SUBJECT: Ecological Effects Branch Science Chapter to the

Reregistration Eligibility Document for Picloram Active

Ingredients (Chemical No. 005101, 005102, 005103, 005104)

FROM: Anthony F. Maciorowski, Branch Chief

Ecological Effects Branch

Environmental Fate and Effects Division

TO: Walter Waldrop, PM 71

Reregistration Branch

Special Review and Reregistration Division (7507 W)

Attached please find the Ecological Effects Branch Science Chapter for the Reregistration Eligibility Document (RED)(for Picloram (Case #: 0096). This action was submitted under DP

barcode D188309.

This review was completed in accordance with the format outlined in the September 18, 1992 memorandum from Doug Campt. To better meet the needs of SRRD, an Executive Summary of this risk assessment is presented at the beginning of the document.

If there are any questions concerning this review please contact Bill Evans of my staff on 305-6754.

Executive Summary

Due to the extreme phytotoxicity, its persistence under typical environmental conditions, and its extreme propensity to leach into groundwater in all soil types, the EEB is strongly recommending against the reregistration of all active ingredients of Picloram. This conclusion is based on the extreme exceedance of the acute levels of concern for non-endangered and endangered terrestrial plants.

The risk quotients (RQ) are exceeded as follows for the various

application methods.

UNINCORPORATED GROUND APPLICATIONS

ACTIVE INGREDIENT

(P.C. Code)

NUMBER OF TIMES RISK QUOTIENT EXCEEDED

TIPA Salt

(5102)

4603X

IOE

(5103)

5714X

Potassium Salt

(5104)

8065X

AERIAL APPLICATIONS - SOIL

ACTIVE INGREDIENT

(P.C. Code)

NUMBER OF TIMES RISK QUOTIENT EXCEEDED

TIPA Salt

(5102)

7531X

IOE

(5103)

Potassium Salt

(5104)

12,903X

AERIAL APPLICATIONS - FOLIAR

ACTIVE INGREDIENT

(P.C. Code)

NUMBER OF TIMES RISK QUOTIENT EXCEEDED

TIPA Salt

(5102)

550X

IOE

(5103)

Potassium Salt

(5104)

278X

In 1989 EEB received incident data from a private citizen

who cited 30 incident reports of plant damage resulting from

surface runoff or leaching into groundwater. Based on these

reports, EPA is requesting additional phytotoxicity data for

potatoes and other sensitive crops including tobacco,

soybeans, corn, pasture, watermelons, tomatoes, bell peppers,

and hay. Further, there are sufficient data to state that

picloram will likely cause serious adverse effects in

nontarget terrestrial plants. These additional data are

confirmatory and will support our risk assessment.

Risk Quotients for Aquatic Plants appear to be quite low

for green alga (Selenastrum capricornutum), but 4 aquatic

plant species still remain to be tested, submitted, validated,

and assessed all active ingredients. The risk quotients for

green alga are regarded as a preliminary risk assessment, and

the 4 remaining aquatic plant species will be obtained as

confirmatory data which will be necessary to complete the risk

assessment.

Aquatic Organism Risk

The preliminary aquatic risk assessment indicates that

the Picloram TIPA and Potassium Salts are not likely to affect

nontarget aquatic organisms from ground and aerial

applications on an acute toxicity basis. However, for

endangered species the Potassium salt is likely to adversely

affect fish for ground applications. To complete the aquatic

risk EEB will require the acute LC50s for a coldwater fish

(rainbow trout), a warmwater fish (bluegill), a freshwater and

marine invertebrate, and a marine oyster shell deposition

study for the IOE, and a marine fish study for the Potassium

and TIPA salts.

For chronic hazard the only data available is for the

Potassium salt. The MATCs (Maximum Acceptable Toxicant

Concentrations) for the fish early life stage and the aquatic

invertebrate life-cycle are 700 ppb and 14,600 ppb

respectively, and neither exceeds the chronic level of

concerns. However, Subdivision E section 72-4 requires a fish

early lifecycle test to be submitted if the pesticide is likey

to be continuous or recurrent in water and the pesticide is

highly persistent. Based on this information, the need for

chronic fish studies for the remaining active ingredients is

indicated.

Furthermore, incident data indicate that 15,880 pounds

of fish died from symptoms of chemical poisoning at a fish

hatchery in Sheridan, Montana on July 21, 1989. Picloram

(Tordon 22K) was detected at the scene and the chemical had

been sprayed one quarter mile upstream from the fish hatchery

by Montana State highway personnel. Rain on the day of the

fish kill had washed Picloram into the hatcheries water

source. Although the LC50 data indicates that the risk does

not exceed the LOC, the latest EPA paradigm states that an

incident itself is sufficient to exceed the LOC for acute

risk.

Mammalian Risk

Mammalian acute risks lie within the presumption of low

acute mammalian to non-endangered mammals. However, the

resulting risk quotients for the Picloram TIPA and Potassium

salts trigger the acute levels of concern for endangered

mammalian insectivores, while the acute levels of concern are

are exceeded for endangered mammalian herbivores as well as

insectivores.

Avian Risk

Acute and chronic avian risks lie within the presumption

of low risk to non-endangered and endangered avian species.

No further avian data is required at this time.

Adequacy of Labelling and mitigation

Concerning labelling and mitigation, use rates would have

to be reduced to as low as 0.0003 lb ai/A for the TIPA salt,

0.0000473 lb ai/A for the Isooctyl Ester, and 0.00055 lb ai/A

for the Potassium salt to reduce risks below the LOCs for

terrestrial plants. These rates are further identified in

section C. of the risk assessment. It may be quite likely

that use rates this low may render the pesticide inefficacious

for their intended use. The EEB, therefore, concludes that

practical mitigative measures cannot be identified for all

active ingredients of Picloram.

A. Ecological Toxicity

1. Summary and Review of Terrestrial Organisms Toxicity

a. Toxicity to Avian Species

The following acute and chronic studies have been

reviewed and can be used in risk assessment for birds for

the four active ingredients of Picloram.

AVIAN TEST RESULTS

Picloram 4-amino-3,5,6-trichloropicolinic acid

P.C. Code: 005101

GLN #

TEST TYPE

MRID #

EVALUATION

DATE CLASSIF.

A.I.

TEST

DATE

RESULT

71-1(a)

Mallard, Acute

Oral LD50

Accession #'s

261883

265983

40054501

MRID # 157173

7/1/87

core

93.8

1983

LD50

>2150 mg/kg

This avian study conducted with the technical

grade of the acid indicates that the technical grade of

the active ingredient is practically nontoxic to birds

on an acute oral basis (LD50 > 2150 mg/kg). This was

the only avian study conducted with the acid.

Picloram 4-amino-3,5,6-triisopropanolamine salts (TIPA)

P.C. Code: 005102

GLN #

TEST TYPE

MRID #

EVALUATION

DATE CLASSIF.

A.I.

TEST

DATE

RESULT

71-2(a)

Quail, Dietary

LC50

not listed

10/14/82

supplemental

(not

completed

with TGAI)

10.2

1975

LC50

>10,000

ppm

71-2(b)

Mallard, Dietary

LC50

not listed

10/14/82

supplemental

(not

completed

with TGAI)

10.2

1975

LC50

>10,000

ppm

71-4(a) (Not

required)

Ring-neck

pheasant, Avian

Reproduction

not listed

10/14/82

supplemental

(not

completed

with TGAI or

correct test

species)

10.2

1974

NOEC = 2.8

kg/ha

71-4(a) (Not

required)

Chicken, Avian

Reproduction

not listed

10/14/82

supplemental

(not

completed

with TGAI or

correct test

species)

10.2

1974

NOEC = 2.8

kg/ha

The avian dietary studies conducted with a product

with 10.2 % of the technical grade of the active

ingredient indicate that the test material is

practically nontoxic to birds on an acute dietary basis

(LC50 > 5620). Additionally, two reproduction studies

put NOECs at 2.8 kg/ha.

Picloram Isooctyl Ester (IOE)

P.C. Code: 005103

GLN #

TEST TYPE

MRID #

EVALUATION

DATE CLASSIF.

A.I.

TEST

DATE

RESULT

71-2(a)

Quail, Dietary

LC50

Accession #'s

265982

6/29/87

core

100

1986

LC50

>5620 ppm

71-2(a)

Quail, Dietary

LC50

164726

5/5/88

core

Tech.(%

not

given

1986

LC50

>5620 ppm

The avian dietary studies conducted with the technical

grade of the active ingredient indicate that Picloram

Isooctyl Ester is practically nontoxic to birds on an acute

dietary basis (LC50 > 5620).

Picloram Potassium Salt

P.C. Code: 005104

GLN #

TEST TYPE

MRID #

EVALUATION

DATE CLASSIF.

A.I.

TEST

DATE

RESULT

71-1(a)

Mallard, Acute

Oral LD50

164726

5/20/88

core

tech. (%

not

given)

1985

LD50 > 2250

mg/kg

71-1(a)

Quail, Acute Oral

LD50

164727

5/20/88

core

tech. (%

not

given)

1985

LD50 > 2250

mg/kg

71-2(a)

Quail, Dietary

LC50

REOPIC 08

10/14/82

supplemental

because study

was not

conducted

with TGAI

11.6

1975

LC50 >

10,000 ppm

71-2(a)

Mallard, Dietary

LC50

REOPIC 07

10/14/82

supplemental

because study

was not

conducted

with TGAI

11.6

1975

LC50 >

10,000 ppm

71-2(a)

Mallard, Dietary

LC50

129070

10/14/82

supplemental

because study

was not

conducted

with TGAI

24.4

1975

LC50 >

10,000 ppm

71-2(a)

Quail, Dietary

LC50

129068

10/14/82

supplemental

because study

was not

conducted

with TGAI

24.4

1975

LC50 >

10,000 ppm

71-2(a)

Quail, Dietary

LC50

Accession #'s

261883

265983

40054501

7/1/87

core

38.6

1982

LC50

>5620 ppm

71-4(a) (not

required)

Chicken, Avian

Reproduction

not given

10/14/82

supplemental

was not

conducted

with TGAI and

required

species was

not used

24.4

1978

NOEL = 11.2

kg/ha

The two avian acute oral studies conducted with

the technical grade of the active ingredient imply that

Picloram Potassium Salt is practically nontoxic on an

acute oral basis (LD50 > 2150 mg/kg). Testing on a

products containing 11.2, 24.4, and 38.6% of the the

technical grade of the active ingredient indicate that

this salt is practically nontoxic on an acute dietary

basis (LC50 > 5620). An avian chicken study revealed a

NOEC of 11.2 kg/ha for reproductive effects.

b. Mammalian Toxicity

Picloram 4-amino-3,5,6-trichloropicolinic acid

P.C. Code: 005101

Picloram acid, the parent compound, is practically

nontoxic to mammals based on an acute oral rat LD50 > 5000

mg/kg for males and a LD50 = 4012 mg/kg for females. Acute

inhalation LC50 > 0.035 mg/l for both sexes.

Picloram 4-amino-3,5,6-triisopropanolamine salts (TIPA)

P.C. Code: 005102

The TIPA salt tested with 33.9% a.i. is practically

nontoxic to mammals based on an acute oral rate LD50 > 5000

mg/kg for males and females. The LC50 for an acute

inhalation is > 0.07 mg/l.

Picloram Isooctyl Ester (IOE)

P.C. Code: 005103

The Picloram Isooctyl Ester (IOE) is practically

nontoxic to mammals based on an acute oral rate LD50 = 2830

mg/kg for males and LD50 = 3250 mg/kg for females.

Picloram Potassium Salt

P.C. Code: 005104

The Picloram Potassium Salt TIPA salt tested with 38.8%

a.i. is practically nontoxic to mammals based on an acute

oral rate LD50 > 5000 mg/kg for males and a LD50 = 3536 mg/kg

for females. The LC50 for an acute inhalation is > 1.63

mg/l.

c. Honey Bee Toxicity

Data from a honey bee acute toxicity studies for

all a.i.'s of picloram including the acid, ester, and

salts indicate that Picloram is practically nontoxic to

honey bees with the lowest contact LD50 > 25 micrograms

per bee for the IOE. The data is summarized in the

tables below.

Picloram 4-amino-3,5,6-trichloropicolinic acid

P.C. Code: 005101

GLN #

TEST TYPE

MRID #

EVALUATION

DATE CLASSIF.

A.I.

