EPA  540/9-86-135
                              June  1986
                                     -$-7 -
          HAZARD EVALUATION DIVISION

        STANDARD EVALUATION PROCEDURE

               NON-TARGET PLANTS:

      TERRESTRIAL FIELD TESTING - TIER 3
                  Prepared by

             Robert W. Hoist, Ph.D.
Standard Evaluation Procedures Project Manager
               Stephen L. Johnson
          Hazard Evaluation Division
         Office of Pesticide Programs


                         'i.S. E.-:vJr".-">cn*,!:\ Protect!on Agency

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                         .Vi'ijliiagton, DC   20469


United States  Environmental Protection Agency
         Office of Pesticide Programs
           Washington, D.C.  20460

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                          TABLE OF CONTENTS
  I. INTRODUCTION

       A.  Purpose of the Standard Evaluation
           Procedure ...,	   1
       B.  Background Information	   1
       C.  Objective of the Terrestrial Field
           Testing Tier 3 Test 	   1


 II.  INFORMATION TO BE SUPPLIED	   1


III.  DATA INTERPRETATION	   2


 IV.  THE DATA EVALUATION PROCESS

       A.  Identify Data Gaps 	   2
       B.  Assess the Appropriateness and
           Adequacy of the Data 	   3
       C.  Report Preparation ,	   3
       D.  Conclude if the Requested Action
           i s Supportable 	   3


  V.  APPENDICES

       Appendix 1:  Information Requested of the
                    Registrant 	   4

       Appendix 2:  Specific Questions for the
                    Reviewer	   7

       Appendix 3:  Sample Standard Format for
                    Preparation of Scientific
                    Reviews 	  10


  REFERENCES	  11
                                                               001

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        NON-TARGET PLANTSi  TERRESTRIAL FIELD TESTING - TIER 3


 I.  INTRODUCTION

      A.  Purpose of the Standard Evaluation Procedure

      This Standard Evaluation Procedure is designed to aid Ecologi-
 cal Effects Branch (EEB) data reviewers in their evaluations of
 Tier 3 terrestrial field testing plant studies submitted by regis-
 trants in the assessment of pesticide effects on non-target plants.

      B.  Background Information

      Terrestrial field testing (Tier 3) studies are designed to pro-
 vide phytotoxicity data on a pesticide.  These phytotoxicity data
 are needed to evaluate the level of pesticide exposure to non-target
 terrestrial plants and to assess the impact of pesticides on endan-
 gered and threatened plants as noted under the Endangered Species
 Act.  Where 'a phytotoxic effect is noted in one or more plants,
 additional terrestrial field testing studies may be required.  These
 data are required by 40 CFR § 158.150 to support the registration
 of any pesticide intended for outdoor use under the Federal Insecti-
 cide, Fungicide and Rodenticide Act (FIFRA), as amended.

      Pesticides with outdoor use patterns that do not readily releas^
 the pesticide to the environment do not have to be evaluated using
 this phytotoxicity test.  These use patterns include tree injection,
 subsurface soil applications, recapture systems, wick applications,
 and swimming pool uses.  If any of these use patterns do readily
 expose non-target plants to the pesticide, as through vapors, the
 pesticide phytotoxicity potential may need to be evaluated.

      C.  Objective of the Terrestrial Field Testing Tier 3 Test

      The objective of the Tier 3 terrestrial field testing study is
 to determine if a pesticide exerts a detrimental effect to plants
 during critical stages in their development.  The test is performed
 on species from a cross-section of the non-target terrestrial plant
 population.  This is a multiple dose test designed to evaluate the
 phytotoxic effects of the pesticide over a wide range of anticipated
 pesticide quantities as may be found in the environment.


II.  INFORMATION TO BE SUPPLIED

      The registrant's report on terrestrial field testing studies
 should include all information necessary to provide:  1) a complete
 and accurate description of the laboratory/greenhouse treatments
 and procedures, 2) sampling data and phytotoxicity rating, 3) data
 on storage of the plant material until analysis, if so performed,
 4) any chemical analysis of the plant material as to chemical con-
 tent, if so performed, 5) reporting of the data, rating system and


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                                  -2-
  statistical analysis, and 6) quality control measures/precautions
  taken to ensure the fidelity of the operations.

