FINAL SCIENCE MEMO APP202697 – Para-Ken 250 Herbicide Substance database ID - 48033 April 2016 Project team: Application advisor: Trudy Geoghegan Toxicologist: Stuart Creton Ecotoxicologist: Miguel Santos Peer-reviewer: Cora Drijver (consultant for the ecotox); Jeane Nicolas (tox) 2 1. Executive summary 1.1. Background and justification for a Cat B standard pathway 1.1.1 Para-Ken 250 Herbicide is a soluble concentrate containing paraquat dichloride as the active ingredient, plus other components. It is intended for use as an herbicide for the control of weeds in Lucerne, Clover seed crops, Forestry, Industrial site, Streets and for Barley grass control. 1.1.2 Para-Ken 250 Herbicide was originally submitted as a Rapid application (APP202591). However it was declined under this pathway due to international concerns regarding the safety of paraquat for human health and the environment. Paraquat is banned in the EU and has been either banned or severely restricted in a number of other countries. Human health 1.1.3 Para-Ken 250 Herbicide is proposed to be used at a similar application rate to other approved substances containing paraquat dichloride. However, due to international concerns regarding the safety of paraquat a quantitative human health risk assessment was undertaken. Ecotox 1.1.4 Para-Ken 250 Herbicide contains paraquat dichloride and is proposed to be used at a similar application rate to other approved substances containing paraquat dichloride. However, due to international concerns regarding the safety of paraquat a quantitative environmental risk assessment was undertaken. 1.2. Key points 1.2.1 The applicant classified Para-Ken 250 Herbicide as follows: 6.1B (O), 6.1B (D), 6.1A (Inh), 6.3A, 6.4A, 6.9A, 9.1A, 9.3A, 9.4B. The staff classified Para-Ken 250 Herbicide as follows: 6.1C (O), 6.1B (D), 6.1A (I), 6.3A, 6.4A, 9.1A, 9.3A, 9.4B. The difference in the acute oral toxicity classification appears to be based on a different interpretation of mixture rules by the applicant. 1.2.2 The applicant provided ecotox studies with a formulation containing 20% paraquat dichloride. The results with the formulation were used for the risk assessment when considered acceptable. 1.2.3 Predicted exposures of operators during mixing, loading and application of Para-Ken 250 Herbicide are greater than the AOEL for paraquat, even with the use of full PPE including a respirator. 1.2.4 Based on the use pattern re-entry worker exposure to Para-Ken 250 Herbicide is likely to be minimal and therefore no quantitative re-entry worker exposure assessment has been performed. 1.2.5 Predicted exposures of a bystander 8 metres away from the edge of an application area are greater than the acceptable levels for both active ingredients. If spraying of Para-Ken 250 Herbicide were limited to use of coarse droplets, minimum buffer zones of 16 or 30 metres from sensitive areas would April 2016 3 be required for low boom or high boom application, respectively, in order to reduce exposures to the AOEL. 1.2.6 Predicted exposures for children playing directly on a treated area (such as children playing on street verges) are also substantially higher than the AOEL. 1.2.7 Staff consider that the approval of Para-Ken 250 Herbicide as broadcast spray to clover, Lucerne, forestry and barley grass control should be declined due to the unacceptable risks posed to aquatic organisms (algae) and birds. 1.2.8 Staff consider that the application of Para-Ken 250 Herbicide as spot treatment (using knapsack in non-wide dispersive manner) in non-crop situations such as in streets, industrial sites the risks can be considered below the level of concern in terms of risks to the environment. However, the staff recommended that the application using knapsack should be carried out using nozzles equipped to release coarse droplets and thus preventing spray drift. 1.2.9 Although the risks for the environment could be managed by limiting use of Para-Ken 250 Herbicide to spot treatment, the human health risk assessment indicates that there would still be unacceptable risks for operators applying the substance by knapsack and potentially for children playing on treated areas such as street verges. Therefore it is proposed that the application should be declined. 1.2.10 Based on the concerns identified it is proposed that grounds should be sought to reassess Paraquat and the formulations containing it that are currently approved under HSNO. 1.3. Regulatory status Table 1 Active ingredient regulatory status Active ingredient name Regulatory history in New International regulatory Zealand history (Australia, Canada, Europe, Japan, USA) Paraquat dichloride Approved in NZ Approved in Australia, USA and Canada. Not approved as a pesticide active in Europe. Banned or restricted in a number of other jurisdictions. April 2016 4 1.4. Use pattern Table 2 Substance use pattern Substance category Wide Dispersive use Concentration Application rate(s) 250 g/L See GAP Table Yes Herbicide No April 2016 Remarks Table 3 GAP table Crop and/or situation (a) Clover seeds Fence lines, Stock yards, Street verges, Streets and Industrial sites Product code F G or I (b) F Pests or Group of pests controlled Formulation PHI Application rate per treatment (days) Application (c) Grasses, Broad Leaf Weeds (l) Type Conc. of as method kind (d-f) (i) (f-h) growth stage & season (j) 2 weeks before closing clover crop for seed. 250 g/L High volume broadcast SL 250 g/L All stages and growth High seasons volume but more broadcast, predominatel Handgun, y in the Knapsack spring/summ er/autumn period SL F Grasses, Broad Leaf Weeds Forestry F Grasses, Broad Leaf Weeds SL 250 g/L Lucerne F Grasses, Annual Broad Leaf Weeds SL 250 g/L All stages in High spring/summ volume er/autumn broadcast season Winter while High Lucerne is volume dormant broadcast number min max (k) interval between application s (min) kg as/hL water L/ha kg as/ha min max min max min max 1-2 28 days 0.1-0.16 250300 0.3-0.4 1-4 28 days 0.1-0.3 5001000 1.0-1.5 1-2 28 days 0.333-0.5 200300 1 1-2 28 days 0.1330.240 250300 0.4-0.6 Remarks: (m) Crop and/or situation Product code (a) F G or I (b) Pests or Group of pests controlled Formulation (l) Type Conc. of as method kind (d-f) (i) (f-h) Australia sedges F SL Tall rescue and rushes Remarks Application (c) Barley grasses Non selective weed control 250 g/L growth stage & season (j) number min max (k) During the active growth phase of the target species but before 1-4 seed Handgun maturity. Predo minately in the spring/summ er/autumn period (a) For crops, the EU and Codex classifications (both) should be used; where relevant, the use situation should be described (e.g. fumigation of a structure) (b) Outdoor or field use (F), glasshouse application (G) or indoor application (I) (c) e.g. biting and suckling insects, soil born insects, foliar fungi, weeds (d) e.g. wettable powder (WP), emulsifiable concentrate (EC), granule (GR) (e) GCPF Codes - GIFAP Technical Monograph No 2, 1989 (f) All abbreviations used must be explained (g) Method, e.g. high volume spraying, low volume spraying, spreading, dusting, drench (h) Kind, e.g. overall, broadcast, aerial spraying, row, individual plant, between the plants type of equipment used must be indicated April 2016 PHI Application rate per treatment (days) (i) (j) interval between application s (min) kg as/hL water L/ha kg as/ha min max min max min max 0.06-0.12 5001000 0.6 0.0250.2727 5501000 0.251.5 0.15-0.3 5001000 1.5 Remarks: (m) 28 days g/kg or g/l Growth stage at last treatment (BBCH Monograph, Growth Stages of Plants, 1997, Blackwell, ISBN 3-8263-3152-4), including where relevant, information on season at time of application (k) The minimum and maximum number of application possible under practical conditions of use must be provided (l) PHI - minimum pre-harvest interval (m) Remarks may include: Extent of use/economic importance/restrictions 7 2. Applicant and Staff hazard classifications of the mixture Table 4 Applicant and Staff classifications of the mixture Staff’s classification Class 1 Explosiveness NA ND Class 2, 3 & 4 Flammability NA ND Class 5 Oxidisers/Organic Peroxides NA Subclass 8.1 Metallic corrosiveness NA Remarks Mixture rules1 Applicant’s classification Read across Hazard Class/Subclass Method of classification Mixture data Mixture classification ND ND Mainly paraquat dichloride Difference appears to be a different interpretation of mixture rules Subclass 6.1 Acute toxicity (oral) 6.1B 6.1C Subclass 6.1Acute toxicity (dermal) 6.1B 6.1B Mainly paraquat dichloride Subclass 6.1 Acute toxicity (inhalation) 6.1A 6.1A Paraquat dichloride Subclass 6.1 Aspiration hazard NA ND Subclass 6.3/8.2 Skin irritancy/corrosion 6.3A 6.3A Paraquat dichloride Subclass 6.4/8.3 Eye irritancy/corrosion 6.4A 6.4A Mainly paraquat dichloride Subclass 6.5A Respiratory sensitisation NA Subclass 6.5B Contact sensitisation NA Subclass 6.6 Mutagenicity NA ND Subclass 6.7 Carcinogenicity NA ND 1 ND ND Use of mixture rules may not adequately take into account interactions between different components in some circumstances and must be considered of lower reliability than data on the mixture itself. April 2016 8 Subclass 6.8 Reproductive/ developmental toxicity NA Subclass 6.8 Reproductive/ developmental toxicity (via lactation) NA Subclass 6.9 Target organ systemic toxicity2 6.9A Subclass 9.1 Aquatic ecotoxicity Staff’s classification Remarks Mixture rules1 Applicant’s classification Read across Hazard Class/Subclass Method of classification Mixture data Mixture classification ND ND 6.9A Paraquat dichloride 9.1A 9.1A Paraquat dichloride Subclass 9.2 Soil ecotoxicity NA ND Subclass 9.3 Terrestrial vertebrate ecotoxicity 9.3A 9.3A Paraquat dichloride Subclass 9.4 Terrestrial invertebrate ecotoxicity 9.4B 9.4B Paraquat dichloride -: No information provided by the applicant NA: Not Applicable --> For instance when testing is technically not possible: testing for a specific endpoint may be omitted, if it is technically not possible to conduct the study as a consequence of the properties of the substance: e.g. very volatile, highly reactive or unstable substances cannot be used, mixing of the substance with water may cause danger of fire or explosion or the radio-labelling of the substance required in certain studies may not be possible. ND: No Data or poor quality data (according to Klimisch criteria3) --> There is a lack of data for one or more components. No: Data are available for the formulation or for all components and classification is not triggered. 3. Mammalian toxicology 3.1. Studies submitted with the formulation and the active ingredient technical concentrate 2 When appropriate include separate rows to address single as well as repeat dose target organ toxicity, and any of the relevant routes (oral, dermal and/or inhalation). 3 Klimisch, H-J., Andrear, M., & U. Tillmann, 1997. A systematic approach for evaluating the quality of experimental toxicological and ecotoxicological data. Reg. Toxicol. Pharmacol. 25, 1–5 (1997) April 2016 9 The applicant submitted a number of toxicity studies with the paraquat dichloride technical concentrate (44% paraquat dichloride) and for a formulation coded “PARAQUAT 20% SL”, containing 200 g/L paraquat dichloride. The amount of paraquat dichloride in PARAQUAT 20% SL is less than the amount of paraquat dichloride in Para-Ken 250 Herbicide, which contains 250 g paraquat dichloride/L. The applicant provided a bridging statement where reasons are presented to read-across the data from “PARAQUAT 20% SL” to the Para-Ken 250 Herbicide. The applicant claims that the toxicological studies for Human health for the 20% formulated product will be closely similar or the same for the 25%. This conclusion is stated to be based on the results for the 44% Active and comparing them to the 20%. The applicant states that the results for a number of the LD50 tests are stated to be nearly identical between the 20% and 44%, suggesting that the results for the 20% formulation can be read across to the 25% formulation Para-Ken 250 Herbicide. However, Staff note that while the results were similar in the majority of cases, in some tests there were substantial differences. For example, in the acute dermal toxicity test with the 20% formulation mortality was observed in all animals at 4000 mg/kg bw whereas with the technical concentrate (which contains a higher concentration of paraquat dichloride) only 1/10 animals died at this dose. In addition, the composition of “PARAQUAT 20% SL” was not provided so it was not possible to compare its composition with that of ParaKen 250 Herbicide. Therefore Staff have used mixture rules rather than the test data to classify Para-Ken 250 Herbicide. 4. Ecotoxicology 4.1. Robust study summaries for the formulation The applicant provided ecotox studies performed with a formulation coded “PARAQUAT 20% SL”, containing 200 g/L paraquat dichloride. The amount of paraquat dichloride in PARAQUAT 20% SL is less than the amount of paraquat dichloride in Para-Ken 250 Herbicide, which contains 250 g paraquat dichloride/L. The applicant provided a bridging statement where reasons are presented to read-across the data from “PARAQUAT 20% SL” to the Para-Ken 250 Herbicide. The applicant claims that since the difference in the amount of paraquat dichloride between the two formulations is 50 g/L the results may be used in the risk assessment. Staff summarised the studies provided by the applicant and used the results when deemed appropriate for the risk assessment. Classification of Para-Ken 250 Herbicide was carried out according to mixture rules. 