-DEA and the data are
summarized in Tables E12 and E13.  For the vegetative vigor study, the
most sensitive monocot was sorghum with an EC25 of 0.105 lbs ae/A and a
NOAEC of 0.045 lbs ae/A, and the most sensitive dicot was mustard, with
an EC25 of 0.00547 lbs ae/A and a NOAEC of 0.0029 lbs ae/acre.  For both
monocots and dicots, the most sensitive parameter was shoot fresh
weight. Symptoms of toxicity included stunting, chlorosis, necrosis and
distortion. This study was originally classified as acceptable, however
this study will be reviewed for a possible classification of
Supplemental  because this study  was based on fresh weight  instead of
dry weight which is required  according to guideline 123-1 (MRID
435496-01). 

           Seedling emergence toxicity data was not available and data
was not available from other anilide analogs to derive EC25 values. To
estimate possible effects measurement endpoints for seedling emergence,
EFED assumed that EC25 toxicity values for vegetative vigor are equal to
seedling emergence measurement endpoints for mefluidide, mefluidide-DEA
and mefluidide-K.  Therefore, the most sensitive seedling emergence EC25
estimated values are 0.105 and 0.0054 lb ae/acre for monocots and
dicots, respectively.  The NOEC estimated values for seedling emergence
are 0.045 and 0.0029 lb ae/acre for monocots and dicots, respectively.  
  SEQ CHAPTER \h \r 1 

                               Earthworms

 

         No earthworm studies were submitted to the Agency.   However,
Ecotox data indicates that mefluidide is non-toxic to earthworms (Ref
#39542 Potter DA; Spicer PG;Redmond CT; Powell AJ (1994) Toxicity of
Pesticides to Earthworms in Kentucky Bluegrass Turf). Two evaluations
were conducted in the spring and the fall of 1992.  Earthworm
populations were sampled at 1 and 3 weeks after treatment.  The
application rate of mefluidide applied to the plots were 0.56 ai/ha of
Embark 2S which resulted in 0% and 17 % reduction of earthworms in the
spring and fall respectively after the 3 week treatments.

                                SEQ CHAPTER \h \r 1 Review of Incident
Data

            A review of the EIIS database for ecological incidents
involving mefluidide, mefluidide-DEA and mefluidide-K was completed on
December 28, 2006.  There were no incidences reported for mefluidide,
mefluidide-DEA and mefluidide-K in the EIIS database.

 

Incident reports submitted to EPA since approximately 1994 have been
tracked by assignment of I #s in an Incident Data System (IDS),
microfiched, and then entered to a second database (in EFED), the
Ecological Incident Information System (EIIS).   An effort has also been
made to enter information to EIIS on incident reports received prior to
establishment of current databases.  Incident reports are often not
received in a consistent format (e.g., states and various labs usually
have their own formats), may involve multiple incidents involving
multiple chemicals in one report, and may report on only part of a given
incident investigation (e.g., residues). 

					

	It is believed that the EFED database contains reports of only a small
portion of plant and animal wildlife incidents that actually occur as a
result of pesticide use.  Mortality incidents must be seen, reported,
investigated, and had investigation reports submitted to EPA to have the
potential to get entered into a database.  Incidents often are not seen,
especially if the affected organisms are inconspicuous or few people are
systematically looking, for example.   Incidents seen may not get
reported to appropriate authorities capable of investigating the
incident because the finder may not know of the importance of reporting
incidents, may not know who to call, or may not feel they have the time
or desire to call, for example.  Incidents reported may not be
investigated if resources are limited or may not get investigated
thoroughly.  Reports of investigated incidents often do not get
submitted to EPA, since reporting by states is voluntary and some
investigators may believe that they don’t have the resources to submit
incident reports to EPA.

                                        

                                SEQ CHAPTER \h \r 1 Review of ECOTOX
Data  SEQ CHAPTER \h \r 1 

             A search of the ECOTOX from a Duluth review was completed
on 7/ 5/06 for mefluidide.  Six studies were reviewed with reference
numbers 39542, 71019, 74741, 82489, 82719 and 82721. Studies with
reference numbers 71019, 74741, 82489 were not incorporated in the
assessment. The references to the above referenced studies and studies
that were not accepted by OPP are posted in Appendix H.

         Ecotox data indicates that mefluidide is non-toxic to
earthworms (Ref #39542 Potter DA; Spicer PG; Redmond CT; Powell AJ
(1994) Toxicity of Pesticides to Earthworms in Kentucky Bluegrass Turf).
Two evaluations were conducted in the spring and the fall of 1992. 
Earthworm populations were sampled at 1 and 3 weeks after treatment. 
The application rate of mefluidide applied to the plots were 0.56 ai/ha
of Embark 2S which resulted in 0% and 17 % reduction of earthworms in
the spring and fall respectively after the 3 week treatments.
(ref#39542)

           Ecotox data indicates that mefluidide is non-toxic to grazing
cattle based on weight gain. Twelve Hereford heifers were used in a
grazing experiment to determine intake and digestibility of tall fescue
forage treated with mefluidide.  Additionally, steer and heifer
performance were evaluated after grazing tall fescue pastures or
consuming hay harvested from pastures treated with mefluidide. Two
forage plots were sprayed with 0.28kg ai/ha when tall fescue herbage was
10 cm in height. Steers grazing mefluidide–treated herbage had greater
total weight gains than untreated fields during a 168 d study (86 vs 69
kg).  Heifers fed hay harvested from mefluidide treated pastures also
exhibited similar improvements in gain (49 vs 38 kg) because of
increased forage consumption (8.3 vs. 7.3 kg/d) greater forage OM
digestibility (65 vs. 61%). Greater weight gains were attributed to a
increased nitrogen content, lowered NDF neutral detergent fiber content
(NDF) and increased OM digestibility from herbage available( ref#82719)
A similar study (ref#82721)  for effects of mefluidide on grazing
cow–calf performance on smooth brome pastures also  resulted in
improved calf performance on treated mefluidide fields with 0.28kg ai/ha
of mefluidide.  Mefluidide sprayed on fields produced 26 kg/ha more cow
gain than the controlled smooth brome pastures.

4	RISK CHARACTERIZATION

   

Risk characterization is the integration of exposure and effects
characterization to determine the ecological risk from the use of
mefluidide and the likelihood of effects on aquatic life, wildlife, and
plants based on varying pesticide-use scenarios.  The risk
characterization provides a estimation and a description of the risk;
articulates risk assessment assumptions, limitations, and uncertainties;
synthesizes an overall conclusion; and provides the risk managers with
information to support regulatory decision making.

                        4.1.      Risk Estimation - Integration of
Exposure and Effects Data tc \l2 "Field result goes here Risk Estimation
- Integration of Exposure and Effects Data 

            Results of the exposure and toxicity effects data are used
to evaluate the likelihood of adverse ecological effects on non-target
species.  For the assessment of mefluidide risks, the risk quotient (RQ)
method is used to compare exposure and toxicity values.  Estimated
environmental concentrations (EECs) are divided by acute and chronic
toxicity values. The resulting RQs are compared to the Agency’s levels
of concern (LOCs).  These LOCs are the Agency’s interpretive policy
and are used to analyze potential risk to non-target organisms and the
need to consider regulatory action.  These criteria are used to indicate
when a pesticide’s use as directed on the label has the potential to
cause adverse effects on non-target organisms.  

           A summary of toxicity values used to calculate RQs is
provided in Table 4.1 and 4.2 and 4.3 more detailed discussion of
mefluidide toxicity can be found in section 3.3 and Appendix D.  

Table 4.1: Summary of endpoints (LC50 or EC50, mg ae/L) for Aquatic
Toxicity used in RQ calculations for Mefluidide 1



TAXONOMIC GROUP	Acute endpoint  	Chronic endpoint	MRID/

Estimated value



Acute freshwater fish	>68.47*

Rainbow Trout

MRID

418937-02



Chronic freshwater fish

>0.267	Estimated value acute to chronic ratio



Acute freshwater inverts	>77.25*

Daphnid

MRID

418937-03



Chronic freshwater inverts

>5.54	Estimated value acute to chronic ratio



Acute estuarine/marine fish	>84.75*

Sheepshead minnow

MRID

425623-03



Chronic estuarine/marine fish

>0.267	Estimated value acute to chronic ratio



Acute estuarine/marine inverts	67*

Eastern oyster

MRID

425624-01



Chronic estuarine/marine inverts

>5.54	Estimated value acute to chronic ratio

                                      1 For fish and invertebrates data
evaluating   mefluidide-K,  mefluidide-DEA and mefluidide  have been
bridged 

                          for the runoff risk assessment. 

                          *most sensitive species

Table 4.2: Summary of endpoints (LC50 or EC50, mg ae/L) for Plant
Toxicity used in RQ calculations for  Mefluidide1



TAXONOMIC GROUP	Acute endpoint  	 NOAEC or EC05  

	

Acute  vascular plant	0.515*

Lemna

MRID 435266-01

Tier I(8% growth stimulation)  

Used this value as    EC50,                                   



Vascular plant (EC05 )

>0.29	Estimated value acute to chronic ratio



Acute  non-vascular plant	0.629*

Navicula

MRID 435266-05

Tier I(11.5% growth reduction)

Used this value as    EC50,                                   

 Non-vascular plant ( EC05

>0.786	Estimated value acute to chronic ratio

 Terrestrial Plant: 

Vegetative Vigor 

	Monocot:* Sorghum

EC25 0.105 lb ae/A

 Dicot:* Mustard  EC25  0.0054lb ae/A	Monocot:* Sorghum

NOAEC 0.045 lb ae/A

Dicot:* Mustard     

NOAEC 0.0029 lb ae/A	MRID 435496-01

   

  Terrestrial Plant: 

Seedling Emergence 

	Monocot:

Sorghum

EC25 0.105 lb ae/A

 Dicot:* Mustard  EC25  0.0054lb ae/A	Monocot: Sorghum

NOAEC 0.045 lb ae/A

Dicot:* Mustard     

NOAEC 0.0029 lb ae/A	Estimated value from  vegetative vigor  study MRID
435496-01

   



 1For terrestrial plants data evaluating  mefluidide-K, mefluidide-DEA
and mefluidide  have

 been  bridged for the terrestrial risk assessment. *most sensitive
species tested

Table 4.3: Summary of endpoints (LD50  or LC50 mg ae/kg) for Terrestrial
Toxicity  data used in RQ calculations for Mefluidide1



TAXONOMIC GROUP	Acute endpoint  	Chronic endpoint

	Acute Avian  	>1500*

Bobwhite quail

MRID 416019-01

Used this non-definitive endpoint as LD50

Chronic Avian 

38	Estimated value acute to chronic ratio based on mammal data

Acute Dietary Avian 	>3750*



Acute mammal	829.8*

mouse

MRID 00047116



Chronic mammal



102*

rat	MRID 00082748



1For terrestrial plants data evaluating mefluidide-K, mefluidide-DEA and
mefluidide have

 been  bridged for the terrestrial risk assessment. *most sensitive
species tested

   4.1.1         Non-target Aquatic Animals and Plants

            Routes of exposure evaluated in this risk assessment focused
on runoff and/or spray drift for mefluidide–K, mefluidide-DEA and
mefluidide.  Tier II PRZM/EXAM modeling was used to estimate mefluidide
acid concentrations in surface water.  The runoff assessment considered
the maximum label application rates.   Because the mefluidide can be
used on general turf areas including residential and agricultural areas,
the runoff modeling was conducted using the PA turf and FL turf
scenarios.   More importantly, mefluidide labels allow broadcast
applications as well as spot treatments.  Application rates, therefore,
were expressed on lbs ae/A regardless of the recommend application
treatment.  This approach is expected to be conservative because it
assumes 100% of the watershed is treated with mefluidide. 
Concentrations of mefluidide are expressed in acid equivalence to
address the bridging of mefluidide-K, mefluidide-DEA, mefluidide to
mefluidide acid.   Foliar dissipation half-lives were incorporated in
the modeling to address mefluidide dissipation from the foliage of
warm-season and cool season grasses. PRZM /EXAMS input parameters for
mefluidide are shown in Table 3.1.   Estimated environmental
concentrations are shown in Table 3.2.

            The 1-in-10 year peak EECs were compared to acute toxicity
endpoints to derive acute RQs for mefluidide. For aquatic vascular and
non-vascular plants, 1-in-10 year peak EECs were compared to acute EC50
values to derive acute non-listed species RQs.  NOAEC values for
vascular and non-vascular plants were estimated to derive listed species
RQs for these taxonomic groups.  RQs for listed and non-listed aquatic
vascular and non-vascular plants are summarized in Table 4.2.

		 4.1.1.1	 Freshwater Fish and Invertebrates tc \l4 " Field result goes
here Freshwater Fish and Invertebrates 

 	Risk quotients for mefluidide-K, mefluidide-DEA and mefluidide were
<0.0001 for acute freshwater fish and invertebrates based on the
non-definitive EC50 of  >68.47 mg ae/L for freshwater fish and  >77.25
mg ae/L for freshwater invertebrates.  Acute risk quotients for
freshwater fish and invertebrates are summarized in TABLE 4.4.

  

	Risk quotients for mefluidide-K, mefluidide-DEA and mefluidide were
<0.001 for chronic  freshwater fish  and invertebrates  based on  the
non-definitive estimated NOAEC values of  >0.267 mg ae/L for freshwater
fish and  >5.54 mg ae/L for freshwater invertebrates.  Chronic RQs for
mefluidide freshwater fish and invertebrates were derived from estimated
values due to lack of toxicity data and are summarized in Appendix D. 

     		No LOC exceedances occurred for acute and chronic risks to
freshwater fish and invertebrates for all application scenarios.  

Table 4.4. Aquatic acute freshwater fish  and Invertebrate RQs for
Mefluidide-K, Mefluidide-DEA and Mefluidide applications by Ground (G)
Spray  and Granular(GR) for the aquatic runoff assessment1,2,3

Application Scenario



	Fresh water Invertebrates	Freshwater

Fish

	Acute 

EECs mg ae/L	Acute RQs

(EC50 >77.25 mg ae/L)2	Acute RQs

(EC50 >68.47  mg ae/L)2

Ornamental Turf

(FLTurf  PRISM scenario)

3 applications per season ( interval of 6 weeks apart)

	mefluidide  (GR)	0.004835	0.0000625	0.0000706

	mefluidide-K and mefluidide-DEA (G)	0.010573	0.0001368	0.0001544

Ornamental Turf

( PA Turf PRISM scenario) 

3 applications per season ( interval of  6 weeks apart)

.	mefluidide (GR)	0.003031	0.0000392	0.0000442

	mefluidide-K and mefluidide-DEA (G)	0.007054	0.0000913	0.000103

1  The below notation will be used to denote values that exceed the
Levels of Concern (LOC)

 * exceeds LOC for acute risk to listed fish or invertebrate species (RQ
( 0.05)

** exceeds LOCs for acute risk to listed fish or invertebrate species
and restricted use (RQ ( 0.1)

            	               4.1.1.2       Estuarine/Marine Fish and
Invertebrates tc \l4 " Field result goes here Estuarine/Marine Fish and
Invertebrates 

               Risk quotients for mefluidide-K, mefluidide-DEA and
mefluidide were <0.0001 for acute estuarine marine fish aquatic-phase
amphibians based on the non-definitive EC50 of  >84.75 mg ae/L.  No LOC
exceedances occurred for acute risks to estuarine/ marine invertebrates
with an EC50 of 67 mg ae/L and RQs <0.0001 for all application
scenarios. Acute risk quotients for estuarine marine fish and
invertebrates are summarized in TABLE 4.5.

	There are insufficient data to establish a definitive toxicity endpoint
for estuarine/marine fish and invertebrate chronic effects for
mefluidide and mefluidide-DEA.  For the purposes of this risk
assessment, it was assumed that estuarine marine fish were at least as
sensitive as freshwater fish in terms of chronic toxicity.  Therefore,
the estimated endpoint for freshwater fish (NOAEC >0.267 mg ae/L) was
used to estimate a chronic effects endpoint for estuarine/marine fish. 
Therefore, based on the estimated NOAEC of  >0.267 mg ae/L no
exceedances occurred for chronic estuarine marine fish and
invertebrates. These estimated RQ values are summarized in Appendix D.

Table 4.5. Aquatic Estuarine Marine fish and Invertebrate RQs for
Mefluidide-K, Mefluidide-DEA and Mefluidide  applications by Ground (G)
Spray  and Granular(GR) for the aquatic runoff assessment1,2,3

Application Scenario



	E/M Invertebrates	E/M 

Fish

	Acute 

EECs mg ae/L	Acute RQs

(EC50 67 mg ae/L)2	Acute RQs

(EC50 >84.75  mg ae/L)2

Ornamental Turf

(FLTurf  PRISM scenario)

3 applications per season ( interval of 6 weeks apart)

	mefluidide (GR)	0.004835	0.0000721	0.000057

	mefluidide-K and mefluidide-DEA (G)	0.010573	0.0001578	0.0001247

Ornamental Turf

( PA Turf PRISM scenario) 

3 applications per season ( interval of  6 weeks apart)

.	mefluidide (GR)	0.003031	0.0000452	0.0000357

	mefluidide-K and mefluidide-DEA (G)	0.007054	0.0001052	0.0000832

1  The below notation will be used to denote values that exceed the
Levels of Concern (LOC)

 * exceeds LOC for acute risk to listed fish or invertebrate species (RQ
( 0.05)

** exceeds LOCs for acute risk to listed fish or invertebrate species
and restricted use (RQ ( 0.1)

          Aquatic Plants	 tc \l4 " Field result goes here Aquatic Plants
 

         Although no EC50 values were available from aquatic plant
studies, RQs were calculated for aquatic plants based on a EC50 values
>0.515 mg ae/L for vascular plants and >0.629 mg ae/L for non-vascular
plants.  RQ values were <0.1 for all modeled scenarios.

         Risk quotients for mefluidide-K, mefluidide-DEA and mefluidide
were <0.1 for   vascular and non-vascular plants based on the
non-definitive estimated EC05 values of  >0.029 mg ae/L for vascular 
plants and  >0.786 mg ae/L for non-vascular plants.  

        No LOC exceedances occurred for acute listed and non-listed
risks to vascular and non-vascular plants for all application scenarios.
 

             Table 4.6 lists the RQs for aquatic vascular and
non-vascular plants potentially exposed to   mefluidide-K,
mefluidide-DEA and mefluidide.   No LOC exceedances (RQs <0.1) occurred
for vascular and non-vascular plants.  

 Table 4.6. Aquatic Plant RQs for Mefluidide-K, Mefluidide-DEA and
Mefluidide applications by Ground (G) Spray  and Granular(GR) for the
aquatic runoff assessment1

Application Scenario	EECs to calculate Acute RQs mg ae/L	Vascular Plants
RQs ( EC50 >0.515 mg ae/L)	Vascular Plants (listed)

RQs (EC05>0.29 mg ae/L)	Non-vascular Plants RQs  EC50 (>0.629 mg ae/L)2	
Non-vascular Plants RQs   (EC05>0.786 mg ae/L) 2

Ornamental Turf

(FLTurf  PRZM scenario)

3 applications per season ( interval of 6 weeks apart)

	mefluidide (GR)	0.004835	0.0093883	0.0166724	0.0076868	0.0061513

	mefluidide-K and mefluidide-DEA (G)	0.010573	0.02053	0.0364586
0.0168092	0.0134516

Ornamental Turf

( PA Turf PRZM scenario) 

3 applications per season ( interval of  6 weeks apart)

.	mefluidide (GR)	0.003031	0.0058854	0.0104517	0.0048187	0.0038562

	mefluidide-K and mefluidide-DEA (G) 	0.007054	0.013697	0.0243241
0.0112146	0.0089745

 1  The below notation will be used to denote values that exceed the
Levels of Concern (LOC)

* exceeds LOC for acute risk to aquatic plant species (RQ > 1.0,
calculated as acute EEC /EC50 )

 **exceeds LOC for acute risk to listed aquatic plant species (RQ > 1.0,
calculated as acute EEC /NOAEC)

***exceeds LOC for acute risk to listed aquatic plant species (RQ > 1.0,
calculated as acute EEC /NOAEC), 

    However,  currently  there are no listed non-vascular plants. 

2 EC50  or NOAEC  estimated calculations are summarized in Appendix E

4.1.2       Non-target Terrestrial Animals

 tc \l3 " Field result goes here Non-target Terrestrial Animals 

            EECs were calculated for all ornamental turf labeled uses
with application rates ranging from 0.5 to 1.0 lb ae/A.  Risk quotients
are based on the most sensitive studies that yielded the lowest toxicity
values.  For this assessment, the lowest LD50 and NOAEC values were used
for birds and the lowest LD50 and NOAEL were used for mammals (based on
lab rat and mouse studies). 

      Birds

	                                 Avian Risk  tc "

Avian Risk " \l 2 

	The EEC’s for terrestrial exposure were derived from the Kenaga
nomograph, as modified by Fletcher et al. (1994), based on a large set
of field residue data. The EECs were calculated by the T-REX Version
1.3.1 model and corresponding avian acute and chronic risk quotients are
based on the most sensitive subacute dietary LC50, single oral dose
LD50, and NOAEC for birds. 

	Calculations for single-oral dose risk quotients are based on a
Northern bobwhite quail oral acute LD50 of 1500 mg ae/kg-bw.  RQs for
oral dose-based scenarios are calculated by dividing the
consumption-weighted equivalent dose by the body weight-adjusted LD50.
The avian LD50 is adjusted for body weight according to the following
equation:

 

(USEPA, 2006)

The assessed weight (AW) is the body weight of the wildlife species of
concern. An adjusted LD50 is calculated for three weight classes of
birds (20, 100, and 1000 g). The test weight (TW) is the body weight of
the species used in the toxicity study. In this case, the weight of the
bobwhite quail is estimated to be 178 g. The adjusted LD50 is 1080,
1375, and 1943 mg ae/kg-bwt for the weight classes 20, 100, and 1000 g
birds, respectively. 

Foliar Summary for Mefluidide-K and Mefluidide-DEA

Acute RQs were calculated for birds based on the non-definitive LD50
value of >1500 mg ae/kg-bw.   No mortality occurred at the single dose
treatment level (1500 mg ae/kg-bw) for the Tier I Acute Toxicity to
Bobwhite quail study MRID 416019-01. RQ values ranged 0 to 0.25 for the
1.0 lb ae/A ornamental turf modeled scenario.  RQs are summarized in
Appendix D. summarizes the avian dietary-based chronic RQs for foliar
uses of mefluidide-K and mefluidide-DEA.  Chronic RQs were estimated for
birds based on the non-definitive LD50 value of 38 mg ae/kg.  Chronic
dietary-based exceedances occurred for birds for the 1.0 lb ae/A modeled
scenario with risk quotients ranging from 2.9 to 6.32. Chronic estimated
NOAEC values and calculations are summarized in Appendix E.

          Table 4.7 summarizes the avian dose-based acute RQs for foliar
uses of mefluidide-K and mefluidide-DEA.

         For mefluidide-DEA and mefluidide-K,  acute restricted use
and/or listed species  risk LOCs are exceeded for 20 g birds that
consume short grass, tall grass, and broadleaf plants and small insects
for the 1.0 ae/A application rate modeled scenario with acute RQs of
<0.25.

          For mefluidide-DEA and  mefluidide-K, acute risk to listed
species LOCs are exceeded for 20 g birds that consume short grass, tall
grass, and broadleaf plants and small insects  and 100 g birds that
consume short grass for the 1.0 lb ae/A application rate modeled
scenario with acute RQs ranging from <0.11 to <0.25.  

          Table 4.8 summarizes the avian dietary-based chronic RQs for
foliar uses of mefluidide-K and mefluidide-DEA. Chronic dietary-based
exceedances occurred for birds for the 1.0 lb ae/A modeled scenario with
risk quotients ranging from 2.9 to 6.32.   Risk quotients based on
dietary exposure levels are provided for comparison purposes.        

Table 4.7.  Avian dose-based acute RQ values for proposed uses of
Mefluidide-K, Mefluidide-DEA and Mefluidide based on a bobwhite quail
LD50 > 1500 mg ae/kg -bw and upper-bound Kenaga values1. 



Use	

Application Rate lbs. ae/A

(# app / interval, days)	

Body Weight, g	

Mammalian Acute Risk Quotients (upper-bound Kenaga residues)



	

Short Grass	

Tall Grass	

Broadleaf Plants/Small Insects	

Fruits/pods/

seeds

large insects

Ornamental Turf

(mefluidide salts only)

Ground spray 	1.0

3 per season

42

day interval	

20	<0.25**	<0.12*	<0.14*	<0.02





100	<0.11*	<0.05	<0.06	<0.01





1000	<0.04	<0.02	<0.02	<0.00

1  

1 For avian toxicity assessments, data evaluating Mefluidide-K,
Mefluidide-DEA and Mefluidide toxicity have been bridged because
toxicity is expected to come from the benzene ring of mefluidide. 
Therefore, the most sensitive Mefluidide endpoint was selected to
represent avian for all application scenarios. 

* exceeds LOC for acute risk to listed species (RQ ( 0.1)

** exceeds LOCs for acute risk to listed species and restricted use (RQ
( 0.2)

Table 4.8.  Avian dietary-based chronic RQ values for Mefluidide-K and
Mefluidide-DEA based on an estimated NOAEC of 38.0 mg/ ae kg and
upper-bound Kenaga residues1. 



Use	

Application Rate lbs. ai/A

(# app / interval, days)	

Food Items	

Upper Bound EEC (mg/kg) 2	

Chronic RQ

(EEC/ NOAEC)

Ornamental Turf

(mefluidide salts only)

Ground spray 	1.0

3 per season

42

day interval	

Short grass	240.17	6.32*





Tall grass	110.08	2.90*





Broadleaf plants/small insects	135.09	3.56*





Fruits, pods, seeds, and large insects	15.01	0.40

 1 For avian toxicity assessments, data evaluating Mefluidide-K,
Mefluidide-DEA and Mefluidide  toxicity  have been bridged because
toxicity is expected to come from the benzene ring of mefluidide. 
Therefore, the most sensitive Mefluidide endpoint was selected to
represent  avian for all application scenarios. 

* exceeds LOC for chronic risk to listed species (RQ ( 1.0)

LD50/sq ft Summary

Mefluidide is the only proposed granular application.  Based on one
application of mefluidide at 0.5lbs ae/acre, LOC exceedances occurred
for small-sized 20 g birds for acute restricted use and/or listed
species (RQ=0.24). LD50s/sq-ft can be interpreted as the number of
lethal doses (LD50s) that are available within one square foot
immediately after application. EFED does not currently assess chronic
risks to birds from granular applications. The acute RQs for LD50/sq ft
based on a single application of mefluidide are summarized in Appendix D

Mammals 

 tc \l4 " Field result goes here Mammals 

                                          Mammalian Risk 

	EECs and corresponding mammalian acute and chronic RQs for Mefluidide
application were determined using the T-REX Version 1.3.1 model.
Calculations for mammalian organisms oral dose-based risk quotients were
based on an acute laboratory mouse LD50 value of 829.8 mg ae/kg bw and a
chronic reproductive effect (NOAEC) observed at 102 mg ae/kg bw/day .
Oral dose-based RQ values were calculated by dividing the
consumption-weighted equivalent dose by the body weight-adjusted LD50.
The mammalian LD50 is adjusted for body weight according the following
equation:

 

(USEPA, 2006)

The assessed weight (AW) is the body weight of the wildlife species. An
adjusted LD50 is calculated for each weight class of mammal (15, 35, and
1000 g). The test weight (TW) is the weight of the species used in the
toxicity study. In this case, the average weight of the laboratory mouse
was 20 g; however, T-REX assumes the average weight is 350 g. 
Therefore, the TW was adjusted to a mouse weighing 20 g in the model
instead of 350 g rat weight.  However,  the assumed 350 g TW for the rat
 was used for  the chronic oral dose-based RQ calculations, the NOAEC
(102 mg ae/kg bw/day) was converted to a NOAEL (2040 mg ae/kg diet)
based on a standard FDA lab rat conversion. 

Foliar Summary for Mefluidide-K and Mefluidide-DEA

 tc \l4 " Field result goes here Birds 

 

          Table 4.9 summarizes the mammalian dose-based acute RQs for
foliar uses of  mefluidide-K and mefluidide-DEA. 

         For  mefluidide-DEA and mefluidide-K, acute restricted use
and/or listed species acute risk LOCs are exceeded for 15 g  and 35 g
mammals that consume short grass for the 1.0 lb ae/A application rate
modeled scenario with acute RQs ranging from 0.22 to 0.26. 

         Acute risk to listed species are exceeded for  15 and 35 g
sized mammals that  consume short grass, tall grass, broadleaf plants
and small insects  and 1000 g mammals that consume short grass for the
1.0 lb ae/A application rate modeled scenario with acute RQs ranging
from 0.10 to 0.26.

           Table 4.10 summarizes the mammalian dose-based chronic RQs
for foliar uses of mefluidide-K and mefluidide-DEA.  The chronic LOC is
exceeded for 15 g mammals that consume short grass with an RQ of 1.02
for the 1.0 lb ae/A modeled scenario. 

          Table 4.11 summarizes the mammalian dietary-based chronic RQs
for foliar uses of  mefluidide-K and  mefluidide-DEA.  No chronic
dietary-based exceedances occurred for mammals for the1.0 lb ae/A
modeled scenario. Risk quotients based on dietary exposure levels are
provided for comparison purposes.

