UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON D.C., 20460

										

	MEMORANDUM							DATE:  08/24/2011

	SUBJECT:	Non-target Organism and Endangered Species Screening Risk
Assessment for the Methyl Anthranilate (Benzoic Acid, 2-Amino, Methyl
Ester) Registration Review Preliminary Work Plan

		Chemical Class: 			Biochemical	

		PC Code: 				128725

					CAS Number:		134-20-3

		Tolerance Exemptions: 	40 CFR 180.			

FROM:	Russell S. Jones, Ph.D., Senior Biologist

	Biochemical Pesticides Branch

	Biopesticides & Pollution Prevention Division

TO:	Chris Pfeifer, Regulatory Action Leader

	Biochemical Pesticides Branch

	Biopesticides & Pollution Prevention Division

	

	EXECUTIVE SUMMARY

The bird repellent, Methyl Anthranilate, in a naturally occurring
flavoring substance in grapes.  The repellent action arises from the
stimulation of the trigemimal nerve in the head of a bird resulting in a
pain response (Kirifides et. al., 2004).  

Based on the available data and information, the Agency does not foresee
the need for new data or for new risk assessments for this active
ingredient.  Non-target organism hazard and exposure information as well
as Agency risk assessments on Methyl Anthranilate were evaluated against
current safety standards established by the Agency’s scientific
policies and regulations and it was determined that there is no need to
conduct additional risk assessments.  The active ingredient is a
naturally occurring substance, has a non-toxic mode of action, and is of
low toxicity.  There is reasonable certainty of no harm to non-target
organisms when Methyl Anthranilate is applied in accordance with
EPA-approved product labeling.  A screening level assessment was
conducted to evaluate the existing non-target organism data base.  

Toxic endpoints have not been identified for non-target mammals and
non-target birds on an acute and dietary basis in laboratory testing
(respective non-definitive endpoints of >5000 mg/kg and >500 mg/kg/day).
 The active ingredient is moderately toxic to slightly toxic to
freshwater fish on a acute basis (9.12 ppm to 42.56 ppm), and
practically non-toxic on a dietary basis (>1000 mg/kg in diet) in
laboratory testing.  It is slightly toxic to aquatic invertebrates (17.0
to 29.1 ppm).  Toxic endpoints have not been established for non-target
insects (honey bees).  Non-target terrestrial plants can tolerate
>40,000 ppm of Methyl Anthranilate before exhibiting any observable
foliar desiccation or necrosis (MRID 42740204).  Based on the highest
respective application rates for terrestrial and aquatic  use sites,
calculated Risk Quotients (RQs) are all <0.05 for all taxa.  

Based on the fact that Methyl Anthranilate is relatively non-toxic to
non-target organisms and on its use pattern and use instructions, EPA
has determined that Methyl Anthranilate will have "No Effect" on any
currently listed threatened or endangered species or any designated
critical habitat. 

		1.	Description of the Active Ingredient

			Common Name:	Methyl Anthranilate

			Chemical Name:	Benzoic Acid, 2-Amino, Methyl Ester

			Synonyms:		Anthranilic Acid, methyl ester

						Methyl-2-amonobenzoate

						Methyl o-aminobenzoate

						o-Carbomethoxyaniline

						Neroli Oil

						Nevoli Oil

			CAS Number:	134-20-3

			Empirical Formula:	C8H9NO2

			

					

						Figure 1.  Structure of Methyl Anthranilate

Methyl Anthranilate is a repellent used to repel pest birds from food
use and non-food use sites.  The active ingredient is employed in
pesticide products used on landfills, tailing ponds,
commercial/industrial water impoundments, temporary pools, decorative
fountains, non-fish bearing waters, electrical substations, farmsteads,
agricultural sites, structures, buildings, airports & other open areas;
ornamental trees & shrubs; turf; lakes, ponds, harbors, boat docks,
aquatic production sites (non-fish bearing waters such as hatcheries and
culture ponds), pome fruits, stone fruits, cereal grains, blueberries,
sunflowers, table grapes, and turf.

