-&EPA
               United States
               Environmental Protection
               Ayenoy
               Office cf Festic-des Programs
               Washington, DC 20460
                              July 1966
Hazard Evaluation Division
Standard Evaluation Procedure
               Avian Reproduction Test
                                          Support Document 54

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          HAZARD EVALUATION DIVISION

        STANDARD EVALUATION PROCEDURE

           AVIAN REPRODUCTION TEST
                 Prepared by


            Dennis J. McLane, B.S
Standard Evaluation Procedures Project Manager
              Stephen L. Johnson
          Hazard ^Evaluation ;B,i vision
         Office of Pesticide Programs
United States Environmental Protection  Agency
         Office of Pesticide Programs
           Washington, D.C.  20460

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                  STANDARD EVALUATION PROCEDURE

                             PREAMBLE


     This Standard Evaluation Procedure  (SEP)  is one of a set  of

guidance documents which explain the procedures used to evaluate

environmental and human health effects data submitted to the

Office of Pesticide Programs.  The SEPs are designed to ensure

comprehensive and consistent treatment of major scientific topics

in these reviews and to provide interpretive policy guidance

where appropriate.  The Standard Evaluation Procedures will be

used in conjunction with the appropriate Pesticide Assessment

Guidelines and other Agency Guidelines.  While the documents were

developed to explain specifically the principles of scientific

evaluation within the Office of Pesticide Programs, they may also

be used by other offices in the Agency in the evaluation of

studies and scientific data.  The Standard Evaluation Procedures

will also serve as valuable internal reference documents and will

inform the public and regulated community of important consider-

ations in the evaluation of test data for determining chemical

hazards.  I believe the SEPs will improve both the quality of

science within EPA and, in conjunction with the Pesticide Assess-

ment Guidelines, will lead to more effective use of both public

and private resources.
                                Fohn W. Melone, Director
                               Hazard Evaluation Division

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                     TABLE OF CONTEMTS  {Continued)


                                                          Page

III.  REPORTING  REQUIREMENTS (Continued)

       E. Body Weight  and Food Consumption  ............    8
       F, Raw Mortality Data	    8
       G. Gross  Necropsy -	• .    8
       H. Other  Observations	    8
       I. Statistical  Analysis ........................    9
       J. Acceptable Protocols	    9
 IV.  REVIEWER  EVALUATION

       A* Review  of  Materials and Methods	. *   10
             1.  Test  Substance	   10
             2.  Diet	   10
             3.  Body  Weight and Consumption	   10
             4,  Raw Data	   10
       B. Verification of Statistical Analysis  	   10
       C. ri.scuss.ion of Results .......................	..	.   11
             1.  Reproductive Effect, Mortality,  and
                Behavioral Observations	.....,,..   11
             2.  Implications of Dose/Effect  Response  ...   11
             3.  Gross Necropsy .........................   11
             4.  General Comments ...,,...........,»...••   11
       D. Reviewer's Conclusions	   11
             .1..  Category .......„..„*....	........................   .11
             2.  Rationale' ..-.,...,*...........».......-•.<•••   "12
             3..  Repairabi 1 ity •'. . •-•... - ^ ............, - .................   .13
       .E.. References 	.... —	...........-.....*   13

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                     AVIAN REPRODUCTION TEST
I.  INTRODUCTION

     A.  When Required

     Avian reproductive effects are required to support the regis-
tration of an end-use product which meets one or more of the follow-
ing criteria:

     0  Its labeling contains,-d4rections for using the product
        under conditions where birds may be subject to repeated or
        continuous exposure to the pesticide or any of its major
        metabolites or degradation products, especially preceding
        or during the breeding season;

     0  The pesticide or any of its major metabolites or degrada-
        tion products are stable in the environment to the extent
        that potentially toxic amounts may persist in avian feed;

     0  The pesticide or any of its major metabolites or degrada-
        tion products is stored or accumulated in plant or animal
        tissues, as indicated by the partition coefficient of
        lipophilic pesticides, metabolic release and retention
        studies, or as indicated by structural similarity .to known
        bioaccumulative chemicals; and/or

     0  Any other information, such as that derived from mammalian
        reproduction studies, that indicates reproduction in terres-
        trial vertebrates may be adversely aff.e.cted by the antici-
        pated use of the pesticide product.

