p-2-ynyloxy-acetamide (mandipropamid; NOA446510; radiochemical purity
98.9%)

was stable in pH 5, 7, and 9 sterile aqueous buffered solutions at 25
ºC over the course of a 32-day incubation period. Overall recoveries of
[14C]residues averaged 100.0 ( 3.4% of the applied (range 94.4-104.9%)
from the pH 5 buffer solution, 98.1 ( 0.8% of the applied (range
97.2-99.4%) from the pH 7 buffer solution, and 100.1 ( 1.1% (range
99.1-101.6%) from the pH 9 buffer solution.  There was no pattern of
loss of material over time from any of the buffer solutions.
[14C]Mandipropamid averaged 97.8-102.5% of the applied in the pH 5
solutions, 97.5-99.0% in the pH 7 solutions, and 99.3-101.6% in the pH 9
solutions.  No major or minor transformation products were detected;
mandipropamid was the only compound detected and comprised 100% of the
recovered at all sampling intervals.  Volatiles were not measured. This
study is classified as Acceptable.

161-2. Aqueous Photolysis

MRID 46800009(Acceptable)

[chlorophenyl-U-14C]-labeled
2-(4-chlorophenyl)-N-[2-(3-methoxy-4-prop-2-ynyloxy-phenyl)-ethyl]-2-pro
p-2-ynyloxy-acetamide (mandipropamid; NOA446510; radiochemical purity
(98%), at a nominal concentration of 1 (g a.i./mL, at 25(C in sterilized
pond  water from the UK (pH 7.02), degraded with a reviewer-calculated
first-order linear half-life of 15.2 hours based on the continuous
irradiation of  44.79 W/m2 (300-400 nm); 1 hour of artificial light was
equivalent to 0.65 hours of summer sunlight (68.98 W/m2; 300-400 nm) at
40(N latitude.  Mandipropamid was stable in the dark controls during the
7 days of incubation. In the irradiated buffer solutions, no major
transformation products were identified.  Polar compounds totaled a
maximum average of 36.7% of the applied at 168 hours posttreatment
(individual samples 24.7% and 48.7%).  Two minor nonpolar transformation
products were identified.  CGA380778 and NOA458422 averaged maximums of
3.7% and 3.9% of the applied, respectively.  The study is Acceptable.

MRID 46800010(Acceptable)

[methoxyphenyl-U-14C]-labeled
2-(4-chlorophenyl)-N-[2-(3-methoxy-4-prop-2-ynyloxy-phenyl)-ethyl]-2-pro
p-2-ynyloxy-acetamide (mandipropamid; NOA446510; radiochemical purity
(95.7%), at a nominal concentration of 1 (g a.i./mL, at 25(C in
sterilized pond water from the UK (pH 7.02). degraded with a
reviewer-calculated first-order linear half-life of 15.2 hours based on
the continuous irradiation of  22.4 hours, continuously irradiated using
a filtered xenon lamp (300- 800 nm) for 166.4 hours (ca. 7 days).
Mandipropamid was stable in the dark control during the 3 days of
incubation. No major transformation products were isolated and no minor
transformation products were identified in either the irradiated samples
or dark controls.  In the irradiated solutions only, unidentified polar
compounds totaled a maximum of 25.0% of the applied at 72.2 hours
posttreatment.  This fraction consisted of at least 14 separate
components with no single component (8.4% of the applied.  At 72 hours
posttreatment, 14CO2 averaged 6.0% of the applied in the irradiated
samples and were not detected in the dark controls. Based on the study
results, mandipropamid photodegrades to numerous minor polar compounds
and CO2. The study is Acceptable.

MRID 46800011,12(supplemental)

[chlorophenyl-U-14C]-labeled
2-(4-chloro-phenyl)-N-[2-(3-methoxy-4-prop-2-ynyloxy-phenyl)-ethyl]-2-pr
op-2-ynyloxy-acetamide (mandipropamid; NOA446510) radiochemical purity
98.1%), at a nominal concentration of 1.0 mg a.i./L at 25(C sterile pH 7
buffer (0.01M phosphate), continuously irradiated using a filtered xenon
lamp (290- 750 nm) for 15 days, dissipated with a half-life of 6.6 days
(158.4 hours), based on the continuous irradiation of 30.74 W/m2
(300-400 nm); 1 hour of artificial light was equivalent to 0.45 hours of
summer sunlight (68.98 W/m2; 300-400 nm) at 40(N latitude.
[14C]Mandipropamid was stable in the dark controls. No major
transformation products were isolated from either the irradiated samples
or dark controls.  Based on the study results, mandipropamid
photodegrades to numerous minor transformation products and CO2. This
study is supplemental and upgradeable upon submission of the detailed
results (concentration of parent) or the square vessel experiment.

MRID 46800013,14(Acceptable)

[methoxyphenyl-U-14C]-labeled
2-(4-chloro-phenyl)-N-[2-(3-methoxy-4-prop-2-ynyloxy-phenyl)-ethyl]-2-pr
op-2-ynyloxy-acetamide (mandipropamid; NOA446510; radiochemical purity
(99%), at a nominal concentration of 1.0 mg a.i./L, at 25(C sterile pH 7
buffer (0.01M phosphate) continuously irradiated using a filtered xenon
lamp (300- 800 nm) for 336 hours, dissipated with a half-life of 26.4
hours, based on the continuous irradiation of 29.93 W/m2 (300-400 nm); 1
hour of artificial light was equivalent to 93 W/m2 (300-400 nm); 1 hour
of artificial light was equivalent to 0.43 hours of summer sunlight
(68.98 W/m2; 300-400 nm) at 40(N latitude.  No major transformation
products were isolated from either the irradiated samples or dark
controls.  No minor transformation products were identified in the
irradiated samples and none were isolated from the dark controls.  In
the irradiated buffer solution, 16 minor nonpolar transformation
products, none averaging (5% of the applied, and at least 10 minor polar
transformation products were isolated.

161-3. Soil Photolysis

MRID 46800015 (Acceptable)

[14C-chlorophenyl]-labeled
2-(4-chlorophenyl)-N-[2-(3-methoxy-4-prop-2-ynyloxy-phenyl)-ethyl]-2-pro
p-2-ynyloxy-acetamide (mandipropamid; NOA446510; radiochemical purity
(98.0%) on loam soil (pH 7.1, organic matter 3.5%) from Switzerland
under continuous irradiation for 15 days at 20 ( 2(C, degraded with a
half-life of 16.39 days and 20.33 days in the irradiated samples for the
dry soil and moist soil experiments, respectively. The intensity of the
Xenon arc lamp was 53.14-53.98 W/m2/nm, which was reported to be similar
to natural summer sunlight at latitude 30-50(N.  Mandipropamid degrades
to CGA380778, NOA458442 and SYN521195.  CGA380778 degrades to NOA459119
and CGA380775.  NOA458442 degrades to CGA380775 and SYN505503.
SYN521195 degrades to SYN505503.  CGA380775 degrades to NOA459119.  The
transformation products are ultimately degraded to non-extractable
residues and carbon dioxide. This study is acceptable.

162-1. Aerobic Soil Metabolism

MRID 46800020,21 (Acceptable)

[14C-chlorophenyl]-labeled
2-(4-chlorophenyl)-N-[2-(3-methoxy-4-prop-2-ynyloxy-phenyl)-ethyl]-2-pro
p-2-ynyloxy-acetamide (mandipropamid; NOA446510; radiochemical purity
99.28%) was applied at the rate of 0.23 mg a.i./kg soil, equivalent to
150 g a.i./ha (nominal)

to a sandy loam soil (pH 6.6, organic carbon 0.5%) from Visalia,
California for 371 days under aerobic conditions in darkness at 25 ( 1(C
and 75% field moisture capacity at 1/3 bar. The linear and nonlinear
half-lives of [14C]mandipropamid in aerobic soil were 72.2 and 34.3
days, respectively.  No major transformation products were identified.
Four minor transformation products identified: CGA380778
(benzeneacetamide,
4-chloro-alpha-hydroxy-N-[2-[3-methoxy-4-(2-propynyloxy)phenyl]ethyl])
was a maximum of 4.25% at 30 days, CGA380775 (benzeneacetamide,
4-chloro-alpha-hydroxy-N-[2-(4-hydroxy-3-methoxyphenyl)ethyl]) was a
maximum of 0.51% at 30 days, SYN500003 was a maximum of 0.27% at 7 days,
and NOA458422 was a maximum 0.18% at study termination.

A supplementary study at a high dose was conducted in order to identify
mandipropamid and transformation products.  Mandipropamid was applied to
soil at 1.35 mg a.i./ kg soil.  The concentration of mandipropamid
decreased from 97.25% of the applied at day 0 to 48.74% at 59 days and
was 6.69% at study termination.  The first-order linear and nonlinear
half-life values were 100.5 and 59.2 days, respectively, in the sandy
loam soil.  The major transformation product was volatilized 14CO2
totaling 43.1% of the applied.  Four minor transformation products were
identified as CGA380778, CGA380775, SYN500003 and NOA458422.

A second supplementary study was performed to determine the microbial
viability of the soil by monitoring for carbon dioxide efflux with a
Micro-Oxymax Biomass Analyzer for ca. 18 hours.  The biomass of the soil
samples after incubation for 0, 182 and 371 days was 124.07, 62.32 and
44.43 mg C/kg soil, respectively. This study is acceptable.

MRID 46800022 (Supplemental)

[methoxyphenyl-U-14C]-labeled
2-(4-chlorophenyl)-N-[2-(3-methoxy-4-prop-2-ynyloxy-phenyl)-ethyl]-2-pro
p-2-ynyloxy-acetamide (mandipropamid, NOA 446510; radiochemical purity
98.9%} was studied in a silt loam soil (pH 7.2, organic carbon 2.14%)
from Switzerland for 120 days under aerobic conditions in dark at 20.3 (
0.3(C and 40% of water holding capacity at pF 1.  [14C]Mandipropamid was
applied at the rate of 0.40 mg a.i./kg soil, which is  equivalent to
0.30 kg a.i./ha.  Based on nonlinear analysis and using individual
sample data, the half-life was determined to be 19.6 days.  The
first-order linear half-life was 26.1 days.

No major transformation products were isolated.  The only minor
transformation product that was identified was CGA380778 which averaged
a maximum of 2.9% of the applied.  Unidentified “Minor metabolites”
(up to 13 compounds) totaled a maximum of 2.4%, and “remainder”
(unresolved radioactivity in HPLC and Soxhlet extracts) was observed at
a maximum of 8.7%.  Extractable [14C] residues decreased from 96.79% of
the applied at time 0 to 9.07% at 120 days, while nonextractable
[14C]residues increased to 45.45% at 120 days. At 120 days
posttreatment, 14CO2 and organic volatiles accounted for 37.06% and
0.01% of the applied, respectively. This study is classified as
supplemental and upgradeable upon submission of additional information
related to classification of soils used in this study, in accordance to
FAO Soil Classification (i.e. Soil Units) or equivalent U.S. Soil
Taxonomy.

MRID 46800023 (Supplemental)

The biotransformation of [14C-methoxyphenyl]-labeled
2-(4-chloro-phenyl)-2-hydroxy-N-[2-(3-methoxy-4-prop-2-ynyloxy-phenyl)-e
thyl]-acetamide (CGA380778; radiochemical purity 97.9%) was studied in a
silt loam soil (pH 7.35, organic carbon 2.2%) from Switzerland and a
sandy clay loam soil (pH 5.88, organic carbon 2.7%) from the United
Kingdom for 28 days and a sandy loam soil (pH 6.0, organic carbon 0.5%)
from the United States for 120 days under aerobic conditions in darkness
at 19.3 ( 0.5(C and soil moisture of pF2.   [14C]CGA380778 was applied
at a rate of 0.09 mg a.i./kg, equivalent to 9 g a.i./ha (nominal).
CGA380778 dissipated more slowly in the sandy loam soil compared to the
silt loam and sandy clay loam soils.  The linear and nonlinear
half-lives of CGA380778 were 6.4 and 3.5 days in the silt loam soil, 6.9
and 3.1 days in the sandy clay loam soil and 57.8 and 41.5 days in the
sandy loam soil, respectively. One major transformation product was
volatilized 14CO2 (identification confirmed) totaling means of 51.0%,
50.6% and 31.5% of the applied for the silt loam, sandy clay loam and
sandy loam soils, respectively, at study termination; volatile
[14C]organic compounds were not detected ((0.2%) for all three soils at
any sampling interval.  No minor transformation products were
identified.

This study is classified as supplemental and upgradeable upon submission
additional information related to classification of soils used in this
study, in accordance to FAO Soil Classification (i.e. Soil Units) or
equivalent U.S. Soil Taxonomy.

MRID 46800024,25 (Supplemental)

The biotransformation of [14C-methoxyphenyl]-labeled
2-(4-chlorophenyl)-N-[2-(3-methoxy-4-prop-2-ynyloxy-phenyl)-ethyl]-2-pro
p-2-ynyloxy-acetamide (mandipropamid; NOA446510; radiochemical purity
(97%) was studied in a sandy loam soil (pH 7.3, organic carbon 2.3%)
from Switzerland for 119 days under aerobic conditions in darkness at 20
( 2(C and 75% of pF2 moisture.  Mandipropamid was applied at the rate of
0.2 mg a.i./kg soil and 1.0 mg a.i./kg soil (nominal).  At the 0.2 mg
a.i./kg application rate, the linear and nonlinear half-lives of
mandipropamid were 77.9 and 77.0 days, respectively.  Two minor
transformation products, CGA380778 and SYN536638 (unknown 1) formed at
maximums of 1.4% (28 and 119 days) and 2.4% (91 days) of the applied,
respectively.  One transformation product, NOA458422, was detected by
LC/MS/MS, but was below the limit of detection for HPLC.  At study
termination volatilized 14CO2 totaled 21.8% of the applied.

At the 1.0 mg a.i./kg application rate, the linear and nonlinear
half-lives of mandipropamid were 103.5 days.  Two minor transformation
products, CGA380778 and SYN536638 (unknown 1) formed at maximums of 1.7%
(7 days) and 3.1% (119 days) of the applied, respectively.  Total
extractable [14C]residues decreased from an average of 94.4% of the
applied at day 0 to 49.2% at study termination, while nonextractable
[14C]residues increased from 1.3% of the applied at day 0 to 27.1% at
study termination.  At study termination, volatilized 14CO2 totaled
19.7% of the applied.

Mandipropamid is ultimately degraded into carbon dioxide and
unextractable residues.

Two supplementary studies were performed with soil samples treated with
0.2 mg a.i./kg mandipropamid maintained at low moisture (30% of pF2
moisture) and at low temperature (10(C) for 119 days.  Mandipropamid
degraded more slowly in the supplementary experiments.  In the low
moisture study, the concentration of mandipropamid decreased from an
average of 92.6% of the applied at day 0 to 53.7% at study termination.
The calculated DT50 and DT90 were 149.5 and 497.2 days, respectively,
based on both simple first-order regression, and first-order
multi-compartment regression. The same transformation products,
CGA380778 and SYN536638 (unknown 1), were detected in each study at
(1.7% of the applied.

This study is classified as supplemental and upgradeable upon the
submission of additional information related to classification of soils
used in this study, in accordance to FAO Soil Classification (i.e. Soil
Units) or equivalent U.S. Soil Taxonomy.

MRID 46800027 (Supplemental)

The biotransformation of [chlorophenyl-U-14C]-labeled
2-(4-Chlorophenyl)-N-[2-(3-methoxy-4-prop-2-ynyloxy-phenyl)-ethyl]-2-pro
p-2-ynyloxy-acetamide (mandipropamid, NOA446510, radiochemical purity
100%} was studied in a loam/silt loam soil (pH (KCl) 7.3, organic carbon
1.7%) from Switzerland for 120 days under aerobic conditions in dark at
19.0 ( 0.6(C and soil moisture content of 100% of pF 2.
[14C]Mandipropamid was applied at the rate of 0.40 mg a.i./kg soil,
which is  equivalent to 0.30 kg a.i./ha.  The nonlinear analysis
(SigmaPlot v 9) and using individual sample data, the half-life was
determined to be 26.1 days.  The first-order linear half-life was 32.4
days.  No major transformation products were isolated.  The only minor
transformation product that was identified was CGA380778, which averaged
a maximum of 3.2% of the applied.  Nine minor transformation products
totaled a maximum of 2.4% of the applied and “remainder” (unresolved
radioactivity) was observed at a maximum of 11.4%.  At 120 days
posttreatment, [14C]CO2 and organic volatiles accounted for 36.0% and
0.0% of the applied, respectively.

