Addendum for Trifluralin Second Draft Prepared by BiPRO GmbH March 2010 Adjusted: April 2010 Table of Content 1 Introduction ................................................................................................................................... 2 2 Assessment of new information provided by Canada ....................................................................... 3 2.1Summary of the information provided by Canada on Bioaccumulation ................................. 3 2.2Comments on the information provided by Canada on Bioaccumulation .............................. 4 2.3Summary of the information provided by Canada on criterion 2b ....................................... 10 2.4Comments on the information provided by Canada on criterion 2b .................................... 11 3 Additional information on environmental occurrence/monitoring ..................................................12 4 Transformation products of trifluralin ............................................................................................17 5 References ....................................................................................................................................21 1 1 Introduction In accordance with Article 14 of the UNECE POP protocol the European Community and its Member States have proposed trifluralin to be added to the Protocol. The TFPOP in its seventh meeting in June 2009 agreed that this substance fulfils the POP criteria. The European Commission hence has the lead to develop a risk management option dossier for trifluralin for consideration in the next UNECE task force meeting. However, some concerns have been raised as regards certain aspects of the trifluralin dossier during the TFPOP meeting in June 2009. Canada provided additional information on trifluralin in December 2009 for consideration of the review of the substance. This report is an addendum to the Trifluralin Dossier prepared in support of the EC nomination proposal of trifluralin [EC 2007]. To ensure that the POP dossier on trifluralin contains the latest relevant information on its POP characteristics and its metabolites, this addendum includes an assessment on the additional information submitted by Canada (Chapter 2), an update on the available literature (Chapter 3) and a limited assessment of the POPs characteristics of the most important degradation/biotransformation products of trifluralin (Chapter 4). 2 2 Assessment of new information provided by Canada The information provided by Canada in December 2009 included additional information for consideration in the interpretation of the bioaccumulation criterion and the adverse human health and/or environmental effects as a result of its long-range transboundary atmospheric transport. 2.1 Summary of the information provided by Canada on Bioaccumulation BCF and BAF values The authors of the Canadian comments summarise that reported and reviewed laboratory BCF and BAF values of trifluralin ranged from 276-4730 in algae, 20 - 870 in snails, 30 - 92 in daphnia, to 8893-8870 in various fish species. It was highlighted that there is considerable variability in BCF values between studies, within studies and within species suggesting that the evidence of trifluralin for bioaccumulation is conflicting. It is concluded that some studies stress that this substance exceeds the numeric criterion for bioaccumulation. However, many of these studies also show that trifluralin is readily depurated. Elimination of trifluralin Various studies addressing the depuration half-lives for different aquatic species presented in the paper indicate half-lives between 2 and 57 days. It is claimed that trifluralin is readily eliminated in fish and other organisms and that the metabolism profile seen in fish is consistent with the metabolism profile observed in various terrestrial species. The authors associate studies with terrestrial animals with depuration in aquatic organisms. Thus, it is highlighted that in studies conducted on rats, trifluralin was shown not to be readily absorbed from the gastrointestinal tract after oral intake. Essentially all of absorbed trifluralin was completely metabolised and eliminated within 3 days after oral administration. It is pointed out that although no robust data on the toxicokinetics of trifluralin in humans have been reported, the Trifluralin Dossier (EC 2007) indicated “that there is no evidence of bioaccumulation of trifluralin and it does not appear to have been detected in human adipose tissue, breast milk or in blood samples from the general population.” It is concluded that this is despite evidence of long range transport of trifluralin and its high volume of use in North America and other parts of the world for over 40 years. Bioavailability It is stated that studies may not adequately represent bioaccumulation dynamics in the natural environment where it is expected that trifluralin may be primarily adsorbed to sediment. The available data indicate that the substance is strongly adsorbed to sediments but there is uncertainty whether trifluralin is readily available for bioaccumulation. According to the additionally provided data, there is evidence in published studies that toxicity and bioconcentration factors are lower when exposure occurs under realistic conditions in the presence of sediment in a static system versus when fishes are exposed to an artificial system where there is a continuous input of trifluralin through the water phase only. Lack of monitoring data in biota It is stated that although some BCF values indicate that there is a potential for bioconcentration, there is no evidence of appreciable levels of trifluralin measured in biota in the field under typical exposure conditions despite evidence of long range transport of trifluralin and its high volume of use in North America and other regions for the past 40 years. 3 2.2 Comments on the information provided by Canada on Bioaccumulation Comments regarding BCF and BAF values Within the technical Track A review process, all four reviewers, based on the indicative numerical values (BCF >5000 and log Kow = 5.27), concluded that trifluralin satisfies the LRTAP guidance for bioaccumulation. Bioaccumulation of trifluralin is evidenced by various studies for different species. With BCF values in the range 1580-8870 trifluralin is considered to be highly bioaccumulative as highlighted in the UNECE Risk Profile of Trifluralin, especially for fish [EC 2007]. The Canadian paper presents some additional information with respect to BAF values of zooplankton, oysters and fish indicating BCF and BAF values below the indicative numerical value. At first sight, the reported BCF and BCA values for different species seem to be in conflict. Nevertheless, it is well known, that the calculation of BCA values is influenced by various factors like species of the test animals, duration and intensity of exposition, way of exposure (solubilised or bound to sediment) water temperature