Flutolanil was included in Annex I on November 26th, 2008 (entry into force March 2009). The List of Endpoints of the EFSA conclusion is used for the assessment.
In the inclusion directive (PART B) the following is mentioned:
In assessing applications to authorise plant protection products containing flutolanil for uses other than potato tuber treatment, Member States shall pay particular attention to the criteria in Article 4(1)(b), and shall ensure that any necessary data and information is provided before such an authorisation is granted. For the implementation of the uniform principles of Annex VI, the conclusions of the review report on flutolanil, and in particular Appendices I and II thereof, as finalised in the Standing Committee on the Food Chain and Animal Health on 20 May 2008 shall be taken into account.
Conditions of authorisation should include risk mitigation measures, where appropriate.
An additional study, a kinetic analysis of field trials, was evaluated and summarized by Alterra (Nov 2007, report no. 10579-mil). For the application for extension of Monarch (20090949), one additional field study was evaluated (Alterra report no. 23495-mil, October 2010). Evaluated endpoints of these studies are added to the List of Endpoints (below the field studies) in italics.
Moreover, for current application a kinetic analysis of water –sediment studies. A summary of this study including evaluated endpoints are added in italics below the list of endpoints.
List of Endpoints Fate/behaviour (in line with EFSA conclusion) Route of degradation (aerobic) in soil (Annex IIA, point 7.1.1.1.1) (The percentages quoted are referred to the % of the applied radioactivity) Mineralization after 100 days ‡
([aniline ring-U-14C]-label)
- European soils: 2.9-9.9 % after 105 d (n1= 4), 20
oC
- US soil: 13.4 % after 116 d (27.5 % after 365 d) (n=1), 25 oC
Non-extractable residues after 100 days ‡ ([aniline ring-U-14C]-label)
- European soils: 9.4-27.9 % after 105 d (n=4), 20
oC
- US soil: 15.9 % after 116 d (26.7 % after 365 d) (n=1), 25 oC
Metabolites requiring further consideration ‡ - name and/or code, % of applied (range and maximum) ([aniline ring-U-14C]-label)
No (the only metabolite appearing over 5 % was CO2)
Route of degradation in soil – Supplemental studies (Annex IIA, point 7.1.1.1.2) Anaerobic degradation ‡
Mineralization after 100 days days ([aniline ring-U-14C]-label)
0.2 % / 120 d (0.4 % / 365 d) (n=1) Sterile conditions: no data available Non-extractable residues after 100 days
([aniline ring-U-14C]-label)
4.6 % / 120 d (7.4 % / 365 d) (n=1)
Metabolites that may require further consideration for risk assessment - name and/or code, % of applied (range and maximum)
No (after 365 days total amount of flutolanil 86 %)
Soil photolysis ‡
Metabolites that may require further consideration for risk assessment - name and/or code, % of applied (range and maximum)
The study is not relied upon (PRAPeR 22, May 2007), but it is not required for the representative use evaluated (seed treatment for potatoes prior planting)
1
Rate of degradation in soil (Annex IIA, point 7.1.1.2, Annex IIIA, point 9.1.1) Laboratory studies ‡
Parent Aerobic conditions Soil type Org.
Geometric mean/median 190/143 (n =
6)
SFO
1 = based on average determinations on soil samples taken from the same location five years before the test started, no information on the measurement method
2 = calculated by the RMS
3 = calculated by the RMS by the equation DT90 = 3.32 x DT50
No metabolites requiring further consideration
Field studies ‡ field studies available, revised DT50 values not peer reviewed. *, **
pH dependence ‡
(yes / no) (if yes type of dependence)
No
Soil accumulation and plateau concentration ‡ No field accumulation studies
The plateau concentration (0.1301 mg/kg) was calculated to be achieved after 16 years (a 2-year rotation, 276 g as/ha) 1
1 = based on the worst case laboratory DT50 value of 412 days, as calculated in the original DAR;
agreed by PRAPeR 22 as worst case
* Ctgb added from EFSA conclusion: The view of the experts was that as the study design of the treated seed potato trials represents the intended use applied for flutolanil, the derived DT50s can be considered appropriate for PECsoil calculations (see section 4.1.3). However, no agreement could be reached on the suitability of the use of the field DT50 derived from the available field trials for FOCUS modelling.
