              OFFICE OF CHEMICAL SAFETY
AND POLLUTION PREVENTION
                 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                            WASHINGTON, D.C.  20460








MEMORANDUM


DATE:		August 23, 2011

SUBJECT:	Preliminary Environmental Assessment for the Registration Review of AVI Glycine Hydrochloride (AVG) 

				Registration Review Case #: 6070
				PC Code: 129104
				CAS #: 55720-26-8
				Chemical Class: Biochemical


FROM:		Gina M. Casciano, M.S., Biologist
            Biochemical Pesticides Branch
				Biopesticides & Pollution Prevention Division (7511P)


THROUGH:	Mike Rexrode, Ph.D., Senior Scientist
            Biochemical Pesticides Branch
            Biopesticides & Pollution Prevention Division (7511P)
            				 
            				
TO:			John Fournier, Regulatory Action Leader
				Biochemical Pesticides Branch
            Biopesticides & Pollution Prevention Division (7511P)
            
            
ACTION REQUESTED

The following is the preliminary environmental assessment for AVI Glycine Hydrochloride (AVG), in support of the Registration Review Preliminary Work Plan.  


Executive Summary

Based on the available data, AVG is characterized as moderately toxic to avian species (acute LD50 =121 mg/kg, LC50 = 230 ppm; reproductive NOAEC = 50 ppm) and practically non-toxic to mammalians on an acute basis (LD50 = 6,480 mg/kg). The Rat Reproductive Toxicity study, however, produced a NOAEL = 2.5 mg/kg/day and a LOAEL = 4.0 mg/kg/day for F1 offspring and showed decreased viability of pups and retarded growth of F1 and F2 pups. Test diet was administered continuously for at least 70 days prior to F0 mating and during mating, gestation, and lactation until the litters were weaned. The F1 pups were weaned onto the same diet received by their parents. AVG is
practically non-toxic to coldwater fish (LC50 > 139 mg/L) and aquatic invertebrates (48 hr EC50 = 1.81 - 137 mg/L).  AVG is also practically non-toxic to honey bees (oral and contact LD50 > 100ug/bee) and exposure to plants should not result in adverse effects on seedling emergence, growth, weight or condition. 
 
The Agency assessed the potential risk of AVG (0.11 lbs ai/A) to non target organisms by using the Tier I aquatic model, GENEEC, for evaluating exposure and to aquatic organisms and actual field residues for terrestrial species. All calculated RQ values were less than the Agency LOC (aquatic LOC = 0.05  -  0.5; and terrestrial LOC = 0.1  -  1.0). The Agency also has concluded a No Effect for endangered/ threatened species based on the risk assessment for non-target aquatic and terrestrial species, the persistence of AVG in the environment (1.7 - 4.7 days), and the application rate (50 grams/A; 0.11 lbs ai/A).

STUDY SUMMARIES
1.0	Environmental Chemistry and Fate Assessment

AVI glycine hydrochloride (AVG) is a plant growth regulator used on apples, pears, and ornamentals. As a naturally occurring chemical, AVG prevents the biosynthesis of ethylene in plants by interfering with the functioning of the enzyme aminocyclopropanecarboxylate synthase (ACC synthase). When applied to apples, it may delay fruit maturity, leading to benefits such as a reduction in pre-harvest fruit drop and improved fruit quality. In pears, AVG may help maintain fruit firmness. For specific ornamentals (miniature carnations, hibiscus, and rooted geranium cuttings and seedlings), AVG may reduce problems such as flower senescence and flower bud abscission that occur during shipping. Registered products containing AVG are intended for use as spray solutions, applied to apples or pears as a single application 28 days prior to the anticipated beginning of the normal harvest period, and to specified ornamentals 24 to 48 hours prior to boxing/shipping. 

AVG is very soluble in water at 674 +- 23 g/L (pH =6.0), has a very low vapor pressure, and a low potential to volatilize. AVG is hydrolytically stable (sterile conditions) with an expected half-life of greater than 5days. Photodegredation data for water or soil was not available, but models indicate the half life of AVG in the atmosphere to be 0.7 hours during daylight and 4 hours at night (assuming ozone mediated decay and hydroxyl mediated decay, respectively). No data is available on leaching rates of AVG. 