       A quideline of specific information that should be included in
  the registrant's report of terrestrial field testing studies is pro-
  vided in Appendix 1 of this document;  The lists of requested infor-
  mation and reviewer aids are derived from the Pesticide Assessment
  Guidelines, Subdivision Jt  Hazard Evaluation of Non-Target Plants,
  which is complemented by this Standard Evaluation Procedure.


III.   EftTA INTERPRETATION

       The acceptability of the study results will depend upon whether
  the test requirements/standards are followed.  If a deviation is
  made, a determination must be made as to whether the deviation has
  changed the quality of the results in such a manner that the results
  cannot be extrapolated to the natural environment.   There  should be
  little or no deviation from the liberalized standards prescribed
  in  this study.

       The results of the phytotoxicity test of the chemical with
  respect to the  quantity applied to the foliage are  important.   The
  concentration of the chemical in the carrier is important  in that
  stronger concentrations than normally used can lead to burning and
  necrosis.  Subtoxic concentrations, on the other hand, may also
  cause unwanted  rapid growth.

       Plants can recover from certain types of injury that  will have
  little or no effect on the esthetic or economic value of the plant(s
  tested or to which an evaluation is made.  Therefore, it is importan
  that a minimum  of two weeks of observations be made after  applicatio
  of  the pesticide; three to four weeks are preferable.

       A decision point to perform additional Tier 3  terrestrial tests
  is  a 25% detrimental effect, i.e., a 25% change in  plant growth or
  injury as compared to untreated controls.  This level is considered
  to  be that point at which the plants will not recover to their full
  esthetic value, economic value or reproductive potential as in the
  case of the maintenance of the endangered or threatened species.


 IV.   THE DATA EVALUATION PROCESS

       Upon careful examination of the information/data supplied by
  trie registrant  in his submission to the Agency,  the reviewer shall
  evaluate the data as follows.

       A.  Identify Data Gaps

       Using Appendix 1 of this document as a guide,  the reviewer
  should look for data gaps - omissions in the information supplied
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                                —3 —
by the registrant in his report.  These should be duly noted in the
reviewer's report, and a judgment made as to which are considered
significant enough to adversely affect the review process.  Those
so identified should be communicated back to the registrant by the
Product Manager for corrective action.

     B.  Assess the Appropriateness and Adeguacy of the Data

     The data reviewer then considers the appropriateness, i.e., the
intended use pattern, and adeguacy of the data/information that has
been supplied.  Appendix 1 of this document is a useful guide to the
various parameters that need to be considered.  Appendix 2 provides
specific guestions that should be answered by the reviewer during
the study evaluation process.  Statistical treatments of the data
should be independently verified and the guality control precautions
noted.

     As an adjunct to these, the reviewer should draw upon the tech-
nical guidance in the reviewer aids materials that are available.
{See also the recommended references in Subdivision J - Hazard Eval-
uation;  N on- Target Pi ants . )  A listing of additional source materials
is located in the References section of this document.

     In addition to the data gaps noted above, any perceived defi-
ciencies in the data/information supplied should also be identified.
A statement as to these deficiencies should be made in the reviewer'
report and corrective action to resolve them should be provided.
This information can be relayed to the registrant by the Product
Manager for appropriate action.

     C.  Report Preparation

     The Agency reviewer prepares a standard review report following
the standard format for preparation of scientific reviews as provide):!
in Appendix 3 of this document.  All important information provided
fcy the registrant including the methodology and results should be
summarized in order that future evaluations can be made.  The resultjs
ir.ay be expressed in the form of tables where specific values are
related.  Figures (graphs) may be provided but are not to be the sol
source of the values needed for future evaluations.