TEST

DATE

RESULT

141-1

Honey Bee LC50

Study

None

10/29/82

supplemental;

test

conducted

with a

mixture

8.7 as

mixture

1965

LC50> 1000

ppm

No required

guideline

Honeybee LC50

Not given

12/14/82

supplemental

(not required

guideline

requirement)

Aqueous

emulsion

(% not

given

1965

LC50 > 4,000

ppm

No required

guideline

Honeybee LC50

129066

10/29/82

supplemental

(not required

guideline

requirement)

Aqueous

emulsion

(% not

given)

1965

LC50 > 500

ppm

No required

guideline

Honey Bee LC50

None given

12/14/82

supplemental

(not a

required

guideline

requirement)

18.1 as

mixture

1972

significant

mortality

above

controls at

4 lb a.i./

acre

Picloram 4-amino-3,5,6-triisopropanolamine salts (TIPA)

P.C. Code: 005102

GLN #

TEST TYPE

MRID #

EVALUATION

DATE CLASSIF.

A.I.

TEST

DATE

RESULT

141-1

Honey Bee Acute

Contact Study

413669-01

4/90/92

core

5.68

1989

LD50> 100

æg/bee

No required

quideline

Honeybee LC50

No given

10/29/82

supplemental

8.7

1965

LC50

>1000 ppm

No required

quideline

Honeybee Tox.

study

none cited

6/30/82

supplemental

18.1

1972

LC50

< controls

Picloram Isooctyl Ester (IOE)

P.C. Code: 005103

GLN #

TEST TYPE

MRID #

EVALUATION

DATE CLASSIF.

A.I.

YEAR

RESULT

141-1

Honey Bee Acute

Contact Study

421211-07

1/4/93

core

89.7

1991

LD50> 25

æg/bee

141-1

Honey Bee Acute

Contact Study

426259-01

6/3/93

core

4.7 as

mixture

1992

LD50 > 25

æg/bee

Picloram Potassium Salt

P.C. Code: 005104

GLN #

TEST TYPE

MRID #

EVALUATION

DATE CLASSIF.

A.I.

YEAR

RESULT

141-1

Honey Bee Acute

Contact Study

413669-02

4/92

core

35.2

1989

LD50> 100

æg/bee

No required

guideline

Honeybee LC50

Not given

12/14/82

supplemental

because test

not conducted

with TGAI

23.6

1965

LC50 > 5,000

ppm

No required

guideline

Honeybee LC50

Not given

10/29/82

supplemental

because test

not conducted

with TGAI

8.7

1965

LC50> 500

ppm

No required

guideline

Honeybee Tox

study

not given

6/30/82

supplemental

because test

not conducted

with TGAI

24.4

1972

significant

mortality

above

controls at

4 lb a.i./

acre

d. Plant Toxicity

Generally, nontarget plant data are required only

for herbicides and fungicides, but may be required for

any pesticide if phytotoxicity concerns cannot be

resolved from the open literature or existing EEB data

base. Testing can be accomplished at the Tier 1 and/or

Tier 2 level. Before the implementation of the current

policy paper ("the White Paper"or "New Paradigm")

resulting from the Ecological Fate and Effects Task

Force, EEB could request Tier 3 field studies when the

Estimated Environmental Concentration (EEC) exceeds the

EC25 for terrestrial plants or the EC50 for aquatic

plants. At present, Tier 3 plant studies fall under

the current paradigm and Tier 3 studies are no longer

requested, but the criteria noted for mitigation

purposes. The Tier 1 level tests are carried out at the

maximum label rate, and if more than 50% adverse

effects are noted for aquatic plants and 25% adverse

effects for terrestrial plants, Tier 2 testing will be

required. Tier 2 tests use multiple dosages to

determine an EC50 or EC25 and a NOEC for the plant

species tested in Tier 1. Nontarget Phytotoxicity data

is required automatically at the Tier 2 level for all

herbicides applied aerially, via mist blowers, and with

most irrigation equipment. In many cases Tier 1 tests

are bi-passed and the registrant begins with Tier 2

tests. The current data base is presented in the

tables below. Please note that a number of test

species are missing for Tier 2 guidelines.

Picloram 4-amino-3,5,6-trichloropicolinic acid

P.C. Code: 005101

GLN #

TEST TYPE

MRID #

EVALUATION

DATE CLASSIF.

A.I.

TEST

DATE

RESULT

122-1(b)

Vegetative Vigor

Tier 1

261128

(accession no.)

4/29/86

supplemental

(needs to be

repeated or

go to Tier 2)

not

given

1985

No valid

results

122-2

Aquatic plant

Tier 1

261128

(accession no)

4/29/86

core for S.

Capricornutum

93.4

1986

EC50=

36.9mg/l

122-2

Aquatic plant -

freshwater &

saltwater species

(Euglena gracilis

& Pedisastrum

sp.)

none listed

10/29/82

supplemental

1970

NOEC < 24

mg/l

Picloram 4-amino-3,5,6-triisopropanolamine salts (TIPA)

P.C. Code: 005102

GLN #

TEST TYPE

MRID #

EVALUATION

DATE CLASSIF.

A.I.

TEST

DATE

RESULT

122-2

Aquatic plant -

freshwater &

saltwater species

(Euglena gracilis

& Pedisastrum

sp.)

none listed

10/29/82

supplemental

1970

NOEC < 24

mg/l

123-1(a)

Seed Germination

/Seedling Emerg.

- Tier 2

412965-01

5/25/93

supplemental

(NOECs

lacking for

soybean and

EC25 missing

for barley)

6.094

1989

Seed Germ.

Soybean EC25

= 2.3 &

NOEC < 0.25

gae/ha

Barley EC25

> 70 &

NOEC = 35

gae/ha

Seed Emerg.

Soybean EC25

= 0.027 &

NOEC <

0.031

gae/ha

Wheat EC25

= 38.8 &

NOEC = 17.5

gae/ha

123-1(b)

Vegetative Vigor

- Tier 2

412965-01

5/25/93

supplemental

(NOECs

lacking for

soybean &

tomato)

6.094

1989

Tomato EC25

= 0.22 &

NOEC <

0.125

gae/ha

Wheat EC25

= 227.7 &

NOEC = 70

gae/ha

123-2

Growth &

Reproduction of

Aquatic Plants -

Tier 2

414077-01

5/26/93

core for S.

capricornutum

only

5.7

1990

EC50 = 234

mg/l

NOEC = 18.5

mg/l

Picloram Isooctyl Ester (IOE)

P.C. Code: 005103

GLN #

TEST TYPE

MRID #

EVALUATION

DATE CLASSIF.

A.I.

TEST

DATE

RESULT

123-1(a)

Seed Germination/

Seedling Emerg. -

Tier 2

412965-01

5/25/93

supplemental

(NOEC lacking

for drybean)

11.7

1989

Seed Germ.

Drybean EC25

= 1.5 &

NOEC < 0.25

gae/ha

Barley EC25

= 3.6 &

NOEC = 1.1

Seed Emerg.

Drybean EC25

= 0.004 &

NOEC <

0.031

gae/ha

Wheat EC25

= 28.4 &

NOEC = 8.8

gae/ha

123-1(b)

Vegetative Vigor

- Tier 2

412965-01

5/25/93

supplemental

(NOECs

lacking for

soybean)

11.7

1989

Soybean EC25

= 0.24 &

NOEC <

0.125

gae/ha

Wheat EC25

= 235.3 &

NOEC = 70

gae/ha

123-2

Growth and

Reproduction of

Aquatic Plants -

Tier 2

426459-01

6/15/93

core for S.

capricornatum

only

4.7 as

mixture

1993

EC50 = 4.9

mg/l

NOEC = 3.2

mg/l

LOEC = 5.5

mg/l

Picloram Potassium Salt

P.C. Code: 005104

GLN #

TEST TYPE

MRID #

EVALUATION

DATE CLASSIF.

A.I.

TEST

DATE

RESULT

122-1(b)

Vegetative Vigor

Tier 1

261128

(accession no.)

(Hemphill,

D.D.)

4/29/86

supplemental

(needs raw

data or go to

Tier 2)

not

given

for

Tordon

22K

1986

Info. in

summary

form. Need

raw data.

123-2

Growth and

Reproduction of

Aquatic Plants -

Tier 2

414077-02

5/26/93

core for S.

Capricornutum

only

35.2

1990

EC25= 52.6

mg/l

NOEC= 13.1

mg/l

0124-2

Terrestrial Field

Study - Tier 3

(modified)

Acc. #

261128 (Herr,

Stroube, Ray)

4/29/93

supplemental,

can't be up-graded; many

deviations

from protocol

not

given

for

Tordon

product

1986

Cannot be

accessed

due to

insuff. no.

plant spp.

124-2

Terrestrial Field

Study - Tier 3

(modified)

Acc. #

261128

4/29/93

supplemental,

can't be up-graded; many

deviations

from protocol

21.5

1986

Cannot be

accessed

due to

insuff. no.

plant spp.

124-2

Terrestrial Field

Study - Tier 3

(modified)

Acc. #

261128

4/29/86

supplemental,

can't be up-graded; many

deviations

from protocol

not

given

1986

Cannot be

accessed

due to

insuff. no.

plant spp.

123-1(a)

Seed Germination/

Seedling Emerg. -

Tier 2

412965-01

5/25/93

supplemental

(lacks NOECs

for soybean &

drybean and

lacks EC25 for

barley)

0.2885

1989

Seed Germ.

Soybean EC25

= 3.5 &

NOEC = 0.25

gae/ha

Barley EC25

> 70 &

NOEC = 4.4

gae/ha

Seed Emerg.

Soybean EC25

= 0.014 &

NOEC <

0.031

gae/ha

Wheat EC25

= 23.5 &

NOEC = 8.8

gae/ha

123-1(b)

Vegetative Vigor

- Tier 2

412965-01

5/25/93

core for veg.

vigor test of

K-salt only

0.2885

1989

Soybean EC25

= 0.4 &

NOEC =

0.125

gae/ha

Wheat EC25

= 310 &

NOEC = 70

gae/ha

2. Aquatic Organism Toxicity

a. Toxicity to Freshwater Organisms

The following table summarizes the acute and

chronic data which can be used in risk assessment for

freshwater organisms for the four active ingredients of

Picloram.

Picloram 4-amino-3,5,6-trichloropicolinic acid

P.C. Code: 005101

GLN #

TEST TYPE

MRID

EVALUATION

DATE CLASSIF.

A.I.

TEST

DATE

RESULT

72-1(a)

Bluegill, Acute

LC50

00129078

10/15/82

core

92.74

1978

LC50= 19.4

mg/l

72-1(a)

Bluegill, Acute

LC50

112016

10/14/82

core

92.9

1974

LC50= 14.5

mg/l

72-1(c)

Rainbow, Acute

LC50

112016

10/14/82

core

92.9

1974

LC50=

5.50

mg/l

72-2(a)

Daphnia, Acute

LC50

0096-008

12/21/88

core

1977

LC50=

34.4

mg/l

72-6

Aquatic Org.

Accum. (Bluegill)

1218947 (acces.

no.)

7/29/82

core, but was

classified as

supplemental

because it

was never

required for

registration

99.6

1980

< 1 (Won't

accum.in

aquatic

organisms)

72-6

Aquatic Org.

Accum. (Channel

Catfish)

none listed

10/14/82

core, but was

classified as

supplemental

because it

was never

required for

registration

99.6

1980

< 1 (Won't

accum.in

aquatic

organisms)

N.A.

Field runoff

conditions for

cutthroat trout

129085

12/6/82

Supplemental

because it

was never

required for

registration

1979

Study

concludes

that conc.

as low as

610 æg/l

will affect

survival &

growth.

N.A.

Field runoff

conditions for

cutthroat trout

REOPICO2

10/14/82

supplemental

because it

was never

required for

registration

1979

Study

concludes

that conc.

as low as

290 æg/l

will affect

survival &

growth.

The above table characterizes the Picloram acid as

moderately toxic to freshwater fish with a LC50 of 5.5

mg/l (ppm) and slightly toxic to freshwater

invertebrates (LC50 of 34.4 mg/l). Field runoff

studies conducted with cuttroat trout concludes that

concentrations as low as 290 æg/l and 610 æg/l will

affect survival & growth of cuttroat trout. These two

studies appear to be the same study but were reviewed

by the same contract reviewer a few months apart. Due

to the lack of details in the reviews of these studies,

conclusions of an NOEC or LOEC as low as 290 æg/l

cannot be confirmed without a rereview of the original

study.

There are no records indicating that tests for

freshwater invertebrates (Daphia magna) have been

conducted. Since the acid is not used as an end

product, EEB will not require this test.

Picloram 4-amino-3,5,6-triisopropanolamine salts (TIPA)

P.C. Code: 005102

GLN #

TEST TYPE

MRID

EVALUATION

DATE CLASSIF.

