United States        Prevention, Pesticides     EPA 738-R-95-006
         Environmental Protection    And Toxic Substances     April 1995
         Agency	(7508W)	
4>EPA  Re registration
         Eligibility Decision (RED)
         Metolachlor

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                 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                                      WASHINGTON, D.C. 20460
                                                                            OFFICE OF
                                                                      PREVENTION, PESTICIDES
                                                                      AND TOXIC SUBSTANCES
CERTIFIED MAIL
Dear Registrant:

       I am pleased to announce that the Environmental Protection Agency has completed its
reregistration eligibility review and decisions on the pesticide chemical case metolachlor which
includes the active ingredient metolachlor.  The enclosed Reregistration Eligibility Decision
(RED) contains the Agency's evaluation of the data base of these chemicals, its conclusions of
the potential human health and environmental risks of the current product uses, and its
decisions and conditions under which these uses and products will be eligible for
reregistration. The  RED includes the data and labeling requirements for products for
reregistration. It may also include requirements for additional  data (generic) on the active
ingredients to confirm the risk  assessments.

       To assist you with a proper response, read the enclosed document entitled "Summary
of Instructions for Responding to the RED."  This summary  also refers to other enclosed
documents which include further instructions.  You must follow all instructions and submit
complete and timely responses.  The first set of required responses are due 90 days from
receipt of this letter.  The second set of required responses are due 8 months  from the
date of this letter.  Complete and timely responses will avoid the Agency taking  the
enforcement action of suspension against your products.

       If you have questions on the product specific data requirements or wish to meet with
the Agency, please contact the  Special  Review and Reregistration Division representative
Veronica Dutch at (703) 308-8585.  Address any questions on required generic data to the
Special Review and Reregistration Division representative, Jane Mitchell at (703) 308-8061.

                                                      Sincerely yours,
                                                     Lois A. Rossi, Director
                                                       Special Review
                                                       and Reregistration Division
Enclosures

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              SUMMARY OF INSTRUCTIONS FOR RESPONDING TO
              THE REREGISTRATION ELIGIBILITY DECISION (RED)

1.  DATA CALL-IN (PCI) OR "90-DAY RESPONSE" If generic data are required for
reregistration, a DCI letter will be enclosed describing such data.  If product specific data
are required, another DCI letter will be enclosed listing such requirements.  If both generic
and product specific data are required, a combined Generic and Product Specific letter will
be enclosed describing such data.  Complete the two response forms provided with each DCI
letter (or four forms for the combined) by following the instructions provided. You must
submit the response forms for each product and for each DCI within 90 days of receipt of
this letter (RED issuance date); otherwise, your product may be suspended.

2.  TIME EXTENSIONS AND DATA WAIVER REQUESTS No time extension requests
will be granted for the 90-day response. Time extension requests may be submitted only with
respect to actual data submissions.  Requests for data waivers must be submitted  as part of the
90-day response. Requests  for time extensions should be submitted in the 90-day response,
but certainly no later than the 8-month response date. All data waiver and time extension
requests must be accompanied by a full justification. All waivers and time extensions must be
granted by EPA in order to go into effect.

3.  APPLICATION FOR REREGISTRATION OR "8-MONTH RESPONSE" You must
submit the following items for each product within eight months of the date  of this letter
(RED issuance date).

       a.  Application for Reregistration (EPA Form 8570-1). Use only an original
application form. Mark it "Application for Reregistration."  Send your Application for
Reregistration (along with the other forms listed in b-e below) to the address listed in item 5.

       b.  Five copies of draft labeling which complies with the RED and current regulations
and requirements.  Only make labeling changes which are required by the RED and current
regulations (40 CFR 156.10) and policies.  Submit any other amendments (such as formulation
changes, or labeling changes not related to reregistration) separately.  You may delete uses
which the RED says are ineligible for reregistration. For further labeling guidance,  refer to
the labeling section of the EPA publication " General Information on Applying for Registration
in  the U.S., Second Edition, August 1992" (available from the National Technical Information
Service, publication #PB92-221811; telephone number 703-487-4650).

       c.  Generic or Product Specific Data. Submit all data  in a format which complies
with PR Notice 86-5, and/or submit citations of data already submitted and give  the EPA
identifier (MRID) numbers.  Before citing these studies, you must make sure that they meet
the Agency's  acceptance criteria (attached to the DCI).

       d.  Two copies of the Confidential Statement of Formula (CSF) for each basic and
each alternate formulation.  The labeling and CSF which you submit for each product must
comply with P.R. Notice 91-2 by declaring the active ingredient as the nominal
concentration.  You have two options for submitting a CSF:  (1) accept the standard certified
limits (see 40  CFR §158.175) or (2) provide certified limits that are supported by the analysis
of five  batches.  If you choose the second option, you must submit or cite the data for the five
batches along  with a certification statement as described in 40 CFR §158.175(e).   A copy of
the CSF is enclosed; follow the instructions on its back.

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      e.  Certification With Respect to Data Compensation Requirements. Complete and
sign EPA form 8570-31 for each product.

4.  COMMENTS IN RESPONSE TO FEDERAL REGISTER NOTICE Comments
pertaining to the content of the RED may be submitted to the address shown in the Federal
Register Notice which announces the availability of this RED.

5.  WHERE TO SEND PRODUCT SPECIFIC PCI RESPONSES (90-DAY) AND
APPLICATIONS FOR REREGISTRATION (8-MONTH RESPONSES)

By U.S. Mail:

      Document Processing  Desk (RED-SRRD-PRB)
      Office of Pesticide Programs (7504C)
      EPA, 401 M St. S.W.
      Washington, D.C. 20460-0001

By express:

   Document Processing Desk (RED-SRRD-PRB)
      Office of Pesticide Programs (7504C)
      Room 266A, Crystal Mall 2
      1921 Jefferson Davis Hwy.
      Arlington, VA 22202

6.  EPA'S REVIEWS—EPA  will screen all submissions for completeness; those which are not
complete will be returned with a request for corrections.  EPA will try to respond to data
waiver and time extension requests within 60 days. EPA will also try to respond to all 8-
month submissions with a final reregistration determination within 14 months after the RED
has been issued.

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REREGISTRATION ELIGIBILITY DECISION

            METOLACHLOR

                LIST A

               CASE 0001
         ENVIRONMENTAL PROTECTION AGENCY
           OFFICE OF PESTICIDE PROGRAMS
       SPECIAL REVIEW AND REREGISTRATION DIVISION

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                         TABLE OF CONTENTS
METOLACHLOR REREGISTRATION ELIGIBILITY DECISION TEAM	i


      EXECUTIVE SUMMARY  	v

I.     INTRODUCTION	1

II.    CASE OVERVIEW	2
      A.    Chemical Overview  	2
      B.    Use Profile  	2
      C.    Estimated Usage of Pesticide  	4
      D.    Data Requirements	6
      E.    Regulatory History	6

III.   SCIENCE ASSESSMENT	7
      A.    Product Chemistry	7
            1.     Identification of the Active Ingredient 	7
            2.     Other Product Chemistry Considerations	8
      B.    Human Health Assessment	9
            1.     Toxicology Assessment	9
                  a.    Acute Toxicity    	9
                  b.    Subchronic Toxicity	9
                  c.    Chronic Toxicity	10
                  d.    Carcinogenicity	10
                  e.    Developmental Toxicity  	11
                  f.     Reproduction	11
                  g.    Mutagenicity   	11
                  h.    Metabolism  	12
                  i.     Reference Dose (RfD) for Chronic Oral Exposure	12
                 j.     Toxiocology Data Gaps	12
            2.     Exposure Assessment	12
                  a.    Dietary Exposure  	12
                       (1)    Residue Information and Background	12
                       (2)    Anticipated Residue Data  	14
                  b.    Occupational and Residential  	16
                       (1)    Use Summary	16
                       (2)    Summary of Toxicity Concerns Impacting
                              Occupational and Residential Exposure	17
                       (3)    Summary of Potential Occupational and Residential
                              Exposures	17
                       (4)    Handler (Mixers, Loaders, Applicators, Etc.)

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                              Exposures	17
                        (5)    Post Application Exposure to Workers  	19
            3.    Risk Assessment	19
                  a.    Dietary  	19
                  b.    Occupational and Residential  	20
      C.    Environmental Assessment	23
            1.    Environmental Fate  	23
                  a.    Environmental Chemistry, Fate and Transport  	23
                  b.    Environmental Fate Assessment	27
            2.    Ecological Effects	29
                  a.    Ecological Hazard	29
                        (1)    Non-Target Birds	29
                        (2)    Non-Target Freshwater Fish  	30
                        (3)    Non-Target Freshwater Invertebrates  	30
                        (4)    Non-Target Estuarine and Marine Organisms .... 31
                        (5)    Non-Target Plants  	31
                  b.    Ecological Effects Risk Assessment	32
                        (1)     Non-Endangered Species  	33
                        (2)    Endangered species  	39

IV.   RISK MANAGEMENT AND REREGISTRATION DECISION	40
      A.    Determination of Eligibility	40
            1.    Eligibility Decision  	40
            2.    Eligible and Ineligible Uses  	41
      B.    Regulatory Position  	41
            1.    Tolerance Reassessment	41
            2.    Rotational Crop Restriction  	48
            3.    Reference Dose	48
            4.    Cancer Risk Assessment	48
            5.    Endangered Species Statement  	49
            6.    Environmental Hazard Statements	49
            7.    Restricted Use Classification	49
            8.    State Management Plan Candidate  	49
            9.    Groundwater Advisory  	50
            10.   Surface Water Advisory	50
            11.   Spray Drift Advisory	50
            12.   Occupational/Residential Labeling Rationale/Risk Mitigation ... 50
            13.   Ground-Water Protection Requirements	55

V.    ACTIONS REQUIRED BY REGISTRANTS  	56
      A.    Manufacturing-Use Products	56
            1.    Additional Generic Data Requirements	56
            2.    Labeling Requirements for Manufacturing-Use Products	56
      B.    End-Use Products  	57
            1.    Additional Product-Specific Data Requirements	57

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            2.    Labeling Requirements for End-Use Products	57
                  a.    Occupational/Residential Labeling	57
                        (1)    Personal Protective Equipment Requirements for
                               Pesticide Handlers (mixers, loaders, applicators, etc);
                                	57
                        (2)    Entry Restrictions; Labeling   	59
                        (3)    Other Labeling Requirements  	61
                  b.    Environmental Hazards Statements   	62
                  c.    Rotational Crops Restriction	63
                  d.    Ground Water Labeling/Mitigation; Mixing/Loading  ...  63
                  e.    Ground Water Advisory	63
                  f.    Surface Water Advisory	64
                  g.    Spray Drift Labeling	64
      C.    Existing Stocks  	67

VI.  APPENDICES	69
      APPENDIX A.  Table of Use Patterns Subject to Reregistration

            Appendix A is  63 pages long and is not being included.  Copies of Appendix
            A are available upon request per the instructions in Appendix D  	71
      APPENDIX B.  Table of the Generic Data Requirements and Studies Used to
            Make the Reregistration Decision	73
      APPENDIX C.  Citations Considered to be Part of the Data Base Supporting the
            Reregistration  of Metolachlor	93
      APPENDIX D.  List of Available Related Documents  	  137
      APPENDIX E	  141
            PR Notice 86-5	  143
            PR Notice 91-2	  165
      APPENDIX F.  Combined Generic and Product Specific Data Call-In	  171
            Attachment 1.  Chemical Status Sheets	  191
            Attachment 2.  Combined Generic and Product Specific Data Call-in
                  Response Forms Plus Instructions	  195
            Attachment 3.  Generic and Product Specific Requirement Status and
                  Registrant's Response Forms and Instructions	  201
            Attachment 4.  EPA Batching of End-Use Products for Meeting Data
                  Requirements for Reregistration	  209
            Attachment 5.  EPA Acceptance Criteria   	  215
            Attachment 6.  List of All Registrants Sent This Data Call-In Notice  .  .  229
            Attachment 7.  Cost Share, Data Compensation Forms, Confidential
                  Statement of Formula Form and Instructions 	  231
      APPENDIX G. FACT SHEET	  241

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METOLACHLOR REREGISTRATION ELIGIBILITY DECISION TEAM
Office of Pesticide Programs:

Biological and Economic Analysis Division

Art Grube
Neil Anderson

Environmental Fate and Effects Division

Kathy Monk
Concepcion Rodriguez
George Tompkins
Estella Waldman

Health Effects Division

Linda Kutney
Susan Hummel
Pat McLaughlin
Jeff Evans
Economic Analysis Branch
Biological Analysis Branch
Science Analysis and Coordination Staff
Ecological Effects Branch
Environmental Fate and Groundwater Branch
Environmental Fate and Groundwater Branch
Risk Characterization and Analysis Branch
Chemistry Branch, Reregistration Support
Toxicology Branch II
Occupational and Residential Exposure Branch
Registration Division

Eugene Wilson                         Fungicide-Herbicide Branch

Special Review and Reregistration Division

Jane Mitchell                           Reregistration Branch

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11

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              GLOSSARY OF TERMS  AND  ABBREVIATIONS

AE      Acid Equivalent
a.i.      Active Ingredient
ADI      Acceptable Daily Intake. A now defunct term for refernce dose (RfD).
ARC     Anticipated Residue Contribution
CAS     Chemical Abstracts Service
CI       Cation
CNS     Central Nervous System
CSF     Confidential Statement of Formula
DFR     Dislodgeable Foliar Residue
ORES    Dietary Risk Evaluation System
DWEL   Drinking Water Equivalent Level (DWEL)  The DWEL represents a medium specific (i.e. drinking water) lifetime
         exposure at which adverse, non carcinogenic health effects are not anticipated to occur.
EEC     Estimated Environmental Concentration. The estimated pesticide concentration in an environment, such as a
         terrestrial ecosystem.
EP      End-Use Product
EPA     U.S. Environmental Protection Agency
FDA     Food and Drug Administration
FIFRA   Federal Insecticide, Fungicide, and Rodenticide Act
FFDCA  Federal Food, Drug, and Cosmetic Act
GLC     Gas Liquid Chromatography
GM      Geometric Mean
GRAS    Generally Recognized as Safe as Designated by FDA
HA      Health Advisory (HA)  The HA values are used as informal guidance to municipalities and other organizations when
         emergency spills or contamination situations occur.
HOT     Highest Dose Tested
LC50     Median Lethal  Concentration.  A statistically derived concentration of a substance that can be expected to cause death
         in 50% of test animals.  It is usually expressed as the weight of substance per weight or volume of water, air or feed,
         e.g., mg/L, mg/kg or ppm.
LD50     Median Lethal  Dose.  A statistically derived single dose that can be expected to cause death in 50% of the test
         animals when administered by the route indicated (oral, dermal, inhalation). It is expressed as a weight of substance
         per unit weight of animal, e.g., mg/kg.
LDlo     Lethal  Dose-low. Lowest Dose at which lethality occurs
LEL     Lowest Effect Level
LOG     Level of Concern
LOD     Limit of Detection
LOEL    Lowest Observed Effect Level
MATC   Maximum Acceptable Toxicant Concentration
MCLG   Maximum Contaminant  Level  Goal (MCLG)  The MCLG is used by the Agency to regulate contaminants in
         drinking water under the Safe Drinking Water Act.
pg/g     Micrograms Per Gram
mg/L     Milligrams Per Liter
MP      Manufacturing-Use Product
MPI     Maximum Permissible Intake
MOE     Margin of Exposure
MRID    Master Record Identification (number). EPA's system of recording and tracking studies submitted.
N/A     Not Applicable
NPDES  National Pollutant Discharge Elimination System
NOEL    No Observed Effect Level
OP      Organophosphate
OPP     Office  of Pesticide Programs
PADI     Provisional Acceptable Daily Intake
PAG     Pesticide Assessment Guideline
PAM     Pesticide Analytical Method
PHED    Pesticide Handler's Exposure Data
                                                      111

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            GLOSSARY  OF TERMS AND ABBREVIATIONS

PPE      Personal Protective Equipment
ppb      Parts Per Billion
ppm      Parts Per Million
PRN      Pesticide Registration Notice
Q*j       The Carcinogenic Potential of a Compound, Quantified by the EPA's Cancer Risk Model
RBC      Red Blood Cell
RED      Reregistration Eligibility Decision
REI      Restricted Entry Interval
RfD      Reference Dose
RS       Registration Standard
SLN      Special Local Need  (Registrations Under Section 24 (c) of FIFRA)
TC       Toxic Concentration. The concentration at which a substance produces a toxic effect.
TD       Toxic Dose. The dose at which a substance produces a toxic effect.
TEP      Typical End-Use Product
TGAI     Technical Grade Active Ingredient
TMRC    Theoretical Maximum Residue Contribution
TLC      Thin Layer Chromatography
WP      Wettable Powder
WPS      Worker Protection Standard
                                                IV

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EXECUTIVE SUMMARY

Background

       This Reregistration Eligibility Decision document (RED) addresses the reregistration
eligibility of the pesticide metolachlor, 2-chloro-N-(2-ethyl-6-methylphenyl)-N-(2-methoxy-l-
methylethyl) acetamide.

       Metolachlor, a broad spectrum herbicide, was first registered in 1976 for general weed
control in noncrop areas. Metolachlor is manufactured by Ciba-Geigy Corporation, the sole
producer and primary registrant.  Since first registered for use on turf, it is now also
registered for use on corn, cotton, peanuts, pod crops, potatoes, safflowers, sorghum,
soybeans, stone fruits, tree nuts, nonbearing citrus, nonbearing grapes, cabbage, peppers (bell,
chili,  Cubanelle, tabasco), buffalograss,  guymon bermudagrass for seed production, nurseries,
hedgerows/fencerows and landscape plantings. Metolachlor's major use sites are corn,
soybeans, and sorghum.  The emulsifiable  concentrate formulation is the most commonly used
formulation on all sites. Ground application is the method of choice for all sites.  Some
formulations may be applied by chemigation with special use directions.

       The first registration standard for metolachlor was issued in  1980 and a second
standard was issued in 1987.  The Agency  has now completed its review of the metolachlor
target data base including data submitted in response to the 1987 standard.

Reregistration Eligibility

       The Agency has determined that all uses of metolachlor with the exception of potatoes,
soybeans and peanuts as currently registered will not cause unreasonable risk to humans or the
environment and these uses are  eligible for reregistration. An eligibility decision for use on
potatoes, soybeans, and peanuts cannot be made at this time because under current policies
section 409 tolerances under the Federal Food, Drug and Cosmetic Act (FFDCA) are needed
because metolachlor concentrates in some of the processed fractions of these crops and  such
tolerances may be barred by the Delaney Clause. The Agency has recently required additional
data to confirm this decision. (Data Call-in Notices dated 12/10/93, 2/15/94 and 5/10/94).
Also,  additional confirmatory data (foliar soil  dissipation and dermal passive dosimetry) are
required for residential lawn and turf uses.

Health Effects

       The Agency's Office of Pesticide Program's Carcinogenicity Peer Review Committee
has classified metolachlor in Group C (possible human carcinogen) under EPA's Cancer
Assessment Guidelines with no cancer risk quantification. The Committee recommended that
chronic exposure to metolachlor be addressed  by margin of exposure estimates.  A RfD of 0.1
mg/kg body weight/day has been established based on a NOEL of 9.7 mg/kg/day and an

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uncertainty factor of 100.  The NOEL was based on a one year feeding study in dogs that
demonstrated a decreased body weight gain.

       A tolerance reassessment was performed and is included in this document.  Data for
cottonseed, peanuts (EC formulation at layby), fresh corn and safflower processing are
required for the continued registration of metolachlor. Food additive tolerances are needed
for potato granules and feed additive tolerances are needed for potato dry peel,  wet peel, and
waste from processing, soybean hulls and peanut meal. However, such tolerances may be
barred by the Delaney Clause of FFDCA which provides that a food/feed additive regulation
for a processed food may not be established for a pesticide which induces cancer in man or
animals. The Agency is unable to make a reregistration decision for these uses because EPA
is currently evaluating legal challenges related to the coordination of actions under FFDCA
section 409's Delaney Clause and FFDCA section 408 in FIFRA.