4.1.1. Aquatic toxicity Fish acute toxicity (Freshwater species) Type of study Full test Flag Supplemental study, formulation is not Para-Ken 250 Herbicide April 2016 10 Test Substance PARAQUAT 20% SL (containing 210 g/L paraquat dichloride) Species Danio rerio (zebrafish) Type of exposure Semi-static for 96 hours, daily renewal Endpoint LC50 Value 141.42 mg/L, equivalent to 28.28 mg paraquat dichloride/L. PM Bidinotto (2008) Acute toxicity of PARAQUAT 20% SL to fish Danio rerio. Reference BIOAGRI, Piracicaba, Brazil. Study No 5258.208.365.08 Klimisch Score 1 Amendments/Deviations None GLP Yes Test Guideline/s OECD 203 (1992) No/Group 7 fish per treatment 0, 50, 200, 400, 800 mg/L (nominal concentrations) Dose Levels Reference substance: potassium dichromate (0, 100, 180, 320 and 560 mg/L) Analytical measurements At the beginning and end of the tests using HPLC/UV The acute toxicity of PARAQUAT 20% SL to the zebrafish Danio rerio was determined in a semi-static test for 96 hours. The validity criteria were fulfilled. Study Summary The deviations between measured and nominal concentrations ranged between 2.53 and 14.02%, thus lower than 20%, therefore the endpoint is expressed as nominal concentration. The LC50 was 141.42 mg/L. Conclusion The LC50 was 141.42 mg/L, equivalent to 28.28 mg paraquat dichloride/L. Fish chronic toxicity (Freshwater species) No study provided. Invertebrate acute toxicity (Freshwater species) Type of study Full test Flag Supplemental study, formulation is not Para-Ken 250 Herbicide Test Substance PARAQUAT 20% SL (containing 210 g/L paraquat dichloride) Species Daphnia magna Type of exposure Semi-static for 48 hours, renewal after 24h Endpoint EC50 Value 17.43 mg/L April 2016 11 JN Sesso (2008) Acute toxicity of PARAQUAT 20% SL to Daphnia magna. Reference BIOAGRI, Piracicaba, Brazil. Study No 5258.206.370.08. Klimisch Score 1 Amendments/Deviations None GLP Yes Test Guideline/s OECD 202 (2004) No/Group 4 replicates of 5 Daphnids per treatment 0, 6.5, 13, 25, 50, 100 mg/L (nominal concentrations) Dose Levels Reference substance: potassium dichromate (0, 0.32, 0.56, 1.0, 1.8 and 2.4 mg/L) Analytical measurements At the beginning and end of the tests using HPLC/UV The acute toxicity of PARAQUAT 20% SL to Daphnia magna was determined in a semi-static test for 48 hours. Deviations from nominal concentrations ranged Study Summary from 3.64 to 15.85%, therefore all effect levels were based on nominal concentrations. The validity criteria were fulfilled. The 48-hour EC50 was 17.43 mg/L. Conclusion The EC50 was 17.43 mg/L, equivalent to 3.5 mg paraquat dichloride/L. Invertebrate chronic toxicity (Freshwater species) No study provided. Algae acute toxicity (Freshwater species) Type of study Full test Flag Supplemental study, formulation is not Para-Ken 250 Herbicide Test Substance PARAQUAT 20% SL (containing 210 g/L paraquat dichloride) Species Pseudokirchneriella subcapitata Type of exposure Static for 72 hours Endpoint ErC50 and EyC50 Value ErC50 = 2.41 mg/L; EyC50 = 0.88 mg/L PM Bidinotto (2008) Toxicity of PARAQUAT 20% SL to alga Reference Pseudokirchneriella subcapitata. BIOAGRI, Piracicaba, Brazil. Study No 5258.202.359.08 Klimisch Score April 2016 1 12 Amendments/Deviations None GLP Yes Test Guideline/s OECD 201 (2006) No/Group 104 cells/mL 0, 0.1, 0.32, 1, 3.2, 10 mg/L(nominal concentrations) Dose Levels Reference substance: potassium dichromate (0, 0.18, 0.32, 0.56, 1.0 and 1.8 mg/L) Analytical measurements At the beginning and end of the tests using HPLC/UV The aim of this study was to determine the effects of PARAQUAT 20% SL on the growth rate and yield of the green alga over a period of 72 hours. Deviations from nominal concentrations ranged from 0.4 to 11.75%, therefore Study Summary all effect levels were based on nominal concentrations. The study met the validity criteria of the test guideline. The 72-hour EyC50 was 0.88 mg/L (CI: 0.74 – 1.03 mg/L) and the 72-hour ErC50 was 2.41 mg/L (CI: 2.08 -2.80 mg/L). The EyC50 was 0.88 mg formulation/L and the ErC50 was 2.41 mg Conclusion formulation/L. General conclusion about aquatic toxicity classification Para-Ken 250 Herbicide is classified as 9.1A, according to mixture rules. 4.1.2. Soil toxicity Soil macro-invertebrates Type of study Limit test Flag Supplemental study, formulation is not Para-Ken 250 Herbicide Test Substance PARAQUAT 20% SL (containing 210 g/L paraquat dichloride) Species Eisenia foetida Type of exposure Spiked soil for 14 days Endpoint LC50 Value >1000 mg/kg soil RA Franco (2008) Acute toxicity of PARAQUAT 20% SL to earthworm Eisenia Reference foetida. BIOAGRI, Piracicaba, Brazil. Study No 5258.203.381.08 Klimisch Score April 2016 1 13 Amendments/Deviations None GLP Yes Test Guideline/s OECD 207 (1984) No/Group 4 replicates of 10 earthworms per treatment 0, 1000 mg/kg soil Dose Levels Reference: chloroacetamide Analytical measurements At the beginning and end of the tests using HPLC/UV The aim of this study was to determine the effects of PARAQUAT 20% SL on the survival of the earthworm Eisenia foetida. The study met the validity criteria Study Summary of the test guideline. The 14-day LC50 was higher than 1000 mg formulation/kg bw. Conclusion The 14-day LC50 was higher than 1000 mg formulation/kg bw. Non-target terrestrial plants No study provided. Nitrogen transformation test Type of study Full test Flag Supplemental study, formulation is not Para-Ken 250 Herbicide Test Substance PARAQUAT 20% SL (containing 210 g/L paraquat dichloride) Species Soil microflora Type of exposure Spiked soil for 28 days Endpoint Nitrogen transformation Value No effects of PARAQUAT 20% SL at 3 kg paraquat dichloride per hectare. VCB Cardinalli (2008) Effects of PARAQUAT 20% SL to soil microoganisms: Reference Nitrogen transformation test. BIOAGRI, Piracicaba, Brazil. Study No 5258.218.328.08 Klimisch Score 1 Amendments/Deviations None GLP Yes Test Guideline/s OECD 216 (2000) No/Group 3 replicates per treatment 0, 0.6 kg paraquat dichloride/ha (maximum used rate), 3 kg paraquat Dose Levels dichloride/ha (5*MUR) April 2016 14 Analytical measurements At the beginning of the test in the stock solution using HPLC/UV The aim of this study was to determine the effects of PARAQUAT 20% SL on soil microorganisms through a nitrogen transformation test using two different Brazilian soils, a Latosoil (LVdf) and an Argisoil (PVAe) as test systems. The Study Summary study met the validity criteria of the test guideline. Two concentrations were tested: 0.6 kg a.i./ha and 3 kg a.i./ha. The deviation at the end of the 28 days of exposure between control and treated soils were below the 25% threshold. Effects of PARAQUAT 20% SL were below 25% at 3 kg paraquat dichloride Conclusion per hectare. Carbon transformation test Type of study Full test Flag Supplemental study, formulation is not Para-Ken 250 Herbicide Test Substance PARAQUAT 20% SL (containing 210 g/L paraquat dichloride) Species Soil microflora Type of exposure Spiked soil for 28 days Endpoint Carbon transformation Value No effects of PARAQUAT 20% SL at 3 kg paraquat dichloride per hectare. VCB Cardinalli (2008) Effects of PARAQUAT 20% SL to soil microorganisms: Reference Carbon transformation test. BIOAGRI, Piracicaba, Brazil. Study No 5258.201.468.08 Klimisch Score 1 Amendments/Deviations None GLP Yes Test Guideline/s OECD 217 (2000) No/Group 3 replicates per treatment 0, 0.6 kg paraquat dichloride/ha (maximum used rate), 3 kg paraquat Dose Levels dichloride/ha (5*MUR) Analytical measurements At the beginning of the test in the stock solution using HPLC/UV The aim of this study was to determine the effects of PARAQUAT 20% SL on soil microorganisms through a carbon transformation test using two different Study Summary Brazilian soils, a Latosoil (LVdf) and an Argisoil (PVAe) as test systems. The study met the validity criteria of the test guideline. Two concentrations were April 2016 15 tested: 0.6 kg a.i./ha and 3 kg a.i./ha. The deviation at the end of the 28 days of exposure between control and treated soils were below the 25% threshold. Effects of PARAQUAT 20% SL were below 25% at 3 kg paraquat dichloride Conclusion per hectare. General conclusion about soil toxicity classification Para-Ken 250 Herbicide does not trigger a classification for soil toxicity. 4.1.3. Terrestrial vertebrate toxicity Acute oral toxicity Type of study Full test Flag Supplemental study, formulation is not Para-Ken 250 Herbicide Test Substance PARAQUAT 20% SL (containing 210 g/L paraquat dichloride) Species Coturnix coturnix japonica (Japanese quail) Type of exposure Acute oral Endpoint LD50 Value 775.92 mg/kg bw RA Franco (2008) Avian acute toxicity test of PARAQUAT 20% SL in Japanese Reference quails. BIOAGRI, Brazil. Study No 5258.302.410.08. Klimisch Score 2 Amendments/Deviations None that have impacted the results GLP No Test Guideline/s OPPTS 850.2100 (1996) No/Group 10 (5 males and 5 females) per treatment Dose Levels 0 (control), 257.2, 429.6, 717.4, 1198 and 2000 mg formulation/kg bw Analytical measurements Not required PARAQUAT 20% SL was tested for acute oral toxicity in birds using the Japanese quail. Twenty-one dosed quails (42%) died in the study. Compoundrelated deaths were registered on 717.4 (1 or 10%), 1198 (10 or 100%) and Study Summary 2000 (10 or 100%) mg/kg bw. Dose-related clinical signs (apathy, ataxia, ruffled feathers, dyspnea, sialorrhea and decubitus) were acute neurological and respiratory signs observed on 717.4, 1198 and 2000 mg/kg bw. No animal from control groups, 257.2 and 429.6 mg/kg bw presented any clinical sign during April 2016 16 the 14-day observation period. The validity criteria were met. The combined (males and females) LD50 of the test substance PARAQUAT 20% SL was 775.92 mg/kg bw. Conclusion The LD50 was 775.92 mg formulation/kg bw. General conclusion about toxicity to terrestrial vertebrate classification Para-Ken 250 Herbicide is classified as 9.3A, according to mixture rules. 4.1.4. Ecotoxicity to terrestrial invertebrates Bees – Laboratory studies Type of study Full test Flag Supplemental study, formulation is not Para-Ken 250 Herbicide Test Substance PARAQUAT 20% SL (containing 210 g/L paraquat dichloride) Species Apis mellifera Type of exposure 48 hours, contact Endpoint LD50 Value 41.23 µg/bee (equivalent to 8.25 µg a.i./bee) RA Franco (2008) Acute contact toxicity test of PARAQUAT 20% SL to Reference honeybee Apis mellifera (africanized). BIOAGRI, Brazil. Study No 5258.204.385.08. Klimisch Score 1 Amendments/Deviations None that have impacted the results GLP Yes Test Guideline/s OECD 214 (1998) No/Group 3 replicates with 10 bees per treatment 0, 7.8125, 15.625, 31.25, 62.25 and 125 µg/bee (nominal concentrations), Dose Levels equivalent to 1.5625, 3.125, 6.25, 12.5 and 25 µg a.i./bee Reference item: dimethoate Analytical measurements Not required The acute contact toxicity of PARAQUAT 20% SL to the honeybee was tested. Study Summary The validity criteria were met. The LD50 (48 hours) was 41.23 µg a.i./bee. Conclusion April 2016 LD50 = 41.23 µg/bee (equivalent to 8.25 µg a.i./bee) 17 General conclusion about toxicity to terrestrial invertebrate classification Para-Ken 250 Herbicide is classified as 9.4B, according to mixture rules. 5. Human health risk assessment 5.1.1. Para-Ken 250 Herbicide contains paraquat dichloride and is proposed to be used in a higher application rate than other approved substances containing this active ingredient. Therefore, a quantitative human health risk assessment was undertaken. Quantitative worker (operator) risk assessment Critical endpoint definition Using an existing AOEL for paraquat Available international AOELs Key systemic effect Pulmonary lesions, clinical chemistry, and urine analysis EU (2003) NOAEL mg/kg bw/Day Uncertainty factors AOEL mg/kg bw/Day Staff’s modifications Remarks None Corrected for 10% oral absorption AOEL short term: 0.0005 0.45 100 AOEL long term: 0.0004 (90 day and 1 year dog studies) Other inputs for human worker (operator) and re-entry exposure modelling4 Active Physical form Concentration of each active (g/L) Maximum application rate (for each active, for Dermal absorption (%) each method of Concentrate AOEL Spray application) mg/kg bw/day g a.i./ha Paraqu at ion Liquid 1500 6 30 0.0005 The EPA’s operator exposure assessment is based on a modification of the approach used by European regulators. Full details of the methodology can be provided on request. 4 April 2016 18 Comments on inputs for human worker (operator) exposure modelling input parameters: Dermal absorption Dermal absorption data for paraquat in the formulation Para-Ken 250 were not provided. In the absence of specific data Staff consider it is appropriate to use default values for dermal absorption, as recommended in EFSA guidance on Guidance on Dermal Absorption (2012 5) and OECD Guidance Notes on Dermal Absorption (20116). For pesticides, Staff have agreed to adopt less conservative default values than those proposed in the EFSA and OECD guidance, using default values proposed by Aggarwal et al (2015 7), which are based on a review of a robust data set of 295 in vitro human dermal absorption studies with over 150 agrochemical active ingredients. These default values are 2% for solid concentrates, 6% for liquid concentrates and 30% for spray dilutions. Staff note that the oral absorption of paraquat is low (10% for paraquat). Staff considered whether it may be possible to use this information to refine the dermal absorption values however no oral absorption, distribution, metabolism and excretion (ADME) studies are available with the Para-Ken 250 Herbicide formulation and the influence of the co-formulants in this formulation on dermal absorption is unknown. Therefore staff do not consider it appropriate to use oral absorption as a surrogate dermal absorption value. Staff also note that assessments of the EU and the US EPA have noted that dermal absorption of paraquat may be as low as 0.5%, however these conclusions predate the introduction of the OECD and EFSA guidance on dermal absorption which provides criteria for deciding when it is appropriate to read across data to a specific formulation. In this case information is not available as to the formulations or vehicles used to perform the dermal absorption studies with paraquat and how these compare to the Para-Ken 250 Herbicide formulation. In the absence of more information Staff consider it is appropriate to use the default dermal absorption values in the present assessment, however it is acknowledged that these values may result in an overestimate of exposure. Work rates Para-Ken 250 Herbicide is intended to be used the control of weeds in Lucerne, Clover seed crops, Forestry, Industrial site, Streets and for Barley grass control by high volume broadcast and by hand gun. The default work rate for boom spraying for cereals, legume vegetables, bare soil and grasslands in the EPA exposure