Table 4.9.  Mammalian dose-based acute RQ values for proposed uses of
Mefluidide-K and Mefluidide-DEA based on a mouse LD50 = 829.8 mg ae/kg
-bw and upper-bound Kenaga values1. 



Use	

Application Rate lbs. ae/A

(# app / interval, days)	

Body Weight, g	

Mammalian Acute Risk Quotients (upper-bound Kenaga residues)



	

Short Grass	

Tall Grass	

Broadleaf Plants/Small Insects	

Fruits/pods/

seeds

large insects	

 Seeds

(granivore)

Ornamental Turf

(mefluidide salts only)

Ground spray 	1.0

3 per season

42

day interval	

15	0.26**	0.12*	0.14*	0.02	0.00





35	0.22**	0.10*	0.12*	0.01	0.00





1000	0.12*	0.05	0.07	0.01	0.00



1 For mammal toxicity assessments, data evaluating Mefluidide-K,
Mefluidide-DEA and Mefluidide toxicity  have been bridged because
toxicity is expected to come from the benzene ring of mefluidide. 
Therefore, the most sensitive Mefluidide endpoint was selected to
represent  mammals for all application scenarios. 

* exceeds LOC for acute risk to listed species (RQ ( 0.1)

** exceeds LOCs for acute risk to listed species and restricted use (RQ
( 0.2)

  

Table 4.10. Mammalian dose-based chronic RQ values for proposed uses of
Mefluidide-K and Mefluidide-DEA based on a rat reproductive NOAEC of 102
mg ae/kg-bw/day and upper-bound Kenaga residues1.



Use	

Application Rate lbs. ae/A

(# app / interval, days)	

Body Weight, g	

Mammalian Acute Risk Quotients (upper-bound Kenaga residues)



	

Short Grass	

Tall Grass	

Broadleaf Plants/Small Insects	

Fruits/pods/seeds 

large insects	

Seeds

(granivore)

Ornamental Turf

(mefluidide salts only)

Ground spray 	1.0

3 per season

42

day interval	

15	1.02*	0.47	0.57	0.06	0.01





35	0.87	0.40	0.49	0.05	0.01





1000	0.47	0.21	0.26	0.03	0.01

 1 For mammal toxicity assessments, data evaluating Mefluidide-K,
Mefluidide-DEA and Mefluidide toxicity  have been bridged because
toxicity is expected to come from the benzene ring of mefluidide. 
Therefore, the most sensitive Mefluidide endpoint was selected to
represent  mammals for all application scenarios. 

*exceeds the chronic risk LOC (RQ > 1.0) for non-listed and listed
species.

Table 4.11.  Mammalian dietary-based chronic RQ values for Mefluidide-K
and Mefluidide-DEA based on a rat reproductive NOAEC of 2040 mg/kg-diet
and upper-bound Kenaga residues1. 



Use	

Application Rate lbs. ai/A

(# app / interval, days)	

Food Items	

Upper Bound EEC (mg/kg) 2	

Chronic RQ

(EEC/ NOAEC)

Ornamental Turf

(mefluidide  salts only)

Ground spray 	1.0

3 per season

42

day interval	

Short grass	240.17	0.12





Tall grass	110.08	0.05





Broadleaf plants/small insects	135.09	0.07





Fruits, pods, seeds, and large insects	15.01	0.01

 1 For mammal toxicity assessments, data evaluating Mefluidide-K,
Mefluidide-DEA and Mefluidide toxicity  have been bridged because
toxicity is expected to come from the benzene ring of mefluidide. 
Therefore, the most sensitive Mefluidide endpoint was selected to
represent  mammals for all application scenarios. 

2 estimated chronic diet concentration equivalent  based on reported
chronic dose

*exceeds the chronic risk LOC (RQ > 1.0) for non-listed and listed
species.

 LD50/sq ft Summary

           Mefluidide is the only proposed granular application.  Based
on one application of mefluidide at 0.5lbs ae/acre, acute restricted use
and/or listed species acute risk LOC exceedances occurred for the
LD50s/sq-ft for small and medium-sized mammals.  The RQs are 0.39 and
0.21 for small and medium mammals, respectively.  LD50s/sq-ft can be
interpreted as the number of lethal doses (LD50s) that are available
within one square foot immediately after application. EFED does not
currently assess chronic risks to mammals from granular applications.
The acute RQs for LD50/sq ft based on a single application of mefluidide
are summarized in Appendix D.  Calculations for LD50/sq ft are based on
the acute laboratory mouse LD50 value of 829.8 mg ae/kg bw, adjusted to
an average weight of 20 g. The calculations for food intake for a 20
gram size class mouse are summarized in Appendix D.  The LD50 approach
is only applied to a single application. 

   Plants

            Non-target Terrestrial Plants in Dryland and Semi-aquatic
Areas tc \l3 "3. Non-target Terrestrial Plants in Dryland and
Semi-aquatic Areas:   

	An analysis indicates exceedance of the Acute Risk LOC for listed and
non-endangered monocots and dicots in dryland and semi-aquatic areas
located adjacent to treated areas, both as a result of combined runoff
and spray drift, and from spray drift alone for mefluidide-DEA and
mefluidide-K.  

	For terrestrial plants, only one vegetative vigor toxicity study was
submitted for plants based on fresh weight exposed to mefluidide-DEA. 
These data were bridged with mefluidide and mefluidide-K.

	 Risk to terrestrial plants from spray drift alone is evaluated by
comparing the estimated exposure from drift to the most sensitive EC25
calculated from vegetative vigor laboratory tests. The most sensitive
vegetative vigor EC25 values were 0.105 and 0.0054 lb ae/acre for
monocots and dicots, respectively.  The NOAEC values were 0.045 and
0.0029 lb ae/acre for monocots and dicots, respectively.  Wet weight was
the most sensitive endpoint for monocots and dicots in the vegetative
vigor studies used to evaluate risk to terrestrial plants.

 

 	 Seedling emergence toxicity data was not available and data was not
available from other anilide analogs to derive EC25 values. To estimate
possible effects measurement endpoints for seedling emergence, EFED
assumed that EC25 toxicity values for vegetative vigor are equal to
seedling emergence measurement endpoints for mefluidide, mefluidide-DEA
and mefluidide-K.  Therefore, the most sensitive seedling emergence EC25
estimated values are 0.105 and 0.0054 lb ae/A for monocots and dicots,
respectively.  The NOEC estimated values for seedling emergence are
0.045 and 0.0029 lb ae/A for monocots and dicots, respectively.    These
values are used to calculate risk quotients for exposure from combined
runoff and spray drift to adjacent fields.

	Because RQs based on the EC25 values exceed the acute LOC, and exposure
can be expected which would cause greater than a 25% effect, risk to
listed plants is also a concern. Because RQs based on the NOAEC values
exceed the acute LOC, and exposure can be expected which would cause
potential risks to listed plants.   Risk quotients with which to
evaluate listed plant risks from a result of combined runoff and spray
drift, and from spray drift alone for mefluidide, mefluidide-DEA and
mefluidide-K were calculated with the above NOAEC values from the
vegetative vigor studies.  

                        	Spray applications with 1.0lb ae/A demonstrated
the highest RQ exceedances followed by granular applications with 0.5 lb
ae/A.  Dicots demonstrated more sensitivity than monocots in most
application scenarios with exposure to mefluidide, mefluidide-DEA and
mefluidide-K. 

  

                                     (Table 4.12) summarizes vegetative
vigor and seedling emergence terrestrial plant RQs for foliar and
granular uses of mefluidide-K, mefluidide-DEA and mefluidide from a
result of combined runoff and spray drift, and from spray drift alone.
Risk quotients were exceeded for ground spray (1.0 lb ae/A) and granular
applications (0.5 lb ae/A) for monocots and dicots. Dicots demonstrated
more sensitivity than monocots in all application scenarios with
exposure to mefluidide-K and mefluidide-DEA with all TERR Plant modeled
scenarios.

Table 4.12. Summarized Terrestrial Plant Risk Quotients for  Mefluidide,
Mefluidide-DEA and Mefluidide-Ka, b, c, d



Scenario	

Acute Non-endangered RQs	

Acute listed RQs

	

adjacent to 

treated sites	

semi-aquatic areas	

drift	

adjacent to 

treated sites	

semi-aquatic areas	

drift



Ground  spray application (1.0 lbs ae/acre)	





	

Monocot	0.571	4.86**	0.10	1.33*	11.33*	0.22



	

Dicot	11.11**	94.44**	1.85*	20.69*	175.86*	3.45*



Granular ground application (0.5 lbs ae/acre)e



	

Monocot	0.24	2.38**	n/a	0.56	5.56*	n/a



	

Dicot	4.63**	46.3**	n/a	8.62*	86.21*	n/a

 1 For  terrestrial plant (seedling emergence and vegetative vigor)
toxicity assessments, data evaluating Mefluidide-K, Mefluidide-DEA and
Mefluidide toxicity  have been bridged.  Therefore, the most sensitive
Mefluidide endpoint was selected to represent  terrestrial plants for
all application scenarios. 

a RQs for spray turf applications in this table were calculated for the
maximum labeled application rates of (1.2 lbs ae/acre)  and  (1.0 lbs
ae/acre) for mefluidide-DEA and mefluidide-K respectively.. 

b Acute non-endangered toxicity thresholds (EC25) were (0.105, 0.0054,
0.105, 0.0054)ae/acre for seedling emergence monocot, seedling emergence
dicot, vegetative vigor monocot, and vegetative vigor dicot,
respectively. EFED assumed that EC25 toxicity values for terrestrial
plants (vegetative vigor) are equal to (seedling emergence) measurement
endpoints for Mefluidide, Mefluidide-DEA and Mefluidide-K due to lack of
submitted data.  

c Acute listed toxicity thresholds (NOAEC) were  (0.045, 0.0029, 0.045,
0.0029) lb ai/acre for seedling emergence monocot, seedling emergence
dicot, vegetative vigor monocot, and vegetative vigor dicot,
respectively. EFED assumed that NOAEC toxicity values for terrestrial
plants (vegetative vigor) are equal to (seedling emergence) measurement
endpoints for Mefluidide, Mefluidide-DEA and Mefluidide-K due to lack of
submitted data.   

	* indicates an exceedance of the listed Species Level of Concern (LOC).

**indicates an exceedance of the Acute Risk LOC.

dRQs for ground granular applications in this table were calculated for
the maximum labeled application rate of  0.5lbs ae/acre. Drift RQs are
not applicable for granular applications. 

 

          Spray drift is an important factor in characterizing the risk
of Mefluidide to non-target plants. Spray drift exposure from ground
application is assumed to be 1% of the application rate and the EECs and
RQs were calculated using EFED’s TerrPlant.xls model (Version 1.2.1).
The AgDrift Tier 1 model (ground application, very fine to fine droplet
size and low boom height for turf application) was used to determine
what conditions are represented by a 1% spray drift exposure from ground
application. AgDrift provided 90th percentile estimates based on the
distribution of field measurements at 10 to 900 feet distances from the
edge of field (Table 3.5). The 90th percentile drift estimates from
AgDrift for 1.0 lb ae/A ground application was 0.51% of applied at a
distance of 200 ft from the edge of the field for turf applications. LOC
exceedences did not occur with a 200 foot or above buffer size for both
listed and non-listed dicots for the 1.0 lb ae/A application scenario.
RQs were calculated for buffers from 10 to 900 feet are summarized in
Appendix D. 

 

4.1.3                     RQs Based on Mean Kenaga Residues 

  

           For this risk assessment, the RQ that were compared to the
LOCs were calculated using maximum EECs derived from the Kenaga
nomograph. Risk quotients were also calculated using mean EECs to
determine the extent of the risk to mammals. RQs were based on both
single oral dose and dietary studies for mammals. 

                                       Birds

            Acute RQs were calculated for birds based on the
non-definitive LD50 value of >1500  mg ae/kg-bwt .   No mortality
occurred at the single dose treatment level (1500 mg ae/kg-bw) for the
Tier I Acute Toxicity to Bobwhite quail study MRID 416019-01.  When mean
residues were assumed, RQ values ranged from 0 to <0.09 for the 1.0 lb
ae/A ornamental turf modeled scenario.  Based on the mean kenaga
assessment, no acute LOC exceedances occurred for birds for the 1.0 lb
ae/A application scenario.

 

            Based on the chronic estimated value of NOAEC of 38 mg/ ae
kg diet, when mean residues were assumed, RQ values ranged from 0.18 to
2.23 for the 1.0 lb ae/A ornamental turf modeled scenario.  Based on the
mean Kenaga assessment, chronic LOC exceedances for birds occurred for
the1.0 lb ae/A ornamental turf modeled scenario.  RQs are summarized in
APPENDIX D.  

                   

                                            Mammals   

When mean residues were assumed:

Mammalian Acute listed LOCs were no longer exceeded for the 1 lb ae/A
modeled scenario.

Mammalian Acute Restricted Use LOCs were no longer exceeded for 15 g and
35 g mammals for the 1.0 lb ae/A modeled scenario.  

Mammalian Chronic LOCs (dose-based) were no longer  exceeded for the 15
g and 35 g size mammals for the 1.0 lb ae/A application scenario. 

4.2.	Risk Description – Interpretation of Direct Effects

Risks to Aquatic Organisms and Plants

          Based on the risk hypothesis terrestrial organisms (birds,
mammals, reptiles, terrestrial-phase amphibians and plants) and aquatic
organisms (invertebrates, fish,  amphibians and plants) in surface
waters (freshwater or saltwater) are subject to adverse effects when
exposed to mefluidide residues as a result of labeled use of the
pesticide. Routes of exposure evaluated in this risk assessment focused
on runoff and spray drift from ground spray with mefluidide applied at
application rates of 1.0 lb ae/A (mefluidide-K and mefluidide-DEA) and
runoff from granular applications with 0.5 lb ae/A mefluidide.

          No LOCs were exceeded for acute effects on  SEQ CHAPTER \h \r
1  freshwater and estuarine marine fish,  aquatic invertebrates,
non-vascular and vascular aquatic plants in water bodies adjacent to
ornamental turf in areas treated with mefluidide DEA, mefluidide K and
mefluidide. 

         No LOC exceedances occurred for chronic freshwater fish,
chronic estuarine marine fish, chronic estuarine marine invertebrates,
chronic freshwater invertebrates, vascular plants and non-vascular
plants.  

   4.2.2	         Risks to Terrestrial Organisms and Plants

           Direct application of mefluidide-K, mefluidide-DEA, and
mefluidide to the field leads to the conclusion that exposure is likely
to terrestrial organisms that are foraging or nesting in or near the
treated field.    SEQ CHAPTER \h \r 1 Birds and mammals in treated
fields may be exposed to spray and granular applications of pesticides
by ingesting material directly with the diet. When pesticides are
applied as a granular formulation, the exposure estimate is assumed to
account for all methods of exposure.  They may also be exposed by other
routes, such as incidental ingestion of contaminated soil, dermal
contact with treated plant surfaces and soil during activities in the
treated areas, direct impingement of sprayed material on the body at the
time of application, preening activities, inhalation of pesticide vapor
and contaminated particulate, and ingestion of drinking water
contaminated by the pesticide. 

            1.              Birds

           Six acute dietary studies were considered in determining the
risk for birds following 

applications of  mefluidide, mefluidide-K, and mefluidide-DEA to
ornamental turf. Also, no mortality occurred at the highest levels for
all six dietary studies. No toxic effects were identified for the above
studies. Acute RQs were calculated for birds based on the non-definitive
LD50 value of >1500 mg ae/kg-bw.  RQ values ranged from 0 to <0.25 for
the 1.0 ae/A ornamental turf modeled scenario. The available dietary
toxicity studies on avian species failed to establishe definitive acute
LD50 values (i.e., the lethality values exceed the highest dose tested).
 Therefore,   SEQ CHAPTER \h \r 1 use of this value adds uncertainty and
may overestimate risk to avian species. Therefore, when the LD50 value
of >1500 mg ae/kg-bw was applied to the TREX model it resulted in LOC
exceedances for acute listed for 20 and 100g birds  and restricted use
for 20 g birds for mefluidide-DEA and mefluidide-K (1.0 lb ae/A at 3
spray applications).  The LD50 value of 5000 mg ae/bw if applied to the
above modeled scenario would result in no acute LOC exceedances for
birds.   Based on the mean kenaga assessment, no acute LOC exceedances
occurred for birds (1.0 lbae/A at 3 spray applications).  

	Chronic RQs were estimated for birds based on the non-definitive NOAEC
value of 

38 mg ae/kg.  Chronic dietary-based exceedances occurred for birds for
the 1.0 lb ae/A modeled scenario with risk quotient exceedances ranging
from 2.90 to 6.32.   Chronic estimated NOAEC values and calculations are
summarized in Appendix E.

	Due to the high degree of uncertainty based on the estimated NOAEC
value 38 mg ae/kg and the non-definitive LD50 value of >1500 lb ae/A. 
Acute and chronic avian studies with definitive LD50 and NOAEC values
would quantify the uncertainties of avian risk.

.  

     LD50/sq ft Summary

Mefluidide is the only proposed granular application. Based on one
application of mefluidide at 0.5lbs ae/acre, acute restricted use and/or
listed species acute risk LOC exceedances occurred for the LD50s/sq-ft
for small and medium-sized mammals.  The RQs are 0.39 and 0.21 for small
and medium mammals, respectively. LD50s/sq-ft can be interpreted as the
number of lethal doses (LD50s) that are available within one square foot
immediately after application. EFED does not currently assess chronic
risks to birds from granular applications. The acute RQs for LD50/sq ft
based on a single application of mefluidide are summarized in Appendix D

Mammals 

            Two dietary studies were considered in determining the risk
for mammals following the application of mefluidide, mefluidide-K and
mefluidide-DEA.  	 

            Based on this analysis, it is likely that listed and
non-listed mammals that feed on grasses and broadleaf plants and small
insects are at risk from acute exposure due to spray applications of
mefluidide-K and mefluidide-DEA residues for turf modeled scenarios.
Also, it is likely that listed and non-listed mammals that feed on
grasses and broadleaf plants or small insects are at risk from chronic
exposure due to mefluidide-DEA and mefluidide-K residues based on the
ornamental  turf  (1.0 lb ae/A) modeled scenario.

           Based on one granular application of mefluidide (0.5 lb ae/A)
acute listed and restricted use LOCs were exceeded for small and medium
sized mammals. 

 

	

	3.             Non-Target Insects and Earthworms

           EFED currently does not quantify risks to terrestrial
non-target insects. Risk quotients, therefore, are not calculated for
these organisms.  Because mefluidide, mefluidide-K and mefluidide-DEA
are practically non-toxic to honey bees (96-hr acute contact LD50 >
18.75 µg ae/bee, MRID 425628-01, LD50 > 22.25 µg ae/bee, MRID
425628-02), the risk are not likely to have adverse effects on
pollinators and other beneficial insects.

           Ecotox data indicates that mefluidide is non-toxic to
earthworms (Ref #39542 Potter DA; Spicer PG; Redmond CT; Powell AJ
(1994) Toxicity of Pesticides to Earthworms in Kentucky Bluegrass Turf).
Two evaluations were conducted in the spring and the fall of 1992. 
Earthworm populations were sampled at 1 and 3 weeks after treatment. 
The application rate of mefluidide applied to the plots were 0.56 ai/ha
of Embark 2S which resulted in 0% and 17 % reduction of earthworms in
the spring and fall respectively after the 3 week treatments.

Terrestrial Plants

           Ground spray and granular applications were modeled for both
monocots and dicots from combined runoff and drift and drift only
scenarios.  Only one vegetative vigor toxicity study was submitted for
terrestrial plants based on fresh weight basis exposed to
mefluidide-DEA. These data were bridged with mefluidide and
mefluidide-K. Seedling emergence toxicity data were not available to
evaluate exposure of terrestrial plants to mefluidide from combined
runoff and drift.  In addition, data were not available from other
anilide analogs to derive estimated EC25 values. To estimate possible
effects measurement endpoints for seedling emergence, EFED assumed that
EC25 toxicity values for vegetative vigor are equal to seedling
emergence measurement endpoints for mefluidide, mefluidide-DEA and
mefluidide-K.   

           Levels of concerns are exceeded for acute non-listed and
listed monocots and dicots for ground applications for turf modeled
scenarios.  For the ornamental turf (1.0 lb ae/A) modeled scenario, RQs
ranged from 0.10 to 175.86 (ground spray applications) for monocots and
dicots from combined runoff and spray drift.  For the ornamental turf
(0.5 lb ae/A) modeled scenario, RQs ranged from 0.24 to 86.21 (granular
applications) for monocots and dicots from runoff.

           For the ornamental turf (1.0 lb ae/A) modeled scenario RQs
ranged from 0.1 to 3.45 (ground spray applications) for monocots and
dicots from spray drift only.

           Levels of concerns are exceeded for acute non-listed and
listed monocots and dicots from granular turf applications.  For the
ornamental turf (0.5 lb ae/A) modeled scenario, RQs were 46.3 for
non-listed dicots, 86.2 for listed dicots, 2.38 for non-listed monocots
and 5.56 for listed monocots.

           An analysis of the results indicates exceedance of the Acute
Risk LOC for listed and non-listed monocots and dicots in dryland and
semi-aquatic areas located adjacent to treated areas, both as a result
of combined runoff and spray drift, and from spray drift alone for
mefluidide, mefluidide-DEA and mefluidide-K.   

                                   Spray applications with 1.0 lb
ae/acre demonstrated the highest RQ exceedances followed by granular
applications with 0.5 lb ae/A.  Dicots demonstrated more sensitivity
than monocots in most application scenarios with exposure to mefluidide,
mefluidide-DEA and mefluidide-K.   Due to the high degree of uncertainty
based on the estimated seedling emergence EC25 value, submission of a
seedling emergence toxicity study based on dry weight would quantify
uncertainties as a result of terrestrial plants exposed to mefluidide
from combined runoff and spray drift.

 

Endocrine Disruption Assessment

           No studies were submitted for mefluidide-K, mefluidide-DEA
and mefluidide that indicated endocrine disruption.  

           The degradates of mefluidide-K, mefluidide-DEA and mefluidide
have not been identified as possessing the potential for endocrine
disruption.  In addition, the registrant has not submitted, nor has the
Agency requested, studies on the potential for endocrine disruption for
any of these degradates resulting from the use of mefluidide. Until such
time as the Agency determines that any of these degradates have the
potential to be an endocrine disruptor, this risk assessment has not
included an evaluation of the relative risk of mefluidide-K,
mefluidide-DEA and mefluidide, degradates for endocrine disruption and
as such is a source of uncertainty in this assessment.

           EPA is required under the Federal Food, Drug, and Cosmetic
Act (FFDCA), as amended by the Food Quality Protection Act (FQPA), to
develop a screening program to determine whether certain substances
(including all pesticide active and other ingredients) "may have an
effect in humans that is similar to an effect produced by a naturally
occurring estrogen, or other such endocrine effects as the Administrator
may designate."  Following the recommendations of its Endocrine
Disruptor Screening and Testing Advisory Committee (EDSTAC), EPA
determined that there were scientific bases for including, as part of
the program, the androgen and thyroid hormone systems, in addition to
the estrogen hormone system.  EPA also adopted EDSTAC’s recommendation
that the Program include evaluations of potential effects in wildlife. 
For pesticide chemicals, EPA will use The Federal Insecticide,
Fungicide, and Rodenticide Act (FIFRA) and, to the extent that effects
in wildlife may help determine whether a substance may have an effect in
humans, FFDCA authority to require the wildlife evaluations.  As the
science develops and resources allow, screening of additional hormone
systems may be added to the Endocrine Disruptor Screening Program
(EDSP).  When the appropriate screening and/or testing protocols being
considered under the Agency’s EDSP have been developed, mefluidide-K,
mefluidide-DEA and mefluidide may be subjected to additional screening
and/or testing to better characterize effects related to endocrine
disruption. 

     6.               	Potential for Avian and Mammalian Exposure in
Space and Time tc "The Potential for Wildlife Exposure Opportunities in
Time and Space " \l 2 

           In order for chemical residues in potential wildlife food
items to result in direct adverse effects in a mammalian population, the
organisms must be exposed to those food items at locations and at times
when the residues are present.  There are a number of important
questions that must be considered:

Are the residues present at locations where wildlife might feed?

Are the residues present in food items at times when wildlife might use
the areas?

Are the residues likely to be around long enough to result in exposure
sufficient to trigger the expected adverse responses?

          Mefluidide formulations are for use on:  agricultural/farm
structures/buildings and equipment, agricultural/nonagricultural
uncultivated areas/soils, airports/landing fields, commercial industrial
lawns, commercial institutional/industrial premises/equipment
(indoor/outdoor), golf course turf, hospitals/medical institutions
premises (human veterinary), household domestic dwellings outdoor
premises, industrial areas (outdoor), nonagricultural outdoor
buildings/structures, nonagricultural rights-of-way/fencerows/hedgerows,
ornamental and or shade trees, ornamental ground cover, ornamental
herbaceous plants, ornamental lawns and turf, ornamental nonflowering
plants, ornamental woody shrubs and vines,  paths/patios, paved area
(private roads/sidewalks), recreational areas, and residential lawns. 

          One category of ornamental turf that mefluidide is used on is
golf courses. Golf courses are recognized as having strong potential for
providing quality habitat to many wildlife species (Stangel and Distler
2002). For example, Audubon International has more than 2,200 golf
courses enrolled in its Audubon Cooperative Sanctuary System Program for
Golf Courses providing education and assistance to golf course managers
promoting environmental stewardship, conservation of biological
diversity, and sustainable resource management. Audubon International
has also been awarded a grant from Wildlife Links to create a database
for information on wildlife habitat on golf courses. 

          Across 24 golf courses in the northern coast of South
Carolina, a total of 5,362 birds, 82 species, and 30 neotropical
migratory birds species were recorded at 599 point count stations over a
two year study (Crum et al. 2003). Crum et al. (2003) report that the
majority of birds associated with less developed landscapes (i.e. golf
courses with less habitat disturbance) were woodland breeding species,
while urban breeding species were found primarily on golf courses in
which the majority of native vegetation had either been removed or
replaced with ornamental vegetation, or contained a high level of human
disturbance including residential and non-residential structures. The
large number of species observed on golf courses in this small
geographic area of the US indicates that a wide variety of birds will
utilize golf courses. Because of the large number of species
represented, it is likely that some population of birds will be on the
golf course year-round and that bird breeding seasons will be spread
throughout much of the year. In another study, Merola-Zwartjes and
DeLong (2005) compared a number of golf courses in the Albuquerque, New
Mexico, area with paired natural areas to see whether golf courses have
the potential of acting as surrogate riparian habitats for Southwestern
birds. They concluded that golf courses do have the potential to support
riparian bird communities, but that their conservation potential can be
enhanced through the addition of habitat complexity and structure
utilizing native plants.

	

           Sod farms are also registered for application with
mefluidide-K, mefluidide-DEA, mefluidide. One example of a bird species
that utilizes sod farms is the mountain plover who is attracted to
manmade landscapes (e.g., sod farms and cultivated fields) that mimic
their natural habitat associations, or sites with little vegetative
cover (e.g., other agricultural lands and alkali flats)
(http://www.epa.gov/fedrgstr/EPA-IMPACT/2002/December/Day-05/i30801.htm,
accessed 01 October 2006). Land management practices on cultivated
fields may include periods when fields are fallow, idle, or barren. If
these fields remain fallow, idle, or barren during April and May,
mountain plovers may choose these fields for nesting.  Sod farms are
often listed as popular sites for birding enthusiasts.

 (e.g.,http://home.comcast.net/~ehoward24/localbirdingsites.html,
http://www.crbo.net/SpecialtyBirds.html, accessed on 01 October 2006). 

          An example of wildlife use of roadsides is provided by the
Minnesota Department of Natural Resources
(http://www.dnr.state.mn.us/roadsidesforwildlife/index.html, accessed on
01 October 2006). Researchers have found that over 40 species of birds
and mammals utilize roadsides for shelter, nesting, and food. Roadsides
receive almost continuous nesting use from April through August.
Roadsides also provide the right combination of abundant food and cover
for birds that nest in cavities or in trees near roads. Examples of
birds and mammals documented to use roadsides in Minnesota are:
cottontail rabbit, white-tailed jackrabbit, short-tailed shrew,
woodchuck, meadow vole, meadow jumping mouse, ring-necked pheasant, gray
(Hungarian) partridge, mallard, blue-winged teal, pintail, and upland
sandpiper. Disturbance of roadside cover by early mowing, farm tillage,
grazing, "blanket" spraying, or vehicle and tractor encroachment during
the peak nesting months (May, June, July) will significantly lower
production for species that use roadsides for nesting.

             Based on a 4 day foliar half-life with LOC exceedances for
mammals and birds for the 1.0 and 0.5 lb ae/A application scenarios,
residues are likely to result in exposure sufficient to trigger the
expected adverse responses.

          This analysis suggests that the patterns of mefluidide uses
are such that they coincide in time and space to areas frequented by
mammalian wildlife.  These areas have been of demonstrated use by
wildlife as sources of food and cover. Finally, the potentially
problematic wildlife food items suggested by the risk assessment of
mefluidide are likely to be present in and around the treated areas. 

         4.2.4              Federally Threatened and Endangered (Listed)


                                  Species Concerns                      
                                                                        
                                        tc \l3 "4.	Federally Threatened
and Endangered (Listed) Species Concerns 

4.2.4.1             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 collocated 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 which has the relatively highest potential
exposure to the pesticide, and that exposures are likely to decrease
with distance from the treatment area.  