Occupational and Residential Exposure

       No toxicological endpoints of concern for acute or short term exposure to metolachlor
through occupational or residential exposure have been identified.

       Toxicological endpoints are of concern for workers exposed ten days or longer
(intermediate exposure).  A 21-day rabbit dermal toxicity study demonstrated systemic
NOELS of 100 mg/kg/day  for both sexes, based on increased bilirubin, increased liver
weights in males and increased kidney weights in females. Using the NOEL of 100
mg/kg/day, the corresponding margin of exposure  (MOE) for intermediate duration of
occupational exposure was  calculated. The MOEs range from 30 to 3890.  The lower MOE's
represent exposure scenarios for aerial mixer/loaders using open pour systems.  The  Agency is
requiring that aerial mixer/loaders use closed systems. This requirement provides MOE's of
approximately 300 or greater.

       Postapplication worker exposure and risk to residues from preemergent  applications to
agricultural crops is likely to be minimal.  Postapplication worker exposure and risk  from
postemergent applications to agricultural crops is also likely to be minimal since the target
crops or weeds are small at the time of application, and harvesting or other maintenance
activities are likely to be limited.  However, there is a greater potential for postapplication
exposure and risk following turf treatment.  A foliar residue dissipation study and dermal
passive dosimetry study are required as confirmatory data to  better refine the risk for
residential turf.

       A foliar dissipation study submitted on weeds and ornamental turf grass gave  exposure
estimates that do not pose an unreasonable risk to individuals reentering treated areas.  These
estimates assume a 24-hour restricted entry interval (REI).

       The Worker Protection Standard (WPS) for Agricultural Pesticides-40 CFR Parts 156
and 170—established an interim restricted-entry interval (REI) of 12 hours for metolachlor,
                                           VI

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because the acute toxicity categories of metolachlor for acute dermal toxicity, skin irritation
potential,  and eye irritation potential are Toxicity Category III and IV.  However, since
metolachlor has been shown to have intermediate effects and is classified as a group C
carcinogen, a REI of 24 hours for all sites within the scope of the WPS is required.

Environmental Fate and Ecological Effects

       Metolachlor appears to be moderately persistent to persistent and mobile to highly
mobile. Metolachlor is stable to hydrolysis under normal environmental conditions.
Metolachlor degradation appears to be dependent on microbially mediated and abiotic
processes. It appears to have a low potential to bioaccumulate in fish. Additional information
on terrestrial field dissipation is required to fully satisfy the  guideline requirement; however
this additional information is not expected to change the overall fate assessment for
metolachlor.  The additional information for terrestrial field dissipation will help  determine the
efficiency and precision of extraction and analysis for metolachlor and several of  its
metabolites.  Five  major degradates have been identified for metolachlor.

        Metolachlor residues  exceed the following levels of concern for ground water:   (1)
Ground-water quality - Metolachlor has been detected in ground water in 20 states, although
generally  below thresholds of concern for humans and animals.  Considering the widespread
use of metolachlor, the Agency is  concerned about the degradation of water quality in
metolachlor use areas.  (2) Human health - Metolachlor residues have been detected in three
states above the lifetime Human Health Advisory (HAL) of  100 ppb.  In five other states
detections exceeded  10% of the HAL; (3) Nontarget plants - No data are currently available to
assess the effect of metolachlor on aquatic or terrestrial plants.  However, because metolachlor
is a herbicide, potential risk to non-target plants is likely.  In areas where  irrigation water is
contaminated with metolachlor, or where ground water discharges to surface water,
metolachlor residues could present a threat to non-target plants.

       Substantial amounts of metolachlor  could be available for runoff to surface water for
several months post-application. Metolachlor is among the top five pesticides in terms of
frequency of detection and greatest concentrations in samples of both raw  and finished surface
water in the mid-western corn belt.  It is detected in a high percentage of surface  water
samples collected from numerous locations within the corn belt for several months post-
application.  In streams and rivers of the corn belt,  metolachlor concentrations  typically
increase rapidly from pre-application concentrations of below one ppb to post-application peak
concentrations of typically several ppb.

       Based upon the available results it appears highly unlikely that maximum or short term
average metolachlor concentrations in surface water will exceed the 1-10 day HALs of 2000
ppb or that annual average metolachlor concentrations will exceed the lifetime HAL
(potentially the MCL) of 100 ppb anywhere.  Although not formally regulated by the Safe
Drinking Water Act, water supply systems are required to sample and analyze for
metolachlor.  The Agency will review such data when  they become available.
                                           vn

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       To address ground-water concerns, the registrant is conducting two small-scale
prospective ground water studies for metolachlor and its metabolites.  The registrant has also
proposed additional labeling statements to mitigate point source contamination, i.e.
mixing/loading sites and precautionary label language which will reduce potential for off-
target movement due to spray drift, run-off or wind erosion. The registrant is presently
monitoring for metolachlor as part of the 19-state atrazine monitoring program.  The wells
being monitored were selected by the states and are representative of vulnerable areas.  The
registrant will provide the Agency with the  metolachlor analyses  from this program in 1995.

       No chronic effects are expected for freshwater and estuarine/marine fish.  The roadside
(rights-of-way) use pattern poses an acute risk for endangered freshwater fish  in shallow
water.

       The levels of concern for acute effects to non-endangered birds are not exceeded for
any application rate.  At an application rate of 6 Ibs. ai/A the level of concern for acute risk
to endangered birds is exceeded for non-granular formulations.  Based on a supplementary
study for waterfowl, the level of concern for chronic effects is exceeded at the 6 Ib. ai/A
application rate. Because this study is supplementary, new  avian reproduction studies have
been required.  These studies, which are  due May 10, 1996, could result in changes in the
avian risk assessment.

       A risk assessment using maximum and typical estimated environmental concentrations
(EECs) was done for acute effects to small mammals.  The  endangered species level of
concern is exceeded, using the maximum EEC,  for small mammals eating short grass at an
application rate of 2 Ibs. ai/A.  The endangered species level of concern is exceeded, using
typical EEC's, for small mammals eating short grass, at application rates of 4 Ibs. ai/A and
higher. The Agency is developing a program to identify all pesticides whose use may cause
adverse effects on  endangered plants/animals. Any label changes or use modifications will be
implemented through the Endangered Species Program.

       Because metolachlor is  a herbicide, risk  to non-target plants is expected.  Toxicity  data
for non-target plants were required on 12/10/93 in a Data Call-In Notice. Once these data
have been submitted, a risk assessment will be performed.

       The Agency has been working  with the Spray Drift Task Force, EPA Regional Offices
and State Lead Agencies  for pesticide regulation to develop the best spray drift management
practices. The Agency is now requiring interim measures that must be placed on product
labels/labeling as specified in Section V.  Once  the Spray Drift Task Force completes their
studies, submits data, and the Agency  evaluation is completed, there may be further
refinements in spray drift management practices.

       Before reregistering the products containing metolachlor,  the Agency is requiring that
product specific data, revised Confidential Statements of Formula (CSF) and revised labeling
                                           vin

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be submitted within eight months of the issuance of this document.  These data include product
chemistry and acute toxicity testing for each registration.  After reviewing these data and any
revised labels and finding them acceptable in accordance with Section 3(c)(5) of FIFRA, the
Agency will reregister a product.  Those products which contain other active ingredients will
be eligible for reregistration only when the other active ingredients subject to reregistration are
determined to be eligible for reregistration.
                                            IX

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I.      INTRODUCTION

       In 1988, the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) was
amended to accelerate the reregistration of products with active ingredients registered prior to
November 1, 1984. The amended Act provides a schedule for the reregistration process to be
completed in nine years. There are  five phases to the reregistration process. The first four
phases of the process focus on identification of data requirements to support the reregistration
of an active ingredient and the generation and submission of data to fulfill the requirements.
The  fifth phase is a review by the U.S. Environmental Protection Agency (referred to as  "the
Agency") of all data submitted to support reregistration.

FIFRA Section 4(g)(2)(A) states that in Phase 5  "the Administrator shall determine whether
pesticides containing such active ingredient are eligible for reregistration" before calling in
data on products and either reregistering products or taking "other appropriate regulatory
action." Thus, reregistration involves a thorough review of the scientific data base underlying
a pesticide's registration. The purpose of the Agency's review is to reassess the potential
hazards arising from the currently registered uses of the pesticide; to determine the need for
additional data  on health and environmental effects; and to determine whether the pesticide
meets the "no unreasonable adverse effects" criterion of FIFRA.

This document  presents the Agency's decision regarding the reregistration eligibility of the
registered uses  of metolachlor.  The document consists of six sections. Section I is the
introduction.  Section II describes metolachlor, its uses, data requirements and regulatory
history. Section III discusses the human health and environmental assessment based on the data
available to the Agency. Section IV presents the reregistration decision for metolachlor.
Section V discusses the reregistration requirements for metolachlor.  Finally, Section VI is the
Appendices which support this Reregistration Eligibility Decision. Additional details
concerning the  Agency's review of applicable data are available on request.

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II.    CASE OVERVIEW

      A.     Chemical Overview

             The following active ingredient(s) are covered by this Reregistration Eligibility
      Document:

      •     Common Name:           Metolachlor
             Chemical Name:           2-chloro-N-(2-ethyl-6-methylphenyl)-N-2-
                                       methoxy-1-methylethyl) acetamide
       •     Chemical Family:          Chloroacetanilide


       •     CAS Registry Number:     51218452


       •     OPP Chemical Code:      108801


       •     Empirical Formula:        C15H22C1N02


       •     Trade and Other Names:   Dual

       •     Basic Manufacturer:       Ciba-Geigy

       B.     Use Profile

             The following is information on the current registered uses with an overview of
       use sites and application methods.  A detailed table of these uses of metolachlor is in
       Appendix A.

Type of Pesticide:   Herbicide

Mode of Action:    Chloracetanilide inhibits seedling development.

Use Sites:          Terrestrial Food Crops -cabbage, pepper (bell, chile, tabasco), radish,
                   stone fruits

                   Terrestrial Food and Feed Crops -corn (field, pop, sweet), cotton,

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                     legume vegetables, peanuts, peas, potato (white/Irish), safflower,
                     sorghum, soybeans, tree nuts

                     Terrestrial Feed Crops -alfalfa

                     Terrestrial Non-Food Crops -agricultural rights-of-
                     way/fencerows/hedgerows, airports/landing fields, Christmas tree
                     plantations, commercial/industrial lawns, golf course turf,
                     nonagricultural rights-of-way/fencerows/hedgerows, nonagricultural
                     uncultivated areas/soils,  ornamental and/or shade trees, ornamental
                     lawns and turf, ornamental woody shrubs and vines, recreation area
                     lawns, recreational areas, nonbearing fruits (apples, cherries, citrus
                     fruits, crabapples, grapes, pears)

                     Terrestrial Non-Food and Outdoor Residential -ornamental and/or shade
                     trees, ornamental herbaceous plants, ornamental nonflowering plants,
                     ornamental  woody shrubs and vines

                     Forestry -forest trees (softwoods, conifers)

                     Outdoor Residential -residential lawns

Pests:
                     Grass and Grasslike Weeds -barnyardgrass, browntop panicum,
                     crabgrass, crowfootgrass, fall panicum, giant foxtail, goosegrass, green
                     foxtail, red  rice, signalgrass, southwestern cupgrass, witchgrass, yellow
                     foxtail, foxtail millet, prairie cupgrass, yellow nutsedge

                     Broadleaf Weeds -Eastern black nightshade, carpetweed, Florida pusley,
                     galinsoga, pigweed

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Formulation Types Registered:
Single Active Ingredient Products
Granular—5 to 25%
Emulsifiable concentrate-84.4 to 86.4%
Technical/liquid—95%

Multiple Active Ingredient (AI) Products
Granular-4% + 1 other AI
Emulsifiable concentrate—22 to 70% + 1 other AI

Methods and Rates of Application:
       Granular - Use from 1.95 to 4.05 pounds active ingredient per acre as a band,
       broadcast, soil incorporated, or no-till or minimum-till soil treatment. Apply with
       either a granule or pneumatic compressed air applicator postemergence,  post
       transplant, layby, postplant, preemergence, preplant, ground crack, pre  transplant, or
       when needed.

       Emulsifiable Concentrate - Use from 1.2 to 5 pounds active  ingredient per acre as a
       band,  soil incorporated, broadcast,  directed spray, or in-furrow soil treatment.  Use
       also as a no-till or minimum-till soil treatment and through chemigation.  Apply with
       ground,  low volume ground, aircraft, center pivot irrigation, or sprinkler irrigation.
       Application timings include preplant, preemergence, early postemergence,
       postemergence, Fall, Spring, non-bearing, post-plant, layby, when needed, at-planting,
       non-bearing nurserystock, post-transplant, pre-transplant, and containerized.

Use Practices Limitations:
    •  Do not use in greenhouses or other enclosed structures.
    •  Do not use on muck or peat soils.
    •  Do not use on sweet potatoes or yams.
    •  Do not apply to trees or vines transplanted less than 30 days and only after depressions
       around the trees and vines have been filled in.
    •  Do not use on sand or loamy sand soils.
    •  Do not apply to trees or vines that will bear harvestable fruit within 12 months of
       application.
    •  Do not graze livestock in treated areas.
    •  Do not apply to Taloka Silt Loam.
    •  Do not use on English peas in Northeastern U.S.
    •  Do not use on sorghum grown under dry-mulch tillage.
    •  Do not feed or graze cover crops grown in treated orchards.
    •  Do not graze or feed peanut forage or fodder to livestock for 30 days following
       application.

    C.       Estimated Usage of Pesticide

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   The best estimates available for the pesticide uses of metolachlor are derived from a
variety of published and proprietary sources available to the Agency.  The data, reported
on an aggregate and site (crop) basis, reflect annual fluctuations in use patterns as well as
the variability in using data from various information sources.

   The table below summarizes the pesticides use by site.
                          Estimated Metolachlor Usage
                        Based on data from 1987 to 1993
                    Lbs. Used
                    On Site
Use Site             (000's)

Alfalfa              < 10
Almonds            < 10
Apples              < 10
Barley              < 10
Cole crops          20
Corn                41,000
Cotton              550
Cropland for pasture < 10
Crp acres-long term  < 10
Cucurbits           < 10
Dry Beans          320
Dry Peas            < 10
Eggplant            < 10
Green Beans        170
Green Peas          37
Melons              < 10
Oats/Rye            < 10
Onions              < 10
Other hay           < 10
Pasture & Rangeland
 (Other)             < 10
Peanuts             1,300
Pecans              0
Peppers             < 10
Potatoes             690
Rice                < 30
Safflower           100
Setaside acres       < 20
                                      Percent
                                    Of Total Use
                                    On This Site

                                     <0.5
                                     <0.5
                                     <0.5
                                     <0.5
                                     <0.5
                                    69
                                    1
                                     <0.5
                                     <0.5
                                     <0.5
                                    1
                                     <0.5
                                     <0.5
                                     <0.5
                                     <0.5
                                     <0.5
                                     <0.5
                                     <0.5
                                     <0.5

                                     <0.5
                                    2
                                     <0.5
                                     <0.5
                                    1
                                     <0.5
                                     <0.5
                                     <0.5
Percent
Of Site
Treated
25-30
2-6
7-13
0

80-100
5-9
25-35
20-35

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Sorghum            3,000               5                   15-19
Soybeans            11,000              19                  5-10
Sugar beets          < 10                <0.5
Summer fallow      < 10                <0.5
Sunflowers          < 10                <0.5
Sweet Corn          380                 1                   20-30
Tobacco            < 10                < 0.5
Tomatoes           < 10                <0.5
                    58,651              100

These are agricultural sites for which usage was reported. Misreporting may have occurred
and/or usage may have occurred on non-registered sites.  Most numbers are rounded estimates
and actual usage may differ. Based on USD A, proprietary and Resources for the Future
(RFF) data from 1987 to 1993.

    D.       Data Requirements

    Data requested in the 1987 Registration Standard for metolachlor included studies on
product chemistry, residue chemistry, toxicology, and environmental fate. These data were
required to support the uses listed in the Registration Standard.  Also, two Data  Call-In
Notices  were issued on 12/10/93 and 5/10/94 which required data to be submitted for ground
water, phytoxicity, and ecotoxicity requirements. Appendix B includes all data requirements
identified by the Agency for currently registered uses needed to support reregistration.

    E.       Regulatory History

    Metolachlor, a broad spectrum herbicide,  was first registered in 1976 for general weed
control in noncrop areas. Metolachlor is manufactured by Ciba-Geigy Corporation, who is the
sole producer and primary registrant. Since first registered for use on turf,  it is now
registered also for use on food/feed and non-food crops.   Metolachlor's major use sites are
corn, soybeans, and sorghum.

    Metolachlor was the first Registration Standard document issued by the EPA in March
1980.  In Janaury 1987, a second standard was issued.  Additional Data Call-In Notices were
issued in December 1993 and May 1994.  The following data gaps were identified in these
standards and subsequent Data Call-In Notices:

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    1980 and 1987 Standards

    Toxicology

    Mutagenicity
    General metabolism
    Effect on coagulation

    Environmental Fate

    Hydrolysis
    Photodegradation
    Metabolism
    Mobility
    Accumulation
    Ground and Surface Water Monitoring

    Product/Residue Chemistry

    Product Chemistry
    Plant Metabolism
    Storage Stability
    Crop Field Trials

    1993 and 1994 Data Call-in Notices

    Ecological Effects

    Avian Reproduction
    Phytotoxicity
    Fish and Marine Organisms Toxicity
    Ground Water

III. SCIENCE ASSESSMENT

    A.       Product Chemistry

       1.     Identification of the Active Ingredient

Metolachlor [2-chloro-N-(2-ethyl-6-methylphenyl)-N-(2-methoxy-l-methylethyl) acetamide] is
a chloracetanilide herbicide. The molecular structure of metolachlor is:

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Other identifying characteristics and codes are:

Empirical Formula:         C15H22C1N02
Molecular Weight:          283.8
CAS Registry No.:          51218-45-2
Shaughnessy No.:           108801
Basic Manufacturer:         Ciba-Geigy

    Technical metolachlor is an odorless white to tan-colored liquid with a boiling point of
100 EC at 0.001 mm mercury. Its bulk density is 1.12 g/mL at 20 EC.  Metolachlor's
solubility in water at 20 EC is 530 mg/L.  Metolachlor technical is miscible in xylene, toluene,
ethylene dichloride, and cyclohexanone.  It is classified as a Class Illb combustible liquid.

       2.     Other Product Chemistry Considerations

    There is one technical product for metolachlor, the 95% technical (T) (EPA Reg. No.
100-587). All pertinent product chemistry data requirements for the  metolachlor 95% T (EPA
Reg. No. 100-587) have been satisfied, with the exception of analytical methods to verify
certified limits (Guideline Ref. No. 62-3).

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    B.
Human Health Assessment
       1.     Toxicology Assessment

             a.     Acute Toxicity

    Table 1 summarizes acute toxicity results and categories for metolachlor.