and much more. Related aspects are also discussed in the following sections when considering depuration of trifluralin from different species and adsorption of trifluralin to sediment. Therefore it is not astonishing that there exists information about trifluralin bioconcentration factors well below the numerical indicative value of 5000 for several species. BCFs should be independent of the specific waterborne concentrations. This is not the case in several of the relevant studies, most likely due to the experimental conditions (for example reduced bioavailability at high concentrations). Low BCFs observed at relatively high exposure concentrations should be disregarded because they are irrelevant for assessing bioconcentration at much lower environmental concentrations as they may occur under realistic conditions. Accordingly, the results for BCFs shown in Table 1 indicate comparatively low BCFs at high exposure levels and vice versa. There are two GLP studies indicating BCF values above the numeric criterion 5000 (Graper and Rainey (1988): BCF 5674; Meyerhoff and Gunnoe (1992): BCF 1750 to 8870; see bold lines in Table 1). For the second study, only the value of 8870 obtained at the lowest tested concentration should be considered relevant. Table 1: Results of bioaccumulation studies with trifluralin in fish (quoted from [OSPAR 2005]). Species BCF whole fish Lepomis macrochirus 5674* Lepomis macrochirus 1580** Lepomis macrochirus 1087-1838* Pimephales promelas 1750-8870**¯ Test conditions 28 days uptake; FLO; 2μg/l trifluralin; GLP 35 days uptake; FLO; ~8 μg/l trifluralin; non-GLP*** 8 days; STA; 0,5-12,5 mg/kg trifluralin; non-GLP**** 35 days uptake; FLO; 0,3-30 μg/l trifluralin; GLP Clearance half-life ct₅₀ [d] Residues after 14d 4,6 < 10% 4,3 - 5,6 Not calculated Not calculated Source Year [EUTTF 2002] 1996 [EUTTF 2002] 1973 [EUTTF 2002] 1985 [EUTTF 2002] 1990 *calculated from the uptake rate constant. ** calculated from the ration of concentrations in fish and water. ***there are major deviations from the OECD Guideline 205E. therefore, this study is intended to provide supplementary information only. **** Sediment containing trifluralin was stirred into the test vessels. Concentrations refer to test substance in sediment wet weight. Dissolved trifluralin was detected at a maximum of 1,9 μg/l, declining to 0,6 μg/l. This nonstandard study is intended to provide supplementary information only. ¯ The low BCF of 1750 was obtained in the high concentration of trifluralin (30 μg/l) and the high BCF of 8870 was obtained in the low concentration of trifluralin (0,3 μg/l). STA: static test; FLO: flow-through test; GLP: test conducted under "Good Laboratory Practice". 4 The BCFs that have been determined in GLP studies (i.e. 5674 and 8870) are only slightly above the numeric value for the bioaccumulation criterion (5000). Considering also the rapid metabolism/elimination observed in different taxonomic groups, reported values below the criterion of 5000 can most likely be associated to the experimental conditions and/or physiological differences, particularly in the case of on non-fish species. Thus the conclusion should be that the numeric screening criterion of BCF >5000 is fulfilled. Comments regarding bioavailability The authors of the Canadian paper indicate some concerns regarding the highest BCF and BAF values for fish in the field reported by Graper and Rainey (1988) because the high potential of trifluralin to adsorb to the sediment was not considered in these studies. Such statement could be done for any of the listed POPs as all of them are highly hydrophobic and therefore are strongly absorbed to sediment and reduce the availability to be directly uptaken via the water phase. However, direct uptake by sediment or suspended matter should not be ignored for such hydrophobic compounds as shown for Trifluralin in [Francis and Cocke 1985]. Francis and Cocke (1985) examined the “Bioavailability of Sediment-sorbed Trifluralin to Bluegill Under Laboratory Conditions”. Mean sediment trifluralin concentrations following aging were 0.5, 2.40 and 11.59 mg/kg. Suspended sediment concentrations immediately after stirring were 0.0070-0.0084, 0.0390-0.0432 and 0.2207-0.2553 mg/L, respectively. At the highest level of sediment treatment and concentration of sediment in exposure water, dissolved trifluralin was detected at 1.9 µg/L declining to 0.6 µg/L by test termination. Trifluralin was detected in all groups of exposed fish at 0.001-1.606 µg/g above the background level in control fish (of 0.003 µg/g or less). Tissue levels increased with suspended sediment load and sediment trifluralin concentration. A model developed to describe the distribution of trifluralin between the three compartments of the study system used first-order kinetics for trifluralin uptake by fish and dissipation from the exposure solution, taking into account the effect of suspended sediment on these factors. The model provided good estimates of the residues measured in exposed fish. Estimated uptake and depuration rate constants were used to compute steady-state bioconcentration factors in the range 1087-1838 mL/g. It was concluded that Trifluralin was readily bioconcentrated (BCF 1087-1838 mL/g) in bluegill (Lepomis macrochirus) exposed for eight days to solutions containing 0.01-0.25 g/L of sediment treated with 0.5-12.5 mg trifluralin/kg. The results of this study clearly indicate that uptake of trifluralin bound to sediment by aquatic animals (especially animals which inhabit sediment) is likely to occur. The latter may result from oral uptake of sediment particles carrying trifluralin on their surface or by uptake of trifluralin dissolving from the sediment particles over the gills [EUTTF 2002]. Regarding the results of The National Lake Fish Tissue Study (US EPA 2009, see chapter on levels of trifluralin in biota) it should be highlighted that trifluralin occurred in the bottom-dweller samples of 32 % of the sites and predator samples of 10 % of the sites. Uptake of sediment particles and thus sediment bound trifluralin is much more likely to occur for bottom-dwellers than for predator fish. This may be the main reason for more frequent detection of trifluralin residues in bottom-dweller tissues. The differences in uptake between predator fish and bottom-dwellers clearly indicates that considerable uptake of sediment bound trifluralin occurs under environmental conditions. Therefore, it cannot be argued that most of the trifluralin released is bound to sediment and therefore not available for uptake by fish. Consequently it cannot be concluded that BCF values of trifluralin measured under laboratory conditions are generally disproportionately higher than respective BCF values determined from field data. Furthermore, it was criticized that the study of Spacie and Hamelink (1979) reporting a BAF value of 6000 was conducted downstream of a manufacturing plant, which 5 might not be typical of exposure conditions