          Taxonomic Groups Potentially at Risk

Based on available screening level information, the greatest concerns
for direct Mefluidide ecological risks lie with effects to terrestrial
and semi-aquatic plants as well as acute and chronic effects to birds
and mammals.  The screening-level risk assessment for Mefluidide has
identified potential concerns for direct effects on the following listed
species categories: birds, mammals, and terrestrial and semi-aquatic
plants (both monocots and dicots). Since birds are used as a surrogate
for reptiles and terrestrial phase amphibians, they are also considered
to be of concern. 

The LOCATES database was not used for this assessment to identify
specific listed and threatened species at risk from exposure to
Mefluidide. Because of its widespread use on non-crop areas and because
it is used throughout the United States, the search of the database
could not be restricted by crop or geographic area. Therefore, all
species within each of the categories listed above would be identified
as being at risk through the LOCATES database. 

                                   Probit Slope Analysis

 tc \l3 "Probit Slope Analysis 

           Screening-level acute listed LOCs are exceeded for
terrestrial organisms potentially exposed to residues by Mefluidide
applications. The Agency uses the dose response relationship from the
toxicity study used for calculating the RQ to estimate the probability
of acute effects associated with an exposure equivalent to the EEC. 
This information serves as a guide to establish the need for and extent
of additional analysis that may be performed using Services-provided
“species profiles” as well as evaluations of the geographical and
temporal nature of the exposure to ascertain if a “not likely to
adversely affect” determination can be made.  The degree to which
additional analyses are performed is commensurate with the predicted
probability of adverse effects from the comparison of the dose response
information with the EECs.  The greater the probability that exposures
will produce effects on a taxa, the greater the concern for potential
indirect effects for listed species dependant upon that taxa, and
therefore, the more intensive the analysis on the potential listed
species of concern, their locations relative to the use site, and
information regarding the use scenario (e.g., timing, frequency, and
geographical extent of pesticide application).

           The Agency uses the probit dose response relationship as a
tool for providing additional information on the listed animal species
acute levels of concern.  The acute listed Species LOCs of 0.1 and 0.05
are used for terrestrial and aquatic animals, respectively.  As part of
the risk characterization, an interpretation of acute LOCs for listed
species is discussed.  This interpretation is presented in terms of the
chance of an individual event (i.e., mortality or immobilization) should
exposure at the estimated environmental concentration actually occur for
a species with sensitivity to Mefluidide on par with the acute toxicity
endpoint selected for RQ calculation.  To accomplish this
interpretation, the Agency uses the slope of the dose response
relationship available from the toxicity study used to establish the
acute toxicity measurement endpoints for each taxonomic group.  The
individual effects probability associated with the LOCs is based on the
mean estimate of the slope and an assumption of a probit dose response
relationship.  In addition to a single effects probability estimate
based on the mean, upper and lower estimates of the effects,
probabilities are also provided to account for variance in the slope. 
The upper and lower bounds of the effects probability are based on
available information on the 95% confidence interval of the slope. 
Confidence in the applicability of the assumed probit dose response
relationship for predicting individual event probabilities is also
relevant.  Studies with good probit fit characteristics (i.e.,
statistically appropriate for the data set) are associated with a high
degree of confidence. Conversely, a low degree of confidence is
associated with data from studies that do not statistically support a
probit dose response relationship.  In addition, confidence in the data
set may be reduced by high variance in the slope estimate (i.e., large
95% confidence intervals), despite good probit fit characteristics.

          The individual effect probabilities for aquatic organisms were
calculated based on an Excel spreadsheet tool IECV1.1 (Individual Effect
Chance Model Version 1.1) The model allows for such calculations by
entering the mean slope estimate (and the 95% confidence bounds of that
estimate) as the slope parameter for the spreadsheet.   For all species
event probability was calculated for the exceeded LOC based on a default
slope assumption of 4.5 due to studies that do not statistically support
a probit dose response relationship with confidence intervals of 2 and 9
as per original Agency assumptions of typical slope cited in Urban and
Cook (1986). 

          The corresponding estimated chance of individual mortality
associated with the terrestrial listed Species LOC 0.10 for terrestrial
species located near ornamental turf (1.0 lb ae/A) areas exposed to
mefluidide is approximately 1 in 2.94E+05 for mammals.  Probit analysis
was not conducted for birds because the LD50 was greater than 1500 mg
ae/kg-bw in the Bobwhite quail study (MRID 416019-01) and there were no
mortalities reported. 

 

However, based on the screening level assessment, the acute risk
quotients for mammals are as high as 0.26, above the acute listed LOC of
0.05. The probability of individual mortality based on the calculated
RQs is 1 in 236 for potentially exposed mammals (based on the LD50
study). Table 4.7 summarizes information on the Probability of
Individual Mortality for Mammals and Birds.   

Table 4.7  SEQ CHAPTER \h \r 1   Probability of Individual Mortality for
Birds and Mammals  at the Highest RQs and Application Rate (1.0lb ae/A)
Mefluidide 

Species	Type of application	 EC50 LD50	RQ	Probit Slope	95% Confidence
Interval	Probability of Individual Mortality at the RQ in this
Assessment   	MRID Source of Probit Slope

Bobwhite quail LD50	Ornamental

Turf	>1500	 	 n/a	 	 	416019-01

Lab mouse LD50	Ornamental

Turf 	829.8	 0.26**	default = 4.5	default 2-9

 	 1 in 236

(95% confidence interval 1 in 8.27 and  1 in 1.43 E+ 07)	00047116

1 For  terrestrial avian  toxicity assessments, data evaluating toxicity
data have been bridged.  Therefore, the most sensitive mefluidide
endpoint for birds was selected to represent all three Mefluidide
formulations for   birds for all application scenarios For terrestrial
mammal toxicity assessments, data evaluating toxicity data have been
bridged.  Also the most sensitive mefluidide endpoint for mammals was
selected to represent all three Mefluidide formulations for  mammals for
all application scenarios.

* exceeds LOC for acute risk to listed species (aquatic LOC = 0.05,
terrestrial LOC = 0.10)

** exceeds LOCs for acute risk to listed species and restricted use
(aquatic LOC = 0.1, terrestrial LOC = 0.20)

*** exceeds LOCs for acute risk, acute risk to listed species, and
restricted use (LOC = 0.5)



          The corresponding estimated chance of individual mortality
associated with the aquatic species listed Species LOC of 0.05 for
potentially exposed estuarine marine invertebrates located near
ornamental turf (1.0 lb ae/A) is approximately 1 in 4.18E*8.  Probit
analysis was not conducted for freshwater fish because the LC50 was
greater than 68.47 mg ae/L in the rainbow trout study (MRID 418937-02)
and there were no mortalities reported. Probit analysis was not
conducted for freshwater invertebrates because the LC50 was greater than
77.25 mg ae/L in the Daphnia study (MRID 418937-03) and there were no
mortalities reported.

Based on the screening level assessment, the highest acute risk quotient
for estuarine marine invertebrates is 0.0001, two orders of magnitude
below the acute listed LOC of 0.05. The probability of individual
mortality based on the calculated RQs is 1 in 1.03E+72 for potentially
exposed invertebrates (based on the LC50 study) Table 4.8 summarizes
information on the Probability of Individual Mortality for fish and
aquatic invertebrates.   

Table 4.8 Probability of Individual Mortality for fish and aquatic
invertebrates at the Highest RQs and Application Rate (1.0 ae/A)
Mefluidide 

Species	Type of Application  	 LC50 LD50

EC50	RQ	Probit Slope	95% Confidence Interval	Probability of Individual
Mortality at the RQ in this Assessment  	MRID Source of Probit Slope

FW Rainbow trout	Ornamental turf

	>68.47	 	n/a

	418937-02

FW Daphnid	Ornamental turf

	>77.25

n/a

	418937-03

EM

Sheepshead minnow	Ornamental turf

	>84.75

n/a

	425623-03

EM

Eastern oyster	Ornamental turf

	67	0.0001	default = 4.5	default 2-9 

 	1 in 1.03E+72

(95% confidence interval  1 in 1.61E+15 and 1 in 2.39E+283)	425624-01

1 For  terrestrial avian  toxicity assessments, data evaluating toxicity
data have been bridged.  Therefore, the most sensitive mefluidide
endpoint for birds was selected to represent all three Mefluidide
formulations for   birds for all application scenarios For terrestrial
mammal toxicity assessments, data evaluating toxicity data have been
bridged.  Also the most sensitive mefluidide endpoint for mammals was
selected to represent all three Mefluidide formulations for mammals for
all application scenarios.

* exceeds LOC for acute risk to listed species (aquatic LOC = 0.05,
terrestrial LOC = 0.10)

** exceeds LOCs for acute risk to listed species and restricted use
(aquatic LOC = 0.1, terrestrial LOC = 0.20)

*** exceeds LOCs for acute risk, acute risk to listed species, and
restricted use (LOC = 0.5)



                             Indirect Effects Analysis

         The Agency acknowledges that pesticides have the potential to
exert indirect effects upon the listed organisms by, for example,
perturbing forage or prey availability, altering the extent of nesting
habitat, etc. In conducting a screen for indirect effects, direct effect
LOCs for each taxonomic group are used to make inferences concerning the
potential for indirect effects upon listed species that rely upon
non-endangered organisms in these taxonomic groups as resources critical
to their life cycle. There are acute and chronic direct effects for
mammals, birds and acute direct effects for terrestrial plants (monocot
and dicot).  

           Indirect effects are possible for terrestrial animals that
are dependent on terrestrial monocots and dicot plants for food and/or
shelter.  Therefore, there is potential for adverse effects to those
species that rely either on a specific plant species or multiple plant
species.  Also, plant indirect effects may be limited to general habitat
modification, host plant loss, and competition.  If the available plant
material is impacted due to the effects of mefluidide, this may have
negative effects not only on the herbivorous animals, but throughout the
food chain. Also, depending on the severity of impact to the plant
communities (edge and riparian vegetation), community assemblages and
ecosystem stability may be altered (i.e. reduced bird and mammal
populations in edge habitats; reduced riparian vegetation resulting in
increased light penetration and temperature in aquatic habitats).       
    

         

                   Acute listed LOCs were exceeded for 20 g and 100 g
birds and acute restricted use LOCs were exceeded for 20 g birds that
were exposed to and consumed various feed items.  Consequently, there
may be a concern for potential indirect effects to listed species
dependent upon birds that consume feed items (short and tall grasses,
broadleaf plants, and small insects) contaminated with mefluidide
residues; such as predatory birds and mammals.   

                Acute listed and acute restricted use LOCs were exceeded
for mammals (15 g and 35 g) and acute listed LOCs were exceeded for 1000
g mammals that consumed various feed items.  The results of the probit
dose analysis for mouse indicated a 1 in 236 for mammals chance of
mortality based on the maximum use scenario and RQ of 0.26 for small
mammals consuming mefluidide.  Consequently, there may be a concern for
potential indirect effects to listed species dependent upon mammals that
consume feed items (short and tall grasses, broadleaf plants, and small
insects) contaminated with mefluidide residues; such as predatory birds
and mammals.   

          There are potential concerns for indirect effects on aquatic
organisms (fish, invertebrates, and plants) due to the potential for
changes in the habitat adjacent to water bodies. Shading of water bodies
that provides temperature regulation of the water could be reduced, thus
altering the habitat by increasing water temperature. This change in
temperature could affect the abundance and/or diversity of aquatic
plants and organisms in the adjacent water bodies. Furthermore, the
reduction of upstream riparian vegetation that would otherwise supply
downstream habitats could result not only in a loss of a significant
component of food for aquatic herbivores and detritivores, but also of
habitat (i.e. leaf packs, materials for case-building for
invertebrates).  These concerns are not only for freshwater systems, but
also for estuarine/marine systems. As an example, many golf courses are
located on or near coastal areas. 

          Again, the LOCATES database was not used for this assessment
to identify specific listed and threatened species at risk from indirect
effects to Mefluidide-K, mefluidide-DEA and mefluidide. Because of its
widespread use on non-crop areas and because it is used throughout the
United States, the search of the database could not be restricted by
crop or geographic area. Therefore, further co-location analysis is
recommended once the locations of mefluidide use can be identified.

                            SEQ CHAPTER \h \r 1 Critical Habitat for
Listed Species

	

           In the evaluation of pesticide effects on designated critical
habitat, consideration is given to the physical and biological features
(constituent elements) of a critical habitat identified by the U.S Fish
and Wildlife and National Marine Fisheries Services as essential to the
conservation of a listed species and which may require special
management considerations or protection.  The evaluation of impacts for
a screening level pesticide risk assessment focuses on the biological
features that are constituent elements and is accomplished using the
screening-level taxonomic analysis (RQs) and listed species levels of
concern (LOCs) that are used to evaluate direct and indirect effects to
listed organisms.

           The screening-level risk assessment for mefluidide has
identified potential concerns for direct effects on the following listed
species categories: small and medium birds, small, medium and large
mammals, and terrestrial and semi-aquatic plants (both monocots and
dicots). Since birds are used as a surrogate for reptiles and
terrestrial phase amphibians, they are also considered to be of concern.
In light of the potential for both direct effects, the next step for EPA
and the Service(s) is to identify which listed species and critical
habitat are potentially implicated.

          Analytically, the identification of such species and critical
habitat can occur in either of two ways.  First, the Agencies could
determine whether the action area overlaps critical habitat or the
occupied range of any listed species.  If so, EPA would examine whether
the pesticide's potential impacts on non-endangered species would affect
the listed species indirectly or directly affect a constituent element
of the critical habitat.  Alternatively, the Agencies could determine
which listed species depend on biological resources, or have constituent
elements that fall into the taxa that may be directly or indirectly
impacted by a pesticide.  Then EPA would determine whether or not use of
the pesticide overlaps the critical habitat or the occupied range of
those listed species.  At present, the information reviewed by EPA is
not sufficient to permit use of either analytical approach to make a
definitive identification of species that are potentially impacted
indirectly or critical habitats that are potentially impacted directly
by the use of pesticides.  EPA and the Service(s) are working together
to conduct the necessary analysis.

Because of the large number of species that are potentially impacted,
critical habitats will not be analyzed in this assessment. Therefore, it
is the continued responsibility of the EPA and the Service(s) to make
these assessments before final regulatory decisions are made.

            Species with identified critical habitats are listed at: 

  HYPERLINK
"http://ecos.fws.gov/tess_public/CriticalHabitat.do?listings=0&nmfs=1" 
http://ecos.fws.gov/tess_public/CriticalHabitat.do?listings=0&nmfs=1   

(Fish and Wildlife Service)

  HYPERLINK
"http://ecos.fws.gov/tess_public/CriticalHabitat.do?listings=0&nmfs=2" 
http://ecos.fws.gov/tess_public/CriticalHabitat.do?listings=0&nmfs=2  

(National Oceanic and Atmospheric Administration). A critical habitat
mapper for a subset of listed species is available at:
http://ecos.fws.gov/imf/imf.jsp?site=ecos. 

Description of Assumptions, Limitations, Uncertainties, Strengths and

            Data Gaps tc \l2 "C.  Description of Assumptions,
Limitations, Uncertainties, Strengths and Data Gaps 

             1.        Uncertainties and data gaps associated with the
environmental fate

                        and toxicity  data

             Exposure estimates for this screening level risk assessment
focused on the mefluidide, mefluidide-K and mefluidide-DEA.  Degradation
products were not considered in the exposure assessment.  There are no
environmental fate data on the degradation products of mefluidide,
mefluidide-K and mefluidide-DEA.  More importantly,
5-amino-2,4-dimethyltrifluoromethane-sulfonilide is a minor degradation
product of mefluidide. Diethanolamine (DEA) degrades rapidly (t1/2= 1.7
to 5.8 days) in aerobic soil and water environments (MRID 43685901,
43685902, 44439401).  In contrast, DEA is persistent (t1/2= 990 days) in
anaerobic aquatic environments (MRID 43882901).  Degradation products of
diethanolamine are glycine, ethanolamine, and CO2. Therefore, the
potential mechanisms of transformation (i.e., which degradates may form
in the environment, in which media, and how much) must be known,
especially for a chemical whose metabolites/degradates such as DEA are
of greater toxicological concern.         

 tc \l2 "E. Uncertainties and Data Gaps 

Additional uncertainty results from the lack of information and/or data
in several components of this ecological risk assessment as follows:

Ecotoxicity data for chronic risks to freshwater fish and freshwater
invertebrates  exposed to mefluidide were not available. However,
estimated values were derived from only one anilide (propanil) herbicide
to obtain effects measurement endpoints. A range of anilide herbicides
was not available to extrapolate endpoints. Therefore, these
extrapolated endpoints are uncertain and are not considered complete
substitutes for missing effects data. Additional information on these
estimated values are provided in Appendix E.  However, EFED concluded
that resulting estimated risk quotients, had they been based on
definitive effects measurement endpoints, would not trigger concerns for
chronic risks to these taxonomic groups. 

Ecotoxicity data for chronic risks to estuarine marine fish and
estuarine marine invertebrates exposed to mefluidide were not available.
  However, assuming ACRs from the freshwater fish and invertebrates are
similar to the estuarine marine species. No chronic exceedances would
occur for estuarine marine fish or invertebrates with RQs <0.01.  These
extrapolated endpoints are uncertain and are not considered complete
substitutes for missing effects data.  RQ calculations for chronic risks
to estuarine marine fish and estuarine marine invertebrates are
summarized in Appendix E. However, EFED concluded that resulting
estimated risk quotients, had they been based on definitive effects
measurement endpoints, would not trigger concerns for chronic risks to
these taxonomic groups.

Ecotoxicity data for chronic risks to birds exposed to mefluidide were
not available. Therefore, EFED calculated estimates for measurement
endpoints for chronic toxicity to birds by evaluating the available data
from mammal toxicity data (acute and chronic) and extrapolating the
findings to available data for mefluidide, mefluidide-DEA and
mefluidide-K to estimate possible effects measurement endpoints.  These
extrapolated endpoints are uncertain and are not considered complete
substitutes for missing effects data. Additional information on these
estimated values are provided in Appendix E.   Submission of a chronic
bird study would quantify risks associated with exposure of mefluidide
to birds.

The magnitude of toxicity to terrestrial plants is uncertain because
only one terrestrial vegetative vigor plant study was available and
conducted on fresh weight and not dry weight as required by EPA
guidelines.  Also, no other terrestrial plant toxicity studies (seedling
emergence and vegetative vigor) were available to estimate an EC25
values. Ecotoxicity data for terrestrial plants (seedling emergence)
exposed to mefluidide were not available. To estimate possible effects
measurement endpoints for seedling emergence, EFED assumed that EC25
toxicity values for terrestrial plants (vegetative vigor) are equivalent
to (seedling emergence) measurement endpoints for mefluidide,
mefluidide-DEA and mefluidide-K.  These estimated endpoints are
uncertain and are not considered complete substitutes for missing
effects data. Additional information on these estimated values are
provided in Appendix E. Submission of seedling emergence toxicity data
based on dry weight will quantify risks associated with exposure of
mefluidide to terrestrial plants.

 NOAEC or EC05 values were not available to calculate (listed) aquatic
vascular plants exposed to mefluidide. However, estimated values were
derived from only one anilide herbicide to obtain effects measurement
endpoints. A range of anilide herbicides was not available to
extrapolate endpoints. Therefore, these extrapolated endpoints are
uncertain and are not considered complete substitutes for missing
effects data. Additional information on these estimated values are
provided in Appendix E. However, EFED concluded that resulting estimated
risk quotients, had they been based on definitive effects measurement
endpoints, would not trigger concerns for chronic risks to these
taxonomic groups

The available dietary toxicity studies on avian species failed to
established definitive acute LD50 values (i.e., the lethality values
exceed the highest dose tested).  Therefore,   SEQ CHAPTER \h \r 1 use
of this value adds uncertainty and may overestimate risk to avian
species. Therefore, when the LD50 value of >1500 mg ae/kg-bw was applied
to the TREX model it resulted in LOC exceedances for Acute listed (20
and 100 g birds) and Restricted Use (100 g birds) for mefluidide-DEA and
mefluidide-K (1.0 lb ae/A at 3 applications).  The LD50 value of 5000 mg
ae/bw if applied to the above modeled scenario would result in no acute
LOC exceedances for birds.  

	4.3.1	  Assumptions and Limitations Related to Exposure to All Taxa  tc
"1.  Assumptions and Limitations Related to Exposure For All Daxa " \l 3


		

          There are a number of areas of uncertainty in the aquatic and
terrestrial risk assessments.  The toxicity assessment for terrestrial
and aquatic animals is limited by the number of species tested in the
available toxicity studies.  Use of toxicity data on representative
species does not provide information on the potential variability in
susceptibility to acute and chronic exposures. 

Assumptions and Limitations Related to Exposure to Aquatic

                   Species  	            tc "2.  Assumptions and
Limitations Related to Exposure For Aquatic Species	 " \l 3 

		

                                      PRZM/EXAMS standard runoff model

            SEQ CHAPTER \h \r 1 Although there are uncertainties and
limitations with the use of the PRZM/EXAMS standard runoff scenario for
a regional aquatic exposure assessment, it is designed to represent
pesticide exposure from an agricultural watershed impacting a vulnerable
aquatic environment. Extrapolating the risk conclusions from this
standard small water body scenario may either underestimate or
overestimate the potential risks.

          Major uncertainties with the standard runoff scenario are
associated with the physical construct of the watershed and
representation of vulnerable aquatic environments for different
geographic regions. The phyisco-chemical properties (pH, redox
conditions, etc.) of the standard small water body are based on a
Georgia farm pond. These properties are likely to be regionally specific
because of local hydrogeological conditions. Any alteration in water
quality parameters may impact the environmental behavior of the
pesticide. The small water body represents a well mixed, static water
body. Because the small water body is a static water body (no flow
through); it does not account for pesticide removal through flow through
or accidental water releases. However, the lack of water flow in the
small water body provides an environmental condition for accumulation of
persistent pesticides. The assumption of uniform mixing does not account
for stratification due to thermoclines (e.g., seasonal stratification in
deep water bodies). Additionally, the physical construct of the standard
runoff scenario assumes a watershed water body area ratio of 10. This
ratio is recommended to maintain a sustainable pond in the Southeastern
United States. The use of higher watershed water body ratios (as
recommended for sustainable ponds in drier regions of the United States)
may lead to higher pesticide concentrations when compared to the
standard watershed water body ratio.

          The standard small water body scenario assumes uniform
environmental and management conditions exist over the standard 10
hectare watershed. Soils can vary substantially across even small areas,
and thus, this variation is not reflected in the model simulations.
Additionally, the impact of unique soil characteristics (e.g., fragipan)
and soil management practices (e.g., tile drainage) are not considered
in the standard runoff scenario. The assumption of uniform site and
management conditions is not expected to represent some site-specific
conditions. Extrapolating the risk conclusions from the standard small
water body scenario to other aquatic habitats (e.g., marshes, streams,
creeks, and shallow rivers, intermittent aquatic areas) may either
underestimate or overestimate the potential risks in those habitats.

           SEQ CHAPTER \h \r 1 Currently, crop sites for PRZM/EXAMS
modeling are chosen to represent sites which produce high-end, but not
unrealistic or worst-case, EECs for that crop.  The EECs in this
analysis are accurate only to the extent that the site represents a
hypothetical high-end exposure site.  It should be remembered that while
the standard pond would be expected to generate lower EECs than shallow
water bodies near agricultural fields that receive most of their water
as runoff from use sites that have been treated with mefluidide.  

         

	

	4.3.3            Assumptions and Limitations Related to Exposure to
Terrestrial  tc "3.  Assumptions and Limitations Related to Exposure For
Terrestrial Species " \l 3 

                                Species

	                                   Residue concentration

         The data available to support the exposure assessment for
mefluidide is substantially complete, with the exception of a chronic
bird study, which is an input variable for Tier 1 modeling of risks to
birds and mammals (i.e., T-REX Model).  EFED is confident that the
estimated foliar half-life of 4 days derived from the two field
dissipation studies on warm and cool season turf soil are acceptable
(MRID 43276802 and 43276801).  Therefore, EFED used the 4 day half-life
for aquatic and terrestrial modeling in this assessment.

        EFED also identified alternative foliar half lives and
applications to identify LOC exceedances. To assess risks to terrestrial
animals, the Tier I terrestrial model, T-REX, was used with maximum
application rates (1 and 3 applications), foliar half-lives (4 day and
35 day) and values derived from upper bound and mean kenaga assessments.

 To obtain an upper and lower bound estimates, both the estimated foliar
half-life (4 days) and the default foliar half-life (35 days) with 1 and
3 applications resulted in acute LOC exceedances for both mammals and
birds from both the upperbound and mean kenaga assessments. Chronic dose
based exceedances for mammals did not exceed from the mean kenaga
assessment for the 1.0 lb ae/A application scenario.  The 35 day foliar
half life with 3 applications resulted in RQ values approximately 61%
higher than the single application rates for mammals.  EFED is confident
that the estimated foliar half-life of 4 days derived from the two field
dissipation studies on warm and cool season turf soil is acceptable
(MRID 43276802 and 43276801).  Therefore, EFED will use the 4 day
half-life for aquatic and terrestrial modeling in this assessment. Based
on acute RQ values for the upper bound kenaga values for mammals, LOC
exceedances for acute mammals would occur for the 1.0 lb ae/A modeled
scenario. However, acute exceedences for mammals did not exceed from the
mean kenaga assessment for the 1.0 lb ae/A application scenario. These
RQ values are summarized in Appendix D.

                                Variation in habitat and dietary
requirements

         For screening terrestrial risk assessments, a generic bird or
mammal is assumed to occupy either the treated field or adjacent areas
receiving pesticide at a rate commensurate with the treatment rate on
the field.  The habitat and feeding requirements of the modeled species
and the wildlife species may be different. It is assumed that species
occupy, exclusively and permanently, the treated area being modeled. 
This assumption leads to a maximum level of exposure in the risk
assessment. 

            SEQ CHAPTER \h \r 1 The acute studies have a fixed exposure
period, not allowing for the differences in response of individuals to
different durations of exposure.  Further, for the acute oral study,
Mefluidide is administered in a single dose which does not mimic wild
birds’ exposure through multiple feedings.  Also, it does not account
for the effect of different environmental matrices on the absorption
rate of the chemical into the animal. Because exposure occurs over
several days, both the accumulated dose and elimination of the chemical
from the body for the duration of the exposure determine the exact
exposure to wildlife, however they are not taken into account in the
screening assessment. There was also no assumption of an effect of
repeated doses that change the tolerance of an individual to successive
doses. EFED is confident based on the acceptable bird and mammal
toxicity studies and conservative modeling procedures that the above
assumptions pertaining to variations in habitat and dietary requirements
do not effect the certainty of the risk conclusions.

                                 SEQ CHAPTER \h \r 1 Variation in diet
composition

          The risk assessment and calculated RQs assume 100% of the diet
is relegated to single food types foraged only from treated fields. The
assumption of 100% diet from a single food type may be realistic for
acute exposures based on this assessment, but diets are likely to be
more variable over longer periods of time. This assumption is likely to
be conservative and will tend to overestimate potential risks for
chronic exposure.  These large animals (e.g., deer and geese) will tend
to forage from a variety of areas and move on and off of treated fields.
Small animals (e.g., mice, voles, and small birds) may have home ranges
smaller than the size of a treated area and will have little or no
opportunity to obtain foodstuffs that have not been treated with
mefluidide. Even if their home range does cover area outside the treated
field, mefluidide may have drifted or runoff to areas adjacent to the
treated area. 

                        Exposure routes other than dietary

         Screening-level risk assessments for spray applications of
pesticides consider dietary exposure to terrestrial organisms.  Other
exposure routes are possible for animals residing in or moving through
treated areas. These routes include ingestion of contaminated drinking
water, ingestion of contaminated soils, preening/grooming, and dermal
contact. Preening exposures, involving the oral ingestion of material
from the feathers remains an unquantified, but potentially important,
exposure route. If toxicity is expected through any of these other
routes of exposure, then the risks of a toxic response to mefluidide is
underestimated in this risk assessment. Other routes of exposure, not
considered in this assessment, are discussed below:

                Incidental soil ingestion exposure

	

         This risk assessment does not consider incidental soil
ingestion.  Available data suggests that up to 15% of the diet can
consist of incidentally ingested soil depending on the species and
feeding strategy (Beyer et al, 1994). Because mefluidide is moderately
persistent in soils, incidental soil ingestion is a possible exposure
pathway.  

                Inhalation exposure

         The screening risk assessment does not consider inhalation
exposure however, due to the low Henrys Constant of mefluidide (2.27E-7
atm m3/mole) inhalation is not likely to be an important exposure
pathway. Also, mammalian toxicity studies for inhalation exposure to
mefluidide indicate low acute toxicity Appendix E.   

          Based on the acceptable mammal toxicity studies and low Henrys
Constant of mefluidide the above assumptions pertaining to inhalation
exposure do not effect the certainty of the risk conclusions.

                                  Dermal Exposure

         The screening assessment does not consider dermal exposure. 
Dermal exposure may occur through three potential sources: (1) direct
application of spray to terrestrial wildlife in the treated area or
within the drift footprint, (2) incidental contact with contaminated
vegetation, or (3) contact with contaminated water or soil.