Degradation of AVG into two major metabolites has been observed in water and soil with ethoxyvinylglycine as the predominate degradate, and ω-N-acetyl-AVG as a slightly less predominate metabolite.  AVG migrates rapidly from the aqueous phase to the sediment phase and strongly adsorbs to sediment. 

AVG is easily desorbed from soils with low clay content (humic sand and low humic content sandy loam) and degrades rapidly in sandy loam and loam during adsorption and desorption.  Generally, AVG degrades rapidly in soil, with half-life ranging from 1.7 to 4.7 days depending on soil type.  The half life for the two metabolites in soil ranged from 0.3-8.2 days. A summary of the environmental chemistry and fate properties for AVG appear in Table 1.0.



Table 1.0 Summary of AVG Environmental Chemistry and Fate Properties

                                     Study

                                 Value (units)
                                       

                               Major Degradates
                               Minor Degradates

                                    MRID #

                                 Study Status
Sediment and Soil Adsorption/ Desorption
Sandy loam:
Kd-ads = 59.96 mL/g
Koc- ads =  7,495 mL/g
Kd-des  = 76.22 mL/g

Low humic content sandy loam:
Kd-ads =  4.11 mL/g
Koc- ads =  1,028 mL/g
Kd-des  =  5.18 mL/g

Loam:
Kd-ads = 73.86 mL/g
Koc- ads = 7,386 mL/g
Kd-des  = 82.66 mL/g

Humic sand:
Kd-ads = 7.86 mL/g
Koc- ads = 561 mL/g
Kd-des  = 18.01 mL/g

Degraded rapidly in sandy loam and loam during adsorption and desorption. Stable during adsorption in low humic sand and sand, but some degradation during desorption. Two degradates were observed but were not identified. 

                                   45359607
Acceptable
Hydrolysis
Hydrolytically stable at pH 7, 9. Slight hydrolysis (6%) at pH 4. Test performed at 50[o]C over five days.
Degradates were not identified.
                                   46791701
Acceptable
Aerobic Soil Metabolism
Degraded very rapidly in sandy loam and loam soils with a half life of 1.7 and 2.4 days, respectively. Half life in humic sand and low humic content sand soils were 3.0 and 4.7 days, respectively. 
HPLC confirmed that parent degraded rapidly and two major metabolites were formed. The half life of the two metabolites in the four soil types ranged from 0.3-8.2 days. 
                                   46066803
Acceptable
Aerobic/Anaerobic aquatic metabolism
Moved rapidly from water column to sediment in an anaerobic sediment/aerobic water system. Less than 1% test substance remaining in aqueous phase after 9 days of incubation.


HPLC detected two metabolites, which were identified via LC-MS/MS. Metabolite appearing in greatest quantity (and eluding first) was identified as ethoxyvinylglycine. Metabolite of lesser quantity was identified as ω-N-acetyl-AVG. 
                                   45796502
                                   45796503
                                  Acceptable
Photodegredation in air
Model results indicate a half life of 0.7 hours during daylight and 4 hours during night-time.
                                       -
                                   46066802
Non-Guideline/ Acceptable

2.0       Measures of Ecological Exposure

Measures of exposure are based on aquatic and terrestrial models that predict estimated environmental concentrations (EECs) of a pesticide using maximum labeled application rates and methods of application. The use patterns for the three currently registered end-use products (EPs) containing AVG 

are applied as spray solutions to flowers, orchard fruit and foliage. Therefore, runoff and spray drift are potential transport mechanisms of AVG to non-target aquatic and terrestrial sites. However, all end-use product labels currently include the statement "For Terrestrial Uses: Do not apply directly to water, to areas where surface water is present or to intertidal areas below the mean high water mark. Do not contaminate water when disposing of equipment wash water or rinsate." The maximum use rate for AVG on outdoor crops is 50 grams/acre applied twice pre-harvest on apples and once pre-harvest on all other approved crops. 

