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United States Environmental Protection Agency Washington, D.C UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, D.C. 20460 OFFICE OF CHEMICAL SAFETY AND POLLUTION PREVENTION MEMORANDUM Date: 26-SEP-2018 SUBJECT: Imidazolinone Herbicides: Imazamox, Imazapic, and Imazethapyr. Draft Human Health Risk Assessment for Registration Review PC Codes: 129171, 129041, 128943, 128922, 128923 DP Barcodes: D446950, D446951, D447462 Decision Nos.: 540766, 540767, 541775 Registration No.: NA Petition No.: NA Regulatory Action: Registration Review Risk Assessment Type: Multiple Chemical/Aggregate Case Nos.: 7238, 7234, 7208 TXR No.: NA CAS Nos.: 114311-32-9, 104098-48-8, 104098-49-9, 81335-77-5; 101917-66-2 MRID No.: NA 40 CFR: §180.1223, §180.490, §180.447 FROM: Cassi L. Walls, Ph.D., Senior Biologist Monique M. Perron, Sc.D., Toxicologist Sarah J. Levy, Chemist Risk Assessment Branch 1 (RAB1) Health Effects Division (HED, 7509P) THROUGH: Christine L. Olinger, Branch Chief George F. Kramer, Ph.D., Senior Chemist RAB1/HED (7509P) TO: Patricia Biggio, Chemical Review Manager Eric Fox, Chemical Review Manager Ricardo Jones, Team Leader Risk Management and Implementation Branch 1 Pesticide Re-Evaluation Division (PRD) (7508P) Matthew Manupella, Chemical Review Manager Katherine St. Clair, Chemical Review Manager Nicole Zinn, Team Leader Risk Management and Implementation Branch 2 Pesticide Re-Evaluation Division (PRD) (7508P) As part of Registration Review, PRD of the Office of Pesticide Programs (OPP) has requested that HED evaluate the hazard and exposure data and conduct occupational and residential exposure assessments, as needed, to estimate the risk to human health that will result from the Page 1 of 19 Imazamox, Imazapic, Imazethapyr Human Health Risk Assessment DP Nos. 446950, 446951, 447462 currently registered uses of pesticides. This memorandum serves as HED’s draft human health qualitative risk assessment of the dietary, occupational and residential exposure, and aggregate risk from the registered uses of the imidazolinone herbicides imazamox, imazapic, and imazethapyr. A quantitative human health risk assessment of imazapyr, also an imidazolinone herbicide, is not required for registration review because the details are presented in a separate document (M. Sahafeyan, D417328, 03/05/2014). A quantitative human health risk assessment for another imidazolinone herbicide, imazaquin, is required and will be presented in a separate document. The most recent human health risk assessments were performed as follows: Imazamox (L. Venkateshwara, D416556, 05/28/2014), Imazapic (W. Wassell, D384054 and D401585, 05/16/2013), and Imazethapyr (H. Johnson, D321723, 11/07/2005). The following risk assessment updates have been made for imazapic: The chronic oral toxicity study in dogs was updated to reflect current practices in hazard evaluation. As a result, effects in the database were only noted in two studies at doses that are not considered relevant for human health risk assessment (>500 mg/kg/day). Therefore, no endpoints were selected for imazapic and a quantitative assessment is not needed. The following risk assessment updates have been made for imazethapyr: The toxicological database and endpoints were reevaluated. No effects were seen at doses relevant for human health risk assessment; therefore, a quantitative assessment is not needed for imazethapyr. Page 2 of 19 Imazamox, Imazapic, Imazethapyr Human Health Risk Assessment DP Nos. 446950, 446951, 447462 Table of Contents 1.0 Executive Summary ........................................................................................................... 4 2.0 Risk Assessment Conclusions ........................................................................................... 5 2.1 Data Deficiencies .......................................................................................................... 5 2.2 Tolerance Considerations ............................................................................................. 6 2.2.1 International Harmonization ......................................................................................... 6 2.3 Label Recommendations .............................................................................................. 7 3.0 Introduction ........................................................................................................................ 7 3.1 Chemical Identity and Physical/Chemical Characteristics ........................................... 7 3.2 Pesticide Use Pattern .................................................................................................... 7 3.3 Anticipated Exposure Pathways ................................................................................... 