A.I.

TEST

DATE

RESULT

72-1(c)

Rainbow, Acute

LC50

not listed

10/14/82

supplemental

98-99

1968

LC50=

375

mg/l

72-1(d)

Rainbow, Acute

LC50 - TEP

not listed

10/29/82

supplemental

8.1

1968

LC50=

25 mg/l

72-1(d)

Rainbow, Acute

LC50 - TEP

not listed

10/29/82

supplemental

2.5

1968

LC50=

1250 mg/l

No guideline

requirement

Coho salmon,

Acute LC50

not listed

10/29/82

supplemental

10.2

1979

LC50=

20 mg/l

The above table characterizes this Picloram salt

as slightly toxic to freshwater fish with a LC50 of 25

mg/l (ppm). However, a test with coho salmon yielded a

LC50 of 20 ppm. There are no records indicating that

tests for freshwater invertebrates (Daphia magna) have

been conducted, and since this salt is used for the

manufacture of several end products, EEB will require

this test.

Picloram Isooctyl Ester (IOE)

P.C. Code: 005103

There is no data for freshwater organisms for the

isooctyl ester of Picloram. At a minimum EEB will

require the acute LC50s for a coldwater fish (rainbow

trout), a warmwater fish (Bluegill), and a freshwater

invertebrate (Daphnia magna).

Picloram Potassium Salt

P.C. Code: 005104

GLN #

TEST TYPE

MRID

EVALUATION

DATE CLASSIF.

A.I.

TEST

DATE

RESULT

72-1(a)

Bluegill, Acute

LC50

GS0096-007

10/29/82

supplemental

due to lack

of raw data

1966

LC50= 24

mg/l

72-1(c)

Rainbow, Acute

LC50

GS0096-007

10/29/82

supplemental

due to lack

of raw data

1966

LC50= 13

mg/l

72-1(d)

Rainbow, Acute

LC50

Not given

10/14/82

core for

formulated

product only

24.4

1977

LC50=

26 mg/l

72-2(a)

Daphnia, Acute

LC50

151783

5/20/85

core

93.8

1984

LC50 = 68.3

mg/l

72-2(b)

Daphnia, Acute

LC50 (TEP)

Not given

10/14/82

supplemental

(not

conducted

with TGAI)

88.6

1977

LC50 = 226

mg/l

72-4(a)

Rainbow Trout,

Early life Stage

151784

2/12/85

core

93.8

1984

LOEC= 0.88

mg/l

NOEC= 0.55

mg/l

MATC= 0.70

mg/l

72-4(b)

Life-Cycle

Aquatic

Invertebrate

151783

5/20/85

core

93.8

1984

MATC= 14.6

mg/l

NOEC= 11.8

mg/l

LOEC= 18.1

mg/l

The above table characterizes this Picloram

Potassium salt as moderately toxic to freshwater fish

with a LC50 of 13 mg/l (ppm) and slightly toxic to

freshwater invertebrates (LC50 of 68.3 mg/l). The fish

early life stage and the Life-Cycle Aquatic

Invertebrate Studies gave LOECs of 0.88 mg/l and 18.1

mg/l respectively as indicated.

b. Toxicity to Marine/Estuarine Organisms

As the use of products containing picloram may be

expected to enter a marine/estuarine environment a

limited amount of data which can be used in risk

assessment for marine/estuarine organisms is required.

The data presently reviewed for the marine/estuarine

studies are presented below.

Picloram 4-amino-3,5,6-trichloropicolinic acid

P.C. Code: 005101

There is no marine/estuarine data for the parent

compound Picloram acid. As no products containing the

acid are used for anything other than manufacturing use

product, no data requirements are required at this

time.

Picloram 4-amino-3,5,6-triisopropanolamine salts (TIPA)

P.C. Code: 005102

GLN #

TEST TYPE

MRID

EVALUATION

DATE CLASSIF.

A.I.

TEST

DATE

RESULT

72-3(e)

Oyster, Shell

deposition EC50

not listed

10/14/82

supplemental

(not tested

with TGAI)

10.3

1975

10 < EC50 <

18 ppm

72-3(f)

Shrimp, Acute

EC50

not listed

10/14/82

supplemental

(not tested

with TGAI)

10.3

1975

EC50 = 306

ppm

The above table characterizes this Picloram salt

as slightly toxic to marine/estuarine mollusc with an

EC50 between 10 and 18 mg/l (ppm) and practically

nontoxic to marine crustaceans (EC50 =306 ppm). As

this salt is lacking data on marine/estuarine fish, an

acute marine/estuarine fish study will be required.

Picloram Isooctyl Ester (IOE)

P.C. Code: 005103

There is no data for marine/estuarine or

freshwater organisms for the isooctyl ester of

Picloram. As the use of products containing picloram

may be expected to enter a marine/estuarine environment

a limited amount of data which can be used in risk

assessment for marine/estuarine organisms is required.

At a minimum EEB will require the acute LC/EC50s for

marine/ fish, mollusc, shrimp studies.

Picloram Potassium Salt

P.C. Code: 005104

GLN #

TEST TYPE

MRID

EVALUATION

DATE CLASSIF.

A.I.

TEST

DATE

RESULT

72-3(e)

Oyster, 48-h

Embryo Larvae

EC50

111560

10/14/82

core for

formulated

product only

11.6

1975

EC50> 1000

ppm

72-3(e)

Oyster, 48-h

Embryo Larvae

EC50

129073

10/14/82

core for

formulated

product only

24.9

1975

18 ppm <

EC50 < 32

ppm

The above table also characterizes this Picloram

salt as slightly toxic to marine/estuarine molluscs and

invertebrates with an EC50 between 18 and 32 mg/l

(ppm). As with the TIPA salt this salt is lacking data

on marine/estuarine fish, an acute marine fish study

will be required.

B. Ecological Effects Risk Assessment

1. Use Profile

As Picloram is produced in the forms of an acid, two

salts, and an ester, each is represented as a separate

active ingredient. However, the acid is not used as an end

use product, and risk assessment is consequently limited to

the salts and esters. The use profiles for the products

only for these active ingredients are characterized.

Picloram 4-amino-3,5,6-triisopropanolamine salts (TIPA)

P.C. Code: 005102

The five products currently registered which contain

mixtures of this picloram salt (TIPA) with 2,4,D are listed

below.

- Tordon 101 mixture (10.2% TIPA, 39.6% 2,4,D)

(EPA Reg. No. 62719-5)

Weed and Brush Killer

- Grazon P+D (10.2% TIPA, 39.6% 2,4,D)

(EPA Reg. No. 62719-182)

Range and Pasture Management

- Tordon 101 R (5.4% TIPA, 20.9% 2,4,D)

(EPA Reg. No. 62719-31 (formerly 464-510))

Forestry Herbicide

(Control unwanted trees via cut surface treatment)

- Tordon RTU (5.4% TIPA, 20.9% 2,4,D)

(EPA Reg. No. 62719-31)

Weed and Brush Control

(Control unwanted trees via cut surface treatment)

- Pathway (5.4% TIPA, 20.9% 2,4,D)

(EPA Reg. No. 62719-31)

Vegetation Management

(Control unwanted trees via cut surface treatment)

It should be noted that the last three products essentially

have the same reg. no. and differ only in the title of the use

sites. The label wording for Tordon RTU and Pathway are

identical. These three pesticides are not restricted to use by

certified applicators only. The products are used for the

control of unwanted trees in forests, non-cropland areas such as

fence rows, roadsides and rights-of-way and are applied by tree

injection, frill or girdle treatment, or stump treatment. This

treatment can be applied during any season and there are no

limitations on the maximum number of treatments per season. The

maximum rate per application is also unclear. For the tree

injection method 1 ml of undiluted product is injected at

intervals of 2 - 3 inches between the edges of injector wounds,

however, it is not specified if 1 ml is injected at each interval

or whether a total of 1 ml of product is injected per tree.

Concerning these problems, DowElanco was contacted and replied by

fax (copy attached dated October 22, 1993) that the rate of 0.168

lb ai/A could be applied at an application by injection method.

They further state that these injection applications are

"typically applied" once every 3 to 4 years at most.

Tordon 101 mixture and Grazon P+D are both Restricted Use

Pesticides and can be applied by both aerial and ground

equipment. Grazon P+D is registered for use in New Mexico,

Oklahoma, Texas, Arkansas, Louisiana, Alabama, Georgia, and

Mississippi only and is applied to range and pasture at a maximum

rate of 1 gallon/acre or 0.54 lbs a.i./acre (245 g/A) once a

year. Tordon 101 mixture, however, has no maximum seasonal and

repeated applications or intervals between applications are not

restricted. It is used "for the control of unwanted annual and

perennial broadleaved weeds and woody plants and vines on forest

planting sites and non-crop areas including industrial

manufacturing and storage sites, right-of-ways such as electrical

power lines, communication lines, pipelines, highways, railroads,

and wildlife openings in forest and non-crop areas". The maximum

rate for single applications varies with the type of target plant

treated. These rates are summarized in the table below.

TARGETED PLANT GROUP

MAXIMUM SINGLE APPLICATION RATE

Broadleaved Annual &

Perennial Weed & Vines &

Woody Plants

2 gal ai/A = 1.1 lbs ai/A =

499.4 gae/A

Conifer Strip Thinning in

the Northeast U.S.

3 gal ai/A = 1.6 lbs ai/A =

735.5 gae/A

Broadcast Cut Stubble

Treatment

4 gal ai/A = 2.2 lb ai/A = 980

gae/A

Picloram Isooctyl Ester (IOE)

P.C. Code: 005103

Access (EPA Reg. No. 464-576) is the only product currently

registered for this isooctyl ester (IOE) of picloram mixed with

32.5% Triclopyr. This pesticide is restricted to use by

certified applicators only "for control of unwanted woody plants

in forests, rights-of-way such as electrical power lines,

communication lines pipelines, roadsides, and railroads and on

non-crop areas including industrial manufacturing and storage

sites and fence rows". It can be applied during any season and

the maximum number of treatments per season or intervals is not

addressed. Access is applied as a basal bark treatment by

backpack sprayer only either diluted or undiluted. It can be

diluted as 2 gallons (908 g ae) of product in enough oil to make

100 gallons of spray mixture and applied with a backpack sprayer

using low pressure (20 to 40 psi) at the spray nozzle or it can

be diluted as 30 gallons (13,620 g ae) of product to make 100

gallons and applied as a low volume treatment using low pressure

and a cone or flat fan nozzle. The only apparent difference with

these two dilutions is that the low volume treatment does not wet

the stem to the point of runoff. Alternatively, Access may be

applied undiluted "in a thin stream to all sides of the lower

stems". Between 2 to 15 ml (0.0005284 to 0.003969 g ae) is

required for treatment of a single stem. As discussed above

concerning the tree injection applications of the TIPA salt,

DowElanco was contacted (see fax dated November 3, 1993) to

address these issues. According to this communication, trees 1

to 6 inches in diameter require 5 to 30 milliliters per tree. A

maximum density situation would involve treating 500 stems per

acre. This would require 15,000 ml (3.96 gallons) of product per

acre. As a 30% dilution 1.19 gallons of Access would be applied

per acre. Since there is 1 lb ai/gallon, the maximum rate on a

per acre basis is 1.19 lb ai/A. A similar scenario was used to

arrive at a 0.24 lb ai/A amount for the 2% dilution. However,

the undiluted treatment of 15 ml yields a maximum application

rate of 2 lb ai/A (500 stems x 15 ml)/3785 ml/gallon).

Therefore, the maximum rate used for the risk assessment for this

Isooctyl ester is 2.00 lb ai/A. It should also be noted that the

EEB is in the process of verification of the vegetation density

assumption of 500 stems per acre.

Picloram Potassium Salt

P.C. Code: 005104

The Picloram Potassium Salt (K-Salt) is represented by three

end use products as listed below.

- Tordon 22K (24.4% a.i.)

(EPA Reg. No. 62719-6)

Small grain Control

- Tordon K (24.4% a.i.)

(EPA Reg. No. 62719-17)

Industrial Rights-of-Way and Forestry Control

- Grazon PC (24.4% a.i.)

(EPA Reg. No. 62719-181)

Range and Pasture Control

All the end-use products of this salt are Restricted Use

Pesticides and can be applied by both aerial and ground

equipment. Grazon PC is registered for use in New Mexico,

Oklahoma, and Texas only and is applied to range and permanent

grass pasture at a maximum rate of 1 gallon/acre or 2 lbs

a.i./acre (908 g/A) once a year even though the label recommends

not to use more than 1 quart/acre or 0.54 lb a.i./acre (227 g/A)

lbs for high-volume foliar applications. It is used to control

broadleaf annual and perennial weed, pricklypear, mesquite and

other species and can be applied employing both ground and aerial

equipment.