For aquatic exposure estimates, the Agency estimated environmental concentrations (EECs) of AVG that may impact aquatic organisms by applying a Tier I aquatic model, GENEEC Version 2.0 (Appendix B). Terrestrial exposure was assessed by using actual residues taken in the field (peach orchard) for a similar compound ABG-3168 (50 grams ai/A).

3.0    Measures of Effect

Measures of effect for AVG are obtained from the registrant-submitted guideline studies for this biochemical.  The acute measures of effect routinely used for non-target animals in screening level assessments are the LD50, LC50 or EC50, depending on taxa.  LD stands for "Lethal Dose", and LD50 is the amount of a material, given all at once, that is estimated to cause the death of 50% of a group of test organisms.  LC stands for "Lethal Concentration" and LC50 is the concentration of a chemical that is estimated to kill 50% of a sample population.  EC stands for "Effective Concentration" and the EC50 is the concentration of a chemical that is estimated to produce some measured effect in 50% of the test population.  Endpoints for chronic measures of exposure for listed and non-listed animals are the NOAEL or NOAEC.  NOAEL stands for "No Observed-Adverse-Effect-Level" and refers to the highest tested dose of a substance that has been reported to have no harmful (adverse) effects on a test population.  The NOAEC (i.e., "No-Observed-Adverse-Effect-Concentration") is the highest test concentration at which none of the observed results were statistically different from the control.  

5.0	Terrestrial Species Hazard Assessment 

Avian
An acute oral toxicity study using the technical grade of the active ingredient (TGAI) is required to establish the toxicity of AVG to birds. The preferred test species is either mallard duck (Anas platyrhynchos; a waterfowl) or Bobwhite quail (Colinus virginianus; an upland game bird). Through two acute studies on Bobwhite quail, AVG has been shown to be moderately toxic to avian species with LD50 = 121 mg/kg and LC50 = 230 ppm. A chronic study in Bobwhite quail showed reproductive effects in the 125ppm treatments groups (decline in offspring weight), thus setting the NOAEC at 50 ppm (Table 5.0).

Mammalian
The Agency relied on the Acute Oral Rat study (OPPTS 870.1100) and the Two-Generation Rat Reproduction study (OPPTS 870.3800) as surrogates for predicting the potential for mammalian hazard from exposure to AVG (Table 5.1). The Acute Oral LD50 for rats was calculated at > 6,480 mg/kg suggesting that this compound is practically non toxic to mammals on an acute basis (MRID 42672203). The Reproductive Toxicity study, however, produced a NOAEL = 2.5 mg/kg/day and a LOAEL = 4.0 mg/kg/day for F1 offspring and showed decreased viability of pups and retarded growth of F1 and F2 pups. Test diet was administered continuously for at least 70 days prior to F0 mating and during mating, gestation, and lactation until the litters were weaned. The F1 pups were weaned onto the same diet received by their parents (MRID 44946501). 

Non Target Insects
AVG produced LD50 > 100ug/bee for oral and contact honey bee (Apis mellifera L.) studies, indicating that AVG is practically non-toxic to honey bees (Table 5.2). 

Plants
In a single pre-emergent application of 124 g a.i./ha, AVG application to corn, onion, ryegrass, wheat, bean, cabbage, lettuce, radish, tomato, and soybean seeds resulted in no adverse effects on seedling emergence, growth, weight or condition. In addition, no phytotoxicity was observed in any of the plants (NOEC = 124 g a.i./ha, and EC25 > 124 g a.i./ha; MRIDs 45359611 and 45359612).