     D.  Conclude if the Requested Action is Supportable

     Lastly, the reviewer considers the results of the terrestrial
field testing studies and makes a judgment as to whether they sup-
port the requested registration action of the data submitter.  If
the data are not supportive, possible alternative action(s) that
iray be taken by the registrant, such as label modification, are
suggested.  If deficiencies/omissions exist in the submitted data,
the reviewer may have to defer judgment until such time as appro-
priate corrective action has been rendered by the registrant.
                                                           004


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                                 -4-
                              APPENDIX 1

               INFORMATION REQUESTED OF THE REGISTRANT
      The registrant's report on terrestrial field testing studies
        include all information necessary to provide:  1) a complete
   d accurate description of the field treatments and procedures,
    sampling data and phytotoxicity rating, 3) data on storage of the
   ant material, if so performed, 4) any chemical analysis of the
   jant material as to chemical content, if so performed, 5) reporting
    the data, rating system and statistical analysis, and 6) Quality
   ntrol measures/precautions taken to ensure the fidelity of the
   erations.
      Specifically, each laboratory/greenhouse/small field plot ter-
 r ^trial field testing report should include the following informati<


 1   General •

      0  Cooperator or researcher (name and address), test location
 ( Bounty and state; country, if outside of the U.S.A.), and date of
 s fudy;

      0  Name (and signature), title, organization, address, and
 i ;lephone number of the person(s) responsible for planning/super-
 \ .sing/monitoring and, for field plot studies, applying the pesticid

      0  Trial identification number;
      0  Quality assurance indicating:  control measures/precautions
  jllowed to ensure the fidelity of the phytotoxicity determinations;
  icord-keeping procedures and availability of logbooks; skill of
  ie laboratory personnel; status of the field and supporting labora-
  >ry equipment; degree of adherence to good laboratory practices;
  id degree of adherence to good agricultural practices in maintainin
  ^althly plants; and
      0  Other information the registrant considers appropriate and
 i slevant to provide a complete and thorough description of the test
 I -ocedures and results.


II.   Test Substance (Pesticide)

      0  Identification of the test pesticide active ingredient (ai)
 including chemical name, common name (ANSI, BSI,  ISO,  WSSA), and
 Company developmental/experimental name;

      0  Active ingredient percentage in the end-use product or repre
 sentative end-use product from the same major formulation category
 for that general use  pattern;


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                                  -5-
       0  Dose rate(s)  in terms of active ingredient per area of land
  or of leaf (if leaf-area-index is provided);

       e  Dose rate{s)  in terms of less than the maximum label rate
  with dosages in a geometrical progression of  no more than two-fold
  and with subtoxic (<  EC$Q level) and non-toxic (no-observable-effect
  level) concentrations;

       0  Method of application including equipment type (nozzles,
  orifices, pressures); and

       0  Number and timing of applications.


III.  Plant Species

       0  Identification of the plant species used.  They shall be
  representatives of the  following plant groups:

     Dicotyledonae (dicots)                           3 Families
     Monocotyledonae (monocots)                       3 Families
     Vascular Cryptogamae (ferns and allies)          2 Families
     Bryophyta (mosses) or Hepatophyta (liverworts)
          (Wetland use  patterns only)                  1 Family
     Gymnospermae (conifers)                           1 Representative

       "  Identification of the cultivar(s)  of  the plant species used,
  where possible;

       0  Identification of the number of replicates and the number
  of plants per replicate per dose; and

       0  Identification of the date of planting, date of pesticide
  application, and date of phytotoxicity rating or harvest.


 IV.  Site of the Test

       0  Site description of the terrestrial field testing study such
  as a grassland, forested area, fallow field,  tilled field, etc.;

       0  Location of the test site(s)  that represent the general
  regional areas of potential usage as noted below:

          Northeastern  temperate deciduous
          Southeastern  temperate deciduous
          Northern grassland  (cool prairie)
          Southern grassland  (warm prairie)
          Northwestern  (and Alaskan) conifer forest and high desert
          Southwestern  chaparral Mediterranean  and low desert
          Hawaiian and  Caribbean semi-tropical  and tropical regions
                                                              006