Methyl Anthranilate was classified as a Biochemical Pesticide Active
Ingredient by the OPP Biotechnology Work Group August 24, 1992 (EPA,
1992). 

		2.	Registered End-Use Products and Maximum Use Rates

There are 7 currently registered End-Use Products (EPs) containing
Methyl Anthranilate as their active ingredient (see Appendix Table 1).  

	3.	Ecological Hazards

Adequate non-target toxicology data/information are available to support
registration of Methyl Anthranilate.  All non-target organism toxicology
data requirements for Methyl Anthranilate have been satisfied.  No
additional data are required.  

There are no concerns for any non-target organisms when Methyl
Anthranilate is applied in accordance with EPA-approved label use
directions.  Toxic endpoints have not been identified for non-target
mammals and non-target birds on an acute and dietary basis in laboratory
testing.  The active ingredient is moderately toxic to slightly toxic to
freshwater fish on a acute basis, and practically non-toxic on a dietary
basis in laboratory testing.  It is slightly toxic to aquatic
invertebrates.  Toxic endpoints have not been established for non-target
insects (honey bees).  Non-target terrestrial plants can tolerate
>40,000 ppm of Methyl Anthranilate before exhibiting any observable
foliar desiccation or necrosis (MRID 42740204).  

A review of the ECOTOX database did not reveal any additional non-target
toxicity data or endpoints that were lower than those previously
evaluated by the Agency.  

	

	4.  Environmental Fate and Ground Water Data

The need for environmental fate and groundwater data was not triggered
because results of the acute toxicity assessment did not trigger any
additional Tier I studies.  Some data, however, are available from
studies submitted in support of a Tolerance Exemption and from external
technical sources.  Residues of Methyl Anthranilate (MA) applied to food
crops are expected to dissipate to background levels before they are
distributed for consumption.  

Methyl anthranilate is extremely volatile (vapor pressure of 2.7 x 10-2
mm Hg at 25oC) and will rapidly dissipate into the surrounding
atmosphere from foliar surfaces to which it has been applied, and is
expected to have an atmospheric half-life of 11 hours  (HSDB, 2004). 
Based on its vapor pressure and low water solubility, MA is also
expected to volatilize rapidly from water surfaces (HSDB, 2004) in as
little as 16 days.  

Data obtained from the technical literature suggest a range of
degradation rates depending upon environmental conditions.  Aronov and
Clark (1996) report that MA is not subject to hydrolysis under
laboratory conditions between pH 5 to pH 9 in aqueous phosphate buffers,
but is susceptible to degradation by UV light (up to 42% after 27 days
of illuminance at 1.25 mW cm-2, equivalent to natural sunlight at noon
at 40o north latitude).  Microbial activity was observed to be a
significant degradation pathway with 22% loss after nine days and 100%
loss after 20 days at optimal conditions of light and temperature (a
12:12 hr light:dark cycle and 23oC).  Laboratory studies (Askham, 1992)
with MA on glass slides demonstrated that MA was extremely photolabile
with 50% loss after two days of exposure to full sunlight and was
undetectable after four days exposure.

Avery et. al. (1995) reported residues on rice as 11.7 ppm immediately
following an application of ReJex-It AG-36 (14.5% a.i.) at 6.2 lb
a.i./A, which rapidly declined over the next 14 days with a half-life of
7 days (interpolated by reviewer based on study author data).  The
application rate used in this study is equivalent to the maximum
approved label application rate for food crops (see Appendix Table 1).  

Based on data from empirical studies, MA residues will be low
immediately following application and will rapidly dissipate in
terrestrial environments under the combined influences of UV light and
microbial degradation (Aronov & Clark, 1996; Askham, 1992) .  Low
solubility in water coupled with rapid volatilization and microbial
degradation will result in minimal residues in aquatic habitats.  