Table 5.0 Summary of Avian Toxicity for AVG
Test Species 
                                       
                                     % ai 
                                       
                                   Endpoint 
Toxicity Category 
MRID No. Author/Year 
Study Classification 
Acute Toxicity
Bobwhite quail
(Colinus virginianus)
                                     80.6
LD50 = 121mg ai/kg
Moderately toxic
43183610 Campbell et al.,/1993
Acceptable
Bobwhite quail
(Colinus virginianus)
                                     80.6
LC50 = 230 ppm
Moderately toxic
43183611 Campbell and Beavers, 1993.
Acceptable
Chronic Toxicity
Bobwhite quail
(Colinus virginianus)
                                      88
No reproductive effects at 20 or 50 ppm. Effects observed at 125ppm were a decline in offspring body weight. 
NOAEC = 50 ppm.
45796504
Frey et al./2002
Acceptable

Table 5.1 Summary of Mammalian Toxicity for AVG
Study 
                                       
                                 Test Species
                                       
                                   Endpoint 
Toxicity Category 
MRID No. Author/Year 
Study Classification 
Acute Toxicity
Acute Oral (OPPTS 870.1100)
                                      Rat
LD50 = 6,480 mg ai/kg 
Practically non toxic
42672203
Acceptable
Chronic Toxicity
Two-Generation Reproduction study
(OPPTS 870.3800)
                                      Rat
NOAEL = 2.5 mg/kg/day and LOAEL = 4.0 mg/kg/day for F1 offspring (decreased viability of pups and retarded growth of F1 and F2 pups).
44946501

Acceptable

Table 5.2 Toxicity of AVG to Honey Bee
Test Species 
                                     % ai
                                       
                                   Endpoint 
Toxicity Category 
MRID No. Author/Year 
Study Classification 
Honey bee
(Apis mellifera L.)
                                      82
48 hour oral and contact studies: LD50>100ug/bee for each study
Practically non-toxic
45402204 Wainwright/2001

Acceptable




6.0       Aquatic Hazard Assessment

Fish
The acute freshwater fish study available for AVG concludes that this biochemical is practically non-toxic (LC50 > 139 mg/L) to coldwater fish (Table 6.0). There are no chronic fish studies available for AVG. 

Aquatic Invertebrates
Acute toxicity studies on Daphnia magna are equivocal, with 48 hr EC50 = 1.81 - 137 mg/L. This spans the range of moderate to practically non-toxic to freshwater invertebrates on an acute basis (Table 6.1). There are no chronic toxicity studies available for AVG in freshwater invertebrates. 

There are no studies on AVG involving estuarine or marine invertebrates.

Table 6.0 Freshwater Fish Toxicity Studies for AVG
Species
                                     % ai
Results 
MRID
Classification
Freshwater Species
Rainbow trout (Oncorhynchus mykiss) 


                                     80.6

96hr LC50> 139mg/L


43183612

Acceptable

Table 6.1 Freshwater Invertebrates Toxicity Studies for AVG
Species
% ai
Effect
MRID
Classification
Acute Toxicity
Daphnia magna
                                     80.6
48 hr. EC50 > 135 mg/L
 
43183613
Acceptable
Daphnia magna
                                      15
48hr. EC50 = 11.9 mg/L (1.81 mg ai/L)

45402301
Acceptable


7.0	Risk Characterization

Risk characterization is the integration of exposure and ecological effects characterization to determine the potential ecological risk from registered uses of AVI glycine hydrochloride (AVG) and the likelihood of direct and/or indirect effects to non-target aquatic and terrestrial species.  For the screening-level portion of this assessment, the deterministic risk quotient method (RQ) is used to provide a metric of potential risks.  The RQ is a comparison of exposure estimates to toxicity endpoints; estimated or actual exposure concentrations are divided by acute and chronic toxicity values.  The resulting unit less RQs is compared to the Agency's levels of concern (LOCs) (Table 7.0).  LOCs are used to indicate when the use of a pesticide, as directed on the label, has the potential to cause adverse effects on non-target organisms.