     Table 1:  Acute Toxicity Results and Categories for metolachlor
TEST
MRID
Oral LD50 - Rat 00015523
Dermal LD50 - Rabbit 00015526
Inhalation LC50 - Rat 00015535
W44444444444444444444
Eye Irritation - Rabbit
Dermal Irritation - Rabbit
Dermal Sensitization -
Guinea Pig
00015528
00015530
00015631
RESULTS
2780 mg/kg
> 10 g/kg
>1.75mg/L
W4444444
Non-irritating
Non-irritating
Positive
CATEGORY
in
in
in
W44444U
IV
IV

    Metolachlor displayed a low level of toxicity in acute tests.   Studies using technical
metolachlor showed an oral LD50 of 2780 mg/kg in rats (Category III Toxicity) and a dermal
LD50 in excess of 10 g/kg in rabbits (Category III Toxicity).  The inhalation LC50 in rats was
greater than 1.75 mg/L  (Category III Toxicity).  Neither eye nor dermal irritation was seen in
rabbits (Category IV Toxicities, Document No. 000428).  Metolachlor was positive in a study
for dermal sensitization in guinea pigs (MRID 00015631).

             b.     Subchronic Toxicity

    A three-month feeding study in beagle dogs displayed no effects at the doses of 500 and
1000 ppm; the NOEL for toxicity was equal to or greater than 1000 ppm (equivalent to 25
mg/kg/day) (guideline 82-1; MRID No.  00017690).  Beagle dogs fed 0,  100, 300, or 1000
ppm for six months displayed a NOEL of 300 ppm (equivalent to 7.5 mg/kg/day) (MRID
00032174). The LOEL was 1000 ppm (equivalent to 25 mg/kg/day) based upon reduced body
weight gains and food consumption in the high dose dogs (Document Number 010251).

    A 21-day dermal toxicity study was  performed on New Zealand white rabbits with 0,  10,
100, or 1000 mg/kg/day of metolachlor  (guideline 82-2, MRID 418331-01). The systemic
NOEL was 100 mg/kg/day for both sexes. The systemic LOELs was 1000 mg/kg/day based

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upon increased bilirubin in both sexes, increased relative and absolute liver weights in males
and increased kidney weights in females.

             c.     Chronic Toxicity

    The requirement for a chronic feeding study in rodents is satisfied by the chronic
carcinogenicity study in rats (see discussion below).

    Metolachlor was fed to beagle dogs at dose levels of 0, 100, 300, or 1000 ppm for up to
52 weeks (guideline 83-1; MRID 409807-01).  The systemic NOEL for  male dogs was 1000
ppm (32.7 mg/kg/day). The systemic NOEL for female dogs was 300 ppm (9.7 mg/kg/day)
and the LOEL was 1000 ppm (33 mg/kg/day) based on decreased body weight gain
(Document Number 010088).

             d.     Carcinogenicity

    Metolachlor has been evaluated for carcinogenic activity in both rats and mice.  No
treatment-related carcinogenic effects were observed in two acceptable chronic studies in mice.
Both Charles River CD-I  mouse studies were two years in duration.  One utilized dietary
concentrations of 0, 30, 1000, or 3000 ppm and the  other used 0, 300, 1000, or 3000 ppm
(450 mg/kg/day) (Guideline 83-1, 83-2; 248722; MRID 000015634, 00042725, and
00084003, 00117597).

    Metolachlor was fed to CD-Crl:CD (SD) BR albino rats from Charles River for 2 years at
0, 30, 300, or 3000 ppm (0, 1.5,  13.5 or 150 mg/kg/day)  (MRID 00129377, Study 80030) as
part of a combined chronic toxicity and carcinogenity study.  The NOEL was 300 ppm (15
mg/kg/day) for systemic toxicity. The LOEL was 3000 ppm (150 mg/kg/day) based on
decreased body weight gain and increased liver weights in high dose  males.  A significant
increase in liver neoplastic nodules was observed in  females at the highest dose level
(equivalent to 150 mg/kg/day) (Guideline 83-1,  -2; MRID  00129377).  This study satisfies the
requirement for a chronic toxicity study in rats (MRID 00129377)  (Guideline 83-la). Increases
of neoplastic modules and hepatocellular carcinomas were found in high dose females (MRID
00244166).

    The 1991 HED Peer Review Committee recommended that metolachlor be classified as a
Group C (possible human) carcinogen, with a Qx* of 9.2 x 103 (mg/kg/day) *).  The
classification of Group C was based on increases in  liver tumors in the female rat, by both
pair-wise and trend analysis and the replication of the finding of tumors  in the female rat in a
second study. However, the Peer Review conducted July 27, 1994, recommended an MOE
approach since there was no supportable mutagenicity concern and in light of new information
on the relative metabolism of metolachlor, quinone imine is presumed to be the ultimate
carcinogen for 2,6-dimethylaniline.   Because of steric hindrance (provided by the additional
alkyl group about the nitrogen atom), the nitrogen atom is significantly less susceptible to
amide dealkylation and extremely stable to metobolic hydrolysis  of the amide so that formation


                                          10

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of the disubstituted aniline is presumably very low (if any).

             e.     Developmental Toxicity

    Metolachlor was given to New Zealand white rabbits at 0, 36,  120, or 360 mg/kg/day by
gavage on gestation days 6-18.  Under the conditions of the study, it was not a developmental
toxicant, with the NOEL for developmental toxicity equal to or greater than 360 mg/kg/day
(highest dose tested) (guideline 83-3; MRID 00041283).  The NOEL for maternal toxicity was
120 mg/kg/day. The maternal LOEL was 360 mg/kg/day, based on lacrimation, miosis, and
reduced body weight gain.

    In one developmental toxicity study in Sprague-Dawley rats, both the maternal and
developmental toxicity NOELs were  greater than 360 mg/kg/day (highest dose tested).  The
doses were 0, 60,  180, or 360 mg/kg/day, given by gavage on gestation days 6-15  (guideline
83-3; Ciba Geigy Report 227625).  In a second study in CD rats, the gavage doses on
gestation days 6-15 were 0,  30, 100,  300, or 1000 mg/kg/day. The maternal and
developmental toxicity NOELs were  300 mg/kg/day (MRID 00151941).  Both LOELs were
1000 mg/kg/day, and the LOEL for maternal toxicity was based on deaths, salivation,
lacrimation,  convulsions, reduced body weight gain and food consumption.  The LOEL  for
developmental toxicity was based on  reduced mean fetal body weight, reduced number of
implantations per dam with resulting  decreased litter size,  and a slight increase in resorption  s
per dam with resulting increase in post-implantation loss (guideline 83-3, Document Number
009509).

             f.     Reproduction

    A two-generation reproduction study in albino CD rats, with doses of 0, 30, 300 or 1000
ppm in the diet, revealed a reproductive NOEL of 300 ppm (23.5-26.0 mg/kg/day) (MRID
00080897).  This NOEL was derived from reduced pup weights in the Fla and F2a litters at the
highest dose tested, i.e., 1000 ppm (75.8-85.7 mg/kg/day).  The NOEL for parental  toxicity
was  1000 ppm  (Guideline 83-4; Document Number 010088).

             g.     Mutagenicity

    Metolachlor was not found to be mutagenic in several tests.  The tests for gene mutation
were the Salmonella assay and an L5178/TK+/ mouse lymphoma test (Accession Number
262712 and 262713). The tests for structural  chromosome aberration were an in vivo
micronucleus assay in Chinese hamsters (Accession Numbers 26712 and 26713)  and a
dominant lethal  assay in mice (MRID 00015630). Tests for other genotoxic activity included
DNA damage/repair assays in rat hepatocytes  and in human fibroblasts and an in vivo/in vitro
unscheduled DNA synthesis assay (MRID 43244003).

    However, metolachlor was positive in a test for induction of cell proliferation for
hepatocytes from male rats at one dose  level (MRID 43244004).

                                          11

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             h.     Metabolism

    In a dermal penetration study, doses of 0.01, 0.1, and 1.0 mg/cm2 of metolachlor applied
to rat skin were found to be absorbed in relatively large amounts with significant
bioaccumulation observed in the carcass.  The absorption at 24 hours was up to 62.8% of the
administered dose, with up to 30.1% of the dose remaining in the carcass (MRID 418331-02).
Dermal absorption is assumed to be 62.8% in the human, based on this study.

    Several metabolism studies have been performed with metolachlor and the available data
indicate the compound is readily absorbed after  oral dosing and excreted in approximately
equal amounts in urine and feces over 3 days (MRID 401144-01; Accession Number 262713).
A variety of metabolites were located in urine and feces and the proposed metabolic pathway
involves cleavage of metolachlor's ether bond and subsequent oxidation to carboxylic acid, as
well as hydrolytic removal of the chlorine atom. No conjugation was observed. (MRID Nos.
00015655, 00039193, 00015425).

             i.      Reference Dose (RfD) for Chronic Oral Exposure

    The RfD  for metolachlor was determined to be 0.10 mg/kg/day based upon the results of
the  one-year toxicity study in dogs. The NOEL was 300 ppm, or 9.7 mg/kg/day, based on
decreased body weight gain at 1000 ppm (33 mg/kg/day).  An uncertainty factor of 100 was
used to derive the RfD for metolachlor.

    There is no acceptable daily intake (ADI) set by the Joint FAO/WHO Meeting  on
Pesticide Residues (JMPR).

             j.      Toxiocology Data Gaps

    There are no toxicological data gaps.

       2.     Exposure Assessment

             a.     Dietary Exposure

                    (1)    Residue Information and Background

    Tolerances for residues of metolachlor in or on food/feed commodities are currently
expressed in terms of the combined residues (free and bound) of the herbicide metolachlor [2-
chloro-N-(2-ethyl-6-methylphenyl)-N-(2-methoxy-l-methylethyl)acetamide] and its
metabolites, determined as the derivatives, 2-[(2-ethyl-6-methylphenyl)amino]-l-propanol and
4-(2-ethyl-6-methylphenyl)-2-hydroxy-5-methyl-3-morpholinone, each expressed as the  parent
compound.  Adequate enforcement methods are available for the determination of these
residues.

                                          12

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    The qualitative nature of the residue in plants is adequately understood.  The Metolachlor
Registration Standard dated March, 1980,  concluded that the qualitative nature of the residue
was adequately understood in corn and soybeans.  Metabolism of metolachlor involves
conjugation with glutathione, breakage of this bond to form the mercaptan, conjugation of the
mercaptan with glucuronic acid, hydrolysis of the methyl ether, and conjugation of the
resultant alcohol with a neutral sugar.  A minor pathway may involve sugar conjugation of
metolachlor directly to the corresponding oxo-compounds.  Residues of concern in  corn and
soybeans are metolachlor and its metabolites, determined as the derivatives CGA-37913 and
CGA-49751.

    The Metolachlor Registration Standard dated March, 1980, concluded that the  qualitative
nature of the residue in animals was adequately understood.  Metolachlor is rapidly
metabolized and almost totally eliminated in the urine and feces of ruminants (goats), non-
ruminants (rats), and poultry.  Metolachlor per se was not detected in any of the excreta or
tissues.

    Adequate methods for purposes of data collection and enforcement of tolerances for
metolachlor residues are available.  Methods for determining the combined residues of
metolachlor and its metabolites, as the  derivatives CGA-37913 and CGA-49751, are described
in PAM, Vol. II, as Method I (plants; GC-NPD) and Method II (animals; GC-MS).

    Storage stability studies have been conducted using fortified samples of beef muscle, beef
liver, milk, eggs, peanut nutmeats, potatoes, corn forage, corn grain, and corn oil.   Residues
of CGA-37913 are stable in frozen storage (# -10 EC) in beef muscle for up to 52 days, in
corn oil for up to 102 days, and in or on the remaining animal and plant commodities for  up  to
1 year.  Residues of CGA-49751 are stable in frozen storage (# -10 EC) in the animal
commodities for up to  1 year, and in or on the plant commodities for up to 2 years. The
registrant has reported the storage intervals for a sufficient number of the treated samples from
existing studies used to support proposed and established tolerances. The outstanding plant
and animal magnitude of residue studies must report the storage conditions and intervals for all
samples; samples should be stored under the conditions and analyzed within the intervals of
demonstrated residue stability.

    Residue  data are needed to support post-emergence uses of the new DF formulations.

    Sufficient data are available to ascertain the adequacy of the established tolerances listed
in 40 CFR  §180.368(a) for:  almonds,  hulls; cabbage; corn, field, forage; corn, field, fodder;
corn, field, grain;  peppers, bell; potatoes;  sorghum, fodder (milo); sorghum,  forage (milo);
sorghum, grain (milo); stone fruits group;  peas and associated vine and hay commodities;
beans and associated forage and hay commodities; soybeans; soybeans, forage; and soybeans,
hay; tree nuts group, eggs; milk; the fat, kidney, liver, meat, and meat byproducts  of cattle,
goats, hogs, horses, sheep; and the fat, liver, meat, and meat byproducts of poultry.  The
dietary burden has been recalculated and the residues reported in the livestock feeding studies
adjusted for losses in frozen storage.


                                           13

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    Sufficient data are available to ascertain the adequacy of the established tolerances listed
in 40 CFR §180.368(b) for:  the straw,  forage, and grain of barley, buckwheat, oats, rice,
rye,  and wheat.

    Sufficient data are available to ascertain the adequacy of the established tolerances listed
in 40 CFR §180.368(c) for:  peppers, chili; peppers, Cubanelle; and peppers, tabasco.

    Food/feed additive tolerances are needed for the following processed commodities:
"potatoes, dry peel"  (4.0ppm); "potatoes, wet peel" (0.5 ppm);  "potatoes, granules"  (0.5
ppm); and  "potatoes, waste from processing" (4.0 ppm), soybean hulls (0.4 ppm) and
"peanuts, meal"  (level cannot be determined).  However, Delaney issues may prevent the
establishment of these tolerances.

    Additional data are required to reassess other established tolerances (see tolerance
reassessment section, for details).

    The confined rotational crop data indicate that [14C]Metolachlor residues accumulated in
lettuce,  beets,  and wheat planted  115 days after ring-labeled [14C]metolachlor (radiochemical
purity 99.1%) was applied at approximately 3.0 Ib ai/A to loamy sand soil subsequently
planted  to potatoes.  At mature harvest, total [14C]residues were  0.3 ppm in lettuce; 0.66 ppm
and 0.86 ppm in beet tops and roots; and 2.86, 0.14, an 1.17 ppm in wheat stalks, grain, and
hulls, respectively. In immature and mature crops, organosoluble  residues ranged from 4.09
to 19.66% of the recovered radioactivity, water soluble residues ranged from 55.44 to
92.74%, and unextractable residues ranged from 1.82 to 28.52%  Radioactive residues were
inadequately characterized. Additional data are required.

    Because metolachlor is assessed as a Group C  carcinogen, it is subject to the Delaney
clause of the FFDCA.  See Section IV.B.I "Tolerance Reassessment."

    Feeding studies  are available for ruminants and poultry.  These studies indicate that finite
residues will occur in milk, meat, poultry, and eggs.  The tolerance reassessment summary for
these commodities is included in the Risk Managament Decision Section of this Reregistration
Eligibility Document.

                     (2)     Anticipated Residue Data

    In order to more accurately estimate dietary exposure to metolachlor, anticipated residues
for commodities which are major contributors  to the dietary risk were determined using
available field trial data. Portions of the metolachlor residue database consist of Craven data.
Ciba-Geigy is in the  process of generating replacement data for the Craven data.  For this
anticipated residue assessment,  Craven data were not used to generate average residues.
Tolerances previously established using Craven data were used provided sufficient other data
were available to support those tolerances on an interim basis.
                                            14

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Cabbage
Potatoes

whole or pulp
granules
flakes
peel
chips
Peanuts

peanut oil
Milk

local
milksheds
Meat




Eggs
Poultry

Anticipated residues were:
0.055 ppm

0.09 ppm
0.18 ppm
0.18 ppm
0.14 ppm
0.09 ppm
0.27 ppm
0.054 ppm
0.0005 ppm

0.0021 ppm
0.0018 ppm beef, goat,
sheep, & pork MEAT
0.0013 ppm beef, goat,
sheep, & pork FAT
0.0044 ppm beef, goat,
sheep, & pork LIVER
0.007 ppm beef, goat,
sheep, & pork KIDNEY
0.006 ppm
0.006 ppm for poultry liver
(giblets)
0.0108 ppm poultry meat,
meat by-products
Tolerances:
1.0 ppm

0.2 ppm




0.5 ppm

0.02 ppm


0.02 ppm
0.02 ppm
0.05 ppm
0.2 ppm
0.02 ppm
0.05 ppm
0.02 ppm
15

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poultry fat
Field, corn grain
Corn Processed Products

Soybean
seed
meal
hulls
oil
0.006 ppm
0.04 ppm
0.04 ppm

0.10 ppm
0.10 ppm
0.14 ppm
0.03 ppm

Not established
Not established

0.2 ppm for grain
Not established, 0.4 ppm
tolerance needed
Not established, 0.4 ppm
tolerance needed
Not established, 0.4 ppm
tolerance
needed
              b.      Occupational and Residential

              An occupational and/or residential exposure assessment is required for an active
ingredient if (1) certain toxicological criteria are triggered and (2) there is potential exposure
to handlers (mixers, loaders,  applicators, etc.) during use  or to persons entering treated sites
after application is complete.

                     (1)     Use Summary

    The emulsifiable  concentrate formulation is the most commonly used formulation on all
sites.  Ground application is the method of choice for all sites. Aerial applications are  allowed
for some use sites.

    Metolachlor is applied by chemigation, air or is broadcast. Rates of application vary from
0.75 Ib  ai/A to 4.0 Ib ai/A. Maximum use rates on the  major crops are: 4 Ib ai/A (nursery
turf),  and 3 Ib ai/A (corn, soybeans,  peanuts, potatoes, pod crops, sorghum  and safflower).
Metolachlor is applied either  immediately at or after planting (soybeans) or at a 14 to 45  day
pre-plant or post-emergent interval (dry beans and grapefruit). In the case of Tabasco  or chili
peppers, directed post-emergent sprays can be made at mid-season.

    At this time some products containing metolachlor are intended primarily for homeowner
use and some are intended primarily  for occupational  use.
                                           16

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                    (2)    Summary of Toxicity Concerns Impacting Occupational and
                           Residential Exposure

    Metolachlor technical is in Toxicity Category III for acute dermal, oral, and inhalation
effects and is in Toxicity Category IV for dermal and eye irritation.  These toxicity categories
do not trigger any requirement for evaluation of or reduction in, worker exposure.
Consequently, no worker exposure data were required by the Registration Standard (1980).
However, since the Standard was issued additional toxicological endpoints for worker
exposure have been identified. A 21-day dermal toxicity study was performed on New
Zealand white rabbits with 0, 10, 100 or 1000 mg/kg/day of metolachlor. The systemic
NOELS were 100 mg/kg/day for both sexes.  The systemic LOEL was 1000 mg/kg/day based
on increased  bilirubin in both sexes, absolute and relative liver weights for males, and in
relative kidney weights for females.  In addition, metolachlor is  classified as a Group C non-
quantified carcinogen.  Quantification of risk is based on a NOEL of 15 mg/kg/day derived
from the  chronic rat study.
                    (3)    Summary of Potential Occupational and Residential
                           Exposures

    Handler (Mixers, Loaders, Applicators, etc.)  Exposures:  EPA has determined that there
is an exposure potential for mixers,  loaders, applicators, or other handlers during normal use
associated with metolachlor.  Exposures to loaders, applicators,  and loader-applicators is
likely when granular formulations are used.  Exposures to mixer-loaders, applicators,
flaggers, and mixer-loader-applicators is likely when liquid formulations are used.

    Post-Application Exposures:  EPA has determined that there is an exposure potential for
persons entering treated sites after application is complete.  For  many uses of metolachlor, the
potential for post-application exposure is diminished since the herbicide is incorporated into
the soil following application.  If metolachlor is appropriately incorporated, post-application
exposures should be limited to those situations where the task being performed disturbs the soil
sub-surface. There is more risk of exposure to metolachlor following post-emergent
applications, especially applications to turf.