assessment model is 50 ha per day. Staff have assumed that this work rate is appropriate for the proposed uses of Para-Ken 250 Herbicide. The default work rate for knapsack/hand gun spraying is 1 ha per day. 5 EFSA 2012 Guidance on dermal absorption. EFSA Panel on Plant Protection Products and their Residues. EFSA Journal 2012: 10(4):2665 http://ec.europa.eu/food/plant/pesticides/guidance_documents/docs/efsa_guidance_document_dermal_absorption_18042012.pdf Accessed 05/02/2016 6 OECD 2011 OECD Guidance notes on dermal absorption. Series on Testing and Assessment, No. 156. ENV/JM/MONO(2011)36 http://www.oecd.org/chemicalsafety/testing/48532204.pdf Accessed 05/02/2016 7 Aggarwal et al. 2015 Assessment of an extended dataset of in vitro human dermal absorption studies on pesticides to determine default values, opportunities for read-across and influence of dilution on absorption. Regul Toxicol Pharmacol 72: 58-70. http://www.sciencedirect.com/science/article/pii/S0273230015000458 April 2016 19 Output of human worker (operator) mixing, loading and application exposure modelling Estimated operator exposure (mg/kg bw/day) Risk Quotient No PPE8 during mixing, loading and application 0.8117 1623.43 Gloves only during mixing and loading 0.6729 1345.71 Gloves only during application 0.7018 1403.57 Full PPE during mixing, loading and application (excluding respirator) 0.0560 112.07 Full PPE during mixing, loading and application (including FP1, P1 and similar respirator achieving 75 % inhalation exposure reduction) 0.0546 109.11 Full PPE during mixing, loading and application (including FP2, P2 and similar respirator achieving 90 % inhalation exposure reduction) 0.0543 108.60 No PPE during mixing, loading and application 0.5308 1061.57 Gloves only during mixing and loading 0.2936 587.14 Gloves only during application 0.4695 938.91 Full PPE during mixing, loading and application (excluding respirator) 0.0503 100.50 Full PPE during mixing, loading and application (including FP1, P1 and similar respirator achieving 75 % inhalation exposure reduction) 0.044316 88.63 Full PPE during mixing, loading and application (including FP2, P2 and similar respirator achieving 90 % inhalation exposure reduction) 0.043191 86.38 Exposure Scenario Boom Backpack - High Level Target Outcomes of the worker (operator) exposure assessment Predicted exposures of workers (operators) during mixing, loading and application of Para-Ken 250 Herbicide are greater than the AOEL for paraquat for both boom and knapsack spraying, even with the use of full PPE including a respirator9. Re-entry exposure assessment 8 Full” PPE includes: gloves, hood/visor, coveralls, and heavy boots during application. The model only provides for use of gloves at mixing loading. 9 Gloves, hood/visor, coveralls, and heavy boots with a respirator April 2016 20 Para-Ken 250 Herbicide is intended to be used primarily before sowing or transplanting, or before crop emergence. Therefore staff anticipate that re-entry worker exposure to Para-Ken 250 Herbicide is likely to be minimal and no quantitative re-entry worker exposure assessment is required. Quantitative bystander risk assessment10 The AOEL derived for operator and re-entry worker assessment above is also used for the bystander assessment calculations. Output of human bystander exposure modelling11 Exposure Scenario Estimated exposure of 15 kg toddler exposed through contact to surfaces 8 m from an application area Risk Quotient Buffer zone needed to reduce toddler exposure to the AOEL (µg/kg bw/day) Boom High boom, fine droplets 10.54 21.0817 136 High boom, coarse droplets 1.67 3.3446 30 Low boom, fine droplets 3.56 7.1143 70 Low boom, coarse droplets 0.85 1.6924 16 Staff note that the intended use pattern for Para-Ken 250 Herbicide includes Street verges. It is possible that in some cases children may play on such areas. Therefore Staff have also assessed the potential recreational exposure for children. This uses the same approach as the bystander exposure assessment; apart from the fact that the area of contact is 0 m from the application area. Output of recreational exposure modelling Estimated exposure of 15 kg toddler exposed through contact to surfaces 0 m from an application area 10 Risk Quotient The Staff considers that the main potential source of exposure to the general public for substances of this type (other than via food residues which will be considered as part of the registration of this substance under the Agricultural Compounds and Veterinary Medicines (ACVM) Act 1997) is via spray drift. In terms of bystander exposure, toddlers are regarded as the most sensitive subpopulation and are regarded as having the greatest exposures. For these reasons the risk of bystander exposure is assessed in this sub-population. EPA has agreed that the AOEL used for operator and re-entry worker exposure assessment should be used for the bystander assessment, as the use of an oral chronic reference dose (CRfD) is usually likely to be over precautionary. 11 The EPA’s bystander exposure assessment is based on a modification of the approaches used by European regulators and the US EPA. Full details of the methodology can be found in Appendix X.. Spray drift deposition from ground based application is estimated using the AgDisp model. Spray drift deposition from aerial application is estimated using the AGDISP model along with appropriate New Zealand input parameters. April 2016 21 (µg/kg bw/day) 108 216 Outcomes of the bystander exposure assessment Predicted exposures of bystanders are greater than the AOEL for paraquat. If spraying of Para-Ken 250 Herbicide were limited to use of coarse droplets, minimum buffer zones of 16 or 30 metres from sensitive areas would be required for low boom or high boom application, respectively, in order to reduce exposures to the AOEL. Exposures for children playing directly on a treated area are also substantially higher than the AOEL. 5.2. Summary and conclusions of the human health risk assessment Predicted exposures of operators during mixing, loading and application of Para-Ken 250 Herbicide are greater than the AOEL for paraquat, even with the use of full PPE including a respirator. Based on the use pattern re-entry worker exposure to Para-Ken 250 Herbicide is likely to be minimal and therefore no quantitative re-entry worker exposure assessment has been performed. Predicted exposures of a bystander 8 metres away from the edge of an application area are greater than the acceptable levels for both active ingredients. If spraying of Para-Ken 250 Herbicide were limited to use of coarse droplets, minimum buffer zones of 16 or 30 metres from sensitive areas would be required for low boom or high boom application, respectively, in order to reduce exposures to the AOEL. Predicted exposures for children playing directly on a treated area are also substantially higher than the AOEL. The risk assessment includes a number of default assumptions which leads to conservatism in the risk assessment. Information that could potentially be used to refine the risk assessment includes: Dermal absorption data for the active ingredients in the Para-Ken 250 formulation Information on the expected work rates per day for each use scenario Operator exposure studies Confirmation that the application rate relates to the paraquat ion Information on the relevance of the recreational exposure scenario included in the present risk assessment However, with regard to dermal absorption, Staff note that even if the low value of 0.5% absorption proposed by the EU in 2002 were confirmed as being suitable for use in the risk assessment, this would lead to predicted exposures greater than the AOEL for operators mixing, loading and applying Para-Ken 250 Herbicide by boom and knapsack application methods (RQs of 4 and 6, respectively). April 2016 22 6. Environmental risk assessment Para-Ken 250 Herbicide contains paraquat dichloride and is proposed to be used in a higher application rate than other approved substances containing paraquat dichloride. Therefore, a quantitative risk assessment for the environment was undertaken. 6.1. Robust studies with the active ingredient The information on the environmental fate and behaviour and ecotoxicological data of paraquat dichloride are depicted in Table 1 and Table 2. April 2016 Table 3: Summary of environmental fate data on paraquat dichloride Test Paraquat dichloride Hydrolytically stable at pH 5, 7 and 9 after 30 Hydrolysis days at 25 and 40 °C. Rapid biodegradation in Not rapidly biodegradable. water Photolytically stable at environmentally Aqueous photolysis relevant wavelengths. Aerobic degradation in water (water/sediment) Anaerobic degradation The log Kow for paraquat dichloride is -4.5 at Bioaccumulation 20 °C indicating that bioaccumulation is unlikely. Paraquat is expected to be almost immobile Aerobic degradation in soil in soil. The estimated average field half-life of (laboratory) paraquat in soil is 1000 days. Aerobic degradation in soil No half-life calculated, estimates indicate (field) more than 10 years. Soil photolysis - Adsorption/desorption Koc = 1000000 (Koc values) Volatilisation - No data provided Not relevant, due to low vapour pressure. 24 Table 4: Summary of ecotoxicological data on paraquat dichloride – Values in bold are used for the risk assessment. Test Paraquat dichloride Reference Paraquat 20% SL Acute / fish LC50 = 10.85 mg/L (Barbus sharpeyi) EPA internal database LC50 = 141.42 mg/L, equivalent to 28.28 mg a.i./L) Acute / aquatic invertebrates EC50 = 1.2 mg/L (Daphnia magna) EPA internal database EC50 = 17.43 mg/L, equivalent to 3.49 mg a.i./L ErC50 = 2.41 mg/L, equivalent to 0.48 mg a.i/L EC50 = 0.32 mg/L (Selenastrum capricornutum) EPA internal database EC50 = 0.00055 mg/L (Naviculla peliculosa) EPA internal database - EC50 = 0.098 mg/L EPA internal database - Chronic / fish - - - Chronic / Aquatic invertebrates NOEC = 0.12 mg/L SANCO, 2003 - Chronic toxicity sediment dwelling organism Chironomus NOEC = 100 mg/kg (sediment); SANCO, 2003 - Algae Algae - diatom Aquatic plant (Lemna gibba) (Pseudokirchneriella subcapitata) (Daphnia magna) NOEC = 0.367 mg/L (water phase only) Acute / Earthworm LC50 > 1380 mg/kg soil EPA internal database LC50 > 210 mg a.i./kg soil Chronic / Earthworm - - - SANCO, 2003 No adverse effects on carbon and nitrogen transformations after application up to 3 kg a.i./ha. Soil microorganisms No adverse effects were observed after application up to 720 kg ai/ha in one year. EC25 = 0.95 kg/ha (seedling emergence, cocklebur) Non target plants EC25 = 0.015 kg/ha (vegetative vigour, cocklebur) April 2016 EPA internal database 25 NOEC = 0.004 kg/ha (vegetative vigour, cocklebur) LD50 = 35 mg/kg bw Acute / bird LD50 = 176 mg/kg bw Reproduction bird NOEC = 2.8 mg/kg bw/d LD50 (contact) = 9.26 µg/bee Acute / bees Non target arthropods - SANCO, 2003 EPA internal database LD50 = 775.92 mg/kg bw, equivalent to 155.2 mg a.i./kg bw USEPA, 1997 SANCO, 2003 EPA internal database LD50 (oral) = 9.06 µg/bee (120-hr study) SANCO, 2003 - - LD50 (contact) = 41.23 µg/bee (equivalent to 8.25 µg a.i./bee) - No data provided 6.2. Risk assessment Methodology Methods used to assess environmental exposure and risk differ between environmental compartments (Table 5). Table 5 Reference documents for environmental exposure and risk assessments Aquatic organisms Environmental exposure Risk assessment (GEN)eric (E)stimated (E)nvironmental (C)oncentration Model Version 2.0 – 01 August 2002 Overview of the Ecological Risk Assessment Process in the Office of Pesticide Programs, U.S. Environmental Protection Agency. Endangered and threatened Species Effects Determinations – 23 January 2004 AgDrift and EPA Software12 12 The Staff used two different models for assessing the EEC and associated risks: Generic Estimated Environmental Concentration Model v2 (GENEEC2) surface water exposure model (USEPA, 2001) estimates the concentration of substance in surface water which may arise as a result of surface runoff and spraydrift. To examine how buffer zones would reduce the active ingredient concentrations in receiving waters, the Staff used the AgDRIFT® model (developed under a cooperative Research and Development Agreement, CRADA, between the EPA, USDA, US Forest Service, and SDTF). AgDRIFT® incorporates a proposed overall method for evaluating offsite deposition of aerial, orchard or ground applied pesticides, and acts as a tool for evaluating the potential of buffer zones to protect sensitive aquatic and terrestrial habitats from undesired exposures. Calculations are made assuming the receiving water is a 30 cm deep pond. The model is used to estimate the buffer zone that would reduce exposure through spray drift to such a concentration that an acute risk quotient of 0.1 cannot be calculated. It is noted that April 2016 26 Guidance on information requirements and Sediment organisms chemical safety assessment, Chapter R.16: Environmental Exposure Estimation, Version: 2 May 2010 Guidance on information requirements and chemical safety assessment, Chapter R.10: Characterisation of dose [concentration]-response for environment – May 2008 Soil organisms, invertebrates (macroinvertebrates) Soil persistence models and EU registration. The final report of the work of the Soil Modelling Work group of FOCUS (FOrum for the Co-ordination of pesticide fate models and their USe) – 29 February 1997 Bees Guidance for assessing pesticide risks to bees. US EPA, Health Canada Pest Management Regulatory Agency, California Department of Pesticide Regulation, 19 June 2014 Terrestrial organisms, invertebrates (nontarget arthropods) Guidance document on regulatory testing and risk assessment procedures for plant protection products with non-target arthropods. From ESCORT 2 Workshop – 21/23 March 2000 SANCO/10329/2002 rev 2 final. Guidance Document on terrestrial ecotoxicology under Council Directive 91/414/EEC- 17 October 2002 Guidance of EFSA. Risk assessment to birds and mammals – 17 December 2009. Terrestrial vertebrates (birds) Secondary poisoning and biomagnification EFSA calculator tool - 200913 SANCO/4145/2000 final. Guidance Document on risk assessment for birds and mammals under Council Directive 91/414/EEC- 25 September 2002 Technical Guidance Document on risk assessment in support of Commission Directive 93/67/EEC on Risk Assessment for new notified substances, Commission Regulation (EC) No 1488/94 on Risk Assessment for existing substances, Directive 98/8/EC of the European Parliament and of the Council concerning the placing of biocidal products on the market – Part II - 2003 Guidance of EFSA. Risk assessment to birds and mammals – 17 December 2009 EFSA calculator tool - 2009 SANCO/4145/2000 final. Guidance Document on risk assessment for birds and mammals under Council Directive 91/414/EEC- 25 September 2002 6.3. Consideration of threatened native species unlike GENEEC2, AgDRIFT® model only considers transport by spray drift, input through runoff, volatilisation, etc. will pose additional risks. 