Table 7.0 Agency Levels of Concern (LOC).
                                     Risk
                                  Description
                                      RQ
                                     Taxa
Acute
Potential for acute risk to non-target organisms which may warrant regulatory action in addition to restricted use classification
acute RQ > 0.5
aquatic animals, mammals, birds
Acute Restricted Use
Potential for acute risk to non-target organisms, but may be mitigated through restricted use classification
acute RQ > 0.1
aquatic animals


acute RQ > 0.2
mammals and birds
Acute Listed Species
Listed species may be potentially affected by use
acute RQ > 0.05
aquatic animals and terrestrial invertebrates


acute RQ > 0.1
mammals and birds
Chronic
Potential for chronic risk may warrant regulatory action, listed species may potentially be affected through chronic exposure
chronic RQ > 1
all animals
Non-Listed and Listed Plant 
Potential for effects in non-listed and listed plants
RQ > 1
all plants

Aquatic Risk Assessment
Risk quotients (RQ) were calculated as an exposure/hazard ratio in order to determine the potential ecological risk from AVG exposure to non-target aquatic species. The Agency has calculated the potential for exposure through GENEEC (Generic Estimated Environmental Concentration Model Version 2.0; Aug. 2001) a Tier I computer program,  that uses  soil/water partition coefficient and degradation kinetic data to estimate runoff from a ten hectare field into a one hectare by two meter deep "standard" pond. This first tier is designed as a coarse screen and estimates conservative pesticide concentrations in surface water from a few basic chemical parameters and pesticide label use and application information. Tier I is used to screen chemicals to determine which ones potentially pose sufficient risk to warrant higher level modeling. GENEEC is a program to calculate acute as well as longer-term estimated environmental concentration (EEC) values. It considers reduction in dissolved pesticide concentration due to adsorption of pesticide to soil or sediment, incorporation, degradation in soil before wash off to a water body, direct deposition of spray drift into the water body, and degradation of the pesticide within the water body (Appendix B).  The acute risk to freshwater fish and invertebrates form AVG exposure is not expected to be an environmental concern (RQ = 0.00), all RQ values are below the Agency LOC values (Table 8.0).

Table 8.0 GENEEC (Version 2.0) EEC Values (ppb) for AVG Application to Peaches (0.11 lbs. ai/A, One Applications/Year) and Acute RQ Values Calculated for Fish and Aquatic Invertebrates 
Species
Toxicity End Point
Peak EEC (ppb)
RQ
(acute)
4 Day EEC 
(ppb)
RQ
(acute)
Acute Exposure LOC = 0.05  -  0.5

Rainbow trout (Oncorhynchus mykiss) 

96 hr LC50 > 139 mg/L

1.18

0.00

1.10

0.00
Daphnia magna
48 hr EC50 > 135 mg/L
1.18
0.00
1.10
0.00




Terrestrial Risk Assessment
The Agency assessed the potential risk to terrestrial species from AVG exposure by evaluating actual field residues of ABG-3168 (S-trans-2-amino-4-(2-aminoethoxy)-3-butenoic acid hydrochloride) on peaches (Table 8.1). This compound is similar to AVG and also acts as a fruit ripening inhibitor with a treatment rate of 50 g active ingredient per acre (0.11 lbs ai) administered through a spray application to peach trees. Residues were collected at the day of application, as well as, 3, 5, 7, 9, 11, and 14 days post application. Based on avian and mammalian toxicity data and one application per year (ABG-3168; 15% ai) the Agency calculated potential acute and chronic RQs to these species.

Table 8.1 Residues Collected for ABG-3168 (15% ai)
Date Sampled
Days Post Application
Residues Found for Parent (ppm)
Residues for 15% ai
(ppm)
6/02/99
0
0.29  -  0.39
0.04  -  0.06
6/05/99
3
0.21  -  0.31
0.03  -  0.05
6/07/99
5
0.13  -  0.14
0.02  -  0.02
6/09/99
7
0.10  -  0.09
0.01  -  0.01
6/11/99
9
0.06  -  0.06
0.01  -  0.01
6/13/99
11
0.03  -  0.04
0.00  -  0.01
6/16/99
14
< Level of Detection
< Level of Detection

The acute and chronic risk to terrestrial species form AVG exposure is not expected to be an environmental concern (RQ = 0.00), all RQ values are below the Agency LOC values (Table 8.2)

Table 8.2 Acute and Chronic RQ Values Calculated for Avian and Mammalian Exposure to One Application of ABG-3168 (15% ai)
Species
Toxicity End Point
Peak Residue
(ppm)
RQ
(acute)
3 Day Residue 
(ppm)
RQ
(acute)
7 Day Residues
(ppm)
RQ
(chronic)
Acute Avian Exposure LOC = 0.1  -  0.5
Bobwhite quail
(Colinus virginianus)
LD50 = 121mg ai/kg

0.06

0.00

0.05

0.00


Chronic Avian Exposure LOC = 1.0
Bobwhite quail
(Colinus virginianus
NOAEC = 50 ppm.