     B. '"Purpose

     The data from this study are used to:

     0  Establish the effects of the active ingredient on bird
        reproduction;

     0  Determine the stage of the reproductive cycle affected for
        the tested species;

     0  Compare  toxicity information with measured or estimated pes-
        ticide residues in the terrestrial environment in order to
        assess potential impact on avian wildlife;

     0  Determine susceptibility differences between waterfowl and
        upland game;

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                                 -2-
      0  Provide support for precautionary label statements to ml
         mize adverse effects to avian wildlife; and             ni-

      0  Indicate the need for further testing and/or field studies

      C .   Test Substance

           1 ,  Technical Grade

      This study must be conducted with the technical grade active
 ingredient (a.i.).  If more than one a,i. constitutes a technical
"duet, then the technical grade of each a.i, must be tested separately


II.   MATERIALS AND METHODS:  TESTING STANDARDS/RECOMMENDATIONS

      A.   Acceptable Protocols

      Because avian reproduction testing is an established technique
 for assessing toxicity of a chemical to avian wildlife,, much of the
 methodology for performing these studies, as well as the procedures
 for statistical analysis of results, have been carefully outlined
 and documented in the published literature.  Kotably, the infor-
 mation to be discussed in this Standard Evaluation Procedure (SEP}
 is  presented in greater detail in the following reference.

      Ecological Effects Branch 1982.  Pesticide Assessment
      Guidelines Subdivision E, Hazard Evaluation?  Wildlife
      and Aquatic Organisms, EPA-540/9-82-024 . pp. 48-57.
      B.   Test^ Org_anisms_

           1,   Acceptable Species/Age /Physical Condition

      Testing  must be done on both a wild waterfowl species, prefer-.
 ably mallard  duck (Anas platyrhynchos) and an upland game species,
 preferably bobwhite quail (Colinus vj_rg_inianus) .  Birds approaching
 their first breeding season should be "used.

      Test birds should be pen-reared and phenotypically indistingui
 shable from wild birds.  It is recommended that the birds to be
 used are selected only from colonies that have had breeding his-
 tories maintained for them.  This history should include lighting
 practices during rearing, disease record, drugs and any other medi-
 cation administered, and exact age.  If shipped, all birds should
 be examined following shipment for possible physical injury that
 have been encountered in transit.  If deemed necessary, several_-
 birds may be  randomly selected for pretreatment necropsy at a diag-
 nostic laboratory to assess the state of health upon arrival.

      Sickness,  injuries, excessive mortality of hatchlings or any
 abnormal observations of birds are all signs that the affected
 may not  be adequate for testing.

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                                 -3-
     These species were chosen because of their commercial
availability, ecological significance, broad geographical distri-
bution, commercial and recreational  importance, ease of handling
in the laboratory, and their past use in toxicity testing and known
susceptibility to chemical exposure.  The test species should be
verified by its scientific name.

          2.  Source/Acclimation

     Within a given test all organisms must be from the same source
(this includes laboratory or commercial stocks).  It is desirable
to have a two- to six-week health observation period prior to selec-
tion of birds for treatment.

     C.  Test Conditions

          1.  Number Per Level

     For either bobwhite quail or mallard ducks a minimum of three
test groups should be used.  One group should serve as a control
and two groups as treated birds.  For bobwhite quail one male and
two females per pen by random distribution, replicated by a minimum
of 12 pens, should be used per group.

     For mallards two males and five females per pen by random
distribution, replicated by five or more pens, should be used per
group.  For either species if individual pairs (one male and one
female)  are to be used per pen, considerably more pens, greater
than 12 per test group, should be used to provide similar sensiti-
vity to the group testing design.  Control and treated birds should
be kept under the same experimental conditions.

     When other test data reveal bioaccumulative potential., the
number of test animals in the test group should be increased suffi-
ciently to partly offset animal deaths or data-gathering problems
associated with morbidity or with tissue residue determinations.

          2.  Pen Facilities

     Pen conditions should conform to good husbandry practices.
This implies clean pens, adequate room, clean food and water,
heated areas for young birds, and protection from excessive distur-
bance.  Pens should also be arranged to prevent cross-contamination.
Pen construction materials should not be toxic, capable of excessively
adsorbing test substance, dissolve in water, or loosened by peck-
ing .  For example, stainless steel, galvanized steel and materials
coated with perfluorocarbon plastics can be used.  The temperature
and relative humidity should be controlled throughout the reproductive
test and should be recorded.  Recommended levels are 21°C and 55 per-
cent relative humidity.  Ventilation is necessary.  It is desirable
to offer mallards water in which to bathe.          '

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                                -4-
          3.  Photoperiod

     Since light is extremely important, both during rearing and
during the egg laying period, all birds should be maintained for
the first eight weeks under a regime of seven hours of light per
day for maximum egg production.