compared with concentration and timing of exposure resulting from agriculture uses or in remote areas. Spacie and Hamelink (1979) when calculating the BCF values for the period before water treatment determined the average concentration of trifluralin in water to be 1.8 µg/L. Exposure concentrations in other field studies and laboratory studies listed in Annex A of the Canadian paper seem to be in a comparable range (e.g. 5.9 µg/L Graper and Rainey (1988), 20 µg/L Slieght (1973), 2 µg/L Schultz and Hayton (1994)). The Canadian authors point out that the BCF values determined for larger species (e.g. sauger) in the study of Spacie and Hamelink (1979) were not reflective for steady state conditions because the fish burdens were not yet at equibrilium. However, Spacie and Hamelink (1979) used the measured residues in fish and water to calculate a concentration ratio K defined as residue concentration in mg/kg of body weight devided by concentration in water (mg/L). They note that under steady-state conditions, when the body residues are equilibrated with respect to uptake and clearance, this K ratio is equal to the bioconcentration factor (BCF). The derived BCF values for sauger, (5800) shorthead redhorse (2800) and golden redhorse (1800) were calculated from trifluralin concentrations measured before carbon treatment of waste water. At that time the fish had been exposed to trifluralin over a long period and concentration levels are well equilibrated with respect to uptake and clearance (i.e. steady state conditions) This is explicitly mentioned in the paper. (source [Spacie and Hamelink 1979]). Comments related to elimination of trifluralin Reported depuration half-life values for fish between 2 days to 57 days are reported in the Canadian document. Similar values are reported for existing POPs or POPs candidates (see table below). The Preliminary guidance paper on bioaccumulation evaluation, depuration half-life is not used to demonstrate the lack of bioaccumulation, but can be used, in case of long half-life, as an additional argument to confirm bioaccumulation potential of a substance in particular where BCF is below the cut-off value (UNEP/POPS/POPRC.3/20) 6 In a study of Han et al. (2007), values of intrinsic clearance (CLint) of seven reference compounds1 in hepatocytes freshly isolated from rainbow trout and rat were determined using a substrate depletion approach. Trifluralin was metabolised in rat hepatocytes with a CLint value of 2.15 ±0.56 mL/h/ 106 cells, whereas in trout hepatocytes, the clearance rate was estimated to be 0.027± 0.016 mL/h/106 cells. CLint for all compounds were 5.5-78.5-fold lower in trout hepatocytes than those in rat hepatocytes. Trifluralin was the substance with the lowest clearance rate in rainbow trout (78.5 fold lower compared to rat). This clearly indicates that even if the metabolism profile of trifluralin in terrestrial animals and fish may be comparable, the elimination rates are quite different [Han et al. 2007]. The results of Han et al. (2007) illustrate that the elimination rate of trifluralin in terrestrial animals might be significantly higher than in aquatic animals. Guerrero et al. (2002) performed acute static bioassays using the three freshwater invertebrate species (oligochaete Lumbriculus variegatus, fingernail clam Sphaerium corneum and the larvae Chironomus riparius). The organisms were exposed separately to 14C radiolabelled Trifluralin to investigate if trifluralin remained as parent compound after the treatments. Homogenates of the whole body tissue of each organism were prepared and total radioactivity was measured. Contaminants were then extracted into organic solvents and analysed by high-pressure liquid chromatography techniques. For S. corneum and C. riparius, the concentrations accumulated were quite similar (taken from the presented figures approximately 3nmol/g wet tissue). Instead Lumbriculus variegatus presented the highest levels of uptake for trifluralin analysed (taken from the presented figures approximately 12 nmol/g wet tissue). Since the soft tissues of clams, worms and midges were roughly the same weight, differences on uptake could not be attributed to 1 atrazine, molinate, 4,4-bis(dimethylamino)- benzophenone, 4-nonylphenol, 2,4-di-tert-butylphenol, trifluralin, benzo(a)pyrene 7 the size of the organisms. Chromatograms showed that most of the trifluralin extracted was present as parent compound in S. corneum and in L. variegatus. In contrast, for C. riparius the recovery of trifluralin as parent compound represented a 17.5% of the total radioactivity of the homogenate. The chromatograms showed the presence of two additional peaks [Guerrero et al. 2002]. These results suggest that different metabolic processes could take place in the different species resulting in different uptake and metabolism and bioaccumulation rates. Therefore, it is unlikely that trifluralin is metabolised and depurated equally effective by all aquatic organisms and as a consequence it cannot be concluded that bioaccumulation of trifluralin in aquatic biota is unlikely to occur under natural conditions. If specific differences between aquatic organisms result in high levels of accumulation, these metabolic differences may result in biomagnification processes in their predators [Guerrero et al. 2002]. According to Kelly et al. (2007) poorly metabolisable, moderately hydrophobic substances (i.e., Kow between 100 and 100,000), which do not biomagnify in aquatic food webs, can biomagnify to a high degree in food webs containing air breathing animals (e.g., humans , marine mammals) if they have a high octanol-air partition coefficient and corresponding low rate of respiratory elimination to air. This is the case for trifluralin. Under the assumption, that no metabolic transformation occurred, calculated biomagnification factors for trifluralin for water respiring organisms are below 1 (for zooplankton, forage fish and predatory fish) whereas they range from 2.8 to 34 for air breathing organisms (reptile 6.2, amphibian 11, seabird 12, marine mammal 26, terrestrial herbivore 2.8, terrestrial carnivore 34, human 28) [Kelly et al. 2007]. These findings indicate that trifluralin has the potential to biomagnify in terrestrial food webs and in air breathing organisms of the marine mammalian food web. However, under environmental conditions, metabolic transformation needs to be taken into account and will be a key issue for assessing a realistic bioaccumulation potential of trifluralin. When discussing the bioavailability of trifluralin, the non-extractable residues (NER) formation in soil or sediment needs to be taken into account. An observed disappearance of a compound does not necessarily mean that the compound has been degraded. In an open system the compound may have been transferred to another compartment (e.g. from water to sediment). In a closed system non-extractable residues may have formed and the observed disappearance is a combined