** Ctgb: study submitted for the Dutch application for authorisation evaluated by Alterra (report no.
10579-mil, November 2007). During evaluation, some values were rejected and the data set was improved by first averaging DT50 values from the same soils). Individual values are: 152, 153, 171 (geomean of 140 and 208 d), 175 d (overall geomean normalised DT50 162 days, used for assessment of potato tuber treatment).
Ctgb, November 2012: the value of 140 d. should be excluded from the above DT50 endpoint calculation, as only the studies with tube treatment should be taken into account for this application.
New DT50 = 171 days (=geomean of 152, 153, 208 and 175).
Laboratory studies ‡
Parent Anaerobic conditions Soil type Org.
* = Water saturated soil
** = Test concentration 5 mg/kg
*** = Test concentration 50 mg/kg
**** = The first order decline curve was calculated based on the concentrations of flutolanil as a percentage of recovered radioactivity. However, very little degradation was detected over the course of the study (after 365 days total amount of flutolanil 86 %) and the substance can be classified as stable in anaerobic conditions.
No metabolites requiring further consideration
Soil adsorption/desorption (Annex IIA, point 7.1.2) Parent ‡
Arithmetic mean/median/geometric mean 7814/641/735 0.93/0.935 /0.924
pH dependence, Yes or No No
1 = assuming organic matter (%) = 2.0 x organic carbon (%) 2 = assuming organic matter (%)= 1.72 x organic carbon (%)
3 = these values were omitted in PECgw modelling due to their low organic matter content
4 = the arithmetic mean value used in PECgw modelling (683, n = 8) was calculated assuming organic matter = 1.724 x organic carbon
No metabolites requiring further consideration
Mobility in soil (Annex IIA, point 7.1.3, Annex IIIA, point 9.1.2)
Column leaching ‡ Eluation (mm): 200 mm
Time period (d): 2 d
Leachate: less than 0.24 % total residues/radioactivity in leachate
The radioactivity of soil column was not analyzed.
Aged residues leaching ‡ After 8 months of aging flutolanil still accounted for 84 % of the extracted radioactivity. Thus it was considered inappropriate to continue the
experiment and the study was found unnecessary.
Lysimeter/ field leaching studies ‡ Not considered necessary
Route and rate of degradation in water (Annex IIA, point 7.2.1) Hydrolytic degradation of the active substance
and metabolites > 10 % ‡
Photolytic degradation of active substance and metabolites above 10 % ‡
Stable to hydrolysis (pH 5-9: at the end of a 30-day study recovery of applied radioactivity 103-108 %, flutolanil accounted for 98.3-99.5 %, no hydrolysis products were observed)
DT50: 277 d (SFO, r2 = 0.812) No relevant metabolites Xenon arc lamp, 30 d Quantum yield of direct phototransformation in
water at Σ > 290 nm N.a.
Readily biodegradable ‡ (yes/no)
No (the change of BOD/28 days was 0 %)
Degradation in water / sediment
Parent Distribution (max in water 96.8-97.8 % after 0.25 d. Max. sed 34.0-68.7 % after 30 d) Water /
1 = before study start 2 = study end
No metabolites requiring further consideration
Mineralization and non-extractable residues Water /
sediment system
pH water
pH sed Mineralization
x % after n d. (end of the study)
Non-extractable residues in sed.