Based on the study results, mandipropamid degrades into multiple minor
metabolites, including CGA380778, CO2, and tightly bound residues.

This study is classified as as supplemental and upgradeable upon the
submission of additional information related to classification of soils
used in this study, in accordance to FAO Soil Classification (i.e. Soil
Units) or equivalent U.S. Soil Taxonomy.

MRID 46800028 (Supplemental)

The biotransformation of [14-C-chlorophenyl]-labeled
2-(4-chlorophenyl)-N-[2-(3-methoxy-4-prop-2-ynyloxy-phenyl)-ethyl]-2-pro
p-2-ynyloxy-acetamide (mandipropamid; NOA446510; radiochemical purity
(98.7%) was studied in a sandy clay loam soil (pH 6.2, organic carbon
3.5%) from the United Kingdom, a loamy sand soil (pH 6.5, organic carbon
0.8%) from Germany and a loam soil (pH 8.5, organic carbon 1.3%) from
France for 120 days under aerobic conditions in darkness at 20 ( 2(C and
pF2 moisture.  Mandipropamid was applied at the rate of 0.2 mg a.i./kg
soil (nominal).

In sandy clay loam soil, based on first-order linear and nonlinear
regression analysis, mandipropamid degraded with half-life values of
51.3 and 43.9 days, respectively.

In loamy sand soil, based on first-order linear and nonlinear regression
analysis, mandipropamid degraded with half-life values of 83.5 and 80.6
days, respectively.

In loam soil, based on first-order linear and In sandy clay loam soil,
based on first-order linear (Excel 2003) and nonlinear (SigmaPlot v 9)
regression analysis, mandipropamid degraded with half-life values of
51.3 and 43.9 days, respectively (DER Attachment 2).  Observed DT50
value was 21-28 days (Table 9, p. 51).  Using Model Manager v. 1.1, the
study author determined the half-life for mandipropamid using simple
first order and first order multicompartment kinetics as 43.9 and 33.7
days, respectively (p. 26, Table 8, p. 50, Appendix 7, p. 40 and Figure
29-30, pp. 116-117).

In loamy sand soil, based on first-order linear and nonlinear regression
analysis, mandipropamid degraded with half-life values of 83.5 and 80.6
days, respectively.

In loam soil, based on first-order linear and nonlinear regression
analysis, mandipropamid degraded with half-life values of 90.0 and 85.6
days, respectively. In each of the soils, one minor transformation
product was identified as CGA380778.  LC/MS/MS analysis identified low
levels of transformation products not identified by HPLC and 2D-TLC
including: CGA380775, NOA458422 and SYN505503. Mandipropamid is
ultimately degraded into carbon dioxide and bound residues. This study
is classified as as supplemental and upgradeable upon the submission of
additional information related to classification of soils used in this
study, in accordance to FAO Soil Classification (i.e. Soil Units) or
equivalent U.S. Soil Taxonomy.

162-2 Anaerobic Soil Metabolism

MRID 46800027 (Supplemental)

The biotransformation of [chlorophenyl-U-14C]-labeled
2-(4-chlorophenyl)-N-[2-(3-methoxy-4-prop-2-ynyloxy-phenyl)-ethyl]-2-pro
p-2-ynyloxy-acetamide (mandipropamid, NOA446510, radiochemical purity
100%} was studied in flooded loam/silt loam soil (pH (KCl) 7.3, organic
carbon 1.7%) from Switzerland for 120 days under anaerobic conditions in
dark at 19.0 ( 0.6(C.  [14C]Mandipropamid was applied at the rate of
0.40 mg a.i./kg soil, which is  equivalent to 0.30 kg a.i./ha.
Anaerobicity, temperature and other experimental conditions were
reportedly maintained throughout the study.  In the water layer, the
dissolved oxygen and pH levels were 0.01-0.96 mg/L and 6.50-8.77,
respectively.  Redox potentials in the water layer ranged from (148 to
(68 mV; redox potentials in the soil ranged (232 to (72 mV.  The
viability of the soil microflora in soil treated with mandipropamid was
not determined.

Based on first-order linear regression analysis, mandipropamid
dissipated with a half-life of 198.0 days.  Based on nonlinear analysis,
the half-life was 183 days.

No major transformation products were isolated.  The only minor
transformation product that was identified was CGA380778, which averaged
a maximum of 3.9% of the applied.  Nine minor transformation products
totaled a maximum of 4.1% of the applied and “remainder” (unresolved
radioactivity) was observed at a maximum of 9.6%.  At 120 days
postflooding, the nonextractable residues were partitioned into 3.1-6.5%
of the applied as fulvic acids, 1.3-5.6% humic acids and 16.7-25.2%
humin.  At 120 days postflooding, 14CO2 and organic volatiles accounted
for 17.4% and 0.2%, respectively.  Based on the study results,
mandipropamid degrades into multiple minor metabolites, including
CGA380778, CO2, and tightly bound residues. This study is classified as
supplemental and upgradeable upon the submission of additional
information related to classification of soils used in this study, in
accordance to FAO Soil Classification (i.e. Soil Units) or equivalent
U.S. Soil Taxonomy.

162-3 Anaerobic Aquatic Metabolism

MRID 46800033,34 (Unacceptable)

The biotransformation of [methoxyphenyl-U-14C]-labeled
2-(4-chloro-phenyl)-N-[2-(3-methoxy-4-prop-2-ynyloxy-phenyl)-ethyl]-2-pr
op-2-ynyloxy-acetamide (mandipropamid, NOA446510; radiochemical purity
(98.0%) was studied in lake water-silt loam sediment (water pH 8.1-8.25,
dissolved organic carbon 12.1 mg/L; sediment pH 7.2-7.6, organic carbon
5.5%) and lake water-loamy sand sediment (water pH 5.8-5.83, dissolved
organic carbon 1.5 mg/L; sediment pH 4.6-5.3, organic carbon 0.9%)
systems from the United Kingdom for 120 days under anaerobic conditions
in darkness at 20 ( 2(C.  Based on the water volume, [14C]mandipropamid
was applied at a rate of 0.26 mg a.i./L.  For both systems, the
sediment:water ratio used was 1:4 (40 g dry wt. sediment:160 g water).

The test conditions presented in the study appear to have been
maintained throughout the 120-day incubations.  In untreated lake
water-silt loam systems incubated alongside the treated systems,
conditions were moderately reducing to moderately oxidizing in the water
layers and moderately reducing in the sediment with average redox
potentials of (253 ( 79 mV and (124 ( 15 mV, respectively, and water pH
levels of 8.24 ( 0.15.  In untreated lake water-loamy sand systems,
conditions in the water layers and sediment went from moderately
reducing during the initial month posttreatment to moderately oxidizing
from 2 months to study termination with average redox potentials in the
water layer and sediment increasing from (78 ( 14 mV at 6 days
posttreatment to (231 ( 10 mV at 59 days and were (229 ( 7 mV at 119
days; water pH levels averaged 7.51 ( 0.33 over the 120-day incubation.

For both systems, the following four transformation products were
detected:

2-(4-chloro-phenyl)-N-[2-(3-hydroxy-4-prop-2-ynyloxy-phenyl)-ethyl]-2-pr
op-2-ynyloxy-acetamide (SYN521195),

N-[2-(4-allyloxy-3-hydroxy-phenyl)-ethyl]-2-(4-chloro-phenyl)-2-prop-2-y
nyloxy-acetamide (SYN539678),

2-allyloxy-N-[2-(4-allyloxy-3-hydroxy-phenyl)-ethyl]-2-(4-chloro-phenyl)
-acetamide (SYN539679) and

N-[2-(4-allyloxy-3-methoxy-phenyl)-ethyl]-2-(4-chloro-phenyl)-2-prop-2-y
nyloxy-acetamide (SYN536638).

SYN521195 and SYN539678 were major transformation products in the lake
water-silt loam systems, but minor products in the lake water-loamy sand
systems.  SYN539679 and SYN536638 were minor products in both systems.
Dissipation of mandipropamid and formation of products in the total
system occurred at a faster rate in the silt loam systems as compared to
the loamy sand systems.  The faster dissipation rate in the silt loam
systems may have been due to greater microbial activity, with microbial
biomass (as (C/g soil) ca. 5- to 10-fold higher in the silt loam systems
as compared to the loamy sand systems.  14CO2 was a major volatile
product with maximum totals of 40.3% and 36.0% of the applied at study
termination for the lake water-silt loam and lake water-loamy sand
systems, respectively, while no [14C]residues were extracted from the 7-
to 3-day organic volatiles carbon traps. Mandipropamid in the total
system decreased from 96.3% of the applied at day 0 to 58.2% at 21days,
41.3% at 30 days, 9.5% at 62 days, 2.3-2.4% at 83-100 days and was 0.1%
at study termination; 120-day sediment extracts were not analyzed.  In
the water layer, mandipropamid decreased from 93.6% at day 0 to 51.8% at
21 days, 38.7% at 30 days, 9.5% at 62 days, 1.4% at 100 days and was
0.1% at 120 days.  In the sediment, [14C]mandipropamid increased from
2.7% at day 0 to 7.3% at 14 days, then decreased to 2.6% at 30 days and
was (1.1% at 42-100 days.  Observed DT50 values were 21-30 days in the
water layer, sediment and total system.  Calculated linear half-lives
(r2 = 0.4053-0.9473) were 14 days in the water layer and total system
and 13 days in the sediment, while nonlinear half-lives (r2 =
0.9406-0.9861) were 22 days in the water and total system and 12 days in
the sediment.  Maximum levels of the transformation products in the
water, sediment and total system were as follows:  2.8%, 5.6% and 8.5%,
respectively, for SYN521195, 2.1%, 6.4% and 6.4%, respectively, for
SYN539678, and 3.3%, 2.3% and 4.0%, respectively, for
SYN539679/SYN536638.  Unretained [14C]residues were detected at maximums
of 10.4%, 5.5% and 15.5% in the water, sediment and total system,
respectively.  In a supplementary experiment, volatilized 14CO2 (2M KOH)
and volatile [14C]organic compounds (combustion furnace/2M KOH) totaled
23.29% and 8.55% of the applied, respectively, after 40 days of
anaerobic incubation of [methoxyphenyl-U-14C]mandipropamid treated lake
water-silt loam systems.  Based on these results, the study author
proposed that the incomplete material balances in this study were due to
untrapped low molecular weight organic volatiles, such as methane. This
study is classified as unacceptable for the following reasons:

For both systems, material balances were incomplete with up to 46.4% and
40.0% of the applied unaccounted for in the lake water-silt loam and
lake water-loamy sand systems, respectively.

For both systems, all transformation products detected at (10% of the
applied may not have been identified.

162-4 Aerobic Aquatic Metabolism

MRID 46800030,31 (Supplemental)

The biotransformation of [chlorophenyl-U-14C]-labeled
2-(4-chloro-phenyl)-N-[2-(3-methoxy-4-prop-2-ynyloxy-phenyl)-ethyl]-2-pr
op-2-ynyloxy-acetamide (mandipropamid, NOA446510; radiochemical purity
(98.6%) was studied in lake water-silt loam sediment (water pH
7.63-7.84, dissolved organic carbon (2.0 mg/L; sediment pH 7.0-7.2,
organic carbon 5.8%) and lake water-sand sediment (water pH 6.48-6.68,
dissolved organic carbon 9.3 mg/L; sediment pH 4.9-5.3, organic carbon
0.5%) systems from the United Kingdom for 100 days under aerobic
conditions in darkness at 20 ( 2(C.  For both systems, the
sediment:water ratio used was 1:4 (45 g dry wt. sediment:180 g water).
Sediment and water were pre-incubated for 13-15 days, then following
treatment, duplicate vessels per system type were collected after 0, 1,
2, 3, 10, 30, 45, 70 and 100 days of incubation; however, only one of
the two replicates per system type was processed and analyzed at the 2-
and 3-day intervals.  Water layers were separated from the sediment via
aspiration and analyzed directly.  Sediment samples were extracted
either once (0-day sediments) or twice (all remaining sediment samples)
with acetonitrile; resulting extracts were concentrated
(method/conditions not reported.

The test conditions presented in the study appear to have been
maintained throughout the incubations.  In untreated lake water-silt
loam systems incubated alongside the treated systems, conditions were
moderately oxidizing in the water layers and moderately reducing in the
sediment with average redox potentials of (280 ( 25 mV and (112 ( 11 mV,
respectively, and dissolved oxygen and pH levels of 3.3 ( 0.2 mg/L and
7.23 ( 0.74, respectively, in the water.  In untreated lake water-sand
systems, conditions were strongly oxidizing in the water layers and
moderately to strongly oxidizing in the sediment with average redox
potentials of (485 ( 30 mV and (392 ( 22 mV, respectively, and dissolved
oxygen and pH levels of 4.0 ( 0.0 mg/L and 4.92 ( 0.16, respectively, in
the water.

For both systems, the following six transformation products were
detected:

SYN500003 (chemical name not provided),

SYN504851 (chemical name not provided),

SYN539678
(N-[2-(4-allyloxy-3-hydroxy-phenyl)-ethyl]-2-(4-chloro-phenyl)-2-prop-2-
ynyloxy-acetamide),

SYN539679
(2-allyloxy-N-[2-(4-allyloxy-3-hydroxy-phenyl)-ethyl]-2-(4-chloro-phenyl
)-acetamide),

SYN536638
(N-[2-(4-allyloxy-3-methoxy-phenyl)-ethyl]-2-(4-chloro-phenyl)-2-prop-2-
ynyloxy-acetamide) and

SYN521195
(2-(4-chloro-phenyl)-N-[2-(3-hydroxy-4-prop-2-ynyloxy-phenyl)-ethyl]-2-p
rop-2-ynyloxy-acetamide).

SYN504851 was a major transformation product, while SYN500003,
SYN539678, SYN539679, SYN536638 and SYN521195 were minor products.
Dissipation of mandipropamid and formation of products in the total
system occurred at a faster rate in the silt loam systems as compared to
the sand systems.  The faster dissipation rate in the silt loam systems
may have been due to greater microbial activity, with microbial biomass
(as (C/g soil) 10-fold higher in the silt loam systems as compared to
the sand systems.  Additionally, after application of [14C]mandipropamid
to the water layers, [14C]residues readily partitioned from the water
layer to the silt loam sediment, with movement from the water layer to
the sand sediment occurring at a slower rate.

MRID 46800032 (Unacceptable)

The biotransformation of [chlorophenyl-U-14C]- and
[methoxyphenyl-U-14C]-labeled
2-(4-chloro-phenyl)-N-[2-(3-methoxy-4-prop-2-ynyloxy-phenyl)-ethyl]-2-pr
op-2-ynyloxy-acetamide (mandipropamid; NOA446510; radiochemical purities
99.1%) was studied in a simulated pond water-sandy clay loam sediment
(water pH 7.91, total organic carbon 5.6 mg/L; sediment pH 7.2-7.7,
organic carbon 1.9%) system from the United Kingdom for 120 days under
natural, outdoor conditions.  Based on the water volume,
[14C]mandipropamid was applied at a rate of 0.06-0.07 mg a.i./L.  The
sediment:water ratio used was ca. 1:3 (ca. 10-cm sediment layer:30-cm
water layer); the water volume was ca 648 L, but sediment weight/volume
was not reported.

For both systems, conditions were moderately reducing in the water
layers and reducing to strongly reducing in the sediments during the
initial month posttreatment, after which redox potentials were not
measured.  Redox potentials in the water layers decreased from (177.7 to
(199.2 mV at 3 days to (5.6 to 11.9 mV at 17-31 days, while in the
sediment were (160.1 to (324.4 mV at 3-17 days and (84.2 to (80.6 mV at
31 days.

Observed DT50 values for mandipropamid (both labels) were 2-7 days in
the water layer and total system and 7-15 days in the sediment.  In the
water, sediment and total system, calculated linear half-lives (r2 =
0.6742-0.9818) were 4, 39 and 21 days, respectively, with nonlinear
half-lives (r2 = 0.7428-0.8769) of 4, 11 and 7 days, respectively.