effect of NER formation and actual degradation. The formation of NERs can often be observed in biodegradation studies with soil or sediment. The NERs are defined as the fraction of the original test substance (and metabolites) that is not degraded and not recovered via exhaustive sequential extraction of the solid matrix. A relevant question is whether NERs are still bioavailable or may become again bioavailable. The two extreme viewpoints in this debate are (1) either, according to the precautionary principle, to consider all NERs bioavailable as long as scientific findings are inconclusive or (2) conversely, to consider all NERs not bioavailable( [Boething et al. 2009]). According to a recent water-sediment study for trifluralin the NERs amount to 77 % applied radioactivity (AR) associated with the humin fraction [EFSA 2009]. As a consequence, for substances such as trifluralin with a high rate of NERs formation, low levels of the compound detected in the environment do not allow to simply conclude on low bioavailability of the compound (see also chapter 4). Monitoring data in biota and mammals The National Lake Fish Tissue Study is the first national freshwater fish tissue survey to be based on a probabilistic sampling design, and it includes data on the largest set of PBT chemicals ever studied in fish. 8 EPA worked with partner agencies in states, tribes, and other federal organizations over a four-year period (2000–2003) to collect fish from 500 lakes and reservoirs in the conterminous USA. The information provided in the report documents the national distribution of 268 PBT chemicals in predator fish species (e.g., bass and trout) and in bottom-dwelling fish species (e.g., carp and catfish) from lakes and reservoirs in the USA. Trifluralin occurred in the bottom-dweller samples of 32 % of the sites and predator samples of 10 % of the sites. Table 2: Results from the National Lake Fish Tissue Study. MDL: method detection limit; ML: minimum level [U.S. EPA 2009]. Tissue Concentration Estimates for Predators (Fillets) ppb < MDL < MDL < MDL < MDL < MDL < MDL 95 th Percentile 11 90 th Percentile 36 75 th Percentile 486 50 th Percentile Units 25 th Percentile Maximum Conc. 10 th Percentile Number of Detects 5 th Percentile Number of Samples 3.16 < MDL < MDL 3.76 7.26 13.88 Tissue Concentration Estimates for Bottom Dweller (Whole Bodies) 395 144 96 ppb < MDL < MDL Results for Predators MDL μg/kg (ppb) ML μg/kg (ppb) < MDL ≥ MDL & < ML ≥ ML Total 2.98 10.0 450 35 1 486 10.0 251 84 60 395 Results for Bottom Dweller 2.98 A field monitoring study on fish was cited in the draft assessment report on trifluralin. The study was designed to measure trifluralin residues in fish and benthic invertebrates, to perform radiological examinations on fish and to monitor the concentrations of trifluralin in water, sediment and field run-off. The results of the study demonstrated that trifluralin can accumulate to detectable levels in fish inhabiting ponds that receive run-off from fields treated with trifluralin. Furthermore, the data from the study confirmed that actual residue levels, although typically increasing after run-off events, are low under environmental conditions. The maximum whole body residue level measured in fish during the entire study was 0.290 µg/g, which is approximately one order of magnitude lower than the residues found in fish continuously exposed to the chronic NOEC of 0.3 g/L for 35 days [Francis et al. 1985]. The authors of the Canadian comments highlight that the Trifluralin Dossier [EC 2007] indicated that trifluralin does not appear to have been detected in human tissue, breast milk or blood despite evidence of long range transport and high volume use in North America for over 40 years. Barr et al., 2010 evaluated in utero exposures to pesticides by measuring maternal and cord serum biomarkers in a New Jersey cohort of pregnant women and the birth outcomes of their neonates. The study was based on 150 women that underwent an elective cesarean delivery at term in a hospital in central New Jersey. The frequencies of detection of trifluralin were 68 % in maternal serum and 25 % in cord serum samples. The agreement between maternal and cord sera detection was significant for trifluralin (p<0.001). Generally, if a pesticide was detected in maternal serum, it was also found in the corresponding cord serum indicating transfer of some portion of the maternal dose to the fetus. Mean maternal serum concentrations are summarized in Table 3 [Barr et al. 2010]. The results of this study indicate that uptake of trifluralin to humans occurs due to 9 environmental exposure and contact with pesticide residues whether from dietary, non-dietary ingestion, residential, or occupational pathways . Therefore, the lack of data regarding trifluralin residues in human tissues and blood may not simply result from the absence of detects as supposed by the Canadian authors. In fact, there exists an information gap regarding monitoring data of trifluralin in humans and biota from use areas and remote areas. Table 3: Mean maternal serum concentrations of trifluralin in a population of pregnant women and newborns in New Jersey (source [Barr et al. 2010]) Number of samples with detectable pesticide level Mean (SD) (ng/g) Minimum / maximum Maternal serum 138 0.75 (1.37) 0.00 / 8.50 Cord serum 148 2.16 (1.54) 0.007 / 4.42 Sample It can be concluded that information on appreciable levels in fish and humans is available. However, the information is very limited. Conclusion on bioaccumulation The numerical criterion for bioaccumulation according to BCF values can be considered fulfilled. However, the assessment of the potential for bioaccumulation under environment conditions is related to specific knowledge gaps. It is difficult to simulate realistic environmental conditions in laboratory studies and to investigate the uptake of sediment associated trifluralin. However, also laboratory studies provide indications that trifluralin adsorbed to sediment is available for uptake by aquatic organisms (e.g. Francis and Cocke (1985)). The potential for bioaccumulation under environment conditions depends largely on the elimination rates in biota and the environment. Even if the metabolism profile of trifluralin in terrestrial animals and fish may be comparable, the elimination rates are quite different [Han et al. 2007]. The elimination rate of trifluralin in terrestrial animals might be significantly higher than in aquatic animals. Furthermore, it is unlikely that trifluralin is metabolised and depurated equally effective by all aquatic organisms (see [Guerrero et al. 2002]). Trifluralin has in theory the potential to biomagnify in terrestrial food webs and in air breathing organisms of the marine mammalian food web. BCF values for fish are inappropriate indicators for the biomagnification potential in air breathing animals. The bioaccumulation potential depends largely on the species dependent elimination rates. Available data indicate that trifluralin can accumulate to detectable levels in fish and benthic invertebrates [Francis et al. 1985] and is stronger accumulated by sediment living aquatic organisms than by organisms living in the water body (see [U.S. EPA 2009]. Information on elimination rates indicates that the elimination rate of trifluralin in terrestrial animals might be significantly higher than in aquatic animals. The formation of NERs should also be considered when studying elimination rates of trifluralin. 