Tordon K is used for control of unwanted annual and

perennial broadleaved weeds, woody plants, and vines on non-crop

areas including forest planting sites, industrial manufacturing

and storage sites, right-of-ways such as electrical power lines,

communication lines, pipelines, highways, railroads, and wildlife

openings in forest. There are no limitations on the maximum

number of treatments per season. Tordon K can be applied using

several application methods including high-volume leaf/stem

treatment, spot treatment, broadcast ground or aerial foliage

treatment, and broadcast cut stubble treatment. The maximum

single application rate is 2 quarts per acre or 1 lbs a.i./acre

(454 g/A) except for the the broadcast cut stubble treatment

which is 1 gallon/A or 2 lbs a.i./acre (908 g/A).

Tordon 22K can be applied west of the Mississippi on

rangeland and permanent grass pastures, fallow cropland, wheat,

barley, oats, non-crop land (such as roadsides or other rights-of-way, along fence rows, and around farm building), on

Conservation Reserve Program (CRP) and wildlife openings in

forest. Treatments can be applied by aerial application or spot

treatment. Although not specifically stated, it is inferred that

Tordon 22K is applied one time per season with a maximum rate of

1 quart/A or 1/2 lb a.i./acre (227 g/A) for broadcast

applications and 1 gallon/A or 2 lb a.i./acre (908 g/A) for spot

treatmeats. Maximum broadcast and spot treatment rates are

summarized in the table below for various plant groups.

TARGETED PLANT GROUP

MAXIMUM SINGLE APPLICATION RATE

(Broadcast and Spot Treatments)

Woody plants and Broadleaf

Weeds

Broadcast rate:

1 quart ai/A = 1/2 lb ai/A =

227gae/A

Spot treatment rate:

1 gal ai/A = 2 lb ai/A = 908

gae/A

Non-Cropland Areas such as

rights-of-way, fence rows,

and around farm buildings

Broadcast rate:

1/2 gal ai/A = 1 lb ai/A = 454

gea/A

Rangeland and permanent

Grass Pastures

Broadcast & Spot treatment

rates:

1 quart ai/A = 1/2 lb ai/A =

227 gae/A

Barley, Oats, and Wheat Not

Underseeded With a Legume

Broadcast rate:

1 1/2 fl oz ai/A = 0.01 gal

ai/A = 0.02 lb ai/A = 0.00004

gae/A

Fallow Cropland (Not Rotated

to Broadleaf Crops)

Broadcast rate:

1 pint ai/A = 1/4 lbs ai/A =

114 gae/A

Spot treatment rate:

1 gal ai/A = 2 lb ai/A = 908

gae/A

Conservation Reserve Program

(CRP) for Seeding to

Permanent Grasses Only

Broadcast rate:

1 quart ai/A = 1/2 lb ai/A =

227 gae/A

Spot treatment:

1 gal ai/A = 2 lb ai/A = 908

gae/A

2. Environmental Fate and Residues

The detailed characterization of the environmental fate

of the Picloram active ingredients is detailed in the EFGWB

science chapter. After conversations with EFGWB review

scientists it was concluded that EEB has enough

environmental fate information on Picloram to finish its

assessment. The following paragraphs briefly summarizes the

EFGWB science chapter.

The water solubility of the Picloram active ingredients

exceeds 100 ppm and is considered very soluble for the acid

and the two salts. The Picloram acid water solubility is

560 ppm, while that of the Potassium salt is 740,000 ppm at

200 C. The Isooctyl Ester water solubility is considerably

lower at 0.23 ppm at 200 C.

Picloram is extremely mobile in sandy loam, clay, and

sand soils with a high organic matter content. Data

indicate that it is stable to aqueous and soil photolysis as

well as microbial degradation. EFGWB has concluded that the

active ingredients containing Picloram has a very high

potential to leach into groundwater and is recommending

against reregistration. Further, due to its high

persistence in coarse-textured soils, it appears that

Picloram will not degrade over a number of years once in

groundwater.

3. Terrestrial Risk Assessment (Non-endangered and

Endangered Species)

The principles of ecological risk assessment used to

regulate pesticides under the Federal Insecticide,

Fungicide, and Rodenticide Act (FIFRA) are explained in the

EPA Standard Evaluation Procedures (SEP). These procedures

define risk in the form of a risk ratio (RQ) comparing the

potential estimated exposure to the greatest experimental

toxicity level obtained.

The potential estimated exposure is represented by the

calculation of an Estimated Environmental Concentration

(EEC) based on application rates, intervals, frequencies,

and other quantitative information found on the label. The

greatest toxicity level comes from the results of studies

which are required for registration. As Picloram is

produced in the forms of an acid, two salts, and an ester,

each is represented as a separate active ingredient.

However, the acid is not used as an end use product, and

risk assessment is consequently limited to the salts and

esters.

a. Avian - Dietary Exposure

i. Non-endangered Species - The criterion for the

determination and presumption of low avian risk based

on acute toxicity data for non-granular pesticides is a

value less than one ( <1 ) for the quotient of the EEC

divided by one half of the lowest LC50 value for birds

- this is known as the risk quotient or RQ.

The EEC is based on the maximum application rate of lb

ai per acre. EEB uses the methods of Kenaga and

Hoerger as outlined in the SEP cited above to determine

the maximum terrestrial residues expected. These

methods are based on a single application rate, and do

not take into account repeated applications or the

total amount applied or available per season. The EECs

and the corresponding Risk Quotients for each active

ingredient of Picloram products are presented below and

summarized in a table.

Picloram 4-amino-3,5,6-triisopropanolamine salts (TIPA)

P.C. Code: 005102

The maximum application rate for the Picloram TIPA Salt

is 2.2 lb ai/acre. The residues found on dietary food

items following a single application at the maximum

application rate are presented below as adapted from

Kenaga and Hoerger.

Use Sites Residues (ppm)

Range grasses (short) 528

Long grasses 242

Leaves and leafy crops 275

Forage crops (small insects) 128

Pods containing seeds

(large insects) 26

Fruits 15

Soil (Top 1 inch) 49

These residues found on dietary food items following

application may be compared to LC50 values to arrive at

a risk quotient as discussed above. The avian acute

toxicity levels come from the studies summarized in the

Toxicity Tables discussed above.

For this TIPA salt the highest expected residue is 528

ppm on short range grasses. The lowest LC50 is greater

than 10,000 ppm on a supplemental study. The RQ for

acute effects is 0.1056 (528/(10,000/2)) indicting a

low avian dietary risk. Use rates greater than about

20.8 lbs a.i./A are expected to result in acute RQs

greater than 1.

The remaining EECs and Risk Quotients (as well as the

TIPA information presented above) are summarized in the

table below.

ACTIVE

INGREDIENT

(P.C Code)

DIETARY

LC50

(ppm)

HIGHEST

CALCULATED EEC

VALUE (ppm)

Risk

Quotient

(EEC/(LC50/2))

USE RATE (lb

ai/A)

REQUIRED TO

BRACKET RISK

QUOTIENT

(LC50/2)/240)

TIPA Salt

(5102)

10,000

528

0.1056

> 20.8

IOE (5103)

> 5620

480

0.171

> 11.7

Potassium

Salt

(5104)

> 5620

480

0.171

> 8.3

The resulting risk quotients for the Picloram salts and IOE lie

within the presumption of low acute avian risk to non-endangered

species.

ii. Endangered Species - The criterion for the

determination and presumption of low avian risk for

endangered species based on acute toxicity data for

non-granular pesticides is a risk quotient value less

than one ( <1 ) for the quotient of the EEC divided by

one tenth of the lowest LC50 value for birds. Using

the EEC values from the maximum residue values as

calculated above the resulting risk quotients as well

as the use rate required to bracket the level of

concern for endangered species for all the active

ingredients containing Picloram are presented in the

table below.

ACTIVE

INGREDIENT

(P.C Code)

DIETARY

LC50

(ppm)

HIGHEST

CALCULATED EEC

VALUE (ppm)

Risk

Quotient

(EEC/(LC50/10))

USE RATE (lb

ai/A)

REQUIRED TO

BRACKET RISK

QUOTIENT

(LC50/10)/240)

TIPA Salt

(5102)

10,000

528

0.528

> 4.2

IOE (5103)

> 5620

480

0.854

> 2.34

Potassium

Salt

(5104)

> 5620

480

0.854

> 2.34

The resulting risk quotients for the Picloram salts and IOE lie

within the presumption of low acute risk to endangered avian

species.

b. - Avian Chronic Risks

For chronic risks the criterion for the determination

of low avain risk to non-endangered and endangered

species is a risk quotient < 1 with an EEC < LEL.

According to the supplemental studies conducted more

than 10 years ago NOELs of 2.8 kg ai/ha (15.2 lb ai/A)

for the TIPA salt and 11.2 kg ai/ha (60.9 lb ai/A) for

the Potassium salt resulted. As the maximum residues

likely to be expected in with a use rate of 2.2 lb/A is

528 ppm as discussed above, the maximum expected

residue at the NOEL is 3648 ppm (15.2 lb ai/A x 240

ppm/lb ai). This chronic level effect is well within

the presumption of low avian risk (528 ppm < 3648 ppm).

c. Avian - Acute Exposure (Non-endangered and

Endangered) - EEB estimates risk from Granular

pesticide formulations by calculating the number

of LD50s per square feet. However, since all

products of this salt are non-granular or water

dispersible pesticides estimation of acute risk by

this method is not applicable.

d. Mammalian acute exposure

i. Non-endangered Species - An acute exposure for

mammals may be estimated by converting an experimental

mammalian (eg. rat or mouse) LD50 to an estimated LC50

value. The procedure used to determine risk is

illustrated with the TIPA Salt as follows.

The LC50S for three animals representative of small

wild mammals were calculated using the following

formula which estimates the LC50 using the actual LD50

value. The lowest LD50 value was greater than 5000

mg/kg.

Lowest LD50 mg/kg X Body Weight (gms)

LC50/Day = ÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄ

Weight Consumed (gms)

TABLE OF SMALL MAMMAL FOOD CONSUMPTION (LD50= 5000 mg/kg)

SMALL MAMMAL BODY WEIGHT FOOD ESTIMATED

WEIGHTS EATEN/DAY CONSUMED ONE DAILY

(gms) (%) /DAY (gms) LC50S

(ppm)

Meadow vole

(herbivore) 46 61 28.1 8185

Old field mouse

(granivore) 13 16 2.1 30952

Least shrew

(insectivore) 5 110 5.5 4545

Table 5 above was obtained from a table published in: Davis, D.

E. and F. Golly, 1963. Principles of Mammology. Reinhold Corp.

The criterion for the determination of the presumption of no risk

for small mammals is the same as that used for avian risk

assessments discussed above (i.e. RQ = EEC/(1/2 X LC50)). Again,

the maximum expected residue or EEC is 528 ppm. The risk ratios

for the three representative animals discussed above are as

follows.

SMALL MAMMALS Risk Quotients

Meadow vole (herbivore) 528/(8185/2) = 0.129

Old field mouse (granivore) 528/(30952/2) = 0.034

Least shrew (insectivore) 528/(4545/2) = 0.232

Using the EEC values from the maximum residue values as

calculated above the resulting risk quotients as well as the use

rate required to bracket the level of concern for endangered

species for all the active ingredients containing Picloram are

presented in the table below.

ACTIVE

INGREDIENT

(P.C Code)

MAMMAL LC50

(ppm)

HIGHEST

CALCULATED

EEC VALUE

(ppm)

Risk

Quotient

(EEC/(LC50/2))

USE RATE

(lb ai/A)

REQUIRED TO

BRACKET

RISK

QUOTIENT

(LC50/2)/240

TIPA Salt

(5102)

LD50 > 5000

mg/kg

8185

Meadow vole

(herbivore)

30952

Old field

mouse

(granivore)

4545

Least shrew

(insectivore)

528

0.129

0.034

0.232

> 6.82

> 64.5

> 9.47

IOE (5103)

LD50 = 2830

mg/kg

4632

Meadow vole

(herbivore)

17519

Old field

mouse

(granivore)

2572.7

Least shrew

(insectivore)

480

0.207

0.055

0.373

9.65

36.5

5.36

Potassium

Salt

(5104)

LD50 = 3536

mg/kg

5788.5

Meadow vole

(herbivore)

21889.5

Old field

mouse

(granivore)

3214.6

Least shrew

(insectivore)

480

0.166

0.044

0.299

12.06

45.6

6.7

The resulting risk quotient for the Picloram salts and IOE lie

within the presumption of low acute risk to non-endangered

mammals. Based on this use pattern it is can be concluded that

the Picloram salts and IOE do not trigger a level of concern for

available acute toxicity data.

ii. Endangered Species - The criterion for the

determination and presumption of low mammalian risk for

endangered species based on acute toxicity data is a

risk quotient value less than one ( <1 ) for the

quotient of the EEC divided by one tenth of the lowest

LC50 value for rats or other small mammals. Using the

EEC values from the highest avian data, the resulting

risk quotients as well as the use rate required to

bracket the level of concern for endangered species for

all the active ingredients containing Picloram are

presented in the table below.