                    (4)    Handler (Mixers, Loaders, Applicators, Etc.) Exposures &
                           Assumptions

    Mixer/loader/applicator (M/L/A) exposure data for metolachlor were not required during
the Registration Standard or Phase IV of the reregistration process, since no toxicological
criteria had been triggered at that time. However,  handler exposure data for the emulsifiable
concentrate (EC) are available. A mixer/loader (MRID #40279809) was submitted.  Data
from this study, combined with the Pesticide Handlers Exposure Database (PHED, ver 1.01)
were used to estimate worker exposure. The daily exposure estimates  for the mixer/loader
(M/L),  applicator (A),  flagger (F), and combined job functions, mixer/loader/applicator

                                           17

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(M/L/A) are shown in the attached tables. Surrogate exposure data for the granular
formulation are available using PHED.  However, these data are deficient, since the surrogate
exposure data for exposure to granular formulations are based on an insufficient number of
data measurements (fewer than 15 replicates) that are of unacceptable quality.  In addition,
there is no information on exposure when coveralls and gloves are used.

    Based on the use  patterns and potential exposures described above, four major exposure
scenarios were identified for metolachlor: (1) mixing/loading the liquid formulation to support
ground application, (2) applying the liquid formulation with a ground equipment,  (3)
mixing/loading the liquid formulation to support aerial application, (4) applying the liquid with
aerial equipment, (5)  flagging for aerial applications, (6) loading the dry (granular)
formulation, and  (7) applying the dry formulation with ground equipment. The exposure
scenarios are presented in the attached Tables along with the corresponding exposure/risk
assessment. Footnotes to the tables list the actual clothing and equipment worn by persons
being monitored in the exposure  studies.

Daily exposure (mg ai/kg  bw/day)

    = unit exposure (mg ai/lb ai) x use(lb ai/A) x Daily Acres Treated (A/day)
                               body wt (kg)

    The following assumptions are made for the EC and granular use patterns:

•mixing/loading  by ground application is done 1 day/year (Typical Private Rate)
•ground application is done 1  day/year (Typical Private Rate)
•aerial application is  done 1 day/year (Typical Private Rate)
•M/L/A exposure is  10 days/year via ground equipment (Typical Commercial Rate)
•Aerial exposure is 10 days/year for turf uses (conservative estimate)
•Applications to  rights of way, pastures, rangeland, very large farms are expected to be a
maximum of 10 d/yr  (conservative estimate).

    Mixer/loaders diluting large batches of metolachlor on  a regular basis will be exposed to a
greater extent than those who prepare the pesticide for one application per year.  Furthermore,
the label instructions specify a maximum use rate of 4.0 Ib ai/A for use on sod farms.

    These calculations of daily exposure to metolachlor by handlers are used to assess the risk
to those handlers.

                     (5)    Post Application Exposure to Workers

    Post-application exposure data were  not required during the Registration Standard or
Phase IV of the reregistration process, since, at that time, no toxicological criteria had been
triggered for metolachlor.  A foliar dislodgeable residue study (MRID#410539-01) was
submitted in support of a registration for the use of metolachlor to control weeds on
ornamental turf grass.
                                           18

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    A rough estimate of the exposure to postapplication workers was made using foliar
dislodgeable residues from that study together with the Poppendorf transfer coefficient of
10,000 to estimate transfer of residues to the entire body surface. These calculations of daily
exposure to metolachlor by post-application workers are used to assess the risk to those
workers.

                    (6)     Additional Occupational/Residential Exposure Studies

                    Two exposure studies are required as confirmatory data. A foliar
residue dissipation (132-la) and dermal passive dosimetry study  (133-3) are required to better
refine the risk for residential turf.

       3.     Risk Assessment

              a.     Dietary

    There was no evidence, based on the available data,  that metolachlor is associated with
significant reproductive or developmental toxicity  under the testing conditions. The data
available for review to  address or characterize the  hazard of a one-time or one-day  exposure,
did not indicate that a one-day exposure to  the chemical would be of such concern as to
warrant the need for an acute  dietary risk assessment.

    The  DRES chronic exposure analysis used a Reference Dose (RfD) of 0.10 mg/kilogram
body weight/day, based on a No Observed Effect Level (NOEL) of 9.7 mg/kg bwt/day and an
uncertainty factor of 100.  The NOEL was from a one year feeding study in dogs which
demonstrated decreased body  weight gain as the effect of concern.

    Metolachlor has been classified as a Group C  (possible human)  carcinogen by the HED
Carcinogenicity Peer Review  Committee. As discussed under the Toxicology Assessment
(B)(l)(d) cancer risk assessments are based on a MOE approach.  The MOE was calculated
from a NOEL of 15 mg/kg/day derived from the chronic rat study.  However, because the
RfD is set on a NOEL  of 9.7  mg/kg/day, dietary cancer concerns are adequately addressed by
the DRES chronic exposure analysis using the RfD.

    Anticipated Residue/Dietary Risk Estimates

    A DRES analysis using anticipated residue (AR) estimations and percent crop treated data
was performed to estimate dietary risk.

    The  ARC for the overall  U.S. population from food uses of metolachlor being  supported
through reregistration is 0.000199 mg/kg bwt/day, which represents less than 0.2% of the
RfD.  If the pending use on celery is included, the ARC is raised to 0.000205 mg/kg bwt/day,
still less than 0.2% of the RfD.  The subgroup most highly exposed through the diet, non-
nursing infants less than one year of age, has an ARC from recommended uses of 0.00641


                                           19

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mg/kg bwt/day, or less than 0.6% of the RfD.  If the pending use is included, the exposure is
raised to 0.000644 mg/kg bwt/day (less than 0.6% of the RfD).  This low fraction of
allowable RfD is considered to be an acceptable dietary exposure risk. Tolerance
reassessments due to replacement of Craven data are not expected to significantly affect the
RED.

             b.     Occupational and Residential

    The toxicological  endpoints of concern for occupational and residential exposure are
Group C carcinogen classification and systemic toxicity resulting from exposure of one week
to several months (intermediate exposure).  A NOEL of 100 mg/kg/day was used to estimate
MOEs,  based on systemic toxicity from a 21-day dermal toxicity study in New Zealand white
rabbits.  Because the effects discussed above are from a dermal study, a dermal absorption of
100% is assumed.

Intermediate Length Exposure  MOE =

    NOEL =        100 mg/kg/day	
    Dose            Maximum Daily Exposure

Risk to  Handlers (Mixers, Loaders, Applicators, etc.)

    Margins of exposure (MOEs) for occupational exposure were calculated for handlers
using the NOEL (100 mg/kg/day) based on a risk concern for intermediate (one week to
several months) exposure.  The calculated MOE's for subchronic toxicity are given presented
in the following Tables. The primary risk concern is for commercial handlers.  Non-
commercial handlers are likely to be exposed only once per year.

     The calculations indicate that MOEs for subchronic systemic effects are unacceptable
(less than 100) for mixer/loaders supporting aerial applications of metolachlor. The MOEs for
mixers/loaders supporting ground applications of liquid metolachlor formulations and for
applicators applying liquid metolachlor formulations using ground equipment are acceptable
only when certain personal protective equipment (gloves and coveralls) are worn by those
handlers.

    The following risk mitigation measures for handlers, combined with generic worker
protection labeling,  should mitigate these risks:

•  mandatory use of a closed mixing and loading system by mixer/loaders who are
    supporting aerial applications of metolachlor when using liquid formulations.

•  requirement of chemical-resistant gloves and coveralls worn over short-sleeve shirt
    and short pants for mixers/loaders supporting ground use applications of liquid
    metolachlor formulations and for applicators applying liquid metolachlor

                                          20

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    formulations using ground equipment.

Risk From Post Application Exposures

    Based on the rough post-application exposure estimates, the risk posed by post-application
exposure to metolachlor was estimated.  Results of a turf dislodgeable residue study indicate
significant residue levels at 0 days post-application (at 16 micrograms/cm2).  However,
residues rapidly decline by one day post application (0.269 micrograms/cm2). EPA has
determined that post-application exposures do not appear to pose an unreasonable risk to
individuals entering treated areas, provided entry is not permitted immediately following
application. Therefore, for all uses within the scope of the worker protection standards
(WPS), EPA is requiring  a restricted-entry interval (REI) of 24 hours and personal protective
equipment for workers who enter the treated area before the REI is expired.

    The 24-hour  post-application entry restriction for metolachlor does not apply to uses
outside the scope of the Worker Protection Standard for Agricultural Chemicals, including
out-of-scope commercial uses  and homeowner uses.  The predicted frequency, duration, and
degree of exposure by such uses do not warrant the same risk mitigation measures required for
users covered by  the WPS who are engaged in agriculture for commercial or research
purposes.  For nonWPS occupational uses and homeowner uses,  EPA is requiring:

    •  for liquid  applications: a prohibition on entry until sprays have dried;

    •  for granular applications: a prohibition on entry until dusts have settled or, if the
       granules must be watered-in, a prohibition on entry until the treated area is dry,
       following  the watering-in.
                                           21

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      The calculated MOE's for subchronic toxicity are given in the following Tables 2 and 3.

      TABLE 2: ESTIMATED MOE'S FOR MIXER/LOADERS, APPLICATORS,
      MIXER/LOADER/APPLICATORS, AND FLAGGERS FOR LIQUID FORMULATION
      OF METOLACHLOR
SITE


VEGETABL
E
Corn,
Soybeans,
Sorghum,
Peanuts,
Potatoes, Pod
Crops,
Safflower
(Maximum
Rate, 3.0 Ib
ai/A)
TURF
Nursery and
Sod
(Maximum
Rate, 4.0 Ib
ai/A)
INDIVIDUAL
EXPOSED

M/L:

A:
M/L/ A:
F:



M/L :
A:
M/L/ A:
F:
GROUND
OPEN POUR

170

3890
170



130
2920
130

GROUND
CLOSED
SYSTEM
1670

3890
1170



1250
2920
880

AERIAL
OPEN
POUR
40

950
260



30
710
—
200
AERIAL
CLOSED
SYSTEM
380

950
260



290
710
—
200
M/L, A, and M/L/A wears Gloves and Coveralls
Aerial Applicator (pilot) wears No Gloves and Short Sleeves
Flaggers wear No Gloves, No Coveralls, Long pants and Long Sleeves
M/L = Mixer/Loader; A  = Applicator; M/L/A = Mixer/Loader/Applicator;
F  = Flagger
                                               22

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TABLE 3: ESTIMATED MOE'S FOR MIXER/LOADERS, APPLICATORS AND
MIXER/LOADER/APPLICATORS FOR THE GRANULAR FORMULATION OF METOLACHLOR
SITE

VEGETABLE
Corn, Soybean, Sorghum,
Peanut, Potatoes, Pod Crops,
Safflower

(Maximum Rate, 3.0 Ib ai/A)
TURF
Nursery and Sod

(Maximum Rate, 4.0 Ib ai/A)
INDIVIDUAL
EXPOSED
M/L:

A:

M/L/ A:

M/L:

A:
M/L/A
GROUND OPEN POUR

4200

25000

3600

3100

19000
2700
M/L, A, and M/L/A wears Gloves and Coveralls
M/L  = Mixer/Loader
A   = Applicator
M/L/A = Mixer/Loader/Applicator
          c.
Environmental Assessment
            1.    Environmental Fate

                  a.    Environmental Chemistry, Fate and Transport

                  Metolachlor appears to be stable to hydrolysis at pH's of 5, 7, 9 without
                  significant degradation of parent material after 30 days.

                  The aqueous photolysis half-life was 70 days when exposed to natural sunlight
                  and 0.17 day when exposed to artificial sunlight (450 watt mercury arc lamp
                  with light intensity of 4500-4800 uW/cm2).  After 30 days exposure to natural
                  sunlight the  degradation products were CGA-41638 (3.63% of applied
                  radiocarbon), CGA-51202 (3.54%), CGA-46129 (3.42%), CGA-50720
                                             23

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(3.20%), and parent metolachlor remaining was 62.92%.

The soil photolysis half-life of metolachlor when exposed to natural sunlight
was 8 days, and when exposed to artificial light conditions  (mercury arc lamp
with intensity of 1600-2400 uW/cm2) the half-life was 37 days. The major
degradates reported after 21 days exposure to natural sunlight were CGA-51202
(maximum of 3.4% of applied radiocarbon), CGA-37735 (9.0%), CGA-41638
(5.7%), CGA-40172  (6.2%), and CGA-37913 (maximum of 7.3% of applied
radiocarbon).

Under aerobic soil conditions metolachlor degraded with a half-life of 67 days
in a sandy loam soil.  The major metabolite was CGA-51202 (maximum of
28.09% of applied radioactivity at 90 days posttreatment). Other identified
metabolites were CGA-37735  (maximum of 14.85% at 272 days), CGA-41638
(maximum of 2.06% at 90 days), and CGA-13656  (maximum of 1.02%
immediately posttreatment). Other metabolites that were detected but not
quantified were CGA-40172, CGA-41507, CGA-40919, and CGA-37913.

The aerobic aquatic metabolism half-life of metolachlor was 47 days. The major
metabolites in the sediment were CGA-41507 (3.34% of applied radiocarbon at
29 days), CGA-50720 (1.17%), CGA-40172 (1.13%), CGA-46127 (1.54%)
and parent metolachlor was 34.56%. In the water fraction after 29 days
incubation parent metolachlor was 30.90% and the metabolite CGA-41507 was
1.21% and CGA-51202 was 1.99%.

Under anaerobic soil conditions metolachlor degraded with a half-life of 81
days in a sandy loam soil that was incubated under anaerobic conditions for 60
days at 25°C following 30 days of aerobic incubation. The major degradate in
both the soil and flood water was CGA-51202  (maximum of 23.33% of applied
radiocarbon at  29 days after anaerobic conditions were established); and other
reported degradates were CGA-37735  (1.25%  at 29 days),  CGA-41638 (8.30%
at 60 days), CGA-13656 (1.46% at 29 days), and CGA-50720 (maximum of
7.34% at 60 days).

The anaerobic aquatic metabolism half-life for metolachlor  was 78 days. In the
anaerobic waters the major degradates were CGA-40172 (maximum of 5.64%
at 12 months),  CGA-37913 (maximum of 4.28% at 6 months), CGA-46127
(maximum of 4.69% at 12 months) and CGA-41507  (maximum of 4.85% at 6
months). The major degradates in the sediment were  CGA-41507 (maximum of
15.88% of applied radiocarbon at 12 months),  CGA-40172 (maximum of
3.18% at 12 months), CGA-46127 (maximum  of 13.02% at 12 months), CGA-
50720 (maximum of 1.67% at 29 days), and CGA-37913 (maximum of 2.33%
at 6 months), and after 12 months the sediment contained 1.47% parent
metolachlor.
                            24

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In the unaged portion of the leaching and adsorption and desorption study
metolachlor was shown to range from being highly mobile in a sand soil (Kd
value of 0.08)  to being moderately mobile  (Kd value of 4.81 in a sandy loam
soil) from column leaching studies using four soils. The leachate contained from
15.03% to 82.91% (comprised of 75.5% parent metolachlor, 1.14% of CGA-
51202, 3.69% of CGA-37735, and 2.26%  CGA-41638) of the applied
radioactivity. In batch equilibrium studies employing the same four soils, the
Freundlich adsorption (Kad)  values ranged from 0.108 to 2.157.  These data
indicate that metolachlor has the potential to range from being a moderately
mobile material (clay soil and sandy loam soil) to being a highly mobile
material (loam soil and sand soil).

In the aged leaching portion of the leaching and adsorption and desorption study
the reported cumulative Kd for aged metolachlor and its degradates in columns
of an Iowa sandy loam soil was 2.01. This indicates  that metolachlor and its
identified  degradates (CGA-51202, CGA-37735, and CGA-41638) have the
potential to be mobile since in other studies it was  shown that metolachlor and
its CGA-51202 degradate leached the slowest in the Iowa sandy loam soil
compared to their leaching rate in the other three soils tested. Batch equilibrium
studies showed that CGA-51202 has the potential to be extremely mobile with
reported Freundlich adsorption (Kad) values ranging from 0.04 in the Maryland
sand to 0.171 in the Iowa sandy loam soil.

Laboratory volatility studies indicated that  volatility is not a significant mode of
dissipation for metolachlor from the soil. The maximum dissipation was 0.05%
of the metolachlor dose volatilizing per day.

In numerous terrestrial field dissipation studies using metolachlor (Dual 8E and
Dual 25G) both applied at 4 and 6 Ib ai/A  the half-life of metolachlor in the 6-
12 inch soil layer ranged from 7 days (Iowa) to 292 days (California) with a
range of the total water applied ranging from 16.97 inches to > 40 inches
during the study period. Detections of metolachlor were made as far as the 36-
48 inch soil layer in some of the tests. The degradate CGA-40172 (0.07 ppm)
and CGA-40919 (0.21 ppm) were detected in the 36-48 inch soil layers in one
Iowa site. CGA-50720 was not detected  (< 0.07 ppm) in any soil sampled at
any interval.

Metolachlor appears to have a low potential to bioaccumulate in fish with a
reported whole body bioconcentration factor of 69X and a whole body
elimination of 93% after 14 days depuration.

Substantial amounts of metolachlor could be available for runoff to surface
water for several months post-application.  The low soil/water partitioning of
metolachlor indicates that most of the metolachlor  runoff from soil will be in
                             25

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the form of dissolution in runoff water.  A substantial amount of data on
metolachlor in the surface water of the mid-western corn belt are available.
Based upon these data along with a literature review submitted by  Ciba-Geigy
(Tierney and Newby 1993),  the Agency has reached and/or concurs with the
following conclusions with respect to metolachlor concentrations in surface
waters.

Metolachlor is among the top five pesticides  in terms of frequency of detection
and greatest concentrations in samples of both raw and finished surface water in
the mid-western corn belt. It is detected in a high percentage of surface water
samples collected from numerous locations within the corn belt for several
months post-application. Detection percentages in early spring, before
application, and in late fall and winter, many months after application, are
lower than  the first few months post-application, but are still relatively high due
presumably to its persistence.

Metolachlor concentrations typically increase rapidly from pre-application
concentrations of below one  ppb to post-application peak concentrations of
typically several ppb.  Peak concentrations sometimes exceed 10 ppb and
occasionally exceed 20 ppb.  Peak concentrations exceeding 50  ppb appear to be
rare, but peak concentrations of metolachlor  exceeding  50 ppb  (up to 154 ppb)
have been reported. In areas where tile drainage and/or groundwater inflow
contribute substantially to the loading to surface waters, secondary peaks may
occur substantially after peak flow.  Peak concentrations of metolachlor are
generally greater in surface waters draining small watersheds than in those
draining  large watersheds.

Most of the available metolachlor data are for streams and rivers.  Goolsby et al
(1993) reported detection percentages for metolachlor in 76 midwestern
reservoirs that were comparable  to those for  streams and rivers. The small
amount of metolachlor data for 10 lakes and  reservoirs summarized by Tierney
and Newby (1993) indicate that elevated metolachlor concentrations sometimes
occur later  and/or remain longer in some lakes and reservoirs than in streams or
rivers. However, the maximum metolachlor  concentration reported for the 10
lakes and reservoirs listed in the Tierney and Newby review was only 6.8 ppb.

The study by Smith et al (1987) was the only study available in which finished
drinking  water was sampled. However, metolachlor concentrations in raw and
finished water should generally be comparable because the primary treatment
processes employed by most surface water supply systems are not  effective in
removing pesticides with low soil/water partitioning such  as metolachlor.

The Agency computed annual and multiple year Time Weighted Mean
Concentrations (TWMCs)  using the available data. All were less than 10 ppb,
                             26

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and most were less than 5 ppb. The computed annual TWMCs are probably
somewhat larger than the actual time integrated means, but are more accurate
approximations of the time integrated means than arithmetic means.  Maximum
and seasonal-annual time weighted mean concentrations of metolachlor in
surface water at the same sampling location often vary substantially, sometimes
by greater than ten times, from year to year depending in part upon the
intensity, duration, and timing of post-application runoff events.