2.3 Summary of the information provided by Canada on criterion 2b The Canadian authors highlight that based on the existing data, it does appear that there is transport to 10 remote areas, likely primarily via adsorption to particles. Furthermore, it is stated that once in a remote location, it seems unlikely that such adsorbed material is readily bioavailable. When entering the aquatic environment, trifluralin will migrate quickly from water and adsorbs strongly to sediment thereby reducing the availability for uptake. Toxicity endpoints are significantly higher (i.e. less toxic) and bioconcentration factors are significantly lower in systems including sediment bound residues versus those systems with continual influx of trifluralin residues in the water column. This, coupled with the known high rate of elimination, suggests that the lack of trifluralin (both detections and low concentrations) in biota is likely related to chemical dynamics and exposure metrics. 2.4 Comments on the information provided by Canada on criterion 2b As outlined above, sediment associated trifluralin may be readily bioavailable and information on elimination rates of trifluralin indicates high species dependency. Monitoring data on levels of trifluralin in relevant species and humans are limited for remote areas. Such information could enable to assess possible adverse effects due to long range transport of trifluralin. 11 3 Additional information on environmental occurrence/monitoring Arctic Trifluralin has been measured in air at three Arctic monitoring stations (Tagish: 2.92 pg/m3, Alert: 0.64 pg/m3, Dunai: 0.13 pg/m3). According to half-life calculations based on photochemical degradation, detectable quantities of trifluralin should not reach the Arctic at measurable quantities even though relatively large amounts (>5 x 106 kg) are applied annually to crops in western Canada and the USA. Other pathways (transport on dry particulate or aerosol) might be probable transport forms (quoted from [EC 2007]). Trifluralin was sporadically found in samples from Nuuk collected in winter and autumn with an annual average concentration of 0.24 ± 0.22 pg/m3. Further information is listed in Table 1. [AMAP 2005] Table 4: Annual mean, median, minimum and maximum concentrations values of trifluralin [pg/m³] in Nuuk. The d/n column indicates number of detected concentrations. [AMAP 2005] Substance d/n Mean Median Min Max Trifluralin 4/13 0.2 0.2 0.0 0.6 Literature on current use pesticides (CUPs) in arctic media has been reviewed from 2000 to 2007 by Hoferkamp et al. (2009). The following summary is quoted from their review. Welch et al. (1991) reported trifluralin in snow from the Canadian arctic. The snow was associated with a “brown snow” event whose clay mineral composition, soot particles, and visible organic remains point to an Asian source, probably western China. Melted snow samples were found to contain trifluralin at 0.660 ng/L [Welch et al. 1991]. Methoxychlor and trifluralin were detected in air sampled at stations in the Canadian Arctic (Halsall et al., 1998; Hung et al., 2002) while trifluralin, chlorpyrifos and chlorothalonil were identified in surface water, ice and fog samples from the Bering and Chukchi Seas (Chernyak et al., 1996). Studies of Arctic air masses sampled at stations in the Canadian, Alaskan, Russian and Norwegian Arctic between 2000 and 2003 included direct measurements of the CUPs methoxychlor and trifluralin (Su et al., 2008). Positive results for air concentrations of these CUPs were noted but the levels were below analytical detection limits and thus values not specified. In an earlier report Hung et al. (2005) reported annual average levels of trifluralin in air approaching the practical quantitation limit (PQL); 0.13–0.18 pg/m3 at Tagish, 0.1–0.05 pg/m3 at Kinngait and 0.18–0.16 pg/m3 at Dunai. Muir et al. (2007) analyzed large volume water samples from Lake Hazen in northern Ellesmere Island and from Char Lake on Cornwallis Island, collected in 2005 and 2006. Trifluralin was among the CUPs detected in all samples at low pg/L concentrations. Evenset et al. (2004) report finding trifluralin and lindane residues in sediments, collected in 1996 from two lake sites on Bjornoya Island in the Barents Sea. Lake sediments showed levels of trifluralin that were at the PQL (0.04 ng/g dw). Evenset et al. (2004) report finding trifluralin and lindane in zooplankton and Arctic Char collected in 1996 from two lake sites on Bjornoya Island in the Barents Sea. However, trifluralin was below the limit of quantification and actual concentrations were not reported. In the opinion of Hoferkamp et al., the question whether the presence of current use pesticides at low levels in arctic ecosystems has any significance biologically or results in risks for human consumers is a question that has not been adequately addressed. In their conclusion they point out that UNECE dossiers for the pesticides trifluralin, PCP and dicofol have not addressed this issue for human or wildlife exposure in remote environments generally(source [Hoferkamp et al. 2009]). 12 Bossi et al. (2008) report atmospheric concentrations of trifluralin in arctic air. Sampling was carried out in Nuuk during 2004 and 2005. The annual average concentration of trifluralin in Nuuk was 0.09 to 0.19 pgm3. Trifluralin was only detected in samples collected in winter and autumn. Model calculations were performed in order to correlate temperature and anthropogenic CO to atmospheric concentrations. The model calculations showed that the predominant anthropogenic sources for CO in Nuuk are located in North America. The results showed a clear correlation with CO for trifluralin, indicating an anthropogenic origin of trifluralin from current use [Bossi et al. 2008]. Marine waters A few trifluralin findings in the North Sea (0.002-0.02 ng/l) and the Baltic Sea (0.0-0.06 ng/l) have been reported by the German Marine Environmental Database (Meeres-Umweltdatenbank, MUDAB) between 1997 and 1999. Details on sampling locations and analytical methods are presently not available. The reported values are below the limit of detection reported for findings in freshwater. Data from marine sediment is not available [Hillenbrandt et al. 2006]. The German Bundesamt für Seeschifffahrt und Hydrographie (BSH) reported that trifluralin concentrations in North Sea water (area of the German Bight and the Elbe-Estuary) as well as water from the German Baltic Coast did