13 www.efsa.europa.eu/en/efsajournal/pub/1438.htm April 2016 27 No studies are requested to be conducted on native New Zealand species; the risk assessment is based on studies performed on standard surrogate species from Europe or North America. Uncertainty factors included in the risk assessment process encompass the possible susceptibility variations between the surrogate species and the native New Zealand species. However, these factors are designed to protect populations not individual organisms. EPA staff acknowledge that these factors may not be protective enough for threatened species for which the survival of the population could depend on the survival of each and every individual. Therefore, the US EPA approach for risk assessment of endangered species has been implemented. Additional uncertainty factors are included, depending on the type of organisms. US EPA consider higher factors when organisms cannot escape the contaminated area (for aquatic organisms for instance) than for birds. US EPA has not defined any additional factor for soil organisms except for plants, so EPA staff applied the same approach as for aquatic environment, considering that soil invertebrates won’t be able to escape from the contaminated area. For the purpose of this risk assessment, the threatened species are those included in the following categories of the New Zealand Threat Classification System: threatened (Nationally critical, Nationally endangered, Nationally vulnerable) and at risk (declining, recovering, relict, and naturally uncommon). 6.4. Aquatic risk assessment For Class 9 substances, irrespective of the intrinsic hazard classification, the ecological risk can be assessed for a substance by calculating a Risk Quotient (RQ) based on an estimated exposure concentration. Such calculations incorporate toxicity values, exposure scenarios (including spray drift, leaching and run-off, application rates and frequencies), and the half-lives of the component(s) in water. For the aquatic environment, the calculations provide an Estimated Environmental Concentration (EEC) which, when divided by the L(E)C50 or a NOEC, gives a RQ acute or chronic. 𝐴𝑐𝑢𝑡𝑒 𝑅𝑄 = 𝐸𝐸𝐶𝑠ℎ𝑜𝑟𝑡−𝑡𝑒𝑟𝑚 𝐿(𝐸)𝐶50 𝐶ℎ𝑟𝑜𝑛𝑖𝑐 𝑅𝑄 = 𝐸𝐸𝐶𝑙𝑜𝑛𝑔−𝑡𝑒𝑟𝑚 𝑁𝑂𝐸𝐶 If the RQ exceeds a predefined level of concern, this suggests that it may be appropriate to refine the assessment or apply the approved handler control and/or other controls to ensure that appropriate matters are taken into account to minimize off-site movement of the substance. Conversely, if a worst-case scenario is used, and the level of concern is not exceeded, then in terms of the environment, there is a presumption of April 2016 28 low risk which is able to be adequately managed by such things as label statements (warnings, disposal). The approved handler control can then be removed on a selective basis. Levels Of Concern (LOC) developed by the USEPA (Urban and Cook, 1986) and adopted by EPA determine whether a substance poses an environmental risk (Table 6). Table 6 Levels of concern as adopted by EPA New Zealand Endpoint LOC Presumption Aquatic (fish, invertebrates, algae, aquatic plants) Acute RQ ≥ 0.5 High acute risk Acute RQ 0.1 - 0.5 Risk can be mitigated through restricted use Acute RQ < 0.1 Low risk Chronic RQ ≥1 High chronic risk Aquatic threatened species Acute RQ ≥ 0.05 High acute risk Chronic RQ ≥ 0.1 High chronic risk RQ ≥ 1 calculated on the basis of EC25 or TER < 5 calculated on the basis of EC50 High acute risk Plants (terrestrial) Acute RQ /TER Threatened plants species (terrestrial) Acute RQ ≥ 1 calculated on the basis of the NOEC or EC05 High acute risk 6.4.1. GENEEC2 modelling Calculation of expected environmental concentrations The parameters used in GENEEC2 modelling are listed in Table 7. Table 7 Input parameters for GENEEC2 analysis April 2016 29 Non-crop Non selective Clover seed fence lines, weed crops streets, control industrial (barley sites grass) 400 Application frequency 1-2 Application interval (days) 28 days Koc* 15 473 Aerobic soil DT50 (days) 1000 Pesticide wetted in? No HV broadcast Methods of application ‘No spray’ zone No Water solubility (ppm) 620 000 Hydrolysis (DT50 in days) Stable Aerobic aquatic DT50 whole system (days)** 2000 Aqueous photolysis DT50 (days) Stable 1500 1000 600 600 - 1500 1-4 1-2 1-2 1-4 HV broadcast, knapsack, handgun HV broadcast HV broadcast Handgun 0.03223 0.01091 0.00652 Low dose = 0.01284 0.00437 *Lowest value of a non sand soil ** Twice the value of the DT50 soil according to the GENEEC2 recommendations Output from the GENEEC2 model for paraquat dichloride April 2016 Lucerne situations: Application rate (g a.i./ha) Highest concentration Peak EEC (mg/L) Forestry High dose = 0.03223 30 RUN No. 1 FOR Paraquat dichlor ON Clover * INPUT VALUES * -------------------------------------------------------------------RATE (#/AC) No.APPS & SOIL SOLUBIL APPL TYPE NO-SPRAY INCORP ONE(MULT) INTERVAL Koc (PPM ) (%DRIFT) (FT) (IN) -------------------------------------------------------------------0.356( 0.705) 2 28 15473.0******* GRHIFI( 6.6) 0.0 0.0 FIELD AND STANDARD POND HALFLIFE VALUES (DAYS) -------------------------------------------------------------------METABOLIC DAYS UNTIL HYDROLYSIS PHOTOLYSIS METABOLIC COMBINED (FIELD) RAIN/RUNOFF (POND) (POND-EFF) (POND) (POND) -------------------------------------------------------------------1000.00 2 0.00 0.000.00 ****** 2000.00 GENERIC EECs (IN MICROGRAMS/LITER (PPB)) Version 2.0 Aug 1, 2001 -------------------------------------------------------------------PEAK MAX 4 DAY MAX 21 DAY MAX 60 DAY MAX 90 DAY GEEC AVG GEEC AVG GEEC AVG GEEC AVG GEEC -------------------------------------------------------------------4.37 4.17 3.19 1.92 1.43 RUN No. 2 FOR Paraquat dichlor ON Non crop s * INPUT VALUES * -------------------------------------------------------------------RATE (#/AC) No.APPS & SOIL SOLUBIL APPL TYPE NO-SPRAY INCORP ONE(MULT) INTERVAL Koc (PPM ) (%DRIFT) (FT) (IN) -------------------------------------------------------------------1.335( 5.190) 4 28 15473.0******* GRHIFI( 6.6) 0.0 0.0 FIELD AND STANDARD POND HALFLIFE VALUES (DAYS) -------------------------------------------------------------------METABOLIC DAYS UNTIL HYDROLYSIS PHOTOLYSIS METABOLIC COMBINED (FIELD) RAIN/RUNOFF (POND) (POND-EFF) (POND) (POND) -------------------------------------------------------------------1000.00 2 N/A 0.000.00 ****** 2000.00 GENERIC EECs (IN MICROGRAMS/LITER (PPB)) Version 2.0 Aug 1, 2001 -------------------------------------------------------------------PEAK MAX 4 DAY MAX 21 DAY MAX 60 DAY MAX 90 DAY GEEC AVG GEEC AVG GEEC AVG GEEC AVG GEEC -------------------------------------------------------------------32.23 30.82 23.55 14.19 10.54 RUN No. 3 FOR Paraquat dichlor ON Forestry * INPUT VALUES * -------------------------------------------------------------------RATE (#/AC) No.APPS & SOIL SOLUBIL APPL TYPE NO-SPRAY INCORP ONE(MULT) INTERVAL Koc (PPM ) (%DRIFT) (FT) (IN) -------------------------------------------------------------------0.890( 1.764) 2 28 15473.0******* GRHIFI( 6.6) 0.0 0.0 April 2016 31 FIELD AND STANDARD POND HALFLIFE VALUES (DAYS) -------------------------------------------------------------------METABOLIC DAYS UNTIL HYDROLYSIS PHOTOLYSIS METABOLIC COMBINED (FIELD) RAIN/RUNOFF (POND) (POND-EFF) (POND) (POND) -------------------------------------------------------------------1000.00 2 N/A 0.000.00 ****** 2000.00 GENERIC EECs (IN MICROGRAMS/LITER (PPB)) Version 2.0 Aug 1, 2001 -------------------------------------------------------------------PEAK MAX 4 DAY MAX 21 DAY MAX 60 DAY MAX 90 DAY GEEC AVG GEEC AVG GEEC AVG GEEC AVG GEEC -------------------------------------------------------------------10.91 10.44 7.97 4.80 3.57 RUN No. 4 FOR Paraquat dichlor ON Lucerne * INPUT VALUES * -------------------------------------------------------------------RATE (#/AC) No.APPS & SOIL SOLUBIL APPL TYPE NO-SPRAY INCORP ONE(MULT) INTERVAL Koc (PPM ) (%DRIFT) (FT) (IN) -------------------------------------------------------------------0.534( 1.058) 2 28 15743.0******* GRHIFI( 6.6) 0.0 0.0 FIELD AND STANDARD POND HALFLIFE VALUES (DAYS) -------------------------------------------------------------------METABOLIC DAYS UNTIL HYDROLYSIS PHOTOLYSIS METABOLIC COMBINED (FIELD) RAIN/RUNOFF (POND) (POND-EFF) (POND) (POND) -------------------------------------------------------------------1000.00 2 N/A 0.000.00 ****** 2000.00 GENERIC EECs (IN MICROGRAMS/LITER (PPB)) Version 2.0 Aug 1, 2001 -------------------------------------------------------------------PEAK MAX 4 DAY MAX 21 DAY MAX 60 DAY MAX 90 DAY GEEC AVG GEEC AVG GEEC AVG GEEC AVG GEEC -------------------------------------------------------------------6.52 6.23 4.74 2.84 2.10 RUN No. 5 FOR Paraquat dichlor ON Non select * INPUT VALUES * -------------------------------------------------------------------RATE (#/AC) No.APPS & SOIL SOLUBIL APPL TYPE NO-SPRAY INCORP ONE(MULT) INTERVAL Koc (PPM ) (%DRIFT) (FT) (IN) -------------------------------------------------------------------0.534( 2.076) 4 28 15743.0******* GRHIFI( 6.6) 0.0 0.0 FIELD AND STANDARD POND HALFLIFE VALUES (DAYS) -------------------------------------------------------------------METABOLIC DAYS UNTIL HYDROLYSIS PHOTOLYSIS METABOLIC COMBINED (FIELD) RAIN/RUNOFF (POND) (POND-EFF) (POND) (POND) -------------------------------------------------------------------1000.00 2 N/A 0.000.00 ****** 2000.00 April 2016 32 GENERIC EECs (IN MICROGRAMS/LITER (PPB)) Version 2.0 Aug 1, 2001 -------------------------------------------------------------------PEAK MAX 4 DAY MAX 21 DAY MAX 60 DAY MAX 90 DAY GEEC AVG GEEC AVG GEEC AVG GEEC AVG GEEC -------------------------------------------------------------------12.84 12.27 9.33 5.59 4.14 The maximum Estimated Environmental Concentration (EEC) for paraquat dichloride when used in ParaKen 250 Herbicide for clover, forestry, lucerne, non-crop situations and non-selective weed control (barley grass) high and low rate estimated by GENEEC2 were 0.00433 mg/L, 0.01091 mg/L, 0.00652 mg/L, 0.03223 mg/L and 0.01284 mg/L, respectively. Calculation of acute risk quotients using GENEEC2 expected environmental concentrations Table 8 gives calculated acute risk quotients for each trophic level considering EEC estimated by GENEEC2 and lowest relevant toxicity figures. The calculations are based on a conservative model taking into account the degradation of the substance and its adsorption potential in order to cover both run-off, drift input into water bodies. The model also considers information about the application method to determine the drift input into water bodies. Table 8 Acute risk quotients derived from the GENEEC2 model and toxicity data Species Peak EEC from LC50 or EC50 GENEEC2 (mg/L) (mg/L) Acute RQ Trigger value / Presumption Clover - 0.4 kg a.i./ha, 2 applications at 28 days interval Fish < 0.1 / Risk below concern 10.85 0.0004 < 0.05 / Risk below concern for threatened species 0.00437 < 0.1 / Risk below concern Invertebrates April 2016 1.2 0.0036 < 0.05 / Risk below concern for threatened species 33 Species Peak EEC from LC50 or EC50 GENEEC2 (mg/L) (mg/L) Acute RQ Trigger value / Presumption < 0.1 / Risk below concern Algae Selenastrum capricornutum 0.32 0.014 Algae - diatom < 0.05 / Risk below concern for threatened species > 0.5 / High risk 0.00055 (Navicula pelliculosa) 7.94 > 0.05 / High risk for threatened species < 0.1 / Risk below concern Aquatic plant 0.098 0.045 (Lemna gibba) < 0.05 / Risk below concern for threatened species Forestry - 1 kg a.i./ha, 2 applications at 28 days interval Fish < 0.1 / Risk below concern 10.85 0.001 < 0.1 / Risk below concern Invertebrates 1.2 0.009 (Daphnia magna) Algae Selenastrum capricornutum 0.01091 0.32 0.034 < 0.05 / Risk below concern for threatened species > 0.5 / High risk 0.00055 19.84 Aquatic plant 0.098 (Lemna gibba) Lucerne - 0.6 kg a.i./ha, 2 applications at 28 days interval April 2016 < 0.05 / Risk below concern for threatened species < 0.1 / Risk below concern Algae - diatom (Navicula pelliculosa) < 0.05 / Risk below concern for threatened species 0.11 > 0.05 / High risk for threatened species 0.1-0.5 / Risk can be mitigated through restricted use > 0.05 / High risk for threatened species 34 Species Peak EEC from LC50 or EC50 GENEEC2 (mg/L) (mg/L) Acute RQ Trigger value / Presumption < 0.1 / Risk below concern 10.85 Fish 0.0006 < 0.1 / Risk below concern Invertebrates 1.2 0.0054 (Daphnia magna) Algae Selenastrum capricornutum < 0.05 / Risk below concern for threatened species < 0.05 / Risk below concern for threatened species < 0.1 / Risk below concern 0.00652 0.32 0.02 Algae - diatom < 0.05 / Risk below concern for threatened species > 0.5 / High risk 0.00055 (Navicula pelliculosa) 11.85 > 0.05 / High risk for threatened species < 0.1 / Risk below concern Aquatic plant 0.098 0.067 (Lemna gibba) > 0.05 / High risk for threatened species Barley grass control – 1.5 kg a.i./ha, 4 applications at 28 days interval Fish < 0.1 / Risk below concern 10.85 0.00297 < 0.1 / Risk below concern Invertebrates (Daphnia magna) 0.03223 1.2 0.027 < 0.05 / Risk below concern for threatened species < 0.1 / Risk below concern Algae Selenastrum capricornutum 0.32 Algae - diatom 0.00055 April 2016 < 0.05 / Risk below concern for threatened species 0.1 > 0.05 / High risk for threatened species 58.6 > 0.5 / High risk 35 Species Peak EEC from LC50 or EC50 GENEEC2 (mg/L) (mg/L) Acute RQ (Navicula pelliculosa) Trigger value / Presumption > 0.05 / High risk