ACTIVE

INGREDIENT

(P.C Code)

MAMMAL LC50

(ppm)

HIGHEST

CALCULATED

EEC VALUE

(ppm)

RISK

QUOTIENT

(EEC/(LC50/10))

USE RATE

(lb ai/A)

REQUIRED TO

BRACKET

RISK

QUOTIENT

LD50/10)/240

TIPA Salt

(5102)

LD50 > 5000

mg/kg

8185

Meadow vole

(herbivore)

30952

Old field

mouse

(granivore)

4545

Least shrew

(insectivore)

528

0.645

0.17

1.16

3.4

12.9

1.9

IOE (5103)

LD50 = 2830

mg/kg

4632

Meadow vole

(herbivore)

17519

Old field

mouse

(granivore)

2572.7

Least shrew

(insectivore)

480

1.036

0.274

1.866

1.93

7.3

1.07

Potassium

Salt

(5104)

LD50 = 3536

mg/kg

5788.5

Meadow vole

(herbivore)

21889.5

Old field

mouse

(granivore)

3214.6

Least shrew

(insectivore)

480

0.829

0.219

1.5

2.41

9.12

1.34

The resulting risk quotients for the Picloram TIPA and Potassium

salts slightly exceed the acute levels of concern only for

endangered mammalian insectivores. The levels of concern for the

IOE are exceeded for endangered mamalian herbivores as well as

insectivores.

e. Chronic Mammalian Risks

For chronic risks the criterion for the determination

of low mammalian risk to non-endangered and endangered

species is a risk ratio < 1 with an EEC < LEL.

However, as acute risks are low based on LC50s, EEB has

not requested chronic studies.

f. Honey bee acute exposure

As mentioned above bee acute toxicity studies indicate

that all active ingredients of Picloram are practically

nontoxic to honey bees with a contact LD50 > 25

micrograms per bee.

g. Exposure to Plants

The criterion for the determination of the presumption

of low risk risk quotients for terrestrial plant

species is when the calculated EEC < EC25 for the most

sensitive species tested. The presumption of no risk

for aquatic plants is when the calculated EEC < EC50

for the most sensitive species. Both these criteria

apply to non-endangered and endangered plant species.

h. Terrestrial Plants

i. Unicorporated Ground Applications

Terrestrial Plant EEC calulations for unincorporated

ground applications are expressed as the runoff

scenarios for terrestrial nontarget plants from an

application which assumes 1% to 5% runoff (depending on

water solubility) from 1 acre onto an adjacent acre.

The following water solubilities determine the percent

runoff to use.

Water Solubilitity % Runoff Assumed

< 10 ppm 1%

10 - 100 ppm 2%

> 100 ppm 5%

The lb ai runoff potential (EEC) impacting a 1 acre

site is expressed as the following formula.

Runoff = maximum x % runoff x 1 acre

Potential appl. rate

(lb ai)

The procedure used to determine risk is illustrated

with the TIPA Salt below. The EECs and the

corresponding Risk Quotients for each active ingredient

of Picloram products are summarized in a table.

Picloram 4-amino-3,5,6-triisopropanolamine salts (TIPA)

P.C. Code: 005102

As pointed out in the Use Profile section above,

the maximum application rate can not be determined due

to the lack of limitations on the maximum number of

treatments per season or intervals between treatments.

The only maximum application rate for the Picloram

Triispropanolamine Salts which can be used at this time

is the single application rate of 2.2 lb ai/acre used

for the Tordon 101 broadcast stubble cut treatment.

Using this single application rate and the 5% runoff

assumption the estimated EEC is 0.11 lb ai (2.2 lb ai x

5% runoff x 1 acre) which can potentially affect an

adjacent 1 acre site. The seed germination and

seedling emergence EC25s for soybeans, the most

sensitive plants tested, are 0.002 lb ai/A (2.3 gae/ha)

and 0.0000239 lb ai/A (0.027 gae/ha) respectively. The

estimated EEC therefore exceeds the soybean EC25 by

more than 55X for the seed germination test and 4600X

for the seedling emergence test. For monocot plants

the seed germination EC25s for barley, the most

sensitive monocots tested, was > 0.035 lb/A (38.8

gae/ha). For the seedling emergence test the EC25 was

0.062 lb/A (70 gae/ha) for wheat, the most sensitive

species. The estimated EEC exceeds the EC25 by < 3.14X

for barley for the seed germination test and 1.8X for

wheat for the seedling emergence test.

ACTIVE

INGREDIENT

(P.C Code)

SEED GERM.

EC25

SEEDLING EMERG.

LC25

(lb ai/A)

MAXIMUM

APPLICATION

RATE (lb ai/A)

% RUNOFF

BASED ON

SOLUBILITY

EEC

(lb

ai/A)

RISK

QUOTIENT

(EEC/EC25)

USE RATE (lb

ai/A)

REQUIRED TO

BRACKET RISK

QUOTIENT

(EC25/

0.05)

TIPA Salt

(5102)

0.002

(Dicots-Soybeans)

> 0.035

(Monocots-barley)

0.0000239

(Dicots-Soybeans)

0.0346

(Monocots-wheat)

2.2

0.11

< 3.14

4603

3.18

0.04

0.7

0.000478

3.18

IOE (5103)

0.0013376

(Dicots-Drybeans)

0.0032103

(Monocots-barley)

0.0000035

(Dicots-Soybeans)

0.0253259

(Monocots-wheat)

2.0

0.02

14.994

6.17

5714

0.790

0.026752

0.0642

0.00007

0.5065

Potassium

Salt

(5104)

0.0031

(Dicots-Soybeans)

0.062

(Monocots-Barley)

0.0000124

(Dicots-Soybeans)

0.02

(Monocots-Wheat)

2.0

0.1

32.3

1.61

8065

0.062

1.24

0.000248

0.4

Based on the model described above these Picloram salts and IOE

are very likely to affect nontarget plants (especially dicots) in

an adjacent 1 acre site. The requirement for Tier 3 plant field

testing has been met, and should be implemented. However,

current EPA policy does not require these studies.

Endangered Species - As explained above the criterion

for the determination and presumption of low risk to

endangered plants is based on the same criteria used to

determine low risk to non-endangered plant species

(i.e. EEC < EC25). Hence, the conclusion stated above

also applies to endangered species.

ii. Aerial Applications - Soil

EEC calulations for aerial applications to soil are

expressed as the runoff scenarios for terrestrial

nontarget plants in the same manner as unincorporated

ground applications except that a 60% application

efficiency for runoff and a 5% drift are factored into

the calculations accordingly.

The lb ai runoff potential impacting a 1 acre site is

expressed as the following formula.

Runoff: (from site after application)

maximum x 60% application x % runoff x 1 acre

appl. rate efficiency

(lb ai/A)

The lb ai drift potential impacting a 1 acre site is

expressed accordingly.

Drift: (from site during application)

maximum x 5% drift

appl. rate

(lb ai/A)

The total loading factor (EEC) or the total lb ai

potentially impacting an adjacent 1 acre site is the

sum of the runoff and drift calculations.

The procedure used to determine risk is illustrated

with the TIPA Salt below. The EECs and the

corresponding Risk Quotients for each active ingredient

of Picloram products are summarized in a table.

Picloram 4-amino-3,5,6-triisopropanolamine salts (TIPA)

P.C. Code: 005102

The estimated EEC concentration for aerial

applications to soil is 0.18 lb ai (2.2 lb ai x 60% x

5% runoff x 1 acre) + (2.2 lb ai x 5%). The seed

germination and seedling emergence EC25s for soybeans,

the most sensitive dicot plants tested, are 0.002 lb

ai/A (2.3 gae/ha) and 0.0000239 lb ai/A (0.027 gae/ha)

respectively. The estimated EEC therefore exceeds the

soybean EC25 by more than 90X for the seed germination

test and 7531X for the seedling emergence test for

dicot plants. For monocot plants the seed germination

EC25s for barley, the most sensitive monocots tested,

was > 0.035 lb/A (70 gae/ha). For the seedling

emergence test the EC25 was 0.062 lb/A (38.8 gae/ha)

for wheat, the most sensitive species. The estimated

EEC exceeds the EC25 by 2.9X for wheat for the seedling

emergence test and 5X for barley for the seed

germination test for monocot plants.

ACTIVE

INGREDIENT

(P.C Code)

SEED GERM.

EC25

SEEDLING EMERG.

LC25

(lb ai/A)

MAXIMUM

APPLICATION

RATE (lb ai/A)

% RUNOFF

BASED ON

SOLUBILITY

EEC

(lb

ai/A)

RISK

QUOTIENT

(EEC/EC25)

USE RATE

REQUIRED TO

BRACKET Risk

Quotient (lb

ai/A)(EC25/

0.08

TIPA Salt

(5102)

0.002

(Dicots-Soybeans)

0.035

Monocots-barley)

0.0000239

(Dicots-Soybeans)

0.062

(Monocots-wheat)

2.2

0.18

5.1

7531

2.9

0.025

0.44

0.0003

0.78

IOE (5103)

0.0013376

(Dicots-Drybeans)

0.0032103

(Monocots-barley)

0.0000035

(Dicots-Soybeans)

0.0253259

(Monocots-wheat)

2.0

0.032

23.9

9.9679

9143

1.2635

0.0167

0.04013

0.0000437

0.3166

Potassium

Salt

(5104)

0.0031

(Dicots-Soybeans)

0.062

(Monocots-Barley)

0.0000124

(Dicots-Soybeans)

0.02

(Monocots-Wheat)

2.0

0.16

51.6

2.5

12,903

0.039

0.78

0.000155

0.25

Based on the model described above these Picloram salts and IOE

are very likely to affect nontarget plants (especially dicots) in

an adjacent 1 acre site when applied as aerial applications to

soil. The requirement for Tier 3 plant field testing has been

met, and should be implemented. However, current EPA policy does

not require these studies.

Endangered Species - As explained above the criterion

for the determination and presumption of low risk to

endangered plants is based on the same criteria used to

determine low risk to non-endangered plant species

(i.e. EEC < EC25). Hence, the conclusion stated above

also applies to endangered species.

iii. Aerial Applications - Foliar

The EEC calculations for foliar aerial applications

only factor drift into the equation and compare these

to the most sensitive monocot and dicot EC25 values

from vegetative vigor tests. The lb ai drift potential

impacting a 1 acre site is expressed accordingly.

Drift: (from site during application)

maximum x 5% drift

appl. rate

(lb ai/A)

Again, the procedure used to determine risk is

illustrated with the TIPA Salt below. The EECs and the

corresponding Risk Quotients for each active ingredient

of Picloram products for foliar aerial applications are

summarized in a table.

Picloram 4-amino-3,5,6-triisopropanolamine salts (TIPA)

P.C. Code: 005102

As pointed out in the Use Profile section above,

the maximum application rate can not be determined due

to the lack of limitations on the maximum number of

treatments per season or intervals between treatments.

The only maximum application rate for the Picloram

Triispropanolamine Salts which can be used at this time

is the single application rate of 2.2 lb ai/acre used

for the Tordon 101 broadcast stubble cut treatment.

Using this single application rate and the 5% drift

assumption the estimated EEC is 0.11 lb ai (2.2 lb ai x

5% drift) which can potentially affect an adjacent 1

acre site. The vegetative vigor EC25s for tomatoes,

the most sensitive dicot plant tested, is 0.0002 lb

ai/A (0.22 gae/ha). The estimated EEC therefore

exceeds the tomato EC25 by more than 550X for the

vegetative vigor test. For monocot plants the seed

germination EC25s for wheat, the most sensitive monocot

tested, was > 0.20 lb/A (227.7 gae/ha). The risk

quotient of 0.55 does not exceed the level of concern

for the vegetative vigor test. However, the most

sensitive root crop tested (radish) has a vegetative

vigor EC25 of 0.012 lb/A (13.7 gae/ha) yielding a risk

quotient of 9.2.