not exceed the detection limit (< 0.03 ng/l and < 0.005 ng/l, respectively) between 1999 and 2002. [OSPAR, 2005] Chernyak et al. (1996) discovered trifluralin concentrations of about 1150 pg/l (detection limit 10 pg/l) in the water surface microlayer in the Bering and the Chukchi Seas (North Pacific) in 1993, which may arise from marine fog since trifluralin has been found therein. Concentrations of trifluralin in samples of subsurface water and ice were below the detection limit (0.5 and 2 pg/l, respectively).. Europe The European Commission focused on the prioritisation of substances potentially hazardous for the aquatic environment (Water Framework Directive 2000/60/EC) and therefore applied a combined monitoring and modeling based setting (COMMPS) working with monitoring data collected from different rivers in Europe. (http://europa.eu.int/comm/environment/water/water-dangersub/commps_report.pdf). Trifluralin was detected in 819 from 12,800 surface water samples at 752 sampling stations from Austria, Belgium, France, Germany, UK and Italy. Many measurements resulted in findings below the determination limit (0.005-0.2 μg/l), but positive findings of trifluralin and according to COMMPS trifluralin is to be expected due to regular uses (90th percentile concentration: 0.0306 μg/l). Means for trifluralin are in the range of the German quality standard for trifluralin in surface waters with respect to aquatic biocoenoses (0.03 μg/l). The 90-percentile value of 0.0306 μg/l is lower than the drinking water threshold concentration for individual plant protection products (0.1 μg/l) [OSPAR, 2005]. According to the shared database of Länderarbeitsgemeinschaft Wasser (LAWA) and the German Federal Environmental Agency [UBA 2005] water samples of German flowing waters were analysed for trifluralin in 187 series of measurements between 2002 and 2004. Within 30 test series the mean value measured was < 0.05 μg/l, 5 test series had a mean value < 0.06 μg/l and 15 test series had a mean value < 0.1 μg/l. Another survey focusing on occurrence of trifluralin in surface water, drinking water and other water as well as ground water sources was undertaken by Dow AgroSciences in EU 15 including Norway and Switzerland. Tables 4 and 5 give an overview on the results of the monitoring data (source: [OSPAR 2005]). 13 Table 5: Summary of trifluralin monitoring data in surface water, drinking water and others (unpublished survey report by producer Dow AgroSciences). Notes: LoD: limit of detection (LoDtm: limit of determination), ©: Data ex COMMPS database, *: Where there was a risk of multiple reference (e.g. COMMPS and national data) sites or samples have not been added in the total count, i.e. the total sample number represents the minimum number, **: 95th percentile; ***: One value at 8.3 mg/l (must be due to isolated pollution incident), n.d.: no data available. (source: [OSPAR 2005]) Country Surface water Austria © Belgium Belgium © France Date No. sites No. Samples Detected (samples) Samples >0.1 µg/l No. % No. % 0 87 12 sites 21 1 5 sites 0 0 1 7 >6.8 16.4 0.3 >3 0.1 0 1 0 n.d. n.d. >1 0 0 0 0.08 -- 3.2 0.070.3 0.03 0.04 0.06 Max LoD (LoDtm) µg/l Cat I I I I III I I II I 0.05 0.36 0.036 n.d. 0.045 n.d. n.d. n.d. (0.02) n.d. 0.03-0.05 <0.1n.d. 0.01-0.1 (0.005-0.2) n.d. 0.005 0.05 0.05-0.1 0.01 n.d. 0.002** 0.27*** 0.005 0.0050.7 0.22 n.d. 0.005-0.01 0.005-1.0 0.005-0.08 0.005-0.2 0.005-0.05 0.005-0.2 (0.005-0.2) n.d. II II I I I I I-III 0.01-0.1 (0.01-0.1) 0.02 0.002 0.01 0.002-0.01 (0.01-0.1) I µg/l 1998 96-99 1997 1996 1997 1996 1992 91-93 93-94 2 n.d. 33 n.d. 38 37 n.d. 5 44 6 1281 177 128 304 165 n.d. 147 936 1996 92-93 1997 95-97 91-92 92-94 9 7 2 12 3 n.d. 122 63 2 150 56 n.d. 1 6 0 0 4 n.d. 0.8 9.5 7.1 - 0 2 0 0 0 n.d. 1995 1999 92-95 1996 1997 1998 91-99 n.d. 729 7 5 5 7 870 3264 4888 >19 72 68 104 11651 98 214 0 1 0 0 437 3 4.4 1.4 3.8 1 2 0 0 0 0 7 96-98 83 472 18 sites >3.8 (22% sites) 1-5 sites 0.2-1 (1-6% sites) Drinking water Germany 93-94 166 1092 0 - 0 - - Ireland Netherlands UK Total* 95-96 1992 94-96 92-96 50 7 59 282 50 7 5228 6377 0 0 1 1 0.02 0.02 0 0 1 1 0.02 0.02 >0.1 >0.1 42 255 3 1.3 0 - 0.01 0.0005 II 4682 30575 449 1.5 9 0.03 0.7*** 0.0005-0.2 (0.005-0.2) I-III France © Germany Germany © Greece Italy © Switzerland UK River Rhine (CH D NL) Total* EU-COMMPS (A B D F I) Unspecified waters Greece 95-97 All water types Total* 90-99 14 >0.6 - 0.7 0.09 n.d. n.d. 0.22 0.05 I I I III III II I I II III I-III Table 6: Summary of trifluralin monitoring data in ground water (unpublished survey report by producer Dow AgroSciences). Note: LoD: limit of detection (LoDtm: limit of determination), *: determination of the limit of detection is uncertain, **: where there was a risk of multiple reference (e.g. COMMPS and national data) sites or samples have not been added in the total count, i.e. the total sample number represents the minimum number. (source: [OSPAR 2005]) Country Date No. sites No. samples Austria 92-97 7000 No. 1 % 0.01 1997 90-93 9394 170580 56 20 344 2 336 100 2114 1 0 0 0.3 - ? 0 0 1997 1996 1992 1999 90-99 146 >1 7 334 3 488 2146 72 7 517 >12292 0 0 0 6 8 1.2 <0.06 0 0 0 0 1 France Germany Switzerland Netherlands UK Total** Detected (samples) Samples >0.1 µg/l No. % 1 0.01 Max. LoD (LoDtm) Cat. µg/l >0.1 µg/l 0.1 II - >0.02 - <0.008 0.1 >0.1 (0.02) 0.1 * 0.01-0.1 (0.01-0.1) <0.1 * 0.01 0.002 0.005-0.01 0.002-0.1 (0.01-0.1) III II I II I I II I-III For Table 5 and Table 6 the monitoring report describes the categories as follows: Category III: Reliable data (i.e. analytical method with specific detection and including analytical quality control). Category II: Moderately reliable data (e.g. adequate analytical methods but no information on analytical quality control, or insufficient information to assign to Category III). Category I: Reliability uncertain (e.g. screening only with semi-quantitative method, such as immunoassay based techniques) or inadequate information to determine reliability of data, or data compiled from various sources with little information concerning the reliability of the data. Trifluralin concentrations in surface water were in the range 0.2-0.7 μg/l for Belgium, France, Greece and UK. A large number of negative findings have been reported from, Switzerland, Austria, Italy and the International Rhine Commission [OSPAR, 2005]. One case of non-compliance with the drinking water standard of 0.1 μg/l has been reported for UK in 1994. One case was reported from Germany, where remedial measures were implemented at one site for the abstraction of drinking water from surface water, although the trifluralin concentration (0.05 μg/l) was below the drinking water limit at this site. These findings relate to a large amount of data from Germany, Ireland and the UK, and a small number of samples from the Netherlands [OSPAR, 2005]. Occurrence of trifluralin in ground water is reported to be rare (Table 5). Only few samples of over 12000 from almost 3500 sites analysed