 The low octanol/water partitioning coefficient with a Kow value of (log
Kow=1.97; Kow=94.5 indicates the potential for mefluidide to be absorbed
via dermal exposure is not likely to be an important exposure pathway.  
Also, mammalian toxicity studies for mefluidide indicate low acute
toxicity by dermal exposure routes Appendix E.    

           The available measured data related to wildlife dermal
contact with pesticides are extremely limited.  The Agency is actively
pursuing modeling techniques to account for dermal exposure via direct
application of spray and by incidental contact with vegetation. EFED is
confident based on the acceptable mammal toxicity studies and low
octanol/water partitioning coefficient of mefluidide that the above
assumptions pertaining to dermal exposure do not effect the certainty of
the risk conclusions.

            Drinking Water Exposure

           Drinking water exposure to a pesticide active ingredient may
be the result of consumption of surface water or consumption of the
pesticide in dew or other water on the surfaces of treated vegetation.
Given that Mefluidide is soluble in water there exists the potential to
dissolve in runoff and puddles on the treated field may contain the
chemical.  Consumption of drinking water would appear to be
inconsequential if water concentrations were equivalent to the
concentrations from PRZM/EXAMS; however, concentrations in puddled water
sources on treated fields may be higher than concentrations in modeled
small water body. Given that this exposure route is not included in the
assessment, overall risk may be underestimated.

                 Dietary Intake - Differences between Laboratory and

                Field Conditions

            SEQ CHAPTER \h \r 1 There are several aspects of the dietary
test that introduce uncertainty into calculation of the LC50 value
(Mineau, Jobin, and Baril, 1996; ECOFRAM, 1999).  The endpoint of this
test is reported as the concentration mixed with food that produces a
response rather than as the dose ingested.  Although food consumption
sometimes allows for the estimate of a dose, calculations of the
mg/kg/day are confounded by undocumented spillage of feed and how
consumption is measured over the duration of the test.  Usually, if
measured at all, food consumption is estimated once at the end of the
five-day exposure period.  Further, group housing of birds undergoing
testing only allows for a measure of the average consumption per day for
a group; consumption estimates can be further confounded if birds die
within a treatment group.  The exponential growth of young birds also
complicates the estimate of the dose; controls often nearly double in
size over the duration of the test.  Since weights are only taken at the
initiation of the exposure period and at the end, the dose per body
weight (mg/kg) is difficult to estimate with any precision.  The
interpretation of this test is also confounded because the response of
birds is not only a function of the intrinsic toxicity of the pesticide,
but also the willingness of the birds to consume treated food.

           Further, the acute and chronic characterization of risk rely
on comparisons of wildlife dietary residues with LC50 or NOAEC values
expressed in concentrations of pesticides in laboratory feed. These
comparisons assume that ingestion of food items in the field occurs at
rates commensurate with those in the laboratory.  Although the screening
assessment process adjusts dry-weight estimates of food intake to
reflect the increased mass in fresh-weight wildlife food intake
estimates, it does not allow for gross energy and assimilative
efficiency differences between wildlife food items and laboratory feed.
On gross energy content alone, direct comparison of a laboratory dietary
concentration- based effects threshold to a fresh-weight pesticide
residue estimate would result in an underestimation of field exposure by
food consumption by a factor of 1.25 - 2.5 for most food items.  Only
for seeds would the direct comparison of dietary threshold to residue
estimate lead to an overestimate of exposure.

          Differences in assimilative efficiency between laboratory and
wild diets suggest that current screening assessment methods do not
account for a potentially important aspect of food requirements. 
Depending upon species and dietary matrix, bird assimilation of wild
diet energy ranges from 23 - 80%, and mammal's assimilation ranges from
41 - 85% (U.S. Environmental Protection Agency, 1993).  If it is assumed
that laboratory chow is formulated to maximize assimilative efficiency
(e.g., a value of 85%), a potential for underestimation of exposure may
exist by assuming that consumption of food in the wild is comparable
with consumption during laboratory testing.  In the screening process,
exposure may be underestimated because metabolic rates are not related
to food consumption.

          Finally, the screening procedure does not account for
situations where the feeding rate may be above or below requirements to
meet free living metabolic requirements.  Gorging behavior is a
possibility under some specific wildlife scenarios (e.g., bird
migration) where the food intake rate may be greatly increased. 
Kirkwood (1983) has suggested that an upper-bound limit to this behavior
might be the typical intake rate multiplied by a factor of 5. In
contrast is the potential for avoidance, operationally defined as
animals responding to the presence of noxious chemicals in their food by
reducing consumption of treated dietary elements.  This response is seen
in nature where herbivores avoid plant secondary compounds.

          In the absence of additional information, the acute oral LD50
test provides the best estimate of acute effects for chemicals where
exposure can be considered to occur over relative short feeding periods,
such as the diurnal feeding peaks common to avian species (ECOFRAM,
1999). EFED is confident based on the acceptable bird and mammal
toxicity studies that the above assumptions pertaining laboratory and
field conditions do not effect the certainty of the risk conclusions.   
     

                         Assumptions and Limitations Related to Effects
Assessment  tc "4.  Assumptions and Limitations Related to Effects
Assessment " \l 3 

         EFED has identified gaps in the effects dataset for mefluidide,
mefluidide-DEA and mefluidide-K.  These data gaps prevent the
establishment of definitive effects measurement endpoints for the
following taxonomic groups for mefluidide, mefluidide-DEA and
mefluidide-K:  Chronic freshwater fish, chronic estuarine marine fish,
chronic estuarine marine invertebrates, chronic freshwater
invertebrates, vascular plants (EC05 or NOAEC) and non-vascular plants
(EC05 or NOAEC).   Therefore, EFED calculated estimates for
measurement endpoints for these taxonomic groups by evaluating the
available data from other anilide herbicides (Propanil) and
extrapolating the findings to available data for mefluidide,
mefluidide-DEA and mefluidide-K to estimate possible effects measurement
endpoints.  Other anilide herbicides that were considered for data were
Chloranocryl, Monalide and Pentanochlor, however no information was
available for these chemicals.  Therefore, Propanil was used to estimate
acute to chronic ratios for mefluidide. EFED then compared estimated
environmental concentrations for surface waters with these endpoints.
 In all cases, EFED concluded that resulting estimated risk quotients,
had they been based on definitive effects measurement endpoints, would
not trigger concerns for acute or chronic risks to these taxonomic
groups.  In fact, the RQ estimates are multiple orders of magnitude
below Agency LOCs.  However, estimated values were derived from only
one anilide herbicides to obtain effects measurement endpoints. A range
of anilide herbicides was not available to extrapolate endpoints.
Therefore, these extrapolated endpoints are uncertain and are not
considered complete substitutes for missing effects data. 

           EFED has identified gaps in the effects dataset for
mefluidide, mefluidide-DEA and mefluidide-K.  These data gaps prevent
the establishment of definitive effects measurement endpoints for the
following taxonomic groups for mefluidide, mefluidide-DEA and
mefluidide-K: birds (chronic) and terrestrial plants (seedling
emergence).   Therefore, EFED calculated estimates for measurement
endpoints for chronic toxicity to birds by evaluating the available data
from mammal toxicity data (acute and chronic) and extrapolating the
findings to available data for mefluidide, mefluidide-DEA and
mefluidide-K to estimate possible effects measurement endpoints. 

           To estimate possible effects measurement endpoints for
seedling emergence, EFED assumed that EC25 toxicity values for
terrestrial plants (vegetative vigor) are equivalent to (seedling
emergence) measurement endpoints for mefluidide, mefluidide-DEA and
mefluidide-K.   Therefore, these estimated endpoints are uncertain and
are not considered complete substitutes for missing effects data.

 

	                         Age class and sensitivity of effects
thresholds

          It is generally recognized that test organism age may have a
significant impact on the observed sensitivity to a toxicant.  The
screening risk assessment acute toxicity data for fish are collected on
juvenile fish between 0.1 and 5 grams.  Aquatic invertebrate acute
testing is performed on recommended immature age classes (e.g., first
instar for daphnids, second instar for amphipods, stoneflies and
mayflies, and third instar for midges).  Similarly, acute dietary
testing with birds is also performed on juveniles, with mallard being
5-10 days old and quail 10-14 days old.

           Testing of juveniles may overestimate toxicity of older age
classes for pesticidal active ingredients, such as Mefluidide, that act
directly (without metabolic transformation) because younger age classes
may not have the enzymatic systems associated with detoxifying
xenobiotics.  The screening risk assessment has no current provisions
for a generally applied method that accounts for this uncertainty.  In
so far as the available toxicity data may provide ranges of sensitivity
information with respect to age class, the risk assessment uses the most
sensitive life-stage information as the conservative screening endpoint.
However, EFED is confident based on all the acceptable aquatic and
terrestrial toxicity studies that the above assumptions pertaining to
age sensitivity does not effect the certainty of the risk conclusions.

	                      Use of the Most Sensitive Species Tested

          Although the screening risk assessment relies on a selected
toxicity endpoint from the most sensitive species tested, it does not
necessarily mean that the selected toxicity endpoint reflect sensitivity
of the most sensitive species existing in a given environment.  The
relative position of the most sensitive species tested in the
distribution of all possible species is a function of the overall
variability among species to a particular chemical.  In the case of
listed species, there is uncertainty regarding the relationship of the
listed species' sensitivity and the most sensitive species tested.

          The Agency is not limited to a base set of surrogate toxicity
information in establishing risk assessment conclusions. The Agency also
considers toxicity data on non-standard test species when available.
EFED is confident based on the acceptable aquatic and terrestrial 
toxicity studies that the above assumptions pertaining to the most
sensitive species tested  does not effect the certainty of the risk
conclusions.

          REFERENCES

Beyer, W.N. 1994. Estimates of soil ingestion by wildlife. J Wildlife
Manage 58(2):375–382.

Crum, J. R., F. W. Thomas, and J. N. Rogers III. 2003. Agronomic and
engineering properties of USGA putting greens. USGA Turfgrass and
Environmental Research Online 2(15): 1-9.

ECOFRAM. 1999. ECOFRAM Terrestrial Draft Report. Ecological Committee on
FIFRA Risk Assessment Methods. USEPA, Washington, DC.

  SEQ CHAPTER \h \r 1 Fletcher, J.S., J.E. Nellessen, and T.G. Pfleeger.
 1994.  Literature review and evaluation of the EPA food-chain (Kenaga)
nomogram, an instrument for estimating pesticide residues on plants. 
Environ. Tox. Chem. 13:1383-1391.

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

Gibson, L. R. and M. Liebman. 2002. Course Material for Principles of
Weed Science, Agronomy 317, Iowa State University. Website accessed 17
July 2006,
http://www.agron.iastate.edu/courses/Agron317/Herbicide_mode_of_action.h
tm.

Kirkwood JK. 1983. Minireview. A limit to metabolisable energy intake in
mammals and birds. Comp Biochem Physiol A 75(1):1-3.

Lehman,A.J.1975. Appraisal of the Safety of Chemicals in Foods, Drugs
and Cosmetics. Association of Food and Drug Officials of the United
States 

Merola-Zwartjes, M., and J. P. DeLong. 2005. Southwestern golf courses
provide needed riparian habitat for birds. USGA Turfgrass and
Environmental Research Online 4(14): 1-18

Mineau, P., B. T. Collins, and A. Baril. 1996. On the use of scaling
factors to improve interspecies extrapolation of acute toxicity in
birds. Regulatory Toxicology and Pharmacology. 24:24-29.

Stangel, P., and K. Distler. 2002. Golf courses for wildlife: Looking
beyond the turf. USGA Turfgrass and Environmental Research Online
1(2):1-6.

Urban DJ & Cook NJ (1986) Hazard Evaluation Division Standard Evaluation
Procedure: Ecological risk assessment. EPA 540/9-85-001. Office of
Pesticide Programs, United States Environmental Protection Agency,
Washington, D.C 



Appendix A      Ecological Data Requirements

  Ecological Effects Data Requirements for Mefluidide1

Guideline #	Data Requirement	Species / MRID	Study Classification

71-1	850.2100	Avian Oral LD50

	Northern Bobwhite Quail (416019-01 )

Mallard duck  Not submitted	Supplemental

71-2	850.2200	Avian Dietary LC50

	Northern Bobwhite Quail (416019-02)	Supplemental



	Mallard duck (416019-03)	Supplemental

71-4	850.2300

	Avian Reproduction	Not submitted	                            Estimated
values

81-1



Acute Mammal	Laboratory mouse (00047116)	Acceptable

83-4

Chronic Mammal	Laboratory rat   (00082748)	Acceptable

72-1	850.1075	Freshwater Fish LC50

	Rainbow Trout Coldwater species Freshwater fish

(418937-02)	Acceptable



	Bluegill sunfish Warmwater species Freshwater fish

(418937-01)	Acceptable

72-2	850.1010	Freshwater Invertebrate Acute LC50

	Water flea 

Freshwater Invertebrate (418937-03)

	Acceptable

72-3(a)	850.1075	Estuarine/Marine Fish LC50	Sheepshead minnow

(425623-03)	Acceptable

72-3(b)	850.1025	Estuarine/Marine Invertebrates EC50	Eastern Oyster
(425624-01)	Acceptable

72-4(a)	850.1400	Fish Early Life-Stage	Not submitted	              
Estimated values

72-4(b)	850.1300

850.1350	Aquatic Invertebrate Life-Cycle	Not submitted	              
Estimated values

72-5	850.1500	Freshwater Fish Full Life-Cycle	Not submitted	Estimated
values

123-1(a)	850.4225	Seedling Emergence 	Not submitted	Estimated values

123-1(b)	850.4250	Vegetative Vigor (Tier II)

	Most sensitive monocot: Onion

Most sensitive dicot: cabbage, lettuce

( 435496-01  )	Supplemental

123-2	850.4400	Aquatic Plant Growth (Tier II)	Navicula pelliculosa Tier
I Nonvascular  Plant(435266-05  )	Acceptable

123-2	850.4400	Aquatic Plant Growth (Tier II)	Lemna gibba Tier I
Vascular  Plant( 435266-01 )	Acceptable

141-1	850.3020	Honey Bee Acute Contact LD50	Honeybee ( 425628-01 )
Acceptable



Appendix B  Bibliography for Environmental Fate and Selected Chemical
Structures

Bibliography

Morrison Robert T. and R. N. Boyd. 1973.  Organic Chemistry 3rd edition.
Allyn and Bacon, Inc., Boston.

Chemical Stuctures for Mefluidide

  	 	

Mefluidide a.i			Mefluidide-K a.i			Mefluidide-DEA a.i

		

Mefluidide acid (Enol form)		Mefluidide (Keto form)

Propanil analog

Appendix C Aquatic Exposure Modeling Assessment PRZM-EXAMS model
outputs

PRZM-EXAMS SIMULATIONS

FL TURF mefluidide-DEA

stored as MefluDEA.out

Chemical: Mefluidide

PRZM environment: FLturfC.txt	modified Monday, 16 June 2003 at 13:48:06

EXAMS environment: pond298.exv	modified Thuday, 29 August 2002 at
16:33:30

Metfile: w12834.dvf	modified Wedday, 3 July 2002 at 09:04:28

Water segment concentrations (ppb)

Year	Peak	96 hr	21 Day	60 Day	90 Day	Yearly

1961	6.522	6.393	5.844	4.781	4.142	1.629

1962	2.048	2.006	1.904	1.621	1.473	1.009

1963	10.33	10.1	9.353	7.649	6.617	2.702

1964	3.237	3.164	3.003	2.477	2.159	1.513

1965	1.479	1.45	1.332	1.139	1.112	0.679

1966	16.06	15.7	14.25	11.58	10.03	4.671

1967	3.069	3.035	2.896	2.614	2.409	1.701

1968	8.56	8.38	7.675	6.287	5.45	2.273

1969	5.46	5.357	5.124	4.396	3.892	1.956

1970	2.4	2.345	2.128	1.816	1.765	1.048

1971	6.952	6.81	6.223	5.131	4.881	2.576

1972	2.756	2.706	2.502	2.233	2.031	1.15

1973	2.109	2.069	1.968	1.866	1.792	0.9159

1974	5.179	5.102	4.72	3.909	3.396	1.445

1975	3.035	2.971	2.726	2.251	2.01	1.233

1976	12.62	12.39	11.53	9.825	8.995	4.192

1977	1.88	1.837	1.714	1.619	1.523	1.118

1978	1.602	1.565	1.421	1.337	1.278	0.6743

1979	1.461	1.427	1.304	1.145	1.04	0.5849

1980	5.023	4.929	4.5	3.632	3.132	1.623

1981	1.565	1.529	1.387	1.276	1.222	0.7967

1982	5.846	5.753	5.376	4.844	4.576	2.162

1983	2.743	2.703	2.492	2.398	2.317	1.295

1984	10.6	10.42	9.653	8.537	8.545	3.988

1985	1.841	1.806	1.697	1.559	1.529	1.038

1986	1.867	1.84	1.679	1.404	1.239	0.6823

1987	2.407	2.354	2.14	1.739	1.515	0.7955

1988	1.338	1.309	1.194	1.038	1.003	0.5808

1989	1.267	1.239	1.126	0.9689	0.9342	0.4958

1990	1.281	1.251	1.198	0.9955	0.953	0.5079

Sorted results

Prob.	Peak	96 hr	21 Day	60 Day	90 Day	Yearly

0.032258064516129	16.06	15.7	14.25	11.58	10.03	4.671

0.0645161290322581	12.62	12.39	11.53	9.825	8.995	4.192

0.0967741935483871	10.6	10.42	9.653	8.537	8.545	3.988

0.129032258064516	10.33	10.1	9.353	7.649	6.617	2.702

0.161290322580645	8.56	8.38	7.675	6.287	5.45	2.576

0.193548387096774	6.952	6.81	6.223	5.131	4.881	2.273

0.225806451612903	6.522	6.393	5.844	4.844	4.576	2.162

0.258064516129032	5.846	5.753	5.376	4.781	4.142	1.956

0.290322580645161	5.46	5.357	5.124	4.396	3.892	1.701

0.32258064516129	5.179	5.102	4.72	3.909	3.396	1.629

0.354838709677419	5.023	4.929	4.5	3.632	3.132	1.623

0.387096774193548	3.237	3.164	3.003	2.614	2.409	1.513

0.419354838709677	3.069	3.035	2.896	2.477	2.317	1.445

0.451612903225806	3.035	2.971	2.726	2.398	2.159	1.295

0.483870967741936	2.756	2.706	2.502	2.251	2.031	1.233

0.516129032258065	2.743	2.703	2.492	2.233	2.01	1.15

0.548387096774194	2.407	2.354	2.14	1.866	1.792	1.118

0.580645161290323	2.4	2.345	2.128	1.816	1.765	1.048

0.612903225806452	2.109	2.069	1.968	1.739	1.529	1.038

0.645161290322581	2.048	2.006	1.904	1.621	1.523	1.009

0.67741935483871	1.88	1.84	1.714	1.619	1.515	0.9159

0.709677419354839	1.867	1.837	1.697	1.559	1.473	0.7967

0.741935483870968	1.841	1.806	1.679	1.404	1.278	0.7955

0.774193548387097	1.602	1.565	1.421	1.337	1.239	0.6823

0.806451612903226	1.565	1.529	1.387	1.276	1.222	0.679

0.838709677419355	1.479	1.45	1.332	1.145	1.112	0.6743

0.870967741935484	1.461	1.427	1.304	1.139	1.04	0.5849

0.903225806451613	1.338	1.309	1.198	1.038	1.003	0.5808

0.935483870967742	1.281	1.251	1.194	0.9955	0.953	0.5079

0.967741935483871	1.267	1.239	1.126	0.9689	0.9342	0.4958

0.1	10.573	10.388	9.623	8.4482	8.3522	3.8594

					Average of yearly averages:	1.56783666666667

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

Data used for this run:

Output File: MefluDEA

Metfile:	w12834.dvf

PRZM scenario:	FLturfC.txt

EXAMS environment file:	pond298.exv

Chemical Name:	Mefluidide

Description	Variable Name	Value	Units	Comments

Molecular weight	mwt	310.6	g/mol

Henry's Law Const.	henry	2.27E-7	atm-m^3/mol

Vapor Pressure	vapr	1E-4	torr

Solubility	sol	180	mg/L

Kd	Kd	0.073	mg/L

Koc	Koc		mg/L

Photolysis half-life	kdp		days	Half-life

Aerobic Aquatic Metabolism	kbacw	72	days	Halfife

Anaerobic Aquatic Metabolism	kbacs		days	Halfife

Aerobic Soil Metabolism	asm	36 	days	Halfife

Hydrolysis:	pH 7		days	Half-life

Method:	CAM	2	integer	See PRZM manual

Incorporation Depth:	DEPI		cm

Application Rate:	TAPP	1.12	kg/ha

Application Efficiency:	APPEFF	0.99	fraction

Spray Drift	DRFT	0.01	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	42	days	Set to 0 or delete line for single app.

Interval 2	interval	42	days	Set to 0 or delete line for single app.

Record 17:	FILTRA	

	IPSCND	1

	UPTKF	

Record 18:	PLVKRT	

	PLDKRT	0.1715

	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 mefluidide-K

stored as MefluK.out

Chemical: Mefluidide

PRZM environment: FLturfC.txt	modified Monday, 16 June 2003 at 13:48:06

EXAMS environment: pond298.exv	modified Thuday, 29 August 2002 at
16:33:30

Metfile: w12834.dvf	modified Wedday, 3 July 2002 at 09:04:28

Water segment concentrations (ppb)

Year	Peak	96 hr	21 Day	60 Day	90 Day	Yearly

1961	6.522	6.393	5.844	4.781	4.142	1.629

1962	2.048	2.006	1.904	1.621	1.473	1.009

1963	10.33	10.1	9.353	7.649	6.617	2.702

1964	3.237	3.164	3.003	2.477	2.159	1.513

1965	1.479	1.45	1.332	1.139	1.112	0.679

1966	16.06	15.7	14.25	11.58	10.03	4.671

1967	3.069	3.035	2.896	2.614	2.409	1.701

1968	8.56	8.38	7.675	6.287	5.45	2.273

1969	5.46	5.357	5.124	4.396	3.892	1.956

1970	2.4	2.345	2.128	1.816	1.765	1.048

1971	6.952	6.81	6.223	5.131	4.881	2.576

1972	2.756	2.706	2.502	2.233	2.031	1.15

1973	2.109	2.069	1.968	1.866	1.792	0.9159

1974	5.179	5.102	4.72	3.909	3.396	1.445

1975	3.035	2.971	2.726	2.251	2.01	1.233

1976	12.62	12.39	11.53	9.825	8.995	4.192

1977	1.88	1.837	1.714	1.619	1.523	1.118

1978	1.602	1.565	1.421	1.337	1.278	0.6743

1979	1.461	1.427	1.304	1.145	1.04	0.5849

1980	5.023	4.929	4.5	3.632	3.132	1.623

1981	1.565	1.529	1.387	1.276	1.222	0.7967

1982	5.846	5.753	5.376	4.844	4.576	2.162

1983	2.743	2.703	2.492	2.398	2.317	1.295

1984	10.6	10.42	9.653	8.537	8.545	3.988

1985	1.841	1.806	1.697	1.559	1.529	1.038

1986	1.867	1.84	1.679	1.404	1.239	0.6823

1987	2.407	2.354	2.14	1.739	1.515	0.7955

1988	1.338	1.309	1.194	1.038	1.003	0.5808

1989	1.267	1.239	1.126	0.9689	0.9342	0.4958

1990	1.281	1.251	1.198	0.9955	0.953	0.5079

Sorted results

Prob.	Peak	96 hr	21 Day	60 Day	90 Day	Yearly

0.032258064516129	16.06	15.7	14.25	11.58	10.03	4.671

0.0645161290322581	12.62	12.39	11.53	9.825	8.995	4.192

0.0967741935483871	10.6	10.42	9.653	8.537	8.545	3.988

0.129032258064516	10.33	10.1	9.353	7.649	6.617	2.702

0.161290322580645	8.56	8.38	7.675	6.287	5.45	2.576

0.193548387096774	6.952	6.81	6.223	5.131	4.881	2.273

0.225806451612903	6.522	6.393	5.844	4.844	4.576	2.162

0.258064516129032	5.846	5.753	5.376	4.781	4.142	1.956

0.290322580645161	5.46	5.357	5.124	4.396	3.892	1.701

0.32258064516129	5.179	5.102	4.72	3.909	3.396	1.629

0.354838709677419	5.023	4.929	4.5	3.632	3.132	1.623

0.387096774193548	3.237	3.164	3.003	2.614	2.409	1.513

0.419354838709677	3.069	3.035	2.896	2.477	2.317	1.445

0.451612903225806	3.035	2.971	2.726	2.398	2.159	1.295

0.483870967741936	2.756	2.706	2.502	2.251	2.031	1.233

0.516129032258065	2.743	2.703	2.492	2.233	2.01	1.15

0.548387096774194	2.407	2.354	2.14	1.866	1.792	1.118

0.580645161290323	2.4	2.345	2.128	1.816	1.765	1.048

0.612903225806452	2.109	2.069	1.968	1.739	1.529	1.038

0.645161290322581	2.048	2.006	1.904	1.621	1.523	1.009

0.67741935483871	1.88	1.84	1.714	1.619	1.515	0.9159

0.709677419354839	1.867	1.837	1.697	1.559	1.473	0.7967

0.741935483870968	1.841	1.806	1.679	1.404	1.278	0.7955

0.774193548387097	1.602	1.565	1.421	1.337	1.239	0.6823

0.806451612903226	1.565	1.529	1.387	1.276	1.222	0.679

0.838709677419355	1.479	1.45	1.332	1.145	1.112	0.6743

0.870967741935484	1.461	1.427	1.304	1.139	1.04	0.5849

0.903225806451613	1.338	1.309	1.198	1.038	1.003	0.5808

0.935483870967742	1.281	1.251	1.194	0.9955	0.953	0.5079

0.967741935483871	1.267	1.239	1.126	0.9689	0.9342	0.4958

0.1	10.573	10.388	9.623	8.4482	8.3522	3.8594

					Average of yearly averages:	1.56783666666667

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

Data used for this run:

Output File: MefluK

Metfile:	w12834.dvf

PRZM scenario:	FLturfC.txt

EXAMS environment file:	pond298.exv

Chemical Name:	Mefluidide

Description	Variable Name	Value	Units	Comments

Molecular weight	mwt	310.6	g/mol

Henry's Law Const.	henry	2.27E-7	atm-m^3/mol

Vapor Pressure	vapr	1E-4	torr

Solubility	sol	180	mg/L

Kd	Kd	0.073	mg/L

Koc	Koc		mg/L

Photolysis half-life	kdp		days	Half-life

Aerobic Aquatic Metabolism	kbacw	72	days	Halfife

Anaerobic Aquatic Metabolism	kbacs		days	Halfife

Aerobic Soil Metabolism	asm	36 	days	Halfife

Hydrolysis:	pH 7		days	Half-life

Method:	CAM	2	integer	See PRZM manual

Incorporation Depth:	DEPI		cm

Application Rate:	TAPP	1.12	kg/ha

Application Efficiency:	APPEFF	0.99	fraction

Spray Drift	DRFT	0.01	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	42	days	Set to 0 or delete line for single app.

Interval 2	interval	42	days	Set to 0 or delete line for single app.