 	5.  Ecological Exposure and Risk Characterization

Methyl Anthranilate is a naturally-occurring substance in plants such as
corn, sunflowers, grapes (33 ppm) and cherries (35 ppm), as well as
cocoa and black tea (EPA, 1994).  Honey made from citrus floral sources
has been reported to contain from 3.60 to 5.04 mg/kg of MA (Ferreres et.
a., 1994; White & Bryant, 1996, unpublished study).   It is extremely
volatile and degrades rapidly into non-toxic components such as
anthranilic acid.  Numerous studies are available evaluating residues on
crops and aquatic environments following application of Methyl
Anthranilate at maximum label use rates for the respective use sites.  

Terrestrial Residues:  Data from magnitude of the residue studies on
apples, corn (sweet), and sunflower, submitted in support of an
Experimental Use Permit in 2000 (66550-EUP-001; EPA, 2000) confirm the
rapid dissipation of MA.  Residues on whole apples treated with a single
foliar application of MA at 2.29 lbs a.i./A declined from 1.79 ppm at
1-hour posttreatment to <0.055 ppm (non-detectable) by 14 days
posttreatment (MRID 45065105).  Residues on sweet corn treated with a
single foliar application of MA at 0.573 lbs a.i./A were 1.65 ppm at
1-hour posttreatment.  Following a second treatment after a five-day
application interval, residues were 0.374 ppm 10-days after the second
application (MRID 45065103).  Residues on sunflowers treated with a
single foliar application of MA at 0.573 lbs a.i./A were 0.011 ppm at
1-hour posttreatment.  Following a second treatment after a five-day
application interval, residues were 0.233 ppm 10-days after the second
application (MRID 45065104).  

Avery et. al. (1995) reported residues on rice as 11.7 ppm immediately
following an application of ReJex-It AG-36 (14.5% a.i.) at 6.2 lb
a.i./A, which rapidly declined over the next 14 days with a half-life of
7 days (interpolated by reviewer based on study author data).  The
application rate used in this study is equivalent to the maximum
approved label application rate for food crops (see Appendix Table 1).  

The residue value reported by Avery et. al. (1995) was used to calculate
Risk Quotients (RQs) for mammals and birds following terrestrial
applications of methyl Anthranilate at the maximum label used rate.  

Aquatic Residues:  Magnitude of the residue studies have been conducted
for both direct application and fogging applications of Methyl
Anthranilate products to aquatic sites.  

In a catfish toxicity study (Dorr et. al. 1998), a 40% liquid MA end-use
product (ReJex-iT AG 40; EPA Reg. No. 58035-7; not currently registered)
was applied directly to the surface of an aquaculture pond at an
exaggerated rate of 80 lb a.i./A water surface (10X the maximum label
rate for currently registered products).  The maximum concentration of
MA was 4.44 ppm at a depth of 24 inches following seven applications
over a two week period.  If mathematically adjusted to a 1X rate, the
calculated residues are estimated to be approximately 0.444 ppm.  

A magnitude of the residue study (MRIDs 45210201, 45210202, & 45229701)
was conducted to determine the maximum amount of MA residues that would
occur in a pond following fogging applications using two different types
of foggers (thermal and ultra low volume) and a product that is no
longer registered for use (ReJex-iT TP-40; EPA Reg. No. 58035-7; 40%
a.i.).  The samples were not replicated which precluded statistical
analysis and an assessment of sample variability, and there were five
anomalously high MA residue measurements (5.97 ppm to 60.47 ppm) that
were well outside the range of the majority of samples (total = 26),
which were in the range of <0.016 ppm to 1.6 ppm.  In addition, the
unusually high values were well outside the values reported by Dorr et.
al. (1998), following direct spray application to pond.  Therefore,
these data are considered unreliable for purposes of non-target organism
risk assessment.  It was observed, however, that MA content of water
samples generally decreased with distance from the foggers.  