ACTIVE

INGREDIENT

(P.C Code)

VEGETATIVE VIGOR

EC25

(lb ai/A)

MAXIMUM

APPLICATION

RATE (lb ai/A)

% RUNOFF

BASED ON

DRIFT

EEC

(lb

ai/A)

RISK

QUOTIENT

(EEC/EC25)

USE RATE (lb

ai/A)

REQUIRED TO

BRACKET RISK

QUOTIENT

(EC25/

0.05)

TIPA Salt

(5102)

0.0002

(Dicots-Tomatoes)

0.20

(Monocots-Wheat)

0.012

(Root crops-Radish)

2.2

0.11

550

0.55

9.2

0.004

4.0

0.24

IOE (5103)

0.000214

(Dicots-Soybeans)

0.2098307

(Monocots-Wheat)

0.0346893

(Root crops-Radish)

2.0

0.02

93.4

0.095

0.5765

0.00428

4.197

0.6938

Potassium

Salt

(5104)

0.00036

(Dicots-Soybeans)

0.276

(Monocots-Wheat)

0.062

(Root crops-Radish

2.0

0.1

277.7

0.36

1.6

0.0072

5.5

1.24

Based on the model described above these Picloram salts and IOE

are very likely to affect nontarget dicot plants and root crops

in an adjacent 1 acre site when applied as foliar aerial

applications. The requirement for Tier 3 plant field testing has

been met, and should be implemented. However, current EPA policy

does not require these studies.

Endangered Species - As explained above the criterion

for the determination and presumption of low risk to

endangered plants is based on the same criteria used to

determine low risk to non-endangered plant species

(i.e. EEC < EC25). Hence, the conclusion stated above

also applies to endangered species.

i. Aquatic Plants

i. Unicorporated Ground Applications

Aquatic Plant EEC calulations for unincorporated

ground applications are expressed as the runoff

scenarios for aquatic nontarget plants from an

application which assumes 1% to 5% runoff (depending on

water solubility) into a 10 acre drainage basin. The

following water solubilities determine the percent

runoff to use.

Water Solubilitity % Runoff Assumed

< 10 ppm 1%

10 - 100 ppm 2%

> 100 ppm 5%

The lb ai runoff potential (EEC) impacting a 1 acre

site is expressed as the following formula.

Runoff = maximum x % runoff x 10 acre drainage

Potential appl. rate basin

The final EEC value is determined by multiplying the

EEC of a hypothetical direct application to a 1 A pond

with 6 inch shallows or 6 feet deep and the total

loading. The EEC for direct application in a pond 6

feet deep is 61 ppb. For direct application to a pond

with 6 inch shallows the EEC is 734 ppb.

As with the terrestrial plant risk procedures the

procedure used to determine risk is illustrated with

the TIPA Salt below. The EECs and the corresponding

Risk Quotients for each active ingredient of Picloram

products for unincorporated ground applications are

summarized in a table. It should, however, be

emphasized that 4 remaining aquatic plant species still

remain to be tested, and a complete aquatic plant risk

assessment can not be completed until these studies are

reviewed and validated.

Picloram 4-amino-3,5,6-triisopropanolamine salts (TIPA)

P.C. Code: 005102

The estimated EEC concentration is 808.5 ppb ai

for 6 inch shallow (2.2 lb ai x 5% runoff x 10 acre x

734 ppb) and 67 ppb for 6 feet deep water (2.2 lb ai x

5% runoff x 10 acres x 61ppb). The aquatic EC50 is 234

mg/L (ppm) or 234,000 ppb for Selenastrum capricornutum

(freshwater green algae), the only aquatic species

tested.

ACTIVE

INGREDIENT

(P.C Code)

FW AQUATIC

PLANTS

EC50 (PPB)

MAXIMUM

APPLICATION

RATE (lb

ai/A)

% RUNOFF

BASED ON

SOLUBILITY

EEC (PPB)

RISK

QUOTIENT

IN 6"

SHALLOWS

(EEC/EC50)

USE RATE (lb

ai/A)

REQUIRED TO

BRACKET RISK

QUOTIENT IN

6" SHALLOWS

(EC50/367.5)

Shallows

6' Deep

water

TIPA Salt

(5102)

234,000

(S.

Capricornutum)

2.2

808.5

0.0035

636.73

IOE (5103)

4900

(S.

Capricornutum)

2.0

147

12.2

0.03

13.333

Potassium

Salt

(5104)

85,500

(S.

Capricornutum)

2.0

734

0.009

232.7

Based on this model the Picloram salts and IOE are not likely to

affect nontarget aquatic plants in an adjacent 1 acre site when

applied as unincorporated ground applications.

Endangered Species - As pointed out under the "Exposure

to Plants" section above the criterion for the

determination and presumption of low risk to endangered

aquatic plants is based on the same criteria used to

determine low risk to non-endangered aquatic plant

species (i.e. EEC < EC50). Hence, the conclusion

stated above also applies to endangered species.

ii. Aerial Applications

Aquatic EEC calulations for aerial applications

are expressed as the runoff scenarios for terrestrial

nontarget plants in the same manner as unincorporated

ground applications except that a 60% application

efficiency for runoff and a 5% drift are factored into

the calculations accordingly.

The lb ai runoff potential impacting a 1 acre pond is

expressed as the following formula.

Runoff: (from site after application)

maximum x 60% application x % runoff x 10 acre

appl. rate efficiency

(lb ai/A)

The lb ai drift potential impacting a 1 acre site is

expressed accordingly.

Drift: (from site during application)

maximum x 5% drift

appl. rate

(lb ai/A)

The final EEC value is determined by multiplying the

EEC of a hypothetical direct application to a 1 A pond

with 6 inch shallows or 6 feet deep and the total

loading. The EEC for direct application in a pond 6

feet deep is 61 ppb. For direct application to a pond

with 6 inch shallows the EEC is 734 ppb.

The total loading factor (EEC) or the total ppb ai

potentially impacting an adjacent 1 acre site is the

sum of the runoff and drift calculations.

The procedure used to determine risk is illustrated

with the TIPA Salt below. The EECs and the

corresponding Risk Quotients for each active ingredient

of Picloram products for unincorporated ground

applications are then summarized in a table. It

should, however, be emphasized that 4 remaining aquatic

plant species still remain to be tested, and a complete

aquatic plant risk assessment can not be completed

until these studies are reviewed and validated.

Picloram 4-amino-3,5,6-triisopropanolamine salts (TIPA)

P.C. Code: 005102

The maximum application rate for the Picloram

Potassium Salt is 2.2 lb ai/acre. Runoff is assumed to

be 5% due to high solubility. The estimated EEC

concentration for runoff is 0.66 lb ai (2.2 lb ai x 60%

application efficiency x 5% runoff x 10 acre) and 0.11

lb ai for drift (2.2 lb ai x 5% runoff). The total

loading factor then is 0.77 lb ai potentially impacting

an adjacent 1 acre pond. The final EEC for 6 inch

shallows is 566 ppb and 50 ppb for 6 feet deep water.

The aquatic EC50 is 234 mg/L (ppm) or 234,000 ppb for

Selenastrum capricornutum (freshwater green algae), the

only aquatic species tested. The estimated EEC

therefore does not exceed the freshwater green algae

EC50 only, and the resulting risk ratio is 0.0024 for 6

inch shallows and 0.0002 for 6 feet deep water.

ACTIVE

INGREDIENT

(P.C Code)

FW AQUATIC

PLANTS

EC50 (PPB)

MAXIMUM

APPLICATION

RATE (lb

ai/A)

% RUNOFF

BASED ON

SOLUBILITY

EEC (PPB)

RISK

QUOTIENT

IN 6"

SHALLOWS

(EEC/EC50)

USE RATE (lb

ai/A)

REQUIRED TO

BRACKET RISK

QUOTIENT IN

6" SHALLOWS

(EC50/

256.9)

Shallows

6' Deep

water

TIPA Salt

(5102)

234,000

(S.

Capricornutum)

2.2

566

0.0024

910.9

IOE (5103)

4900

(S.

Capricornutum)

2.0

249.6

20.74

0.051

19.07

Potassium

Salt

(5104)

85,500

(S.

Capricornutum)

2.0

513.8

42.7

0.006

330.9

Based on this model the Picloram salts and IOE are not likely to

affect nontarget aquatic plants in an adjacent 1 acre site when

applied as unincorporated ground applications.

Endangered Species - As pointed out under the "Exposure

to Plants" section above the criterion for the

determination and presumption of low risk to endangered

aquatic plants is based on the same criteria used to

determine low risk to non-endangered aquatic plant

species (i.e. EEC < EC50). Hence, the conclusion

stated above also applies to endangered species.

Additional Phytotoxic Information

An outstanding EEB review to assess the restricted use

classification for Picloram products was apparently completed by

EEB in 1989 but never signed off and forwarded to RD. This

review was prompted by incident reports from Ms. J. Kerns, a

potato farmer in Haines, Oregon. Mrs. Kearns sited 30 incidents

in which plant injury resulting from surface runoff or leaching

to groundwater. Plants reported to be injured by Picloram

include potatoes, tobacco, soybeans, corn, pasture, watermelons,

tomatoes, bell peppers, and hay.

Additionally, a 1989 study published in the Journal of

Environmental Quality concerning roadside application of

Piclormam to noxious weeds on logging road in the northern

rockies. The study concluded that roadside applications in the

northern Rocky Mountains should not exceed 0.25 lb ai/acre and

that less than 1% of a given watershed be treated. Currently,

none of the Picloram labels address the maximum watershed area

that can be treated per year.

Based on this information it is highly recommended that

phytotoxicity data be submitted as confirmatory data for potatoes

and other sensitive crops.

4. Aquatic Risk Assessment (Non-endangered and Endangered

Aquatic Organisms)

The criterion for the determination of the presumption

of no risk for aquatic organisms is based on a risk quotient

value less than one ( <1 ). This risk quotient is the

calculated EEC divided by 0.1 x lowest LC50 value for non-endangered species.

a. Unicorporated Ground Applications

Aquatic EEC calculations for unincorporated ground

applications are expressed as the runoff scenarios for

aquatic organisms from an application which assumes 0.1% to

5% runoff (depending on water solubility) into a 10 acre

drainage basin. The following water solubilities determine

the percent runoff to use.

The percentage of runoff based on the water solubility of

the compound are determined based upon a computer

simulation. The following percentages are used based on

water solubility.

Water Solubility % of Nominal Application Rate

> 100 ppm 5

< 100 ppm > 1 ppm 2

> 1 ppm 1

< 1 ppb 0.1

Water solubility of for all Picloram active ingredients used

as end products greatly exceeds 100 ppm.

The lb ai runoff potential (EEC) impacting a 10 acre

drainage basin is expressed as the following formula.

Runoff = maximum x % runoff x 10 acre drainage

Potential appl. rate basin

The final EEC value is determined by multiplying the

EEC of a hypothetical direct application to a 1 A pond with

6 inch shallows or 6 feet deep and the total loading. The

EEC for direct application in a pond 6 feet deep is 61 ppb.

For direct application to a pond with 6 inch shallows the

EEC is 734 ppb.

As with the aquatic plant risk procedures the procedure

used to determine risk is illustrated with the TIPA Salt

below. The EECs and the corresponding Risk Quotients for

each active ingredient of Picloram products for

unincorporated ground applications are then summarized in

the following tables.

Picloram 4-amino-3,5,6-triisopropanolamine salts (TIPA)

P.C. Code: 005102

The estimated EEC concentration for unincorporated

ground applications is 1.1 lb ai (2.2 lb ai x 5% runoff x 10

acre). The estimated EEC concentration is 808.5 ppb ai for

6 inch shallow (2.2 lb ai x 5% runoff x 10 acre x 734 ppb)

and 67 ppb for 6 feet deep water (2.2 lb ai x 5% runoff x 10

acres x 61ppb).

AQUATIC RISK QUOTIENTS FOR UNINCORPORATED GROUND APPLICATIONS

APPLIED AT 2.2 LBS. AI/A

(Runoff = 5% of Maximum Application Rate)

SPECIES

LC50

ppb

6 FEET DEEP

(67.1/(0.1 x

LC50)

6 INCH SHALLOWS

(807.4/(0.1 x LC50)

USE RATE (lb ai/A)

REQUIRED TO

BRACKET RISK

QUOTIENT IN 6"

SHALLOWS (0.1 x

LC50)/367

Coho Salmon

(FW fish - coldwater)

20,000

0.0335

0.404

5.422

Marine Shrimp

306,000

0.00218

0.026

83.37

Eastern Oyster

(Shell deposition)

10,000

0.07

0.807

2.725

Picloram Iosoctyl Ester (IOE)

P.C. Code: 005103

As explained above there are no data for freshwater or

marine/estuarine organisms for this active ingredient. At a

minimum EEB will require the acute LC50s for a coldwater

fish (rainbow trout), a warmwater fish (bluegill), and a

freshwater invertebrate (Daphnia magna) to complete the risk

assessment.