SYN504851 was a major transformation product, with SYN521195 a major
product in the chlorophenyl-label treated system and neared 10% of
applied in the methoxyphenyl-label treated system.  SYN539678,
SYN539679, SYN536638 and SYN500003 were minor products.  In the
chlorophenyl-label treated system, SYN521195 was detected at a maximum
mean 10.8% of applied in the sediment and total system at 15 days,
decreasing to 2.5% at study termination, and was only detected at one
interval in the water at 1.1%; while in the methoxyphenyl-label treated
system, SYN521195 was detected only in the sediment at a maximum mean
8.8% (range 7.9-9.6%).  SYN504851 was detected at maximum means of 7.2%
(120 days), 4.5% (71 days) and 11.1% (120 days) in the water, sediment
and total system, respectively.  SYN500003 was detected at maximum means
of 5.4%, 1.7% and 6.4% in the water, sediment and total system,
respectively.  SYN539678, SYN539679 and SYN536638 were detected only in
the sediment (both labels) at maximum means of 5.6-6.9%, 0.6-0.9% and
1.1-1.9%, respectively.  Unidentified [14C]residues
(unassigned/unaccounted for organo-and aqueous-soluble residues) were
detected at maximums of 7.2-7.7%, 2.0-3.3% and 8.7-9.0% of the applied
in the water, sediment and total system, respectively.  Extractable
[14C]residues (both labels) increased from means of 5.6-7.7% of the
applied at 1 hour to maximum means of 24.7-31.8% at 15 days, then
decreased to 6.8-14.9% at 120 days.  Nonextractable chlorophenyl-label
[14C]residues increased from a mean 0.6% at day 0 (1 and 6 hours) to
27.1% at 120 days, while methoxyphenyl-label residues increased from
0.3-0.7% at day 0 to 29.2% at 71 days and were 20.2% at study
termination.  [14C]Residues (both labels) in the plant material
comprised only 1.3-5.0% of the applied. In a supplemental experiment
investigating the distribution depth of residues in the sediment,
[14C]residues were found primarily in the upper 0- to 5-cm sediment
layer; quantitative results were not reported. This study is classified
as unacceptable for the following reasons:

Material balances were incomplete with up to 58.6% and 71.8% of the
applied unaccounted for in the chlorophenyl- and methoxyphenyl-label
treated systems, respectively.

The systems were not maintained at a constant temperature between 18 and
30(C.

The systems were not maintained in continuous darkness.

163-1 Adsorption/Desorption

MRID 46800035 (Supplemental)

The adsorption/desorption characteristics of
[chlorophenyl-U-14C]-labeled
2-(4-chloro-phenyl)-N-[2-(3-hydroxy-4-prop-2-ynyloxy-phenyl)-ethyl]-2-pr
op-2-ynyloxy-acetamide (SYN521195) were studied in a silt loam soil [pH
7.6, organic carbon 2.0%] from Switzerland, a silt loam soil [pH 7.9,
organic carbon 0.8%] from France, and a sandy loam soil [pH 6.0, organic
carbon 0.5%] from the United States, in a batch equilibrium experiment.
The experimental temperature employed during the study was reported to
be maintained at 19.3 ( 0.04(C.  The pH of the test solutions after
adsorption ranged from 6.89-7.33

After 48 hours of equilibration, 23.1-61.1%, 27.9-46.6%, and 17.7-36.4%
of the applied [14C]SYN521195 was adsorbed to the Gartenacker silt loam,
Marsillargues silt loam, and Visalia sandy loam soils, respectively
(reviewer-calculated).  The Freundlich adsorption K values were 31.0,
9.2, and 2.83 for the Gartenacker silt loam, Marsillargues silt loam,
and Visalia sandy loam soils, respectively; corresponding Freundlich Koc
values were 1537, 1145, and 567.  The Freundlich desorption K values
were 161.2, 49.95, and 3.34 for the Gartenacker silt loam, Marsillargues
silt loam, and Visalia sandy loam soils, respectively; corresponding
Freundlich desorption Koc values were 7979, 6244, and 668.  This study
is classified as supplemental and upgradeable upon the submission of
additional information related to classification of soils used in this
study, in accordance to FAO Soil Classification (i.e. Soil Units) or
equivalent U.S. Soil Taxonomy. The study was conducted using three
soils, and only two soil types were represented. Additional study with a
fourth soil is needed fourth soil as required by the Subdivision N,
Chemistry: Environmental Fate, Section 163-1

MRID 46800036 (Supplemental)

The adsorption/desorption characteristics of
[chlorophenyl-U-14C]-labeled SYN539678 were studied in a loam soil [pH
7.1, organic carbon 2.0%] from Switzerland, a loam soil [pH 7.8, organic
carbon 0.58%] from France, and a sandy loam soil [pH 6.0, organic carbon
0.47%] from California, in a batch equilibrium experiment.  The
equilibrating solution used was 0.01M CaCl2 solution with a soil
solution ratio of 1:39 (w:v) for all soils. All samples were prepared in
duplicate.  A desorption phase was not conducted.

After 3 or 24 hours of equilibration, 7.6-8.9%, 15.0-23.2%, and
2.6-15.3% of the applied [14C]SYN539678 was adsorbed to the Gartenacker
loam, Marsillargues loam, and Visalia sandy loam soils, respectively.
The adsorption K values were 10.57, 12.68, and 6.17 for the Gartenacker
loam, Marsillargues loam, and Visalia sandy loam soils, respectively;
corresponding Koc values were 520, 2200, and 1300.  The Freundlich
adsorption K values were 8.77, 11.96, and 9.19 for the Gartenacker loam,
Marsillargues loam, and Visalia sandy loam soils, respectively;
corresponding Freundlich Koc values were 430, 2100, and 2000. This study
is classified as unacceptable because a desorption phase was not
conducted for the degradates.

MRID 46800037 (Supplemental)

The adsorption/desorption characteristics of [phenyl-U-14C]-labeled
(4-chloro-phenyl)-prop-2-ynyloxy-acetic acid (SYN500003) were studied in
a silt loam soil [Gartenacker, pH 7.6, organic carbon 2.0%] from
Switzerland, a silt loam soil [Marsillargues, pH 7.9, organic carbon
0.8%] from France, and a sandy loam soil [Visalia, pH 6.0, organic
carbon 0.5%] from the United States, in a batch equilibrium experiment.
The adsorption phase of the study was carried out by equilibrating
air-dried soil with [14C]SYN500003 at nominal test concentrations of
0.01, 0.05, 0.10, 0.50, and 1.00 mg a.i./kg soil, in the dark at 19.4 (
0.1(C for 48 hours.  The equilibrating solution used was 0.01M CaCl2
solution with a soil solution ratio of 1:1 (w:v) for all soils. The
desorption phase of the study was carried out by replacing the
adsorption solution with an equivalent volume of 0.01M CaCl2 solution
and equilibrating in the dark at 19.4 ( 0.1(C for 24 hours.  A single
desorption step was conducted for all soils. The experimental
temperature employed during the study was reported to be maintained at
19.4 ( 0.1(C.  The pH of the test solutions after adsorption ranged from
7.10-7.75. After desorption, the pH ranged from 6.74-6.85.

After 48 hours of equilibration, 0.0-6.1%, 18.2-27.0%, and 1.4-30.0% of
the applied [14C]SYN500003 was adsorbed to the Gartenacker silt loam,
Marsillargues silt loam, and Visalia sandy loam soils, respectively.
The Freundlich adsorption K values were 0.06, 0.23, and 0.01 for the
Gartenacker silt loam, Marsillargues silt loam, and Visalia sandy loam
soils, respectively; corresponding Freundlich Koc values were 2.92,
19.79, and 2.89.  The adsorption K and Koc values were not reported.
The Freundlich desorption K values were 0.08, 0.38, and 0.04 for the
Gartenacker silt loam, Marsillargues silt loam, and Visalia sandy loam
soils, respectively; corresponding Freundlich desorption Koc values were
3.88, 32.52, and 8.66.  The desorption K and Koc values were not
reported. This study is classified as supplemental and upgradeable upon
the submission of additional information related to classification of
soils used in this study, in accordance to FAO Soil Classification (i.e.
Soil Units) or equivalent U.S. Soil Taxonomy. Additional study with a
fourth soil is needed as required by Subdivision N, Chemistry:
Environmental Fate, Section 163-1.

MRID 46800038, 39 (Supplemental)

The adsorption/desorption characteristics of
[methoxyphenyl-U-14C]-labeled
2-(4-chlorophenyl)-N-[2-(3-methoxy-4-prop-2-ynyloxy-phenyl)-ethyl]-2-pro
p-2-ynyloxy-acetamide (mandipropamid; NOA446510) were studied in a
loam/silt loam soil [pH 7.1, organic carbon 2.6%] and a silt loam soil
[pH 7.2, organic carbon 5.0%], each from Switzerland, a loamy sand soil
[pH 5.1, organic carbon 1.0%] from Germany, and a silty clay loam soil
[pH 7.3, organic carbon 1.2%] from France, in a batch equilibrium
experiment.  The adsorption phase of the study was carried out by
equilibrating air-dried soil with [14C]mandipropamid at nominal test
concentrations of 0.16, 0.81, 1.61, 3.23, and 8.06 mg a.i./kg soil
(loam/silt loam); 0.06, 0.30, 0.60, 1.20, and 3.0 mg a.i./kg soil (loamy
sand); 0.08, 0.40, 0.79, 1.59, and 3.97 mg a.i./kg soil (silty clay
loam); and 0.25, 1.25, 2.5, 5.0, and 12.5 mg a.i./kg soil (silt loam),
in the dark at 20.3 ( 0.3(C for 24 hours.  The equilibrating solution
used was 0.01M CaCl2 solution with a soil solution ratio of 3.1:50 (w:v;
loam/silt loam); 8.3:50 (w:v; loamy sand); 6.3:50 (w:v; silty clay
loam); and 2.0:50 (w:v; silt loam).  The desorption phase of the study
was carried out by replacing the adsorption solution with an equivalent
volume of 0.01M CaCl2 solution and equilibrating in the dark at 20.3 (
0.3(C for 24 hours.  Two desorption steps were performed for each test
soil. The experimental temperature employed during the study was
reported to be maintained at 20.3 ( 0.3(C. The pH of the test solutions
during the study was not reported.  After 24 hours of equilibration,
65.0-93.8%, 77.1-100.8%, 60.8-81.9%, and 69.5-80.6% of the applied
[14C]mandipropamid was adsorbed to the Gartenacker loam/silt loam,
Borstel loamy sand, Marsillargues silty clay loam, and Vetroz silt loam
soils.  The Freundlich adsorption K values were 20.3, 12.9, 12.6, and
53.2 for the Gartenacker loam/silt loam, Borstel loamy sand,
Marsillargues silty clay loam, and Vetroz silt loam soils, respectively;
corresponding Freundlich Koc values were 782, 1294, 1067, and 1064.  The
adsorption K and Koc values were not reported.  Following the second
desorption step, the percent of [14C]mandipropamid desorbed from the
test soils, as percent of the radioactivity adsorbed, was 30.8-46.9% for
the Gartenacker loam/silt loam, 25.4-36.0% for the Borstel loamy sand,
19.5-36.3% for the Marsillargues silty clay loam, and 30.9-38.9% for the
Vetroz silt loam soil.  The Freundlich desorption K values were 32.9,
20.8, 21.7, and 86.8 for the Gartenacker loam/silt loam, Borstel loamy
sand, Marsillargues silty clay loam, and Vetroz silt loam soils,
respectively; corresponding Freundlich desorption Koc values were 1271,
2076, 1836, and 1736.  The desorption K and Koc values were not
reported. This study is classified as supplemental and upgradeable upon
the submission of additional information related to classification of
soils used in this study, in accordance to FAO Soil Classification (i.e.
Soil Units) or equivalent U.S. Soil Taxonomy. Additional study with a
fourth soil is needed as required by Subdivision N, Chemistry:
Environmental Fate, Section 163-1.

MRID 46800040, 41 (Supplemental)The adsorption/desorption
characteristics of [methoxyphenyl-U-14C]-labeled
2-(4-chlorophenyl)-N-[3-methoxy-4-(prop-2-ynyloxy)phenylethyl]-2-(prop-2
-ynyloxy)acetamide (mandipropamid; NOA446510) were studied in a sandy
loam soil [pH 6.6, organic carbon 0.52%] from California, a loamy sand
soil [pH 4.9, organic carbon 0.70%] from Georgia, and a loamy sand soil
[pH 6.7, organic carbon 1.16%] from New York, in a batch equilibrium
experiment.  The adsorption phase of the study was carried out by
equilibrating air-dried soil with [14C]mandipropamid at nominal test
concentrations of 0.05, 0.25, 0.50, 1.00, and 3.00 mg a.i./kg soil
(Sanger sandy loam); 0.05, 0.23, 0.45, 0.90, and 2.70 mg a.i./kg soil
(Chula loamy sand); and 0.07, 0.37, 0.74, 1.47, and 4.41 mg a.i./kg soil
(North Rose loamy sand), in the dark at 19.4 ( 0.2(C for 24 hours.  The
equilibrating solution used was 0.01M CaCl2 solution with a soil
solution ratio of 10.0:50 (w:v; Sanger sandy loam); 11.1:50 (w:v; Chula
loamy sand); and 6.8:50 (w:v; North Rose loamy sand).  The experimental
temperature employed during the study was reported to be maintained at
19.4 ( 0.2(C; supporting data were not provided.  The pH of the test
solutions after adsorption ranged from 5.01 to 7.08.  The pH of the test
solutions ranged from 6.16 to 7.03 at the first desorption step (one
desorption step for all test concentrations except high-dose), 6.14 to
7.03 during the second desorption step (high dose only), and from 6.01
to 7.08 during the third desorption step (high dose only).  After 24
hours of equilibration, 47.2-71.0%, 46.3-72.0%, and 55.7-91.4% of the
applied [14C]mandipropamid was adsorbed to the Sanger sandy loam, Chula
loamy sand, and North Rose loamy sand soils, respectively.  The
Freundlich adsorption K values were 3.68, 2.88, and 7.37 for the Sanger
sandy loam, Chula loamy sand, and North Rose loamy sand soils,
respectively; corresponding Freundlich Koc values were 693.9, 405.1, and
624.3.  The adsorption K and Koc values were not reported.  Following
the first desorption step, the percent of [14C]mandipropamid desorbed
from the test soils, as percent of the radioactivity adsorbed, was
21.4-40.1% for the Sanger sandy loam, 19.2-40.9% for the Chula loamy
sand, and 21.9-34.9% for the North Rose loamy sand.  Following the third
desorption step, the percent of [14C]mandipropamid desorbed from the
high-dose soils was 69.3%, 68.0%, and 63.2% for the Sanger sandy loam,
Chula loamy sand, and the North Rose loamy sand soils, respectively
(reviewer-calculated).  The Freundlich desorption K values were 4.98,
4.33, and 11.86 for the Sanger sandy loam, Chula loamy sand, and North
Rose loamy sand soils, respectively; corresponding Freundlich desorption
Koc values were 939.6, 609.9, and 1004.8.  For the high-dose soils
following the third desorption step, Freundlich desorption K values were
2.39, 1.63, and 4.13 for the Sanger sandy loam, Chula loamy sand, and
North Rose loamy sand soils, respectively; corresponding Freundlich
desorption Koc values were 423, 229, and 229.  The desorption K and Koc
values were not reported for any of the test soils. This study is
classified as supplemental and upgradeable upon the submission of
additional information related to classification of soils used in this
study, in accordance to FAO Soil Classification (i.e. Soil Units) or
equivalent U.S. Soil Taxonomy. The study was conducted using three
soils, and only two soil types were represented. Additional study with a
fourth soil is needed as required by the Subdivision N, Chemistry:
Environmental Fate, Section 163-1

MRID 46800042, 43 (Supplemental)

The adsorption/desorption characteristics of
[methoxyphenyl-U-14C]-labeled
2-(4-chloro-phenyl)-2-hydroxy-N-[2-(3-methoxy-4-prop-2-ynyloxy-phenyl)-e
thyl]acetamide (CGA380778) were studied in a sandy clay loam soil [pH
5.6, organic carbon 3.25%] from the United Kingdom, a loam soil [pH 7.2,
organic carbon 2.06%] from Switzerland, and a sandy loam soil [pH 6.3,
organic carbon 0.46%] from the United States, in a batch equilibrium
experiment.  The adsorption phase of the study was carried out by
equilibrating air-dried soil with [14C]-CGA380778 at actual
concentrations of 0.23, 0.61, 1.18, 6.19, and 11.85 mg a.i./kg soil (18
Acres sandy clay loam and Gartenacker loam); and 0.11, 0.31, 0.59, 3.09,
and 5.93 mg a.i./kg soil (Visalia sandy loam), in the dark at 25 ( 0.1(C
for 48 hours.  The equilibrating solution used was 0.01M CaCl2 solution
with a soil solution ratio of 1.0:12.5 (w:v; 18 Acres sandy clay loam
and Gartenacker loam); and 1.0:6.25 (w:v; Visalia sandy loam).  The
desorption phase of the study was carried out by replacing the
adsorption solution with an equivalent volume of 0.01M CaCl2 solution
and equilibrating in the dark at 25 ( 0.1(C for 48 hours.  A single
desorption step was conducted for all soils. The experimental
temperature employed during the study was reported to be maintained at
25 ( 0.1(C. The pH of the test solutions during the study ranged from
6.2-6.5.  After 48 hours of equilibration, 58.0-68.3%, 46.3-59.5%, and
21.0-39.0% of the applied [14C]CGA380778 was adsorbed to the 18 Acres
sandy clay loam, Gartenacker loam, and Visalia sandy loam soils,
respectively.  The Freundlich adsorption K values were 15.7, 10.3, and
1.7 for the 18 Acres sandy clay loam, Gartenacker loam, and Visalia
sandy loam soils, respectively; corresponding Freundlich Koc values were
482, 501, and 361. The adsorption K and Koc values were not determined.
At the end of the desorption phase, the percent of [14C]CGA380778
desorbed from the test soils, as percent of the radioactivity adsorbed,
was 93.0-174.2% for the 18 Acres sandy clay loam, 49.3-100.8% for the
Gartenacker loam, and 10.2-40.9% for the Visalia loam soils.  The
Freundlich desorption K values were 20.0, 13.5, and 3.8 for the 18 Acres
sandy clay loam, Gartenacker loam, and Visalia sandy loam soils,
respectively; corresponding Freundlich desorption Koc values were 615,
654, and 818.