Fog application rates are an order of magnitude below that of direct
spray applications (0.21 lb a.i/A vs. 8.0 lb a.i./A).  The Tier I Rice
Model equation (EPA, 2007) was used to estimate environmental
concentrations in water following a fog application at maximum label use
rates (0.21 lbs a.i./A or 0.24 kg a.i./ HA) and assuming a Koc of 250
for MA (HSDB, 2004):

	Cw =	mai/(0.00105 + (0.00013 * Kd))

	Where:  			Cw = water concentration [µg/L]

mai' = mass applied per unit area [kg/ha]

	Kd = water-sediment partitioning coefficient [L/kg]  (and Kd  =
0.01Koc)

Koc = organic carbon partitioning coefficient [L/kg]

									

	Then:				Cw =	0.24/(0.00105 + (0.00013 * 2.5)) =  0.175 ppm

	This value is less that the calculated EEC of 0.444 ppm (estimated
using data from Dorr et. 

	al., 	1998).  The conservative EEC of 0.444 ppm will be used to
evaluate risk to non-target aquatic organisms when Methyl Anthranilate
is applied at the maximum label use rates.  

	6.  Threatened and Endangered Species Assessment

	

A qualitative risk assessment can be conducted with acute and dietary
mammal and avian toxicity data; aquatic organism LC50 and EC50 data; and
terrestrial plant and insect (honey bee) data from obtained from
guideline studies, non-guideline studies, and the open technical
literature  (Appendix Table 2), in conjunction with the label use
information for Methyl Anthranilate from the product labels (Appendix
Table 1).  Although none of the labels specified any limitation on the
number of applications, there is sufficient information to conduct a
qualitative endangered species risk assessment due to the minimal
toxicity of Methyl Anthranilate to non-target species and its rapid
biodegradation in the environment.    Toxic endpoints were not found for
mammals, birds, and terrestrial insects in laboratory testing (Appendix 
Table 2).  Field testing on cherries, blueberries, grapes, and sweet
corn demonstrated that >40000 ppm of methyl anthranilate was required to
induce slight necrosis and desiccation of foliage (MRID 42740204).  The
product is considered slightly toxic for five of six fish species tested
(LD50 range:  16.23 to 42.56 ppm) and moderately toxic (LD50  =  9.12
ppm) to one fish species (Appendix Table 2).  

Mammals:  Mammalian (rat) acute oral toxicity is >5000 mg/kg (Toxicity
Category IV; Appendix Table 2).  The subchronic (90-day) dietary No
Observable Effects Level (NOEL) was >500 ppm (Appendix Table 2).  The
non-definitive endpoints are respectively approximately 430X and 43X
greater than the observed maximum environmental concentrations of 11.7
ppm for MA residues (Avery et. al., 1995) on terrestrial foliage.  Based
on the data and the Guidance for Using Non-Definitive Endpoints in
Evaluating Risks to Listed and Non-listed Animal Species (EPA, 2010),
there are no concerns for non-target mammals.  

Birds:  Avian acute oral toxicity >2250 mg/kg (Practically Non-toxic;
Appendix Table 2).  avian dietary toxicity was >5620 ppm (Practically
Non-toxic; Appendix Table 2).  The non-definitive endpoints are
respectively approximately 192X and 480X greater than the observed
maximum environmental concentrations of 11.7 ppm for MA residues (Avery
et. al., 1995) on terrestrial foliage.  Based on the data and the
Guidance for Using Non-Definitive Endpoints in Evaluating Risks to
Listed and Non-listed Animal Species (EPA, 2010), there are no concerns
for non-target birds.  

Fish:  Freshwater fish 96-hr LC50s ranged from 9.12 ppm to 42.56 ppm
across five fish species, which are categorized as moderately toxic to
slightly toxic (Appendix Table 2).  Using the most conservative endpoint
for fish in laboratory testing (Bluegill sunfish; 9.12 ppm) and the
measured calculated maximum EEC of MA in water (0.44 ppm), the Risk
Quotient (RQ) was calculated as:

			RQ		=	0.44 ppm	=	0.019

				   			 9.12 ppm

The RQ is well below any Level of Concern (LOC) for non-target fish,
including threatened and endangered species.  