     The photoperiod should then be increased to 16-17 hours of
light per day and either maintained at this level or increased by
15 minutes per week for the following 12 weeks.  (The 12-week
period may vary depending upon the time required for the onset of
egg production.)   An illumination intensity of six footcandles at
the bird level during the lighting phase of the reproductive study
is adequate.  Avoid the use of shorter wavelength "cool white"
fluorescent lights which do not emit the daylight spectrum.

          4.  Body Weights

     Body weights should be recorded at test initiation and at
biweekly intervals up to week eight or up to the onset of egg laying
and at termination.  During egg laying, body weight recording is
discouraged because of the adverse effects that handling may have
on egg production.

          5.  Food Consump-tion

     Food consumption should be recorded at least at biweekly inter-
vals throughout the study.

     Estimates of average consumption for each concentration level
must be reported  (grams per day).  Provisions for minimizing food
spillage and pr^evesting air icontamination by volatile chemicals
should foe reported.

          6.  Dose Preparation

     Concentrations for the test substance should be based on
measured or calculated residues expected in the diet from the
proposed use pattern(s).  The concentrations should include an
actual or expected field residue exposure level and a multiple
level such as five.  The highest nonlethal level may be estimated
from data developed from the avian dietary LC5Q.

     The test material should be added to table grade corn oil or
another appropriate vehicle and premixed with an aliquot of basal
diet, utilizing a mortar and pestle or mechanical blender.  It is
recommended that  the aliquot of basal diet used for the premix be
screened to remove large particles of diet before blending in the
corn oil and test material.  The final diet should be a uniformly
mixed composition consisting of 98 to 99 parts by weight of basal
diet and one or two parts by weight of corn oil.  The basal diet

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                                 _ tf	
should be  a commercial game  bird  breeder  ration  (or  its equivalent)
that  is  treated with an equivalent  amount of. vehicle.  The premix
should be  stored under conditions which maintain stability.  Test
diets should be analyzed  for pesticide concentrations at  inter-
vals  during the tests.  If other  long-term animal tests have demon-
strated  a  propensity for  the test chemical to persist or  bioaccumu-
late, the  degree of bioaccumlation  in birds should be determined by
measurement of tissue residues  in the birds from an  extra pen group
put through the reproduction test.  Two or three tissues  should be
selected for residue analysis at  the end of the exposure  period,
based on tissues known from other studies to hold highest residues.

      Control diets must contain the maximum amount of vehicle avail-
able  to  treatment birds.

           7.  Feeding and Husbandry

     All birds should receive the appropriate diet ad libitum for
the duration of the study.  Water is to be provided~ad"~ITFitum.
The test chemical should  be administered for at least ten weeks
prior to the onset of egg laying.

           8.  Egg Collection, Storage, and Incubation

     All eggs should be collected daily, marked according to pen
from which collected, and stored at 16°C and 65 percent relative
humidity.  Eggs should be set at weekly intervals for incubation in
a commercial incubator.   All eggs should be candled  on day 0 for
eggshell cracks; on approximately day 11 for bobwhites and day 14
for mallards to measure fertility and early death of embryos; and
on day 18  for bobwhite and day  21 for mallards to measure embryo
survival.  For hatching,  transfer of the eggs to a separate commer-
cial  incubator or hatcher should be made on day 21 for bobwhites
and day 23 for mallards.

     Recommended temperatures and relative humidity  during hatching
phase are  39°C and 70 percent,  respectively.
                                                     »
           9.   Observations

               a.  Bobwhite Chicks

     On day 24 of incubation, the hatched bobwhite chicks should be
removed, hatchability recorded, chicks housed according to the
appropriate parental grouping, and maintained on control diet for
14 days.   The time period should be extended if mortality occurs
appreciably late.  The diet should be a commercial bobwhite starter
diet or its equivalent.
               b.  Mallard Ducklings
     On
be removed
day  27 of  incubation,  the  hatched mallard ducklings  should
red,  hatchability  recorded, ducklings housed  according  to

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                                -6-
the appropriate parental grouping, and maintained on control diet
for 14 days.  The time period should be extended if mortality
occurs appreciably late.  The diet should be commercial mallard
starter diet or its equivalent.