This study is classified as supplemental and upgradeable upon the
submission of additional information related to classification of soils
used in this study, in accordance to FAO Soil Classification (i.e. Soil
Units) or equivalent U.S. Soil Taxonomy. The study was conducted using
three soils. Additional study with a fourth soil is needed as required
by the Subdivision N, Chemistry: Environmental Fate, Section 163-1

164-1 Terrestrial Field Dissipation

MRID 46800045 (Acceptable)

Soil dissipation/accumulation of mandipropamid
(4-chloro-N-[2-[3-methoxy-4-(2-propynyloxy)phenyl]ethyl]-α-(2-propynylo
xy)benzeneacetamide) under U.S. field conditions was conducted in bare
plots of sandy loam soil at one site in California. Mandipropamid was
broadcast four times (7-day intervals) at a target rate of 0.165 kg
a.i./ha (0.147 lb a.i./A) to a 21 x 43 m test plot divided into three
replicate areas. The total target rate applied was 660 g a.i./ha or 110%
of the proposed maximum annual rate for leafy vegetables. The
application was made to approximate the timing of typical fungicide
applications in the fall for control of foliar oomycete pathogens on
leafy vegetables in the San Joaquin Valley of California. Total water
input during the study period was 70.32 inches or over 300% of the
30-year historical average precipitation. A control plot was located
approximately 59 m from the treated plot.

Soil samples were collected at 0, 1, and 6 days following the first
three applications and at 0, 1, 3, 7, 14, 21, 30, 58, 90, 125, 182, 272,
359, 454, and 540 days following the fourth application to a depth of
0-120 cm (except application 1, day-0 samples which were collected to a
depth of 15 cm).

The measured zero-time recovery of mandipropamid in the 0-15 cm soil
layer was 56 ppb or 70% of the theoretical. Mandipropamid was detected
in the 0-15 cm soil layer at 97 ppb following the second application,
146 ppb following the third application, and at a maximum of 165 ppb
following the fourth application. Following the fourth application,
mandipropamid decreased to 83 ppb by 58 days, 31 ppb by 182 days, 4.1
ppb by 272 days, and ranged from 2.1-2.6 ppb from 359 to 540 days
posttreatment. Mandipropamid was not detected below the 0-15 cm soil
depth. No transformation products were detected in the soil at greater
than 10% of the applied mandipropamid. Under field conditions at the
test site, mandipropamid had a half-life value of 75.3 days in soil (r2
= 0.9158), calculated using linear regression and the equation t½ = ln
2 / k, where k is the rate constant, and based on all available data
following the fourth application. The major route of dissipation of
mandipropamid under terrestrial field conditions could not be determined
because transformation products were detected at <2% of the applied
mandipropamid, leaching and carryover of residues were not observed, and
volatilization and runoff were not studied. However, the study author
stated that no major degradation product was identified in the
laboratory environmental fate studies.

MRID 46800046 (Acceptable)

-[2-[3-methoxy-4-(2-propynyloxy)phenyl]ethyl]-α-(2-propynyloxy)benzenea
cetamide) under U.S. field conditions was conducted in a bare plot and a
cropped plot (potatoes) of loamy sand soil at one site in New York.
Mandipropamid was broadcast four times (6- to 7-day intervals) at a
target rate of 0.165 kg a.i./ha (0.147 lb a.i./A) to two 29 x 35 m test
plots each divided into three replicate areas. The total target rate
applied was 660 g a.i./ha or 110% of the proposed maximum annual rate
for potatoes. The potato crop was at the late bloom stage (20-inch
height) at the first application and at the post bloom stage (24-inch
height) at subsequent applications; coverage was 70% at the first
application and 85-90% by the fourth application. The crop was harvested
57 days after the fourth application. The application was made to
approximate the timing of typical fungicide applications for control of
oomycete pathogens (late blight) on potatoes in the Northeastern region
of the U.S. Total water input during the study period was 80.60 inches
or 142% of the 30-year historical average precipitation. A control plot
was located approximately 70 m from the nearest treated plot. Soil
samples were collected at 0, 1, and 5 days following the first
application, at 0, 1, and 6 days following the second and third
applications, and at 0, 1, 3, 7, 14, 21, 30, 65, 91, 124, 194, 275, 356,
448, and 505 days following the fourth application to a depth of 0-120
cm (except application 1, day-0 samples which were collected to a depth
of 15 cm).

In the bare plot, the measured zero-time recovery of mandipropamid in
the 0-15 cm soil layer was 68 ppb or 79% of the theoretical.
Mandipropamid was detected in the 0-15 cm soil layer at 100 ppb
following the second application, 136 ppb following the third
application, and 120 ppb following the fourth application. Following the
fourth application, mandipropamid decreased to 63-65 ppb by 7-21 days,
43-54 ppb by 30-194 days, 12 ppb by 275 days, and ranged from 2.7-4.4
ppb from 356 to 505 days posttreatment. Mandipropamid was not detected
below the 0-15 cm soil depth. No transformation products were detected
in the soil at greater than 10% of the applied mandipropamid. In the
cropped plot, the measured zero-time recovery of mandipropamid in the
0-15 cm soil layer was 52 ppb or 60% of the theoretical. Mandipropamid
was detected in the 0-15 cm soil layer at 53 ppb following the second
application, 90 ppb following the third application, and 101 ppb
following the fourth application. Following the fourth application,
mandipropamid increased to a maximum of 167 ppb by 65 days, coinciding
with the sampling interval following the harvest of the potato crop at
57 days posttreatment, when residues bound to the potato leaves were
incorporated into the soil. Following 65 days, mandipropamid decreased
to 68 ppb by 194 days, 20-21 ppb by 356-448 days, and was 16 ppb at 505
days posttreatment. Mandipropamid was not detected below the 0-15 cm
soil depth. No transformation products were detected in the soil at
greater than 10% of the applied mandipropamid. Under field conditions in
the bare plot, mandipropamid had a half-life value of 100.5 days in soil
(r2 = 0.8628), calculated using linear regression and the equation t½ =
ln 2 / k, where k is the rate constant, and based on all available data
following the fourth application. However, dissipation was bi-phasic,
with a more rapid decline phase during the first month of the study; the
half-life based on 0-30 day data was 27.8 days (r2 = 0.5521).

Under field conditions in the cropped plot, mandipropamid had a
half-life value of 126 days in soil (r2 = 0.9384), calculated using
linear regression and the equation t½ = ln 2 / k, where k is the rate
constant, and based on all available data following the maximum
detection of mandipropamid at 65 days following the fourth application.
The major route of dissipation of mandipropamid under terrestrial field
conditions could not be determined because transformation products were
detected at <2% of the applied mandipropamid, leaching and carryover of
residues were not observed (carryover was <5%), and volatilization and
runoff were not studied. However, the study author stated that there was
no major degradation product identified in the laboratory environmental
fate studies.

MRID 46800047 (Acceptable)

Soil dissipation/accumulation of mandipropamid
(4-chloro-N-[2-[3-methoxy-4-(2-propynyloxy)phenyl]ethyl]-α-(2-propynylo
xy)benzeneacetamide) under US field conditions was conducted in bare
plots of loamy sand soil at one site in Georgia. Mandipropamid was
broadcast four times (7-day intervals) at a target rate of 0.165 kg
a.i./ha (0.147 lb a.i./A) to a 35 x 35 m test plot divided into three
replicate areas. The total target rate applied was 660 g a.i./ha or 110%
of the proposed maximum annual rate for squash. The applications were
made to approximate the timing of typical fungicide applications in the
spring for control of oomycete pathogens on squash in the Southeastern
region of the U.S. Total water input during the study period was 138.54
inches or 189% of the 30-year historical average precipitation. A
control plot was located approximately 46 m from the treated plot. Soil
samples were collected at 0, 1, and 6 days following the first three
applications and at 0, 1, 3, 7, 14, 21, 30, 62, 93, 120, 183, 268, 364,
457, and 540 days following the fourth application to a depth of 0-120
cm (except application 1, day-0 samples which were collected to a depth
of 15 cm). The measured zero-time recovery of mandipropamid in the 0-15
cm soil layer was 58 ppb or 76% of the theoretical. Mandipropamid was
detected in the 0-15 cm soil layer at 86 ppb following the second
application, a maximum of 136 ppb following the third application, and
124 ppb following the fourth application. Following the fourth
application, mandipropamid decreased to 60 ppb by 21 days, 19 ppb by 62
days, 4.0-5.9 ppb by 268-364 days, and was 0.74 ppb at 540 days
posttreatment. Mandipropamid was only detected in the 15-30 cm soil
depth once, at 0.53 ppb at 14 days posttreatment, and was not detected
below that depth. No transformation products were detected in the soil
at greater than 10% of the applied mandipropamid. Under field conditions
at the test site, mandipropamid had a half-life value of 81.5 days in
soil (r2 = 0.8934), calculated using linear regression and the equation
t½ = ln 2 / k, where k is the rate constant, and based on all available
data following the fourth application. However, dissipation was
bi-phasic, with a more rapid decline phase during the first two months
of the study; the half-life based on 0-62 day data was 24.5 days (r2 =
0.9090). The major route of dissipation of mandipropamid under
terrestrial field conditions could not be determined because
transformation products were detected at <2% of the applied
mandipropamid, leaching and carryover of residues were not observed, and
volatilization and runoff were not studied. However, the study author
stated that there was no major degradation product identified in the
laboratory environmental fate studies.

The important metabolites formed by the degradation of mandipropamid are
provided in Table A-7 and the chemical structures of these metabolites
are illustrated in Table A-8.

Table A-7. Maximum Amounts of Mandipropamid Metabolites in Degradation
Studies Characterized by Study Type

Study Type	Metabolite (% Maximum)	MRID

161-1 Hydrolysis	No degradation products observed	46800007,8

161-2 Aqueous photolysis	Polar compounds totaled average of 36.7%.

Unidentified polar compounds totaled a maximum of 25.0%.

Unidentified minor residues maximum of (6.2% of the applied

minor nonpolar transformation products, none averaging (5% of the
applied	46800009

46800010

46800011,12

46800013,14

161-3 Soil photolysis	CO2 (6.3%)

CGA380775 (4.1%)

SYN505503 (3.0%)

CGA380778 (2.5%)

NOA495119 (0.2%)

NOA458422 (0.7%)

SYN521195 (not quantified)

CO2 (17.1%)

CGA380778 (3.9%)

CO2 (`14.98%)

CGA380778 (3.80%)	46800015

46800016,17

46800018,19

162-1 Aerobic soil metabolism	CO2 (maximum 56.3%

CGA380778 (4.25%)

CGA380775 (0.51%)

SYN500003 (0.27%)

NOA458422 (0.18%)

CGA380778 (2.9%)

CO2 (maximum 51.0%)

CO2 (21.8%)

CGA380778 (1.4%)

SYN536638 (2.4%)

NOA458422 (below limit of detection

CGA380778 (3.2%)

CO2 (12.3%)

CGA380778 (4.8%)	46800020,21

46800022

46800023

46800024,25

46800027

46800028

162-2 Anaerobic soil metabolism	CO2 was the only significant degradation
product.

CGA380778(4.6%)	46800022

162-3 Anaerobic aquatic metabolism	SYN500003 (25.9%)

SYN504851 (73.5%)

SYN521195 (10.3%)

CO2 (15.8%)

SYN539678 (4.6%)

SYN539679 (6.1%)

SYN536638 (0.9%)	46800030,31

162-4 Aerobic aquatic metabolism	SYN521195 (10.8%)

SYN504851 (11.1%)

SYN500003 (6.4%)

SYN539678 (6.9%)

SYN539679 (0.9%)

SYN536638 (1.9)

	46800032

Table A-8. The Chemical Structure of  NOA446510 (Mandipropamid) and its
Metabolites

NOA446510

SYN505503

CGA380778

CGA380775

SYN536638

SYN521195

SYN539678

SYN504851

SYN539679

Appendix B. GENEEC Aquatic Exposure Model

The GENEEC (GENeric Estimated Environmental Concentration) model, the
tier one computer program, uses the 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 1 is used to
screen chemicals to determine which ones potentially pose sufficient
risk to warrant higher level modeling. Chemicals failing to pass this
program, move on to the tier two modeling. As a matter of policy, OPP
does not take significant adverse regulatory action based upon the
results of tier 1 screening models.

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 washoff to a
water body, direct deposition of spray drift into the water body, and
degradation of the pesticide within the water body ((  HYPERLINK
"http://www.epa.gov/oppefed1/models/water/geneec2_users_manual.htm#intro
duction"
http://www.epa.gov/oppefed1/models/water/geneec2_users_manual.htm#introd
uction )).

GENEEC Output

RUN No.   1 FOR Total Residue    ON   all           * INPUT VALUES *

--------------------------------------------------------------------

RATE (#/AC)   No.APPS &   SOIL  SOLUBIL   APPL TYPE  NO-SPRAY INCORP

ONE(MULT)    INTERVAL     Koc   (PPM )    (%DRIFT)   ZONE(FT)  (IN)

--------------------------------------------------------------------

.130(   .477)   4   7       2.9*******   AERL_B( 13.0)    .0    .0

FIELD AND STANDARD POND HALFLIFE VALUES (DAYS)

--------------------------------------------------------------------

METABOLIC  DAYS UNTIL  HYDROLYSIS   PHOTOLYSIS   METABOLIC  COMBINED

(FIELD)   RAIN/RUNOFF   (POND)     (POND-EFF)    (POND)     (POND)

--------------------------------------------------------------------

72.04        2          N/A      1.10-  136.40   102.00     58.36

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

--------------------------------------------------------------------

20.88       20.67         19.42         16.92         15.29

APPENDIX C.	Explanation of T-REX Model

1.	Introduction

This spreadsheet based model calculates the decay of a chemical applied
to foliar surfaces for single or multiple applications. It uses the same
principle as the batch code models FATE and TERREEC for calculating
terrestrial estimates exposure (TEEC) concentrations on plant surfaces
following application. A first-order decay assumption is used to
determine the concentration at each day after initial application based
on the concentration resulting from the initial and additional
applications. The decay is calculated by from the first-order rate
equation:

CT = Cie-kT

or in log form:

ln (CT/Ci) = kT

where:

CT =	concentration at time T = day zero.

Ci =	concentration, in parts per million (ppm) present initially (on day
zero) on the surfaces. Ci is calculated based on Kenaga and Fletcher by
multiplying the Ci based on the Kenaga nomogram (Hoerger and Kenaga
[1972] as modified by Fletcher [1994]). For maximum concentration the
application rate, in pounds active ingredient per acre, is multiplied by
240 for short grass, 110 for tall grass, and 135 for broad leafed
plants/small insects and 15 for fruits/pods/large insects. 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 = 	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
TETT recommends the use of a default half-life value of 35 days. The
use of the 35 day half-life is based on the highest reported value
(36.9 days) reported by Willis and McDowell (1987).

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 program calculates concentration on each type of surface on a daily
interval for one year. The maximum concentrations during the year are
calculated for both maximum and mean residues. The inputs required are:

Application rate:	The maximum label application rate (in pounds
a.i./acre)

Half-life:	The degradation half-life for the dominate process (in days)

Frequency of application:	The interval between repeated applications,
from the label (in days)

Maximum number of application per year:	From the label

The calculated concentrations are used to calculate Avian and Mammalian
RQ values. The maximum calculated concentration is divided by user input
values for acute and chronic endpoints to give RQs for each type of
plant surface.

