Incident Report

Subform I: General Information

1. Report Type.

New incident report

Incident Report Number: 2013-5390

2. Registrant Information.

Registrant Reference Number: 1 34978918

Registrant Name (Full Legal Name no abbreviations): Syngenta Canada Inc.

Address: 140 Research Lane, Research Park

City: Guelph

Prov / State: Ontario

Country: Canada

Postal Code: N1G4Z3

3. Select the appropriate subform(s) for the incident.

Environment

4. Date registrant was first informed of the incident.

19-JUL-13

5. Location of incident.

Country: CANADA

Prov / State: ONTARIO

6. Date incident was first observed.

10-JUL-13

Product Description

7. a) Provide the active ingredient and, if available, the registration number and product name (include all tank mixes). If the product is not registered provide a submission number.

Active(s)

---

PMRA Registration No. 15724      PMRA Submission No.       EPA Registration No.

Product Name: Daconil 2787 Flowable Fungicide

• Active Ingredient(s)
  • CHLOROTHALONIL

---

7. b) Type of formulation.

Application Information

8. Product was applied?

Yes

9. Application Rate.

Unknown

10. Site pesticide was applied to (select all that apply).

Site: Pub. Area - Outdoor/Zone publique - ext

11. Provide any additional information regarding application (how it was applied, amount applied, the size of the area treated etc).

To be determined by Registrant

12. In your opinion, was the product used according to the label instructions?

Unknown

Subform IV: Environment (includes plants insects and wildlife)

1. Type of organism affected

Fish - Schooling/Poisson-Vivant en banc

2. Common name(s)

Koi

3. Scientific name(s)

Cyprinus carpio

4. Number of organisms affected

250

5. Description of site where incident was observed

Fresh water

Pond

Terrestrial

Salt Water

6. Check all symptoms that apply

Death

7. Describe symptoms and outcome (died, recovered, etc.).

1-34978918 - The reporter, a registrant employee, indicated that numerous fish were exposed to a fungicide containing the active ingredient Chlorothalonil. The pond where the 250 koi were located was on a golf course and measured approximately 105ft x 45ft, was 8 feet deep in the center and had a fountain in the middle. The water for the pond was supplied by an on site irrigation pond that operated approximately 8 hours per day. The reporter indicated that on July 10, 2013 the fungicide was applied according to directions on the golf course, near the pond. A buffer zone of unknown dimensions was adhered to during application. About 6 hours after product application there was a heavy rainfall that dropped ambient temperatures 20C and deposited 2 inches of rain which due to the design of the landscape and the already saturated soil (there were moderate daily rain showers from 7- 4-7- 9) drained almost entirely into the small pond near the fairway. The following morning all 250 Koi that were in the pond were found floating dead on the pond surface. That same day 2 bass were introduced into the pond and by the morning of July 12th they were found dead. Environmental samples were collected on July 12th and analyzed by the University of (name) laboratory services on July 18th. Dissolved oxygen levels in the pond water were found to be 10.3 mg dL. Chlorothalonil levels were 42 ppb. Per the reporter the death of the Koi was consistent with asphyxiation secondary to a pond environment already depleted in available oxygen due to the environmental conditions in the weeks preceding the event along with a premature summer turnover of the water layers resulting in decreased dissolved oxygen throughout the water column. Per the reporter this sudden reduction of dissolved oxygen in the shallow depths, the area that is inhabited by the Koi, would quickly lead to fish asyphyxiation. The reporter indicated that the disruption of the water layers would have occurred secondary to the rapid draining of large amounts of cold rain water into the pond. The reporter thought that the following environmental conditions prior to the event contributed to the overall oxygen depletion of the pond Warm average daily temperatures (June 2 to July 9 the average daily temperature was 22C), an extended period of overcast days (It was overcast June 24 to July 9), high number of fish in the pond and availability of nutrients that could stimulate alga growth (The golf course was last fertilized on July 4th with 19-3- 19 ,lbs nitrogen). For the bass introduced to the pond on July 11th, the reporter indicated that several factors such as continued anoxic conditions, a higher sensitivity to Chlorothalonil compared to koi, or stress associated with introducing the fish to a new aquatic environment may have contributed to their death. No further information is available. Update May 8, 2022: Syngenta Canada Inc. (Syngenta) is submitting herein some additional information to supplement that original incident reporting submission under Ref. No. 2013-5390. Please find below aerial images (accessed via Google maps) of the subject pond, illustrating a vegetative filter strip of less than 10 m (~6.5 m in size). In terms of the general landscape, it is expected that the topography in vicinity of the pond was highly targeted to rapidly remove water from the playing surfaces of the golf course. The subject pond was previously a sand feature, converted to a pond providing very limited habitat and stocked with fish. Also note a correction to the information cited in the PMRA public registry under No. 2013-5390, stating dissolved oxygen levels in the pond water were found to be 10.3 mg dL. Dissolved oxygen measured in the subject pond was 10.3 mg/L.