8 3.4 Consideration of Environmental Justice ....................................................................... 8 4.0 Hazard Characterization and Dose-Response Assessment ............................................ 9 4.1 Endocrine Disruptor Screening Program .................................................................... 10 5.0 Dietary Exposure, Residential and Aggregate Exposure, Non-Occupational Bystander Exposure, Non-Occupational Spray Drift Exposure and Occupational Exposure 11 6.0 Cumulative Exposure/Risk Characterization ............................................................... 11 7.0 Incident and Epidemiological Data Review ................................................................... 12 8.0 References ......................................................................................................................... 15 Appendix A. Literature Search Details ..................................................................................... 16 Appendix B. Toxicity Profile for Imazapic ............................................................................... 17 Page 3 of 19 Imazamox, Imazapic, Imazethapyr Human Health Risk Assessment DP Nos. 446950, 446951, 447462 1.0 Executive Summary The HED has conducted a human health draft risk assessment (DRA) to evaluate all existing registrations of the active ingredients (ai) imazamox, imazapic and its ammonium salt, and imazethapyr and its ammonium salt. These herbicides are members of the imidazolinone class of chemicals that kills weeds by inhibiting the acetolactate synthase (ALS) enzyme, which is also known as acetohydroxyacid synthase (AHAS). This enzyme is involved in the synthesis of three branched-chain aliphatic amino acids. The inhibition causes a disruption in protein synthesis that leads to an interference in DNA synthesis and cell growth. These broad-spectrum contact herbicides target broadleaf weeds, annual or perennial grasses, and vine species in agricultural crops, aquatic areas, and on commercial and residential turf. This assessment was conducted as part of Registration Review. Use Profile Imazamox, imazapic, and imazethapyr are currently registered for use on a variety of agricultural crops, non-crop areas, pasture and rangeland grasses, aquatic areas, and commercial and residential turf. The agricultural crops include alfalfa, beans (dry), canola, chicory, clover grown for seed, corn (field), edamame, legumes, lentil, lima bean (succulent), nongrass animal feeds, peas (dry), pea (English), peanuts, snap bean, soybean, sugarcane, rice, sunflower and wheat. The non-crop areas include railroad, highway, utility, and pipeline rights-of-way, and Conservation Reserve Program land. The commercial and residential turf areas include athletic fields, parks, residential lawns, sod farms, golf courses, and areas around schools/universities, libraries, and hospitals. In addition, there are three Special Local Needs (SLN) registrations for imazamox which provide control of weeds in edamame and Ladino clover grown for seed, and provide for increased residues in irrigation water from the aquatic area use. There is one SLN registration for imazethapyr, which provides additional environmental precautions and soil-type restrictions for the soybean use, and one SLN for imazethapyr, ammonium salt for use on edamame. Exposure Profile Humans may be exposed to imazamox, imazapic, and imazethapyr in food and drinking water since they may be applied directly to growing crops, and applications may result in them reaching surface and ground sources of drinking water. In an occupational setting, applicators may be exposed while handling the pesticides prior to application as well as during applications. There is also potential for post-application exposure for workers re-entering treated fields. In a residential setting, residential adult handlers may be exposed while handling imazamox, imazapic, and imazethapyr and adults and children may be exposed following outdoor applications. Non-occupational exposure resulting from spray drift from agricultural applications onto residential areas may also occur. Hazard Characterization & Dose Response Assessment In the available guideline studies, imazamox, imazapic, and imazethapyr exhibited very low toxicity in mammalian systems, and no effects were seen at doses relevant for human health risk assessment. No additional toxicological studies are currently required, and additional safety factors to protect children are needed. Page 4 of 19 Imazamox, Imazapic, Imazethapyr Human Health Risk Assessment DP Nos. 446950, 446951, 447462 Since no effects were seen in any guideline toxicity studies at doses relevant for human health risk assessment, no toxicological points of departure (PODs) were selected for imazamox, imazapic, and imazethapyr and, as a result, quantitative
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