2.	Avian Species

For calculating dose-based RQs in birds, the maximum and mean Kenaga
residue values are adjusted for avian class and food consumption based
on the following scaling factor (USEPA 1993):

FI (g/d) = 0.648 (g bw)^0.651

For the three avian weight classes considered (20, 100, and 1000 g),
this results in percent of body weight consumption of:

Weight (g)	FI	Wet FI	% Body Weight Consumed

20	4.555599463	22.77799731	114

100	12.98897874	64.94489369	65

1000	58.15338588<PHONE_NUMBER>	29

A.	Dose-Based Acute RQs

Dose-based acute RQs are then calculated using the formula:

RQ = adjusted EEC/LD50 or NOAEL

where the adjusted EEC is considered to be the daily dose weighted for
percent of body weight consumed of a given food source.

B.	Dietary-Based RQs

For dietary-based RQs, two values are given for each food group. First,
the consumption-weighted RQ for each weight class (20, 100, and 1000 g
birds) is displayed and calculated using the equation:

RQ = EEC/((LC50 or NOAEC)/(%bw consumed))

In the second method, no adjustment is made for consumption differences
among the weight classes. This RQ is calculated:

RQ = EEC/LC50 or NOAEC

3.	Mammalian Species

A.	Dose-Based RQs

For calculating dose-based RQs in mammals, the maximum and mean Kenaga
values are adjusted for mammalian class and food consumption (0.95,
0.66, and 0.15 body weight for herbivores and insectivores and 0.21,
0.15, and 0.03 body weight for granivores). Dose-based acute and chronic
RQs are then calculated by dividing the adjusted EECs (daily dose) by
the LD50 or NOAEL.

B.	Dietary-Based RQs

Dietary-based RQs are calculated using the equation:

RQ = EEC/((LC50 or NOAEC)/(% bw consumed))

4.	Graph

A graph of concentration on each plant surface vs. time is plotted and a
concentration of concern line can be added at a user specified level.
The concentration of concern (e.g., avian LC50, mammalian NOAEL) label
should be entered in the cell underneath the value. The graph
automatically plots a line at this concentration and the label is
extracted from that cell. The graph is plotted for the first 100 days
post-application. Graphs displaying acute and chronic LOCs for both
birds and mammals are displayed in the "Graph" worksheet. These graphs
may be useful as a visual aid to communicate risk in your assessment and
can be copy/pasted into your document. To help with scaling issues on
the y axis, you may want to delete one of the endpoints.

5.	New Version Notes

A new look is used in this update in an effort to decrease confusion and
increase transparency in the risk assessment process. This version of
T-REX (v1.3.1) incorporates the ability to calculate EECs and RQs for
maximum and mean residues. Mean residues are calculated exactly as the
maximum residues are, except the corresponding Kenaga values are:
85 for short grass, 36 for tall grass, and 45 for broad leafed
plants/small insects and 7 for fruits/pods/large insects.

Appendix D. Explanation of TerrPlant Model

Introduction

Exposure to Terrestrial Plants including Wetlands (December 26, 2005;
version 1.2.1)

The change to this model version is the removal of the 60% efficiency
factor for aerial applications.

Terrestrial plants inhabiting dry and semi-aquatic (wetland) areas may
be exposed to pesticides from runoff and/or spray drift. Semi-aquatic
areas are low-lying wet areas that may dry up at times throughout the
year.

EFED's runoff scenario 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.

EFED's Spray Drift scenario is assumed as: (1) 1% for ground
application; and (2)	5% for aerial, airblast, forced air, and spray
chemigation applications.

The spray drift ratio used here is in agreement with the policy
procedures at the time the worksheet was designed.

Currently, (1) this worksheet is designed to derive the plant exposure
concentrations from a single, maximum application rate only; and (2) for
pesticide applications with incorporation of depth of less than 1 inch,
the total loading EECs derived for the incorporation method will be same
as the unincorporated method.

To calculate RQ values for Non-Endangered Terrestrial Plants:

Terrestrial Plants Inhabiting Areas Adjacent to Treatment Site:

Emergence RQ = Total Loading to Adjacent Area or EEC/Seedling Emergence
EC25

Drift RQ = Drift EEC/Vegetative Vigor EC25

Terrestrial Plants Inhabiting Semi-aquatic Areas Adjacent to Treatment
Site:

Emergence RQ = Total Loading to Semi-aquatic Area or EEC/Seedling
Emergence EC25

Drift RQ = Drift EEC/Vegetative Vigor EC25

To calculate RQ values for Endangered Terrestrial Plants:

Endangered Terrestrial Plants Inhabiting Areas Adjacent to Treatment
Site:

Emergence RQ = Total Loading to Adjacent Area or EEC/Seedling Emergence
EC05 or NOAEC

Drift RQ = Drift EEC/Vegetative Vigor EC05 or NOAEC

Endangered Terrestrial Plants Inhabiting Semi-aquatic Areas Near
Treatment Site:

Emergence RQ = Total Loading to Semi-aquatic Area or EEC/Seedling
Emergence EC05 or NOAEC

Drift RQ = Drift EEC/Vegetative Vigor EC05 or NOAEC

Background for EEC Calculation

Formulas used to calculate EEC values (November 9, 2005; version 1.2.1)

To calculate EECs for terrestrial plants inhabiting in areas adjacent to
treatment sites:

Un-incorporated Ground Application (Non-granular):

Sheet Runoff = Application Rate (lbs a.i./acre) x Runoff Value

Drift = Application Rate (lbs a.i./acre) x 0.01

Total Loading = EEC = Sheet Runoff + Drift

Incorporated Ground Application with Drift (Non-granular):

Sheet Runoff = [Application Rate (lbs a.i./acre)/Incorporation Depth
(cm)] x Runoff Value

Drift = Application Rate (lbs a.i./acre) x 0.01

Total Loading = EEC = Sheet Runoff + Drift

Un-incorporated Ground Application (Granular):

Sheet Runoff = EEC = Application Rate (lbs a.i./acre) x Runoff Value

Incorporated Ground Application without Drift (Granular):

Sheet Runoff = EEC = [Application Rate (lbs a.i./acre)/Incorporation
Depth (cm)] x Runoff Value

Aerial/Airblast/Spray Chemigation Applications1:

Sheet Runoff = Application Rate (lbs a.i./acre) x Runoff Value

Drift = Application Rate (lbs a.i./acre) x 0.05

Total Loading = EEC = Sheet Runoff + Drift

Runoff Value = 0.01, 0.02, or 0.05 when the solubility of the chemical
is <10 ppm, 10-100 ppm, or >100 ppm, respectively. Incorporation Depth:
Use the minimum incorporation depth reported on the label.

Formulas used to calculate EEC values:

To calculate EECs for terrestrial plants inhabiting semi-aquatic
low-lying areas near treatment sites:

Un-incorporated Ground Application (Non-granular):

Channelized Runoff = Application Rate (lbs a.i./acre) x Runoff Value x
Factor 10

Drift = Application Rate (lbs a.i./acre) x 0.01

Total Loading = EEC = Channelized Runoff + Drift

Incorporated Ground Application with Drift (Non-granular):

Channelized Runoff = [Application Rate (lbs a.i./acre)/Incorporation
Depth (inch)] x Runoff Value x Factor 10

Drift = Application Rate (lbs a.i./acre) x 0.01

Total Loading = EEC = Channelized Runoff + Drift

Un-incorporated Ground Application (Granular):

Channelized Runoff = EEC = Application Rate (lbs a.i./acre) x Runoff
Value x Factor 10

Incorporated Ground Application without Drift (Granular):

Channelized Runoff = EEC = [Application Rate (lbs
a.i./acre)/Incorporation Depth (inch)] x Runoff Value x Factor 10

Aerial/Airblast/Spray Chemigation Applications:

Channelized Runoff = Application Rate (lbs a.i./acre) x Runoff Value x
Factor 10

Drift = Application Rate (lbs a.i./acre) x 0.05

Total Loading = EEC = Channelized Runoff + Drift

Runoff Value = 0.01, 0.02, or 0.05 when the solubility of the chemical
is <10 ppm, 10-100 ppm, or >100 ppm, respectively. Factor 10 represents
10 treated acres per acre of low-lying area. Incorporation Depth: Use
the minimum incorporation depth reported on the label.

Appendix E. Description of Ecological Effects Studies

Toxicity to Terrestrial Animals

Birds, Acute and Subacute

An acute oral toxicity study using the technical grade of the active
ingredient (TGAI) is required to establish the toxicity of mandipropamid
to birds.  The preferred test species is either mallard duck (a
waterfowl) or bobwhite quail (an upland gamebird).  Results of this test
are tabulated below.

Avian Acute Oral Toxicity

Species

% a.i.

LD50 (mg/kg a.i.)

Toxicity Category	MRID No.

	Study

Classification1

Mallard Duck

(Anas platyrhychos)	96.5	> 1000	Practically nontoxic	468001-11
Acceptable

Northern Bobwhite Quail

(Colinus virginianus)	96.5

> 2250

Practically nontoxic

468001-10

Acceptable

The results of these studies demonstrate that mandipropamid is
practically nontoxic to avian species on an acute oral basis.

Two subacute dietary studies using the TGAI are required to establish
the toxicity of mandipropamid to birds.  The preferred test species are
mallard duck and bobwhite quail.  Results of these tests are tabulated
below.

Avian Subacute Dietary Toxicity

Species

% a.i.	5-Day LC50

(ppm a.i.)

Toxicity Category	MRID No.

Study Classification1

Mallard Duck

(Anas platyrhychos)	96.5

> 6080

Practically Nontoxic

468001-12

Acceptable

Northern Bobwhite Quail

(Colinus virginianus)

96.5

> 6080

Practically Nontoxic

468001-13

Acceptable

The results of the avian acute dietary studies indicate mandipropamid is
practically nontoxic to avian species on a subacute dietary basis.

ii. Birds, Reproductive Toxicity

Two avian reproduction studies testing mandipropamid were submitted to
the Agency. The details of these studies are illustrated in the
following table.  The results of these studies demonstrated no
significant effects to either avian reproduction or growth.

Avian Reproductive Toxicity

Species/

Exposure Duration

% a.i.	Test

Type	Toxicity

Value (ppm)	Affected

Endpoints	MRID No.	Study Classification

Mallard Duck

(Anas platyrhychos)	96.5	Avian Reproduction	NOAEC: 1060

LOAEC: > 1060	None	467152-14	Acceptable

Northern Bobwhite

(Colinus virginianus)	96.5	Avian Reproduction	NOAEC: 1060

LOAEC: > 1060	None	468001-15	Acceptable

Mammals, Acute and Chronic

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.   A rat
multigenerational study and a rat acute oral toxicity study have been
submitted to the Agency. The toxicity values for this study are
tabulated below.

Mammalian Toxicity

Species

% a.i.	Test

Type	Toxicity

Value	Affected

Endpoints	MRID No.	Study Classification

Laboratory Rat

(Rattus norvegicus)	Technical	Rat Multi-generational Reproduction
toxicity	250 ppm	Decreased body weights, weight gains, food consumption,
and food utilization	468002-30	Acceptable

Laboratory Rat

(Rattus norvegicus)	Technical	Rat Acute Oral Toxicity	> 5000 mg/kg	No
mortality	MRID 468002-30

	Acceptable

Terrestrial Invertebrates

A honey bee acute contact study using the TGAI is required for
mandipropamid because its proposed uses may result in honey bee
exposure.  Results of this test are tabulated below.

Non-target Insect Acute Contact Toxicity

Species

% a.i.	LD50

(ug/bee)

Toxicity Category	MRID No.

	Study Classification

Honey Bee

(Apis mellifera L.)	99 %	> 200 ug ai/bee	Practically non-toxic

468001-16

	Acceptable

The registrant has also submitted two earthworm acute toxicity studies.
One of the studies tested the TGAI and the other study tested the
mandipropamid degradate, CGA380778.  The results of these studies are
illustrated in the table below.

Earthworm Acute Toxicity Test Toxicity

Species	Chemical

% purity

LC50

Toxicity Category	MRID No.

	Study Classification

Earthworms (Eisenia fetida)	Mandipropamid	99	>1000 mg ai/kg dw of soil.
Nontoxic at the highest concentrations tested

468001-23	Acceptable

Earthworms (Eisenia fetida)	CGA380778

(Mandipropamid

Degradate)	99	>1000 mg ai/kg dw of soil.	Nontoxic at the highest
concentrations tested

468001-22	Acceptable

The above analysis of the results show that mandipropamid is practically
non-toxic to honey bees and that mandipropamid and its’ degradate,
CGA380778, is nontoxic to earthworms at the highest concentrations
tested.  Therefore, it is presumed that the use of mandipropamid will
not pose a significant risk to non-target terrestrial invertebrates.

b. Toxicity to Freshwater Aquatic Animals

I.  Freshwater Fish, Acute

Two freshwater fish acute toxicity studies using the TGAI are required
to establish the toxicity of mandipropamid to fish.  The preferred test
species are rainbow trout (a coldwater fish) and bluegill sunfish (a
warmwater fish). The registrant has submitted 3 freshwater fish acute
toxicity studies. Two of the studies tested the TGAI and one tested,
CGA380778. Currently, all of the registrant submitted freshwater fish
toxicity studies testing mandipropamid and the mandipropamid degradate,
CGA380778, are deemed invalid.  The studies were invalidated because of
the failure of the study authors to take appropriate measures to ensure
the test chemical was adequately dissolved in the test water.  This was
indicated by the failure of the measured concentrations to remain at
least 80% of the nominal concentrations, as required by the fish acute
toxicity Guideline, 850.1075.  Additionally, the test solutions
contained undissolved particulate test material. This was an additional
indication of the failure to successfully dissolve the test solution.
Solubility is defined by the Agency’s Pesticide Registration Rejection
Rate Analysis Document as the amount of chemical retained in the
supernatant of a conventionally centrifuged sample of test media.
Because the test material was not adequately dissolved, it was not
possible to obtain accurate toxicity endpoint values that could be used
for risk assessment purposes.  Further details regarding these studies
are listed in the table below.

Freshwater Fish Acute Toxicity

Species

Chemical

% purity	96-hour

LC50 (a.i. ppm)

NOAEC (ppm a.i.)

Toxicity Category

MRID No.

Author/Year

Study Classification

Fathead Minnow (Pimephales promelas)	Mandipropamid

96.1% a.i.	> 5.8	4.4 Note 1	Undeterminable Note 4	468001-05	Invalid Note
5

Rainbow trout (Oncorhynchus mykiss)	Mandipropamid 96.1% a.i.	4.4	1.7
Note  2	Undeterminable Note 4

	468001-06	Invalid Note 5

Rainbow trout (Oncorhynchus mykiss)	CGA380778	> 43	9.3  Note  3
Undeterminable Note 4

	468001-04	Invalid Note 5

Note 1: The NOAEC value, based on sub-lethal effects, was 4.4 mg a.i./L.
 Sub-lethal effects (loss of equilibrium and lethargy) were observed in
the group exposed to 5.8 mg a.i./L of NOA446510 (Mandipropamid).  As no
sub-lethal quantitative measurements were taken, the reviewer was unable
to determine an EC50 value.

Note 2: This NOAEC value based on mortality and sub-lethal effects, was
1.7 mg a.i./L.  Sub-lethal effects (surfacing, lying on the bottom of
the aquarium, loss of equilibrium, lethargy, erratic swimming and
morphological deformity) were observed in the groups exposed to
mean-measured concentrations 3.1-6.5 mg a.i./L of NOA446510.  As no
sub-lethal quantitative measurements were taken, the reviewer was unable
to determine an EC50 value.

Note 3:  This NOAEC is value, based on mortality and sub-lethal effects,
was 9.3 mg/L.  Sub-lethal effects (quiescence, sounding, dark
discoloration, loss of balance, ceased swimming, labored respiration and
swollen abdomen) were observed in the groups exposed to 17-43 mg/L of
CGA380778.  As no sub-lethal quantitative measurements were taken, the
reviewer was unable to determine an EC50 value.

Note 4: Because of the failure of the mean measured concentrations to
remain at least 80% of the nominal concentrations, the concentrations in
which these effects were observed cannot be validated.

