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Permalink Reply by 14300 on August 4, 2013 at 3:51pm

1 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON,D.C. 20460

Office of Chemical Safety and Pollution Prevention PC Code: 044309

Date: November 2, 2010 DP   Barcodes: 378994, 377955 MEMORANDUM

SUBJECT: Clothianidin Registration of Prosper T400 Seed Treatment on Mustard Seed(Oilseed and Condiment) and Poncho/Votivo Seed Treatment on Cotton. FROM: Joseph DeCant, Ecologist Michael Barrett, Chemist Environmental Risk Branch V Environmental Fate and Effects Division (7507P) THROUGH: Mah T. Shamim, Branch Chief Environmental Risk Branch V Environmental Fate and Effects Division (7507P)

TO: Kable Davis, Risk Manager Reviewer Venus Eagle, Risk Manager Meredith Laws, Branch Chief Insecticide-Rodenticide BranchRegistration Division (7505P)This memo summarizes the Environmental Fate and Effects Division’s (EFED) screening-levelEnvironmental Risk Assessment for clothianidin.

The registrant, Bayer CropScience, is submitting a request for registration of clothianidin to be used as a seed treatment on cotton and mustard (oilseed and condiment). The major risk concerns are with aquatic free-swimming and benthic invertebrates, terrestrial invertebrates, birds, and mammals.

The proposed use on cotton poses an acute and chronic risk to freshwater and estuarine/marinefree-swimming invertebrates, but the risk in some cases depends on the incorporation method and the region of the U.S. where the crops are grown. The proposed use on mustard only shows a risk concern on a chronic basis to estuarine/marine free-swimming invertebrates with a low efficiency incorporation method. The proposed uses result in acute risk to freshwater and estuarine/marine benthic invertebrates, but incorporation and region have minimal impact on the risk conclusions. Chronic risk was only present for estuarine/marine benthic invertebrates but was independent of incorporation efficiency and region. <See actual document for damage to "Bees">

(INFO ADDED BY 14300: 

BAYER CROP SCIENCE is part of Monsanto's colleagues and

"Bayer company" originated in Germany by the Nazis (I.G.Farben) - Look it up.)

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