contained detectable amounts of trifluralin (Austria (1 of 7000 samples, 1992-1997), France (1 of 336 samples, 1997), UK (6 of 517 samples, 1999)). The highest concentration reported was 0.1 μg/l (one report from Austria) [OSPAR, 2005]. Trifluralin has also been found in sediments in France and Great Britain. France reported 2450 individual measurements of trifluralin in sediment. However, all but four of these measurements were below the determination limit (5-100 μg/kg). In three cases the limit of quantification was given to 1000 μg/kg. Four measurements were quantified with 66, 95, 156 and 220 μg/kg [OSPAR 2005]. According to reviewed monitoring data from the EU, Switzerland and Norway, trifluralin occurrence in ground water is rare. Trifluralin was more frequently found in surface waters with maximum concentrations between 0.2 μg/l and 0.7 μg/l. In the countries where trifluralin is found in surface waters, positive samples 15 range between 4 % and 16.4 % of the analysed samples, but only a maximum of 3.2 % of the samples were above 0.1 μg/l. (quoted from [EFSA 2009]). USA In the USA, trifluralin was found in 172 of 2047 surface water samples and one of 507 ground water samples analysed. The 85th percentile of the levels in all non-zero surface water samples was 0.54 μg/L [WHO 2003]. It can be concluded that new monitoring data on environmental occurrence for trifluralin are scarce. Therefore, the most relevant information, which partly is already known from the EC Trifluralin Risk Profile and the OSPAR report on trifluralin, was summarised. New data provided from AMAP is also indicated and new field studies carried out in the United States have been incorporated. The information evidence the long-range transport of trifluralin and further shows its occurrence in biota. 16 4 Transformation products of trifluralin Several transformation products of trifluralin have been identified in soil, water and sediment tests. According to the laboratory and field studies to the major metabolites of trifluralin belong TR-42, TR-63, TR144 and TR-155. Further, numerous minor transformations products of trifluralin were detected. In the following more detailed information is given for possible transformation and degradation of the substance under different environmental conditions. Nevertheless, respective laboratory and field studies should be considered for precise description of the complex transformation processes. SOIL Trifluralin was steadily degraded in soil under aerobic conditions. No major metabolites are formed. Only some minor metabolites are formed by oxidative dealkylation of N-propyl, reduction of nitro groups with cyclation and dimerization to form azoxy-benzene compounds [EFSA 2009]. European and US field studies showed that the substance dissipates slowly in soil. Slower dissipitation was also observed in colder climates [EC 2007]. It can be concluded that trifluralin is persistent in soil. In soil, no major metabolites were observed so far. Under anaerobic conditions in soil, the degradation of trifluralin is more extensive. One major metabolite, TR-4; is formed. Under flooded anaerobic conditions TR-4 has a maximum of 13.2% applied radioactivity (AR) after 60 days. Also TR-7, TR-14 and TR-16 may be attributed to anaerobic conditions [EC 2007]. These were formed by sequential reduction of the nitro groups on the parent molecule (TR-4 and TR-7) or by oxidative dealkylation of the N-propyl group on an aerobic metabolite (TR-13) followed by reduction of the nitro group (TR-14). Latter was formed at above 5% at the end of a study cited by EFSA 2009. TR-14 had a maximum of 8.3% AR after 60 days. Under anaerobic conditions the levels of evolved volatile components were less significant than under aerobic conditions (quoted from [EC 2007]. On the environment expert meeting, it was not possible to exclude the relevance of anerobic conditions for the representative uses. Further, it was concluded that, based on the molecular structure, TR-4 would be degraded under aerobic conditions. As the levels found for TR-14 are lower than for TR-4 and that it is expected to follow a degradation route analogue to other aerobic metabolites, the same conclusion reached for metabolite TR-4 is applicable to TR-14 [EFSA 2009]. According to the soil photolysis study indicated by EFSA 2009, photolysis is not expected to be a significant degration route of trifluralin. No major photolysis products were identified in the environment. A batch adsorption/desorption study in four soils is available for trifluralin. The data indicate that trifluralin is strongly adsorbed to soil (KFoc = 6414 – 13414 mL/g) and may be classified as immobile. For the anaerobic metabolite TR-4 a Koc = 13600 mL/g was estimated, using the “pckocwin v.1.66 (EPA)” program, indicating also low mobility potential for this metabolite. The PRAPeR TC 10 meeting of experts discussed the acceptability of the Koc value estimated for metabolite TR-4. The experts agreed that the value may be considered reasonable when used together with a 1/n = 1 to model the EU representative uses. However, if an assessment at national level indicates that the exposure approaches a groundwater trigger or surface water tier 1 risk assessment trigger, then measured data on adsorption could be needed to assess uses 2 TR-4: 3-nitro-N2,N2-dipropyl-5-(trifluoromethyl)benzene-1,2-diamine TR-6: 3-nitro-5-(trifluoromethyl)benzene-1,2-diamine 4 TR-14: 2-ethyl-1-propyl-5-(trifluoromethyl)-1H-benzimidazol-7-amine 5 TR-15: 2-ethyl-7-nitro-5-(trifluoromethyl)-1H-benzimidazole 3 17 where anaerobic soil conditions cannot be excluded. Two aged residue column leaching studies with a total of three experiments are available (quoted from [EFSA 2009]). Amounts between 0.42 to 2.54 % AR are found in the leachate. However, this radioactivity may not be attributed to the parent compound and was not further identified. More data on the leaching potential of metabolite TR-4 was initially requested by the rapporteur Member State in the Draft Assessment Report pending decision on its relevance. According to the conclusions of the fate and behaviour in the environment EPCO expert meeting no further data for this metabolite are necessary to finalise the assessment made in the context of Annex I inclusion. (quoted from [EFSA 2009]) Trifluralin degrades with a reported half-life of 41 days when exposed to a light source on sandy loam soil. The half-life of dark control samples of trifluralin was reported to be 66 days. Two degradation products, 2,6dinitro-N-propyl-4-trifluoromethylbenzenamine and 2-ethyl-7-nitro-5-trifluoromethylbenzimidazole-3-oxide were identified in the light-exposed samples (US EPA, 1996 quoted from [EC 2007]). AIR Because of its high volatility (vapour pressure= 9.5 x 10-3 Pa (25 °C) and Henry's law constant = 10.2 Pa m3 mol-1 at 20°C), trifluralin may occur in air and may be transported through air. However, the photochemical oxidative degradation half-life of trifluralin