Note 5: The studies were invalidated because of the failure of the study
authors to take appropriate measures to ensure the test chemical was
adequately dissolved in the test water.  This was indicated by the
failure of the measured concentrations to remain at least 80% of the
nominal concentrations, as required by the fish acute toxicity
Guideline, 850.1075.

ii. Fish, Chronic toxicity.

Mandipropamid is mobile and is likely to readily and frequently (due to
multiple applications during a growing season) reach surface water
bodies.  Thus, a fish chronic toxicity study testing mandipropamid is
required.  The registrant has submitted a fish early life-stage chronic
toxicity study testing the TGAI.  The results of the study demonstrated
a NOAEC of 0.210 ppm based on growth.  The details of this study are
listed in the table below.

Freshwater Fish Chronic Toxicity

Species

% ai	Chronic Toxicity NOAEC and LOAEC

(a.i. ppm)

	Most sensitive Endpoint Affected

MRID No.

Author/Year

Study Classification

Fathead minnow	96.5	NOAEC: 0.22

LOAEC:

0.47

	Length, wet and dry weight	468001-08	Acceptable

iii. Freshwater Invertebrates, Acute

A freshwater aquatic invertebrate toxicity test using the TGAI is
required to establish the toxicity of mandipropamid to aquatic
invertebrates.  The preferred test species is Daphnia magna.  Results of
this test are tabulated below.  The registrant has submitted a study
testing the TGAI and a study testing the mandipropamid degradate,
CGA380778.

Freshwater Invertebrate Acute Toxicity for Mandipropamid and a
Mandipropamid degradate, CGA380778

Species

Chemical (% purity).	48-hour EC50 (ppm a.i.)

	NOAEC (ppm a.i.; based on mortality)

Toxicity Category

MRID No.

Study Classification

Waterflea

(Daphnia magna)

Mandipropamid

(96.5 %)

7.1

4.7

Moderately

toxic

468001-50	Acceptable

Waterflea

(Daphnia magna)

CGA380778 (98%)

54.2

37

Slightly

Toxic

468001-51

Acceptable

Since the EC50 for the TGAI, mandipropamid, falls in the range of 1 - 10
ppm, mandipropamid  is moderately toxic to aquatic invertebrates on an
acute basis.  Since the EC50 for the major degradate of mandipropamid,
CGA380778 falls in the range of 10 ppm – 100 ppm, CGA380778 is
classified as practically nontoxic to freshwater invertebrates.

Freshwater Invertebrate, Chronic

Mandipropamid is highly mobile and is likely to readily and frequently
(due to multiple applications during a growing season) reach surface
water bodies.  Thus, invertebrate chronic toxicity testing mandipropamid
is required.  The registrant has submitted one freshwater invertebrate
chronic toxicity study however the study was deemed invalid.  The study
was invalid because reproduction of solvent control daphnids was
significantly lower than that of negative control daphnids. According to
the EPA memo titled, “Interim Policy Guidance for the Use of
Dilution-Water (Negative) and Solvent Controls in Statistical Data
Analysis for Guideline Aquatic Toxicology Studies”, dated March 30,
2006, the study exhibiting such results would be invalidated.  The
details of the study are demonstrated below.

Freshwater Invertebrate Chronic Toxicity

Species

% ai	Chronic Toxicity NOAEC and LOAEC

(a.i. ppm)

Most sensitive Endpoint Affected

MRID No.

Author/Year

Study Classification

Daphnia magna	99	* NOAEC:

< 0.023

LOAEC:

0.023	Reproduction	468001-07	Invalid Note 1

* Note: The reviewer’s analysis showed that reproduction of solvent
control daphnids was significantly lower than that of negative control
daphnids, which according to the EPA memo titled, “Interim Policy
Guidance for the Use of Dilution-Water (Negative) and Solvent Controls
in Statistical Data Analysis for Guideline Aquatic Toxicology
Studies”, dated March 30, 2006, would result in the INVALID
classification of this study.

c. Toxicity to Estuarine/Marine Animals

I.  Estuarine/Marine Fish, Acute

Mandipropamid usage may occur in some areas associated with
marine/estuarine habitats.  Thus, marine/estuarine fish toxicity data is
required. There are two registrant submitted acute toxicity studies
testing marine/estuarine fish.  However both studies were deemed
invalid.  The studies were invalidated because of the failure of the
study authors to take appropriate measures to ensure the test chemical
was adequately dissolved in the test water.  This was indicated by the
failure of the measured concentrations to remain at least 80% of the
nominal concentrations, as required by the fish acute toxicity
Guideline, 850.1075.  Additionally, the test solutions contained
undissolved particulate test material. This was an additional indication
of the failure to successfully dissolve the test solution.  Solubility
is defined by the Agency’s Pesticide Registration Rejection Rate
Analysis Document as the amount of chemical retained in the supernatant
of a conventionally centrifuged sample of test media.  Because the test
material was not adequately dissolved, it was not possible to obtain
accurate toxicity endpoint values that could be used for risk assessment
purposes. The details of the studies are demonstrated in the table
below.

Marine/Estuarine Fish Toxicity for Mandipropamid

Species

(% purity)	96-hour LC50 (ppm a.i.)

NOAEC (ppm a.i.)

Toxicity Category

MRID No.

Study Classification

Sheepshead minnow

(Cyprinodon variegates)

96.1	4.5	2.8 Note 1	Undeterminable

***	468001-03	Invalid Note 4

Sheepshead minnow

(Cyprinodon variegatus)

96.1

>5.8 mg a..i./L

4.4 Note 2

Undeterminable Note 3	468001-05

Invalid Note 4

Note 1: The NOAEC value, based on mortality and sub-lethal effects, was
2.8 mg a.i/L.  Sub-lethal effects (erratic swimming, lying on the bottom
of the test vessel, and surfacing for unusually long periods of time)
were observed in the groups exposed to 4.3 and 6.1 mg a.i./L of
NOA446510.   As no sub-lethal quantitative measurements were reported,
the reviewer was unable to determine an EC50 value.

Note 2: The NOAEC value, based on sub-lethal effects, was 4.4 mg a.i./L.
 Sub-lethal effects (loss of equilibrium and lethargy) were observed in
the group exposed to 5.8 mg a.i./L of NOA446510 (Mandipropamid).  As no
sub-lethal quantitative measurements were taken, the reviewer was unable
to determine an EC50 value.

Note 3:  Because of the failure of the mean measured concentrations to
remain at least 80% of the nominal concentrations, the concentrations in
which these effects were observed cannot be validated.

Note 4:  The studies were invalidated because of the failure of the
study authors to take appropriate measures to ensure the test chemical
was adequately dissolved in the test water.  This was indicated by the
failure of the measured concentrations to remain at least 80% of the
nominal concentrations, as required by the fish acute toxicity
Guideline, 850.1075.

Estuarine and Marine Fish, Chronic

Currently, no estuarine and marine fish chronic toxicity studies have
been submitted to the Agency.

iii. Estuarine and Marine Invertebrates, Acute

Mandipropamid usage may occur in some areas associated with
marine/estuarine habitats.  Thus, marine/estuarine fish toxicity data is
required.  There are two registrant submitted acute toxicity studies
testing marine/estuarine invertebrate.  The details of the studies are
demonstrated in the table below.

Freshwater Invertebrate Toxicity for Mandipropamid

Species

Chemical (% purity).	96-hour EC50 (ppm a.i.)

NOAEC

(ppm a.i.;)

Toxicity Category

MRID No.

Study Classification

Mysid shrimp (Americamysis bahia)	96.1%	1.7(based on mortality)	0.58
Moderately toxic	468001-02	Acceptable

Oyster

Crassostrea virginica

96.1

0.91 (based on sublethal effect of shell deposition)

0.46

Very

Highly toxic	468001-01

Acceptable

iv.  Estuarine and Marine Invertebrate, Chronic

Currently, no estuarine and marine invertebrate chronic toxicity studies
have been submitted to the Agency.

d.   Toxicity to Plants

 tc \l2 "Toxicity to Plants

i.  Terrestrial Plants tc \l3 "Terrestrial Plants

The registrant submitted a seedling emergence and vegetative vigor study
testing the A12946B, the formulation containing the active ingredient
Mandipropamid.  The following summarizes the results of both studies.

The effect of A12946B on the seedling emergence of monocot (corn, Zea
mays; oat, Avena sativa; onion, Allium cepa; and ryegrass, Lolium
perenne) and dicot (carrot, Daucus carota; cucumber, Cucumis sativa;
radish, Raphanus sativus; soybean, Glycine max; sugar beet, Beta
vulgaris; and tomato, Lycopersicon esculentum) crops was studied at
nominal application rates of 0 (negative and surfactant controls),
0.0413, 0.0825, 0.165, 0.330 and 0.660 lbs ai/A.  The growth medium used
in the seedling emergence test was natural soil, classified as a loam
soil, with an organic matter content of 1.7% (1.0% organic carbon) and
an adjusted pH of 7.4.  On day 21 the surviving plants per pot were
recorded and cut at soil level for measuring the plant height and dry
weight.

Dry weight was significantly affected in cucumber, soybean and tomato,
but reductions did not exceed 25%.  The % inhibition in seedling
emergence in the treated species as compared to the control ranged from
-4 to 8%.  No monocot species was sensitive to treatment, but an EC05
value could be calculated for corn dry weight.  Carrot was the only
dicot species to exhibit a reduction of ≥25% (based on dry weight)
relative to the negative control; however, the response was not
dose-dependent, with the three lowest treatment groups experiencing
increases in dry weight of 2-21%.  The reviewer was unable to determine
reliable ECx values for carrot dry weight.   Additionally, one replicate
in the highest treatment group failed to emerge and overall emergence of
the controls and treatment groups was fairly low (60-73%). This implies
that factors other than treatment contributed to the poor performance of
carrot in this study.  The study was deemed supplemental because of this
study deficiency.

Seedling Emergence Study (468001-17) Summary of Most Sensitive
Parameters by Species (lbs ai/A).

Species	Endpoint	NOAEC	EC05	EC25	EC50

Corn	None	0.660	<0.0413	>0.660	>0.660

Oat	None	0.660	>0.660	>0.660	>0.660

Onion	None	0.660	ND	>0.660	>0.660

Ryegrass	None	0.660	ND	>0.660	>0.660

Carrot	Not Determinable	Not Determinable	Not Determinable	Not
Determinable	Not Determinable

Cucumber	None	0.165	<0.0413	>0.660	>0.660

Radish	None	0.660	0.36	>0.660	>0.660

Soybean	None	0.165	<0.0413	>0.660	>0.660

Sugar beet	None	0.660	ND	>0.660	>0.660

Tomato	None	0.660	ND	>0.660	>0.660

The effect of A12946B on the vegetative vigor of monocot (corn, Zea
mays; oat, Avena sativa; onion, Allium cepa; and ryegrass, Lolium
perenne) and dicot (carrot, Daucus carota; cucumber, Cucumis sativa;
radish, Raphanus sativus; soybean, Glycine max; sugar beet, Beta
vulgaris; and tomato, Lycopersicon esculentum) crops was studied at
nominal application rates of 0 (negative and surfactant controls),
0.0495, 0.0994, 0.198, 0.396 and 0.792 lbs ai/A.  The growth medium used
in the test was an artificial soil that represented a loam soil and was
composed of a mixture of kaolinite clay, industrial quartz sand and
peat; the organic matter content was 1.7% (1.0% organic carbon) and the
pH was 7.4.  On day 21 the surviving plants per pot were recorded and
cut at soil level for measuring the plant height and dry weight.

In the vegetative vigor test, plant height was affected by A12946B
treatment in oat only.  Dry weight, plant height and survival were not
affected in any other species.  The most sensitive monocot species,
based on plant height, in the vegetative vigor test was oat with an EC25
of >0.792 lbs ai/A and a NOAEC of 0.198 lbs ai/A.  No dicot was
sensitive to treatment, so the EC25 value was >0.792 lbs ai/A and the
NOAEC values was 0.792 lbs ai/A.

The study was deemed acceptable for a tier II vegetative vigor
terrestrial plant toxicity study.

Vegetative Vigor STUDY (468001-18) Summary of most sensitive parameters
by species (lbs ai/A).

Species	Endpoint	NOAEC	EC05	EC25	EC50

Corn	None	0.792	>0.792	>0.792	>0.792

Oat	Plant Height	0.198	>0.792	>0.792	>0.792

Onion	None	0.792	>0.792	>0.792	>0.792

Ryegrass	None	0.792	>0.792	>0.792	>0.792

Carrot	None	0.792	>0.792	>0.792	>0.792

Cucumber	None	0.792	>0.792	>0.792	>0.792

Radish	None	0.792	>0.792	>0.792	>0.792

Soybean	None	0.792	>0.792	>0.792	>0.792

Sugar beet	None	0.792	>0.792	>0.792	>0.792

Tomato	None	0.792	>0.792	>0.792	>0.792

Aquatic Plants

The registrant has submitted a nonvascular aquatic plant toxicity study
testing the effect of mandipropamid on Pseudokirchneriella subcapitata,
and a vascular aquatic plant toxicity study testing the effect of
mandipropamid on lemna gibba.  The registrant has also submitted a
nonvascular aquatic plant toxicity study testing the effect of
CGA380778, a mandipropamid degradate, on Pseudokirchneriella
subcapitata.  Results of the studies are tabulated below.

Tier II Mandipropamid Aquatic Plant Toxicity Test

	Test Species	Test Chemical and % purity	EC50 (ppm)	NOEAL or EC05 (ppm)
Endpoint Effected	Study Category	MRID

Lemna gibba	Mandipropamid

96.1	> 7.9	1.3 (EC05)	Biomass	Acceptable	468001-19

Pseudokirchneriella subcapitata	Mandipropamid

96.5	> 2.5	2.5 (NOEAL)	Biomass	Acceptable	468001-21

Pseudokirchneriella subcapitata	CGA380778 98.2%	16	2.4	Biomass
Acceptable	468001-20

APPENDIX F.	The Risk Quotient Method and Levels of Concern

The risks to terrestrial and aquatic organisms are determined based on a
method by which risk quotients (RQs) are compared with levels of concern
(LOCs). This method provides an indication of a chemical’s potential
to cause an effect in the field from effects observed in laboratory
studies, when used as directed. Risk quotients are expressed as the
ratio of the estimated environmental concentration (EEC) to the
species-specific toxicity reference value (TRV):

Units for EEC and TRV should be the same (e.g., µg/L or ppb). The RQ
is compared to the LOC as part of a risk characterization. Acute and
chronic LOCs for terrestrial and aquatic organisms are given in recent
Agency guidance (USEPA 2004) and summarized in Table F-1 below.

Table F-1. Level of concern (LOC) by risk presumption category (USEPA
2004)

Risk Presumption	RQ	LOC

Mammals and Birds

Acute Risk a	EEC b/LC50 or LD50/sqft c or LD50/day d	0.5

Acute Restricted Use e	EEC/LC50 or LD50/sqft or LD50/day (or LD50
<50 mg/kg)	0.2

Acute Endangered Species f	EEC/LC50 or LD50/sqft or LD50/day	0.1

Chronic Risk	EEC/NOEC	1

Aquatic Animals

Acute Risk	EEC g/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/NOEC	1

Terrestrial and Semi-aquatic Plants

Acute Risk	EEC/EC25	1

Acute Endangered Species	EEC/EC05 or NOEC	1

Aquatic Plants

Acute Risk	EEC h/EC50	1

Acute Endangered Species	EEC g/EC05 or NOEC	1

a Potential for acute toxicity for receptor species if RQ > LOC (USEPA
2004).

b Estimated environmental concentration (ppm) on avian/mammalian food
items

c mg/ft2

d mg of toxicant consumed per day

e Potential for acute toxicity for receptor species, even considering
restricted use classification, if RQ > LOC (USEPA 2004).

f Potential for acute toxicity for endangered species of receptor
species if RQ > LOC (USEPA 2004).

g EEC = ppb or ppm in water

h EEC = lbs a.i./acre

For acute exposure to terrestrial and aquatic plants, an LOC of 1 is
used. Currently the Agency does not perform assessments for chronic risk
to plants or acute/chronic risks to non-target insects.

  SEQ CHAPTER \h \r 1 For the Tier II aquatic assessment of
mandipropamid acute exposure is represented by the maximum 24-hour EEC
value calculated using PRZM/EXAMS. EECs used to assess acute and chronic
risk to avian and mammalian species to mandipropamid were calculated
using the Tier I model T-REX.