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                                        -6-
             0  Climatological  data during  the test  (records of  applicable
        conditions for the  type of site,  i.e., temperature,  thermoperiod,
        rainfall or watering  regime, light  regime -  intensity and  quality,
        relative humidity,  wind speed);

             0  Field lay-out (for field  plots),  e.g.,  size  and  number  of
        control and experimental plots; number of plants  per plot/unit
        area;

             0  Population  density of seeds or plants;

             0  Cultural  practices such as  cultivation  and  irrigation;  and

             0  Substrate characteristics of the  site(s)  (name/designation
        of  soil type and  its  physical and chemical properties, including pH
        and percent organic matter, presence and  depth  of fragipan or
        shallow bedrock,  etc.).
[        V.   Results
             0   Phytotoxicity  rating  (including  a  description  of  the  rating
        system)  for  each  plant or  group  of  plants  (population)  in the test;

             0   Weight, height or  other  growth parameters  that may have been
        measured to  ascertain  toxic effects of the  pesticide upon the
        plants;  and

             0   Statistical  analysis  of  the results including  environmental
        or  effective concentration (EC)  values.


       VI.   Evaluation

             0   Determination  as to whether additional phytotoxicity  testing
        will  be  necessary to characterize the phytotoxic nature of the
        c.iemical.
                                                                     007

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                     .»•»            •


                               APPENDIX 2

                  SPECIFIC QUESTIONS FOR THE REVIEWER


       The following questions are provided to aid the reviewer in
  performing the standard evaluation procedure in a scientific manner
  c.nd in acquiring the necessary information to complete a standard
  format for preparation of scientific reviews.

  I .  General

       0  Were the name of the cooperator or researcher (name and
  address), test location (county and state; country, if outside of
  the U.S.A.), and date of study provided?

       0  Were the name (and signature), title, organization, address,
  and telephone number of the person(s) responsible for planning/super
  vising/monitoring and, for field plot studies, applying the pesticid
  provided?

       0  Was the trial identification number provided?

       0  Were quality assurance control measures/precautions indicate


 II .  Test Chemical

       °  Was the test chemical used the end-use product or a repre-
  tentative end-use product from the same major formulation category
  for that general use pattern?

       0  Was the active ingredient percentage of the chemical given?

       0  Were the doses given in quantity per unit area (of plant or
  land surface) or tank concentrations?

       0  Was the maximum dose less  than the maximum label rate?

       9  Were the additional dosages of a geometric progression of
  no more than two-fold, e.g., 0.1,  0.2, 0.4, 0.8, 1.6 kg/ha?

       0  Were a subtoxic (< ECsg) and a non- toxic concentration
  evaluated?
III.   Test Species

       0  Were representatives from the following groups included in
  the studies?
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      Dicotyledonae (dicots)                         3 Families
      Monocotyledonae (monocots)                     3 Families
      Vascular Cryptogamae (ferns and allies)        2 Families
      Bryophyta (mosses) or Hepatophyta (liverworts)
           (Wetland use patterns only)               1 Family
      Gymnospermae (conifers)         -                1 Representative

 Where seed germination/seedling emergence studies have been performe
 seeds of plants with low or variable germination potential should
 have been avoided.  Some seeds of Questionable species and varieties
 should have been pretested for viability.

      0  If any plant group is not likely to be exposed to the pesti-
 cide under normal conditions  of use, testing of such groups is not
 required.  Was justification for elimination of a test species or
 group included in the test report?

      0  Where various cultivars could be used/ such  as in the case
 of most agronomic and horticultural plants, were cultivar or varieta
 names provided?  Were the plant and seed sources identified?

      0  Were there at least three replicates with five plants per
 replicate for each dose?

      0  Were the plants healthy and not in a state of stress?

      0  Were the plants in a  staqe of development under which the
 pesticide would be normally applied?

      0  If surrogate plant species were used to represent those of
 the natural habitat, were such relationships identified?

      0  Were endangered or threatened plant species  not used?


IV.  Test Procedures

      0  Were the locations of the test site(s) within the following
 general geographical regions  in which the pesticide  is to be used
 provided?