Aquatic Invertebrates:  Aquatic Invertebrate EC50s for daphnids ranged
from 17.0 to 29.1  ppm which is categorized as moderately to slightly
toxic (Appendix Table 2).  Using the most conservative endpoint for
aquatic invertebrates (17.0 ppm) in laboratory testing and the maximum
estimated environmental concentration (EEC) of MA in water following a
direct spray application to water  (0.44 ppm), the RQ was calculated as:

			RQ		=	0.44 ppm	=	0.048			   								17.0 ppm

The RQ is  below any LOC for non-target aquatic invertebrates, including
threatened and endangered species.  

Plants:  Methyl anthranilate is a naturally-occurring substance found in
many plant species such as corn, sunflowers, grapes (33 ppm) and
cherries (35 ppm).  It is extremely volatile and degrades rapidly into
non-toxic components such as anthranilic acid.  MA has no known toxic
effects when applied exogenously to plants at the proposed rates of
application.  Reports of leaf desiccation in some studies were later
attributed to the presence of certain surfactants in the end-use
products and were not caused by MA (Askham, 1992; MRID 42740204).   In a
field study using leaves of blueberries, cherries, and grapes, it was
demonstrated that non-target terrestrial plants can tolerate >40,000 ppm
of Methyl Anthranilate before exhibiting any observable, but minor
foliar desiccation or necrosis (MRID 42740204).  Minor foliar
desiccation or necrosis was observed at 80000 ppm, but no plant
mortality was reported (Askham, 1992; MRID 42740204).  .  

Using the most conservative non-definitive endpoint for plants (40000
ppm) and the maximum observable residues on plants following a foliar
spray application at the maximum label use rate (11.7 ppm; Avery et.
al., 1995), the RQ was calculated as:

			RQ		=	 11.7 ppm	=	0.002			   								40000 ppm

The RQ is well below any LOC for non-target plants, including threatened
and endangered species.  

Insects:  Non-target insect contact toxicity LD50 for insects (honey
bee) was >25 ug/bee (see Appendix Table 2), which is categorized as
practically non-toxic.  No toxic effects were observed at the highest
rate used in laboratory testing.   Methyl anthranilate is a
naturally-occurring substance found in many plant species such as corn,
sunflowers, grapes (33 ppm) and cherries (35 ppm) to which pollinators
and other insects are exposed on a regular basis (EPA, 1994). 
Endogneous levels of MA reported for grapes and cherries are higher than
residues measured on foliage (11.7 ppm) following a single application
of MA at maximum label use rates (Avery et. al., 1995).  Honey made from
citrus floral sources has been reported to contain from 3.60 to 5.04
mg/kg of MA (Ferreres et. a., 1994; White & Bryant, 1996, unpublished
study)  indicating regualr dietary and contact exposure to
naturally-occurring MA by pollinators.   Based on these data, the Agency
has no concerns to non-target insects.  

CONCLUSIONS:  There are no concerns for any non-target organism when
Methyl Anthranilate is applied in accordance with EPA-approved product
labeling.  

Based on the fact that Methyl Anthranilate has minimal toxicity to
non-target organisms and on its use pattern and use instructions, EPA
has determined that Methyl Anthranilate will have "No Effect" on any
currently listed threatened or endangered species or any designated
critical habitat. 

	REFERENCES

Aronov, E. V. and L. Clark.  1996.  Degradation studies of the
non-lethal bird repellent, methyl anthranilate.  Pesticide Science 47: 
355-362.  

Askham, L. R. and J. K. Fellman.  1989.  Use of DMA to reduce robin
depredation on cherries.  Proceedings of the Great Plains Wildlands
Damage Control Workshop 9:  116-119.