The Agency has developed an Endangered Species Protection Program to
identify pesticides whose use may cause adverse impacts on endangered
and threatened species, and to implement mitigation measures that will
eliminate the adverse impacts. At present, the program is being
implemented on an interim basis as described in a Federal Register
notice (54 FR 27984–28008, July 3, 1989), and is providing information
to pesticide users to help them protect these species on a voluntary
basis. As currently planned, the final program will call for label
modifications referring to required limitations on pesticide uses,
typically as depicted in county-specific bulletins or by other
site-specific mechanisms as specified by state partners. A final
program, which may be altered from the interim program, will be
described in a future Federal Register notice. The Agency is not
imposing label modifications at this time. Rather, any requirements for
product use modifications will occur in the future under the Endangered
Species Protection Program.

APPENDIX G. Data Requirments

  SEQ CHAPTER \h \r 1 Table G-1. Environmental Fate Data Requirements
for Mandipropamid

Guideline No.	Data Requirement	MRID No.	Study Classification

161-1	Hydrolysis	46800007,8	Acceptable

161-2	Photodegradation in Water (pH 7)	46800009,10,11,12,13, 14
Acceptable

161-3	Photodegradation on Soil	4680000	Acceptable

161-4	Photodegradation in Air	No Data

	162-1	Aerobic Soil Metabolism	4680020,21,22,23,24,25,26,27,28
Acceptable

Supplemental

Supplemental

Supplemental

Supplemental

Supplemental

Supplemental

Supplemental

Supplemental

162-2	Anaerobic Soil Metabolism	468000027	Supplemental

162-3	Anaerobic Aquatic Metabolism	46800033,34	Unacceptable

162-4	Aerobic Aquatic Metabolism	46800032	Unacceptable

163-1	Adsorption/Desorption	46800035, 36, 37,38, 39,40,41,42, 43
Supplemental

163-2	Laboratory Volatility	No Data

	163-3	Field Volatility	No Data

	164-1	Terrestrial Field Dissipation	46800045	Acceptable

164-2	Aquatic Field Dissipation	No Data

	164-3	Forestry Dissipation	No Data

	165-4	Accumulation in Fish	No Data

	166-1	Ground Water – small prospective	No Data

	166-2	Ground Water – small retrospective	No Data

	201-1	Droplet Size Spectrum	No Data

	202-1	Drift Field Evaluation	No Data

Table G-2.   SEQ CHAPTER \h \r 1 Ecological Effects Data Requirements
for Mandipropamid

Guideline No.	Data Requirement	Species	Formulation	Are data adequate for
ecological risk assessment?	MRID Number

(Study Classification)

71-1

850.2100	Avian Acute Oral Toxicity	Anas Platyrhynchos (mallard duck)
Technical	Yes	46800110

(Acceptable)

Colinus virginianu (bobwhite quail)	Technical	Yes	46800111

(Acceptable)

71-2

850.2200	Avian Subacute Dietary Toxicity	Colinus virginianu

 (bobwhite quail)	Technical	Yes	46800112

(Acceptable)

Anas Platyrhynchos

(mallard duck)	Technical	Yes	46800113

(Acceptable)

71-4

850.2300	Avian Reproduction Toxicity	Colinus virginianu

(bobwhite quail)	Technical

	Yes

	46800114

(Acceptable)

Anas Platyrhynchos (mallard duck)	Technical	Yes

	46800115

(Acceptable)

72-1

850.1075	Freshwater Fish LC50	Pimephales promelas

(fathead minnow)	Technical	No	46800104

(Unacceptable)

Oncorhynchus mykiss

 (rainbow trout)	Technical	No	46800105

(Unacceptable)

72-2

850.1010	Freshwater Invertebrate Acute LC50	Daphnia magna

(water flea)	Technical	Yes	46800150 (Acceptable)

72-3(a)

850.1075	Estuarine/Marine Fish LC50	Cyprinodon variegatus

(sheepshead minnow)	Technical	No	46800101 (Unacceptable)

72-3(b)

850.1025	Estuarine/Marine Invertebrate (Mollusk)	Crassostrea virginica

(eastern oyster)	Technical	Yes	46800101 (Acceptable)

72-3(c)

850.1035

850.1045	Estuarine/Marine Invertebrate (Mysid)	Americamysis bahia

 (mysid shrimp)	Technical	Yes	46800102 (Acceptable)

72-4 (a)

850.1400	Fish Early Life-Stage

(Freshwater)

(Marine)	Pimephales promelas

 (fathead minnow)	Technical	Yes

	46800108 (Acceptable)

72-4 (b)

850.1300

850.1350	Aquatic Invertebrate Life-Cycle

(Freshwater)

(Marine)	Americamysis bahia

 (mysid shrimp)	Technical	No data submitted

	72-5

850.1500	Fish Full Life-Cycle

(Freshwater)

(Marine)	No data submitted	No data submitted	No	–

122-1(a)

850.4100	Seed Germination/ Seedling Emergence (Tier I)	No data
submitted	No data submitted	No

	–

122-1(b)

850.4150	Vegetative Vigor

(Tier I)	No data submitted	No data submitted	No	–

122-2

850.4400	Aquatic Plant Growth (Tier I)	Lemna gibba (duckweed)	Technical
Yes

Technical	Yes

	123-1(a)

850.4225	Seed Germination/ Seedling Emergence (Tier II)	Monocots and
Dicots	Formulation c	Partially	46800117 (Supplemental)

123-1(b)

850.4250	Vegetative Vigor (Tier II)	Monocots and Dicots	Formulation c
Yes	46800118 (Acceptable)

123-2

850.4400	Aquatic Plant Growth (Tier II)	Lemna gibba (duckweed)	Technical
Yes	466800119 (Acceptable)

123-2

850.5400	Algal Plant Toxicity

(Tier I and Tier II)	Anabaena flos-aquae (freshwater alga)	Technical	No

	Skeletonema costatum (marine alga)	Technical	No

	Pseudokirchneriella subcapitata	Technical	Yes	46800121 (Acceptable)

Navicula pelliculosa (freshwater alga)	Technical	No

	141-1

850.3020	Honeybee Acute Contact Toxicity Test	Apis mellifera (honey bee)
Technical	Yes	46800116 (Supplemental)

141-2

850.3030	Residues on Foliage Honeybee Toxicity Test	No data submitted	No
data submitted	No

	Non-Guideline   SEQ CHAPTER \h \r 1 	  SEQ CHAPTER \h \r 1 Honeybee
Feeding Toxicity Test	No Data Submitted	No data submitted	No

	Non-Guideline	Benthic Organisms	Chironomus riparius

(midge)	No data submitted	No

	Non-Guideline	Earthworm Subacute	No	No data submitted	No

APPENDIX H. Use Characterization Maps

There are no madnipropamid use characterization maps available.

APPENDIX I. Environmental Fate Bibliography

MRID   SEQ CHAPTER \h \r 1 Environmental Fate Studies Submitted to EPA

MRID 46800007 - Buckel, T. 2002. Hydrolysis of [ethyl-1-14C]-labelled
NOA446510 under laboratory conditions.  Unpublished study performed and
sponsored by Syngenta Crop Protection AG, Basel, Switzerland, and
submitted by Syngenta Crop Protection, Inc.  Greensboro, NC. Basel No.:
02TB01; Syngenta No.: T004591-02.  Experiment started April 2, 2002, and
completed May 13, 2002.  Final report issued November 8, 2002.

MRID 46800008 - Murphy, T.  2006.  Hydrolysis of [ethyl-1-14C]-labelled
NOA446510 under laboratory conditions, study profile.  Unpublished study
summary prepared, sponsored and submitted by Syngenta Crop Protection,
Inc., Greensboro, North Carolina.  Syngenta Study No.: T004591-02.
Experimental start and termination dates not applicable.  Final report
issued February 24, 2006.

MRID 46800009- Kuet, S.F.  2004.  NOA446510: photolysis of
14C-chlorophenyl ring labelled NOA446510 in sterile natural water under
laboratory conditions.  Unpublished study performed by Jealott’s Hill
International Research Centre, Berkshire, UK, and submitted and
sponsored by Syngenta Crop Protection, Inc. Greensboro, NC.  Jealott’s
Hill No.: RJ3510B; Syngenta No.: T004575-02.  Experiment started October
2, 2003, and completed January 20, 2004. Final report issued November
25, 2004.

MRID 46800010- Harrison, C.L.  2004.  NOA446510: 14C-methoxyphenyl
labelled sterile natural water photolysis under laboratory conditions.
Unpublished study performed by Jealott’s Hill International Research
Centre, Berkshire, UK, and submitted and sponsored by Syngenta Crop
Protection, Inc. Greensboro, NC.  Jealott’s Hill No.: RJ3481B;
Syngenta No.: T004607-02.  Experiment started November 27, 2003, and
completed March 22, 2004.  Final report issued December 22, 2004.

MRID 46800011 - Nicollier, G. 2003.  Aqueous photolysis of
[chlorophenyl-U-14C]-labelled NOA446510 under laboratory conditions.
Unpublished study performed and sponsored by Syngenta Crop Protection
AG, Basel, Switzerland, and submitted by Syngenta Crop Protection, Inc.
Greensboro, NC.  Basel No.: 02GN07; Syngenta No.: T004618-02.
Experiment started May 14, 2002, and completed July 01, 2003. Final
report issued October 31, 2003.

MRID 46800012 - Murphy, T.  2006.  Aqueous photolysis of
[chlorophenyl-U-14C]-labelled NOA446510 under laboratory conditions,
study profile.  Unpublished study summary prepared, sponsored and
submitted by Syngenta Crop Protection, Inc., Greensboro, North Carolina.
 Syngenta Study No.: T004618-02.  Experimental start and termination
dates not applicable.  Final report issued February 23, 2006.

MRID 46800013 - Hand, L.H. and J. Towers. 2003.  Aqueous photolysis of
14C-methoxyphenyl-NOA446510 under laboratory conditions.  Unpublished
study performed and sponsored by Syngenta Jealott’s Hill International
Research Centre, Berkshire, UK and submitted by Syngenta Crop
Protection, Inc., Greensboro, NC.  Study No.: 02JH091; Syngenta No.:
T004630-02.  Experiment started November 20, 2002, and completed May 28,
2003.  Final report issued August 18, 2003.

MRID 46800014 - Murphy, T.  2006.  Aqueous photolysis of
14C–methoxypehnyl-NOA446510 under laboratory conditions, study
profile.  Unpublished study summary prepared, sponsored and submitted by
Syngenta Crop Protection, Inc., Greensboro, North Carolina.  Syngenta
Study No.: T004630-02.  Experimental start and termination dates not
applicable.  Final report issued February 13, 2006.

MRID 46800015 - Bramley, Y.M.  NOA446510: Soil photolysis of
14C-chlorophenyl ring

labelled NOA446510 under laboratory conditions.  Unpublished study
performed by Jealott’s

Hill International Research Centre, Berkshire, UK and sponsored and
submitted by Syngenta

Crop Protection, Inc., Greensboro, NC.  Report No.: RJ3535B.  Syngenta
No.: T008105-03.

Experiment initiated January 14, 2004 and completed January 7, 2005.
Final report issued

February 7, 2005.

MRID 46800016: Murphy, T.  2006.  NOA446510: Soil photolysis of
14C-methoxyphenyl ring labelled NOA446510 under laboratory conditions.
Unpublished study sponsored and submitted by Syngenta Crop Protection,
Inc., Greensboro, NC.  Syngenta No.: T004595-02.  Experiment start and
completion date not applicable.  Final report issued February 13, 2006.

MRID 46800017: Kuet, S.F.  2003.  NOA446510: Soil photolysis of
14C-methoxyphenyl ring labelled NOA446510 under laboratory conditions.
Unpublished study performed by Jealott’s Hill International Research
Centre, Berkshire, UK and sponsored and submitted by Syngenta Crop
Protection, Inc., Greensboro, NC.  Jealott’s Hill No.: RJ3400B.
Syngenta No.: T004595-02.  Study started January 8, 2003 and completed
August 20, 2003.  Final report issued December 10, 2003.

MRID 46800016: Murphy, T.  2006.  NOA446510: Soil photolysis of
14C-methoxyphenyl ring labelled NOA446510 under laboratory conditions.
Unpublished study sponsored and submitted by Syngenta Crop Protection,
Inc., Greensboro, NC.  Syngenta No.: T004595-02.  Experiment start and
completion date not applicable.  Final report issued February 13, 2006.

MRID 46800018: McKillican, C. B.  2005.  Photodegradation of
14C-NOA-446510 on soil under artificial light.  Unpublished study
performed, sponsored and submitted by Syngenta Crop Protection, Inc.,
Greensboro, NC.  Syngenta No.:  737-02.  Study started June 15, 2004 and
completion date not reported . Final report issued July 29, 2005.

MRID 46800019: Murphy, T.  2006.  Photodegradation of 14C-NOA-446510 on
soil under artificial light.  Unpublished study sponsored and submitted
by Syngenta Crop Protection, Inc., Greensboro, NC.  Syngenta No.:
000737-02.  Experiment start and completion date not applicable.  Final
report issued February 13, 2006.

MRID 46800020: Clark, A.  2004.  Metabolism of
[14C-chlorophenyl]-NOA-446510 in viable soil under aerobic conditions.
Unpublished study performed, submitted and sponsored by Syngenta Crop
Protection, Inc, Greensboro, NC.  Study No.: T000680-02.  Syngenta No.:
680-02.  Experiment started March 7, 2003.  Experimental completion date
not reported.  Final report issued September 1, 2004.

MRID 46800021: Murphy, T.  2006.  Metabolism of
[14C-chlorophenyl]-NOA-446510 in viable soil under aerobic conditions.
Unpublished study submitted and sponsored by Syngenta Crop Protection,
Inc, Greensboro, NC.  Syngenta No.: T000680-02.  Experiment start and
completion date not applicable.  Final report issued February 13, 2006.

MRID 46800022: Nicollier, G.  2003.  Metabolism of [methoxyphenyl-U-14C]
labelled

NOA446510 under aerobic, aerobic/anaerobic and sterile aerobic
laboratory conditions in one

soil at 20(C.  Unpublished study performed by Syngenta Crop Protection
AG, Basel,

Switzerland, and submitted and sponsored by Syngenta Crop Protection,
Inc., Greensboro, NC.

Basel Number: 02RF02.  Syngenta Number: T004633-02.  Experiment
initiated on June 6, 2002

and completed on November 28, 2003.  Final report issued on December 18,
2003.

MRID 46800023: Berdat, T. 2005.  Rate of degradation of [14C] CGA380778
(metabolite of NOA446510) in various soils under aerobic laboratory
conditions at 20(C.  Unpublished study performed and sponsored by
Syngenta Crop Protection AG, Basel, Switzerland and submitted by
Syngenta Crop Protection, Inc., Greensboro, NC.  Sygenta No.:
T004943-04.  Experiment started August 4, 2004 and completed January 20,
2005.  Final report issued March 13, 2005.

MRID 46800024: Hand, L.H.  2004.  NOA446510: Rate of degradation in one
soil under various laboratory conditions.  Unpublished study performed
by Jealott’s Hill International Research Centre, Berkshire, UK and
submitted and sponsored by Syngenta Crop Protection, Inc, Greensboro,
NC.  Report No.: RJ3487B.  Syngenta No.: T008097-03.  Experiment started
July 7, 2003 and completed February 27, 2004.  Final report issued July
14, 2004.

MRID 46800025:  Murphy, T.  2006.  NOA446510: Rate of degradation in one
soil under various laboratory conditions.  Unpublished study submitted
and sponsored by Syngenta Crop Protection, Inc., Greensboro, NC.
Syngenta No.:  T008097-03.  Experiment start and completion date not
applicable.  Final report issued February 13, 2006.

MRID 46800026:  Dorn, R., A. Clark, J. Perine, W. Chen, and T. Murphy.
2006.  Evaluation of degradation times after adjustment for temperature
and moisture effects of NOA446510 and its metabolite in various soils
under laboratory conditions.  Unpublished summary report prepared,
sponsored and submitted by Syngenta Crop Protection, Inc., Greensboro,
North Carolina.  Syngenta Study No.: T014422-05.  Experimental start
date and termination date not applicable.  Final report issued March 1,
2006.

MRID 46800027:  Nicollier, G.  2003.  Metabolism of [chlorophenyl-U-14C]
labelled NOA446510 under aerobic and aerobic/anaerobic laboratory
conditions in one soil at 20(C.  Unpublished study performed by Syngenta
Crop Protection AG, Basel, Switzerland, submitted and sponsored by
Syngenta Crop Protection, Inc., Greensboro, NC.  Basel Number: 02TB03;
Syngenta Number: T004572-02.  Experiment initiated on July 16, 2002 and
completed on January 7, 2003 (p. 9).  Final report issued on November 6,
2003.