          Northeastern temperate deciduous
          Southeastern temperate deciduous
          Northern grassland (cool prairie)
          Southern grassland (warm prairie)
          Northwestern (and Alaskan) conifer forest and high desert
          Southwestern chaparral Mediterranean and low desert
          Hawaiian and Caribbean semi-tropical and tropical regions

      0  Was the test site specified, i.e., small field plot or large
 field plot?
                                                              009

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                                 -9-
      0  Were  the environmental conditions that prevailed during the
 test (temperature, thermoperiod,  light regime - intensity and qualit
 rainfall or watering regime, relative humidity, wind) provided as
 appropriate for the site?

      0  Were  the environmental conditions that prevailed during
 the test those most favorable and most typical to the growth of the
 plants used?  Were the conditions referenced?

      0  Was the test duration two weeks to four weeks in length?

      0  If multiple applications  are directed on the label, were the
 made and did  the observations extend at least two weeks past the
 last application?

      0  Was the test substance applied over a period of time or
 season according to the proposed  label instructions?

      0  Was the method of pesticide application including the type
 of application equipment given?


 V.  Reporting

      0  Were  the detrimental effects reported as severity of phyto-
 toxicity (rating or percentage)?

      0  If a  rating system was used, was an explanation provided?

      0  Were  observations to note plant growth and response to the
 pesticide taken at least twice weekly?

      0  Were  abnormal changes in growth, development, and/or morpho-
 logy reported as compared to the controls?

      0  Though not required, were direct measurements of height,
 weight, or other growth parameters provided?


VI.  Evaluation

      0  Were  the results tabulated to indicate a percentage effect
 level for each species as compared to the untreated control plants?

      0  Were  25 and 50 percent detrimental effect levels determined
 for those plant species of Tier 2 that showed a phytotoxic effect
 to the chemical?

      0  Was a determination made as to whether additional terres-
 trial field phytotoxicity tests were necessary to evaluate the
 effects of the pesticide on non-target plants?
                                                              010

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                                -10-
                             APPENDIX 3

    SAMPLE STANDARD FORMAT FOR PREPARATION OF SCIENTIFIC REVIEWS


     The following format shall be used in documenting the review
of the Subdivision J - Hazard Evaluation;  Non-Target Plants - Tier
3 - Terrestrial Field Testing Study.


Chemical:     (Common Name)

Formulation:  (Percent Active Ingredient)

Study/Action: {Purpose of the Submission)

Study Identification:

             . (Subdivision J Test Title)
              (Reference or Registrant Data Information with
               Study Number)
              (EPA Accession Number)

Reviewer:     (Name and Address of Reviewer; Date of Review)

Approvals     (Quality Control Reviewer)

Conclusions:  (Summary and Conclusion of Tests)

Acceptability and Recommendations:

              (Decide as to (1) the scientific validity of the
              study and (2) compliance to the Subdivision J -
              Terrestial Field Testing guidelines)
Background:

Discussion:
(Introductory Information and Directions for Use)

1.  Study Identification
2.  Materials and Methods
3.  Reported Results
4.  Reported Conclusions
5.  Reviewer's Interpretation of Results and Conclusion
                                                            Oil

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                                 -11-
                              REFERENCES
Little, T. M., and  F,  J.  Hills.  1978.  Agricultural  Experimentatio
     Design and Analysis.   New York:  John Wiley and  Sons.

"ruelove, B., ed.   1977.   Research Methodsin Weed  Science.   Southe
     Weed Science  Society.   Auburn, AL:  Auburn Printing Inc.


     Other scientific  articles of seed germination  may be found in
the following journals:

     Agronomy Journal
     Environmental Science and Technology
     Journal of Environmental Quality
     Soil Science  and  Plant Nutrition
     Weed Science
                      U.S. Environmental Protection Agency
                      Liv T-fii"-'. PTD™; ?'0'i PM-211-A
                      ^01 I' Ftroet. S.W.
                      Washington,  DC   20460
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