Record 17:	FILTRA	

	IPSCND	1

	UPTKF	

Record 18:	PLVKRT	

	PLDKRT	0.1715

	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 mefluidide

stored as Mefluacidi.out

Chemical: Mefluidide

PRZM environment: FLturfC.txt	modified Monday, 16 June 2003 at 13:48:06

EXAMS environment: pond298.exv	modified Thuday, 29 August 2002 at
16:33:30

Metfile: w12834.dvf	modified Wedday, 3 July 2002 at 09:04:28

Water segment concentrations (ppb)

Year	Peak	96 hr	21 Day	60 Day	90 Day	Yearly

1961	2.705	2.623	2.395	1.959	1.697	0.6036

1962	0.4867	0.4819	0.4621	0.4172	0.3845	0.2598

1963	4.628	4.521	4.186	3.424	2.962	1.119

1964	1.063	1.039	0.9768	0.8114	0.7087	0.5198

1965	0.2023	0.2004	0.1923	0.1746	0.1613	0.0877

1966	7.509	7.344	6.666	5.416	4.692	2.106

1967	1.435	1.419	1.354	1.222	1.126	0.6051

1968	3.711	3.633	3.324	2.724	2.361	0.8962

1969	2.254	2.212	2.11	1.748	1.51	0.7417

1970	0.6738	0.6621	0.6153	0.5286	0.4994	0.2943

1971	2.902	2.842	2.597	2.132	1.999	1.053

1972	0.8825	0.8664	0.8012	0.6593	0.5722	0.3381

1973	0.7281	0.7167	0.6819	0.5861	0.5181	0.2195

1974	1.999	1.973	1.825	1.513	1.314	0.4854

1975	0.9183	0.8987	0.8271	0.6841	0.5946	0.3775

1976	5.849	5.746	5.348	4.478	4.143	1.863

1977	0.7792	0.773	0.7472	0.6889	0.6377	0.3198

1978	0.3362	0.3306	0.3074	0.2628	0.2355	0.1042

1979	0.209	0.2042	0.1856	0.1521	0.1322	0.05641

1980	1.927	1.886	1.725	1.393	1.199	0.5759

1981	0.3447	0.3422	0.3319	0.306	0.2846	0.157

1982	2.621	2.58	2.411	2.08	1.908	0.8387

1983	0.9113	0.8994	0.8361	0.7669	0.7557	0.396

1984	4.858	4.774	4.423	3.942	3.914	1.755

1985	0.6437	0.6381	0.615	0.5619	0.5184	0.2808

1986	0.3765	0.3696	0.3383	0.2763	0.2394	0.09841

1987	0.6123	0.5988	0.544	0.4412	0.3805	0.1559

1988	0.1109	0.1099	0.1057	0.09663	0.08981	0.04412

1989	0.02912	0.02866	0.02658	0.02215	0.01923	0.009001

1990	0.08553	0.08355	0.07587	0.0616	0.05313	0.01983

Sorted results

Prob.	Peak	96 hr	21 Day	60 Day	90 Day	Yearly

0.032258064516129	7.509	7.344	6.666	5.416	4.692	2.106

0.0645161290322581	5.849	5.746	5.348	4.478	4.143	1.863

0.0967741935483871	4.858	4.774	4.423	3.942	3.914	1.755

0.129032258064516	4.628	4.521	4.186	3.424	2.962	1.119

0.161290322580645	3.711	3.633	3.324	2.724	2.361	1.053

0.193548387096774	2.902	2.842	2.597	2.132	1.999	0.8962

0.225806451612903	2.705	2.623	2.411	2.08	1.908	0.8387

0.258064516129032	2.621	2.58	2.395	1.959	1.697	0.7417

0.290322580645161	2.254	2.212	2.11	1.748	1.51	0.6051

0.32258064516129	1.999	1.973	1.825	1.513	1.314	0.6036

0.354838709677419	1.927	1.886	1.725	1.393	1.199	0.5759

0.387096774193548	1.435	1.419	1.354	1.222	1.126	0.5198

0.419354838709677	1.063	1.039	0.9768	0.8114	0.7557	0.4854

0.451612903225806	0.9183	0.8994	0.8361	0.7669	0.7087	0.396

0.483870967741936	0.9113	0.8987	0.8271	0.6889	0.6377	0.3775

0.516129032258065	0.8825	0.8664	0.8012	0.6841	0.5946	0.3381

0.548387096774194	0.7792	0.773	0.7472	0.6593	0.5722	0.3198

0.580645161290323	0.7281	0.7167	0.6819	0.5861	0.5184	0.2943

0.612903225806452	0.6738	0.6621	0.6153	0.5619	0.5181	0.2808

0.645161290322581	0.6437	0.6381	0.615	0.5286	0.4994	0.2598

0.67741935483871	0.6123	0.5988	0.544	0.4412	0.3845	0.2195

0.709677419354839	0.4867	0.4819	0.4621	0.4172	0.3805	0.157

0.741935483870968	0.3765	0.3696	0.3383	0.306	0.2846	0.1559

0.774193548387097	0.3447	0.3422	0.3319	0.2763	0.2394	0.1042

0.806451612903226	0.3362	0.3306	0.3074	0.2628	0.2355	0.09841

0.838709677419355	0.209	0.2042	0.1923	0.1746	0.1613	0.0877

0.870967741935484	0.2023	0.2004	0.1856	0.1521	0.1322	0.05641

0.903225806451613	0.1109	0.1099	0.1057	0.09663	0.08981	0.04412

0.935483870967742	0.08553	0.08355	0.07587	0.0616	0.05313	0.01983

0.967741935483871	0.02912	0.02866	0.02658	0.02215	0.01923	0.009001

0.1	4.835	4.7487	4.3993	3.8902	3.8188	1.6914

					Average of yearly averages:	0.5460257

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

Data used for this run:

Output File: Mefluacidi

Metfile:	w12834.dvf

PRZM scenario:	FLturfC.txt

EXAMS environment file:	pond298.exv

Chemical Name:	Mefluidide

Description	Variable Name	Value	Units	Comments

Molecular weight	mwt	310.6	g/mol

Henry's Law Const.	henry	2.27E-7	atm-m^3/mol

Vapor Pressure	vapr	1E-4	torr

Solubility	sol	180	mg/L

Kd	Kd	0.073	mg/L

Koc	Koc		mg/L

Photolysis half-life	kdp		days	Half-life

Aerobic Aquatic Metabolism	kbacw	72	days	Halfife

Anaerobic Aquatic Metabolism	kbacs		days	Halfife

Aerobic Soil Metabolism	asm	36 	days	Halfife

Hydrolysis:	pH 7		days	Half-life

Method:	CAM	2	integer	See PRZM manual

Incorporation Depth:	DEPI		cm

Application Rate:	TAPP	0.56	kg/ha

Application Efficiency:	APPEFF	1.00	fraction

Spray Drift	DRFT	0.0	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	42	days	Set to 0 or delete line for single app.

Interval 2	interval	42	days	Set to 0 or delete line for single app.

Record 17:	FILTRA	

	IPSCND	1

	UPTKF	

Record 18:	PLVKRT	

	PLDKRT	0.1715

	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 mefluidide-DEA

stored as MefluDEA.out

Chemical: Mefluidide

PRZM environment: PAturfC.txt	modified Satday, 12 October 2002 at
16:27:02

EXAMS environment: pond298.exv	modified Thuday, 29 August 2002 at
16:33:30

Metfile: w14737.dvf	modified Wedday, 3 July 2002 at 09:06:12

Water segment concentrations (ppb)

Year	Peak	96 hr	21 Day	60 Day	90 Day	Yearly

1961	1.508	1.481	1.375	1.288	1.184	0.6653

1962	1.894	1.864	1.74	1.627	1.567	1.027

1963	1.689	1.663	1.549	1.395	1.353	0.9127

1964	1.64	1.616	1.507	1.342	1.309	0.861

1965	1.606	1.582	1.477	1.306	1.277	0.8369

1966	1.618	1.591	1.472	1.321	1.274	0.8173

1967	2.52	2.478	2.31	2.014	1.848	1.149

1968	3.188	3.157	3.052	2.893	2.82	1.641

1969	1.823	1.795	1.677	1.549	1.499	1.083

1970	10.34	10.26	9.907	9.204	8.608	4.205

1971	5.302	5.247	5.022	4.55	4.182	2.656

1972	2.679	2.641	2.464	2.311	2.18	1.537

1973	10.43	10.25	9.455	7.943	7.066	3.655

1974	4.838	4.792	4.605	4.369	4.183	2.896

1975	7.102	7.045	6.814	6.374	5.981	3.199

1976	5.928	5.872	5.64	5.283	4.982	2.834

1977	2.329	2.298	2.172	2.051	2.021	1.455

1978	5.93	5.872	5.592	5.087	4.753	2.412

1979	2.673	2.634	2.47	2.386	2.27	1.662

1980	1.753	1.726	1.601	1.465	1.403	0.9518

1981	2.388	2.359	2.239	2.1	1.963	1.108

1982	2.107	2.078	1.943	1.781	1.701	1.123

1983	1.87	1.84	1.719	1.599	1.527	0.9895

1984	6.622	6.507	6.052	5.134	4.63	2.621

1985	2.641	2.607	2.468	2.323	2.243	1.695

1986	2.182	2.148	2.018	1.904	1.816	1.182

1987	3.103	3.066	2.944	2.855	2.755	1.587

1988	2.9	2.866	2.718	2.551	2.358	1.403

1989	3.313	3.275	3.116	2.887	2.683	1.541

1990	2.244	2.208	2.074	1.949	1.867	1.252

Sorted results

Prob.	Peak	96 hr	21 Day	60 Day	90 Day	Yearly

0.032258064516129	10.43	10.26	9.907	9.204	8.608	4.205

0.0645161290322581	10.34	10.25	9.455	7.943	7.066	3.655

0.0967741935483871	7.102	7.045	6.814	6.374	5.981	3.199

0.129032258064516	6.622	6.507	6.052	5.283	4.982	2.896

0.161290322580645	5.93	5.872	5.64	5.134	4.753	2.834

0.193548387096774	5.928	5.872	5.592	5.087	4.63	2.656

0.225806451612903	5.302	5.247	5.022	4.55	4.183	2.621

0.258064516129032	4.838	4.792	4.605	4.369	4.182	2.412

0.290322580645161	3.313	3.275	3.116	2.893	2.82	1.695

0.32258064516129	3.188	3.157	3.052	2.887	2.755	1.662

0.354838709677419	3.103	3.066	2.944	2.855	2.683	1.641

0.387096774193548	2.9	2.866	2.718	2.551	2.358	1.587

0.419354838709677	2.679	2.641	2.47	2.386	2.27	1.541

0.451612903225806	2.673	2.634	2.468	2.323	2.243	1.537

0.483870967741936	2.641	2.607	2.464	2.311	2.18	1.455

0.516129032258065	2.52	2.478	2.31	2.1	2.021	1.403

0.548387096774194	2.388	2.359	2.239	2.051	1.963	1.252

0.580645161290323	2.329	2.298	2.172	2.014	1.867	1.182

0.612903225806452	2.244	2.208	2.074	1.949	1.848	1.149

0.645161290322581	2.182	2.148	2.018	1.904	1.816	1.123

0.67741935483871	2.107	2.078	1.943	1.781	1.701	1.108

0.709677419354839	1.894	1.864	1.74	1.627	1.567	1.083

0.741935483870968	1.87	1.84	1.719	1.599	1.527	1.027

0.774193548387097	1.823	1.795	1.677	1.549	1.499	0.9895

0.806451612903226	1.753	1.726	1.601	1.465	1.403	0.9518

0.838709677419355	1.689	1.663	1.549	1.395	1.353	0.9127

0.870967741935484	1.64	1.616	1.507	1.342	1.309	0.861

0.903225806451613	1.618	1.591	1.477	1.321	1.277	0.8369

0.935483870967742	1.606	1.582	1.472	1.306	1.274	0.8173

0.967741935483871	1.508	1.481	1.375	1.288	1.184	0.6653

0.1	7.054	6.9912	6.7378	6.2649	5.8811	3.1687

					Average of yearly averages:	1.69858333333333

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

Data used for this run:

Output File: MefluDEA

Metfile:	w14737.dvf

PRZM scenario:	PAturfC.txt

EXAMS environment file:	pond298.exv

Chemical Name:	Mefluidide

Description	Variable Name	Value	Units	Comments

Molecular weight	mwt	310.6	g/mol

Henry's Law Const.	henry	2.27E-7	atm-m^3/mol

Vapor Pressure	vapr	1E-4	torr

Solubility	sol	180	mg/L

Kd	Kd	0.073	mg/L

Koc	Koc		mg/L

Photolysis half-life	kdp		days	Half-life

Aerobic Aquatic Metabolism	kbacw	72	days	Halfife

Anaerobic Aquatic Metabolism	kbacs		days	Halfife

Aerobic Soil Metabolism	asm	36 	days	Halfife

Hydrolysis:	pH 7		days	Half-life

Method:	CAM	2	integer	See PRZM manual

Incorporation Depth:	DEPI		cm

Application Rate:	TAPP	1.12	kg/ha

Application Efficiency:	APPEFF	0.99	fraction

Spray Drift	DRFT	0.01	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	42	days	Set to 0 or delete line for single app.

Interval 2	interval	42	days	Set to 0 or delete line for single app.

Record 17:	FILTRA	

	IPSCND	1

	UPTKF	

Record 18:	PLVKRT	

	PLDKRT	0.1715

	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 mefluidide-K

stored as MefluK.out

Chemical: Mefluidide

PRZM environment: PAturfC.txt	modified Satday, 12 October 2002 at
15:27:02

EXAMS environment: pond298.exv	modified Thuday, 29 August 2002 at
15:33:30

Metfile: w14737.dvf	modified Wedday, 3 July 2002 at 08:06:12

Water segment concentrations (ppb)

Year	Peak	96 hr	21 Day	60 Day	90 Day	Yearly

1961	1.508	1.481	1.375	1.288	1.184	0.6653

1962	1.894	1.864	1.74	1.627	1.567	1.027

1963	1.689	1.663	1.549	1.395	1.353	0.9127

1964	1.64	1.616	1.507	1.342	1.309	0.861

1965	1.606	1.582	1.477	1.306	1.277	0.8369

1966	1.618	1.591	1.472	1.321	1.274	0.8173

1967	2.52	2.478	2.31	2.014	1.848	1.149

1968	3.188	3.157	3.052	2.893	2.82	1.641

1969	1.823	1.795	1.677	1.549	1.499	1.083

1970	10.34	10.26	9.907	9.204	8.608	4.205

1971	5.302	5.247	5.022	4.55	4.182	2.656

1972	2.679	2.641	2.464	2.311	2.18	1.537

1973	10.43	10.25	9.455	7.943	7.066	3.655

1974	4.838	4.792	4.605	4.369	4.183	2.896

1975	7.102	7.045	6.814	6.374	5.981	3.199

1976	5.928	5.872	5.64	5.283	4.982	2.834

1977	2.329	2.298	2.172	2.051	2.021	1.455

1978	5.93	5.872	5.592	5.087	4.753	2.412

1979	2.673	2.634	2.47	2.386	2.27	1.662

1980	1.753	1.726	1.601	1.465	1.403	0.9518

1981	2.388	2.359	2.239	2.1	1.963	1.108

1982	2.107	2.078	1.943	1.781	1.701	1.123

1983	1.87	1.84	1.719	1.599	1.527	0.9895

1984	6.622	6.507	6.052	5.134	4.63	2.621

1985	2.641	2.607	2.468	2.323	2.243	1.695

1986	2.182	2.148	2.018	1.904	1.816	1.182

1987	3.103	3.066	2.944	2.855	2.755	1.587

1988	2.9	2.866	2.718	2.551	2.358	1.403

1989	3.313	3.275	3.116	2.887	2.683	1.541

1990	2.244	2.208	2.074	1.949	1.867	1.252

Sorted results

Prob.	Peak	96 hr	21 Day	60 Day	90 Day	Yearly

0.032258064516129	10.43	10.26	9.907	9.204	8.608	4.205

0.0645161290322581	10.34	10.25	9.455	7.943	7.066	3.655

0.0967741935483871	7.102	7.045	6.814	6.374	5.981	3.199

0.129032258064516	6.622	6.507	6.052	5.283	4.982	2.896

0.161290322580645	5.93	5.872	5.64	5.134	4.753	2.834

0.193548387096774	5.928	5.872	5.592	5.087	4.63	2.656

0.225806451612903	5.302	5.247	5.022	4.55	4.183	2.621

0.258064516129032	4.838	4.792	4.605	4.369	4.182	2.412

0.290322580645161	3.313	3.275	3.116	2.893	2.82	1.695

0.32258064516129	3.188	3.157	3.052	2.887	2.755	1.662

0.354838709677419	3.103	3.066	2.944	2.855	2.683	1.641

0.387096774193548	2.9	2.866	2.718	2.551	2.358	1.587

0.419354838709677	2.679	2.641	2.47	2.386	2.27	1.541

0.451612903225806	2.673	2.634	2.468	2.323	2.243	1.537

0.483870967741936	2.641	2.607	2.464	2.311	2.18	1.455

0.516129032258065	2.52	2.478	2.31	2.1	2.021	1.403

0.548387096774194	2.388	2.359	2.239	2.051	1.963	1.252

0.580645161290323	2.329	2.298	2.172	2.014	1.867	1.182

0.612903225806452	2.244	2.208	2.074	1.949	1.848	1.149

0.645161290322581	2.182	2.148	2.018	1.904	1.816	1.123

0.67741935483871	2.107	2.078	1.943	1.781	1.701	1.108

0.709677419354839	1.894	1.864	1.74	1.627	1.567	1.083

0.741935483870968	1.87	1.84	1.719	1.599	1.527	1.027

0.774193548387097	1.823	1.795	1.677	1.549	1.499	0.9895

0.806451612903226	1.753	1.726	1.601	1.465	1.403	0.9518

0.838709677419355	1.689	1.663	1.549	1.395	1.353	0.9127

0.870967741935484	1.64	1.616	1.507	1.342	1.309	0.861

0.903225806451613	1.618	1.591	1.477	1.321	1.277	0.8369

0.935483870967742	1.606	1.582	1.472	1.306	1.274	0.8173

0.967741935483871	1.508	1.481	1.375	1.288	1.184	0.6653

0.1	7.054	6.9912	6.7378	6.2649	5.8811	3.1687

					Average of yearly averages:	1.69858333333333

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

Data used for this run:

Output File: MefluK

Metfile:	w14737.dvf

PRZM scenario:	PAturfC.txt

EXAMS environment file:	pond298.exv

Chemical Name:	Mefluidide

Description	Variable Name	Value	Units	Comments

Molecular weight	mwt	310.6	g/mol

Henry's Law Const.	henry	2.27E-7	atm-m^3/mol

Vapor Pressure	vapr	1E-4	torr

Solubility	sol	180	mg/L

Kd	Kd	0.073	mg/L

Koc	Koc		mg/L

Photolysis half-life	kdp		days	Half-life

Aerobic Aquatic Metabolism	kbacw	72	days	Halfife

Anaerobic Aquatic Metabolism	kbacs		days	Halfife

Aerobic Soil Metabolism	asm	36 	days	Halfife

Hydrolysis:	pH 7		days	Half-life

Method:	CAM	2	integer	See PRZM manual

Incorporation Depth:	DEPI		cm

Application Rate:	TAPP	1.12	kg/ha

Application Efficiency:	APPEFF	0.99	fraction

Spray Drift	DRFT	0.01	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	42	days	Set to 0 or delete line for single app.

Interval 2	interval	42	days	Set to 0 or delete line for single app.

Record 17:	FILTRA	

	IPSCND	1

	UPTKF	

Record 18:	PLVKRT	

	PLDKRT	0.1715

	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 mefluidide

stored as Mefluacid.out

Chemical: Mefluidide

PRZM environment: PAturfC.txt	modified Satday, 12 October 2002 at
16:27:02

EXAMS environment: pond298.exv	modified Thuday, 29 August 2002 at
16:33:30

Metfile: w14737.dvf	modified Wedday, 3 July 2002 at 09:06:12

Water segment concentrations (ppb)

Year	Peak	96 hr	21 Day	60 Day	90 Day	Yearly

1961	0.2013	0.1977	0.1837	0.1572	0.141	0.06874

1962	0.3033	0.3007	0.291	0.265	0.243	0.1292

1963	0.06957	0.06934	0.06838	0.06625	0.06425	0.03723

1964	0.02459	0.0244	0.02365	0.02181	0.0201	0.01287

1965	0.006556	0.006535	0.006445	0.006245	0.006063	0.003507

1966	0.001198	0.001194	0.001178	0.001142	0.001107	0.0007252

1967	0.5128	0.5042	0.4697	0.4045	0.3667	0.1522

1968	0.9759	0.9672	0.9291	0.8587	0.7887	0.3996

1969	0.2438	0.243	0.2397	0.2322	0.2251	0.1299

1970	4.701	4.666	4.505	4.108	3.775	1.704

1971	1.972	1.952	1.868	1.635	1.465	0.9264

1972	0.6406	0.6321	0.5955	0.5166	0.4622	0.3636

1973	4.493	4.414	4.073	3.421	3.043	1.441

1974	1.962	1.943	1.868	1.697	1.565	1.058

1975	3.083	3.059	2.958	2.691	2.461	1.205

1976	2.504	2.481	2.382	2.164	1.981	1.031

1977	0.5919	0.5865	0.5663	0.5151	0.5046	0.333

1978	2.308	2.287	2.179	1.926	1.775	0.8143

1979	0.6768	0.6705	0.6519	0.6315	0.6109	0.4296

1980	0.184	0.1834	0.1809	0.1753	0.17	0.09462

1981	0.5482	0.5415	0.5138	0.4424	0.3929	0.1747

1982	0.3024	0.2988	0.2824	0.246	0.2211	0.149

1983	0.21	0.2082	0.2015	0.1855	0.1727	0.09921

1984	2.558	2.513	2.339	1.984	1.768	0.9311

1985	0.8114	0.8088	0.7976	0.7681	0.7392	0.4633

1986	0.4099	0.4043	0.3805	0.3328	0.2998	0.1956

1987	1.062	1.053	1.014	0.9196	0.8384	0.3995

1988	0.7952	0.7858	0.7451	0.6441	0.5769	0.3123

1989	0.9959	0.9843	0.9364	0.8137	0.7298	0.3742

1990	0.4174	0.4126	0.3863	0.3501	0.3269	0.2328

Sorted results

Prob.	Peak	96 hr	21 Day	60 Day	90 Day	Yearly

0.032258064516129	4.701	4.666	4.505	4.108	3.775	1.704

0.0645161290322581	4.493	4.414	4.073	3.421	3.043	1.441

0.0967741935483871	3.083	3.059	2.958	2.691	2.461	1.205

0.129032258064516	2.558	2.513	2.382	2.164	1.981	1.058

0.161290322580645	2.504	2.481	2.339	1.984	1.775	1.031

0.193548387096774	2.308	2.287	2.179	1.926	1.768	0.9311

0.225806451612903	1.972	1.952	1.868	1.697	1.565	0.9264

0.258064516129032	1.962	1.943	1.868	1.635	1.465	0.8143

0.290322580645161	1.062	1.053	1.014	0.9196	0.8384	0.4633

0.32258064516129	0.9959	0.9843	0.9364	0.8587	0.7887	0.4296

0.354838709677419	0.9759	0.9672	0.9291	0.8137	0.7392	0.3996

0.387096774193548	0.8114	0.8088	0.7976	0.7681	0.7298	0.3995

0.419354838709677	0.7952	0.7858	0.7451	0.6441	0.6109	0.3742

0.451612903225806	0.6768	0.6705	0.6519	0.6315	0.5769	0.3636

0.483870967741936	0.6406	0.6321	0.5955	0.5166	0.5046	0.333

0.516129032258065	0.5919	0.5865	0.5663	0.5151	0.4622	0.3123

0.548387096774194	0.5482	0.5415	0.5138	0.4424	0.3929	0.2328

0.580645161290323	0.5128	0.5042	0.4697	0.4045	0.3667	0.1956

0.612903225806452	0.4174	0.4126	0.3863	0.3501	0.3269	0.1747

0.645161290322581	0.4099	0.4043	0.3805	0.3328	0.2998	0.1522

0.67741935483871	0.3033	0.3007	0.291	0.265	0.243	0.149

0.709677419354839	0.3024	0.2988	0.2824	0.246	0.2251	0.1299

0.741935483870968	0.2438	0.243	0.2397	0.2322	0.2211	0.1292

0.774193548387097	0.21	0.2082	0.2015	0.1855	0.1727	0.09921

0.806451612903226	0.2013	0.1977	0.1837	0.1753	0.17	0.09462

0.838709677419355	0.184	0.1834	0.1809	0.1572	0.141	0.06874

0.870967741935484	0.06957	0.06934	0.06838	0.06625	0.06425	0.03723

0.903225806451613	0.02459	0.0244	0.02365	0.02181	0.0201	0.01287

0.935483870967742	0.006556	0.006535	0.006445	0.006245	0.006063	0.003507

0.967741935483871	0.001198	0.001194	0.001178	0.001142	0.001107	0.0007252

0.1	3.0305	3.0044	2.9004	2.6383	2.413	1.1903

					Average of yearly averages:	0.455540073333333

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

Data used for this run:

Output File: Mefluacid

Metfile:	w14737.dvf

PRZM scenario:	PAturfC.txt

EXAMS environment file:	pond298.exv

Chemical Name:	Mefluidide

Description	Variable Name	Value	Units	Comments

Molecular weight	mwt	310.6	g/mol

Henry's Law Const.	henry	2.27E-7	atm-m^3/mol

Vapor Pressure	vapr	1E-4	torr

Solubility	sol	180	mg/L

Kd	Kd	0.073	mg/L

Koc	Koc		mg/L

Photolysis half-life	kdp		days	Half-life

Aerobic Aquatic Metabolism	kbacw	72	days	Halfife

Anaerobic Aquatic Metabolism	kbacs		days	Halfife

Aerobic Soil Metabolism	asm	36 	days	Halfife

Hydrolysis:	pH 7		days	Half-life

Method:	CAM	2	integer	See PRZM manual

Incorporation Depth:	DEPI		cm

Application Rate:	TAPP	0.56	kg/ha

Application Efficiency:	APPEFF	1.00	fraction

Spray Drift	DRFT	0.00	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	42	days	Set to 0 or delete line for single app.

Interval 2	interval	42	days	Set to 0 or delete line for single app.

Record 17:	FILTRA	

	IPSCND	1

	UPTKF	

Record 18:	PLVKRT	

	PLDKRT	0.1715

	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 D Terrestrial Exposure Modeling TREX and Terrplant

 

                        TREX MODEL OUTPUTS

                                                          TREX (Version
1.3.1)

2006

As part of the terrestrial assessment, EFED modeled exposure
concentrations of Mefluidide, Mefluidide-K and Mefluidide-DEA to
non-target animals following the proposed application rates provided by
the registrant.  For terrestrial birds and mammals, estimates of initial
levels of  Mefluidide, Mefluidide-K and Mefluidide-DEA residues on
various food items, which may be contacted or consumed by wildlife, were
determined using the Kenega-Fletcher nomogram followed by a first order
decline model TREX 1.3.1. Upper bound and Mean Kenega-Fletcher values
were used for RQ calculations.

  T-REX Calculations and Results

  Risk Estimation Based on Dietary Residue Concentrations (Foliar Spray)

The methods used by T-REX to estimate risk from consumption of selected
contaminated food items is described below.  For this analysis, T-REX
calculates EECs and risk quotients based on both the upper bound and
mean residue concentrations as presented by Hoerger and Kenaga (1972)
and modified by Fletcher et al. (1994).  These concentrations are
determined using nomograms that relate application rate of a pesticide
to residues remaining on dietary items of terrestrial organisms.  The
results of the upper bound and mean residue levels are presented in
separate tabs (“upper bound Kenaga” and “mean Kenaga”); however,
the methods used to calculate EECs and risk quotients are equivalent.
Based on the estimated dietary residue concentrations from the upper
bound and mean Kenaga values, T-REX calculates the associated doses for
various size classes of birds and mammals.  

 

T-REX estimates the following:  (1) residue concentrations on selected
food items (mg/kg-dietary item); (2) dose-based EECs (mg/kg-bw) from
dietary concentrations on selected food items; (3) adjusted toxicity
values; and (4) risk quotients.  

Calculation of dietary concentrations on selected food items

The spreadsheet calculates the pesticide residue concentrations on each
selected food item on a daily interval for one year.  When multiple
applications are modeled, residue concentrations resulting from the
final application and remaining residue from previous applications are
summed.  The maximum concentration calculated out of the 365 days is
returned as the EEC used to estimate potential risk to birds and mammals
as described below.  Dissipation of a chemical applied to foliar
surfaces for single or multiple applications is calculated assuming a
first order decay rate from the following first order rate equation:

Ct = C0e-kt

	

or in log form:			

ln(Ct) = ln(C0)(-kT)

Where:

Ct = concentration, parts per million (ppm), at time T.

C0 =	concentration (ppm), present initially (on day zero) on the surface
of selected food items.  C0 is calculated by multiplying the application
rate, in pounds active ingredient per acre, by 240 for short grass, 110
for tall grass, and 135 for broad-leafed plants/small insects and 15 for
fruits/pods/large insects for upper bound residue levels.  Mean residue
levels are derived by multiplying the application rate by 85 for short
grass, 36 for tall grass, and 45 for broad-leafed plants/small insects
and 7 for fruits/pods/seeds/large insects.  Residue levels are based on
work by Hoerger and Kenaga (1972) as modified by Fletcher et al. (1994).
 Additional applications are converted from pounds active ingredient per
acre to ppm on the plant surface and the additional mass added to the
mass of the chemical still present on the surfaces on the day of
application.  

k = 	Exponential rate constant = ln 2 ÷ foliar dissipation half-life. 
This value is in cell Q16 of the upper bound and mean Kenaga worksheets
of TREX.  If the foliar dissipation data submitted to EFED are found
scientifically valid and statistically robust for a specific pesticide,
the 90% upper confidence limit of the mean half-lives should be used. 
When scientifically valid, statistically robust data are not available,
EFED recommends the using a default foliar dissipation half-life value
of 35 days.  The use of the 35-day half-life is based on the highest
reported value (36.9 days), as reported by Willis and McDowell (1987).
However in this assessment a 4 day foliar half life was used.

t = time, in days, since the start of the simulation.  The initial
application is on day 0.  The simulation is designed to run for 365
days.

The dietary concentrations estimated using the above methodology may be
used directly to calculate risk quotients, but may also be used to
calculate dose-based EECs (mg/kg-bw) for various size classes of mammals
and birds .

 Calculating EEC Equivalent Doses based on Estimated Dietary
Concentrations on Selected Bird and Mammal Food Items 

EECs (mg/kg-bw) for various size classes of mammals and birds may be
calculated based on the dietary residue concentrations derived using the
equations presented above.  To allow for this type of analysis, the EECs
and toxicity values are adjusted based on food intake and body weight
differences so that they are comparable for a given weight class of
animal.  The size classes assessed are small (20-gram), medium
(100-gram), and large (1000-gram) birds, and small (15-gram), medium
(35-gram), and large (1000-gram) mammals.  Equations used to calculate
food intake (grams/day) and to adjust toxicity values for dose-based
risk quotients are presented below.  