in air is rapid (5.3 hours or 0.22 days) estimated with SAR method (Atkinson). Hence, the calculated value is under the trigger of 2 days established to represent a concern for a potential long-range transport by the Stockholm Convention ([EFSA 2009]; [EC 2007]). No further information on volatilization and potential long-range transport of trifluralin is available [EFSA 2009]. WATER AND WATER SEDIMENT SYSTEMS Trifluralin is hydrolytically stable in sterile aqueous buffers between pH 3 and pH 9 at 52°C with an extrapolated half-life above one year at 20°C. Aqueous photolysis may contribute to the environmental degradation of trifluralin (DT₅₀ irr. = 7 h vs. DT₅₀dark = 480 h). Aqueous photolysis is enhanced in natural water (DT₅₀ = 1.1 h) [EFSA 2009]. Photodegradation of trifluralin led to the formation of the major photoproducts TR-6 (maximum of 50.4 % AR at the end of the study after 48.5 hours continuous irradiation) and TR-15 (maximum of 31.5 % AR at the end of the study after 48.5 hours continuous irradiation). Initial PECsw values have been calculated based on the maximum amounts observed in the photolysis study and it could be concluded that trifluralin is not readily biodegradable [EFSA 2009]. Trifluralin dissipated from the system mainly by volatilization. Dissipation half-life of trifluralin in the whole system was 4.9- 5.9 days. Half-life for trifluralin in the water phase was estimated to be 13 days based on the worst case system (sandy loam) [EFSA 2009]. Another water sediment system where trifluralin was applied to the sediment showed TR-4 as the major metabolite (max 16 % after 28 days). The substance was identified in the sediment phase. The water phase was not analysed in this system since radioactivity was below 10 % AR in all samples [EFSA 2009]. Another two water sediment systems were studied where the test substance was applied to the sediment. Three major metabolites were found in the sediment: TR-4 (maximum of 27 % AR after 7 days), TR-76 (maximum of 14.2 % AR after 33 days) and TR-14 (maximum of 29.5 % after 54 days). Non-identified 6 TR-7: N2,N2-dipropyl-5-(trifluoromethyl)benzene-1,2,3-triamine 18 compounds (up to 23 % AR) were shown to be the sum of multiple peaks of minor components. Nonextractable residues (NERs) grow up to a maximum of 77 % AR and are associated with the humin fraction. No volatiles were observed in this study. Dissipation half-lives in the water phase in these systems are one and two days based on the only three data points (0 – 3 days) where trifluralin was observed in the aqueous phase [EFSA 2009]. The calculated concentration (estimation with FOCUS PELMO 1.1.1.) for TR-4 in ground water for both compounds was negligible in all scenarios. The results confirmed that 80th percentile annual average concentration over the 20 years simulation period is expected to be below the regulatory limit of 0.1 ìg/L. Reliable calculations with a second model are not available [EFSA 2009]. Conclusion on transformation products Several transformation products of trifluralin have raised attention in the soil, water and sediment tests. According to the laboratory studies and field studies, cited in EFSA 2009, UNECE 2007, OSPAR 2005 and EUTTF 2002, the following conclusions can be made: Under aerobic conditions, degradation from trifluralin in soil did not lead to any major transformation products. However, a number of minor metabolites could be identified. Under anaerobic conditions, the formation of the major metabolite TR-4 and in a lesser extent TR-14 was found. It was concluded that based on its molecular structure, TR-4 would be degraded under aerobic conditions. However, the ecotoxicology should be examined in further studies for specific environmental conditions. TR-14 levels are lower than for TR-4. Under aerobic conditions it is expected that the degradation route of TR-14 is analogous to the one of TR-4. Therefore, the same conclusion for metabolite is as well applicable to metabolite TR-14. TR-4 was a major metabolite in one of the water sediment systems (up to 27% AR). In a new water sediment study where the test substance was applied to the sediment, three metabolites of trifluralin were identified in the sediment: TR-4, TR-7 and TR-14. NERs grow up to a maximum of 77 % AR. However, considering the identified and non-identified compounds it seems clear that significant degradation occurs. It is debatable to which degree the NERs should be considered as degradation and/or to which degree the NERs may be or may become bioavailable trifluralin. At the end of the studies in soil and in water sediment systems low levels of TR-4 were observed at the end of the studies which might indicate a further degradation of TR-4. According to the soil photolysis study, it is not expected that the degradation route of trifluralin in the environment and that no major photolysis products were found. With regard to surface water analyses the following can be concluded: In the water compartment of water sediment studies no major metabolites were found. The two major photoproducts TR-6 and TR-15 were identified in the photolysis study. The provided results from the modeling of the anaerobic metabolite TR-4 with FOCUS PEARL showed that the annual average leachate concentration is expected to be below the regulatory limit. Thus, the 19 contamination of the ground water with trifluralin and its degradation products is considered to be not probable. No metabolites could be identified in air studies. The photochemical half-life in air, calculated with SAR method, was 5.3 hours. This value is under the trigger established to represent a concern for potential LRT set by the Stockholm Convention. The PBT criteria of the examined trifluralin metabolites have been partly explored: The effects of TR-4 were tested on larvae of midge Chrionomus riparius sediment water exposure system (NOEC 0.332mg a.s./L nominal), earthworms (NOEC (14d) 100 mg a.s./kg dry soil nominal) and soil microflora activity (<25% deviation from values after 29 days up to 2 mg a.s./kg dry soil). In relation to the corresponding PEC-values for sediment and soil, toxicity exposure ratios (TERs) exceeded the trigger values by far, indicating that there is no unacceptable risk by this metabolite (quoted from [OSPAR 2005]). Ecotoxicity tests for TR-6 and TR-15, major metabolites from photolysis in aqueous sterile buffer, were performed. The results in algae, daphnids and fish (EC₅₀/LC₅₀ values of 1-5mg/l) showed that these transformation products are less toxic than the parent compound trifluralin. Table 7: Overview of parent and all relevant metabolites requiring further assessment from the fate section [EFSA 2009] Compartment Soil Water Sediment Groundwater Trifluralin Trifluralin, TR-6, TR-15 Trifluralin, TR-4, TR-7, TR-14 Trifluralin It can be concluded that several major transformation products of trifluralin have been identified, especially in soil. 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