Askham, L. R.  1992.  Efficacy of methyl anthranilate as a bird
repellent on cherries, blueberries and grapes.  Proceedings of the
Fifteenth Vertebrate Pest Conference.  J. E. Borrecco & R. E. Marsh,
Eds.  Published at University of California, Davis.  1992, pp. 137-141. 


Avery, M. L.  1989.  Experimental evaluation of partial repellent
treatment for reducing bird damage to crops.  Journal of Applied Ecology
26:  433-439.

Avery, M. L., D. G. Decker, J. S. Humphrey, S. Aronov, S. D. Lindscombe,
and M. O. Way.  1995.  Methyl anthranilate as a rice seed treatment to
deter birds.  Journal of Wildlife management 59(1):  50-56.  

Dorr, B., L. Clark, J. E. Glahn, I. Mezine.  1998.  Evaluation of a
methyl anthranilate-based bird repellent.  Toxicity to channel catfish
Ictalurus punctatus and effect on Great Blue Heron Ardea herodias
feeding behavior.  Journal of the World Aquaculture Society 29(4): 
451-462.

EPA.  1992.  Classification of Methyl Anthranilate (Chem. No. 128725) as
a Conventional Chemical or as a Biochemical Pesticide.  Memorandum from
J. T. McClintock to D. B. Peacock.  

EPA.  1994.  SAB review of the product chemistry, toxicology, summary
information, and toxicology and residue chemistry waivers submitted for
the registration of technical methyl anthranilate and an end-use
product, “Bird Shield Repellent.”  Product chemistry (Case# 008125;
Chemical # 128725; Submission # S455617; DP barcode D197915). 
Memorandum from S. K. Reilly to R. Forrest, dated 11/17/1994.  

EPA.  2000.  Experimental use permit for Bird Shield Repellent (EPA Reg.
No.  6550-EUP-001) containing 26.4% methyl anthranilate as its active
ingredient in or on corn sunflowers, and apples (chemical no. 128725): 
Evaluation of residue chemistry and analytical method.  MRIDs 450651-01,
-02, -03, -04, and -05; Case no. 066100; Submission no. S580610; DP
barcode D266613.  Memorandum from F. Toghrol to J. Downing, dated
08/16/2000.  

EPA.  2007.  Guidance for Tier I Estimation of Aqueous Pesticide
Concentrations in Rice 

Paddies.  Memorandum from S. Bradbury to EFED/OPP, dated 05/08/2007.  

EPA.  2010.  Guidance for Using Non-Definitive Endpoints in Evaluating
Risks to Listed and Non-listed Animal Species.  Memorandum from D. J.
Brady (Director, Environmental Fate and Effects Division) to
Environmental Fate and Effects Division Scientists, dated 08/03/2010.  

Ferreres, F., J. M. Giner, and F. A. Tomas-Barberan.  1994.  A
comparative study of hesperetin and methyl anthranilate as markers of
floral origin of citrus honey.  Journal of the Science of Food and
Agricultural Science 65(3):  371-372.  

Harpaz, S. and L. Clark.  2006.  Effects of addition of a bird repellent
to fish diets on their growth and bioaccumulation.  Aquaculture Research
 37:  132-138.

Hazardous Substances Data Base (HSDB).  2004.  National Library of
Medicine/TOXNET (05/25/2004 update). 

  HYPERLINK
"http://toxnet.nlm.nih.gov/cgi-bin/sis/search/a?dbs+hsdb:@term+@DOCNO+10
08" 
http://toxnet.nlm.nih.gov/cgi-bin/sis/search/a?dbs+hsdb:@term+@DOCNO+100
8 

Kirifides, M. L., M. P. Kurnellas, L. Clark, and B. P. Bryant.  Calcium
responses of chicken trigeminal nerve ganglion neurons to methyl
anthranilate and capsaicin.  Journal of Experimental Biology 207: 
715-722.  