Metolachlor is not yet formally regulated under the Safe Drinking Water Act
(SDWA). Therefore, no enforcement MCL has been established for it.
However, it has relatively high drinking water health advisories  (1-10 day HAs
of 2000 ppb and lifetime HA of 100 ppb). When pesticides become regulated,
their lifetime HA usually becomes their MCL.

Based upon the available results it appears highly unlikely that maximum  or
short term average metolachlor concentrations will exceed the 1-10 day HAs of
2000 ppb or that annual average metolachlor concentrations will exceed the
lifetime HA (potentially the MCL) of 100 ppb anywhere.  Although metolachlor
is not yet formally regulated by the SDWA, water supply systems are required
to  sample and analyze for it. The Agency will review such data when they
become available.

b.      Environmental Fate Assessment

Although the environmental fate data base is not complete,  the information from
all acceptable and upgradeable environmental fate data from the  1980
Registration Standard to present indicate that parent metolachlor appears to be
moderately persistent to persistent. It also ranges from mobile to highly mobile
in  different soils and it has been detected in ground water. Metolachlor is stable
to  hydrolysis under normal environmental conditions of pH 5.0, 7.0, and 9.0.
Metolachlor degradation appears to be dependent on microbially mediated
(aerobic soil metabolism t1/2 = 67 days, anaerobic soil metabolism t1/2 = 81  days)
and abiotic processes (photodegradation in water t1/2 = 70 days under natural
sunlight and photodegradation on soil t1/2 = 8 days under natural sunlight). The
major degradates were identified as CGA-51202,  CGA-50720, CGA-41638,
CGA-37735, and CGA-13656.

Depending on the soil characteristics metolachlor has the potential to range
from a moderately mobile to a highly mobile material (Kd values ranging from
0.08 to 4.81). Upgradeable  field dissipation studies indicate that metolachlor is
persistent in the surface soil (t1/2 ranging from 7 days to 292 days the upper 6
inch soil layer). Metolachlor was reportedly detected as far as the 36 to 48 inch
soil layer in some of the studies. The degradate CGA-51202 was detected (0.11
ppm) as far as the 30-36 inch soil depth; CGA-40172 was detected as far  as the
                             27

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36-48 inch depth; CGA-40919 was detected in the 36-48 inch depth (0.21 ppm),
and CGA-50720 was not detected (0.07 ppm) in any soil segment at any interval
(MRID 41335701 and 41309802).

Metolachlor appears to have a low potential to bioaccumulate in fish with a
reported whole body bioconcentration factor of 69 and a whole body
elimination of 93% after 14 days depuration.

The "Pesticides in Ground Water Data Base 1992" indicates that residues of
metolachlor have been detected in wells in 20 states.  The lifetime Health
Advisory for metolachlor has been established at 100 ppb.  Levels exceeded the
Health Advisory in a total of 3 wells located in Wisconsin, New York, and
Montana.  In five other states concentrations in well water exceeded 10% of the
HAL.  A recent 6 (a) (2)  report submitted by the registrant indicates metolachlor
residues in one well that also exceeds the 100 ppb HAL. Because of these
detections the Agency is concerned about the degradation of water quality that
occurs in metolachlor use areas.

Metolachlor is among the top five pesticides in terms of frequency of detection
and greatest concentrations in samples of both  raw and finished surface water in
the mid-western corn belt. It is detected in a high percentage of surface water
samples collected from numerous locations within the corn belt for several
months post-application. In streams and rivers of the corn belt,  metolachlor
concentrations typically  increase rapidly from pre-application concentrations of
below one ppb to post-application peak concentrations of typically several ppb.

Most of the available metolachlor data are for streams and rivers. However,
available detection percentages for metolachlor in 76 midwestern reservoirs
were comparable to those for streams and rivers. The data indicates that
elevated metolachlor concentrations  sometimes occur later  and/or remain longer
in some lakes and reservoirs than in streams or rivers.

Only one of the available studies involved finished drinking water.  However,
metolachlor concentrations in raw and finished water should generally be
comparable because the  primary treatment processes employed by most surface
water supply systems are not effective in removing pesticides with low
soil/water partitioning such as metolachlor.

Based upon the available results, it appears highly unlikely that maximum or
short term average metolachlor concentrations will exceed  the 1-10 day HAs of
2000 ppb or that annual  average metolachlor concentrations will exceed the
lifetime HA (potentially the MCL) of 100 ppb anywhere. Although metolachlor
is not yet formally regulated by the Safe Drinking Water Act, water supply
systems are required to sample and analyze for it. The  Agency will review
                             28

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       such data when they become available.

2.     Ecological Effects

       a.     Ecological Hazard

             (1)    Non-Target Birds

       Avian Acute

       In order to establish the toxicity of metolachlor to birds, the minimum data
       required on the technical material are: an avian single-dose LD50 test with
       either  one species of waterfowl, preferably the mallard, or one species of
       upland game bird, preferably bobwhite; and two avian dietary LC50 tests, one
       with a species of waterfowl, preferably the mallard, and one with a species of
       upland game bird, preferably the bobwhite.  The acceptable data are described
       below.

       Based on acute toxicity data, metolachlor is practically non-toxic to birds.  An
       avian acute oral study performed on the mallard duck resulted in an LD50 value
       of 4640 mg/kg (MRID 00015547).

       On a subacute dietary basis, metolachlor is practically non-toxic to birds. Two
       studies one on the mallard duck and one on the bobwhite quail, produced LC50
       values greater than 10,000 ppm (MRIDs 00016425, 00016426).

       Avian Chronic

       Avian reproduction studies are required because of repeat application to
       peanuts, corn, and potatoes and because this is a persistent chemical (half life
       ranging from 7 to 292 days).  In order to establish the chronic toxicity of
       metolachlor to  birds, the data required on  the technical material are: two avian
       reproduction studies, one with a species of waterfowl, preferably the  mallard;
       and one with a species of upland game bird, preferably the  bobwhite quail.  The
       available  data are described below.

       One supplemental avian reproduction study for the mallard  duck shows that the
       LOEL is  1000  ppm.  A risk assessment was performed using  this supplemental
       study, but new avian reproduction studies  are required to confirm the chronic
       risk assessment.  (MRID 00162292) The new avian reproduction studies have
       been required in  a Data Call-In Notice dated May 10, 1994.

             (2)    Non-Target Freshwater Fish
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Acute

The minimum data required for establishing the acute toxicity of metolachlor to
fish are two 96-hour studies with the technical product: one with cold water
species, preferably rainbow trout; the other with a warm water species,
preferably bluegill sunfish.  The acceptable data are described below.

The test results show that technical metolachlor is moderately toxic to
freshwater fish in acute exposures.  The LC50's ranged from 3.9 to 10 ppm
(MRID's 00018722, 00018723, 00015534).

Chronic

Chronic toxicity to fish is a concern because of repeat application to peanuts,
corn, and potatoes and because this is a persistent chemical (half life ranging
from 7 to 292 days).  In order to establish the chronic toxicity of metolachlor to
fish, the data required on the technical material is a fish early life stage study
with one of the recommended species. The available study is described below.

The supplemental fish early life stage study gives an NOEC of 0.78 ppm and an
LOEC of 1.6 ppm.  The geometric mean is 1.17 ppm.

       (3)     Non-Target Freshwater Invertebrates

Acute

The minimum data required for establishing the acute toxicity of metolachlor to
aquatic  invertebrates is one 48-hour acute toxicity test with the technical
product. The acceptable study is described below.

The test results show that metolachlor is slightly toxic to aquatic invertebrates in
acute exposures.  The EC50 is equal to 25.1 ppm (MRID 43044603).

Chronic

Chronic toxicity to invertebrates is a concern because of repeat application to
peanuts, corn, and potatoes and because this is a persistent chemical  (half life
ranging from 7 to  292 days). In order to establish the chronic toxicity to
aquatic  invertebrates the data required is  an aquatic invertebrate reproduction
study with the water flea, Daphnia magna.  No acceptable aquatic  invertebrate
reproduction study is available.

However, based on the available data, the risk to freshwater invertebrates is not
expected to be substantially different than the risk to fish. The aquatic
                              30

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invertebrate reproduction study is required to confirm this assessment.  This
study has been required in a Data Call-in Notice dated May 10, 1994.

       (4)    Non-Target Estuarine and Marine Organisms

Acute

Metolachlor is registered for uses which may expose estuarine organisms to the
pesticide.  Such uses include cotton, corn, peanuts, turf, sorghum, soybeans,
and right-of-way.  To establish the toxicity of metolachlor to non-target
estuarine/marine organisms, three studies are required:  acute estuarine/marine
toxicity for the fish, mollusk and shrimp.  The available data are described
below.

Technical metolachlor is slightly toxic to estuarine fish in acute  exposures.  The
LC50 is 7.9 ppm (MRID 43044303).  No studies were available  for the  shrimp
and oyster.  However,  based on the available aquatic data, the toxicity to these
organisms is not expected to be substantially different than the toxicity to fish.
The shrimp  and oyster studies have been recently required in a Data Call-In
Notice (December 10,  1993) to confirm the estuarine assessment for
metolachlor.

Chronic

To establish the chronic toxicity of metolachlor to estuarine fish, a chronic
toxicity study was submitted.  The study provides an NOEC of  1.0 ppm and
LOEC of 2.2 ppm, based on length which was the most sensitive parameter
(MRID 43044602).

       (5)    Non-Target Plants

Non-target plant studies are required for any herbicide used on terrestrial food
and terrestrial non-food sites if, (1) ground application is used and the water
solubility is  greater than 10 ppm (metolachlor solubility is 530 ppm) or the
vapor pressure is greater than  1.0 x 105 mmg Hg at 25 °C (metolachlor vapor
pressure is 1.3 x 105 mmg Hg at 25 °C); or (2) the typical end product  (TEP) is
not thoroughly incorporated immediately after application (aerial application
and chemigation).  To establish the toxicity of metolachlor to  non-target plants,
the following studies are required:  seed germination/seedling emergence; a
vegetative vigor; and an aquatic plant growth study.

Since metolachlor is a herbicide, potential risk to non-target plants is likely.
Non-target plant studies were recently required in a Data Call-In Notice
(December 10,  1993).  These studies are being required to confirm the risk to
                              31

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 non-target plants.

 b.     Ecological Effects Risk Assessment

        The potential for ecological effects is presented in the following risk
 assessments,  each covering a different combination of endpoint and exposure
 scenarios.  Each risk assessment includes a risk quotient which combines the
 toxicity and exposure information.  For each risk quotient there is an
 established value above which the risk is considered to be  at a high level of
 concern (LOG).  In addition to these high risk values, restricted use is
 considered when the risk quotient exceeds 0.1  for acute aquatic risk or 0.2 for
 acute avian risk.  The generic risk quotients and their respective LOC's for each
 risk assessment are provided in the following table. Note  that the same risk
 quotients are used for non-endangered and endangered species, but the acute
 LOG is lower for endangered species.
Established Levels of Concern (LOC's)
Endpoint/Scenario
Mammalian acute
Mammalian chronic
Avian acute
Avian chronic
Aquatic acute
Aquatic chronic
Non-target insects
and plants
Risk
Quotient
EEC/LCsn
EEC/LEL
EEC/LCsn
EEC/LEL
EEC/LC5n
EEC/LEL
NOT QUANTIFIED
Non-Endangered
LOG
0.5
1.0
0.5
1.0
0.5
1.0
N/A
Endangered
LOG
0.1
1.0
0.1
1.0
0.05
1.0
N/A
        (1)      Non-Endangered Species

 Terrestrial Organisms (Avian)

 Metolachlor is registered for numerous outdoor uses.  Exposure to non-target
 organisms  can result from direct applications, spray drift from treated areas,
 and runoff from treated areas.  Such exposures can be both chronic as well as
 acute.
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              Acute Effects

              Granular Products.  The levels of concern for acute effects to avian species
              are not exceeded for any application rate (Table  1). The maximum application
              rate as a granular formulation is 4 Ib ai/acre.  For broadcast application with no
              incorporation the  LD50/ft2 =  0.007.  The same  LD50/ft2 is assumed for
              banding.
Table 1. Comparison of LD50/ft2 to the LOC for the highest
granular application rate of metolachlor. (LD50 = 4640}
Maximum Application
Rate
4 Ibs ai/acre

Method of Application
Broadcast (no incorporation)

LD50/ft2
0.007

LOC
High Risk $0.5
RU$0.2
ESS 0.1
RU = Restricted Use ES = Endangered Species
              Non-Granular Products.   The levels of concern for acute effects to non-
              endangered avian species are not exceeded at any application rate  (Table 2).
              The LOC for endangered birds is exceeded at an application rate of 6 Ibs.
              ai/acre.
    Table 2. Risk Quotient and LOC for the lowest and highest
       application rate of metolachlor. (LC50 > 10,000 ppm)
Use Site
Cabbage, Pepper Chili, Cotton,
Seed Radish
Corn, Peanuts, Alfalfa, Potatoes
Application Rate
2 Ibs ai/acre
6 Ibs ai/acre
Substrate (EEC)
Short Grass (480)
Short Grass (1440)
Risk Quotient
(EEC/LC50)
0.048
0.144
LOC
High Risk $0.5
RU$0.2
ESS 0.1
High Risk $0.5
RU$0.2
ES $ 0.1
RU = Restricted Use ES = Endangered Species
              Chronic Effects
              Preliminary chronic effects have been assessed based on a supplemental study
              for waterfowl.  Preliminary evaluation of the study shows that the LOEL is
              1000 ppm.  Based on that LOEL, the risk quotients do not exceed the LOCs at
              the 2 Ib. application rate (Table 3). The  LOC is eceeded for the 6 Ibs.
              application rate for short grass.  Since this risk assessment was based on a
              supplementary study,  the Agency has recently required two new avian
              reproduction studies in a Data Call-in Notice (May 10,  1994)  to confirm the
              chronic risk assessment for birds.
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Table 3. Chronic Risk Quotient and LOG for the lowest and highest application rate of metolachlor, based on a LOEL of 1000 ppm.
Use Site
Cabbage, Pepper Chili, Cotton,
Seed Radish
Corn, Peanuts
Application Rate
2 Ib ai/acre
6 Ibs ai/acre
Substrate (EEC)
Short Grass(480)
Seeds (24)
Short Grass (1440)
Seeds (72)
Risk Quotient
(EEC/LOEL)
0.48
0.024
1.4
0.072
LOC
High Risk $ 1
             Terrestrial Organisms (Small Mammals)

             The endangered species level of concern is exceeded, using the maximum EEC,
             for small mammals eating short grass at an application rate of 2 Ibs./acre.  The
             endangered species level of concern and restricted use level of concern are
             exceeded, using typical and maximum EEC's, for small mammals eating short
             grass, at application rates of 4 Ibs./acre and higher. The risk quotients range
             from 0.1 to 0.3.  (See table below)  Small endangered grass eating mammals
             that can be associated with agriculture (based on habitat and food) are the
             following:  in Utah the Utah prairie dog and in California the Giant Kangaroo
             rat,  the Fresno Kangaroo rat, and the Stephen's Kangaroo rat.

             An acute rat study indicated that the LD50 for the rat is 2780 mg ai/kg.  The
             LC50 is estimated from the LD50, body weight of the organism  in question,
             and food consumption. A representative of an herbivore (meadow vole LC50
              = 4567 ppm), a granivore (deer mouse LC50 =  17,209 ppm)  and an
             insectivore (least shrew LC50 = 2528) are used to estimate the risk to small
             mammals.
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Table 4. Expected food items, typical and maximum estimated environmental concentrations and Acute LOC's for three small
mammals representing different food preferences. T=Typical EEC, M = Maximum EEC
Use Sites
Cabbage, Pepper,
Chili, Seed Radish
Soybeans, Corn,
Citrus, Stone Fruits,
Grapes
Corn, Peanuts
Application rate
2 Ibs ai/acre
4 Ibs ai/acre
6 Ibs ai/acre
Species (LC50)
Meadow Vole
(4567 ppm)
Least Shrew (2528
ppm)
Deer Mouse
(17,209 ppm)
Meadow Vole
(4567 ppm)
Least Shrew (2528
ppm)
Deer Mouse
(17,209 ppm)
Meadow Vole
(4567 ppm)
Least Shrew (2528
ppm)
Deer Mouse
(17,209 ppm)
Expected Food
(EEC ppm)
Grasses
T = 250
M = 480
Insects
T = 66
M = 116
Seeds
T = 6
M = 24
Grasses
T = 500
M = 960
Insects
T = 132
M = 232
Seeds
T = 12
M = 24
Grasses
T = 750
M = 1440
Insects
T = 198
M = 348
Seeds
T = 18
M = 72
Risk Quotient
(EEC/LC50)
T = 0.05
M = 0.11
T = 0.02
M = 0.04
T = 0.0003
M = 0.001
T = 0.1
M = 0.21
T = 0.05
M = 0.09
T = 0.0006
M = 0.0001
T = 0.16
M = 0.32
T = 0.04
M = 0.07
T = 0.001
M = 0.003
LOG
HR$0.5
RU$0.2
ES $0.1
HR$0.5
RU $0.2
ES $0.1
HR$0.5
RU $0.2
ES $0.1
              Aquatic Organisms

              Acute Effects

              No acute  effects to aquatic organisms (including freshwater invertebrates and
              fish and estuarine fish) are expected as a result of the use of metolachlor when a
              6 or 1 foot deep water body scenario is employed. However, for the roadside
              use, a shallower scenario is considered to be more appropriate.  The Agency
              considers the roadside and rights-of-way use to  be the same.  Using the LC50 of
              the most sensitive aquatic  species, the freshwater  fish, application of 1.25 Ib
              ai/acre triggers the endangered species LOG for a water body of one foot deep
              or less (Table 5).
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Table 5. Acute Risk Quotient and LOG for the lowest and highest application rate of metolachlor. (LC50 = 3.9 ppm)
Use Site
Cabbage, Pepper Chili, Cotton,
Seed Radish
Roadside
Corn, Peanuts, Alfalfa, Potatoes
Application Rate
2 Ibs ai/acre
1.25 Ibs ai/acre
6 Ibs ai/acre
Depth (EEC ppm)
6 ft (0.061)
6 ft
(0.038)
1 ft
(0.229)
6 inches
(0.458)
6 ft (0.186)
Risk Quotient
(EEC/LC50)
0.01
0.009
0.05
0.12
0.04
LOC
High Risk $0.5
RU$0.1
ES $ 0.05
High Risk $0.5
RU $ 0.1
ES $ 0.05
High Risk $0.5
RU$0.1
ES $ 0.05
RU = Restricted Use ES = Endangered Species
               No data are available on acute effects for estuarine/marine invertebrates;
               however, based on the available aquatic data, the risk to these organisms is not
               expected to be substantially different than the risk to the estuarine fish. The
               estuarine invertebrate data are being required to confirm the assessment for
               these organisms.

               Chronic Effects

               No chronic effects to freshwater or estuarine/marine fish are expected from the
               use of metolachlor  (Table 6).
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Table 6. Chronic Risk Quotient and LOG for the lowest and highest a
Use Site
Cabbage, Pepper Chili, Cotton,
Seed Radish
Roadside
Corn, Peanuts, Alfalfa, Potatoes
Application Rate
2 Ibs ai/acre
1.25 Ibs ai/acre
6 Ibs ai/acre
oplication rate of metolachlor. ( Geometric Mean (GM)of NOEL and LOEL = 1.17 ppm
Depth (EEC ppm)
6 ft (0.061)
6ft
(0.38)
1 ft
(0.229)
6 inches
(0.458)
6 ft (0.186)
Risk Quotient
(EEC/CM)
0.05
0.32
0.19
0.39
0.15
LOC
High Risk $ 1
High Risk $ 1
High Risk $ 1
RU = Restricted Use ES = Endangered Species
              No data are available on chronic effects for freshwater invertebrates. However,
              based on the available aquatic data, the risk to these organisms is not expected
              to  be substantially different than the risk to freshwater fish. The invertebrate
              data have recently been required in a Data Call-in Notice (May 10, 1994) to
              confirm this assessment.