for threatened species Aquatic plant 0.098 0.33 (Lemna gibba) 0.1-0.5 / Risk can be mitigated through restricted use > 0.05 / High risk for threatened species Barley grass control, lower rate – 0.6 kg a.i./ha, 4 applications at 28 days interval Fish < 0.1 / Risk below concern 10.85 0.0011 < 0.1 / Risk below concern Invertebrates 1.2 0.0107 (Daphnia magna) Algae Selenastrum capricornutum < 0.05 / Risk below concern for threatened species < 0.05 / Risk below concern for threatened species < 0.1 / Risk below concern 0.01284 0.32 0.04 Algae - diatom < 0.05 / Risk below concern for threatened species > 0.5 / High risk 0.00055 (Navicula pelliculosa) 23.35 Aquatic plant 0.098 0.13 (Lemna gibba) > 0.05 / High risk for threatened species 0.1-0.5 / Risk can be mitigated through restricted use > 0.05 / High risk for threatened species Non-crop situations – 1.5 kg a.i./ha, 4 applications at 28 days interval Fish < 0.1 / Risk below concern 0.03223 April 2016 10.85 0.00297 < 0.05 / Risk below concern for threatened species 36 Species Peak EEC from LC50 or EC50 GENEEC2 (mg/L) (mg/L) Acute RQ Trigger value / Presumption < 0.1 / Risk below concern Invertebrates 1.2 0.027 < 0.05 / Risk below concern for threatened species (Daphnia magna) < 0.1 / Risk below concern Algae Selenastrum capricornutum 0.32 0.1 > 0.05 / High risk for threatened species Algae - diatom > 0.5 / High risk 0.00055 (Navicula pelliculosa) 58.6 > 0.05 / High risk for threatened species 0.1-0.5 / Risk can be mitigated through restricted use Aquatic plant 0.098 0.33 (Lemna gibba) > 0.05 / High risk for threatened species Conclusion for the aquatic acute risk assessment using GENEEC2 data Acute risks were below the level of concern for fish and aquatic invertebrates for all the use scenarios. High acute risks for algae were observed for all use scenarios. High acute risks for threatened plant species were observed for forestry, Lucerne, non selective weed control and non-crop situations. Calculation of chronic risk quotients using GEENEC2 expected environmental concentrations Table 9 gives calculated chronic risk quotients for each trophic level considering EEC estimated by GENEEC2 and lowest relevant toxicity figures. Table 9 Chronic risk quotients derived from the GENEEC2 model and toxicity data Species Relevant EEC from NOEC Chronic Trigger value / GENEEC2 (mg /L)* (mg/L) RQ Presumption Clover seed - 0.4 kg a.i./ha, 4 applications at 28 days interval < 1 / Risk below concern Invertebrates Daphnia magna (21 d) April 2016 0.00319 0.12 0.026 < 0.1 / Risk below concern for threatened species 37 Non-crop situations: Fence lines, streets, industrial - 1.5 kg a.i./ha, 4 applications at 28 days interval < 1 / Risk below concern Invertebrates Daphnia magna (21 d) 0.02355 0.12 0.1965 > 0.1 / High chronic risk to threatened species Forestry - 1 kg a.i./ha, 2 applications at 28 days interval < 1 / Risk below concern Invertebrates Daphnia magna (21 d) 0.00797 0.12 0.066 < 0.1 / Risk below concern for threatened species Lucerne - 0.6 kg a.i./ha, 2 applications at 28 days interval < 1 / Risk below concern Invertebrates Daphnia magna (21 d) 0.00474 0.12 0.0395 < 0.1 / Risk below concern for threatened species Barley grass control - 1.5 kg a.i./ha, 4 applications at 28 days interval < 1 / Risk below concern Invertebrates Daphnia magna (21 d) 0.02355 0.12 0.19 > 0.1 / High chronic risk to threatened species Barley grass control, low rate - 0.6 kg a.i./ha, 4 applications at 28 days interval < 1 / Risk below concern Invertebrates Daphnia magna (21 d) 0.00933 0.12 0.077 < 0.1 / Risk below concern for threatened species * EEC selected must be as close as possible from the exposure duration of the study selected for risk assessment purpose. Conclusion for the aquatic chronic risk assessment using GENEEC2 data Chronic risks were below the level of concern for aquatic invertebrates, but high chornic risks for threatened aquatic invertebrates species were observed for the application on non-crop situations and non-selective control at the highest application rate of 1.5 kg paraquat dichloride per hectare. There were no data to assess the chronic risks to fish. The staff consider that the lack of chronic data on fish does not prevent the conclusion of the risk assessment. AgDRIFT modelling April 2016 38 Further modelling using the AgDRIFT® tool was undertaken in order to refine this result and provide an indication of the extent of the measures that would need to be taken in order to manage the risks so that they are reduced below the level of concern that is indicated in the modelling. AgDRIFT® modelling does not allow determining EEC per se. AgDRIFT® modelling output is a buffer zone determination to be respected in order to get a risk quotient < 1. Output from the AgDRIFTmodel The AgDRIFT® tool utilises buffer zones as a means of mitigating risks to non-target organisms, with higher risks resulting in larger buffer zone distances as the model’s output. As such, the buffer zone outputs of the model provide a relative measure of the risks to the environment and the extent of the mitigation measures that should be applied. The results of the AgDRIFT ® assessment confirmed that measures should be taken during use to ensure that waterways are not exposed to the substance. Based on the application rates and proposed scenarios of use recommended for Para-Ken 250 Herbicide, using coarse nozzles, the environmental fate characteristics and the lowest acute figure for the most sensitive taxa (EC50 = 0.00055 mg/L) for paraquat dichloride on the diatom Navicula pelliculosa, the model concludes that a buffer zone higher than 254 m (highest buffer zone possible to calculate in AgDrift) is needed for all use scenarios. It should be pointed out that this buffer zone higher than 254 meters is already applicable at 400 g a.i./ha, the lowest proposed application rate. Due to model limitations, it was not possible to provide a quantitative estimate of exposure with known uncertainty, beyond the range of AgDRIFT. The additional safety factor for threatened species was not taken into consideration because there is currently no list of endangered algae species for NZ. In conclusion, staff consider that there are no adequate mitigation measures to protect algae from the application of Para-Ken 250 Herbicide. 6.5. Groundwater risk assessment Estimated concentrations of chemicals with Koc values greater than 9995 L/kg are beyond the scope of the regression data used in SCI-GROW model. The staff consider that due to the high adsorption of paraquat dichloride and the fact that it is almost immobile in the soil will preclude a potential risk of groundwater contamination. 6.6. Sediment risk assessment Sediments may act as both a sink for chemicals through sorption of contaminants to particulate matter, and a source of chemicals through resuspension. Sediments integrate the effects of surface water contamination April 2016 39 over time and space, and may thus present a hazard to aquatic communities (both pelagic and benthic) which is not directly predictable from concentrations in the water column. When results from whole-sediment tests with benthic organisms are available the PNECsed has to be derived from these tests using assessment factors. However, the available sediment tests should be carefully evaluated. Special attention should be given to the pathways through which the test organisms are exposed to the chemical and the test protocol should carefully be checked to determine whether feeding with unspiked food has possibly reduced exposure via sediment ingestion. For assessing the toxicity of spiked sediment it is necessary to address adequately all possible routes of exposure. Sediment organisms can be exposed via their body surfaces to substances in solution in the overlying water and in the pore water and to bound substances by direct contact or via ingestion of contaminated sediment particles. The route that is most important is strongly influenced by species-specific feeding mechanisms and the behaviour of the organism in, or on, the sediment. Test design parameters can have a bearing on the route of uptake of a substance. The PNECsed is derived from the lowest available NOEC/EC10 obtained in long-term tests by application of the following assessment factors and is then expressed as mg/kg of dry sediment: Table 10 Assessment factors for derivation of PNECsed Available test result One long-term test (NOEC or EC10) 100 Two long-term tests (NOEC or EC10) with species representing different living and feeding conditions 50 Three long-term tests (NOEC or EC10) with species representing different living and feeding conditions 10 Using the toxicity figures from the tests with spiked sediment on the reproduction of Chironomus, and dividing by the appropriate assessment factor of 100, the calculated PNEC sed is 1 mg/kg dry sediment for paraquat dichloride. PEClocal for sediment can be compared to the PNEC for sediment dwelling organisms. The concentration in freshly deposited sediment is taken as the PEC for sediment, therefore, the properties of suspended matter are used. The concentration in bulk sediment can be derived from the corresponding water body concentration, assuming a thermodynamic partitioning equilibrium (see also Di Toro et al., 1991): 𝑃𝐸𝐶𝑙𝑜𝑐𝑎𝑙 𝑠𝑒𝑑 = 𝐾𝑝 𝑠𝑢𝑠𝑝 − 𝑤𝑎𝑡𝑒𝑟 × 𝑃𝐸𝐶 𝑙𝑜𝑐𝑎𝑙 𝑤𝑎𝑡𝑒𝑟 × 1000 𝑅𝐻𝑂 𝑠𝑢𝑠𝑝 Where PEClocal water concentration in surface water during release episode based on GENEEC2 modelling (mg/L) April 2016 40 Ksusp-water suspended matter-water partitioning coefficient = 5.65 (m 3/m3). Equation R.16-7 of REACH TGD R16. RHOsusp bulk density of suspended matter = 1150 (kg/m 3) Equation R.16-16 of REACH TGD R16. PEClocal sed predicted environmental concentration in sediment (mg/kg) The worst-case scenario for the concentration expected to be measured in pore-water is the expected concentration in the water column (i.e. 0.00895 mg/L, according to GENEEC2), therefore PEClocal sed = 0.043 mg/kg sediment for paraquat. The risk for sediment-dwelling organisms is assessed as the ratio PECsed/PNECsed. This ratio is 0.043 for paraquat. Conclusion for the sediment risk assessment: Risks for sediment dwelling organisms due to paraquat are below the level of concern (LoC < 1). 6.7. Terrestrial risk assessment For terrestrial organisms, Toxicity-Exposure Ratios (TERs) are used for earthworms and birds, Hazard Quotient (HQ) are used for terrestrial invertebrates and Risk Quotient (RQ) for bees. This convention results in concern arising if a risk quotient is less than the trigger value for earthworms and more than a trigger value for terrestrial invertebrates. LOC developed by the European Union and adopted by the Staff allowing determining whether a substance poses an environmental risk are provided in the Table 11. Table 11 Levels of concern as adopted by the Staff Level of Concern (LOC) Presumption Acute TER < 10 High risk Chronic TER <5 High risk Acute TER < 20 High risk Chronic TER < 10 High risk Acute TER < 100 High risk Chronic TER < 50 High risk > 0.4 High risk Earthworm/ Birds Threatened bird species Threatened soil organisms species Bees Acute RQ oral/contact April 2016 41 Chronic RQ >1 High risk ≥2 High risk Terrestrial invertebrates HQ in-field/off-field For more details about the different factors used for calculating TER and RQ refer to the relevant reference documents listed in Table 5. 6.7.1. Earthworm risk assessment Soil Predicted Environmental Concentration (PEC) determination Both acute and reproductive earthworm tests are static tests where the test substance is applied to the system only once at the beginning. Therefore the nominal dose levels in the test match initial concentrations in the field and thus it is appropriate to use initial PEC values (no time-weighted averages) for the acute as well as the long-term TER. The concentration of active substance in the soil is calculated on the basis of the FOCUS (1997) document ‘Soil persistence models and EU registration’ 𝑃𝐸𝐶 𝑜𝑛𝑒 𝑎𝑝𝑝𝑙𝑖𝑐𝑎𝑡𝑖𝑜𝑛 (mg/kg soil) = 𝑎𝑝𝑝𝑙𝑖𝑐𝑎𝑡𝑖𝑜𝑛 𝑟𝑎𝑡𝑒 (kg a.i./ha) × 100 75 𝑘𝑔 𝑠𝑜𝑖𝑙 Soil concentrations of the active ingredient are calculated by assuming the deposition would mix into the top 5 cm of soil, and this soil would have a bulk density of 1,500 kg/m 3, i.e. the deposition expressed in mg/m2 would mix into 75 kg of soil. In case of multiple applications, the following formula has to be used: 𝑃𝐸𝐶 𝑚𝑢𝑙𝑡𝑖𝑝𝑙𝑒 𝑎𝑝𝑝𝑙𝑖𝑐𝑎𝑡𝑖𝑜𝑛𝑠 = 𝑃𝐸𝐶 𝑜𝑛𝑒 𝑎𝑝𝑝𝑙𝑖𝑐𝑎𝑡𝑖𝑜𝑛 × (1 − 𝑒 −𝑛𝑘𝑖 ) (1 − 𝑒 −𝑘𝑖 ) where: n = number of applications k = ln2/DT50 (day-1) i = interval between two consecutive applications (days) DT50 = half-life in soil (days) Use only DT 50 values of lab test done at 10-20 oC and pH between 5 and 9. e = 2.718 (constant) When there are DT50 values of several soils use GENEEC2 formula for determining the relevant DT50 to be used. PEC calculation results are summarized for each scenario in Table 12 and Table 13. Calculation of TERs 𝑇𝐸𝑅𝑎𝑐𝑢𝑡𝑒 = April 2016 𝐿𝐷50 𝐸𝑠𝑡𝑖𝑚𝑎𝑡𝑒𝑑 𝐸𝑛𝑣𝑖𝑟𝑜𝑛𝑚𝑒𝑛𝑡𝑎𝑙 𝐶𝑜𝑛𝑐𝑒𝑛𝑡𝑟𝑎𝑡𝑖𝑜𝑛 42 𝑇𝐸𝑅𝑙𝑜𝑛𝑔 − 𝑡𝑒𝑟𝑚 = 𝑁𝑂𝐸𝐶 𝐸𝑠𝑡𝑖𝑚𝑎𝑡𝑒𝑑 𝐸𝑛𝑣𝑖𝑟𝑜𝑛𝑚𝑒𝑛𝑡𝑎𝑙 𝐶𝑜𝑛𝑐𝑒𝑛𝑡𝑟𝑎𝑡𝑖𝑜𝑛 Table 12 Acute in-field TER value for earthworms Scenarios Clover – 2 applications of 0.4 kg a.i./ha at 28 days interval Non-crop land (streets, fence lines, industrial) - 4 applications of 1.5 kg a.i./ha at 28 days interval PEC (mg/kg LC50 soil) (mg/kg soil) Trigger value TER acute Presumption 1.06 >1306 7.77 >178 > 10 / Risk below concern Forestry – 2 applications of 0.6 kg a.i./ha at 28 days interval 2.64 Lucerne – 2 application of 0.6 kg a.i./ha at 28 days interval 1.58 >871 7.77 >178 Barley grass control – 4 applications of 1.5 kg a.i./ha at 28 days interval / >523 >1380 >100 / Risk below concern for threatened species Table 13 Acute off-field TER value for earthworms Scenarios Clover – 2 applications of 0.4 kg a.i./ha at 28 days interval Non-crop land (streets, fence lines) - 4 applications of 1.5 kg a.i./ha at 28 days interval PEC (mg/kg LC50 soil) (mg/kg soil) Trigger value TER acute Presumption >19792 0.07 0.51 >2690 Forestry – 2 applications of 0.6 kg a.i./ha at 28 days interval 0.17 >7917 Lucerne – 2 application of 0.6 kg a.i./ha at 28 days interval 0.10 Barley grass control – 4 applications of 1.5 kg a.i./ha at 28 days interval 0.51 Conclusion for earthworm acute risk assessment April 2016 / >1380 >13195 >2690 > 10 / Risk below concern > 100 / Risk below concern for threatened species 43 Risks were below the level of concern for off-field situations (outside the crop area) and for in-field (inside the crop area) for earthworm species (including threatened species). Conclusion for earthworm chronic risk assessment There is no information about the chronic effects of paraquat dichloride to earthworms. Conclusion for earthworm risk assessment Risk to earthworms in-field (inside the crop area) and off-field (outside the crop area) were below the level of concern. 