White, J. W. and V. M. Bryant  1996.  Assessing citrus honey quality: 
Pollen and methyl anthranilate content. (Unpublished study).   
HYPERLINK
"http://www.honey.com/white/pdf/white199-assessing-citrus-honey-quality.
pdf" 
http://www.honey.com/white/pdf/white199-assessing-citrus-honey-quality.p
df 

	cc:	C. Pfeifer, R.S. Jones, BPPD Subject File/IHAD

	R. S. Jones, Ph.D., Sr. Scientist, FT, OPY:  08/24/2011

APPENDIX

Appendix Table 1.  Currently registered products and maximum label use
rates for each product label.  Highest use rates are boldfaced.  

Product 	EPA Reg. No.	Methyl Anthranilate Percentage	Maximum Use Rate
per Acre per Application 	Application Intervals

Avian ControlTM	33162-1	20.00%	Ground:  8 lb a.i./A surface water 1	1 -
4 days



	Fog:  0.21 lbs a.i./A 2	1 - 4 days







ReJex-It Fog ForceTM	58037-7	40.00%	Ground:  8 lb a.i./A surface water 1
1 - 4 days



	Outdoor Fog:  0.21 lbs a.i./A 2, 3	1 - 4 days







ReJex-It AG-36TM	58035-9	14.50%	Ground:  6.18  lb a.i./A 4	Not specified



	Aerial:   6.18  lb a.i./A 5	Not specified



	Aerial:  6.18  lb a.i./A 6	22 days 



	Ground:  0.07 lb a.i./A 7	4 days







ReJex-It Fog Force AR-20TM	58035-15	20.00%	Outdoor Fog:  0.21 lb a.i./A
2, 7	1 - 4 days







Bird Shield Repellent	66550-1	20.00%	Ground/aerial:  0.28 – 5.73 lb
a.i./A 8	Not specified



	Aerial:  0.28 lb a.i./A 9	Not specified



	Ground:   2.29 lb a.i./A 10	Not specified



	Ground:  4.58 lb a.i./A 7	7 – 14 days



	Ground:  0.07 lb a.i./gal	Spot spray



	Ground:  0.12 lbs a.i./gal  1	Added to pool







Liquid Fence Goose Repellent	72041-2	20.72%	Ground:  0.5 gal/40K sq ft 7
Not specified







Avex	83359-4	26.40%	Ground/aerial:  5.73 lb a.i./A 8	Not specified



	Aerial:  0.28 lb a.i./A 9	Not specified



	Ground:  2.29 lb a.i./A 10	Not specified



	Ground:  2.29 – 4.58 lb a.i./A 7	7 – 14 days



	Ground:  0.07 lb a.i./gal	Spot spray



	Ground:  0.12 lbs a.i./gal  1	Added to pool

1	Ground application to landfills, tailing ponds, commercial/industrial
water impoundments, temporary pools, decorative fountains, non-fish
bearing waters.

2	Electrical substations, farmsteads, agricultural sites, structures,
buildings, airports & other open areas; ornamental trees & shrubs; turf;
lakes, ponds, harbors, boat docks, aquatic production sites (non-fish
bearing waters such as hatcheries and culture ponds)

3	Tree fruits & cereal grains

4	Apples, stonefruits, blueberries, & grapes

5	Cereal Grains

6	Sunflowers

7	Turf

8	Pome fruit, stone fruit

9	Sunflower, blueberries

10	Table grapes

Appendix Table 2.  Summary of Non-Target Organism Data

Study Type/OCSPP Guideline	

LD50/LC50/EC50 Results	

Toxicity Category	MRID



 Acute Oral Toxicity

/OCSPP 870.1100  	>5000 mg/kg (rat)	Tox Category IV	42608702



 90-day  Feeding (rat)

/OCSPP 870.	>500 mg/kg/day	No effects on growth or survival	42151904



 Avian Acute Oral Toxicity

/OCSPP 850.2100  	>2036 ppm

(Bobwhite quail)	