Picloram Potassium Salt

P.C. Code: 005104

AQUATIC RISK QUOTIENTS FOR UNINCORPORATED GROUND APPLICATIONS

APPLIED AT 2.0 LBS. AI/A

(Runoff = 5% of Maximum Application Rate)

SPECIES

LC50

ppb

6 FEET DEEP

(61/(0.1 x LC50)

6 INCH SHALLOWS

(734/(0.1 x LC50)

USE RATE (lb ai/A)

REQUIRED TO

BRACKET RISK

QUOTIENT IN 6"

SHALLOWS (0.1 x

LC50)/367

Rainbow Trout

(FW fish - coldwater)

13,000

0.0469

0.565

3.5374

Daphnia

(FW Invertebrate)

68,300

0.0089

0.108

18.61

Eastern Oyster

(Embryro Larvae)

18,000

0.0339

0.408

4.9

Based on this model the Picloram TIPA and Potassium salts are not

likely to affect nontarget aquatic organsims when applied as

unincorporated ground applications.

b. Chronic Risks

For chronic risks the criterion for the determination of low

aquatic risk to non-endangered and endangered species is a

risk quotient < 1 with an EEC < MATC (Maximum Acceptable

Toxicant Concentration). The only Picloram active

ingredient in which chronic data is available is the

Potassium salt. The MATCs for the fish early life stage and

the aquatic invertebrate life-cycle are 700 ppb and 14,600

ppb respectively, and neither exceeds the chronic level of

concerns. However, Subdivision E section 72-4 requires a

fish early lifecycle test to be submitted if the pesticide

is likey to be continuous or recurrent in water and the

pesticide is highly persistent. Based on this information,

the need for chronic fish studies for the remaining active

ingredients is indicated.

c. Endangered Species

As discussed above, the criterion for the determination and

presumption of low risk to endangered aquatic organisms is

based on a risk quotient value less than one (<1). This

hazard quotient is the calculated EEC divided by the 0.05 x

LC50 values for the most sensitive species tested. Using

the aquatic EEC values and the lowest LC50s, the resulting

risk quotients as well as the use rate required to bracket

the level of concern for endangered species for all the

active ingredients containing Picloram are presented in the

table below.

Picloram 4-amino-3,5,6-triisopropanolamine salts (TIPA)

P.C. Code: 005102

AQUATIC RISK QUOTIENTS FOR UNINCORPORATED GROUND APPLICATIONS

FOR ENDANGERED SPECIES

APPLIED AT 2.2 LBS. AI/A

(Runoff = 5% of Maximum Application Rate)

SPECIES

LC50

ppb

6 FEET DEEP

(67.1/(0.05 x

LC50)

6 INCH SHALLOWS

(807.4/(0.05 x LC50)

USE RATE (lb ai/A)

REQUIRED TO

BRACKET RISK

QUOTIENT IN 6"

SHALLOWS (0.05 x

LC50)/367

Coho Salmon

(FW fish - coldwater)

20,000

0.067

0.807

2.721

Marine Shrimp

306,000

0.0044

0.0528

41.69

Eastern Oyster

(Shell deposition)

10,000

0.134

1.615

1.361

Picloram Iosoctyl Ester (IOE)

P.C. Code: 005103

As explained above there are no data for freshwater or

marine/estuarine organisms for this active ingredient. At a

minimum EEB will require the acute LC50s for a coldwater

fish (rainbow trout), a warmwater fish (bluegill), and a

freshwater invertebrate (Daphnia magna) to complete the risk

assessment.

Picloram Potassium Salt

P.C. Code: 005104

AQUATIC RISK QUOTIENTS FOR UNINCORPORATED GROUND APPLICATIONS

FOR ENDANGERED SPECIES

APPLIED AT 2.0 LBS. AI/A

(Runoff = 5% of Maximum Application Rate)

SPECIES

LC50

ppb

6 FEET DEEP

(61/(0.05 x

LC50)

6 INCH SHALLOWS

(734/(0.05 x LC50)

USE RATE (lb ai/A)

REQUIRED TO

BRACKET RISK

QUOTIENT IN 6"

SHALLOWS (0.05 x

LC50)/367)

Rainbow Trout

(FW fish - coldwater)

13,000

0.0938

1.13

1.77

Daphnia

(FW Invertebrate)

68,300

0.0179

0.215

9.31

Eastern Oyster

(Embryro Larvae)

18,000

0.0677

0.816

2.452

Although this model indicates that endangered estuarine mollusks

are likely to be affected for the TIPA salt, currently there are

no federally listed endangered species in this category.

Therefore, at this time we do not have a concern for endangered

estuarine molluscs.

According to this model the Potassium salt is likely to effect

endangered fish when applied as unincorporated ground

applications.

d. Aerial or Mist Blower Applications

EEC calculations for aerial or mist blower applications

to aquatic systems are based on runoff and drift into a 10

acre drainage basin. Potential runoff into a 10 acre

drainage basin is determined by the following formula.

Application rate x 0.6 x % runoff x 10 A

(lbs ai/A) (Application (based on (10 Acre

Efficiency) solubility) drainage

basin)

The percentage of runoff based on the water solubility of

the compound are determined based upon a computer

simulation. The following percentages are used based on

water solubility.

Water Solubility % of Nominal Application Rate

> 100 ppm 5

< 100 ppm > 1 ppm 2

> 1 ppm 1

< 1 ppb 0.1

Water solubility of for all Picloram active ingredients used

as end products greatly exceeds 100 ppm.

The runoff EEC value is determined by multiplying this EEC

value from a hypothetical direct application to a 1 A pond

with 6 inch shallows or 6 feet deep and the total loading.

The EEC for direct application in a pond 6 feet deep is 61

ppb. For direct application to a pond with 6 inch shallows

the EEC is 734 ppb.

Drift is determined as 5 percent of the nominal application

rate. The total loading factor (EEC) or the total ppb ai

potentially impacting an adjacent 1 acre site is the sum of

the runoff and drift calculations.

As with the aquatic plant risk procedures the procedure used

to determine risk is illustrated with the TIPA Salt below.

The EECs and the corresponding Risk Quotients for each

active ingredient of Picloram products for aerial and mist

blower applications are then summarized in the following

tables.

Picloram 4-amino-3,5,6-triisopropanolamine salts (TIPA)

P.C. Code: 005102

The maximum application rate for the Picloram TIPA salt

is 2.2 lb ai/acre. Due to the solubility > 100 ppm the

percentage of runoff due to solubility is assumed to be 5%

for this salt. The estimated EEC concentration for runoff

is 0.66 lb ai (2.2 lb ai x 60% application efficiency x 5%

runoff x 10 acre) and 0.11 lb ai for drift (2.2 lb ai x 5%

runoff). The total loading factor then is 0.77 lb ai

potentially impacting a 10 acre drainage basin. The final

EEC for 6 inch shallows is 566 ppb and 47 ppb for 6 feet

deep water.

AQUATIC RISK QUOTIENTS FOR AERIAL APPLICATIONS

APPLIED AT 2.2 LBS. AI/A

(Runoff = 5% of Maximum Application Rate)

SPECIES

LC50

ppb

6 FEET DEEP

(47/(0.1 x LC50)

6 INCH SHALLOWS

(566/(0.1 x LC50)

USE RATE (lb ai/A)

REQUIRED TO

BRACKET RISK

QUOTIENT IN 6"

SHALLOWS (0.1 x

LC50)/256.9

Coho Salmon

(FW fish - coldwater)

20,000

0.0235

0.283

7.79

Marine Shrimp

306,000

0.00154

0.0185

119.11

Eastern Oyster

(Shell deposition)

10,000

0.047

0.566

3.89

Picloram Iosoctyl Ester (IOE)

P.C. Code: 005103

As explained above there are no data for freshwater or

marine/estuarine organisms for this active ingredient. At a

minimum EEB will require the acute LC50s for a coldwater

fish (rainbow trout), a warmwater fish (bluegill), and a

freshwater invertebrate (Daphnia magna) to complete the risk

assessment.

Picloram Potassium Salt

P.C. Code: 005104

AQUATIC RISK QUOTIENTS FOR AERIAL APPLICATIONS

APPLIED AT 2.0 LBS. AI/A

(Runoff = 5% of Maximum Application Rate)

SPECIES

LC50

ppb

6 FEET DEEP

(42.7/(0.1 x

LC50)

6 INCH SHALLOWS

(514.5/(0.1 x LC50)

USE RATE (lb ai/A)

REQUIRED TO

BRACKET RISK

QUOTIENT IN 6"

SHALLOWS (0.1 x

LC50)/256.9

Rainbow Trout

(FW fish - coldwater)

13,000

0.0323

0.396

5.06

Daphnia

(FW Invertebrate)

68,300

0.00625

0.0753

26.59

Eastern Oyster

(Embryro Larvae)

18,000

0.0237

0.2858

7.01

Based on this model the Picloram TIPA and Potassium salts are not

likely to affect non-endangered aquatic nontarget organisms when

applied as an aerial or mist blown spray applications.

e. Chronic Risks

For chronic risks the criterion for the determination

of low aquatic risk to non-endangered and endangered species

is a hazard ratio < 1 with an EEC < MATC. The only Picloram

active ingredient in which chronic data is available is the

Potassium salt. The MATCs for the fish early life stage and

the aquatic invertebrate life-cycle are 700 ppb and 14,600

ppb respectively. The MATCs for the fish early life stage

and the aquatic invertebrate life-cycle are 700 ppb and

14,600 ppb respectively, and neither exceeds the chronic

level of concerns. However, Subdivision E section 72-4

requires a fish early lifecycle test to be submitted if the

pesticide is likey to be continuous or recurrent in water

and the pesticide is highly persistent. Based on this

information, the need for chronic fish studies for the

remaining active ingredients is indicated.

f. Endangered Species

As discussed above, the criterion for the determination

and presumption of low risk to endangered aquatic organisms

is based on a risk quotient value less than one ( <1 ).

This risk quotient is the calculated EEC divided by the 0.05

x LC50 values for the most sensitive species tested. Using

the aquatic EEC values and the lowest LC50s, the resulting

risk quotients as well as the use rate required to bracket

the level of concern for endangered species for all the

active ingredients containing Picloram are presented in the

table below.

Picloram 4-amino-3,5,6-triisopropanolamine salts (TIPA)

P.C. Code: 005102

AQUATIC RISK QUOTIENTS FOR AERIAL OR MIST BLOWN

SPRAY APPLICATIONS

APPLIED AT 2.2 LBS. AI/A

(Runoff = 5% of Maximum Application Rate)

SPECIES

LC50

ppb

6 FEET DEEP

(47/(0.05 x

LC50)

6 INCH SHALLOWS

(566/(0.05 x LC50)

USE RATE (lb ai/A)

REQUIRED TO

BRACKET RISK

QUOTIENT IN 6"

SHALLOWS (0.05 x

LC50/256.9)

Coho Salmon

(FW fish - coldwater)

20,000

0.047

0.566

3.89

Marine Shrimp

306,000

0.00307

0.0370

59.56

Eastern Oyster

(Shell deposition)

10,000

0.094

1.132

1.946

Picloram Iosoctyl Ester (IOE)

P.C. Code: 005103

As explained above there are no data for freshwater or

marine/estuarine organisms for this active ingredient. At a

minimum EEB will require the acute LC50s for a coldwater

fish (rainbow trout), a warmwater fish (bluegill), and a

freshwater invertebrate (Daphnia magna) to complete the risk

assessment.

Picloram Potassium Salt

P.C. Code: 005104

AQUATIC RISK QUOTIENTS FOR AERIAL OR MIST BLOWN

SPRAY APPLICATIONS

APPLIED AT 2.0 LBS. AI/A

(Runoff = 5% of Maximum Application Rate)

SPECIES

LC50

ppb

6 FEET DEEP

(42.7/(0.05 x

LC50)

6 INCH SHALLOWS

(513.8/(0.05 x LC50)

USE RATE (lb ai/A)

REQUIRED TO

BRACKET RISK

QUOTIENT IN 6"

SHALLOWS (0.05 x

LC50)/256.9

Rainbow Trout

(FW fish - coldwater)

13,000

0.0657

0.792

2.53

Daphnia

(FW Invertebrate)

68,300

0.0125

0.1507

13.29

Eastern Oyster

(Embryro Larvae)

18,000

0.0474

0.572

3.5

Although this model indicates that endangered estuarine mollusks

are likely to be affected for the TIPA salt when applied as

aerial or mist blown spray applications, currently there are no

federally listed endangered species in this category. Therefore,

at this time we do not have a concern for endangered estuarine

molluscs.

g. Other Information

Incident data indicate that 15,880 pounds of fish died

from symptoms of chemical poisoning at a fish hatchery in

Sheridan, Montana on July 21, 1989. Picloram (Tordon 22K)

was detected at the scene and the chemical had been sprayed

one quarter mile upstream from the fish hatchery by Montana

State highway personnel. Rain on the day of the fish kill

had washed Picloram into the hatcheries water source.