max x % after n d (end of the study)
Pond, NL 8.31 -7.02
7.3 5.2 % after 105 d 26.3 % after 105 d
Ditch, NL 7.21 -6.52
6.7 3.7 % after 105 d 15.1 % after 105 d
1 = before study start 2 = study end
PEC (ground water) (Annex IIIA, point 9.2.1) Method of calculation and type of study (e.g.
modelling, field leaching, lysimeter )
For FOCUS gw modelling, values used – Model(s) used:
FOCUS PRZM V2.4.1 and FOCUS PEARL V3.3.3:
Scenarios: Chateaudun, Hamburg, Jokioinen, Kremsmünster, Okehampton, Piacenza, Porto, Sevilla, Thiva
Crop: Potatoes
DT50, parent: 190 d (geometric mean, n=6,
ModelMaker optimization and normalisation to pF2, 20 oC with Q10 of 2.2) *
Kfoc, parent: 683 L/kg (arithmetic mean, n=8, the sand soils were omitted from the calculations due their low organic matter content) 1/n= 0.896
Metabolites: No metabolites requiring further consideration
Lysimeter or field leaching studies were not carried out.
Application rate Application rate: 276 g/ha (potato seed planting rate 3000 kg/ha, incorporation depth 20 cm)
No. of applications: 1 application/2 years (a 2-year crop rotation period)
Time of application: the date of planting for PEARL, 15 days pre-emergence for PRZM (January-May)
Fate and behaviour in air (Annex IIA, point 7.2.2, Annex III, point 9.3)
Direct photolysis in air ‡ No data available (flutolanil has a low vapour pressure, 4.7 x 10-8, and as such its concentration in the atmosphere is likely to be negligible) Quantum yield of direct phototransformation No data available (flutolanil is not susceptible to
direct phototransformation and therefore it is not possible to determine the quantum yield)
Photochemical oxidative degradation in air ‡ Half-life: 0.114 days (a day:12 hours of sunlight), 0.057 days (a day: 24 hours of sunlight)
(The concentration of OH radicals 9.5 x 105) (These estimations were carried out with respect to the OH-radical reaction, only.)
Volatilisation ‡ Not available
Metabolites None
Residues requiring further assessment Environmental occurring metabolite requiring further assessment by other disciplines (toxicology and ecotoxicology).
Soil: flutolanil
Surface water: flutolanil Sediment: flutolanil Ground water: flutolanil Air: flutolanil
Monitoring data, if available (Annex IIA, point 7.4)
Soil (indicate location and type of study) No data provided – none requested Surface water (indicate location and type of
study) No data provided – none requested
Ground water (indicate location and type of
study) No data provided – none requested
Air (indicate location and type of study) No data provided – none requested
Points pertinent to the classification and proposed labelling with regard to fate and behaviour data
Not readily biodegradable, R53
Also an additional kinetic evaluation [Hardy and Patterson, 2010] of the water/sediment study [Wyss-Benz, 1993] was submitted. This water/sediment study was according to GLP, and accepted by the RMS. The kinetic analysis was performed according to FOCUS kinetics, statistics and visual fits were good/excellent. Ctgb agrees on the evaluation. DT50 value for modelling is 146 days (geomean, n=2).
Appendix A: Metabolite names, codes and other relevant information of the plant protection product Symphonie with a.s. flutolanil.
The compounds shown below were found in one or more studies involving the metabolism and/or environmental fate of flutolanil. The parent compound structure of flutolanil is shown first in this list and followed by degradate or related compounds.
Compound IUPAC Structural Structure Mole- Observed in
flutolanil α,α,α- trifluoro-3’- isopropoxy-o-toluanilide
C17H16F3NO2 323.3 parent
No major metabolites identified
6.1 Fate and behaviour in soil 6.1.1 Persistence in soil
Article 2.8 of the Plant Protection Products and Biocides Regulations (RGB) describes the authorisation criterion persistence. If for the evaluation of the product a higher tier risk assessment is necessary, a standard is to be set according to the MPC-INS4 method.