0.01

0.00
Acute Mammalian Exposure LOC = 0.1  -  0.5



Rat

LD50 = 6,480 mg ai/kg

0.06

0.00

0.05

0.00


Chronic Mammalian Exposure LOC = 1.0


Rat
LOAEL = 4.0 mg ai/kg/day




0.01
0.00

Risk to Terrestrial Endangered Species
The Agency used surrogate toxicity information on the rat and Bobwhite quail and actual field residues (ABG-3168 applied to peaches) order to assess possible risk to terrestrial species from exposure to AVG.  RQ values for acute avian and mammalian were at 0.00. These low RQ values combined with information that AVG degrades rapidly in the environment (about 1.7  -  4.7 days) shows that residues will not exceed the Agency's LOC =0.1 for avian and mammalian endangered species concerns.  

The Agency has also calculated the potential risk to endangered/threatened terrestrial species by relying on the Individual Effects Model Version 1.1 (Table 8.3) that predicts the chance of individual effect at about 1 in 1,610,000,000,000,000. Based on the avian and mammalian toxicity data that has been submitted on the active ingredients, there should not be toxic risk to endangered/ threatened species from exposure to the end use product. AVG should present a No Effect to terrestrial threatened or endangered species, if used in accordance with approved labeling.

Table 8.3  Individual Effects Chance Model for Predicting the Chance of Individual Effects of AVG to Terrestrial Endangered Species




Risk to Aquatic Endangered Species
Acute risk to endangered/threatened freshwater fish and invertebrates from AVG (0.11 lbs ai/A) exposure is not expected The Agency has also calculated the potential risk to endangered/threatened aquatic species by relying on the Individual Effects Model Version 1.1 (Table 8.4) that predicts the chance of individual effect at about 1 in 418,000,000. Based on the fish and aquatic invertebrate toxicity data on the active ingredients, there should not be toxic risk to endangered/ threatened species from exposure to the end use product. AVG should present a No Effect to aquatic threatened or endangered species, if used in accordance with approved labeling.












 Table 8.4 Individual Effect Chance Model for Predicting Effects to Aquatic Endangered Species after exposure to AVG

Conclusions
The Agency assessed the potential risk of AVG (0.11 lbs ai/A) to non target organisms by using the Tier I aquatic model, GENEEC, for evaluating exposure and to aquatic organisms and actual field residues for terrestrial species. All calculated RQ values were less than the Agency LOC (aquatic LOC = 0.05  -  0.5; and terrestrial LOC = 0.1  -  1.0). If used according to label instructions, exposure to this compound will not have a toxic impact on non target species. The Agency also has concluded a No Effect for endangered/ threatened species based on the risk assessment for non target aquatic and terrestrial species, the persistence of AVG in the environment (1.7 - 4.7 days), and the application rate (50 grams/A; 0.11 lbs ai/A).

Appendix A. The Risk Quotient Method and Levels of Concern

	Risk characterization integrates the results of the exposure and ecotoxicity data to evaluate the likelihood of adverse ecological effects.  The means of this integration is called the quotient method.  Risk quotients (RQs) are calculated by dividing exposure estimates by acute and chronic ecotoxicity values.  

	RQ = EXPOSURE/TOXICITY

	RQs are then compared to OPP's levels of concern (LOCs).  These LOCs are used by OPP to analyze potential risk to nontarget organisms and the need to consider regulatory action.  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 risks - regulatory action may be warranted in addition to restricted use classification, (2) acute restricted use - the potential for acute risk is high, but may be mitigated through restricted use classification, (3) acute endangered species - endangered species may be adversely affected, 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  insects, or chronic risk from granular/bait formulations to birds or mammals.