Although the LC50 data indicates that the risk does not

exceed the LOC, the latest EPA paradigm states that an

incident itself is sufficient to exceed the LOC for acute

risk.

C. Adequacy of Labelling and Mitigation

As stated above in the "Use Profile" section there are

many labelling issues which are not addressed. These issues

mainly concern maximum rates per application, per year or

season, and the intervals between applications. These

issues are summarized below by active ingredient.

Picloram 4-amino-3,5,6-triisopropanolamine salts (TIPA)

P.C. Code: 005102

These products can be applied at any season and there

are no limitations or restrictions on the maximum number of

treatments per season. The maximum rates per application

are also unclear. For the tree injection method 1 ml of

undiluted product is injected at intervals of 2 - 3 inches

between the edges of injector wounds, however, it is not

specified if 1 ml is injected at each interval or whether a

total of 1 ml of product is injected per tree. EEB asked

Dow-Elanco to clarify these issues, and were sent

clarification in the form of a fax (attached). Dow-Elanco

responded that 1 milliliter is injected into each injection

wound at an average of 5 injections per tree. The maximum

plant density was considered to be 500 stems per acre, and

the maximum poundage per acre was calculated to be 0.168 lb

ai/A. Applications are "typically" applied once every 3 to

4 years. The maximum rate used in the risk assessment was,

therefore, 2 lb ai/A from the broadcast stubble treatment.

Picloram Isooctyl Ester (IOE)

P.C. Code: 005103

The only product containing this active ingredient is

applied as a basal bark treatment by backpack sprayer.

There are no limitations on the maximum number of treatments

or intervals between treatments. It can be diluted as 2

gallons (908 g ae) of product in enough oil to make 100

gallons of spray mixture and applied with a backpack sprayer

using low pressure (20 to 40 psi) at the spray nozzle or it

can be diluted as 30 gallons (13,620 g ae) of product to

make 100 gallons and applied as a low volume treatment using

low pressure and a cone or flat fan nozzle. The only

apparent difference with these two dilutions is that the low

volume treatment does not wet the stem to the point of

runoff. Alternatively, Access may be applied undiluted "in

a thin stream to all sides of the lower stems". Between 2

to 15 ml (0.0005284 to 0.003969 g ae) is required for

treatment of a single stem. As discussed in the use profile

section above the undiluted treatment of 15 ml yields a

maximum application rate of 2 lb ai/A (500 stems x 15

ml)/3785 ml/gallon). Therefore, the maximum rate used in

this risk assessment for this Isooctyl ester is 2.00 lb

ai/A. It should also be noted that the EEB is in the

process of verification of the vegetation density assumption

of 500 stems per acre.

Picloram Potassium Salt

P.C. Code: 005104

Of the three products containing this Picloram salt

Tordon K and Tordon 22K does not give limitations on the

maximum number of treatments per season. However, it may be

inferred that Tordon 22K is applied on time per season. For

the EEC calculations for the risk assessment a maximum

seasonal rate of 2 lb ai/A per year was used. This issue

should be clarified in the labels.

Concerning mitigation and label changes, it should be

noted here that the last column in each risk (hazard)

quotient table presented in sections B. 3. and 4. lists the

maximum use rate which would be required to reduce risk

below the acute and chronic levels of concern for

terrestrial and aquatic organisms. Groups of organisms and

the maximum lb ai per acre which could be used are presented

below.

Picloram 4-amino-3,5,6-triisopropanolamine salts (TIPA)

P.C. Code: 005102

TYPE

ORGANISM

TYPE APPLICATION

ENDANGERED (E)

AND/OR NON-ENDANGERED (N)

SPECIES?

MAXIMUM USE

RATE REQUIRED

TO REDUCE RISK

BELOW ACUTE LOC

(LB AI/ACRE)

MAXIMUM USE RATE

REQUIRED TO

REDUCE RISK BELOW

CHRONIC LOC (LB

AI/ACRE)

Mammals

(Insectivores)

UGA/AS/AF

1.9

NO DATA AVAIL.

Terrestrial Plants

UGA

E/N

0.000478

0.0003

0.004

NO DATA AVAILABLE

Fish

UGA/AS/AF

E/N

54.422

NO DATA AVAILABLE

Picloram Isooctyl Ester (IOE)

P.C. Code: 005103

TYPE

ORGANISM

TYPE APPLICATION

ENDANGERED (E)

AND/OR NON-ENDANGERED (N)

SPECIES?

MAXIMUM USE

RATE REQUIRED

TO REDUCE RISK

BELOW ACUTE LOC

(LB AI/ACRE)

MAXIMUM USE RATE

REQUIRED TO

REDUCE RISK BELOW

CHRONIC LOC (LB

AI/ACRE)

Mammals

(Insectivores)

UGA/AS/AF

1.07

NO DATA AVAIL.

Terrestrial Plants

UGA

E/N

0.00007

0.0000437

0.004

NO DATA AVAIL

Fish

UGA

E/N

832.65

NO DATA AVAIL

Picloram Potassium Salt

P.C. Code: 005104

TYPE

ORGANISM

TYPE APPLICATION

ENDANGERED (E)

AND/OR NON-ENDANGERED (N)

SPECIES?

MAXIMUM USE

RATE REQUIRED

TO REDUCE RISK

BELOW ACUTE LOC

(LB AI/ACRE)

MAXIMUM USE RATE

REQUIRED TO

REDUCE RISK BELOW

CHRONIC LOC (LB

AI/ACRE)

Mammals

(Insectivores)

UGA/AS/AF

1.34

NO DATA AVAIL.

Terrestrial Plants

UGA

E/N

0.000248

0.000155

0.0072

NO DATA AVAIL.

Fish

UGA

2.721

1.375

Concerning endangered species, the Endangered Species

Protection Program is expected to become final in early

1994. Picloram has existing biological opinions for which

EPA will require a generic endangered species label

statement (or an equivalently protective alternative) when

the Program is in place. Additional consultation with the

U.S. Fish and Wildlife Service will be required to address

newly listed species and also any use sties not previously

considered. However, no additional label changes are

anticipated as a result of consultation if the label already

contains the generic label statement.

1. Precautionary Label Statement - (Manufacturing Use

Product)

The following precautionary label statement should be

included on all products.

"Do not discharge effluent containing this product into

lakes, streams, ponds, estuaries, oceans or other

waters unless in accordance with the requirements of a

National Pollutant Discharge Elimination System (NPDES)

permit and the permitting authority has been notified

in writing prior to discharge. Do not discharge

effluent containing this product to sewer systems

without previously notifying the local sewage treatment

plant authority. For guidance contact your State Water

Board or Regional Office of the EPA."

D. Adequacy of Toxicity Data

Based on Picloram's extreme phytotoxicity, its

persistence under typical environmental conditions, and its

extreme propensity to leach into groundwater in all soil

types the following additional data are needed as

confirmatory data to support this risk assessment.

Picloram 4-amino-3,5,6-triisopropanolamine salts (TIPA)

P.C. Code: 005102

Guideline

Study

Reason Requesting

123-1(a)

Seed Germination/Seedling

Emergence - Tier 2

Need missing EC25s and

NOECs for most

sensitive plants

123-1(b)

Vegetative Vigor - Tier 2

Need missing EC25s and

NOECs for most

sensitive plants

123-1(a)

Seed Germination/Seedling

Emergence - Tier 2

Need EC25s and NOECs for

sensitive crops which

were reported in

damages from incident

reports. These crops

include potatoes,

tobacco, pasture,

watermelons, tomatoes,

bell peppers, and hay

123-1(b)

Vegetative Vigor - Tier 2

Need EC25s and NOECs for

sensitive crops which

were reported in

damages from incident

reports. These crops

include potatoes,

tobacco, pasture,

watermelons, tomatoes,

bell peppers, and hay

123-2

Growth & Reproduction of

Aquatic Plants - Tier 2

Due to extreme

phytotoxicity, ROWs,

aerial treatments, etc.

all aquatic plant

species must to tested.

These include Lemna

gibba, Skeletonema

costatum, Anabaena

flos-aquae, & a

freshwater diatom.

72-3(d)

Toxicity to

Marine/Estuarine Fish LC50

(TEP)

This study is a minimum

core requirement for

all active ingredients

72-4(a)

Early Life Stage - Fish

This pesticide is

highly persistent and

likely to be present in

water on a recurrent

basis.

Picloram Isooctyl Ester (IOE)

P.C. Code: 005103

Guideline

Study

Reason Requesting

123-1(a)

Seed Germination/Seedling

Emergence - Tier 2

Need missing NOEC for

most sensitive plants

123-1(b)

Vegetative Vigor - Tier 2

Need missing NOEC for

most sensitive plants

123-1(a)

Seed Germination/Seedling

Emergence - Tier 2

Need EC25s and NOECs for

sensitive crops which

were reported in

damages from incident

reports. These crops

include potatoes,

tobacco, pasture,

watermelons, tomatoes,

bell peppers, and hay

123-1(b)

Vegetative Vigor - Tier 2

Need EC25s and NOECs for

sensitive crops which

were reported in

damages from incident

reports. These crops

include potatoes,

tobacco, pasture,

watermelons, tomatoes,

bell peppers, and hay

123-2

Growth & Reproduction of

Aquatic Plants - Tier 2

Due to extreme

phytotoxicity, ROWs,

aerial treatments, etc.

all aquatic plant

species must to tested.

These include Lemna

gibba, Skeletonema

costatum, Anabaena

flos-aquae, & a

freshwater diatom.

72-1(b)

Bluegill, Acute LC50 (TEP)

This study is a minimum

core requirement for

all active ingredients

72-1(d)

Rainbow, Acute LC50 (TEP)

This study is a minimum

core requirement for

all active ingredients

72-2(b)

Toxicity to Freshwater

Invertebrates (Daphnia

magna) (TEP)

This study is a minimum

core requirement for

all active ingredients

72-3(d)

Toxicity to

Marine/Estuarine Fish LC50

(TEP)

This study is a minimum

core requirement for

all active ingredients

72-3(e)

Toxicity to

Marine/Estuarine Mollusc

EC50 (TEP)

This study is a minimum

core requirement for

all active ingredients

72-3(f)

Toxicity to

Marine/Estuarine Shrimp

EC50 (TEP)

This study is a minimum

core requirement for

all active ingredients

72-4(a)

Early Life Stage - Fish

This pesticide is

highly persistent and

likely to be present in

water on a recurrent

basis.

Picloram Potassium Salt

P.C. Code: 005104

Guideline

Study

Reason Requesting

123-1(a)

Seed Germination/Seedling

Emergence - Tier 2

Need missing EC25s and

NOEC for most sensitive

plants

123-1(a)

Seed Germination/Seedling

Emergence - Tier 2

Need EC25s and NOECs for

sensitive crops which

were reported in

damages from incident

reports. These crops

include potatoes,

tobacco, pasture,

watermelons, tomatoes,

bell peppers, and hay

123-1(b)

Vegetative Vigor - Tier 2

Need EC25s and NOECs for

sensitive crops which

were reported in

damages from incident

reports. These crops

include potatoes,

tobacco, pasture,

watermelons, tomatoes,

bell peppers, and hay

123-2

Growth & Reproduction of

Aquatic Plants - Tier 2

Due to extreme

phytotoxicity, ROWs,

aerial treatments, etc.

all aquatic plant

species must to tested.

These include Lemna

gibba, Skeletonema

costatum, Anabaena

flos-aquae, & a

freshwater diatom.

72-3(d)

Toxicity to

Marine/Estuarine Fish LC50

(TEP)

This study is a minimum

core requirement for

all active ingredients

William Evans, Biologist

Ecological Effects Branch

Environmental Fate and Effects Division

Ann Stavola, Chief, Section 5

Ecological Effects Branch

Environmental Fate and Effects Division

Anthony F. Maciorowski, Chief

Ecological Effects Branch

Environmental Fate and Effects Division