Currently this method equals the method described in the Technical Guidance Document (TGD). Additional guidance is presented in RIVM5-report 601782001/20076.
Preceding the harmonisation of the persistence assessment in The Netherlands with regulation 1107/EG, the EU approach for persistence assessment is followed.
For the current application this means the following:
Active substance flutolanil:
The following laboratory DT50 values are available for the active substance flutolanil: 115, 380, 151, 397, 133, 135 days (geomean 190 days, n=6).
Due to the exceeding of the threshold value of 60 days for the mean DT50 (lab) for flutolanil, it must be demonstrated by means of field dissipation studies that the field DT50 is < 90 days.
The DT50 values derived from field data in the DAR were under discussion in PRAPeR 22.
The new values (not yet in updated List of Endpoints) are not EU peer reviewed. However, for the Dutch application for authorisation, a report of Hardy & Pattel7 was submitted. This report is evaluated by Alterra and (after evaluation, some values were rejected and the data set was improved by first averaging DT50 values from the same soils) yields a geomean normalised (to 20 °C assuming a Q10 of 2.2) field DT50 value for use in tuber treatment
(dusting is assumed to be tuber treatment) of 171 days (geomean of: 152, 153, 208, 175 d.).
Based on the above, the proposed application of the plant protection product Symphonie as tuber treatment (includes dusting) does not meet the standards for persistence as laid down in the RGB. Therefore an additional ecotoxicological assessment is needed based on the PECplateau summed up with the PIEC from one season.
PECsoil
The concentration of the active substance flutolanil in soil is needed to assess the risk for soil organisms (earthworms, micro-organisms). The PECsoil is calculated for the upper 5 cm of soil using a soil bulk density of 1500 kg/m3.
4 INS: international and national quality standards for substances in the Netherlands.
5 RIVM: National institute of public health and the environment.
6 601782001/2007: P.L.A. van Vlaardingen and E.M.J. Verbruggen, Guidance for the derivation of environmental risk limits within the framework of 'International and national environmental quality standards for substances in the Netherlands' (INS). Revision 2007’.
7 I.A.J. Hardy & M. Patel. XG/06/002B “Flutolanil: kinetic modelling analysis of data from a field soil dissipation study at four locations in Europe”
CONH
CF3 OCH(CH3)2
As the logPow of the substance is > 3 (3.17), a PEC21days is needed for the assessment of secondary poisoning of birds and mammals through the consumption of earthworms.
The PIECsoil for the tuber treatment (potatoes) is calculated as PECsphere (mg/kg) = Dose / (1500*n*(S/1000)*V)
Where
Dose = application rate (kg active substance/ha) n=sowing density
S=seeds per ton (default 12000 for seed potatoes and 10000 for ware/starch) V=Volume sphere of influence (m3) (default 0.00154854 for potatoes)
According to the WG, the dose is 150 gram product per 100 kg potatoes. This corresponds to 9 gram active substance per 100 kg potatoes. Because Ctgb, as per default, calculates with 4500 kg seed potato per hectare and 2500 ware/starch potatoes per hectare, the
corresponding dose is 405 gram active substance per hectare and 225 gram per hectare, respectively.
The following input data are used for the calculation:
PEC soil:
Active substance flutolanil:
Maximum normalised field DT50 for degradation in soil: 208 days (maximum of tuber treatment DT50 values) for tuber treatment (potatoes)
Molecular mass: 323.3 g/mol
See Table M.1 for other input values and results.
Table M.1 PECsoil calculations for active substance flutolanil (5 cm and 20 cm)
Use Rate
* fraction on soil is detemined as 1 – interception value; interception values derived from Table 1.6 in “generic guidance for FOCUS groundwater scenarios”. For BBCH 00, zero interception is appropriate.
** seed potatoes; calculated assuming 54000 tubers/ha
*** starch/ware potatoes; calculated assuming 25000 tubers/ha
These exposure concentrations are examined against ecotoxicological threshold values in section 7.5.