          10.  Eggshell Thickness

     One day every two weeks newly laid eggs should be collected
and measured for eggshell thickness.  For consistency, the eggs
used for thickness determinations should be collected during weeks
one, three, five, seven, and nine of the egglaying period.^ An
accepted procedure is to crack open the eggs at the widestvpartion
(girth or waist), wash out all egg contents, air-dry the shells for
at least 48 hours, and then measure the thickness of the dried
shell plus the membranes at three or four points around the girth
using a micrometer calibrated to 0.01 mm units.

          11.  Withdrawal

     If the test substance is toxic (reduced reproduction evident),
then a withdrawal study period should be added to the test phase.
The withdrawal period need not exceed three weeks.  Continued
observations should be made on egg production, fertility, hatcha-
bility, and hatching survival.

          12.  Definitions

               a.  Eggs Laid

     The total egg production during a breeding season  (which is
approximately ten weeks).

               b.  Eggs Cracked                    .

     Eggs determined to have cracked shells when inspected with a
candling lamp; fine cracks cannot be detected without utilizing a
candling lamp and if undetected will bias data by adversely affec-
ting embryo development.

               c.  Eggs Set

     All eggs placed under incubation, i.e., total eggs laid minus
cracked eggs and those selected for eggshell thickness  analysis.

               d.  Viable Embryos  (Fertility)

     Eggs in which fertilization has occurred and embryonic develop-
ment has begun.  This is determined by candling the eggs six to 14
days after  incubation has begun.  It is difficult to distinguish
between the absence of fertilization and early embryonic death.
This distinction can be made by breaking out eggs that  appear
infertile and examining further.  This is especially important when
a  test compound induces early embryo mortality.

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                                  -7-
                 e .  Live Three-Week Embryos

       Embryo that is developing normally after thr«e weeks of incu-
  bation.  This is determined by candling the egg.

                 f.  Hatchability

       The percentage of embryos that mature, pip the shell, and
  liberate themselves from their eggs as computed from the number of
  fertile eggs.  For quail this generally occurs on day 23 or 24 of
  incubation, and for mallard on day 25, 26, or 27.

                 g .  Fourteen-Day-Old Survivors

       Birds that survive for 2 weeks following hatch.

                 h.  Eggshell Thickness

       The thickness of the shell and the membrane of the egg at the
  girth after the egg has been opened, washed out, and dried for at
  least 48 hours, at room temperature.


III.   REPORTING REQUIREMENTS

       A.  Test Material

       The purity of the test material must be stated and should
  generally be "technical"  grade unless otherwise required.   The
  percent a.i. must be  stated.

       B .  Observable ^Effects Criteria

       :Ttee -criteria for  ^determining effects must be defined.   In addi-
  tion to any deaths and other acute effects, the following  repro-
  ductive parameters, as defined,  must be reported:

       0   Eggs laid/hen;

       0   Eggs cracked •(%};

       0   Viable  embryos of  egg  set (%);

       0   Live three-week embryos  (%);

       0   Normal  hatchlings  of live three-week embryos (%);

       0   14-day-old  survivors per  hen;  and

       0   14-day-old  survivors of  normal  hatchlings  {%).

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                                 -8-
     C.   Statistically  Significant  Differences

     Statistical methods must  be  presented which calculate  the
differences  between  reproductive  parameters.

     D.   Results of  Chemical Analysis

     If  the  concentration of the  test material was measured,  the
results  should be  reported.  It is  particularly important that
concentrations of  pesticide in the  diet be measured and  results
reported  when:

     0   The  test material was  a dry powder and no vehicle was used;

     0   The  test material was  volatile; or

     °   The  test material was  administered in the feed or water and
         data from  other subdivision(s) suggest that the  actual
         concentrations  over the length of the test may decrease by
         30 percent or more.

     E.   Body Weight and Food Consumption

     Body weights  and food consumption should be recorded at  test
initiation.  Both  should be recorded biweekly thereafter except for
body weights.  Weighing should be discontinued after week eight or
after the onset of egg  laying.  The average for each test group
should be provided.

     F.   Raw Mortality  Data

     Raw mortality data or percentage of death/effects must be re-
ported ...... The data ,must  indicate the numbers ,of birds dying ;at each
dose or control level.  The day of  death/effects must be reported;
it is preferable to  also report the time of death.

     G.  Gross Necropsy

     Gross necropsies are preferred.  When performed, all dead birds
should be examined,  as  well as a  sufficient number of survivors in
order to provide a characterization of gross lesions.  Inspections
of the GT tract, liver, kidneys,  heart, reproductive organs, and
spleen should be made.  Also, subcutaneous fat and muscles should be
examined for evidence of deterioration.