Practically non-toxic 	42966902

	>2250 ppm

(Bobwhite quail)	

Practically non-toxic 	43610701



 Avian Dietary Toxicity

/OCSPP 850.	>5620 ppm

(Mallard duck)	Practically non-toxic	42608808

	>2200

(White crowned sparrow)	Practically non-toxic	42966903

	>5259 ppm

(Mallard duck)	Practically non-toxic	44741501



Freshwater Fish Acute Toxicity, 96 hr

/OCSPP 850.1075  	9.12 ppm 1, 2

(Bluegill sunfish)	Moderately toxic	42718202

	42.56 ppm 

NOEC = 33.6 ppm

 (bluegill)	Slightly toxic	43610702

	22.91 ppm 1

(Rainbow trout)	Slightly toxic	42966901

	25.40 ppm 2

(Rainbow trout)	Slightly toxic	43610703

	16.23 ppm 1

(Channel catfish)	Slightly toxic	42699803

	32.25 ppm 1

(Atlantic salmon)	Slightly toxic	42995101



Freshwater Fish Dietary Toxicity, 12-hr

/Non-Guideline	>1000 mg/kg

(striped bass & African cichlid)	No effects on growth or survival

	Harpaz & Clark, 2006





Aquatic Freshwater Invertebrate Toxicity, 48-hr /OCSPP 850.1010 	

17.0 mg/L 	Slightly toxic	41895207

	

29.1 mg/L 	Slightly toxic	42718203



Non-target Plants

	>40000 ppm on blueberries, cherries, grapes, and raspberries3 
Practically non-toxic	42740204



Non-target Insects (Honey Bee Contact Toxicity, 48-hr)/OCSPP 850.3020	
>25 ng/bee	

Practically non-toxic	41623704

1	Static conditions

2	Flow-through conditions

3	Based on visual observations of foliar necrosis/desiccation



Appendix Table 3.  Maximum N-6-BA residues following a single
application, or two consecutive applications at the maximum label use
rates. 1

Environmental Matrix	Residues (ppm) following  single application at 
0.039lb a.i./A 2	Residues (ppm) following  two applications at 0.041 lb
a.i./A with a 3-day interval 3	Residues (ppm) following  two
applications at 0.165 lb a.i./A with a 7-day interval 3

Short Grass



	Tall Grass



	Broadleaf Plants/Small Insects



	Fruits/Pods/Seedlings/Large insects



	1	Dietary-based Estimated Environmental Concentration (EEC) calculated
using T-REX model (EPA, 2005).  

2	Promalin Plant Growth Regulator (EPA Reg. No. 73049-1)

3	Riteway (EPA Reg. No. 71368-60)

Appendix Table 4.  Maximum N-6-BA residues in aquatic environments
following a single application, or two consecutive airblast applications
at the maximum label use rates (airblast/orchard application method). 1

Environmental Matrix	Residues (ppb) following  single application at 
0.039lb a.i./A 2	Residues (ppb) following  two applications at 0.041 lb
a.i./A with a 3-day interval 3	Residues (ppb) following  two
applications at 0.165 lb a.i./A with a 7-day interval 3

Peak GEEC



	Maximum 4-Day Avg. GEEC



	Maximum 21-Day Avg. GEEC



	Maximum 60-Day Avg. GEEC



	Maximum 90-Day Avg. GEEC



	1	Estimated Environmental Concentration (EEC) calculated using GENEEC2
model (EPA, 2001).  

2	Promalin Plant Growth Regulator (EPA Reg. No. 73049-1)

3	Riteway (EPA Reg. No. 71368-60)

Methyl Anthranilate		

PC Code:  128725	

Non-Target Organism Hazard Assessment and Endangered Species Screening
Risk Assessment for Registration Review Preliminary Work Plan	

 PAGE   

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OFFICE OF

CHEMICAL SAFETY AND POLLUTION PREVENTION

