Dodine Section 3 New Use on Peanuts and Bananas

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON D.C., 20460

OFFICE OF PREVENTION, PESTICIDESDES AND TOXIC SUBSTANCES

PC Code: 044301 DP Barcode: D338148 Date: January 22, 2008 MEMORANDUM

SUBJECT: Ecological Risk Assessment for the Dodine Section 3 New Use on Peanuts and Bananas

TO: Robert Westin, Product Manager Mary Waller, Team Leader Registration Division (7505P)

FROM: Christopher J. Salice, P.h.D, Biologist Marietta Echeverria, Envronmental Scientist Environmental Risk Branch IV Environmental Fate and Effects Division (7507P)

REVIEWED BY: Thomas Steeger, Ph.D., Senior Biologist R. David Jones, Ph.D., Senior Agronomist Environmental Risk Branch IV Environmental Fate and Effects Division (7507P)

APPROVED BY: Elizabeth Behl, Branch Chief Environmental Risk Branch IV Environmental Fate and Effects Division (7507P)

The results of this screening-level risk assessment indicate that the proposed new uses of dodine on peanuts and bananas have the potential for direct adverse effects on listed and non-listed freshwater and estuarine/marine invertebrates, listed and non-listed vascular and non-vascular plants, and listed and non-listed birds and mammals.

Major data gaps are listed below. Without these data potential risk to the associated taxa can not be precluded: • Aquatic vascular plant toxicity data (850.4400)

There is uncertainty regarding the potential chronic effects of dodine to saltwater invertebrates and fish since there are no toxicity data. Using acute-to-chronic ratios (ACR) from freshwater species to calculate chronic endpoints for the saltwater species, however, suggests that risks may be low. The following data would reduce that uncertainty: • Chronic saltwater fish toxicity data (850.1400) • Chronic saltwater invertebrates toxicity data (850.1350)

Recommended Label Language

“For terrestrial uses: Do not apply directly to water, or to areas where surface water is present or to intertidal areas below the mean high water mark. Do not contaminate water when disposing of equipment washwater or rinsate."

“Drift and runoff may be hazardous to aquatic organisms in water adjacent to treated areas.”

“This product may contaminate water through runoff. This product has a potential for runoff for several weeks after application. Poorly draining soils and soils with shallow water tables are more prone to produce runoff that contains this product. A level, well maintained vegetative buffer strip between areas to which this product is applied and surface water features such as ponds, streams, and springs will reduce the potential for contamination of water from rainfall- runoff. Runoff of this product will be reduced by avoiding applications when rainfall is forecasted to occur within 48 hours. Sound erosion control practices will reduce this product’s contribution to surface water contamination.”

"This pesticide is toxic to fish, aquatic invertebrates, oysters and shrimp.”

1. Executive Summary

The Environmental Fate and Effects Division (EFED) has reviewed the proposed label for the use of dodine (n-dodecylguanidine monoacetate; CAS 2439-10-3) and its end-use product SYLLIT® FL (39.6% dodine) fungicide on peanuts and bananas. Dodine is a fungicide of the guanidine group of chemicals and is considered a general toxophore with several sites of action that may differ among members of the guanidine group. Primarily, dodine’s mode of action is through disruptions of cell membranes. An Ecological Risk Assessment was conducted in support of the Reregistration Eligibility Decision (RED) in September 2005 (DP D310539) and assessed dodine use on apples, cherries, peaches,