	The ecotoxicity test values (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 or LOAEC (birds, fish, and aquatic invertebrates) and (2) NOAEL or NOAEC (birds, fish and aquatic invertebrates).  For birds, mammals, fish and aquatic invertebrates the NOAEL or NOAEC generally is used as the ecotoxicity test value in assessing chronic effects, although other values may be used when justified.  Risk presumptions and the corresponding RQs and LOCs, are tabulated below.






	
Table 1.  Risk presumptions for terrestrial animals  based on risk quotients (RQ) and levels of concern (LOC).
                               Risk Presumption
                                      RQ
                                      LOC
                                     Birds
Acute Risk 
EEC[1]/LC50 or LD50/ft[2] or LD50/day[3]
                                      0.5
Acute Restricted Use
EEC/LC50 or LD50/ft[2] or LD50/day (or LD50 < 50 mg/kg)
                                      0.2
Acute Endangered Species
EEC/LC50 or LD50/ft[2] or LD50/day 
                                      0.1
Chronic Risk
EEC/NOAEC
                                       1
                                 Wild Mammals
Acute Risk 
EEC/LC50 or LD50/ft[2] or LD50/day	
                                      0.5
Acute Restricted Use
EEC/LC50 or LD50/ft[2] or LD50/day (or LD50 < 50 mg/kg)
                                      0.2
Acute Endangered Species
EEC/LC50 or LD50/ft[2] or LD50/day	
                                      0.1
Chronic Risk 
EEC/NOAEC
                                       1
 [1]  abbreviation for Estimated Environmental Concentration (ppm) on avian/mammalian food items
 [2]  mg/ft[2]
 [3]  mg of toxicant consumed/day
  LD50 * wt. of bird
  LD50 * wt. of bird  

Table 2.  Risk presumptions for aquatic animals based on risk quotients (RQ) and levels of concern (LOC).
                               Risk Presumption
                                      RQ 
                                      LOC
Acute Risk
EEC[1]/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
 [1]  EEC = (ppm or ppb) in water

Table 3.  Risk presumptions for plants based on risk quotients (RQ) and levels of concern (LOC).
                               Risk Presumption
                                      RQ
                                      LOC
                     Terrestrial and Semi-Aquatic Plants 
Acute Risk
EEC[1]/EC25
                                       1
Acute Endangered Species
EEC/EC05 or NOAEC
                                       1
		Aquatic Plants
Acute Risk
EEC[2]/EC50
                                       1
Acute Endangered Species
EEC/EC05 or NOAEC 
                                       1
[1]  EEC = lbs ai/A 
[2]  EEC = (ppb/ppm) in water 











Appendix B. GENEEC Run for AVG Application to Peaches


------------------------------------------------------------------------------------------------------------------
   RATE (#/AC)   No.APPS &      SOIL    SOLUBIL   APPL TYPE NO-SPRAY INCORP
    ONE(MULT)    INTERVAL      Koc      (PPM )      (%DRIFT)      (FT)             (IN)
  -----------------------------------------------------------------------------------------------------------------
  .110(   .110)                 1   1        4028.0     4121.0     ORCHAR      (  9.7)         .0    .0


  FIELD AND STANDARD POND HALFLIFE VALUES (DAYS)
  ------------------------------------------------------------------------------------------------------------------
  METABOLIC   DAYS UNTIL           HYDROLYSIS   PHOTOLYSIS   METABOLIC  COMBINED
   (FIELD)              RAIN/RUNOFF         (POND)             (POND-EFF)    (POND)            (POND)
  ---------------------------------------------------------------------------------------------------------------------------
     4.70                     0                                     N/A                 .70- 86.80           9.00                    8.15


  GENERIC EECs (IN MICROGRAMS/LITER (PPB)   Version 2.0 Aug 1, 2001
  --------------------------------------------------------------------
      PEAK      MAX 4 DAY     MAX 21 DAY    MAX 60 DAY    MAX 90 DAY
      GEEC      AVG GEEC       AVG GEEC      AVG GEEC      AVG GEEC
  ---------------------------------------------------------------------------------------------------------------------------
       1.18              1.10                     .72                    .35                           .24