6.7.2. Non-target plant risk assessment Non target plants are non-crop plants located outside the treatment area. Spray drift is considered the key exposure route for terrestrial plants located in the vicinity of the treated area. The drift models produced by the BBA for the exposure assessment of aquatic organisms may be used as a surrogate to cover the exposure assessment of terrestrial plants (Ganzelmeier et al., 1995, recently updated by Rautmann et al., 2001). Table 15 and Table 14 shows the drift expressed as percentage of the applied dose: Table 15 Basic drift values for two applications Ground deposition in % of the application rate (82nd percentiles) Distance Field crops Fruit crops Grapevine Hops Vegetables Ornamentals Small fruit Height [m] Early late Early late < 50 cm 1 2.38 3 Height > 50 cm 2.38 25.53 12.13 2.53 7.23 17.73 7.23 5 0.47 16.87 6.81 1.09 3.22 9.60 0.47 3.22 10 0.24 9.61 3.11 0.35 1.07 4.18 0.24 1.07 15 0.16 5.61 1.58 0.18 0.56 2.57 0.16 0.56 20 0.12 2.59 0.9 0.11 0.36 1.21 0.12 0.36 30 0.08 0.87 0.4 0.06 0.19 0.38 0.08 0.19 Table 16 Basic drift values for four applications Ground deposition in % of the application rate (74th percentiles) April 2016 44 Distance Field crops Fruit crops Grapevine Hops Vegetables Ornamentals Small fruit Height [m] Early late Early late < 50 cm 1 1.85 3 Height > 50 cm 1.85 23.61 10.12 2.44 6.71 15.38 6.71 5 0.38 15.42 5.6 1.02 2.99 8.26 0.38 2.99 10 0.19 8.66 2.5 0.31 0.99 3.55 0.19 0.99 15 0.13 4.91 1.28 0.16 0.52 2.17 0.13 0.52 20 0.1 2.21 0.75 0.1 0.33 0.93 0.1 0.33 30 0.06 0.72 0.35 0.05 0.17 0.31 0.06 0.17 40 0.05 0.32 0.2 0.03 0.11 0.14 0.05 0.11 50 0.04 0.17 0.13 0.02 0.08 0.08 0.04 0.08 In fruit, grapevine and hops for herbicides (but not for plant growth regulators) that are applied to the ground, the column “field crops” is applicable. It should be noted that these drift data have been generated with regard to intake into surface waters. In particular, there is no vegetation barrier between the spray boom and the collector plates. In terrestrial scenarios, however, horizontal and vertical interception by in-crop or off-crop vegetation as well as patchy distribution is relevant (“three-dimensional-situation“); thus, when more realistic drift data become available they should be used. The initial assessment should be conducted for a distance of 1 m from the field edge for field crops, vegetables or ground applications such as for herbicides, and 3 m for other crops. Risk mitigation measures based on buffer zones within the crop area can also be quantified using the above table. In case of aerial applications a deposition rate of 100 % is assumed as the default, however this figure may be refined by applying appropriate models (e.g. AgDrift). This tier is a quantitative risk assessment following a RQ approach. Both effects and exposure are expressed in terms of application rate (g/ha). Effects data are represented by ER 25 values from the studies, also expressed as g/ha. Table 17 TER value for non target plant – seedling emergence April 2016 45 Exposure = Scenarios Drift (%) drift x EC25 application (g ai/ha) RQ Trigger value / Presumption rate (g ai/ha) 9.52 Clover 0.01 2.38 at 1 m Non-crop land, fence lines, streets, industrial sites 1.85 at 1 m Forestry 25.53 at 1 m Lucerne 2.38 at 1 m Barley grass control 1.85 at 1 m < 1 / Below the level of concern 0.03 27.75 255.3 < 1 / Below the level of concern 950 14.28 27.75 0.27 < 1 / Below the level of concern 0.02 < 1 / Below the level of concern 0.03 < 1 / Below the level of concern Table 18 TER value for non target plant – vegetative vigour Exposure = Scenarios Drift (%) drift x EC25 application (g ai/ha) RQ Trigger value / Presumption rate (g/ha) Clover 2.38 at 1 m 9.52 Non-crop land: fence lines, streets, industrial sites 1.85 at 1 m 27.75 15 0.63 < 1 / Risk below concern 1.85 >1 / High risk Non-crop land: fence lines, streets, industrial sites 0.38 at 5 m 5.7 Forestry 25.53 at 1 m 255.3 17.02 >1 / High risk Forestry 16.87 at 5 m 168.7 11.2 >1 / High risk Forestry 9.61 at 10 m 96.1 6.4 >1 / High risk Forestry 5.61 at 15 m 56.1 3.74 >1 / High risk April 2016 0.38 < 1 / Risk below concern 46 Forestry 2.59 at 20 m 25.9 0.87 at 30 m 8.7 Lucerne 2.38 at 1 m 14.28 Barley grass control 1.85 at 1m 27.75 Barley grass control 0.38 at 5 m 5.7 Forestry 1.7 >1 / High risk 0.58 < 1 / Risk below concern 0.952 < 1 / Risk below concern 1.85 0.38 >1 / High risk < 1 / Risk below concern The approach for threatened species is based on RQ and the NOEC from the same studies used previously. Table 19 TER value for non target plant threatened species Exposure = Scenarios Drift (%) drift x NOEC application (g ai/ha) RQ Trigger value / Presumption rate (g/ha) Clover Fence lines, streets, Forestry Lucerne April 2016 2.38 at 1 m 9.52 4 2.38 > 1 / High risk 0.47 at 5 m 1.88 4 0.47 < 1 / Below concern 1.85 at 1 m 27.75 4 6.94 > 1 / High risk 0.38 at 5 m 5.7 4 1.425 > 1 / High risk 0.19 at 10 m 2.85 4 0.71 < 1 / Below concern 25.53 at 3 m 255.3 4 63.825 > 1 / High risk 16.87 at 5 m 168.7 4 42.175 > 1 / High risk 9.61 at 10 m 96.1 4 24.025 > 1 / High risk 5.61 at 15 m 56.1 4 14.025 > 1 / High risk 2.59 at 20 m 25.9 4 6.475 > 1 / High risk 0.87 at 30 m 8.7 4 2.175 > 1 / High risk 0.4 at 40 m 4.00 4 1.0 > 1 / High risk 0.22 at 50 m 2.20 4 0.6 < 1 / Below concern 2.38 at 1 m 14.28 4 3.57 > 1 / High risk 0.47 at 5 m 2.82 4 0.705 < 1 / Below concern 1.85 at 1 m 27.75 4 6.9375 > 1 / High risk 47 Barley grass control 0.38 at 5 m 5.7 0.19 at 10 m 2.85 4 1.425 > 1 / High risk 0.7125 < 1 / Below concern 4 Conclusion for non target plant risk assessment The risks to seedling emergence were below the level of concern for all use scenarios. The risks to vegetative vigour were below the level of concern for the uses on clover and Lucerne. However, high risks to vegetative vigour of non-target plants were observed for the uses on non-crop land, forestry and barley grass control. High risks were observed for threatened native terrestrial plants for all the uses. The following downwind buffer zones must be observed in order to protect non-crop plants from unacceptable levels of spray drift from the application of Para-Ken 250 Herbicide: Non-crop situations: 5 meters Forestry: 30 meters Barley grass control: 5 meters For the protection of threatened native terrestrial plants the following advisory downwind buffer zones must be observed: Clover: 5 meters Non-crop situations: 10 meters Forestry: 50 meters Lucerne: 5 meters Barley grass control: 10 meters 6.7.3. Bird risk assessment EPA uses EFSA’s Bird model and Excel© spreadsheets14 freely available on EFSA’s website to assess the risks to birds. The methodology calculates TERs where exposure is calculated as the dose that a bird will receive when feeding in crops that have been sprayed. To avoid doing detailed evaluations for low risk scenarios, assessments are performed in tiers of increasing complexity. The steps for the acute assessment are: 14 Screening assessment Tier I assessment different spreadsheets for spray application, granular application and seed treatment. For bait applications a spreadsheet with Daily Food Intake of NZ relevant species is available (Crocker et al., 2002). April 2016 48 Higher tier assessment The steps for the reproductive assessment are: Screening assessment Phase-specific approach assessment Higher tier assessment Progression to the next tier is only made if the threshold for concern is exceeded at the previous tier. Screening risk assessment Determination of levels of exposure The principles underlying the exposure assessment are the same for all assessments other than higher tier assessments in which more specific field exposure data may be used. The dose that a bird receives (Daily Dietary Dose or DDD) is calculated from the application rate and a so-called ‘Shortcut value’ for the Residue per Unit Dose (RUD), reflecting the concentration on the bird’s food and the quantity of food consumed. Quantities consumed are based on a bird’s energy requirements, its energy assimilation and the energy content of its food (dry weight). Birds’ energy requirements are based on an algorithm based on bodyweight and bird type (e.g. passerine/nonpasserine). For further details, refer to EFSA’ technical guidance document. Both screening step assessments (acute and reproduction) select from 6 ‘indicator species’ each applicable to a particular type of crop. They are not real species, but, by virtue of their size and feeding habits, their exposure is considered worst-case for birds in a particular crop type. For example, the representative species for orchards is described as a ‘small insectivorous bird’. It is assumed that the relevant indicator species feeds only on contaminated food and the concentration of pesticide on the food is not affected by the growth stage of the crop. Thus, the exposure assessment is expressed as follows depending on the number of applications: For acute test: 𝐷𝐷𝐷 𝑜𝑛𝑒 𝑎𝑝𝑝𝑙𝑖𝑐𝑎𝑡𝑖𝑜𝑛 = 𝑎𝑝𝑝𝑙𝑖𝑐𝑎𝑡𝑖𝑜𝑛 𝑟𝑎𝑡𝑒 (𝑘𝑔/ℎ𝑎) × 𝑠ℎ𝑜𝑟𝑡𝑐𝑢𝑡 𝑣𝑎𝑙𝑢𝑒 𝐷𝐷𝐷 𝑚𝑢𝑙𝑡𝑖𝑝𝑙𝑒 𝑎𝑝𝑝𝑙𝑖𝑐𝑎𝑡𝑖𝑜𝑛𝑠 = 𝐷𝐷𝐷 𝑜𝑛𝑒 𝑎𝑝𝑝𝑙𝑖𝑐𝑎𝑡𝑖𝑜𝑛 × 𝑀𝐴𝐹90 For reproduction test: 𝐷𝐷𝐷 = 𝑎𝑝𝑝𝑙𝑖𝑐𝑎𝑡𝑖𝑜𝑛 𝑟𝑎𝑡𝑒 (𝑘𝑔/ℎ𝑎) × 𝑠ℎ𝑜𝑟𝑡𝑐𝑢𝑡 𝑣𝑎𝑙𝑢𝑒 × 𝑇𝑊𝐴 ∗ × 𝑀𝐴𝐹𝑚𝑒𝑎𝑛 *if toxic effect is considered to be caused by long-term exposure, use TWA = 0.53 (estimates time-weighted exposure over 21 days assuming a default DT50 of 10 days). The exposure to paraquat dichloride for bird acute dietary and reproductive screening assessments is shown in the Table 20 and Error! Reference source not found. respectively The methodology calculates TERs where exposure is calculated as the dose that a bird will receive when feeding in crops that have been sprayed. To avoid doing detailed evaluations for low risk scenarios, assessments are performed in tiers of increasing complexity. April 2016 49 The steps for the acute assessment are: Screening assessment Tier I assessment Higher tier assessment The steps for the reproductive assessment are: Screening assessment Phase-specific approach assessment Higher tier assessment Progression to the next tier is only made if the threshold for concern is exceeded at the previous tier. Screening risk assessment Determination of levels of exposure The principles underlying the exposure assessment are the same for all assessments other than higher tier assessments in which more specific field exposure data may be used. The dose that a bird receives (Daily Dietary Dose or DDD) is calculated from the application rate and a so-called ‘Shortcut value’ for the Residue per Unit Dose (RUD), reflecting the concentration on the bird’s food and the quantity of food consumed. Quantities consumed are based on a bird’s energy requirements, its energy assimilation and the energy content of its food (dry weight). Birds’ energy requirements are based on an algorithm based on bodyweight and bird type (e.g. passerine/nonpasserine). For further details, refer to EFSA’ technical guidance document. Both screening step assessments (acute and reproduction) select from 6 ‘indicator species’ each applicable to a particular type of crop. They are not real species, but, by virtue of their size and feeding habits, their exposure is considered worst-case for birds in a particular crop type. For example, the representative species for orchards is described as a ‘small insectivorous bird’. It is assumed that the relevant indicator species feeds only on contaminated food and the concentration of pesticide on the food is not affected by the growth stage of the crop. Thus, the exposure assessment is expressed as follows depending on the number of applications: For acute test: 𝐷𝐷𝐷 𝑜𝑛𝑒 𝑎𝑝𝑝𝑙𝑖𝑐𝑎𝑡𝑖𝑜𝑛 = 𝑎𝑝𝑝𝑙𝑖𝑐𝑎𝑡𝑖𝑜𝑛 𝑟𝑎𝑡𝑒 (𝑘𝑔/ℎ𝑎) × 𝑠ℎ𝑜𝑟𝑡𝑐𝑢𝑡 𝑣𝑎𝑙𝑢𝑒 𝐷𝐷𝐷 𝑚𝑢𝑙𝑡𝑖𝑝𝑙𝑒 𝑎𝑝𝑝𝑙𝑖𝑐𝑎𝑡𝑖𝑜𝑛𝑠 = 𝐷𝐷𝐷 𝑜𝑛𝑒 𝑎𝑝𝑝𝑙𝑖𝑐𝑎𝑡𝑖𝑜𝑛 × 𝑀𝐴𝐹90 For reproduction test: 𝐷𝐷𝐷 = 𝑎𝑝𝑝𝑙𝑖𝑐𝑎𝑡𝑖𝑜𝑛 𝑟𝑎𝑡𝑒 (𝑘𝑔/ℎ𝑎) × 𝑠ℎ𝑜𝑟𝑡𝑐𝑢𝑡 𝑣𝑎𝑙𝑢𝑒 × 𝑇𝑊𝐴 ∗ × 𝑀𝐴𝐹𝑚𝑒𝑎𝑛 *if toxic effect is considered to be caused by long-term exposure, use TWA = 0.53 (estimates time-weighted exposure over 21 days assuming a default DT50 of 10 days). The exposure to paraquat dichloride for bird acute dietary and reproductive screening assessments is shown in the Table 20. April 2016 50 Table 20 Exposure of birds for acute and reproduction screening assessment Crop & BBCH class Indicator (where species2 appropriate)1 Application Short- MAF rate cut value (90th (kg/ha) (90th%)3 %)4 No of applications DDD Clover (legume forage), 2 applications of 0.4 kg a.i./ha at 28 days interval Acute 158.8 Small omnivorous bird 0.4 Long-term 69.87 1.1 2 64.8 15.11 Lucerne (legume forage), 2 applications of 0.6 kg a.i./ha at 28 days interval Acute 158.8 Small omnivorous bird 0.6 Long-term 104.81 1.1 2 64.8 22.67 Non selective weed control (legume forage), 4 applications of 0.6 kg a.i./ha at 28 days interval Acute 158.8 Small omnivorous bird 1.1 0.6 Long-term 104.81 4 64.8 1.2 24.73 Forestry, 2 application of 1 kg a.i./ha at 28 days interval Acute 46.8 Small insectivorous bird 1 Long-term 51.48 1.1 2 18.2 10.61 Non-crop land, 4 applications of 1.5 kg a.i./ha at 28 days interval Acute April 2016 1.5 24.7 1.1 4 40.76 51 Long-term 1 EFSA, 2009, Table 5 p27 2 EFSA, 2009, Table 6 p28 3 EFSA, 2009, Table 6 p28 4 EFSA, 2009, Table 7 p29 Small granivorous bird 1 EFSA, 2009, Table 5 p27 2 EFSA, 2009, Table 10 p34 3 11.4 1.2 10.88 EFSA, 2009, Table 10 p34 4 EFSA, 2009, Table 11 p34 5The exposure assessment of the reproduction assessment uses time-weighted average (TWA) exposure estimates over 1, 2, 3 or 21 days for different phases of the assessment. 