              Non-Target Plants

              There is no quantitative information available to conduct a risk assessment on
              non-target terrestrial plants.  However, because metolachlor is a herbicide, risk
              to  terrestrial non-target plants is expected. Non-target plant data are being
              required  to confirm the risk to non-target plants.

                     (2)     Endangered species

              The level of concern for acute effects to avian species eating short grass is
              exceeded at an application rate of 6 Ibs./acre for non-granular formulations
              using maximum EEC's (risk quotient = 0.1).  Based on a supplemental study,
              the level  of concern for chronic effects to avian species is exceeded at an
              application rate of 6  Ibs./acre (risk  quotient = 1.4).  The level of concern is
              exceeded, using the maximum EEC, for small mammals eating short grass at an
              application rate of 2  Ibs./acre (risk  quotient =0.1).  The level of concern is
              exceeded, using typical and maximum EEC's, for small mammals eating short
              grass, at  application  rates of 4 Ibs. ai and higher (risk quotients range from 0.1
              to  0.3). The roadside use (application rate of 1.25 Ibs. ai/acre) exceeds the
              level of concern for acute effects to endangered fish (risk quotient = 0.12).
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IV. RISK MANAGEMENT AND REREGISTRATION DECISION

    A.        Determination of Eligibility

       Section 4(g)(2)(A) of FIFRA calls for the Agency to determine, after submission of
    relevant data concerning  an active ingredient, whether products containing the active
    ingredients are eligible for  reregistration.  The Agency has previously identified and
    required the submission of  the generic  (i.e. active ingredient specific) data required to
    support reregistration of products containing metolachlor as an active ingredient.  The
    Agency has completed its review  of these generic data, and has determined that the data
    are sufficient to support reregistration of all products containing metolachlor except those
    containing the three crops specified below. Appendix B identifies the generic data
    requirements that the Agency reviewed as part of its determination of reregistration
    eligibility of metolachlor, and lists the  submitted studies that the Agency found acceptable.

       The data identified in Appendix B were sufficient to allow the Agency to assess the
    registered uses of metolachlor except potatoes, soybeans and peanuts and to determine that
    all uses of metolachlor except potatoes, soybeans and peanuts can be used without
    resulting in unreasonable adverse effects to humans and the environment.  The Agency
    therefore finds that all products, except those registered for use on potatoes, soybeans and
    peanuts, containing metolachlor as the  active  ingredient are eligible for reregistration.
    EPA is unable to make an eligibility determination for the potato, soybean and peanut uses
    at this time because under current policies these uses need section 409 tolerances and such
    tolerances may be  barred by the Delaney Clause. Additionally, EPA is in the process of
    evaluating legal challenges  to its policies related to the coordination of actions  under
    section 409's Delaney Clause and FFDCA section 408 and FIFRA.  Refer to the
    discussion under "Tolerance Reassessment."  The reregistration of particular products is
    addressed in Section V of this document.

       The Agency made its reregistration  eligibility determination based upon the target data
    base required for reregistration, the current guidelines for conducting acceptable studies to
    generate such data and the  data identified in Appendix B.  Although the Agency has found
    that all uses of metolachlor except potatoes, soybeans, and peanuts, are eligible for
    reregistration, it should be  understood  that the Agency may take appropriate regulatory
    action, and/or require the submission of additional data to support the registration of
    products  containing metolachlor,  if new information comes to the Agency's attention or if
    the data requirements for registration (or the guidelines for generating such data) change.

       1.      Eligibility Decision

       Based on the reviews of the generic data for the active ingredient  metolachlor, the
    Agency has sufficient information on the health effects  of metolachlor and on its potential
    for causing adverse effects  in aquatic organisms, wildlife and the environment. The
    Agency concludes  that products containing metolachlor for all uses except potatoes,


                                           38

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    soybeans and peanuts are eligible for reregistration.

       The Agency has determined that metolachlor products, labeled and used as specified in
    this Reregistration Eligibility Decision, will not pose unreasonable risks or adverse effects
    to humans or the environment.

       2.     Eligible and Ineligible Uses

             The Agency has determined that all uses of metolachlor except potatoes,
       soybeans and peanuts are eligible for reregistration.

    B.       Regulatory Position

       The following is a summary of the regulatory positions and rationales for metolachlor.
    Where labeling revisions are imposed, specific language is set forth in Section V of this
    document.

       1.     Tolerance Reassessment

       Tolerances Listed Under  40 CFR section 180.368(a)

    The tolerances listed in 40 CFR  180.368(a) are for the combined residues (free and
bound) of the herbicide metolachlor [2-chloro-N-(2-ethyl-6-methylphenyl)-N-(2-methoxy-l-
methylethyl)acetamide]  and its metabolites, determined as the derivatives, 2-[(2-ethyl-6-
methylphenyl)amino]-l-propanol and 4-(2-ethyl-6-methylphenyl)-2-hydroxy-5-methyl-3-
morpholinone, each expressed as the parent compound.

    Sufficient data are available  to ascertain the adequacy of the established tolerances listed
in 40  CFR 180.368(a) for: almonds, hulls; cabbage; corn, field, forage; corn,  field, fodder;
corn,  field, grain;  sunflower, seed; peppers, bell; potatoes; sorghum, fodder  (milo); sorghum,
forage (milo); sorghum, grain (milo); stone fruits group;  peas and  associated vine and hay
commodities; beans and associated forage and hay commodities; soybeans; soybeans, forage;
and soybeans, hay; and tree nuts group.

    Certain analytical data submitted to support the established tolerances listed in 40  CFR
180.368(a) were generated by Craven laboratories.  The Agency has evaluated the impact of
these  data and has determined that sufficient non-Craven data are available to support
extensions of the existing tolerances on an interim basis until the Craven data are replaced.
Craven replacement data are still needed for: corn, sweet (K +  CWHR); cotton, seed
(postemergence use only); peanuts; peanuts, hay; peanuts, vines; peanuts, hulls (EC
formulation at layby); safflower, seed (processing data).

    Sufficient data are available  to ascertain the adequacy of the established tolerances listed
in 40  CFR 180.368(a) for eggs;  milk; the fat,  kidney, liver, meat and meat byproducts of


                                            39

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cattle, goats, hogs, horses, sheep; and the fat, liver, meat and meat byproducts of poultry.
The dietary burden to livestock has been recalculated based on the reassessed tolerances for
metolachlor in livestock feeds and the residues reported in the livestock feeding studies
adjusted for losses in frozen storage.

    So that the commodity definitions listed in 40 CFR 180.368(a) will be in accordance with
the definitions in the Commodity Index Report dated 10/28/92, the tolerances should be
revoked for:  "corn, forage and fodder; (8.0 ppm); "peanut, forage and hay" (30.0 ppm);
"sorghum, forage and fodder"  (2.0 ppm), and "soybeans, forage and hay" (8.0 ppm).
Separate tolerances should be established in 40 CFR 180. 368(a) for: "corn, field, forage"
(8.0 ppm); "corn, field, fodder"  (8.0 ppm); "peanuts, hay" (30.0 ppm); "sorghum, fodder
(milo)" (2.0 ppm); and "sorghum, forage (milo)"  (2.0 ppm).  The tolerances for "seed and
pod vegetables  (except soybeans)" (0.3 ppm) should be revoked, and separate tolerances
should be established for "beans, dry" (0.1 ppm),  "beans, succulent" (0.5 ppm); "peas, dry"
(0.1 ppm) and "peas, succulent"  (0.5 ppm). In addition, tolerances for legume vegetable
group foliage (except soybean forage and soybean hay) should be replaced with tolerances of 3
ppm for beans, forage, and beans, hay; and with a tolerance of 15 ppm for peas, vines and 2
ppm for peas, hay.

    Certain other commodity definitions listed in 40 CFR 180.368(a) are not in accordance
with the definitions in the Commodity Index Report dated 10/28/92; see summary table below
for additional modifications in commodity definitions.

    Tolerances Listed Under 40  CFR 180.368(b)

    The tolerances listed in 40 CFR  180.368(b) are for the combined residues (free and
bound) of the herbicide metolachlor [2-chloro-N-(2-ethyl-6-methylphenyl)-N-(2-methoxy-l-
methylethyl)acetamide] and its metabolites,  determined as the  derivatives, 2-[(2-ethyl-6-
methylphenyl)amino]-l-propanol and 4-(2-ethyl-6-methylphenyl)-2-hydroxy-5-methyl-3-
morpholinone, each expressed as the  parent compound,  when present in the raw agricultural
commodities listed in 40  CFR  180.368(b) as a result of the application  of metolachlor to
growing crops listed in 40 CFR 180.368(a).  (Rotational crops)

    Sufficient data are available to ascertain the adequacy of the established tolerances listed
in 40 CFR 180.368(b) for:  the straw, forage, and grain of barley, buckwheat, oats, rice, rye,
and wheat.

    Certain analytical data submitted to support the established tolerances listed in 40 CFR
180.368(b) were generated by  Craven laboratories.  The Agency has evaluated the impact of
these data and has determined that sufficient non-Craven data are available to support
extensions of the existing tolerances on an interim basis until the Craven data are replaced for
non-grass animal  feeds group.  The non-Craven replacement data for alfalfa and clover (non-
grass animal feeds group) have been received and  screened. The screen indicates that current
tolerances will not be exceeded.
                                           40

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    So that the commodity definitions listed in 40 CFR 180.368(b) will be in accordance with
the definitions in the Commodity Index Report dated 10/28/92,  the tolerances should be
revoked for:  "millet, fodder" (0.5 ppm); "millet, forage" (0.5 ppm);  "milo, fodder"  (0.5
ppm); "milo, forage" (0.5 ppm); and "milo, grain"  (0.1 ppm).   The definitions for millet
forage and fodder have been deleted from the  Commodity Index Report, and do not appear in
Table II of Subdivision 0. The definitions for milo will be covered under 40 CFR 180.368(a)
as: "sorghum, fodder (milo)" (2.0 ppm); "sorghum, forage (milo)" (2.0 ppm);  and
"sorghum, grain" (0.3 ppm).

    Tolerances Listed Under 40 CFR 180.368(c):

    The tolerances with regional registration as defined in section 180.1(n) listed in 40 CFR
180.368(c) are for the combined residues (free and bound) of the herbicide metolachlor [2-
chloro-N-(2-ethyl-6-methylphenyl)-N-(2-methoxy-l-methylethyl)acetamide] and its
metabolites,  determined as the derivatives, 2-[(2-ethyl-6-methylphenyl)amino]-l-propanol and
4-(2-ethyl-6-methylphenyl)-2-hydroxy-5-methyl-3-morpholinone, each expressed as the parent
compound.

    Sufficient data are available to ascertain the adequacy of the established tolerances listed
in 40 CFR 180.368(c) for peppers, chili; peppers, Cubanelle; and peppers, tabasco.

    The established tolerance listed in 40 CFR 180.368(c) for "peppers, tabasco"  (.5  ppm),
should include a  leading zero (0.5 ppm).

    New Tolerances Needed:

    Food/feed additive tolerances are needed for  the following processed commodities:
"potatoes, dry peel" (4.0 ppm);  "potatoes, wet peel" (0.5 ppm);  "potatoes, granules"  (0.5
ppm); and "potatoes, waste from processing"  (4.0 ppm), and soybean hulls (0.4 ppm).
Peanuts will likely need a 409 tolerance once the  Craven replacment data are submitted and
the data are reviewed.

    These tolerances may be barred by the requirement in FFDCA section 409's Delaney
Clause barring the establishment of a tolerance for any substance found to  induce cancer in
man or animal. EPA policies concerning when section 409 tolerances are necessary are being
reevaluated by the Agency in light of challenges questioning their legality.  The  Agency is
unable to make a reregistration eligibility decision on the potato, soybean and peanut uses of
metolachlor until a decision on these challenges has been reached.
                                          41

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TOLERANCE REASSESSMENT SUMMARY
„ , Current r
Commodity ,
(PP

Almond hulls 0
Cabbage 1
"olerance Tolerance
m) Reassessment (ppm)
Tolerances listed under 180. 368 (a)
3 0.3
0 1.0
Comment/ Correct
Commodity Definition

Almonds, hulls

Cattle, fat 0.02 0.02
Cattle, kidney 0
2 0.2

Cattle, liver 0.05 0.05
Cattle, meat 0.02 0.05
Cattle, mbyp (except 0.02 0.05
kidney and liver)
Corn, fresh (inc. sweet K 0
+ CWHR)
Corn, forage and fodder 8
Corn, grain 0
Cottonseed 0
1 TBD
To be determined
0 Revoke and establish
separate tolerances at
8.0 ppm
1 0.1
1 TBD
Changes necessary to correct for
losses in frozen storage and 50%
radiovalidation in plants.
Cattle, mbyp (exc.
liver and kidney)
Changes necessary to correct for
losses in frozen storage and 50%
radiovalidation in plants.
Corn, sweet (K + CWHR)
Corn, field, forage
and
Corn, field, fodder
Corn, field, grain
Cotton, seed
Eggs 0.02 0.02
Goats, fat 0.02 0.02
Goats, kidney 0
2 0.2

Goats, liver 0.05 0.05
Goats, meat 0.02 0.05
Goats, mbyp (except 0.02 0.05
kidney and liver)
Changes necessary to correct for
losses in frozen storage and 50%
radiovalidation in plants.
Goats, mbyp (exc.
liver and kidney)
Changes necessary to correct for
losses in frozen storage and 50%
radiovalidation in plants.
Hogs, fat 0.02 0.02
Hogs, kidney 0
2 0.2

Hogs, liver 0.05 0.05
Hogs, meat 0.02 0.05
Changes necessary to correct for
                                     losses in frozen storage and 50%
                                       radiovalidation in plants.
                   42

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1 Commodity
Current Tolerance
(ppm)
Tolerance
Reassessment (ppm)
Comment/Correct 1
Commodity Definition \
Hogs, mbyp (except kidney
and liver)
Horses, fat
Horses, kidney
Horses, liver
Horses, meat
Horses, mbyp (except
kidney and liver)
Legume vegetables group
foliage (except soybean
forage and soybean hay)
Milk
Peanuts
Peanut, forage and hay
0.02
         0.05
0.02
 0.2
0.05
0.02


0.02
15.0
0.02
 0.5
30.0
         0.02
          0.2
         0.05
         0.05


         0.05
  Revoke and establish
 separate tolerances at 3
ppm for beans,  forage; 3
ppm beans, hay; 15 ppm
  for peas, vines; and 2
   ppm for beans, hay
         0.02
         TBD1
         TBD1
       Hogs, mbyp (exc.
       liver and kidney)
Changes  necessary to correct for
losses in  frozen storage and 50%
    radiovalidation in plants.
Changes necessary to correct for
losses in frozen storage and 50%
    radiovalidation in plants.
      Horses, mbyp (exc.
        liver and kidney)
Changes necessary to correct for
losses in frozen storage and 50%
    radiovalidation in plants.
         beans,  forage
          beans, hay
          peas,  vines
           peas, hay
         Peanuts, hay
peanuts, vines and peanut forage
    are no longer regulated
         commodities
Peanut, hulls
Peppers, bell
Potatoes
Poultry, fat
Poultry, liver
Poultry, meat
Poultry, mbyp (except
liver)

Safflower seed
Seed and pod vegetables
(except soybeans)
 6.0
 0.1
 0.2
0.02
0.05
0.02


0.02


 0.1
 0.3
         TBD1
          0.1
          0.21
          0.02
          0.05
          0.05


          0.05
          0.1
  Revoke and establish
  separate tolerances at
  0.1 ppm beans, dry;
   0.5 ppm for beans,
 succulent; 0.1 ppm for
 peas, dry; and 0.5  ppm
   for pea, succulent
         Peanuts, hulls
Changes necessary to correct for
losses in frozen storage and 50%
    radiovalidation in plants.
Changes necessary to correct for
losses in frozen storage and 50%
    radiovalidation in plants.
         Safflower, seed
          Beans, dry;
       Beans, succulent;
          Peas, dry,
              and
        Peas, succulent
                                                        43

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1 Commodity
Sheep, fat
Sheep, kidney
Sheep, liver
Sheep, meat
Sheep, mbyp (except
kidney and liver)
Sorghum, forage and
fodder
Sorghum, grain
Soybeans
Soybeans, forage and hay

Stone fruits group
Tree nuts group
Current Tolerance
(ppm)
0.02
0.2
0.05
0.02
0.02
2.0
0.3
0.2
8.0

0.1
0.1
Tolerance
Reassessment (ppm)
0.02
0.2
0.05
0.05
0.05
Revoke and establish
separate tolerances at
2.0 ppm
0.3
0.21
8.01

0.1
0.1
Comment/Correct 1
Commodity Definition \



Changes necessary to correct for
losses in frozen storage and 50%
radiovalidation in plants.
Sheep, mbyp (exc.
liver and kidney)
Changes necessary to correct for
losses in frozen storage and 50%
radiovalidation in plants.
Sorghum, fodder (milo)
and
Sorghum, forage (milo)
Sorghum, grain (milo)

Soybeans, forage
and
Soybeans, hay


Tolerances listed under 180. 368(b)
Barley, fodder
Barley, forage
Barley, grain
Buckwheat, fodder
Buckwheat, forage
Buckwheat, grain
Millet, fodder

Millet, forage

Millet, grain
Milo, fodder
0.5
0.5
0.1
0.5
0.5
0.1
0.5

0.5

0.1
0.5
0.5
0.5
0.1
0.5
0.5
0.1
Revoke

Revoke

0.1
Revoke
Barley, straw


Buckwheat, straw


Commodity not listed in
Subdivision 0, Table II, and
deleted from Commodity Index
Report
Commodity not listed in
Subdivision 0, Table II, and
deleted from Commodity Index
Report

Covered under
Milo, forage
0.5
Revoke
"Sorghum, fodder (milo)"
     Covered under
"Sorghum, forage (milo)"
                                                   44

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1 Commodity
Current Tolerance
(ppm)
Tolerance
Reassessment (ppm)
Comment/Correct 1
Commodity Definition \
Milo, grain

Nongrass animal feeds
(forage, fodder, straw, and
hay)  group
Oats, fodder
Oats, forage
Oats, grain
Rice, fodder
Rice, forage
Rice, grain
Rye, fodder
Rye, forage
Rye, grain
Wheat, fodder
Wheat, forage
Wheat, grain
0.1

3.0

0.5
0.5
0.1
0.5
0.5
0.1
0.5
0.5
0.1
0.5
0.5
0.1
Revoke

 TBD

  0.5
  0.5
  0.1
  0.5
  0.5
  0.1
  0.5
  0.5
  0.1
  0.5
  0.5
  0.1
       Covered under
  "Sorghum, grain (milo)"
Non-grass animal feeds group
        Oats, straw
        Rice, straw
         Rye, straw
        Wheat, straw
                                      Tolerances listed under 180.368(c)
Peppers, chili
Peppers, Cubanelle
Peppers, tabasco
0.5
0.1
.5
0.5
0.1
0.5
Food and Feed Additive Tolerances Needed1
potatoes, dry peel
potatoes, granules
potatoes, waste from
processing
potatoes, wet peel
peanuts, meal
soybeans, hulls
                        4.0
                        0.5
                        4.0

                        0.5
                cannot be determined,
                  additional data are
                needed for peanuts, to
                 replace Craven data
                        0.4
   Delaney issues may prevent establishment of these tolerances.
               Codex Harmonization
                                                    45

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       No maximum residue limits (MRLs) for metolachlor have been established by
Codex for any agricultural commodity. Therefore, no questions of compatibility exist
with respect to U.S. tolerances.