8. a) Was the incident a result of (select all that apply)

Run-off

N/A

Unknown

8. b) i) How many times has the product been applied this year?

Unknown

8. b) ii) What was the date of the last application?

10-JUL-13

9. Did it rain

9. a) During application?

No

9. b) Up to 3 days after application?

Yes

10. a) Was there a buffer zone?

Yes

10. b) What type?

Terrestrial

10. c) What was the size of the buffer zone?

11. a) Were environmental samples collected and analysed?

Yes

To be determined by Registrant

12. Severity classification (if there is more than one possible classification, select the most severe)

Major

13. Please provide supplemental information here

Subform IV: Environment (includes plants insects and wildlife)

1. Type of organism affected

Fish-Non-schooling/Poisson-Autre poisson

2. Common name(s)

Bass

3. Scientific name(s)

Unknown

4. Number of organisms affected

2

5. Description of site where incident was observed

Fresh water

Pond

Terrestrial

Salt Water

6. Check all symptoms that apply

Death

7. Describe symptoms and outcome (died, recovered, etc.).

1-34978918 - The reporter, a registrant employee, indicated that numerous fish were exposed to a fungicide containing the active ingredient Chlorothalonil. The pond where the 250 koi were located was on a golf course and measured approximately 105ft x 45ft, was 8 feet deep in the center and had a fountain in the middle. The water for the pond was supplied by an on-site irrigation pond that operated approximately 8 hours per day. The reporter indicated that on July 10, 2013 the fungicide was applied according to directions on the golf course, near the pond. A buffer zone of unknown dimensions was adhered to during application. About 6 hours after product application there was a heavy rainfall that dropped ambient temperatures 20C and deposited 2 inches of rain which due to the design of the landscape and the already saturated soil (there were moderate daily rain showers from 7- 4-7- 9) drained almost entirely into the small pond near the fairway. The following morning all 250 Koi that were in the pond were found floating dead on the pond surface. That same day 2 bass were introduced into the pond and by the morning of July 12th they were found dead. Environmental samples were collected on July 12th and analyzed by the University of (name) laboratory services on July 18th. Dissolved oxygen levels in the pond water were found to be 10.3 mg dL. Chlorothalonil levels were 42 ppb. Per the reporter the death of the Koi was consistent with asphyxiation secondary to a pond environment already depleted in available oxygen due to the environmental conditions in the weeks preceding the event along with a premature summer turnover of the water layers resulting in decreased dissolved oxygen throughout the water column. Per the reporter this sudden reduction of dissolved oxygen in the shallow depths, the area that is inhabited by the Koi, would quickly lead to fish asyphyxiation. The reporter indicated that the disruption of the water layers would have occurred secondary to the rapid draining of large amounts of cold rain water into the pond. The reporter thought that the following environmental conditions prior to the event contributed to the overall oxygen depletion of the pond Warm average daily temperatures (June 2 to July 9 the average daily temperature was 22C), an extended period of overcast days (It was overcast June 24 to July 9), high number of fish in the pond and availability of nutrients that could stimulate alga growth (The golf course was last fertilized on July 4th with 19-3- 19 ,lbs nitrogen). For the bass introduced to the pond on July 11th, the reporter indicated that several factors such as continued anoxic conditions, a higher sensitivity to Chlorothalonil compared to koi, or stress associated with introducing the fish to a new aquatic environment may have contributed to their death. No further information is available. Update May 8, 2022: Syngenta Canada Inc. (Syngenta) is submitting herein some additional information to supplement that original incident reporting submission under Ref. No. 2013-5390. Please find below aerial images (accessed via Google maps) of the subject pond, illustrating a vegetative filter strip of less than 10 m (~6.5 m in size). In terms of the general landscape, it is expected that the topography in vicinity of the pond was highly targeted to rapidly remove water from the playing surfaces of the golf course. The subject pond was previously a sand feature, converted to a pond providing very limited habitat and stocked with fish. Also note a correction to the information cited in the PMRA public registry under No. 2013-5390, stating dissolved oxygen levels in the pond water were found to be 10.3 mg dL. Dissolved oxygen measured in the subject pond was 10.3 mg/L.

8. a) Was the incident a result of (select all that apply)

Run-off

N/A

Unknown

8. b) i) How many times has the product been applied this year?

Unknown

8. b) ii) What was the date of the last application?

10-JUL-13

9. Did it rain

9. a) During application?

No

9. b) Up to 3 days after application?

Yes

10. a) Was there a buffer zone?

Yes

10. b) What type?

Terrestrial

10. c) What was the size of the buffer zone?

11. a) Were environmental samples collected and analysed?

Yes

To be determined by Registrant

12. Severity classification (if there is more than one possible classification, select the most severe)

Minor

13. Please provide supplemental information here