1 day = 1.0; 2 days = 0.93; 3 days = 0.9; 21 days = 0.53 Note about TWA: Table 21 Measures of exposure and toxicity used in the reproduction assessment Breeding phase Pair formation/ breeding site selection Copulation and egg laying (5 days prelaying through end of laying Incubation and hatching 15 From acute study. April 2016 Test endpoint used as Short-term surrogate exposure 0.1 x LD5015 1 day DDD 21 day TWA DDD NOAEL for the number of eggs laid per hen 1 day DDD 21 day TWA DDD NOAEL for mean eggshell thickness 1 day DDD 21 day TWA DDD 0.1 x LD50 1 day DDD 21 day TWA DDD NOAEL for proportion of viable eggs/eggs set/hen 1 day DDD 21 day TWA DDD Long-term exposure 52 Juvenile growth and survival until fledging NOAEL for proportion of hatchlings/viable eggs/hen 3 day TWA DDD 21 day TWA DDD 0.1 x LD50 (extrinsic adult) 2 day TWA DDD 21 day TWA DDD 0.1 x LD50 (extrinsic juvenile) 1 day DDD based on chick shortcut values of 3.8 and 22.716 21 day TWA DDD based on chick shortcut value of 3.8 and 22.73 NOAEL for proportion of 14 day old juveniles/number of hatchlings/hen 3 day TWA DDD 21 day TWA DDD 0.1 x LD50 1 day DDD based on chick shortcut values of 3.8 and 22.73 21 day TWA DDD based on chick shortcut value of 3.8 and 22.73 NOAEL for 14 day old juvenile weights/hen 3 day TWA DDD 21 day TWA DDD Post-fledging survival 2 from acute study two values are to account for ground and foliar dwelling arthropods with mean residue unit doses of 3.5 and 21 respectively. Assessments are made with both values. If TER are exceeded with either value, then an assessment based on the actual composition of the diet of relevant species. 3 The Calculation of TERs TER calculations are detailed in Table 22. Table 22 TER values for acute dietary and reproductive risk assessment – Screening assessment Toxicity Birds type DDD endpoint value TER ratio (mg/kg bw/d) Trigger value / Presumption Clover - 2 applications of 0.4 kg a.i./ha at 28 days interval < 10 / High risk Acute Long-term 16 Small omnivorous bird 69.87 LD50 = 35 0.5 < 20 / High risk for threatened species 15.11 NOEC = 2.8 0.2 < 5 / High risk The two values are to account for ground and foliar dwelling arthropods with mean residue unit doses of 3.5 and 21 respectively. Assessments are made with both values. If TER are exceeded with either value, then an assessment based on the actual composition of the diet of relevant species. April 2016 53 Toxicity Birds type DDD endpoint value TER ratio (mg/kg bw/d) Trigger value / Presumption < 10 / High risk for threatened species Lucerne, 2 applications of 0.6 kg a.i./ha at 28 days interval < 10 / High risk Acute 104.81 LD50 = 35 0.3 Small omnivorous bird Long-term < 20 / High risk for threatened species < 5 / High risk 22.67 NOEC = 2.8 0.1 < 10 / High risk for threatened species Non selective weed control (pastures) - 4 applications of 0.6 kg a.i./ha at 28 days interval < 10 / High risk Acute 104.81 LD50 = 35 0.3 Small omnivorous bird Long-term < 20 / High risk for threatened species < 5 / High risk 24.73 NOEC = 2.8 0.1 < 10 / High risk for threatened species Non selective weed control (pastures) - 4 applications of 1.5 kg a.i./ha at 28 days interval < 10 / High risk Acute < 20 / High risk for threatened species LD50 = 35 Small omnivorous bird < 5 / High risk Long-term < 10 / High risk for threatened species NOEC = 2.8 Forestry, 2 applications of 1 kg a.i./ha at 28 days interval < 10 / High risk Acute Long-term April 2016 Small insectivorous bird 51.48 LD50 = 35 0.7 < 20 / High risk for threatened species 10.61 NOEC = 2.8 0.3 < 5 / High risk 54 Toxicity Birds type DDD endpoint value TER ratio (mg/kg bw/d) Trigger value / Presumption < 10 / High risk for threatened species Non-crop land, 4 applications of 1.5 kg a.i./ha at 28 days interval < 10 / High risk Acute 40.76 LD50 = 35 0.9 Small granivorous bird Long-term < 20 / High risk for threatened species < 5 / High risk 10.88 NOEC = 2.8 0.3 < 10 / High risk for threatened species Conclusion for bird risk assessment (screening) Both acute and chronic screening risk assessment indicates high risks for birds (including threatened species) for all scenarios of use. Therefore, the risk assessment has to be refined. Tier 1 risk assessment Tier 1 uses the same general approach as the screening assessment but requires more specific exposure scenarios. The first step is to identify all general focal species listed in Table I.1 (Annex I) of the EFSA’ technical guidance document that are relevant for the intended use(s). In the Tier 1 acute and phase-specific reproduction assessments exposure is calculated for generic focal species’, applicable to particular crops. Such assessments refine the screening step assessments in that: there are more bird ‘species’ (19) and crop options (21); the growth stage of the crop is taken into account, affecting the residues on the feed; more than one bird species may be considered for any one crop; a bird’s diet can be calculated to include more than one food item. The larger number of bird species, crop types and growth stages of the crops leads to a total of 138 RUD shortcut options, each with a mean and 90th percentile value. Determination of levels of exposure For each generic focal species the DDD is presented in Table 20. April 2016 55 Calculation of TERs (Tier 1) The TER calculations in the frame of the Tier 1 assessment are detailed in the Table 23. The toxicity figures are the same than those considered in the screening assessment. Table 23 TER values for acute dietary and reproductive risk assessment - Tier 1 assessment Crop & BBCH class Generic focal (where species1 appropriate) Short-cut value (90th%) Trigger TER ratio 2 value / Presumption Clover – 2 applications of 0.4 kg a.i./ha at 28 days interval < 10 / High Risk Acute 25.2 BBCH >20 3.2 Small insectivorous bird “wagtail” < 20 / High risk for threatened species < 5 / High risk Chronic 9.7 1.7 < 10 / High risk for threatened species > 10 / Risk below concern Acute 7.4 BBCH > 50 10.7 Small granivorous bird “finch” < 20 / High risk for threatened species < 5 / High risk Chronic 3.4 3.5 < 10 / High risk for threatened species > 10 / Risk below concern Acute 7.2 BBCH > 50 11.7 Small omnivorous bird “lark” < 20 / High risk for threatened species < 5 / High risk Chronic April 2016 3.3 3.6 < 10 / High risk for threatened species 56 < 10 / High risk Acute 26.8 BBCH 10-19 3.0 Small insectivorous bird “wagtail” < 20 / High risk for threatened species < 5 / High risk Chronic 11.3 1.1 < 10 / High risk for threatened species < 10 / High Risk Acute 24.7 BBCH 10-49 3.2 Small granivorous bird “finch” Chronic < 20 / High risk for threatened species < 5 / High risk 11.4 1.1 < 10 / High risk for threatened species < 10 / High Risk Acute 24.0 BBCH 10-49 3.3 Small omnivorous bird “lark” < 20 / High risk for threatened species < 5 / High risk Chronic 10.9 1.1 < 10 / High risk for threatened species < 10 / High risk Acute Chronic 55.6 BBCH 21-49, leaf development 1.4 Medium herbivorous/granivorous bird “pigeon” < 20 / High risk for threatened species < 5 / High risk 22.7 0.5 < 10 / High risk for threatened species Lucerne (legume forage) – 2 applications of 0.6 kg a.i./ha at 28 days interval < 10 / High Risk Small insectivorous bird “wagtail” Acute 25.2 2.1 < 20 / High risk for threatened species 9.7 0.8 < 5 / High risk BBCH >20 Chronic April 2016 57 < 10 / High risk for threatened species < 10 / High Risk Acute 7.4 BBCH > 50 7.2 Small granivorous bird “finch” Chronic < 20 / High risk for threatened species < 5 / High risk 3.4 2.4 < 10 / High risk for threatened species < 10 / High Risk Acute 7.2 BBCH > 50 7.4 Small omnivorous bird “lark” Chronic < 20 / High risk for threatened species < 5 / High risk 3.3 2.4 < 10 / High risk for threatened species < 10 / High Risk Acute 26.8 BBCH 10-19 2.0 Small insectivorous bird “wagtail” < 20 / High risk for threatened species < 5 / High risk Chronic 11.3 0.7 < 10 / High risk for threatened species < 10 / High Risk Acute 24.7 BBCH 10-49 2.1 Small granivorous bird “finch” Chronic < 20 / High risk for threatened species < 5 / High risk 11.4 0.7 < 10 / High risk for threatened species < 10 / High Risk Small omnivorous bird “lark” Acute Chronic April 2016 BBCH 10-49 24.0 2.2 < 20 / High risk for threatened species 10.9 0.7 < 5 / High risk 58 < 10 / High risk for threatened species < 10 / High Risk Acute 55.6 BBCH 21-49, leaf development 1.0 Medium herbivorous/granivorous bird “pigeon” Chronic < 20 / High risk for threatened species < 5 / High risk 22.7 0.4 < 10 / High risk for threatened species Non selective weed control (barley grass) – 4 applications of 0.6 kg a.i./ha at 28 days interval < 10 / High risk Acute 25.2 BBCH >20 2.1 Small insectivorous bird “wagtail” < 20 / High risk for threatened species < 5 / High risk Chronic 9.7 0.8 < 10 / High risk for threatened species < 10 / High risk Acute 7.4 BBCH > 50 7.2 Small granivorous bird “finch” Chronic < 20 / High risk for threatened species < 5 / High risk 3.4 2.2 < 10 / High risk for threatened species < 10 / High risk Acute 7.2 BBCH > 50 Small omnivorous bird “lark” Chronic April 2016 Small insectivorous bird “wagtail” < 20 / High risk for threatened species < 5 / High risk 3.3 BBCH 10-19 Acute 7.4 2.2 < 10 / High risk for threatened species < 10 / High risk 26.8 2.0 < 20 / High risk for threatened species 59 < 5 / High risk Chronic 11.3 0.6 < 10 / High risk for threatened species < 10 / High risk Acute 24.0 BBCH 10-49 2.1 Small granivorous bird “finch” Chronic < 20 / High risk for threatened species < 5 / High risk 11.4 0.6 < 10 / High risk for threatened species < 10 / High risk Acute 24.0 2.2 Small omnivorous bird “lark” < 20 / High risk for threatened species < 5 / High risk BBCH 10-49 Chronic 10.9 0.7 < 10 / High risk for threatened species < 10 / High risk Acute 55.6 BBCH 21-49, leaf development 1.0 Medium herbivorous/granivorous bird “pigeon” Chronic < 20 / High risk for threatened species < 5 / High risk 12.5 0.6 < 10 / High risk for threatened species Forestry, 2 applications of 1 kg a.i./ha at 28 days interval < 10 / High risk Acute 27.4 Not crop directed application all season 1.4 Small granivorous bird “finch” < 20 / High risk for threatened species < 5 / High risk Chronic 12.6 0.4 < 10 / High risk for threatened species Acute 7.4 4.3 < 10 / High risk April 2016 60 Not crop directed application all season < 20 / High risk for threatened species Small insectivorous/worm feeding species “thrush” Chronic < 5 / High risk 2.7 1.8 < 10 / High risk for threatened species Non-crop land (bare soil), 4 applications of 1.5 kg a.i./ha at 28 days interval < 10 / High risk Acute 24.7 0.9 BBCH < 10 Small granivorous bird “finch” Chronic < 20 / High risk for threatened species < 5 / High risk 11.4 0.3 < 10 / High risk for threatened species < 10 / High risk Acute 10.9 BBCH < 10 1.9 Small insectivorous bird “wagtail” Chronic < 20 / High risk for threatened species < 5 / High risk 5.9 0.5 < 10 / High risk for threatened species < 10 / High risk Acute 17.4 BBCH < 10 Small omnivorous bird “lark” Chronic 1 EFSA, 2009, Table I.1, Annex I 2 EFSA, 2009, Table I.1, Annex I 3 EFSA, 2009 - Table 11 p34 Conclusion for bird risk assessment (Tier 1) April 2016 1.2 < 20 / High risk for threatened species < 5 / High risk 8.2 0.4 < 10 / High risk for threatened species 61 For the uses on clover, there were high acute risks for all crops stages with the exception of application after BBCH >50, where high risks were observed only for threatened bird species. There were high chronic risks (including for threatened bird species) for all crop stages. For the uses on Lucerne there were high acute risks and high chronic risks for all crops stages. For the uses on selective weed control (barley grass) at 0.6 kg a.i./ha there were high acute risks and high chronic risks for all crops stages. The risks were high with this lower application rate, thus staff did not modelled the application on barley at 1.5 kg a.i./ha, hence the risks are also deemed to be higher than the level of concern. For the uses on forestry there were high acute and high chronic risks. For the uses on non-crop situations there were high acute and high chronic risks. Refinement for bird risk assessment (Tier I) Staff assessed separately the risk for birds following the application of Para-Ken 250 Herbicide in crop (agricultural) use and non-crop situations (industrial, fence lines and stock yards) taking into account the method of application of Para-Ken 250 Herbicide. It is recognized that the intended uses for high volume broadcast on agricultural fields represent a higher potential risk to birds than the application using a knapsack in non-crop situations. Potential risk to birds from the application to non-crop situations The application using knapsack around industrial sites, fence lines, stock yards to clean up weeds minimizes residue deposition on foliage, thus this method of application is not expected to result in a significant food contamination for birds. Therefore, the acute and chronic risk to birds resulting from the application of ParaKen 250 Herbicide using knapsack for spot treatment on non-crop situations is expected to be of low concern for birds. The staff consider that it is appropriate to apply controls to ensure that the knapsack application is carried out using coarse droplets to minimize spray drift to nearby foliage. Potential acute risk to birds The estimated acute TER exceed the level of concern following a broadcast spray application of Para-Ken 250 Herbicide to clover, Lucerne, barley grass control and forestry. The staff consider that due to the environmental fate characteristics of paraquat dichloride, namely its strong adsorption to biological materials leading to paraquat becoming less bioavailable, the risk to birds only exists shortly after application and therefore once the applied paraquat has dried its risk is greatly reduced. April 2016 62 However, the staff consider that there are no adequate mitigation measures to control the potential acute risks to bird’s species following the application of Para-Ken 250 Herbicide to clover, Lucerne, barley grass control and forestry, thus these risks will remain unmanageable. Potential reproductive risk to birds The estimated chronic TER exceed the level of concern for all bird types following a broadcast spray application of Para-Ken 250 Herbicide to clover, Lucerne, barley grass control and forestry. The chronic risks were estimated using the NOEC of 2.8 mg/kg bw/d selected from the reproduction study in the Mallard duck based on the reduction in the percentage of viable eggs, eggs set, normality of hatching, and number of 14day old survival. The proposed use of Para-Ken 250 Herbicide will potential result in a risk to the reproduction of birds. It was not possible to refine the risk assessment due to lack of appropriate higher tier data (field studies) for the representative uses. Staff consider that the high reproductive risks to birds will remain unmanageable. Secondary poisoning Paraquat dichloride is not bioaccumulative so no risk assessment for secondary poisoning is necessary for this active ingredient. 