     H.  Other Observations

     Signs of intoxication should be described as to what was
observed, when, and  for how long.    Technical terminology used to
name signs of intoxication should be adequately defined  if these
terms are not in general use.  The  report should indicate whether
deaths are associated with specific signs of intoxication, and the
time of onset and remission of toxic signs.  If affected birds

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                                  -9-
 recover,  the  time  interval  to  recovery  should be  reported.  Marked
 observation of  fecal material  and  urine should be reported.

      I.   Statistical Analysis

      A statistical analysis of the mortality data is required.
 Reproductive  data  consist of continuous variables (e.g., shell thick-
 ness, and body  weight data) and discrete variables  (e.g., number of
 eggs laid or  14-day-old survivors).  For continuous variables,
 experimental  groups should  be  compared  to controls by analysis of
 variance.  For  the following discrete variables, survival percentages
 should be computed: eggs cracked, viable embryos of eggs set, live
 three-week embryos, normal  hatchling of live three-week embryos,
 14-day old survivors per hen,  and 14-day old survivors of normal
 hatchlings. These  values should then be arcsine transformed prior
 to analysis of  variance.  Alternately, a chi square analysis of
 survival  (contingency tables) may be used for discrete variables.
 Analyses  should include body weight, food consumption, eggs laid,
 eggshell  thickness, eggs cracked, viable eggs, fertility, live
 three-week ducklings, 14-day old survivors  (per number of eggs
 hatched, per  hen, and per number of eggs laid).  Sample units are
 generally the pens within each group.

      In order that the concentration causing an adverse effect can
 be identified, a test such as the Duncan^s Multiple Range Test
 should be performed if the analysis of variance indicates statis-
 tical differences.

      J.  Acceptable Protocols

      EEB does not endorse any one protocol.   It is sometimes neces-
 sary an<3 desiratelse ±o alter the procedures presented in published
 protocols to meet the needs of the chemical or test organisms used.
 However, EEB does recommend some protocols as guidancefor developing
 avian dietary toxicity tests.  These protocols include:

      Ecological Effects Branch, 1982.  Pesticide Assessment
      Guidelines Subdivision E, Hazard Evaluation:   Wildlife
      and Aquatic Organisms, EPA-540/9-82--024. pp.  48-57.

 This referenced protocol provides flexible guidance  to help resear-
 chers design scientific protocols arid, to assist the  reviewer in
 validating studies.  It is important to recognize  that avian repro-
 duction studies are validated based upon ^whether they fulfill guide-
 line requirements and  whether they provide scientifically sound
 information on the reproductive toxicity of  the test material to
 avian wildlife that is useful in hazard assessments.   This is more
 important than whether they follow a referenced protocol  step-by-
 step.                                   ;


IV.   REVIEWER EVALUATION

      The reviewer  should identify each  aspect of  the  reported  proce-
 dure that is  inconsistent  with recommended protocol.   The signif-
 icance  of these deviations must be determined.   The  number  of

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                               -10-
deviations and their severity will determine the validity of the
study and the interpretation of the results.

     A.  Review of Materials and Methods

          1.   Test Substance

     When the technical grade is greater than 80% a.i., the reviewer
may elect not to adjust the concentration levels at which statis-
tically significant adverse effects occurred to reflect actual
amount of a.i..  Reviewers should check the accuracy of the reported
effect levels by recalculating the doses in ppm a.i. in treated
diets.

          2.   Diet

     A review of the diet composition should be made specifically
to check for  unfamilar ingredients or medications.  Any such-
unfamiliar ingredient or suspected additive should be verified by
contacting the testing laboratory prior to classifying the study.
          3.  Body Weight and Food Consumption

     Body weight and food consumption data can be used
effects, if any, on feeding and/or weight change.
to evaluate
     Reduced food consumption and body weight may affect the ability
of a bird to reproduce.  If reduced food consumption or body weight
occurs, the reproductive parameters should be viewed with this in
mind as a possible explanation for adverse effects.

     Also, those items mentioned in the SEPs for avian LD5Q and LC50
should be incorporated into the design of this study.

          4.  Raw Data

     The raw data must be checked to insure consistency with the
written report.  In cases where the two do not agree, the discrepan-
cies must be explained in writing prior to classifying the study.

     The control data must be checked and should be consistent with
other studies on like species.