Calculating Food Intake for Different Size Classes of Birds and Mammals:


Daily food intake (g/day) is assumed to correlate with body weight using
the following empirically derived equation (U.S. EPA, 1993):  

Avian consumption

 

where:

F = food intake in grams of fresh weight per day (g/day)

BW = body mass of animal (g)

W = mass fraction of water in the food (EFED value = 0.8 for birds and
herbivorous mammals, 0.1 for granivorous mammals)

Based on this equation, a 20-gram bird would consume 22.8 grams of food
daily (114% of its body weight), a 100-gram bird would consume 65 grams
of food daily (65% of its body weight daily), and 1000-gram bird would
consume 290 grams of food daily (29% of its body weight).  These data,
together with the residue concentrations (mg/kg-food item) on selected
food items calculated from the Kenaga nomogram, are used to estimate the
dose (mg/kg-bw) of residue consumed by the three size classes of birds
as discussed below.  Using a small (20-gram) bird as an example, a
dietary concentration of 100 mg/kg-diet (ppm) x 1.14 kg diet/kg bw
(114%) would result in an equivalent dose-based EEC of 114 mg/kg-bw. 
T-REX calculates food intake based on dry weight and wet weight of food
items.  The dose-based assessment uses the wet weight food consumption
values by assuming that dietary items are 80% water by weight.  However,
if dietary items of a species being assessed are known, then a refined
dose-based EEC can be calculated using appropriate water fractions of
the food items.  

A similar relationship between body weight and food intake has been
derived for mammals (U.S. EPA 1993):  

Mammalian food consumption (g/day)

 

where:

F = food intake in grams of fresh weight per day (g/day)

BW = body mass of animal (g)

W = mass fraction of water in the food (EFED value = 0.8 for birds and
herbivorous mammals, 0.1 for granivorous mammals)

The scaling factors result in a percent body weight consumed presented
in the following table for each weight class of mammal.  These values
are used in the same manner described for birds to calculate dose-based
EECs (mg/kg-bw).  Note the difference in food intake of grainivores
compared with herbivores and insectivores.  This is caused by the
difference in the assumed mass fraction of water in their diets.  

Organism and body weight	Food intake

(g day-1)a	Percent body weight consumed (day-1) a

15 g	14.3 / 3.2	95 / 21

35 g	23 / 5.1	66 / 15

1000 g	150 / 34	15 / 3

a The first number in this column is specific to
herbivores/insectivores.  The second number is for granivores.  These
groups have markedly different consumption requirements.

T-REX calculates food intake based on dry weight and wet weight of food
items (wet weight is used for RQ calculations). The dose-based
assessment uses the wet weight food consumption values by assuming that
dietary items are 80% water by weight (10% for granivores).  However, if
dietary items of a species being assessed are known, then a refined
dose-based EEC can be calculated using appropriate water fractions of
the food items.  

Calculating Adjusted Toxicity Values

The dose-based EECs (mg/kg-bw) derived above are compared with LD50 or
NOAEL (mg/kg-bw) values from acceptable or supplemental toxicity studies
that are adjusted for the size of the animal tested compared with the
size of the animal being assessed (e.g., 20-gram bird).  These exposure
values are presented as mass of pesticide consumed per kg body weight of
the animal being assessed (mg/kg-bw).  EECs and toxicity values are
relative to the animal’s body weight (mg residue/kg bw) because
consumption of the same mass of pesticide residue results in a higher
body burden in smaller animals compared with larger animals.  For birds,
only acute values (LD50s) are adjusted because dose-based risk quotients
are not calculated for the chronic risk estimation.  Adjusted mammalian
LD50s and reproduction NOAELs (mg/kg-bw) are used to calculate
dose-based acute and chronic risk quotients for 15-, 35-, and 1000-gram
mammals.  The following equations are used for the adjustment (U.S. EPA
1993):

 

where:

Adj. LD50 = adjusted LD50 (mg/kg-bw) calculated by the equation

LD50 = endpoint reported from bird study (mg/kg-bw)

TW = body weight of tested animal (178g bobwhite; 1580g mallard; 350g
rat)

AW = body weight of assessed animal (avian: 20g, 100g, and 1000g)

x = Mineau scaling factor for birds; EFED default 1.15

 

where:

Adj. NOAEL or LD50 = adjusted NOAEL or LD50 (mg/kg-bw)

NOAEL or LD50 = endpoint reported from animal study (mg/kg-bw)

TW = body weight of tested animal (350g for chronic mammal based on the
rat )  TREX does not incorporate in the model different mammal TW.
Therefore, the above calculation was used and incorporated in model 
(replaced the 350 g to 20 g in the formula equations) with the TW of 20
g for acute mammal based on the laboratory mouse with 829.8mg ae/kg bw 
LD50 to derive the adjusted toxicity values for acute mammals for each
body weight class.

AW = body weight of assessed animal (15g, 35g, 1000g)

  Calculating Risk Quotients

Two types of risk quotients are calculated by T-REX based on the
estimated dietary residue concentrations determined from the Kenaga
nomogram:  (1) dietary based RQs; and (2) dose based RQs.  These RQs are
not equivalent.  Dietary risk quotients are calculated by directly
comparing the concentration of a pesticide administered (or estimated to
be administered) to experimental animals in the diet in a toxicity study
to the concentration estimated to be on selected food items.  These risk
quotients do not account for the fact that smaller-sized animals need to
consume more food relative to their body weight than larger animals or
that differential amounts of food are consumed depending on the water
content and nutritive value of the food.  The dose-based risk quotients
do account for these factors.  The dose-based RQs incorporate the
ingestion rate-adjusted exposure from the various food items to the
different weight classes of birds and the weight class-scaled toxicity
endpoints.  Formulas presented in Table 1 are used to calculate
dose-based and dietary based risk quotients:  

Table 1.  Formulas used to calculate dose- and dietary-based risk
quotients.  

Duration	Dose or Dietary RQ	Surrogate Organism	Equation

Acute	Dose-based	Birds and mammals	Acute Daily Exposure (mg/kg-bw) /
adjusted LD50 (mg/kg-bw)



	Dietary-based	Birds 	Kenaga EEC (mg/kg-food item)  / LC50 (mg/kg-diet)



Chronic	Dietary-based	Birds and mammals	EEC (mg/kg-food item) / NOAEC
(mg/kg-diet)



	Dose-based	Mammals only	EEC (mg/kg-bw) / Adjusted NOAEL (mg/kg-bw)





These risk quotients are compared to the Agency’s LOCs to determine if
risk is greater than EFED’s concern level.

Granular LD50 per square foot 

Mammalian  LD50 per Square Foot 0.5 lbs ae A

 Based on  acute mouse LD50 829.8 mg /kg bw, 4 day half life, 42 day
interval and 3 applications per season

Size Class

(grams)

	Broadcast

LD50 per Square Foot



	15	0.39

35	0.21

1000	0.02



	

Upper Bound and Mean Kenaga 1.0 lbs ae/A application Rate based on 
acute mouse LD50 829.8 mg/kg bw, 4  day half life, 42 day interval and 3
applications per season

Upper 90th Percentile Kenaga, Acute Mammalian Dose-Based  Risk Quotients
1.0 Lbs ae/A 

 Based on  acute mouse LD50 829.8, 4 day half life, 42 day interval and
3 applications per season

Size Class

(grams)	Adjusted

LD50	EECs and RQs



Short Grass	Tall Grass	Broadleaf Plants/

Small Insects	Fruits/Pods/

Seeds/

Large Insects	Granivore



EEC	RQ	EEC	RQ	EEC	RQ	EEC	RQ	EEC	RQ

15	891.68	228.98	0.26	104.95	0.12	128.80	0.14	14.31	0.02	3.18	0.00

35	721.46	158.26	0.22	72.53	0.10	89.02	0.12	9.89	0.01	2.20	0.00

1000	312.05	36.69	0.12	16.82	0.05	20.64	0.07	2.29	0.01	0.51	0.00



Mean Kenaga, Acute  Mammalian Dose-Based  Risk Quotients 1.0 Lbs ae/A

 Based on  acute mouse LD50 829.8, 4 day half life, 42 day interval and
3 applications per season

Size Class

(grams)	Adjusted

 LD50	EECs and RQs



Short Grass	Tall Grass	Broadleaf Plants/

Small Insects	Fruits/Pods/

Seeds/

Large Insects	Granivore



EEC	RQ	EEC	RQ	EEC	RQ	EEC	RQ	EEC	RQ

15	891.68	80.81	0.091	34.22	0.038	42.78	0.048	6.65	0.007	1.47	0.00

35	721.46	56.14	0.078	23.78	0.033	29.72	0.041	4.62	0.006	1.05	0.00

1000	312.05	12.76	0.041	5.40	0.017	6.75	0.022	1.05	0.003	0.21	0.00



Upper Bound and Mean Kenaga 1.0 lbs ae/A application Rate based on 
Chronic rat NOAEL 102 mg ae/A, 4 day half life, 42 day interval and 3
applications per season

 

  Upper 90th Percentile Kenega, Chronic Mammalian Dietary Based Risk
Quotients

1.0 lbs ae/A application Rate based on  Chronic rat NOAEL 102 mg ae/A, 4
day half life, 42 day interval and 3 applications per season

NOAEC (ppm)	EECs and RQs

	Short Grass	Tall Grass	Broadleaf Plants/

Small Insects	Fruits/Pods/

Seeds/

Large Insects

	EEC	RQ	EEC	RQ	EEC	RQ	EEC	RQ

2040	240.17	0.12	110.08	0.05	135.09	0.07	15.01	0.01

Size class not used for dietary risk quotients 

 	 	 	 	 	 	 	 	 

  Upper 90th Percentile Kenega, Chronic Mammalian Dose-Based Risk
Quotients

1.0 lbs ae/A application Rate based on  Chronic rat NOAEL 102 mg ae/A, 4
day half life, 42 day interval and 3 applications per season

Size Class

(grams)	Adjusted NOAEL	EECs and RQs



Short Grass	Tall Grass	Broadleaf Plants/

Small Insects	Fruits/Pods/

Seeds/

Large Insects	Granivore



EEC	RQ	EEC	RQ	EEC	RQ	EEC	RQ	EEC	RQ

15	224.18	228.98	1.02	104.95	0.47	128.80	0.57	14.31	0.06	3.18	0.01

35	181.38	158.26	0.87	72.53	0.40	89.02	0.49	9.89	0.05	2.20	0.01

1000	78.45	36.69	0.47	16.82	0.21	20.64	0.26	2.29	0.03	0.51	0.01



 Mean Kenega, Chronic Mammalian Dietary Based Risk Quotients

1.0 lbs ae/A application Rate based on  Chronic rat NOAEL 102 mg ae/A, 4
day half life, 42 day interval and 3 applications per season

NOAEC (ppm)	EECs and RQs

	Short Grass	Tall Grass	Broadleaf Plants/

Small Insects	Fruits/Pods/

Seeds/

Large Insects

	EEC	RQ	EEC	RQ	EEC	RQ	EEC	RQ

2040	85.06	0.04	36.02	0.018	45.03	0.022	7.00	0.003

Size class not used for dietary risk quotients 

 	 	 	 	 	 	 	 	 

 Mean Kenega, Chronic Mammalian Dose-Based Risk Quotients

1.0 lbs ae/A application Rate based on  Chronic rat NOAEL 102 mg ae/A, 4
day half life, 42 day interval and 3 applications per season

Size Class

(grams)	Adjusted NOAEL	EECs and RQs



Short Grass	Tall Grass	Broadleaf Plants/

Small Insects	Fruits/Pods/

Seeds/

Large Insects	Granivore



EEC	RQ	EEC	RQ	EEC	RQ	EEC	RQ	EEC	RQ

15	224.18	80.81	0.36	34.22	0.153	42.78	0.191	6.65	0.030	1.47	0.01

35	181.38	56.14	0.31	23.78	0.131	29.72	0.164	4.62	0.025	1.05	0.01

1000	78.45	12.76	0.163	5.40	0.069	6.75	0.086	1.05	0.013	0.21	0.00

 

Avian Granular LD50 per square foot

Avian LD50 per Square Foot 0.5 lbs ae A

 Based on  acute bird LD50 >1500 mg ae /kg bw, 4 day half life, 42 day
interval and 3 applications per season

Size Class

(grams)	Adjusted LD50



Broadcast

LD50 per Square Foot





 20	1080.64	0.24

100	1375.71	0.04

1000	1943.25	0.00



Upper Bound and Mean Kenaga 1.0 lbs ae/A application Rate based on 
acute avian LD50 >1500 mg/kg bw, 4 day half life, 42 day interval and 3
applications per season

Upper 90th Percentile Kenaga, Acute Avian Dose-Based  Risk Quotients

1.0 lbs ae/A application Rate based on  acute bird LD50 >1500 mg ae/kg
bw, 4 day half life, 42 day interval and 3 applications per season

Size Class

(grams)	Adjusted

LD50	EECs and RQs



Short Grass	Tall Grass	Broadleaf Plants/

Small Insects	Fruits/Pods/

Seeds/

Large Insects



EEC	RQ	EEC	RQ	EEC	RQ	EEC	RQ

20	1080.64	273.52	0.25	125.37	0.12	153.86	0.14	17.10	0.02

100	1375.71	155.98	0.11	71.49	0.05	87.74	0.06	9.75	0.01

1000	1943.25	69.83	0.04	32.01	0.02	39.28	0.02	4.36	0.00



  Upper 90th Percentile Kenega, Subacute Avian Dietary Based Risk
Quotients

1.0 lbs ae/A application

LC50	EECs and RQs

	Short Grass	Tall Grass	Broadleaf Plants/

Small Insects	Fruits/Pods/

Seeds/

Large Insects

	EEC	RQ	EEC	RQ	EEC	RQ	EEC	RQ

3750	240.17	0.06	110.08	0.03	135.09	0.04	15.01	0.00

Mean Kenaga, Acute Avian Dose-Based  Risk Quotients

1.0 lbs ae/A application Rate based on  acute bird >1500 mg ae/kg bw, 4
day half life, 42 day interval and 3 applications per season

Size Class

(grams)	Adjusted

 LD50	EECs and RQs



Short Grass	Tall Grass	Broadleaf Plants/

Small Insects	Fruits/Pods/

Seeds/

Large Insects



EEC	RQ	EEC	RQ	EEC	RQ	EEC	RQ

20	1080.64	96.97	0.090	41.07	0.038	51.34	0.048	7.99	0.007

100	1375.71	55.29	0.040	23.42	0.017	29.27	0.021	4.55	0.003

1000	1943.25	24.67	0.013	10.45	0.005	13.06	0.007	2.03	0.001



 Mean Kenega, Subacute Avian Dietary Based Risk Quotients

1.0 lbs ae/A application

LC50	EECs and RQs

	Short Grass	Tall Grass	Broadleaf Plants/

Small Insects	Fruits/Pods/

Seeds/

Large Insects

	EEC	RQ	EEC	RQ	EEC	RQ	EEC	RQ

3750	85.06	0.023	36.02	0.010	45.03	0.012	7.00	0.002



Upper Bound and Mean Kenaga 1.0 lbs ae/A application Rate based on 
Chronic bird NOAEL= 38 mg ae/kg, 4 day half life, 42 day interval and 3
applications per season

Upper 90th Percentile Kenega, Chronic Avian Dietary Based Risk Quotients

1.0 lbs ae/A application Rate based on  chronic bird  =  38 mg ae/kg , 4
day half life, 42 day interval and 3 applications per season

NOAEC (ppm)	EECs and RQs

	Short Grass	Tall Grass	Broadleaf Plants/

Small Insects	Fruits/Pods/

Seeds/

Large Insects

	EEC	RQ	EEC	RQ	EEC	RQ	EEC	RQ

38	240.17	6.32	110.08	2.90	135.09	3.56	15.01	0.40



Mean Kenega, Chronic Avian Dietary Based Risk Quotients

1.0 lbs ae/A application Rate based on  Chronic bird  = 38 mg ae/A, 4
day half life, 42 day interval and 3 applications per season

NOAEC (ppm)	EECs and RQs

	Short Grass	Tall Grass	Broadleaf Plants/

Small Insects	Fruits/Pods/

Seeds/

Large Insects

	EEC	RQ	EEC	RQ	EEC	RQ	EEC	RQ

38	85.06	2.238	36.02	0.948	45.03	1.185	7.00	0.184



    TERRPLANT MODEL 

                                                  (November 9, 2005;
version 1.2.1)

Terrestrial plant exposure characterization employs runoff and spray
drift scenarios contained in OPP’s Terrplant model.  Exposure
calculations are based on a pesticide’s water solubility and the
amount of pesticide present on the surface soil within the first inch of
depth.  For dry areas, the loading of pesticide active ingredient or
acid equivalent from runoff to an adjacent non-target area is assumed to
occur from one acre of treatment to one acre of non-target area.  For
terrestrial plants inhabiting semi-aquatic (wetland) areas, runoff is
considered to occur from a larger source area with active ingredient
loading originating from 10 acres of treated area to a single acre of
non-target wetland.  Default spray drift assumptions are 1% for ground
applications and 5% for aerial, forced air (i.e., air pressure within a
spray tank that forces the spray liquid through the boom nozzles), and
chemigation applications.  Predicted EECs resulting from spray drift and
aerial applications are derived for non-granular applications only.

 TERRPLANT

 MEFLUIDIDE-K, MEFLUIDIDE-DEA  (1.0 lbs ae/A) GROUND       SPRAY ONLY

Terrestrial Plant EECs and Acute Non Endangered RQs (November 9, 2005;
version 1.2.1)

	Input Values

Application Rate (lb a.e./acre)	1.0	Estimated Environmental
Concentrations (EECs) for    NON-GRANULAR formulation applications (lbs
a.i./acre)	Risk Quotients (RQs) for NON-GRANULAR formulation
applications

Runoff Value             (0.01, 0.02, or 0.05 if chemical solubility
<10, 10-100,  or >100 ppm, respectively)	0.05	Application Method	Total
Loading  to Adjacent Areas (EEC = Sheet Runoff +Drift)	Total Loading to
Semi-aquatic Areas (EEC = Channelized Runoff + Drift) 	DRIFT EEC*
Emergence RQs, Adjacent Areas                           RQ =
EEC/Seedling Emergence EC25	Emergence RQs, Semi-aquatic Areas           
    RQ = EEC/Seedling Emergence EC25	Drift RQs                     

RQ = Drift EEC/

Vegetative Vigor

EC25 

Minimum Incorporation Depth  (cm)	0



	Monocot	Dicot	Monocot	Dicot	Monocot	Dicot



Ground Unincorp.	0.600	0.5100	0.100	0.571	11.11	4.86	94.44	0.10	1.85

Seed Emerg  Monocot EC25  (lb a.e./acre)	0.105	Ground Incorp	0.600
0.5100	0.100	0.571	11.11	4.86	94.44	0.10	1.85

Seed Emerg Dicot  EC25 (lb a.e./acre)	0.0054

Veg Vigor Monocot EC25 (lb a.e./acre)	0.105

Veg Vigor Dicot EC25 (lb a.e./acre)	0.0054



 TERRPLANT

 MEFLUIDIDE-K, MEFLUIDIDE-DEA  (1.0 lbs ae/A) GROUND SPRAY ONLY

Terrestrial Plant EECs and Acute Endangered RQs (November 9, 2005;
version 1.2.1)

	Input Values

Application Rate (lb a.e./acre)	1.0	Estimated Environmental
Concentrations (EECs) for    NON-GRANULAR formulation applications (lbs
a.i./acre)	Risk Quotients (RQs) for NON-GRANULAR formulation
applications

Runoff Value             (0.01, 0.02, or 0.05 if chemical solubility
<10, 10-100,  or >100 ppm, respectively)	0.05	Application Method	Total
Loading  to Adjacent Areas (EEC = Sheet Runoff +Drift)	Total Loading to
Semi-aquatic Areas (EEC = Channelized Runoff + Drift) 	DRIFT EEC*
Emergence RQs, Adjacent Areas                             RQ =
EEC/Seedling Emergence EC05 or NOAEC 	Emergence RQs, Semi-aquatic areas 
               RQ  =   EEC/Seedling Emergence EC05 or NOAEC	Drift RQs  

 RQ = EEC/

Vegetative Vigor EC05 or NOAEC 

Minimum Incorporation Depth  (cm)	0



	Monocot	Dicot	Monocot	Dicot	Monocot	Dicot



Ground Unincorp.	0.600	0.5100	0.100	1.333	20.69	11.33	175.86	0.22	3.45

Seed Emerg  Monocot EC05 or NOAEC  (lb a.e./acre)	0.105	Ground Incorp
0.600	0.5100	0.100	1.333	20.69	11.33	175.86	0.22	3.45

Seed Emerg Dicot  EC05 or NOAEC (lb a.e./acre)	0.0054

Veg Vigor Monocot EC05 or NOAEC (lbs a.e./acre)	0.105

Veg Vigor Dicot EC05 or NOAEC (lb a.e./acre)	0.0029



TERRPLANT

MEFLUIDIDE (0.5 lbs ae/A) GRANULAR APPLICATION ONLY

Terrestrial Plant EECs and Acute Non Endangered RQs (November 9, 2005;
version 1.2.1)

	Input Values

Application Rate (lb a.e./acre)	0.5	Estimated Environmental
Concentrations (EECs) for    NON-GRANULAR formulation applications (lbs
a.i./acre)	Risk Quotients (RQs) for NON-GRANULAR formulation
applications

Runoff Value             (0.01, 0.02, or 0.05 if chemical solubility
<10, 10-100,  or >100 ppm, respectively)	0.05	Application Method	Total
Loading  to Adjacent Areas (EEC = Sheet Runoff )	Total Loading to
Semi-aquatic Areas (EEC = Channelized Runoff ) 	DRIFT EEC*	Emergence
RQs, Adjacent Areas                           RQ = EEC/Seedling
Emergence EC25	Emergence RQs, Semi-aquatic Areas                RQ =
EEC/Seedling Emergence EC25	Drift RQs                     

RQ = Drift EEC/

Vegetative Vigor

EC25 

Minimum Incorporation Depth  (cm)	0



	Monocot	Dicot	Monocot	Dicot	Monocot	Dicot



Ground Unincorp.	0.0250 	0.2500	N/A	0.24	4.63	2.38	46.30	N/A	N/A

Seed Emerg  Monocot EC25  (lb a.e./acre)	0.105

Seed Emerg Dicot  EC25 (lb a.e./acre)	0.0054

Veg Vigor Monocot EC25 (lb a.e./acre)	0.105

Veg Vigor Dicot EC25 (lb a.e./acre)	0.0054



 TERRPLANT

 MEFLUIDIDE (0.5 lbs ae/A) GRANULAR APPLICATION ONLY

Terrestrial Plant EECs and Acute Endangered RQs (November 9, 2005;
version 1.2.1)

	Input Values

Application Rate (lb a.e./acre)	0.5	Estimated Environmental
Concentrations (EECs) for    NON-GRANULAR formulation applications (lbs
a.i./acre)	Risk Quotients (RQs) for NON-GRANULAR formulation
applications

Runoff Value             (0.01, 0.02, or 0.05 if chemical solubility
<10, 10-100,  or >100 ppm, respectively)	0.05	Application Method	Total
Loading  to Adjacent Areas (EEC = Sheet Runoff )	Total Loading to
Semi-aquatic Areas (EEC = Channelized Runoff ) 	DRIFT EEC*	Emergence
RQs, Adjacent Areas                             RQ = EEC/Seedling
Emergence EC05 or NOAEC 	Emergence RQs, Semi-aquatic areas              
  RQ  =   EEC/Seedling Emergence EC05 or NOAEC	Drift RQs  

 RQ = EEC/

Vegetative Vigor EC05 or NOAEC 

Minimum Incorporation Depth  (cm)	0



	Monocot	Dicot	Monocot	Dicot	Monocot	Dicot



Ground Unincorp.	0.0250	0.2500	N/A	0.56	8.62	5.56	86.21	N/A	N/A

Seed Emerg  Monocot EC05 or NOAEC  (lb a.e./acre)	0.105

Seed Emerg Dicot  EC05 or NOAEC (lb a.e./acre)	0.0054

Veg Vigor Monocot EC05 or NOAEC (lbs a.e./acre)	0.105

Veg Vigor Dicot EC05 or NOAEC (lb a.e./acre)	0.0029



DRIFT RQs for Buffers from 10 to 900 ft  RQs= (EEC/EC25 ) 

EECs derived from AGDRIFT Table 3.5*

Buffer distance	1.0 lb ae/A	RQs                     Monocot (EC25 
0.105)	RQs                    Dicot (EC25 0.0054)

10	0.0923	0.879	17.093

20	0.0437	0.416	8.093

40	0.0218	0.208	4.037

60	0.0149	0.142	2.759

80	0.0115	0.110	2.130

100	0.0095	0.905	1.759

140	0.007	0.067	1.296

180	0.0056	0.053	1.037

200	0.0051	0.049	0.944

250	0.0042	0.040	0.778

500	0.0021	0.020	0.389

900	0.0011	0.011	0.204

* dicots exceed LOCs for spray drift

	

Appendix E

APPENDIX E.  Ecological Effects Characterization for Mefluidide,
Mefluidide-DEA and Mefluidide-K 

310=Molecular Weight of Mefluidide acid

415.24 = Molecular Weight of Mefluidide-DEA  

348.29=Molecular Weight of Mefluidide-K 

The following tables present measures of effect both in terms of active
ingredient and acid equivalents.  Conversion from active ingredient to
acid equivalents was made in accordance with molecular weight
differences (MW acid/ MW salt = AE).   One gram mole of Mefluidide acid
has a mass of 310.0 and one gram mole of Mefluidide-DEA has a mass of
415.24 grams; therefore one unit of salt would be equivalent to 0.75
units of the acid.  Hence, the LC50 values from the toxicity tests with
Mefluidide-DEA were converted to acid equivalents by multiplying the
values by 0.75.  The same conversion scenario was made Mefluidide-K with
one gram mole of Mefluidide-K equal to 348.29.  Therefore, 310 MW
acid/348.29MW potassium salt is equivalent to 0.89.   Hence, the LC50
values from the toxicity tests with Mefluidide-K were converted to acid
equivalents by multiplying the values by 0.89. 

Table E-1: Acute Toxicity of  Mefluidide to Freshwater Fish





Species	

% a.i. / %ae	

96-hr LC50, mg/L (confid. int.)	

NOEC (mg/L)	

Study Propertiesa	

Toxicity Classification (based on a.e.)	

MRID 	

Status





a.i.	

a.e.	

a.i.	

a.e.







Freshwater fish studies were submitted for 114001-Mefluidide and are in
review

MRIDs 73635, 80027, 80028 , 87475, 41893801 and 41893802 with LC50s
ranging from > 96.4 mg/L to 1720 mg/L  

No freshwater fish studies were submitted for 114003 -Mefluidide
potassium salt



  114002- Mefluidide-DEA 



Rainbow trout	28.8	>91.3	>68.47	91.3	68.47	F-T, M	Slightly-toxic
418937-02	Acceptable



Bluegill sunfish	28.8	>94.4	>70.80	94.4	70.80	F-T, M	Slightly-toxic
418937-01	Acceptable



Table E-2: Acute Toxicity of Mefluidide  to Freshwater Invertebrates



Species	

% a.i.	

48-hr EC50, mg/L (confid. int.)	

NOEC (mg/L)	

Study Propertiesa	

Toxicity Classification (based on a.e.)	

MRID 	

Status





a.i.	

a.e.	

a.i.	

a.e.







  

Freshwater invertebrate study was submitted for 114001-Mefluidide and is
in review with MRID 41893803 with and  EC50 of  >111

 No freshwater invertebrate studies were submitted for114003 -Mefluidide
potassium salt

 

  114002- Mefluidide-DEA 

 





Daphnia	28.8% 	>103	>77.25	103	77.25	F-T, M	 Slightly-toxic	418937-03
Acceptable



a M=mean-measured chemical concentrations, N=nominal chemical
concentrations; F-T=flow-through; S=static.

Table E-3: Chronic (Early-life) Toxicity of  Mefluidide to Invertebrates



Species	

% a.i.	

NOEC (mg/L)	

LOEC (mg/L)	

Study Propertiesa	

Most sensitive parameter	

MRID	

Status





a.i.	

a.e.	

a.i.	

a.e.





 No Chronic  invertebrate studies were submitted for 114001-Mefluidide 
, 114002 Mefluidide-DEA  and 114003 - Mefluidide-K  



a M=mean-measured chemical concentrations, N=nominal chemical
concentrations; F-T=flow-through; S=static.

	

Table E-1: Acute Toxicity of  Mefluidide to Estuarine marine Fish





Species	

% a.i. / %ae	

96-hr LC50, mg/L (confid. int.)	

NOEC (mg/L)	

Study Propertiesa	

Toxicity Classification (based on a.e.)	

MRID 	

Status





a.i.	

a.e.	

a.i.	

a.e.







114001-Mefluidide 

Sheepshead minnow	58.2	>130	>130	130	130	F-T, M	Practically non-toxic
425624-03	Acceptable



114002- Mefluidide-DEA 

Sheepshead minnow	28.8	>113	>84.75	113	84.75	F-T, M	Slightly-toxic 
425623-03	Acceptable



Table E-2: Acute Toxicity of Mefluidide  to Estuarine marine
Invertebrates



Species	

% a.i.	

EC50, mg/L (confid. int.)	

NOEC (mg/L)	

Study Propertiesa	

Toxicity Classification (based on a.e.)	

MRID 	

Status





a.i.	

a.e.	

a.i.	

a.e.