6.1.2 Leaching to shallow groundwater
Article 2.9 of the Plant Protection Products and Biocides Regulations (RGB) describes the authorisation criterion leaching to groundwater.
application rate 0.405 kg/ha, the crop [potatoes] and no interception. The application scheme includes injection at 20 cm depth. Date of yearly application is May 25th for spring
applications.
PEARL:
Geometric mean field DT50 for degradation in soil (20°C): 171 days (for tuber treatment application in potatoes, see LoEP)
Arithmetic mean Kom (pH-independent): 396.2 L/kg Arithmetic mean 1/n: 0.896
Saturated vapour pressure: 4.1*10-7 Pa (20 °C) Solubility in water: 8.01 mg/L (20 °C)
Molecular weight: 323.3 g/mol
Plant uptake factor: 0.5 (systemic substance) Q10: 2.2
Other parameters: standard settings of PEARL 4.4.4
The following concentrations are predicted for the active substance flutolanil following the realistic worst case GAP, see Table M. 2a.
Table M.2a Leaching of active substance flutolanil as predicted by PEARL 4.4.4 Use Substance Rate
substance [kg/ha]
Frequency Interval [days]
Fraction Intercepte d *
PEC
groundwater [µµµµg/L]
KREM-spotatoes
Flutolanil 0.405** 1/- 0
(injection at 20 cm)
0.746
* interception values derived from Table 1.6 in “generic guidance for FOCUS groundwater scenarios”. Zero interception is appropriate for BBCH 00.
** Application rate based on 4500 kg seed potatoes per hectare, at 9 gram a.s. per 100 kg potatoes
Results of Pearl 4.4.4 using the Kremsmünster scenario are examined against the standard of 0.01 µg/L. This is the standard of 0.1 µg/L with an additional safety factor of 10 for
vulnerable groundwater protection areas (NL-specific situation).
For active substance flutolanil, expected leaching is larger than 0.1 µg/L. Therefore, further study into the leaching behaviour was done.
In the second tier, leaching in potential area of use is evaluated using the spatial distribution model GeoPEARL 3.3.3.
GeoPEARL
The leaching potential of substances to the shallow groundwater in the potential area of use within The Netherlands is calculated using the GeoPEARL model. The same input data as used in the first tier with Pearl 4.4.4 is employed. Additional input is the crop and the number of plots (minimum 250). Due to new insights on potato application, the injection depth for potatoes is adjusted to 10 cm in this GeoPEARL assessment. For results see Table M.2b.
Table M.2b Leaching of active substance flutolanil as predicted by GeoPEARL 3.3.3 Use Substance Rate
a.s.
[kg/ha]
Frequency Interval [days]
Fraction Intercepted*
PEC
groundwater [µµµµg/L]
Ware
and starch potatoes (dusting)
Flutolanil 0.405** 1/- 0
(injection at 10 cm)
0.007
*interception values derived from Table 1.6 in “generic guidance for FOCUS groundwater scenarios”. Zero interception is appropriate for BBCH 00.
** Application rate based on 4500 kg seed potatoes per hectare, at 9 gram a.s. per 100 kg potatoes
GeoPEARL calculations show that the predicted leachate concentrations for flutolanil are smaller than 0.01 µg/L. Hence, the active substance meets the standards laid down in the RGB for the proposed applications.
Monitoring data
Article 2.10b of the Plant Protection Products and Biocides Regulations (RGB) describes the use of the 90th percentile.
There are no data available regarding the presence of the substance flutolanil in groundwater.
Conclusions
For active substance flutolanil (when used as tuber treatment), a higher tier assessment for persistence is performed in Chapter 7. Ecotoxicology.
The proposed application of the product complies with the requirements laid down in the RGB concerning leaching in soil.