     B.  Verification of Statistical Analysis

     The reviewer should "validate" the statistical analysis of the
data.  This may be done using EEB's "SAS" program "Bigbird" which
performs analysis of variance with and without arcsine transformed
variables.  The significant groups are then identified by Duncan's
Multiple Range Test.  Any differences from the control should be
noted and an explanation required from the registrant.

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                                -11-
     Adjustments to the study's statistical parameters may be made
at this time to reflect the reviewer's estimate of the parameters.
These may be necessary to account for actual amount of a.i. con-
sumed, e.g., in cases where the test material a.i. content was lower
than 80% or insufficient diet was consumed, or to correct errors in
the authors' calculations or methodology.

     C.  Discussion of Results

          1.  Reproductive Effect, Mortality,
              and Behavioral Observations

     The reviewer should discuss the results in light of the observa-
tions of intoxication.  Statistically and biologically significant
observations should be discussed if possible.  Reproductive effects
and mortality which cannot be fully attributed to the effects of
the test material may be better understood if assessed in light of
behavioral observations.  Also, signs of intoxication could aid in
understanding potential sublethal effects which could affect the
birds' ability to develop and survive in the wild.

          2.  Implications of Dose/Effect Response

     Dose/effect response many times reveals important characteris-
tics about the toxicity of the test material, such as whether the
response is commensurate with the decline of the test level.

     Pertinent data on dose/effect response should be included in
data evaluation records.

          3.  Gross Necropsy

     The ^results of gross necropsies, when performed/ may be helpful
in evaluating the study. Lesions of reproductive systems may confirm
changes in the reproductive parameters.

          4.  General Comments

     Reviewers should comment on the protocol used and the methods or
other aspects of the study which are irregular, unfamiliar, or unaccep-
table.  Suggestions for improvements to the protocol can be made, as
well as giving rationale for rejecting certain methods or aspects of
the study.  Of particular importance are the reviewer's comments on
any aspect of the study, such as condition of•the birds, husbandry
practices, dose administration or rejection, toxic symptoms, or envi-
ronmental conditions, which could bear on the interpretation of the
results.

     D.
          1.   Category

     The reviewer should indicate under which of the three valida-
tion categories the study fits:

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                               -12-
    0  Core:  All essential information was reported and the study
       was performed according to recommended protocols.  Minor
       inconsistencies with standard methodologies may be apparent;
       however, the deviations do not detract from the study's
       soundness or intent.  Studies within this category fulfill
       the basic requirements of current guidelines and are accep-
       table for use in a risk assessment.

    °  supplemental:  Studies in this category are scientifically
       sound; however, they were performed under conditions that
       deviated substantially from recommended protocols.  Results
       do not meet guideline requirements; however, the information
       may be useful in a risk assessment.  Some-©f the conditions
       that may place a study in a supplemental category include:

         -  Unacceptable test species;
            Inappropriate test material;
         -  Deviations from recommended diet preparation procedures;
            or                     .     '
         -  Dosage levels tested were below the expected concentra-
            tion on avian food items when  treated at  recommended
            label  rates.

     0  Invalid:  These studies provide  no  useful  information.
       They may not be scientifically sound, or they  were performed
       under conditions  that deviated so  significantly  from the
       .recommended protocols, that the  results  will not be  useful
       in a risk assessment.

       Examples of  studies placed  in  this  category  include  those
       in which there  were problems with  volatility of  the  test
       material or  a dry  chemical  was mixed  without the use of a
       vehicle.  Unless  acceptable chemical  analyses  of actual
       toxicant concentrations were performed  in  studies  such  as
       these,  the  reviewer cannot  be  sure  that  test organisms  were
       actually  exposed  to nominally  designated concentrations.

       A study where  the  test material  was not  properly identified
       can  also  be invalidated.

          2.   Rationale

     Identify what  makes the  study  supplemental or invalid.  \It may
also be necessary  to justify  a higher  category  in  spite of devia-
tions.   That is,  a  study may have been called core or  supplemental
even though  there  were  substantial  deviations from recommended
protocol.  While all deviations  should be noted, it may be that the
deviations did not  actually alter the response  of  the  test organism
to the  test  material.   The reviewer is expected to exercise judgment
in this area.

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                                -13-
          3.   Repairability

     Indicate whether the study may be upgraded or given a higher
validation category if certain conditions are met.  Usually this
would involve the registrant submitting more data about the study.

     E.   References

     The reviewer should reference any information used in the valida-
tion procedure.  This should include protocol documents, statis-
tical methods, or information taken from "files of other Divisions
or Branches within HED.                  ^-"—

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