6.7.4. Bee risk assessment The risk to bees is assessed as follows: Tier1- screening level risks If a reasonable potential for exposure to the pesticide is identified, a screening-level risk assessment is conducted. This step involves a comparison of Tier I estimated exposure concentrations (EECs) for contact and oral routes of exposure to adults and larvae to Tier I acute and chronic levels of effects to individual bees using laboratory-based studies. The conservatism of the Tier I screening-level risk quotient (RQ) value results primarily from the model-generated exposure estimates that, while intended to represent environmentally relevant exposure levels, are nonetheless considered high-end estimates. The resulting acute and chronic RQ values are then compared to the corresponding level of concern (LOC) values for acute and chronic risk (i.e., 0.4 and 1.0, respectively). Generally, if RQ values are below their respective LOCs, a presumption of minimal risk is made, since the Tier I risk estimation methods are designed to be conservative. EEC are calculated as follows: Measurement Exposure Exposure estimate Acute effect Chronic effect endpoint route (EEC)* endpoint endpoint# April 2016 63 Foliar application Individual survival (adults) Individual survival (adults) Brood size and success Contact Application rate (kg Acute ai/ha) x 2.4 µg ai/bee contact LD50 Application rate (kg Diet ai/ha) x 98 µg ai/g x 0.292 g/day Acute oral LD50 Application rate (kg Diet ai/ha) x 98 µg ai/g x None Chronic adult oral NOAEL (effects to survival or longevity) Chronic larval oral Larval LD50 0.124 g/day NOAEL (effects to adult emergence, survival) Soil treatment Individual survival (adults) Brood size and success Diet Diet Briggs EEC x 0.292 Acute oral g/day LD50 Briggs EEC x 0.124 g/day Chronic adult oral NOAEL (effects to survival or longevity) Chronic larval oral Larval LD50 NOAEL (effects to adult emergence, survival) Seed treatment& Individual survival (adults) Brood size and success Diet 1 µg ai/g x 0.292 g/day Acute oral LD50 Chronic adult oral NOAEL (effects to survival or longevity) Chronic larval oral Diet 1 µg ai/g x 0.124 g/day Larval LD50 NOAEL (effects to adult emergence, survival) Tree trunk application** Individual survival (adults) Brood size and success Diet Diet µg ai applied to tree/g Acute oral foliage x 0.292 g/day LD50 µg ai applied to tree/g foliage x 0.124 g/day Chronic adult oral NOAEL (effects to survival or longevity) Chronic larval oral Larval LD50 NOAEL (effects to adult emergence, survival) * Based on food consumption rates for larvae (0.124 g/day) and adult (0.292 g/day) worker bees and concentration in pollen and nectar ** Note that concentration estimates for tree applications are specific to the type and age of the crop to which the chemical is applied. April 2016 64 # To calculate RQs for chronic effects, NOAEC can be used as the effect endpoint to compare with the exposure estimate in concentration & Assume that pesticide concentration in pollen and nectar of seed treated crops is 1 mg a.i./kg (1 μg a.i./g). • No adjustment is made for application rate (Based on EPPO’s recommended screening value) 𝐴𝑐𝑢𝑡𝑒 𝑅𝑄 = 𝐶ℎ𝑟𝑜𝑛𝑖𝑐 𝑅𝑄 = 𝐸𝐸𝐶 𝐿𝐷50 𝐸𝐸𝐶 𝑁𝑂𝐴𝐸𝐿 Toxicity Use scenario Application EEC (µg endpoint rate (kg ai/ha) ai/bee) value (µg RQ Trigger value /Presumption ai/bee) Clover Acute / Adult bees - contact Acute / Adult bees - oral 0.4 0.96 9.26 0.10 0.4 11.45 9.06 1.26 < 0.4 / No concern >0.4 / High risk Non-crop situations: fence lines, streets, industrial sites Acute / Adult bees - contact Acute / Adult bees - oral 1.5 3.6 9.26 0.39 1.5 42.94 9.06 4.74 1 2.4 9.26 0.26 1 28.62 9.06 3.16 < 0.4 / No concern >0.4 / High risk Forestry Acute / Adult bees - contact Acute / Adult bees - oral Lucerne April 2016 < 0.4 / No concern >0.4 / High risk 65 Acute / Adult bees - contact Acute / Adult bees - oral 0.6 1.44 9.26 0.16 0.6 17.17 9.06 1.89 1.5 3.6 9.26 0.39 1.5 42.94 9.06 4.74 < 0.4 / No concern >0.4 / High risk Barley grass control Acute / Adult bees - contact Acute / Adult bees - oral < 0.4 / No concern >0.4 / High risk Acute effects on brood, acute oral effects and chronic effects on adults and brood No assessment possible as no data provided on these toxicity endpoints Conclusions for the bee risk assessment Acute oral risks were below the level of concern for all use scenarios, but high contact risks for the uses on barley grass and non-crop situations (industrial sites, stock yards). The following assumptions are made regarding the potential exposure of bees to Para-Ken 250 Herbicide. Bees are not attracted to pine forests. The application on Lucerne is during winter (when Lucerne is dormant) which will reduce the potential exposure for bees. Likewise the application on non-crop situations will reduce the exposure to bees, which are not likely to forage in industrial sites and/or around buildings. The staff consider that the application on clover for seed production represent the highest potential exposure risk for bees. Therefore, the staff consider that the Para-Ken 250 Herbicide must not be applied in clover crop intended for seed production. 6.8.5 Non-target arthropod risk assessment There was no reliable data to conduct a quantitative risk assessment to non-target arthropods (LR50 and or ER50). The staff conducted a search on relevant information about the effects of paraquat dichloride to nontarget arthropods but no data could be used to support a quantitative risk assessment. The staff consider that the due to the properties and mode of action of paraquat dichloride the risks to non-target arthropods can be considered below the level of concern. April 2016 66 6.8. Summary and conclusions of the ecological risk assessment 6.8.1. Environmental fate and behaviour Paraquat dichloride was shown to be very immobile in soil. Paraquat does not hydrolyse, does not photodegrade in aqueous solutions, and is resistant to microbial degradation under aerobic and anaerobic conditions. The primary route of environmental dissipation of paraquat is adsorption to biological materials and soil clay particles. Due to the apparent adsorption strength of paraquat for soil clays, these bound residues do not appear to be environmentally available. There was no desorption of paraquat from any of the soils tested. Due to high biological toxicity to plants and animals prior to adsorption, paraquat is subject to spray drift concerns. However, paraquat has extremely high adsorption coefficients, it is not expected to volatilize once applied to the soil. 6.8.2. Ecotoxicology The EPA staff assessed the potential risk to be triggered by the use of Para-Ken 250 Herbicide according to the GAP table and draft label recommendations. Aquatic organisms Acute risks were below the level of concern for fish and aquatic invertebrates. High acute risks were observed for algae fior use scenarios and high risk for thretaned aquatic plant species at application rates higher than 1.0 kg paraquat dichloride per hectare. Chronic risks were below the level of concern for aquatic invertebrates, but high chornic risks were observed for threatened species at 1.5 kg paraquat dichloride per hectare. No chronic data was available for fish. Risks to algae cannot be mitigated using mitigation measures such as buffer zones. The modelling with AgDrift calculated a buffer zone larger than 254 meters (largest buffer zone possible to calculate using AgDrift). Therefore, the staff consider that the risks of ParaKen 250 Herbicide to algae are not manageable. Sediment organisms Risk were below the level of concern for sediment dwelling organisms. Soil organisms April 2016 67 Risks were below the level of concern for earthworms in field and outside the crop area, including for threatened species. Non-target plants Risk were below the level of concern for seedling emergence for all proposed uses. However, high risks were identified for vegetative vigour for the uses on non-crop situations, barley grass control and forestry. The following downwind buffer zones must be observed in order to protect non-crop plants from unacceptable levels of spray drift from Para-Ken 250 Herbicide: Non-crop situations (industrial sites, streets, etc.): 5 meters Forestry: 30 meters Barley grass control: 5 meters For the protection of threatened native terrestrial plants the following advisory downwind buffer zones must be observed: Clover: 5 meters Non-crop application (industrial sites, streets, etc.): 10 meters Forestry: 50 meters Lucerne: 5 meters Barley grass control: 10 meters Vertebrates There were high acute and high chronic risks for all crops and bird types. There are no adequate mitigation measures to protect birds from this potential risk. Staff consider that for the applications of Para-Ken 250 Herbicide using knapsack for spot treatment in noncrop situations, such as the removal of weeds in industrial sites and streets will represent a lower potential risk for birds.Therefore this use is considered acceptable by staff. Bees and non target arthropods Acute oral risks to bees were below the level of concern. High contact risk to bees were observed for all use scenarios. Staff consider that the potential exposure to clover crops represent the highest risk to bees.Therefore, the staff consider that the Para-Ken 250 Herbicide must not be applied in clover crop intended for seed production. Staff consider that due to the mode of action and properties of paraquat dichloride the risks to non-target arthropods can be considered below the level of concern. Overall conclusion for the environmental risk assessment April 2016 68 Staff consider that the approval of Para-Ken 250 Herbicide as broadcast spray to clover, Lucerne, forestry and barley grass control should be declined due to the unacceptable risks posed to algae and birds. Staff consider that the application of Para-Ken 250 Herbicide as spot treatment (non wide-dispersive use) in non-crop situations such as the application on streets and industrial sites the risks can be considered below the level of concern for the environment. April 2016 69 7. Controls 7.1. Physical hazards controls Apply the Approved Handler Controls (AH1, F4): Yes No Apply the Tracking control (TR1): Yes No 7.2. Toxicity controls Exposure Thresholds Table 5 Active ingredient(s) exposure thresholds Active Ingredient(s) Acceptable Daily Exposure (ADE) – mg/kg bw/d Potential Daily Exposure (PDE) – mg/kg bw/d Tolerable Exposure Limit (TEL) mg/L (water) mg/kg (soil) mg/m3 (air) Workplace Exposure Standard (WES17) Paraquat dichloride Not set at this time Not set at this time Not set at this time WorkSafe New Zealand has not set a WES for paraquat dichloride . Table 6 Other component(s) exposure thresholds Other component(s) WES Component D WorkSafe New Zealand has set a WES value for Component D of Para-Ken 250 Herbicide and Staff consider this value to be applicable to Para-Ken 250 Herbicide Apply the Approved Handler Controls - Highly Toxic Substances (AH1, T6): Yes No Apply the Tracking Control - Highly Toxic Substances (TR1): Yes No Other toxicity controls Based on the human health risk assessment Staff were not able to identify any controls that would sufficiently ensure that exposures are below acceptable levels. 7.3. 17 Ecotoxicity controls http://www.business.govt.nz/worksafe/information-guidance/all-guidance-items/workplace-exposure-standards-and-biologicalexposure-indices/workplace-exposure-standards-and-biological-indices-2013.pdf April 2016 70 Table 7 Active ingredient(s) maximum application rates Active component Maximum application rate18 (control code E2) Paraquat dichloride 1.5 kg a.i./ha, 4 applications at 28 days interval Apply the Approved Handler Controls- Highly ecotoxic substances (AH1, E7): Yes No Apply the Tracking control- Highly ecotoxic substances (TR1): Yes No Other ecotoxicity controls Additional controls, under section 77A, are set for the application of of Para-Ken 250 Herbicide as spot treatment using knapsack: This substance must not be applied onto or into water. The knapsack must have nozzles equipped to release coarse droplets to prevent spray drift 7.4. Mixture hazard classification calculations for identification controls Table 8 Cut-off values triggering HSNO classification and requiring identification controls on the label and/or Safety Data Sheet (SDS) HSNO Classification Cut-off for label (% w/w) Cut-off for SDS (% w/w) 6.1A, B, C, D Any % of component that would independently of any other component cause the product to classify Any % that causes the product to classify 6.1E aspiration Any % of component that would independently of any other component cause the product to classify Any % of component that would independently of any other component cause the product to classify 8.2, 8.3 Any % that causes the product to classify as 8.2 and/or 8.3 Any % that causes the product to classify 6.5A, 6.5B, 6.6A, 6.7A 0.1 0.1 6.6B 1 1 6.7B 1 0.1 6.8A, 6.8C 0.3 0.1 6.8B 3 0.1 6.9A, 6.9B 10 1 (required on the basis of §77a) Table 9 List of components requiring identification 18 These regulations relate to the requirement to set an application rate for a class 9 substance that is to be sprayed or applied to an area of land (or air or water) and for which an EEL has been set. April 2016 71 Label SDS Paraquat dichloride Paraquat dichloride April 2016 72 References Novis P (2015) New Zealand Freshwater and Brackish Diatom Types. http://www.landcareresearch.co.nz/resources/identification/algae/diatoms SANCO (2003) Review Report for the active substance paraquat. October 3, 2003. United States Environmental Protection Agency (1997) Registration Eligibility Document (RED). Paraquat Dichloride. August 1997. April 2016