2.     Rotational Crop Restriction

       Metolachlor labels must prohibit planting any crop not specified on the label,
unless all appropriate rotational crop tolerances are established.

3.     Reference Dose

       The reference dose for metolachlor was determined to be 0.1 mg/kg /day based
on the chronic feeding study with dogs in which the NOEL was 9.7 mg/kg/day an
uncertainty factor of 100 was used.

4.     Cancer Risk Assessment

       The 1991 HED Peer Review Committee recommended that metolachlor be
classified as a Group C (possible human) carcinogen, with a Qx* of 9.2 x 103
(mg/kg/day) *).  The classification of Group C was based on increases in liver tumors
in the female rat,  by both pair-wise and trend analysis and the replication of the finding
of tumors in the female rat in a second study.  However, the Peer Review conducted
July 27, 1994, recommended an MOE approach since there was no supportable
mutagenicity concern and in light of new information on the relative metabolism of
metolachlor,  quinone imine is presumed to be the ultimate carcinogen for 2,6-
dimethylaniline.

5.     Endangered Species Statement

       Currently, the Agency is developing a program ("The Endangered Species
Protection Program") to identify all pesticides whose use may cause adverse impacts on
endangered and threatened species and to  implement mitigation measures that will
eliminate the adverse impacts.  The program would require use restrictions  to protect
endangered and threatened species at the county level.  Consultations with the Fish and
Wildlife Service may be necessary to assess risks  to newly listed species or  from
proposed new uses.  In the future, the  Agency plans to publish in the Federal Register
a description of the program and have  available enforceable county-specific bulletins.
Because the Agency is taking this approach for protecting endangered and threatened
species, it is not imposing label modifications at this time through the RED. Rather,
any requirements  for product use modifications will occur in the future under the
Endangered Species Protection Program.

6.     Environmental Hazard Statements


                                    46

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       Certain environmental hazard statements are required for metolachlor products
because of the potential risk to non-target plants.  Specific language is found in Section
V of this document.

7.     Restricted Use Classification

       Metolachlor is not currently classified as a restricted use pesticide.  The Agency
has determined that metolachlor products should not be classified as "restricted use" at
this time.  However, once the Restricted Use Rule for Ground Water is finalized,
metolachlor will be considered a candidate for classification as restricted use for
groundwater concerns.  The eligibility determination made at this time is based upon a
presumption that registrations will conform to all applicable regulatory conditions
included in the final restricted use rule for groundwater.

8.     State Management Plan Candidate

       Since metolachlor has been detected in ground water as a result of normal
agricultural  use,  the Agency will consider metolachlor as a candidate for state
management plans when the State Management Plan rule is promulgated.  EPA is
proposing regulations that currently: 1) designate five pesticides, one of which is
metolachlor, to be subject to EPA-approved State Management Plans (SMPs) as a
condition of their legal sale and use; and 2) establish these SMPs as an "other
regulatory restriction"  by specifying procedures and criteria for SMP development,
review and approval, as provided under the Federal Insecticide, Rodenticide and
Fungicide Act (FIFRA) Section 3(d).  In proposing these individual pesticides to be
subject to SMPs, EPA has determined that these pesticides may pose an unreasonable
adverse effect to the environment by their ground-water contamination potential, in the
absence of effective local management measures provided in a State plan. Any uses of
metolachlor allowed pursuant to the final rule will  be predicated on a finding that such
uses will not pose unreasonable adverse  effects on  the environment when used pursuant
to the conditions contained in the  rule. Upon promulgation of this  rule, the labels for
pesticide products containing metolachlor may need to be changed to require use in
accordance with  an EPA-approved SMP, and to prohibit sale and use in those States
without such an EPA-approved SMP, after  a period (to be established in the rule)
allowed for  development and approval of these State plans. The eligibility
determination  made at this time is  based upon a presumption that registrations will
conform to all applicable requirements of the final  regulation addressing this issue.

9.     Groundwater Advisory

       Current metolachlor labels have a ground water advisory statement.  This
statement must be modified to reflect  current advisory language. Specific language is
found in Section V of this document.
                                    47

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10.    Surface Water Advisory

       Since metolachlor can contaminate surface water through ground spray drift and
run-off, a surface water advisory is required.   Specific language is found in Section V
of this document.

11.    Spray Drift Advisory

       The Agency has been working with the Spray Drift Task Force, EPA Regional
Offices and State Lead Agencies for pesticide regulation to develop the best spray drift
management practices.  The Agency is now requiring interim measures that must be
placed on product labels/labeling as specified  in Section V.  Once the Spray Drift Task
Force completes their studies, submits data, and the Agency evaluation is completed,
there may be further refinements in spray drift management practices.

12.    Occupational/Residential Labeling Rationale/Risk Mitigation

       a.  Compliance with Worker Protection

       The 1992 Worker Protection Standard for Agricultural Pesticides (WPS)
established certain worker-protection requirements (personal protective equipment,
restricted entry intervals, etc.) to be specified on the label of all products that contain
uses within the scope of the WPS. Uses within the scope of the WPS include  all
commercial  (non-homeowner) and research uses on farms, forests, nurseries, and
greenhouses to produce agricultural plants (including food, feed,  and fiber plants,
trees, turf grass, flowers, shrubs, ornamentals, and seedlings).  Uses within scope
include not only uses on plants,  but also uses on the soil or planting medium the plants
are (or will be) grown in.

       At this  time some of the  registered uses of metolachlor are within the  scope of
the Worker Protection Standard for Agricultural Pesticides (WPS) and some uses are
outside the scope of the WPS.  Those that are outside the scope of the WPS include
use:

       •      on plants grown for other than  commercial or research purposes, which
              may include  plants in habitations, home fruit and vegetable gardens, and
              home  greenhouses,

       •      on plants that are in ornamental gardens, parks, golf courses, and public
              or private lawns and grounds and that are intended only for decorative
              or environmental benefit.   (However, pesticides  used on sod farms ARE
              covered by the WPS).

       •      in a manner not directly related to the production of agricultural  plants,


                                    48

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             including, for example, control of vegetation along rights-of-way, in
             hedgerows and fencerows and in other noncrop areas.

       Any product whose labeling reasonably permits use in the production of an
agricultural plant on any farm, forest, nursery, or greenhouse must comply with the
labeling requirements of PR Notice 93-7, "Labeling Revisions Required by the Worker
Protection Standard (WPS), and PR Notice 93-11, "Supplemental Guidance for PR
Notice 93-7, which reflect the requirements of EPA's labeling regulations for worker
protection statements (40 CFR part 156, subpart K). These labeling revisions are
necessary to implement the Worker Protection Standard for Agricultural Pesticides (40
CFR part 170) and must be completed in accordance with, and within the deadlines
specified in, PR  Notices 93-7 and 93-11. Unless otherwise specifically directed in this
RED, all statements required by PR Notices 93-7 and 93-11  are to be on the product
label exactly as instructed in those notices.

       After April 21, 1994, except as otherwise provided in PR Notices 93-7 and
93-11, all products within the scope of those notices must bear WPS PR Notice
complying labeling when they are distributed or sold by the primary registrant or any
supplementally registered distributor.

       After October 23, 1995, except as otherwise provided in PR Notices 93-7 and
93-11, all products within the scope of those notices must bear WPS PR Notice
complying labeling when they are distributed or sold by any person.

Personal Protective Equipment (PPE) and Engineering Controls for Handlers (Mixer/
Loader/Applicators)

       Occupational-Use Products (WPS and NonWPS Uses)

       At this time some of the registered uses of metolachlor are within the scope of
the Worker Protection Standard for Agricultural Pesticides (WPS) and some are
outside the scope of the WPS. The PPE requirements will pertain to both the WPS and
nonWPS uses by occupational handlers, since the potential exposure to occupational
handlers is similar for WPS and nonWPS uses.

       For each  end-use product,  PPE requirements for pesticide handlers will be set
during reregistration in one of two ways:

1.      If the Agency has no special concerns regarding other adverse effects of an
active ingredient, the PPE for pesticide handlers will be established based on the acute
toxicity of the end-use product.  For occupational-use products, PPE will be
established using the process described in PR Notice 93-7 or more recent EPA
guidelines.
                                    49

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2.      If the Agency has special concerns about an active ingredient due to very high
acute toxicity or certain adverse effects, such as allergic effects or other effects
(cancer, developmental toxicity,  reproductive effects, etc):

       •      In the RED document for that active ingredient, the Agency may
              establish minimum or "baseline" handler PPE requirements that pertain
              to all or most occupational end-use products containing that active
              ingredient.

       •      These minimum PPE requirements must be compared with the PPE that
              would be designated on the basis of the acute toxicity of each end-use
              product.

       •      The more stringent choice  for each type of PPE (i.e.,  bodywear, hand
              protection, footwear, eyewear, etc.)  must be placed on the label of the
              end-use product acute toxicity of each end-use product.

       For granular metolachlor formulations, the MOE's were  calculated as being
acceptable for loaders and applicators without additional active-ingredient-based
personal protective equipment.

       For liquid (emulsifiable concentrate) there are special risk concerns (Group C
carcinogen and systemic toxicity for intermediate exposure) that warrant the
establishment of active-ingredient-based minimum PPE requirements for handlers of
liquid (emulsifiable concentrate)  metolachlor formulations.  The MOE's were
calculated as being acceptable for (1) occupational mixers/loaders of liquid
formulations to support ground application and (2) occupational  applicators and
flaggers exposed during applications of the liquid formulation using the assumption that
coveralls over a short-sleeved shirt and short pants  and  chemical-resistant gloves were
worn.  The use of PPE was not sufficient to reduce the  MOE's to an acceptable level
for mixers and loaders using open mixing systems to support aerial applications.
Those MOE's were acceptable only with the use of closed mixing systems.

Handler PPE for Homeowner-Use Products

       At this time some products containing metolachlor are intended primarily for
homeowner use.  EPA is not establishing minimum (baseline) handler PPE for
metolachlor end-use products that are intended primarily for homeowner use, since the
Agency anticipates that the frequency, duration, and degree of exposure by such users
do not warrant the risk mitigation measures imposed for occupational handlers.
Personal  protective equipment, if appropriate, will be established based on the acute
toxicity of the end-use product.

Postapplication/Entry Restrictions


                                    50

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Occupational-Use Products (WPS Uses)

       Restricted-Entry Interval:  Under the Worker Protection Standard (WPS),
interim restricted entry intervals (REI) for all uses within the scope of the WPS are
established on the basis of the acute toxicity of the active ingredient. The toxicity
categories of the active ingredient for acute dermal toxicity, eye irritation potential,
and skin irritation potential are used to determine the interim WPS REI.  If one or
more of the three acute toxicity effects are in toxicity category I, the interim WPS REI
is established at 48 hours.  If none of the acute toxicity effects are in category I, but
one or more of the three is classified as category II, the interim WPS REI is established
at 24 hours.  If none of the three acute toxicity effects are in category I or II, the
interim WPS REI is established at 12 hours.  A 48-hour REI is increased to 72 hours
when an organophosphate pesticide is applied outdoors in arid  areas.  In addition, the
WPS specifically retains two types of REI's established by the Agency prior to the
promulgation of the WPS: product-specific REI's established on the basis of adequate
data and interim REI's that are longer than those that would be established under the
WPS.

       For occupational  end-use products containing metolachlor as an active
ingredient, EPA is establishing a 24-hour restricted-entry interval for each use of the
product that is within the scope of the Worker Protection Standard for Agricultural
Pesticides (WPS). The basis  for this recommendation is that metolachlor has a
toxicological endpoint of concern for systemic toxicity for intermediate exposures and
also is classified as a Group C carcinogen. EPA notes that the WPS places very
specific restrictions on entry  during restricted-entry intervals when that entry involves
contact with treated surfaces. EPA believes that these existing WPS protections are
sufficient to mitigate post-application exposures of workers who contact surfaces
treated with metolachlor.

       The  WPS REI in effect until now was 12 hours.  The WPS REI was established
through labeling modifications specified in PR Notice 93-7, which implemented the
labeling requirements of the  1992 Worker  Protection Standard for Agricultural
Pesticides.

       For those  uses of metolachlor that are incorporated into the soil, EPA notes that
if metolachlor has been correctly incorporated, the  WPS permits workers to enter the
treated area during the restricted-entry interval without personal protective equipment
or any other restriction if they are performing tasks that do not involve contact with the
soil subsurface.

       Early Entry PPE:  The WPS establishes  very specific restrictions on entry by
workers to areas that remain  under a restricted-entry by workers if the entry involves
contact with treated surfaces. Among those restrictions are a prohibition of routine
entry to perform hand labor tasks and requirement that personal protective equipment


                                     51

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be worn.  Personal protective equipment requirements for persons who must enter
areas that remain under a restricted-entry interval are based on the toxicity concerns
about the active ingredient.  The requirements are set in one of two ways.

       1.      If the Agency has no special concerns about the acute or other adverse
       effects of an active ingredient, it establishes the early-entry PPE requirements
       based on the acute dermal toxicity, skin irritation potential, and eye irritation
       potential of the active ingredient.

       2.      If the Agency has special concerns about an active ingredient due to very
       high acute toxicity or to certain other adverse effects, such as allergic effects,
       cancer, developmental toxicity, or reproductive effects, it may establish early-
       entry PPE requirements that are more stringent than would be established
       otherwise.

       EC Formulations:  There are special concerns about emulsifiable concentrate
formulations of metolachlor (Group C carcinogen and systemic toxicity) and the
MOE's for handlers were marginal.  Therefore,  for early entry following applications
of the emulsifiable concentrate, EPA is establishing PPE for dermal protection that is
more stringent than the PPE that would otherwise be established based on the acute
toxicity of the active ingredient. Since metolachlor  is  classified as category IV for eye
irritation potential, protective eyewear is not required.

       Granular Formulations  There are no special concerns about the granular
formulation of metolachlor, since the MOE's for handlers were high.  The PPE
required for early entry following applications of granular formulation is the minimum
early-entry PPE allowed by the Worker Protection Standard for Agricultural
Pesticides. Since metolachlor is classified as  category IV for eye irritation potential,
protective eyewear is not required.

       Occupational Use Products (nonWPS Uses)

       At this time some registered uses of metolachlor are outside the scope of the
Worker Protection Standard for Agricultural Pesticides (WPS). The Agency is
establishing entry restrictions for all nonWPS occupational uses of metolachlor end-use
products.  For specific language refer to Section V of this document.

       Homeowner Use Products (nonWPS Uses)

       At this time some products containing metolachlor are intended primarily for
homeowner use.  EPA is concerned about post-application exposures to homeowners
following application of metolachlor.  For specific language, refer to Section V of this
document.
                                    52

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Additional Labeling Requirements

             The Agency is requiring additional labeling statements to be located on all end-
       use products containing metolachlor that are primarily for occupational use.  For the
       specific labeling statements, refer to Section V of this document.

       13.    Ground-Water Protection Requirements

             The "Pesticides in Ground Water Data Base 1992" indicates that residues of
       metolachlor have been detected in wells in 20 states.  Levels exceeded the Health
       Advisory level of 100 ppb in a total of 3 wells located in  Wisconsin, New York, and
       Montana.  In five other states concentrations in well water exceeded 10% of the HAL.
       A recent 6 (a) (2) report submitted by the registrant indicates metolachlor residues in one
       well that also exceed  the HAL. Because of these  detections, the Agency is concerned
       about the degradation of water quality that may occur in metolachlor use areas.
       Because of the widespread use of metolachlor and the detections in many states, the
       Agency is requiring two small scale prospective ground-water studies to determine
       metolachlor's impact on ground-water quality. In addition, metolachlor is part of a 19-
       state  atrazine monitoring program.  Data on metolachlor  from this program have and
       are being made available to the Agency.  The registrant will submit a full report of all
       metolachlor analyses  from this program which is scheduled for completion in 1995.

             The Agency is also requiring label statements to further reduce the risk  of
       contamination posed by practices involved in the mixing and loading of metolachlor.
       These label statements are already found on some metolachlor labels.  These
       statements are found  in Section V.

V.  ACTIONS REQUIRED BY REGISTRANTS

    This section specifies the  data requirements and responses necessary for the reregistration  of
both manufacturing-use and end-use products.

    A.       Manufacturing-Use Products

       1.     Additional Generic Data Requirements

             The generic data base supporting the reregistration of metolachlor for the above
       eligible uses has been reviewed and  determined to be  substantially complete for all  uses.
       As noted, additional data have been recently required  in Data Call-In Notices  (12/10/93,
       2/15/94  and 5/10/94).   Also,  additional  confirmatory  data are  needed  to fulfill
       requirements for  the studies listed below:

             Foliar Residue Dissipation (132-la) - for use on residential turf
             Dermal Passive Dosimetry Exposure (133-3) - for use on residential turf


                                           53

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   2.     Labeling Requirements for Manufacturing-Use Products

         To remain in compliance with FIFRA, manufacturing use product (MP) labeling
   must be revised to comply with all current EPA regulations, PR Notices and applicable
   policies.  The MP labeling must bear the following statement under Directions for Use:

         "Only for formulation into a herbicide for the following uses(s):	
   (fill blank only with those uses that are being supported by MP registrant)."

         An MP registrant may, at his/her discretion, add one of the following statements
   to an MP  label under "Directions for Use" to permit the reformulation of the product
   for a specific use or all additional uses supported by a formulator or user group:

   (a)    "This product may be used to formulate  products for specific use(s) not listed
         on the MP label if the formulator, user  group, or grower has complied with
         U.S. EPA submission requirements regarding the support of such uses(s)."

   (b)    "This product may be used to formulate products  for any additional use(s)  not
         listed on the  MP label if the formulator, user group, or grower has complied
         with U.S. EPA submission requirements regarding the support of such uses(s)."
B.       End-Use Products

   1.     Additional Product-Specific Data Requirements

         Section 4(g)(2)(B) of FIFRA calls for the Agency to obtain any needed product-
   specific data regarding the pesticide after a determination of eligibility has been made.
   The product specific data requirements are listed in Appendix G, the Product Specific Data
   Call-in Notice.

         Registrants must review previous data submissions to ensure that they meet current
   EPA acceptance criteria (Appendix F; Attachment E) and if not, commit to conduct new
   studies.   If a registrant believes that  previously submitted data meet current testing
   standards, then study MRID numbers should be cited according to the instructions in the
   Requirement Status and Registrants Response Form provided for each product.

   2.     Labeling Requirements for End-Use Products


         a.     Occupational/Residential Labeling

                (1)     Personal Protective  Equipment Requirements  for Pesticide

                                      54

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             Handlers (mixers, loaders, applicators, etc);

       Sole-active-ingredient end-use products that contain metolachlor must be revised to adopt
    the handler personal  protective  equipment requirements set forth  in this  section.   Any
    conflicting PPE requirements on their current labeling must be removed.

       Multiple-active-ingredient end-use products that contain metolachlor must compare the
    handler personal protective equipment requirements set forth in this section to the PPE
    requirements on their current labeling and retain the more protective. For guidance on which
    PPE is considered more protective, see PR Notice 93-7.

                    •     Handler PPE for Occupational-Use Products (products NOT
    intended primarily for home use — (see tests in PR Notice 93-7 and 93-11):

    Minimum (Baseline) Personal Protective Equipment Requirements:

       Some of the registered uses of metolachlor are within the scope of the Worker Protection
    Standard for Agricultural Pesticides (WPS) and some are  outside the scope of the WPS. The
    minimum (baseline) PPE requirements pertain to both  the  WPS and nonWPS uses by
    occupational  handlers, since the potential exposure to occupational handlers is similar for
    WPS and nonWPS uses.

             Granular Formulations:  The Agency is establishing no minimum (baseline) PPE
       for WPS and  nonWPS uses of metolachlor  end-use  products that  are  formulated as
       granules.