MRID 46800028:  Kuet, S.F.  NOA446510: Metabolism and rate of
degradation of 14C-chlorophenyl ring labelled NOA446510 under aerobic
laboratory conditions, in three soils, at 20(C.  Unpublished study
performed by Jealott’s Hill International Research Centre, Berkshire,
UK and submitted and sponsored by Syngenta Crop Protection, Inc,
Greensboro, NC.  Report No.: RJ3469B.  Syngenta No.: T008109-03.
Experiment started March 27, 2003 and completed December 3, 2003 (p.
28).  Final report issued July 16, 2004.

MRID 46800029:  Dorn, R. 2005.  Evaluation of half-lives of selected
metabolites of

NOA446510 in aquatic systems.  Unpublished summary report prepared,
sponsored and

submitted by Syngenta Crop Protection, Inc., Greensboro, North Carolina.
 Syngenta Study No.:

T001209-06 and Report No.: Ass05RD04 (pp. 1, 4).  Experimental start
date and termination

date not applicable.  Final report issued August 16, 2005.

MRID 46800030: Murphy, T.  2006.  NOA446510: degradation in two aquatic
sediment systems, study profile.  Unpublished study summary prepared,
sponsored and submitted by Syngenta Crop Protection, Inc., Greensboro,
North Carolina.  Syngenta Study No.: T008095-03.  Experimental start and
termination dates not applicable.  Final report issued March 9, 2006.

MRID 46800031: Hurt, A.D.  2005.  NOA446510: degradation on two aquatic
sediment systems, final report.  Unpublished study performed by
Jealott's Hill International Research Centre, Berkshire, United,
Kingdom, sponsored and submitted by Syngenta Crop Protection, Inc.,
Greensboro, North Carolina.  JH Study No.: 03JH023 and Report No.:
RJ3669B (pp. 1, 15 in MRID 46800031).  Syngenta Study No.: T008095-03.
Experimental start date July 16, 2003, and termination date February 24,
2005 (p. 50 in MRID 4600031).  Final report issued July 27, 2005.

MRID 46800032:  Oliver, R.G., et al.  2005.  NOA446510: degradation in
an outdoor aquatic sediment system.  Unpublished study performed by
Jealott's Hill International Research Centre, Berkshire, United Kingdom,
sponsored and submitted by Syngenta Crop Protection, Inc., Greensboro,
North Carolina.  JH Study No.: 04JH007 and Report No.: RJ3569B (pp. 1,
12).  Syngenta Study No.: T009117-04.  Experimental start date June 2,
2004, and termination date May 10, 2005 (p. 35).  Final report issued
July 27, 2005.

MRID 46800033: Hurt, A.D.  2005.  NOA446510: degradation in two aquatic
sediment systems (methoxyphenyl ring), final report.  Unpublished study
performed by Jealott's Hill International Research Centre, Berkshire,
United Kingdom, sponsored and submitted by Syngenta Crop Protection,
Inc., Greensboro, North Carolina.  JH Study No.: 03JH035 and Report No.:
RJ3580B (pp. 1, 6 in MRID 46800033).  Syngenta Study No.: T008104-03.
Experimental start date May 6, 2004, and termination date April 13, 2005
(p. 43 in MRID 4600033).  Final report issued July 14, 2005.

MRID 46800034: Clark, A.  2006.  NOA446510: degradation on two aquatic
sediment systems (methoxyphenyl ring), study profile.  Unpublished study
summary prepared, sponsored and submitted by Syngenta Crop Protection,
Inc., Greensboro, North Carolina.  Syngenta Study No.: T008104-03.
Experimental start and termination dates not applicable.  Final report
issued March 3, 2006.

MRID 46800035:  Indergand, P.  2005.  Adsorption/desorption of a
[chlorophenyl-U-14C]-labeled SYN521195 in various soils.  Unpublished
study performed and sponsored by Syngenta Crop Protection AG, Bracknell,
Basel, Switzerland; submitted by Syngenta Crop Protection Inc.,
Greensboro, North Carolina.  Syngenta Number T013384-04.  Experimental
start date January 27, 2005, and experimental completion date June 21,
2005 (p. 9).  Study completion date August 19, 2005.

MRID 46800036:  Hand, L.H. and E.A. Fleming.  2005.
Adsorption/desorption properties of a metabolite (SYN539678) in three
soils.  Unpublished study performed by Jealott’s Hill International
Research Centre, Bracknell, Berkshire, United Kingdom; submitted and
sponsored by Syngenta Crop Protection Inc., Greensboro, North Carolina.
Syngenta Number T013385-04.  Jealott’s Hill Number RJ3674B.
Experimental start date January 11, 2005, and experimental completion
date May 11, 2005 (p. 22). Study completion date July 6, 2005.

MRID 46800037:  Indergand, P. and G. Nicollier.  2005.
Adsorption/desorption of [phenyl-U-14C]-labeled SYN500003 in various
soils (including final report amendment 1).  Unpublished study performed
and sponsored by Syngenta Crop Protection AG, Basel, Switzerland;
submitted by Syngenta Crop Protection Inc., Greensboro, North Carolina.
Syngenta Number T0006595-04.  Experimental start date January 11, 2005,
and experimental completion date May 2, 2005 (p. 9).  Study completion
date June 9, 2005.

MRID 46800038:  Nicollier, G. 2003.  Adsorption/desorption of
[methoxyphenyl-U-14C]-labelled NOA446510 in various soils (including
final report amendment 1).  Unpublished study performed and sponsored by
Syngenta Crop Protection AG, Basel, Switzerland; and submitted by
Syngenta Crop Protection Inc., Greensboro, NC.    Syngenta AG Study
Number T004577-02.  Basel Number 02TB04.  Experimental start date August
9, 2002, and completion date February 18, 2002 (p. 9).  Final report
issued October 24, 2003.

MRID 46800039: Murphy, T.  2006.  Adsorption/desorption of
[methoxyphenyl-U-14C]-labelled

NOA446510 in various soils.  Unpublished study submitted and sponsored
by Syngenta Crop

Protection Inc., Greensboro, NC.  Syngenta Study Number T004577-02.
Study completion date

February 27, 2006.

MRID 46800040:  Berdat, T. and G. Nicollier.  2004.  NOA446510:
Adsorption/desorption of [methoxyphenyl-U-14C]-labelled NOA446510 in
various US field soils (includes final report amendment 1).  Unpublished
study performed by Syngenta Crop Protection AG, Basel, Switzerland;
sponsored and submitted by Syngenta Crop Protection Inc., Greensboro,
North Carolina.  Study Number 04TB01.  Syngenta Number T000738-02.
Experimental start date January 16, 2004, and experimental completion
date March 17, 2004 (p. 9).  Study completion date December 23, 2004.

MRID 46800041:  Murphy, T.  2006.  NOA446510: Adsorption/desorption of
[methoxyphenyl-U-14C]-labelled NOA446510 in various US field soils.
Sponsored and submitted by Syngenta Crop Protection Inc., Greensboro,
North Carolina.  Syngenta Number T000738-02.  Completion date March 8,
2006.

MRID 46800042:  Adam, D.  2004.  Adsorption/desorption of
[14C]-CGA380778 on various soils.  Unpublished study performed by RCC
Ltd, Itingen, Switzerland; sponsored and submitted by Syngenta Crop
Protection Inc., Greensboro, North Carolina.  RCC Study Number 855381.
Syngenta Number T004956-04.  Experimental start date August 11, 2004,
and completion date September 22, 2004 (p. 12).  Study completion date
December 6, 2004.

MRID 46800043:  Murphy, T.  2006.  Adsorption/desorption of
[14C]-CGA380778 on various soils.  Sponsored and submitted by Syngenta
Crop Protection Inc., Greensboro, North Carolina.  Syngenta Number
T004956-04.  Study completion date March 8, 2006.

MRID 46800044:  Harrison, C.L.  2005.  NOA446510:  Adsorption/desorption
properties of a water sediment metabolite SYN504851 in three soils.
Unpublished study performed by Jealott’s Hill International Research
Centre, Bracknell, Berkshire, United Kingdom; submitted and sponsored by
Syngenta Crop Protection Inc., Greensboro, North Carolina.  Syngenta
Number T013383-04.  Jealott’s Hill Number RJ3633B.  Experimental start
date January 5, 2005, and experimental completion date April 1, 2005 (p.
20). Study completion date May 19, 2005.

MRID 46800045:  Peters, J. 2005. Dissipation of NOA446510 250SC in bare
soil plot under simulated leafy vegetable production conditions in the
San Joaquin Valley of California. Unpublished study performed by
Syngenta Crop Protection, Inc., Greensboro, NC; Excel Research Services,
Inc., Fresno, CA (field research facility); and North Coast
Laboratories, Ltd., Arcata, CA (analytical laboratory); and sponsored
and submitted by Syngenta Crop Protection, Inc., Greensboro, NC.
Syngenta No. T000052-03. Excel Study No. ERS23039. NCL No. 110.025.
Experiment initiation October 1, 2003 (first application date; Appendix
1, p. 84) and completion April 29, 2005 (analytical phase termination
date; Appendix 2, p. 133). Final report issued October 3, 2005.

MRID 46800046:  Peters, J. 2005. Dissipation of NOA446510 250SC under
field conditions on crop (potatoes) and bare soil in New York.
Unpublished study performed by Syngenta Crop Protection, Inc.,
Greensboro, NC; Waterborne Environmental, Inc., Leesburg, VA (field
phase management); A.C.D.S. Research , Inc., North Rose, NY (field
research facility); and Enviro-Test Laboratories, Edmonton, Alberta,
Canada (analytical laboratory); and sponsored and submitted by Syngenta
Crop Protection, Inc., Greensboro, NC. Syngenta No. T000053-03. ETL
Report No. 05SYN150.REP. WEI Study No. 242.68. Experiment initiation
August 7, 2003 (first application date; Appendix 1, p. 93) and
completion February 24, 2005 (analytical phase termination date;
Appendix 2, p. 199). Final report issued October 3, 2005.

MRID 46800047:  Peters, J. 2005. Dissipation of NOA446510 250SC in a
bare soil plot under simulated squash production conditions in Georgia.
Unpublished study performed by Syngenta Crop Protection, Inc.,
Greensboro, NC (analytical laboratory); Waterborne Environmental, Inc.,
Leesburg, VA (field management); Ag. Research Associates, LLC, Chula, GA
(field research facility); and sponsored and submitted by Syngenta Crop
Protection, Inc., Greensboro, NC. Syngenta No. T000054-03. WEI Study No.
242.69. Experiment initiation May 21, 2003 (first application date;
Appendix 1, p. 78) and completion July 13, 2005 (analytical phase;
Appendix 2, p. 165). Final report issued October 3, 2005.

MRID 46800109: Roberts, G.C. and F. Peurou.  2003.  NOA446510:
Determination of the accumulation and elimination of [14C]NOA446510 in
fathead minnow (Pimephales promelas).  Unpublished study performed by
Brixham Environmental Laboratory, United Kingdom; sponsored and
submitted by Syngenta Crop Protection, Inc., Greensboro, NC.  Brixham
Number BL7579/B.  Syngenta Number T011831-05.  Experiment initiated
March 12, 2003, and completed May 30, 2003 (p. 10).  Final report issued
December 18, 2003.

MRID 46800048 (NG study):  Peters, J. and B. Schwartz. 2005. Stability
of NOA-446510 and CGA-380778 in soil under freezer storage conditions.
Unpublished study performed and sponsored and submitted by Syngenta Crop
Protection, Inc., Greensboro, NC. Syngenta No. T001672-03. Experiment
initiation November 24, 2003 and completion September 9, 2005 (p. 8 and
Appendix 1, p. 68). Final report issued November 7, 2005.

MRID 46800049 (NG study):  Chen, W. 2006. Degradation of NOA446510
influenced by soil temperature under cropped and bare soil conditions: A
conceptual model approach to bridge data from laboratory to field.
Unpublished summary report prepared, sponsored, and submitted by
Syngenta Crop Protection, Inc., Greensboro, North Carolina. Syngenta
Study No.: T021955-04. Experimental start date and termination date not
applicable. Final report issued March 22, 2006.

MRID 46800124 (NG study):  Kendall, T. and W. Nixon.  2005.  Analytical
method verification for the determination of NOA446510 in saltwater.
Unpublished study performed by Wildlife International, Ltd., Easton,
Maryland, sponsored and submitted by Syngenta Crop Protection, Inc.,
Greensboro, North Carolina.  Wildlife International Project No.:
528C-123 (p. 8).  Syngenta Study No.: T003405-03.  Experimental start
and termination date November 15, 2004 (p. 8).  Final report issued May
13, 2005.

MRID 46800125 (NG study):  Bruns, G. and S. Nelson.  2004.  Independent
laboratory validation: Syngenta: “Analytical method REM 202.02 for the
determination of NOA-446510 and its metabolite CGA-380778, in soil,
using liquid chromatography-electrospray ionization tandem mass
spectrometry (including validation data).”  Unpublished study
performed by Enviro-Test Laboratories, Edmonton, Alberta, Canada,
sponsored and submitted by Syngenta Crop Protection, Inc., Greensboro,
North Carolina.  ETL Study No.: 04ILV05SYN and Report No.: 04SYN142.REP.
 Syngenta Study No.: T006443-04.  Experimental start and termination
dates not reported; study initiation date September 17, 2004 (p. 8).
Final report issued November 23, 2004.

MRID 46800126 (NG study):  Williams, R.  2003.  Analytical method REM
202.02 for the determination of NOA-446510 and its metabolite
CGA-380778, in soil, using liquid chromatography-electrospray ionization
tandem mass spectrometry (including validation data).  Unpublished study
performed, sponsored and submitted by Syngenta Crop Protection, Inc.,
Greensboro, North Carolina.  Syngenta Study No.: T000056-03.
Experimental start date not reported; study initiation date August 11,
2003 (p. 8).  Experimental termination date September 9, 2003 (p. 8).
Final report issued October 9, 2003.

APPENDIX J. Ecological Toxicity Bibliography

MRID Ecotoxicity Studies Submitted to EPA

MRID 468001-01 Palmer, S.J., et al., NOA446510: A 96-Hour Flow-Through
Shell Deposition Test with the Eastern Oyster (Crassostrea virginica)
Study Completion Date: May 9, 2005 Wildlife International, Ltd., Easton,
MD Syngenta Crop Protection, Greensboro, NC

MRID  468001-02 Palmer, Susan J., et al. NOA446510: A 96-Hour
Flow-Through Acute Toxicity Test with the Saltwater Mysid (Americamysis
bahia) May 10, 2005 Wildlife International, Ltd., Easton, MD Sponsor:
Syngenta Crop Protection, Inc., Greensboro, NC Laboratory Report ID:
528A-137 MRID No.:468001-02

MRID 468001-03 Palmer, Susan J., et al.  2005.  NOA446510: A 96-Hour
Flow-Through Acute Toxicity Test with the Sheepshead Minnow (Cyprinodon
variegatus).  Unpublished study performed by Wildlife International,
Inc., Easton, MD.  Laboratory report number 528A-138.  Study sponsored
by Syngenta Crop Protection, Inc., Greensboro, NC.  Study completed May
9, 2005.

MRID  468001-04 Maynard, S.J. and R.H. Swarbrick.  2005.  NOA446510
Metabolite (CGA380778): Acute Toxicity to Rainbow Trout (Oncorhynchus
mykiss).  Unpublished study performed by Brixham Environmental
Laboratory, Brixham, Devon TQ5 8BA, UK.  Laboratory number BL7958/B.
Study sponsored by Syngenta Crop Protection, Inc.  Study completed
January 4, 2005.

MRID  468001-05 Palmer, S.J., et al.  2006.  NOA446510: A 96-Hour
Flow-Through Acute Toxicity Test with the Fathead Minnow (Pimephales
promelas).  Unpublished study performed by Wildlife International, Ltd.,
Easton, MD.  Laboratory report number 528A-146.  Stud sponsored by
Syngenta Crop Protection, Inc., Greensboro, NC.  Study completed March
7, 2006.

MRID  468001-06 Palmer, S.J., et al.  2006.  NOA446510: A 96-Hour
Flow-Through Acute Toxicity Test with the Rainbow Trout (Oncorhynchus
mykiss).  Unpublished study performed by Wildlife International, Inc.,
Easton, MD.  Laboratory report number 528A-147.  Study sponsored by
Syngenta Crop Protection, Inc., Greensboro, NC.  Study completed March
7, 2006.

MRID  468001-07  Grade, R.  2003.  Daphnia magna Reproduction Test:
Effects of NOA 446510 on the Reproduction of the Cladoceran Daphnia