6.2 Fate and behaviour in water
6.2.1 Rate and route of degradation in surface water
Article 2.10c of the Plant Protection Products and Biocides Regulations (RGB) prescribes the use of Dutch specific drift percentages. However, for the application method applied for, dusting on tubers, no drift and thus no exposure to the surface waters is expected.
Monitoring data
Article 2.10b of the Plant Protection Products and Biocides Regulations (RGB) describes the use of the 90th percentile.
The Pesticide Atlas on internet (www.pesticidesatlas.nl, www.bestrijdingsmiddelenatlas.nl) is used to evaluate measured concentrations of plant protection products in Dutch surface water, and to assess whether the observed concentrations exceed threshold values.
Dutch water boards have a well-established programme for monitoring plant protection product contamination of surface waters. In the Pesticide Atlas, these monitoring data are processed into a graphic format accessible on-line and aiming to provide an insight into measured plant protection product contamination of Dutch surface waters against environmental standards.
The current version 2.0 of the Pesticide Atlas does not contain a land use correlation
Data from the Pesticide Atlas are used to evaluate potential exceeding of the authorisation threshold and the MPC (ad-hoc or according to INS) threshold.
For examination against the drinking water criterion, another database (VEWIN) is used, since the drinking water criterion is only examined at drinking water abstraction points. For the assessment of the proposed applications regarding the drinking water criterion, see next section.
Active substance flutolanil:
The active substance flutolanil was observed in the surface water (at the time of the original assessment data from 2010). In Table M.3. the number of observations in the surface water are presented.
In the Pesticide Atlas, surface water concentrations are compared to the authorisation threshold value of 23.2 µg/L (C-231.3.4, 12-8-2011, consisting of first or higher tier acute or chronic ecotoxicological threshold value, including relevant safety factors, which is used for risk assessment *, in this case [0.01*NOECfish]) and to the indicative Maximum Permissible Concentration (MPC) of 22 µg/L as presented in the Pesticide Atlas.
Currently, this MPC value is not harmonised, which means that not all available
ecotoxicological data for this substance are included in the threshold value. In the near future and in the framework of the Water Framework Directive, new quality criteria will be
developed which will include both MPC data as well as authorisation data.
The currently available MPC value is reported here for information purposes. Pending this policy development, however, no consequences can be drawn for the proposed applications.
Table M.3. Monitoring data in Dutch surface water (from www.pesticidesatlas.nl, version 2.0)
Total no of locations (2010)
n >
authorisation threshold
n > indicative/ad hoc MPC threshold
n > MPC-INS threshold *
358** 1 (exceeding 1-2
x MTR)
1 (exceeding 1-2 x ad hoc MPC)
n.a
* n.a.: no MPC-INS available. < : exceeding expected to be lower than with indicative/ad hoc MPC value; > : exceeding expected to be higher than with indicative/ad hoc MPC value
** the number of observations at each location varies between 1 and 30, total number of measurements is 2118 in 2010.
As there is only one exceeding of the thresholds, no statistical significant relation with the proposed uses can be established. Therefore, the monitoring data have no consequences for the proposed uses of the product.
Drinking water criterion
Article 2.10b of the Plant Protection Products and Biocides Regulations (RGB) describes the use of the 90th percentile.
It follows from the decision of the Court of Appeal on Trade and Industry of 19 August 2005 (Awb 04/37 (General Administrative Law Act)) that when considering an application, Ctgb should, on the basis of the scientific and technical knowledge and taking into account the data submitted with the application, also judge the application according to the drinking water criterion ‘surface water intended for drinking water production’.
The assessment methodology followed is developed by the WG implementation drinking water criterion and outlined in Alterra report 16358.
8Adriaanse et al. (2008). Development of an assessment methodology to evaluate agricultural use ofplant
Substances are categorized as new substances on the Dutch market (less than 3 years authorisation) or existing substances on the Dutch market (authorised for more than 3 years).
- For new substances, a preregistration calculation is performed.
- For new substances, a preregistration calculation is performed.