 114001-Mefluidide 

Mysid

(Mysidopsis bahia) (96 HR)	58.2	133

(113- 204)	133	47	47	F-T, M	Practically non-toxic	425624-02	Acceptable

 Eastern Oyster (Crassostrea virginica)(96 HR)	58.2	67	67	<12	<12	F-T, M
Slightly toxic	425624-01	Acceptable

 

114002- Mefluidide-DEA 

  114002- Mefluidide Diethanolamine salt

 



Mysid

(Mysidopsis bahia) (96 HR)	28.8	>126

	>94.5	42	31.5	F-T, M	Practically non-toxic	425623-02	Acceptable

 Eastern Oyster (Crassostrea virginica) (96 HR)	28.8	77	57.75	<14	<10.5
F-T, M	Slightly toxic	425623-01	Supplemental



a M=mean-measured chemical concentrations, N=nominal chemical
concentrations; F-T=flow-through; S=static.



Table E-3: Acute Toxicity of  Mefluidide to Aquatic Plants



Species	

%a.i.	Definitive test

 	

 Most sensitive parameter	

Initial/mean measured concentrations	

MRID 	

Status





a.i.	

a.e.







 

  114002- Mefluidide-DEA



Navicula pelliculosa

Tier I (120 Hr)

	28.8	831 ug ai/L

	.629mg ae/L	11.5% growth reduction	mean	435266-01	Acceptable

Skeletonema costatum

Tier1(120Hr)	28.8	767ug ai/L

	.575 mg ae/L	no adverse effects	mean	435266-02	Acceptable



Lemna gibba                TierI (14day)	28.8	687 ug ai/L

(8% growth stimulation)	0.515 mg ae/L	 8% growth stimulation	mean
435266-05	Acceptable



Anabaena flos-aquae

Tier1(120 Hr)	28.8	725 ug ai/L

	0.543 mg ae/L	4.3% growth reduction	mean	435266-04	Acceptable



Selenastrum capricornutum

Tier I (120 Hr)	28.8	749 ug ai/L

	0.561 mg ae/L	8% growth reduction	mean	435266-03	Acceptable



Table E-4: Acute Toxicity of  Mefluidide to Aquatic Plants



Species	

 	MRID

	Endpoints definitive tests	Endpoints range finding  tests



	

 

  114002- Mefluidide-DEA Definitive and Range finding Tessts for Tier I
studies for aquatic plants



Navicula pelliculosa

Tier I (120 Hr)

	831 ug ai/L

11.5% growth reduction	1131 ug ai/L 5.10%growth stimulation	435266-01

Skeletonema costatum

Tier1(120Hr)	767ug ai/L

no adverse effects	1117 ugai/L 2.5% growth stimulation	435266-02



Lemna gibba                TierI (14day)	687 ug ai/L8% growth
stimulation	1084 ug ai/L 2.6% growth reduction	435266-05



Anabaena flos-aquae

Tier1(120 Hr)	725 ug ai/L

4.3% growth reduction	1077 ug ai/L 26.5%growth stimulation	435266-04



Selenastrum capricornutum

Tier I (120 Hr)	749 ug ai/L

4.3% growth reduction	1117 ug ai/L 8.5% growth stimulation	435266-03



 Table E-5: Acute Toxicity of  Mefluidide to Birds (oral administration)



Species	

% a.i.	

LD50, mg ai/kg-bw (conf. interval)	

NOEC, mg ai/kg-diet	

Effects	

Toxicity Classification (based on a.e.)	

MRID	

Status





a.i.	

a.e.	

a.i.	

a.e.





 114001-Mefluidide*	





Bobwhite quail

Tier I	58.2	>2000	>2000	>2000	>2000

Practically non-toxic	416021-01	Supplemental 

 

  114002- Mefluidide_DEA	





Bobwhite quail

Tier I	28.8	>2000	>1500	>2000	>1500

Practically non-toxic	416019-01	Supplemental 



*Avian  acute oral studies were submitted for  114001-Mefluidide and are
in review MRIDs 7362 with LD 50 4640 mg/kg bw



Table E-6: Acute Toxicity of Mefluidide  to Birds (dietary
administration)



Species	

% a.i.	

LC50, mg ai/kg-diet (conf. interval)	

NOEC, mg ai/kg-diet	

Effects	

Toxicity Classification (based on a.e.)	

MRID	

Status





a.i.	

a.e.	

a.i.	

a.e.





 114001-Mefluidide*	





Mallard duck

(Tier I or limit test)	58.2% (adjusted to 100%ai)	>5000	>5000	>5000
>5000	No mortality	Practically non- toxic	416021-03	

Supplemental



Bobwhite quail

(Tier I or limit test)	58.2% (adjusted to 100%ai)	>5000	>5000	>5000
>5000	No mortality	Practically non- toxic	416021-02	

Supplemental

 

  114002- Mefluidide Diethanolamine salt	





Mallard duck

(Tier I or limit test)	28.8% (adjusted to 100%ai)	>5000	>3750	>5000
>3750	No mortality	Practically non- toxic	416019-03	

Supplemental



Bobwhite quail

(Tier I or limit test)	28.8% (adjusted to 100%ai)	>5000	>3750	>5000
>3750	No mortality	Practically non- toxic	416019-02	

Supplemental



*Avian  acute dietary studies were submitted for  114001-Mefluidide and
are in review MRIDs, 7633 and 7634 with LC50s of >10,000 mg/kg diet

Table E-7: Chronic Toxicity of  Mefluidide to Birds



Species	

% a.i.	

NOEC (mg ai/kg-diet)	

LOEC (mg ai/kg-diet)	

Effects	

MRID	

Status





a.i.	

a.e.	

a.i.	

a.e.



	 No Chronic bird studies were submitted for 114001-Mefluidide , 114002
Diethanolamine salt and 114003 -Mefluidide potassium salt

 









	

Table E-8: Acute Contact Toxicity of   Mefluidide to Non-target Insects



Species	

% a.i.	

Toxicity endpoint	

NOEL	

Toxicity classification (based on a.e.)	

MRID	

Status





a.i.	

a.e.







 

114002- Mefluidide Diethanolamine salt

Honey bee	28.8	>25	>18.75	12.5	Practically non-toxic	425628-01
Acceptable

114003- Mefluidide Potassium salt



Honey bee	28.8	>25	>22.25	25	Practically non-toxic	425628-02	Acceptable



Table E 9 Acute Toxicity of Mefluidide a



Guideline

 No.	

Study Type	

MRID	Results (LD50/LC50)	

Toxicity Category

870.1100

(81-1)	Acute Oral (female rat)

Mefluidide tech	>4000 mg/kg

MRID 00047118	

III

870.1100

(81-1)	Acute Oral (mouse) Mefluidide tech	1920.2 mg/kg

MRID 00047117 	

III

870.1100

(81-1)	Acute Oral (mouse) Mefluidide tech	829.8 mg/kg

MRID 00047116 	

III

a Status (acceptability) based on HEDs guidelines.



Table E 10  Toxicity Profile of Mefluidide sub chronic and developmental
toxicity and its salts (114001, 114002, 114003) a



Guideline No./ Study type	

MRID No.(year)/Doses/ classification	

Results

870.3200

82-2 

21-Day  Dermal toxicity - rabbit	00082073, (1977)

0, 1, 3, 10 ml of 2S formulation/kg/day (Formulation containing 24%
a.i., equivalent to  0, 240, 720, or 2400 mg mefluidide/kg/day)

(4 rabbits/sex/dose)

Acceptable/Non-guideline

(NOAEL was not observed)

Note: This study assessed the dermal toxicity of 24 % formulation
mefluidide	Dermal LOAEL = 240 mg/kg/day, based on irritation,
inflammation and necrosis at test sites.

Dermal a NOAELs were not established.

870.3700a

83-3(a)

Developmental Toxicity

Gavage [rat]	42097201 (range finding)

42097701 (teratology), 1991

Range finding: 0, 100, 200, 400, 600 or 800 mg a.i./kg/d

Teratology study: 0, 50, 200 or 400 mg a.i./kg/d

Mefluidide technical 58.2% a.i.

Acceptable/Guideline	Maternal LOAEL = 400 mg/kg/d based on reduced gain
and food consumption. Higher dose in the range finding study of 600
mg/kg/day produced excessive mortality.

Maternal NOAEL = 200 mg/kg/d

Developmental LOAEL = 400 mg/kg/d based on slight fetal toxicity as
indicated by a slight nonstatistical increase in 14th rib.

Developmental NOAEL = 200 mg/kg/d

870.3700a 

83-3(a) 

Developmental Toxicity, gavage [rat]	42026102, (1991)

0, 50, 200 400 mg diethanolamine salt of mefluidide (28.78%)/kg/d

(25 females/dose)

Doses adjusted for 100 % purity were 0, 14, 58, or 115 mg/kg/day. 

Acceptable/guideline	Maternal LOAEL = 115 mg a.i./kg/day based on
mortality, clinical signs (tremors, stained nose, urine and vaginal
discharge), decreased body weight and weight gain.

Maternal NOAEL = 58 mg a.i./kg/day), 

Developmental LOAEL = 115 mg a.i./kg/day based on increased number of
early resorptions and mean post-implantation loss.

Developmental NOAEL: 200 mg/kg/day (adjusted to 58 mg/kg/day), 

Non-guideline

14-Day Oral gavage [rabbit]	00047138, (1975)

0, 100, 200, 400, 800 mg/kg/d Vistar tech, 93% a.i.

4 females/dose

range finding

Acceptable/non-guideline	LOAEL  = < 100 mg/kg/day (females), based on
mortality (1/3 deaths) at 100 mg/kg/d.  Tremors and 100% mortality were
noted at the levels of 200 mg/kg/d and above. Histopathology not
reported.

NOAEL: not established, 

870.3700b

83-3(b) Developmental Toxicity, gavage [rabbit]

	00047139, (1975)

0, 15, 30, 60 mg technical MBR 12325/kg/d 

Unacceptable by itself, however, if combined with the 14-day oral study
(00047138), it is acceptable.	Maternal LOAEL = not established.

Maternal NOAEL = 60 mg/kg/day, 

Developmental LOAEL = not established.

Developmental NOAEL = 60 mg/kg/day, 



870.1300

(81-3)	Acute inhalation – rat 

DEA salt of Mefluidide       	>5.2 mg/L

MRID 41888801

870.1300

(81-3)	Acute inhalation – rat 

Mefluidide tech.  	>5.4 mg/L

MRID 41964601

870.3800

(83-4 )

3-generation reproduction [rat]	00082748, (1979)

0, 600, 1800, 6000 ppm, 93% a.i. (M/F: 0/0, 34/60, 102/183, 346/604
mg/kg/d)

Acceptable/guideline	The parental systemic LOAEL = 346/604 mg/kg bw/day
(M/F), based on decreased body weights.  

The parental systemic NOAEL = 102/183 mg/kg bw/day in males/females.

The offspring LOAEL = 346/604 mg/kg bw/day in males/females, based on
decreased body weights in both sexes and both litters in all
generations.  The offspring NOAEL = 102/183 mg/kg bw/day in
males/females. 

The reproductive LOAEL was not observed.  

The reproductive NOAEL = 346/604 mg/kg bw/day in males/females. 

M = Males; F = Females

a Status (acceptability) based on HEDs guidelines.

Table E-11: Toxicity of  Mefluidide to Terrestrial Plants (vegetative
vigor)1



Most Sensitive Species	

% a.i.	

EC25, lbs ai/acre 	

NOEC  (lbs ai/acre)	

 Most sensitive parameter	

MRID	

Status





a.i.	

a.e.	

a.i.	

a.e.



	 

  114002- Mefluidide Diethanolamine salt



Monocot -Sorghum	29.5	0.14

0.06

Shoot  fresh weight	435496-01	 Supplemental



Dicot - Mustard 	29.5	0.0073

0.0039

Shoot fresh weight



1 Seedling emergence studies were not available for Mefluidide
formulations

Calculations for Estimated Endpoints

Seedling emergence toxicity data was not available and data was not
available from other anilide analogs to derive EC25 values. To estimate
possible effects measurement endpoints for seedling emergence, EFED
assumed that EC25 toxicity values for vegetative vigor are equal to
seedling emergence measurement endpoints for Mefluidide, Mefluidide-DEA
and Mefluidide-K.  Therefore, the most sensitive seedling emergence EC25
estimated values are 0.105 and 0.0054 lb ae/acre for monocots and
dicots, respectively.  The NOEC estimated values for seedling emergence
are 0.045 and 0.0029 lb ae/acre for monocots and dicots, respectively.  
 These values are used to calculate risk quotients for exposure from
combined runoff and spray drift to adjacent fields.

There are insufficient data to establish a definitive toxicity endpoint
for freshwater fish chronic effects for the acid and DEA salt acid
equivalents for mefluidide.  To estimate a potential chronic freshwater
fish endpoint for mefluidide the relationship between established acute
and chronic endpoints for mefluidide and propanil were considered (see
source data in Appendix E). A ratio was determined between the 96h acute
freshwater fish endpoints and the chronic freshwater fish endpoints
used for RQ calculation for mefluidide (>68.47 mg/L acute freshwater
fish) and propanil (2.3mg /L/0.009 mg /L = 256 mg/L).  The largest
ratio between acute endpoint and chronic endpoint was applied to the
Mefluidide acute freshwater fish value to derive an estimated chronic
endpoint of 0.267 mg/L (>68.47mg/L/256 = >0.267 mg/L). 

There are insufficient data to establish a definitive toxicity endpoint
for freshwater invertebrate chronic effects for the acid and DEA salt
acid equivalents for mefluidide.  To estimate a potential chronic
freshwater fish endpoint for mefluidide the relationship between
established acute and chronic endpoints for mefluidide and propanil were
considered (see source data in Appendix E). A ratio was determined
between the 48 h acute freshwater invertebrate endpoints and the
chronic freshwater invertebrate endpoints used for RQ calculation for
mefluidide (>77.25 mg/L acute freshwater invertebrate) and propanil
(1.2mg /L acute freshwater invertebrate/0.086 mg /L chronic freshwater
invertebrate = 13.95).  The largest ratio between acute endpoint and
chronic endpoint was applied to the Mefluidide acute freshwater fish
value to derive an estimated chronic endpoint of 5.54 mg/L (>77.25
mg/L/13.95= >5.54 mg/L). 

There are insufficient data to establish a definitive toxicity endpoint
for estuarine/marine fish and invertebrate chronic effects for the acid
and DEA salt acid equivalents for mefluidide. There is also little
available data to compare to other anilide herbicides for this taxonomic
group   For the purposes of this risk assessment, it was assumed that
estuarine marine fish and invertebrates were at least as sensitive as
freshwater fish and invertebrates in terms of chronic toxicity.
 Therefore, the estimated endpoint for freshwater invertebrates (>5.54
mg/L) was used to estimate a chronic effects endpoint for
estuarine/marine invertebrates and >0.267 mg/L was used to estimate
chronic effect endpoint for estuarine marine fish. 

There are insufficient data to establish a definitive toxicity endpoint
for a NOAEC or EC05 value for vascular plant effects for the acid and
DEA salt acid equivalents for mefluidide.  To estimate a potential EC05
endpoint for mefluidide the relationship between established acute and
EC05 endpoints for mefluidide and propanil were considered (see source
data in Table 1 Appendix E). Comparisons were made between the acute
mefluidide endpoint and the propanil EC05 endpoint for vascular plant RQ
calculation for mefluidide (>0.515 mg/L acute vascular plant) and
propanil (0.11mg /L acute vascular plant/0.0063 mg /L EC05 vascular
plant= 17.46).  The largest ratio between acute endpoint and EC05 was
applied to the Mefluidide acute vascular plant value to derive an
estimated EC05 endpoint of >0.029 mg/L (>5.15 mg/L/17.46= >0.029 mg/L). 

             There are insufficient data to establish a definitive
toxicity endpoint for a chronic (NOAEC) value for bird effects for the
acid and DEA salt acid equivalents for mefluidide.  To estimate a
potential chronic endpoint for mefluidide the relationship between
established acute and chronic endpoints for mefluidide mammals were
considered (see source data in Appendix E). Chronic NOAEC values for the
most sensitive mammal (mouse) were not available. Therefore, to derive a
chronic value for the mouse the acute mefluidide endpoint and the
chronic mefluidide endpoint from rat toxicity endpointswere used to
derive a chronic mouse value for mefluidide (829.8 mg ae/kg acute mouse)
and mefluidide (>4000mg ae /kg acute (rat)/102 mg ae /kg chronic (rat))
= 39.2). The largest ratio between acute endpoint and chronic endpoint
was applied to the mefluidide acute mouse value to derive an estimated
chronic mouse endpoint of NOAEC>21 mg ae/kg bw (829.8 mg ae/kg bw /39.2=
NOAEC >21mg ae/kg bw (mouse)).  The acute mefluidide endpoint for bird
and the acute and chronic endpoints for the mouse were used to derive a
ratio for the chronic bird RQ calculation for mefluidide (>1500 mg ae/kg
acute bird) and mefluidide (829.8 mg ae /kg acute (mouse)/ >21mg ae /kg
chronic (mouse) = 39.5). The largest ratio between acute endpoint and
chronic endpoint was applied to the mefluidide acute bird value to
derive an estimated chronic endpoint of NOAEC 38 mg ae/kg bw
(>1500mg/L/39.5= NOAEC 38 mg ae/kg bw).  

Calculations for Estimated Endpoints

Table #1  Summary of Calculations for Estimated Endpoints



ENDPOINT DESIRED For Mefluidide	Acute/Chronic mefluidide =ratio
Acute/Chronic Propanil =ratio	Acute Endpoint Mefluidide/ratio= endpoint
Estimated Endpoint

Chronic Fish	 	2.3/0.009=256	>68.47/256=>0.267

	Chronic Invertebrate	 	1.2/0.086=13.95	>77.25/13.95=>5.54

	Chronic Bird (used mammal rat and mouse toxdata body weight)	>4000
mefluidide rat /102mefuidide rat =39.2 

(829.8 mg ae/kg bw (mouse) /39.2= NOAEC >21mg ae/kg bw (mouse)).

  829.8 mg ae /kg acute (mouse)/ >21mg ae /kg chronic (mouse) = 39.5	 
>1500/39.5=38

	EC05 vascular plant	 	0.11/0.0063=17.46	>0.515/17.46=>0.029

	EC05 non-vascular plant	 	0.016/0.02=0.80	>0.629/0.80=>0.786

	 Seedling emergence EC05 and  EC25	 	 

EC05 and EC25 values are equal to vegetative vigor values



 

Due to data gaps for chronic studies for freshwater and estuarine marine
fish and invertebrates and chronic studies for  birds EFED reviewed the
analog Propanil to obtain estimated LD50 and LC50 values for Mefluidide
from acute to chronic ratios 

Also for the most sensitive estuarine marine invertebrate Propanil is 2
orders more toxic than Mefluidide and no chronic estuarine marine
studies were available for Propanil.

No chronic studies for birds were submitted for Propanil.

Tables #2 to #4 summarize endpoints from mefluidide and propanil
considered for estimated values. Bolded values were used in endpoint
selection for acute and chronic ratios.

 

Table#2 Summary of Aquatic and Terrestrial Plant Toxicity Data used for
Risk Quotient Calculation  Mefluidide and Propanil  Application(bolded 
values were used in acute to chronic ratios)

Species	 Mefluidide	 Propanil

Aquatic Plant: Navicula Tier I

Nonvascular 

	EC50 = >0.629 mg ae/L  

NOAEC N/A due to Tier one study                                       

	Freshwater diatom

0.016 mgai/L

EC05 0.02

Aquatic Plant: Lemna gibba Tier I

Vascular 

	     EC50 = 0.515 mg ae/L           

NOAEC N/A due to Tier one study                                         
                            	.11 mg ai/L

EC05 0.0063

Terrestrial Plant: 

Vegetative Vigor 

	Most sensitive endpoint:                                              
( N/Afor Propanil)

Fresh Weight

Most sensitive monocot: Sorghum NOAEC 0.045 lb ae/A; EC25 0.105 lb ae/A

Most sensitive dicot: Mustard

NOAEC 0.0029 lb ae/A; EC25  0.0054lb ae/A	 N/A for Propanil

Terrestrial Plant: 

Seedling Emergence

	(No studies submitted) Vegetative Vigor enpoints from mefluidide were
used for this data gap.                  

 	EC25 1.4 lb ai/A for   Propanil       



Table#3   Summary of Terrestrial Acute and Chronic Toxicity Data used
for Risk Quotient Calculation for Mefluidide and Propanil  Application  
 (bolded values were used in acute to chronic ratios)



Species	Acute Toxicity	Chronic Toxicity

	Mefluidide

LD50

 mg ae/kg-bw	Propanil

LD50

 mg ae/kg-bw	Mefluidide

LC50	Propanil

LC50	 Mefluidide

NOAEC	Propanil

NOAEC



Laboratory rat

	 >4000 Rat  

Used to calculate chronic bird enpoint 	1080

	102 

Used to calculate chronic bird enpoint	300



Laboratory mouse

	829.8 

Used to calculate chronic bird enpoint





	Northern Bobwhite Quail (Colinus virginianus)

Limit study(Tier l)

	>1500

 Used to calculate chronic bird enpoint

>3750	2311	No studies submitted  	No studies submitted  



 Table#4  Summary of Acute and Chronic Aquatic Toxicity Data used for
Risk Quotient Calculation for  Mefluidide and Propanil Application 
(bolded values were used in acute to chronic ratios)





Species	Acute Toxicity	Chronic Toxicity

	Mefluidide

96-hr LC50

(mg/L ae)	Mefluidide

48-hr EC50

(mg/L ae)	Propanil

 96-hr LC50(mg ai/L )	Propanil

48-hr EC50

(mg ai/L )	Mefluidide

NOAEC / LOAEC

(mg/L)	Propanil

NOAEC / LOAEC

(mg/L) 

 

 Rainbow Trout

Oncorhynchus mykiss

Coldwater species

Freshwater fish 	>68.47



2.3

 No studies submitted 	No studies submitted

Fathead minnow

Freshwater fish



	No studies submitted	.009

Water flea

Daphnia magna

Freshwater Invertebrate 

 >77.25

	 	1.2	 No studies submitted	 .086

Sheepshead minnow

Estuarine marine fish	>84.75



4.6

No studies submitted	No studies submitted

Mysid shrimp

Estuarine marine invertebrate

	 	.400	No studies submitted	No studies submitted

Eastern oyster

Estuarine marine  Invertebrate

 

 67

	 No studies submitted	 No studies submitted

 

 Summary of Endpoints (LC50 or EC50, mg ae/L) for Aquatic  and
Terrestrial Toxicity used in RQ calculations for Mefluidide 1

Summary of endpoints (LC50 or EC50, mg ae/L) for Aquatic Toxicity used
in RQ calculations for Mefluidide 1



TAXANOMIC GROUP	Acute endpoint  	Chronic endpoint	MRID/

Estimated value



Acute freshwater fish	>68.47*

Rainbow Trout

MRID

418937-02



Chronic freshwater fish

>0.267	Estimated value acute to chronic ratio



Acute freshwater inverts	>77.25*

Daphnid

MRID

418937-03



Chronic freshwater inverts

>5.54	Estimated value acute to chronic ratio



Acute estuarine/marine fish	>84.75*

Sheepshead minnow

MRID

425623-03



Chronic estuarine/marine fish

>0.267	Estimated value acute to chronic ratio



Acute estuarine/marine inverts	67*

Eastern oyster

MRID

425624-01



Chronic estuarine/marine inverts

>5.54	Estimated value acute to chronic ratio

    1 For fish and invertebrates data evaluating   Potassium Mefluidide,
Diethanolamine Mefluidide and Mefluidide have been bridged for the
runoff risk assessment. 

 Summary of endpoints (LC50 or EC50, mg ae/L) for Plant Toxicity used in
RQ calculations for  Mefluidide1



TAXONOMIC GROUP	Acute endpoint  	EC05 and NOAEC 

	

Acute  vascular plant	0.515*

Lemna

MRID 435266-01

Tier I(8% growth stimulation)  

Used this value as    EC50,                                   



 Vascular plant (EC05)

>0.29	Estimated value acute to chronic ratio



Acute  non-vascular plant	0.629*

Navicula

MRID 435266-05

Tier I(11.5% growth reduction)

Used this value as    EC50,                                   

 Non-vascular plant(EC05)

>0.786	Estimated value acute to chronic ratio

 Terrestrial Plant: 

Vegetative Vigor 

	Monocot:* Sorghum

EC25 0.105 lb ae/A

 Dicot:* Mustard  EC25  0.0054lb ae/A	Monocot:* Sorghum

NOAEC 0.045 lb ae/A

Dicot:* Mustard     

NOAEC 0.0029 lb ae/A	MRID 435496-01

   

  Terrestrial Plant: 

Seedling Emergence 



	N/A

Summary of endpoints (LD50 mg ae/L) for Terrestrial Toxicity  data used
in RQ calculations for Mefluidide1



TAXONOMIC GROUP	Acute endpoint  	Chronic endpoint

	Acute Avian  	>1500*

Bobwhite quail

MRID 416019-01

Used this non-definitive endpoint as LD50

Chronic Avian 

38	Estimated value acute to chronic ratio based on mammal data

Acute mammal	829.8*

mouse

MRID 00047116



Chronic mammal



102*

rat	MRID 00082748



1For terrestrial plants data evaluating  Potassium Mefluidide,
Diethanolamine Mefluidide and Mefluidide have been

  bridged for the  terrestrial risk assessment.

*most sensitive species tested

Summary of Mammal and Avian RQS with both 35 day and 4 day half lives

Mammalian dose-based acute RQ values for proposed uses of  Mefluidide K
and  Mefluidide DEA  based on a mouse LD50 = 829.8 mg/kg -bw and
upper-bound Kenaga values1.  35day half life (A  4day half life with
either 1 and 3 applications = 1 application at 35 day)



Use	

Application Rate lbs. ae/A

(# app / interval, days)	

Body Weight, g	

Mammalian Acute Risk Quotients (upper-bound Kenaga residues)



	

Short Grass

(1app)	Short Grass

(3 app)	

Tall Grass(1app)	

Tall Grass(3app)	Broadleaf Plants/Small Insects((1app)	Broadleaf
Plants/Small Insects(3 app)

Ornamental Turf

(mefluidide salts only)

Ground spray 	1.0	

15	0.26	0.42	0.12	0.19	0.14	0.23





35	0.22	0.36	0.10	0.16	0.12	0.20





1000	0.12	0.19	0.05	0.09	0.07	0.11



1 For mammal toxicity assessments, data evaluating Potassium Mefluidide,
Diethanolamine Mefluidide and Mefluidide toxicity  have been bridged
because toxicity is expected to come from the benzene ring of
mefluidide.  Therefore, the most sensitive Mefluidide endpoint was
selected to represent  mammals for all application scenarios. 

  

 Mammalian dose-based chronic RQ values  for proposed uses of 
MefluidideK and Mefluidide DEA based based on a rat reproductive NOAEC
of 102 mg ae/kg-bw/day and upper-bound Kenaga residues1 based on a 
35day half life  (4day half life with 1 and 3 application rates)=  1
application 35 day)



Use	

Application Rate lbs. ae/A

(# app / interval, days)	

Body Weight, g	

Mammalian Acute Risk Quotients (upper-bound Kenaga residues)



	

Short Grass

(1app)	

 Short Grass

(3 app)	

 Tall grass(1app)	Tall grass(3 app)	

Broadleaf Plants/Small Insects(1app)	 Broadleaf Plants/Small Insects(3
app)

Ornamental Turf

(mefluidide salts only)

Ground spray 	1.0

3 per season

42

day interval	

15	1.02	1.66	0.47	0.76	0.57	0.93





35	0.87	1.42	0.40	0.65	0.49	0.80





1000	0.47	0.76	0.21	0.35	0.26	0.43





















 1 For mammal toxicity assessments, data evaluating Potassium
Mefluidide, Diethanolamine Mefluidide and Mefluidide toxicity  have been
bridged because toxicity is expected to come from the benzene ring of
mefluidide.  Therefore, the most sensitive Mefluidide endpoint was
selected to represent  mammals for all application scenarios. 

Avian dose-based acute RQ values for proposed uses of MefluidideK and
Mefluidide DEA based on a bobwhite quail LD50 >1500 mg/kg -bw and
upper-bound Kenaga values1.  35day half life (4day half life with 1 and
3 application rates)= same as 1 application 35 day)



Use	

Application Rate lbs. ae/A

(# app / interval, days)	

Body Weight, g	

Avian Acute Risk Quotients (upper-bound Kenaga residues)



	

Short Grass

(1app)	Short Grass

(3 app)	

Tall Grass(1app)	

Tall Grass(3app)	Broadleaf Plants/Small Insects((1app)	Broadleaf
Plants/Small Insects(3 app)

Ornamental Turf

(mefluidide salts only)

Ground spray 	1.0

 	

20	0.25	0.41	0.12	0.19	0.14	0.23





100	0.11	0.18	0.05	0.08	0.06	0.10





1000	0.04	0.06	0.02	0.03	0.02	0.03



1 For mammal toxicity assessments, data evaluating Potassium Mefluidide,
Diethanolamine Mefluidide and Mefluidide toxicity  have been bridged
because toxicity is expected to come from the benzene ring of
mefluidide.  Therefore, the most sensitive Mefluidide endpoint was
selected to represent  mammals for all application scenarios. 

Appendix F Guideline Sequence Bibliographies for Ecological Effects

			PC 14001--Mefluidide

Guideline:  71-1      Avian Single Dose Oral Toxicity

------------------------------------------------------------------------
-------------

MRID:  41602101

Culotta, J.; Campbell, S.; Hoxter, K.; et al. (1990) Mefluidide: An
Acute Oral Toxicity Study with the Northern Bobwhite: Wildlife Int.
Project No. 281-106.  Unpublished study prepared by Wild- life
International Ltd.  17 p. 

Guideline:  71-2      Avian Dietary Toxicity

------------------------------------------------------------------------
-------------

MRID:  41602102

Foster, J.; Driscoll, C.; Hoxter, K.; et al. (1990) Mefluidide: A
Dietary LC50 Study with the Northern Bobwhite: Lab Project Number:
281-104.  Unpublished study prepared by Wildlife Inter- national Ltd. 
17 p. 

MRID:  41602103

Foster, J.; Driscoll, C.; Hoxter, K.; et al. (1990) Mefluidide: A
Dietary LC50 Study with the Mallard: Lab Project No: 281-105.
Unpublished study prepared by Wildlife International Ltd.  19 p. 

Guideline:  72-3      Acute Toxicity to Estuarine/Marine Organisms

------------------------------------------------------------------------
-------------

MRID 425624-01  

Graves, W.C. and  J.P. Swigert. (1992)  Technical Mefluidide:  A 96-Hour
shell deposition Test with Eastern Oyster  Project No. 281A-121 Prepared
by Wildlife International Ltd

MRID 425624-02 

 

Graves, W.C. and  J.P. Swigert. (1992)  Technical Mefluidide:  A 96-Hour
flow through acute toxicity test with the salt water mysid.    Project
No. 281A-122a  Prepared by Wildlife International Ltd

		PC 114002—Mefluidide-DEA

Guideline:  71-1      Avian Single Dose Oral Toxicity

------------------------------------------------------------------------
-------------

MRID:  41601901

Culotta, J.; Campbell, S.; Smith, G. (1990) Diethanolamine Salt of
Mefluidide: An Acute Oral Toxicity Study with the Northern Bob- white:
Lab Project Number: 281-103.  Unpublished study prepared by Wildlife
International Ltd.  17 p. 

Guideline:  71-2      Avian Dietary Toxicity

------------------------------------------------------------------------
-------------

MRID:  41601902

Foster, J.; Driscoll, C.; Hoxter, K.; et al. (1990) Diethanolamine Salt
of Mefluidide: A Dietary LC 50 Study with the Northern Bob- white: Lab
Project Number: 281-101.  Unpublished study prepared by Wildlife
International Ltd.  17 p. 

MRID:  41601903

Foster, J.; Driscoll, C.; Hoxter, K.; et al. (1990) Diethanolamine Salt
of Mefluidide: A Dietary LC50 Study with the Mallard: Lab Project
Number: 281-102.  Unpublished study prepared by Wildlife International
Ltd.  19 p. 

Guideline:  72-1      Acute Toxicity to Freshwater Fish

------------------------------------------------------------------------
-------------

MRID:  41893701

Murphy, D.; Peters, G. (1991) Diethanolamine Salt of Mefluidide: A
96-Hour Flow-Through Acute Toxicity Test with the Bluegill (Lep- omis
macrochirus): Final Report: Lab Project Number: 281A-114. Unpublished
study prepared by Wildlife International Ltd.  56 p. 

MRID:  41893702

Murphy, D.; Peters, G. (1991) Diethanolamine Salt of Mefluidide: A
96-Hour Flow-Through Acute Toxicity Test with the Rainbow Trout
(Oncorhynchus mykiss): Final Report: Lab Project Number: 281A- 1113. 
Unpublished study prepared by Wildlife International Ltd. 56 p. 

Guideline:  72-2      Acute Toxicity to Freshwater Invertebrates

------------------------------------------------------------------------
-------------

MRID:  41893703

Holmes, C.; Peters, G. (1991) Diethanolamine Salt of Mefluidide: A
48-Hour Flow-Through Toxicity Test with the Cladocern (Daphnia magna):
Final Report: Lab Project Number: 281A-109.  Unpublished study prepared
by Wildlife International Ltd.  54 p. 

Guideline:  72-3      Acute Toxicity to Estuarine/Marine Organisms

------------------------------------------------------------------------
-------------

MRID:  42562301

Graves, W.; Swigert, J. (1992) Diethanolamine Salt of Mefluidide: A
96-hour Shell Deposition Test with the Eastern Oyster (Crassostrea
virginica): Final Report: Lab Project Number: 281A-124A.  Unpublished
study prepared by Wildlife International Ltd.  46 p. 

MRID:  42562302

Graves, W.; Swigert, J. (1992) Diethanolamine Salt of Mefluidide: A
96-hour Flow-through Acute Toxicity Test with Saltwater Mysid
(Mysidopsis bahia): Final Report: Lab Project Number: 281A-125. 
Unpublished study prepared by Wildlife International Ltd.  45 p. 

MRID:  42562303

Graves, W.; Swigert, J. (1992) Diethanolamine Salt of Mefluidide: A
96-hour Flow-through Acute Toxicity Test with the Sheepshead Minnow
(Cyprinodon variegatus): Final Report: Lab Project Number: 281A-126. 
Unpublished study prepared by Wildlife International Ltd.  45 p. 

Guideline:  122-2      Aquatic plant growth

------------------------------------------------------------------------
-------------

MRID:  43526601

Hughes, J.; Alexander, M.; Conder, L. (1995) The Toxicity of
Diethanolamine (DEA) Salt of Mefluidide to Navicula pelliculosa: Lab
Project Number: 15-01-3.  Unpublished study prepared by Carolina Ecotox,
Inc.  58 p. 

MRID:  43526602

Hughes, J.; Alexander, M.; Conder, L. (1995) The Toxicity of
Diethanolamine (DEA) Salt of Mefluidide to Skeletonema costatum: Lab
Project Number: 15-01-4.  Unpublished study prepared by Carolina Ecotox,
Inc.  60 p. 

MRID:  43526603

Hughes, J.; Alexander, M.; Conder, L. (1995) The Toxicity of
Diethanolamine (DEA) Salt of Mefluidide to Selenastrum capricornutum:
Lab Project Number: 15-01-1.  Unpublished study prepared by Carolina
Ecotox, Inc.  60 p. 

MRID:  43526604

Hughes, J.; Alexander, M.; Conder, L. (1995) The Toxicity of
Diethanolamine (DEA) Salt of Mefluidide to Anabaena flos-aquae: Lab
Project Number: 15-01-2.  Unpublished study prepared by Carolina Ecotox,
Inc.  62 p. 

MRID:  43526605

Hughes, J.; Alexander, M.; Conder, L. (1995) The Toxicity of
Diethanolamine (DEA) Salt of Mefluidide to Lemna gibba: Lab Project
Number: 15-01-5.  Unpublished study prepared by Carolina Ecotox, Inc. 
59 p. 

Guideline:  123-1      Seed germination/seedling emergence and
vegetative vigor

------------------------------------------------------------------------
-------------

MRID:  43549601

Crosby, K. (1995) Effect of DEA Mefluidide on Vegetative Vigor of
Plants: Lab Project Number: 6272-92-0223-BE-001. Unpublished study
prepared by Ricerca, Inc.  213 p. 

Guideline:  141-1      Honey bee acute contact

------------------------------------------------------------------------
-------------

MRID:  42562801

Hoxter, K.; Bernard, W.; Smith, G. (1992) An Acute Contact Toxicity
Study with the Honey Bee: Diethanolamine Salt of Mefluidide: Final
Report: Lab Project Number: 281-111A. Unpublished study prepared by
Wildlife Int'l Ltd.  16 p. 

PC 114003  Mefluidide-K

Guideline:  141-1      Honey bee acute contact

------------------------------------------------------------------------
-------------

 

MRID:  42562802

Hoxter, K.; Bernard, W.; Smith, G. (1992) An Acute Contact Toxicity
Study with the Honey Bee: Potassium Salt of Mefluidide: Final Report:
Lab Project Number: 281-112A. Unpublished study prepared by Wildlife
Int'l Ltd.  16 p. 

Appendix G: The Risk Quotient Method and Levels of Concern

  SEQ CHAPTER \h \r 1 The Risk Quotient Method is the means used by EFED
to integrate the results of exposure and ecotoxicity data. For this
method, risk quotients (RQs) are calculated by dividing exposure
estimates by ecotoxicity values (i.e., RQ = EXPOSURE/TOXICITY), both
acute and chronic. These RQs are then compared to OPP's levels of
concern (LOCs). These LOCs are criteria used by OPP to indicate
potential risk to non-target organisms and the need to consider
regulatory action. EFED has defined LOCs for acute risk, potential
restricted use classification, and for endangered species.

The criteria indicate that a pesticide used as directed has the
potential to cause adverse effects on nontarget organisms. LOCs
currently address the following risk presumption categories: 

		(1) acute - there is a potential for acute risk; regulatory action may
be warranted in addition to restricted use classification; 

		(2) acute restricted use - the potential for acute risk is high, but
this may be mitigated through restricted use classification 

		(3) acute endangered species - the potential for acute risk to
endangered species is high, regulatory action may be warranted, and 

		(4) chronic risk - the potential for chronic risk is high, regulatory
action may be warranted. 

Currently, EFED does not perform assessments for chronic risk to plants,
acute or chronic risks to non-target insects, or chronic risk from
granular/bait formulations to mammalian or avian species.

The ecotoxicity test values (i.e., measurement endpoints) used in the
acute and chronic risk quotients are derived from required studies.
Examples of ecotoxicity values derived from short-term laboratory
studies that assess acute effects are: (1) LC50 (fish and birds), (2)
LD50 (birds and mammals), (3) EC50 (aquatic plants and aquatic
invertebrates), and (4) EC25 (terrestrial plants). Examples of toxicity
test effect levels derived from the results of long-term laboratory
studies that assess chronic effects are: (1) LOAEL (birds, fish, and
aquatic invertebrates), and (2) NOAEL (birds, fish and aquatic
invertebrates). The NOAEL is generally used as the ecotoxicity test
value in assessing chronic effects.

Risk presumptions, along with the corresponding RQs and LOCs are
summarized in Table E.



Table F: Risk Presumptions and LOCs

Risk Presumption	RQ	LOC

Birds1

	Acute Risk	EEC/LC50 or LD50/sqft or LD50/day	0.5

	Acute Restricted Use	EEC/LC50 or LD50/sqft or LD50/day (or LD50 < 50
mg/kg)	0.2

	Acute Endangered Species	EEC/LC50 or LD50/sqft or LD50/day 	0.1

	Chronic Risk	EEC/NOAEC	1

Wild Mammals1

	Acute Risk	EEC/LC50 or LD50/sqft or LD50/day	0.5

	Acute Restricted Use	EEC/LC50 or LD50/sqft or LD50/day (or LD50 < 50
mg/kg)	0.2

	Acute Endangered Species	EEC/LC50 or LD50/sqft or LD50/day 	0.1

	Chronic Risk 	EEC/NOAEC	1

Aquatic Animals2



	Acute Risk	EEC/LC50 or EC50	0.5

	Acute Restricted Use	EEC/LC50 or EC50	0.1

	Acute Endangered Species	EEC/LC50 or EC50	0.05

	Chronic Risk	EEC/NOAEC	1

Terrestrial and Semi-Aquatic Plants 

	Acute Risk	EEC/EC25	1

	Acute Endangered Species	EEC/EC05 or NOAEC	1

Aquatic Plants2

	Acute Risk	EEC/EC50	1

	Acute Endangered Species	EEC/EC05 or NOAEC 	1

1  LD50/sqft = (mg/sqft) / (LD50 * wt. of animal)  

   LD50/day = (mg of toxicant consumed/day) / (LD50 * wt. of animal)

EEC = (ppb or ug/L) in water

Appendix H           ECOTOX  Results

MEFLUIDIDE

Papers that were accepted for ECOTOX

Acceptable for ECOTOX and OPP

Agnello, A. M., Bradley, J. R. Jr., and Van Duyn, J. W. (1986).
Plant-Mediated Effects of Postemergence Herbicides on Epilachna
varivestis (Coleoptera:  Coccinellidae).  Environ.Entomol. 15: 216-220.

EcoReference No.: 71019

Chemical of Concern: MFD,FZFB,SXD;  Habitat:  T;  Effect Codes: 
REP,GRO,BEH,ENV; Rejection Code:  LITE EVAL CODED(SXD,MFD),OK(ALL
CHEMS).

Griffin, J. L. and Harger, T. J. (1990). Red Rice (Oryza sativa) Control
Options in Soybeans (Glycine max).  Weed Technol. 4 : 35-38.

EcoReference No.: 74045

User Define 2: WASH

Chemical of Concern: MTL,BT,FZFP,ACR,SXD,HFP,MFD,FZF,QZF;  Habitat:  T; 
Effect Codes:  POP; Rejection Code:  NO CONTROL,TARGET(SXD).

Kwon, S. L., Smith, R. J. Jr., and Talbert, R. E. (1991). Red Rice
(Oryza sativa) Control and Suppression in Rice (O. sativa).  Weed
Technol. 5: 811-816.

EcoReference No.: 74741

Chemical of Concern: MLT,FNP,AMC,SXD,MFD;  Habitat:  A;  Effect Codes: 
PHY,POP; Rejection Code:  LITE EVAL CODED(MFD),OK(ALL CHEMS).

Marini, R. P., Byers, R. E., and Sowers, D. L. (1989). Growth Regulators
and Herbicides for Delaying Apple Fruit Abscission.  Hortscience 24:
957-959.

EcoReference No.: 76104

Chemical of Concern: BZO,TPR,DMB,PBZ,DMZ,FXP,PDM,MFD;  Habitat:  T; 
Effect Codes:  GRO; Rejection Code:  OK(FXP,DMZ,PBZ),OK TARGET(DMB),NO
ENDPOINT(MFD,PDM,BZO,TPR).

Potter, D. A., Spicer, P. G., Redmond, C. T., and Powell, A. J. (1994).
Toxicity of Pesticides to Earthworms in Kentucky Bluegrass Turf. 
Bull.Environ.Contam.Toxicol. 52: 176-181.

EcoReference No.: 39542

Chemical of Concern:
24DXY,AZD,BFT,BMY,CPZ,CYF,DTP,EP,FNF,FPD,FSTAl,FVL,MFD,MYC,PRM,TEZ,TPM; 
Habitat:  T;  Effect Codes:  POP; Rejection Code:  LITE EVAL
CODED(AZD,FVL,BFT,CYF),OK(ALL CHEMS).

Potter, D. A., Spicer, P. G., Redmond, C. T., and Powell, A. J. (1994).
Toxicity of Pesticides to Earthworms in Kentucky Bluegrass Turf. 
Bull.Environ.Contam.Toxicol. 52: 176-181.

EcoReference No.: 39542

Chemical of Concern:
24DXY,AZD,BFT,BMY,CPZ,CYF,DTP,EP,FNF,FPD,FSTAl,FVL,MFD,MYC,PRM,TEZ,TPM; 
Habitat:  T;  Effect Codes:  POP; Rejection Code:  LITE EVAL
CODED(MFD,AZD,FVL,BFT,CYF),OK(ALL CHEMS).

Smith, R. J. Jr. (1989). Cropping and Herbicide Systems for Red Rice
(Oryza sativa) Control.  Weed Technol. 3:  414-419.

EcoReference No.: 73748

User Define 2: WASH

Chemical of Concern: MTL,TFN,PAQT,ACR,BT,MFD

Endpoint: POP;  Habitat:  T; Rejection Code:  OK.

Storey, G. K. and Gardner, W. A. (1986). Sensitivity of the Entomogenous
Fungus Beauveria bassiana to Selected Plant Growth Regulators and Spray
Additives.  Appl.Environ.Microbiol. 52: 1-3.

EcoReference No.: 82489

Chemical of Concern: MFD,PBZ,FPD;  Habitat:  T;  Effect Codes: 
POP,MOR,REP; Rejection Code:  LITE EVAL CODED(MFD),OK(ALL CHEMS).

Turner, K. E., Paterson, J. A., Kerley, M. S., and Forwood, J. R.
(1990). Mefluidide Treatment of Tall Fescue Pastures:  Intake and Animal
Performance.  J.Anim.Sci. 68: 3399-3405.

EcoReference No.: 82719

Chemical of Concern: MFD;  Habitat:  T;  Effect Codes:  PHY,BEH,GRO;
Rejection Code:  LITE EVAL CODED(MFD).

Wimer, S. K., Ward, J. K., Anderson, B. E., and Waller, S. S. (1986).
Mefluidide Effects on Smooth Brome Composition and Grazing Cow-Calf
Performance.  J.Anim.Sci. 63: 1054-1062.

EcoReference No.: 82721

Chemical of Concern: MFD;  Habitat:  T;  Effect Codes:  BCM,POP;
Rejection Code:  LITE EVAL CODED(MFD).

Acceptable for ECOTOX but not OPP

Agnello, A. M., Van Duyn, J. W., and Bradley, J. R. Jr. (1986).
Influence of Postemergence Herbicides on Populations of Bean Leaf
Beetle, Cerotoma trifurcata (Coleoptera:  Chrysomelidae) and Corn
Earworm, Heliothis zea (Lepidoptera: Noctuidae), in Soybeans. 
J.Econ.Entomol. 79: 261-265.

EcoReference No.: 72071

Chemical of Concern: MFD,SXD,FZFB;  Habitat:  T;  Effect Codes:  POP;
Rejection Code:  NO MIXTURE(SXD,MFD,FZFB),CONTROL(ACR).

Arnold, C. E., Aldrich, J. H., and Martin, F. G. (1983). Vegetative and
Flowering Response of Peach to Mefluidide.  Act Hortic 137: 145-152.

EcoReference No.: 44149

Chemical of Concern: MFD;  Habitat:  T;  Effect Codes:  GRO; Rejection
Code:  NO ENDPOINT(MFD).

Atkin, J. C. (1984). The Use of Mefluidide to Control Grass Growth in
Amenity Areas.  Asp App Biol 6: 45-53.

EcoReference No.: 31485

Chemical of Concern: MFD;  Habitat:  T;  Rejection Code:  TARGET(MFD).

Banko, T. J. (1985). Evaluation of Growth Regulator Effects of Embark,
Atrinal, Blazer, and Bayleton on Container-Grown Azaleas . 
J.Environ.Hortic. 3: 149-152.

EcoReference No.: 31450

Chemical of Concern: TDF,ACF,DKGNa,MFD;  Habitat:  T;  Effect Codes: 
GRO; Rejection Code:  OK(ACF),NO ENDPOINT(TDF,TARGET-DKGNa,MFD).

Belander, G. and Winch, J. E. (1985). Herbicides for Sod-Seeding Legumes
on Shallow Soil Pastures.  Can.J.Plant Sci. 65: 1049-1055.

EcoReference No.: 44163

Chemical of Concern: GYP,MFD,FZFB,PAQT;  Habitat:  T;  Effect Codes: 
POP,BCM; Rejection Code:  OK(ALL CHEMS),OK TARGET(MFD).

Chappell, W. E., Coartney, J. S., and Link, M. L. (1977). Plant Growth
Regulators for Highway Maintenance.   Proc.South.Weed Sci.Soc. 30:
300-305.

EcoReference No.: 40596

Chemical of Concern: MFD,MLH;  Habitat:  T;  Effect Codes:  GRO,REP;
Rejection Code:  OK(ALL CHEMS),OK TARGET(MFD).

Elkins, D. M., Vandeventer, J. W., and Briskovich, M. A. (1977). Effect
of Chemical Growth Retardants on Turfgrass Morphology.  Agron J 69:
458-461.

EcoReference No.: 43015

Chemical of Concern: MFD,MLH;  Habitat:  T;  Effect Codes:  GRO,MOR;
Rejection Code:  OK(ALL CHEMS),OK TARGET(MFD).

Field, R. J. and Whitford, A. R. (1983). Response of Perennial Ryegrass,
Prairie Grass, and Browntop to the Growth Retardant, Mefluidide.  Nz J
Exp Ag 11: 199-203 .

EcoReference No.: 44162

Chemical of Concern: MFD;  Habitat:  T;  Effect Codes:  BCM,GRO;
Rejection Code:  NO ENDPOINT(ALL CHEMS).

Gerrish, J. R. and Dougherty, C. T. (1983). Tall Fescue Sward Response
to Mefluidide and Nitrogen.  Agron J 75(6): 895-898.

EcoReference No.: 32345

Chemical of Concern: MFD;  Habitat:  T;  Rejection Code:  TARGET(MFD).

Griffin, J. L. and Harger, T. J. (1990). Red Rice (Oryza sativa) Control
Options in Soybeans (Glycine max).  Weed Technol. 4 : 35-38.

EcoReference No.: 74045

Chemical of Concern: MTL,BT,FZFP,ACR,SXD,HFP,MFD,FZF,QZF;  Habitat:  T; 
Effect Codes:  POP; Rejection Code:  NO CONTROL(TARGET-SXD,MFD) .

Ivie, G. W. (1980). Fate of the Plant Growth Regulator Mefluidide
[N-[2,4-Dimethyl-5-[[(trifluoromethyl)sulfonyl]amino]phenyl]acetamide]
in A Cow and Sheep.  J.Agric.Food Chem. 28: 1286-1288.

EcoReference No.: 37270

Chemical of Concern: MFD;  Habitat:  T;  Effect Codes:  PHY; Rejection
Code:  NO ENDPOINT(MFD).

Marini, R. P., Byers, R. E., and Sowers, D. L. (1989). Growth Regulators
and Herbicides for Delaying Apple Fruit Abscission.  Hortscience 24:
957-959.

EcoReference No.: 76104

Chemical of Concern: BZO,TPR,DMB,PBZ,DMZ,FXP,PDM,MFD;  Habitat:  T; 
Effect Codes:  GRO; Rejection Code:  OK(FXP,DMZ,PBZ),OK TARGET(DMB),NO
ENDPOINT(MFD,PDM,BZO,TPR).

McWhorter, C. G. and Barrentine, W. L. (1979). Weed Control in Soybeans
(Glycine max) with Mefluidide Applied Postemergence.  Weed Sci. 27:
42-47.

EcoReference No.: 42763

Chemical of Concern: GYP,BT,MFD,24DB;  Habitat:  T;  Effect Codes: 
POP,PHY; Rejection Code:  OK(ALL CHEMS),OK TARGET(MFD).

McWhorter, C. G. and Wills, G. D. (1978). Factors Affecting the
Translocation of 14C-Mefluidide in Soybeans (Glycine max), Common
Cocklebur (Xanthium pensylvanicum) and Johnson Grass (Sorghum
halapense).  Weed Sci. 26: 382-388.

EcoReference No.: 29602

Chemical of Concern: MFD;  Habitat:  T;  Rejection Code:  TARGET(MFD).

Parups, E. V. and Cordukes, W. E. (1977). Growth of Turfgrass As
Affected by Atrinal and Embark.  Hortscience 12: 258-259.

EcoReference No.: 28947

Chemical of Concern: DKGNa,MFD;  Habitat:  T; Rejection Code: 
TARGET(DKGNa,MFD).

Slade, J. J. and Reynolds, J. H. (1985). Plant Growth Regulator Effects
on Forage Quality of Tall Fescue and Bermudagrass.  Tenn.Farm Home Sci.
134: 19-23.

EcoReference No.: 44106

Chemical of Concern: EDT,CQTC,EPH,MFD;  Habitat:  T;  Effect Codes: 
GRO,BCM,POP; Rejection Code:  OK(ALL CHEMS),OK TARGET(MFD,CQTC).

Smith, R. J. Jr. (1989). Cropping and Herbicide Systems for Red Rice
(Oryza sativa) Control.  Weed Technol. 3:  414-419.

EcoReference No.: 73748

Chemical of Concern: MTL,TFN,PAQT,ACR,BT,MFD;  Habitat:  A;  Effect
Codes:  POP; Rejection Code:  OK(MTL,TFN,ACR,PAQT),NO MIXTURE(MFD,BT).

Sterrett, J. P. (1979). Injection Methodology for Evaluating Plant
Growth Retardants.  Weed Sci. 27: 688-690.

EcoReference No.: 44029

Chemical of Concern: DKGNa,MFD;  Habitat:  T;  Effect Codes:  GRO,BCM;
Rejection Code:  OK TARGET(MFD,DKGNa).

Truelove, B., Davis, D. E., and Pillai, C. G. P. (1977). Mefluidide
Effects on Growth of Corn (Zea mays) and the Synthesis of Protein by
Cucumber (Cucumis sativus) Cotyledon Tissue.  Weed Sci. 25: 360-363.

EcoReference No.: 43005

Chemical of Concern: MFD;  Habitat:  T;  Effect Codes:  POP,GRO,BCM;
Rejection Code:  OK TARGET(MFD).

MEFLUIDIDE

Papers that were excluded from ECOTOX

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improvement) infrastructure.  Hospital Peer Review 26: 45-47.

1996). Four TDR diseases can be "eliminated".  TDR News 1-2.

1992). Pesticide chemicals manufacturing category effluent limitations
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Productivity in the '90s. The outsourcing source book.  The Journal Of
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Abert, James G. and Vancil, Ronald M. (1977). A graphical approach to
determine the economics of recovering resources from municipal solid
waste.  Conservation & Recycling 1: 299-300.

Abramov, V V, Mustafin, A G, Iarygin, V N, and Kozlov, V A (1991).
Immunogenesis and axoplasmic transport in Wistar rats.  Biulleten'
Eksperimental'Noi Biologii i Meditsiny 112: 621-623.

Abramson, D (1987). Hadley Regional Medical Center embarks on laundry
savings plan.   Laundry News 13: 6.

Adamczewsk, A M and Morris, S (2001). Metabolic status and respiratory
physiology of Gecarcoidea natalis, the Christmas Island red crab, during
the annual breeding migration.  The Biological Bulletin 200: 321-335.

Afanas'ev, Iu I and Bobova, L P (1976). Histophysiology of the thymus
gland.  Arkhiv Patologii 38: 3-17.

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Alikhanidi, Sokratis and Takahashi, Yoshimasa (2004). Pesticide
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Amstislavskii, S Ia, Kachanova, I Iu, Markel', A L, and Iakobson, G S
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Anderson, A (1988). US embarks on radon testing.  Nature 335: 285.

Andreeva, Iu A, Kudrin, V S, and Raevskii, K S ( Effect of
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Arbel, A, Zenvirth, D, and Simchen, G (1999). Sister chromatid-based DNA
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Aristakesian, E A ( The development of the wakefulness-sleep cycle in
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Barami, K, Iversen, K, Furneaux, H, and Goldman, S A (1995). Hu protein
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Batuev, A S, Riabinskaia, E A, and Ashikhmina, O V ( Training of rats of
the Wistar and Krushinskii-Molodkinaia lines in a radial maze.  Zhurnal
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Baumann, M and Sander, K ( 1984). Bipartite axiation follows incomplete
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Blum, A. (1983). Genetic and physiological relationships in plant
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Bodelier, Paul L. E. and Laanbroek, Hendrikus J. (2004). Nitrogen as a
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Binding of (3)-imipramine by platelets from spontaneously hypertensive,
normotensive, and Wistar rats and their behavior in stressful
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Bowling, A, Jacobson, B, and Southgate, L (1993). Explorations in
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Bozhkov, A I, Shereshevskaia, Ts M, Martyniuk, N M, and Shakhbazov, V G
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Bush, E. W., Porter, W. C., Shepard, D. P., and McCrimmon, J. N. (1998).
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Bykova, E V, Legostaev, G N, and Rogatina, E L (1987). Characteristics
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Chavrakov, G (1974). Localization of Klossiella muris in various organs
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Churina, S K, Ianushkene, T S, Samoilov, M O, Semenov, D G, Kuznetsov, S
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Coombs, J A and Silversin, J B (1979). The HSA: a focus for advancing
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Dygalo, N N and Naumenko, E V (1984). Genetic aspects of the hormonal
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Elkin, V I ( Type of higher nervous activity in rats affected with
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Elkins, Donald M (1983). Growth regulating chemicals for turf and other
grasses.  2: 113-30.

Chem Codes:  Chemical of Concern: CFRM  Rejection Code:  REVIEW.

A review with 60 refs. of growth regulators, e.g., chlorflurenol 
[2464-37-1], maleic hydrazide  [123-33-1], and mefluidide  [53780-34-0],
for grasses and turf. [on SciFinder (R)] review/ turf/ grass/ growth/
regulator

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FACTEAU, T. and MIELKE, E. (1987). ORCHARD CHEMICAL MOWING.  84TH ANNUAL
MEETING OF THE AMERICAN SOCIETY FOR HORTICULTURAL SCIENCE AND THE 34TH
ANNUAL CONGRESS OF THE INTERAMERICAN SOCIETY FOR TROPICAL HORTICULTURE,
ORLANDO, FLORIDA, USA, NOVEMBER 6-12, 1987. HORTSCIENCE; 22 1127.

Fedorov, V K and Gromova, K I (1971). Effect of growth hormone on the
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Wistar line rats.  Doklady Akademii Nauk SSSR 198: 727-729.

Ferreira, H G (1994). Evaluation of medical schools and universities.
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 Other anilide herbicides considered were chloranocryl, monalide and
pentanochlor, however no ecotoxicity data were available for these
chemicals.  The chemical structures of  mefluidide and propanil are
provided in Appendix B. 3 Submitted ecotoxicity data are summarized in
Appendix A.

 PAGE   

 PAGE   1 

 PAGE   

 PAGE   133 

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Enol Form

Keto Form

Mefluidide-DEA a.i

Mefluidide

Mefluidide-K a.i