             EC  Formulations:   The minimum  (baseline)  PPE for all WPS  and nonWPS
       occupational uses of metolachlor end-use products formulated as a liquid is:

                    •     Products NOT Intended Primarily For Home Use: The personal
protective equipment (PPE) requirement for pesticide handlers on all end-use products,  except
products intended primarily for home use  (see tests in PR Notice 93-7 and 93-11), is:

    "Applicators and other handlers must wear:
    —Coveralls over short-sleeved shirt and short pants
    —Chemical-resistant gloves (see instructions * below)
    —Chemical-resistant footwear plus socks
    —Chemical-resistant headgear for overhead exposure
    —Chemical-resistant apron when cleaning equipment, mixing, or loading"  (see instructions
    ** below)
    * The glove statement for metolachlor is the statement  established through the instructions
in Supplement Three of PR Notice 93-7.
    ** The words "mixing, or  loading" may be removed if the product is formulated as "ready-
to-use."

                                          55

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    Actual End-Use Product Personal Protective Equipment Requirements:  The PPE that would
    otherwise be established based on the  acute toxicity of each  end-use  product  must be
    compared to the minimum (baseline) personal protective equipment, if any, specified above.
    The more protective PPE must be placed on the product labeling. For guidance on which
    PPE is considered more protective, see PR Notice 93-7.

    Placement in Labeling:  The personal protective equipment  must be placed on the end-use
    product labeling in the location specified in PR Notice 93-7 and the format and language of
    the PPE requirements must be the same as is specified in PR Notice 93-7.

                     •      Products Intended Primarily for Homeowner Use: EPA is not
establishing minimum (baseline) handler PPE for metolachlor end-use  products that are intended
primarily for homeowner use. Personal protective equipment, if appropriate, will be established
based on the acute toxicity of the end-use product.

    Placement in Labeling:  The personal protective equipment requirements, if any, must be
placed on the end-use product labeling immediately following the precautionary statements in the
labeling section "Hazards to  Humans (and domestic animals)."
                    (2)    Entry Restrictions; Labeling
       Sole-active-ingredient end-use products that contain metolachlor must be revised to adopt
    the entry restrictions set forth in this section.  Any conflicting entry restrictions on their
    current labeling must be removed.

       Multiple-active-ingredient end-use products that contain metolachlor must compare the
    entry restrictions set forth in this section to the entry restrictions on their current labeling and
    retain  the more  protective.  A specific time-period in hours  or days  is considered more
    protective than "sprays have dried" or "dusts have settled."

                    •     Occupational-Use Products (Products NOT Intended Primarily
                           For Home Use):

       -Uses Within the Scope of the WPS:

       Restricted-Entry Interval: A 24-hour restricted entry interval (REI)  is required for uses
       within the scope  of the WPS (see PR Notice 93-7)  on all end-use products (see tests in PR
       Notices 93-7 and 93-11). This REI must be inserted into the standardized REI statement
       required by Supplement Three of PR Notice 93-7.

       Early-Entry Personal Protective Equipment  (PPE):

              EC Formulations:  The PPE required for early entry  following applications of the
       emulsifiable concentrate is:

                                           56

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—coveralls over short-sleeve shirt and short pants,
—chemical-/resistant gloves,
—chemical-resistant footwear plus socks,
—chemical-resistant headgear for overhead exposures.
       Granular Formulations:   The PPE required for early entry following applications
of granular formulation is:
—coveralls,
—chemical-resistant gloves,
—shoes plus socks.

Placement in Labeling: The REI must be inserted  into the standardized REI statement
required by Supplement Three of PR Notice 93-7. The PPE required for early entry must
be inserted into the standardized early entry PPE statement required by Supplement Three
of PR Notice 93-7.

-Uses Not Within the Scope of the WPS:

For liquid applications:
"Do not enter or allow others to enter the treated area until sprays have dried."

For granular applications:
"Do not enter or allow others to enter the treated area until dusts have settled.  If
soil  incorporation is  required following the application, do  not enter or allow
others to enter the treated area (except those persons involved in the incorporation)
until  the  incorporation is complete.  If the  incorporation is accomplished by
watering-in, do not enter or allow others to enter the treated area  until the surface
is dry following the watering-in."

Placement in Labeling:

If WPS uses are also  on label: Follow the instructions in PR Notice 93-7 for establishing
a Non-Agricultural Use Requirements box  and  place  the appropriate nonWPS entry
restriction in that box.

If no WPS uses are on label:  Add the appropriate nonWPS entry restriction to the labels
of all end-use  products, except products primarily  intended for homeowner  use, in a
section in the Directions For Use with the heading:  "Entry Restrictions:"
Products Primarily Intended for Home Use:

For liquid applications:


                                     57

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       "Do not enter or allow others to enter the treated area until sprays have dried."

       For granular applications:
       "Do not enter or allow others to enter the treated area until dusts have settled. If
       soil incorporation  is required following the application, do not enter or allow
       others to enter the treated area (except those persons involved in the incorporation)
       until the incorporation is complete.  If the incorporation is accomplished by
       watering-in, do not enter or allow others to enter the treated area until the surface
       is dry following the watering-in."

       Placement in Labeling:  Add the entry restriction to the labels of products primarily
       intended for homeowner use in a section in the Directions For  Use with the heading:
       "Entry Restrictions:"

                    (3)    Other Labeling Requirements

                    The Agency  is requiring the following statements  to be  located on all
metolachlor end-use product labeling intended primarily for occupational use:

              Application Restrictions:

              "Do not apply this product in a way that will contact workers or  other persons,
              either directly or through drift.  Only protected handlers may  be in the area during
              application."

              Engineering Controls:

              "Mixers  and loaders supporting aerial  applications are required to use closed
              systems. The closed system must be used  in a manner that meets the requirements
              listed in the Worker Protection Standard (WPS) for agricultural pesticides (40 CFR
              170.240(d)(4).  When using the closed system, the mixers' and loaders' PPE
              requirements may be reduced or modified as specified in the WPS."

              "When handlers use  closed systems, enclosed  cabs, or aircraft in a manner that
              meets the requirements listed in the Worker Protection  Standard  (WPS)  for
              agricultural pesticides (40 CFR 170.240(d) (4-6), the handler PPE requirements
              may be reduced or modified as specified in the WPS."
              User Safety Requirements:

              "Follow manufacturer's instructions for cleaning/maintaining PPE.  If no such
              instructions for washables, use detergent  and hot water.  Keep and wash PPE
              separately from other laundry."
                                           58

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       User Safety Recommendations:

       •      "Users should wash hands before eating, drinking, chewing gum, using
              tobacco, or using the toilet."

       •      "Users should remove clothing immediately if pesticide gets inside. Then
              wash thoroughly and put on clean clothing."

       •      "Users should remove PPE immediately after handling this product. Wash
              the outside  of gloves  before removing.  As  soon  as  possible, wash
              thoroughly and change into clean clothing."
       Skin Sensitizer Statement:

       In addition, because metolachlor is classified as a skin sensitizer, EPA is requiring
       the  following statement in the  "Hazards to Humans (and Domestic  Animals)"
       section of the Precautionary Statements on the labeling of all end-use products
       containing metolachlor:

       "This product may cause skin sensitization reactions in some people."
       Soil Incorporation Statement:

       Registrants may add the following statement to their labeling in the Agricultural
       Use Requirements box immediately following the restricted entry interval:

       "Exception: if the product is soil-incorporated, the Worker Protection Standard,
       under certain circumstances, allows workers to enter the treated area if there will
       be no contact with anything that has been treated."

       b.    Environmental Hazards Statements

       Do not apply directly to water, or to areas where surface water is present or to
intertidal areas below the mean  high-water mark.  Do not contaminate water when
disposing of equipment wash water or rinsate.

       General information section of label:

              "Do not apply under conditions which favor runoff or wind erosion of soil
             containing this product to non-target areas."

       To prevent off-site  movement due to run-off or wind erosion:


                                    59

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              "Avoid  treating powdery dry or light  sand soils when conditions  are
              favorable for wind erosion. Under these conditions, the soil surface should
              first be settled by rainfall or irrigation."

              "Do not apply to impervious substrates such as paved or highly compacted
              surfaces."

              "Do not use tailwater from the first flood or furrow irrigation of treated
              fields to treat non-target crops  unless at least 1/2 inch of rainfall  has
              occurred between application and the first irrigation."
       c.      Rotational Crops Restriction

              Do not rotate to food or feed crops other than those listed on this label.

       d.      Ground Water Labeling/Mitigation; Mixing/Loading

       The following label language regarding mixing/loading setbacks must appear in
Precautionary Statements in the Environmental Hazards section of the label:

       This product may not be mixed or loaded within 50 ft.  of perennial or intermittent
streams and rivers, natural or impounded lakes and reservoirs.  This product may not be
mixed/loaded or used within 50 ft. of all wells, including abandoned wells, drainage wells,
and sink holes.   Operations that involve  mixing, loading, rinsing, or washing of this
product into or from pesticide handling or application equipment or containers within 50
ft. of  any well  are  prohibited unless  conducted on an impervious pad constructed to
withstand the weight of the heaviest load that may be positioned on or moved  across the
pad.   Such a pad shall  be designed and maintained to contain any product spills or
equipment leaks,  container or equipment rinse or wash-water, and rain water that may fall
on the pad.  Surface water shall not be allowed to either flow over or from the pad, which
means the pad must be self-contained. The pad shall be sloped to facilitate material
removal.  An unroofed pad shall be of sufficient capacity to contain at a minimum 110%
of the capacity of the largest pesticide container or application equipment on the pad.  A
pad that is covered by a roof of sufficient  size to completely exclude precipitation from
contact with the pad shall have a minimum containment capacity of 100% of the capacity
of the largest pesticide container  or application equipment on the pad.   Containment
capacities as described above shall be maintained at all times.   The above-specified
minimum containment capacities  do not  apply to vehicles when delivering pesticide
shipments to the mixing/loading site.

       e.      Ground Water Advisory

              The following ground water advisory language must be placed on  all


                                     60

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metolachlor labels:

       "This chemical is known to leach through soil into ground water under
certain conditions as a result of agricultural use.  Use of this chemical in areas
where soils are permeable, particularly where the water table is shallow, may
result in ground-water contamination."

f.      Surface Water Advisory

       The following surface  water  advisory language must  be placed on all
metolachlor labels:

       "Metolachlor can contaminate surface  water through ground spray drift.
       Under some conditions, metolachlor may also have a high potential  for
       runoff into surface water (primarily via dissolution in runoff water),  for
       several months post-application.  These include poorly draining or wet soils
       with readily  visible slopes toward adjacent surface waters, frequently
       flooded areas, areas over-laying extremely  shallow ground water, areas
       with in-field canals or  ditches that drain  to surface water, areas  not
       separated from adjacent surface waters with vegetated filter strips, and
       areas over-laying tile drainage systems that drain to surface water."

g.      Spray Drift Labeling

The following language must be placed on each product label that can be applied
aerially:

Avoiding spray drift at the application site  is the responsibility of the applicator.
The  interaction of many equipment-and-weather-related factors determine  the
potential for spray drift.  The applicator and  the grower are responsible  for
considering all these factors when making decisions.

The following drift management requirements must be followed to avoid off-target
drift  movement  from aerial  applications  to  agricultural field  crops.   These
requirements  do not apply to  forestry applications, public health uses  or to
applications using dry formulations.

1.      The distance of the outer most nozzles on the boom must not exceed 3/4  the
length of the wingspan or rotor.

2.      Nozzles must always point backward  parallel with the air stream and never
be pointed  downwards more than 45 degrees.

Where states have more stringent regulations,  they should be observed.


                              61

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The  applicator should be familiar with and take into account the information
covered in the Aerial Drift Reduction Advisory Information.

The following aerial drift reduction advisory information must be contained in the
product labeling:

[This section is advisory in nature and does not supersede the mandatory label
requirements.]

INFORMATION ON DROPLET SIZE

The  most effective way to reduce drift potential is to apply large droplets.  The
best  drift management  strategy is to  apply  the largest  droplets that  provide
sufficient coverage and control.  Applying larger droplets reduces drift potential,
but  will not  prevent drift  if applications are made  improperly,  or under
unfavorable environmental conditions (see Wind, Temperature and Humidity, and
Temperature Inversions).

CONTROLLING  DROPLET SIZE

•      Volume - Use high flow rate nozzles to apply the highest practical spray
volume.  Nozzles with higher rated flows produce larger droplets.

•      Pressure -  Do  not  exceed the  nozzle  manufacturer's  recommended
pressures. For many nozzle types lower pressure produces larger droplets. When
higher flow rates are needed, use higher flow rate nozzles instead of increasing
pressure.

•      Number of nozzles - Use  the minimum  number of nozzles that  provide
uniform coverage.

•      Nozzle Orientation - Orienting nozzles so that the spray is released parallel
to  the airstream produces  larger  droplets than other  orientations and is  the
recommended practice. Significant deflection from horizontal will reduce droplet
size and increase drift potential.

•      Nozzle  Type  -  Use  a nozzle  type that is  designed  for the  intended
application.  With most nozzle types,  narrower spray angles produce larger
droplets.  Consider using low-drift nozzles. Solid stream nozzles oriented straight
back produce the largest droplets and the lowest drift.

BOOM LENGTH

For some use patterns, reducing the effective boom length to less than 3/4 of the


                             62

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wingspan or rotor length may further reduce drift without reducing swath width.

APPLICATION HEIGHT

Applications should not be made at a height greater than 10 feet above the top of
the largest plants  unless a greater height is required for aircraft safety.  Making
applications at the lowest height that is safe reduces exposure of droplets to
evaporation and wind.

SWATH ADJUSTMENT

When  applications are made with a  crosswind, the  swath will be displaced
downward. Therefore, on the up and downwind edges of the  field, the applicator
must compensate for this displacement by adjusting the path of the aircraft upwind.
Swath adjustment distance should increase, with increasing drift potential (higher
wind, smaller drops,  etc.)

WIND

Drift potential is lowest  between wind speeds of 2-10 mph.  However, many
factors, including droplet size and equipment type determine drift potential at any
given speed.  Application should be avoided below 2 mph due to variable wind
direction and high inversion potential.  NOTE:  Local terrain can influence wind
patterns.  Every applicator should be familiar with local wind patterns  and how
they affect spray drift.

TEMPERATURE AND HUMIDITY

When making applications in low relative humidity, set up equipment to produce
larger droplets to compensate for evaporation.  Droplet evaporation is most severe
when conditions are both hot and dry.

TEMPERATURE INVERSIONS

Applications should  not  occur  during a temperature  inversion because drift
potential is high. Temperature inversions restrict vertical  air mixing, which causes
small suspended droplets to remain in a concentrated cloud. This cloud can move
in unpredictable  directions due to the light variable winds common during
inversions. Temperature inversions are characterized by increasing temperatures
with altitude and are  common on nights with limited cloud cover and light to no
wind.  They begin to form as the sun sets and often continue into the morning.
Their presence can be indicated by ground fog; however, if fog is not present,
inversions can also be identified by the movement of smoke from a ground source
or an aircraft smoke generator.  Smoke that layers and moves laterally in a


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         concentrated cloud (under low wind conditions)  indicates  an inversion, while
         smoke that moves upward and rapidly dissipates indicates good vertical air mixing.

         SENSITIVE AREAS

         The pesticide should only be  applied when the potential for drift to  adjacent
         sensitive areas  (e.g.  residential  areas,  bodies  of water,  known habitat for
         threatened or endangered species, non-target crops) is minimal (e.g. when wind
         is blowing away from the sensitive areas).

C.       Existing Stocks

   Registrants may generally distribute and sell products bearing old labels/labeling for 26
months from  the date of the issuance of this Reregistration Eligibility Decision  (RED).
Persons other than the registrant may generally distribute or sell such products for 50 months
from the date of the issuance of this RED.  However, existing stocks  time frames will be
established case-by-case, depending on the number of products involved, the number of label
changes, and other factors. Refer to "Existing Stocks of Pesticide Products;  Statement of
Policy"; Federal Register, Volume 56,  No. 123, June 26, 1991.

   The Agency has determined that registrants may distribute and sell metolachlor products
bearing old labels/labeling for 26 months from the date  of issuance  of this RED.  Persons
other than the registrant may distribute or sell such products  for 50 months  from the date of
the issuance of this  RED. Registrants and persons other than registrants remain obligated to
meet pre-existing Agency imposed label changes and existing stocks requirements applicable
to products they sell  or distribute.
                                       64

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VI.  APPENDICES
       65

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66

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      APPENDIX A. Table of Use Patterns Subject to Reregistration

Appendix A is 63 pages long and is not being included.  Copies of Appendix A
       are available upon request per the instructions in Appendix D
                                 67

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68

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APPENDIX B. Table of the Generic Data Requirements
and Studies Used to Make the Reregistration Decision
                          69

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70

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                               GUIDE TO APPENDIX B
Appendix B contains listings of data requirements which support the reregistration for active
ingredients within the case Metolachlor covered by this Reregistration Eligibility Decision
Document. It contains generic data requirements that apply to Metolachlor in all products,
including data requirements for which a "typical formulation" is the test substance.

       The data table is organized in the following format:

       1.  Data Requirement (Column 1).  The data requirements are listed in the order in
which they appear in 40 CFR Part 158. the reference numbers accompanying each test refer
to the test protocols set in the Pesticide Assessment Guidelines, which are available from the
National Technical Information Service, 5285 Port Royal Road, Springfield, VA 22161 (703)
487-4650.

       2.  Use Pattern  (Column 2).  This  column indicates the use patterns for which the data
requirements apply.  The following letter  designations are used for the given use patterns:

                           A      Terrestrial food
                           B      Terrestrial feed
                           C      Terrestrial non-food
                           D      Aquatic food
                           E      Aquatic non-food outdoor
                           F      Aquatic non-food industrial
                           G      Aquatic non-food residential
                           H      Greenhouse food
                           I       Greenhouse non-food
                           J       Forestry
                           K      Residential
                           L      Indoor food
                           M     Indoor non-food
                           N      Indoor medical
                           0      Indoor residential

       3.  Bibliographic citation  (Column 3).  If the Agency has acceptable data in  its files,
this column lists the identifying number of each study.  This normally is the Master Record
Identification (MRID) number, but may be a "GS" number if no MRID number has been
assigned.  Refer to the  Bibliography appendix for a complete citation of the study.
                                          71

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72

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                      APPENDIX B
Data Supporting Guideline Requirements for the Reregistration of METOLACHLOR
REQUIREMENT
USE PATTERN
CITATION(S)
PRODUCT CHEMISTRY
61-1
61-2A
61-2B
62-1
62-2
62-3
63-2
63-3
63-4
63-5
63-6
63-7
63-8
63-9
63-10
63-11
63-12
63-13
63-14
Chemical Identity
Start. Mat. & Mnfg. Process
Formation of Impurities
Preliminary Analysis
Certification of limits
Analytical Method
Color
Physical State
Odor
Melting Point
Boiling Point
Density
Solubility
Vapor Pressure
Dissociation Constant
Octanol/Water Partition
PH
Stability
Oxidizing/Reducing Action
ALL
ALL
ALL
ALL
ALL
ALL
ALL
ALL
ALL

ALL
ALL
ALL
ALL
ALL
ALL
ALL
ALL
ALL
40276601
40276601
40276601
40276601
40276601
DATA GAP
40276602
40276602
40276602
N/A
40276602
40276602
40276602
40276602
40276602
40276602
40276602
40276602
40276602
                             73

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Data Supporting Guideline Requirements for the Reregistration of METOLACHLOR
REQUIREMENT
63-15
63-16
63-17
63-18
63-19
63-20
63-21
64-1
Flammability
Explodability
Storage stability
Viscosity
Miscibility
Corrosion characteristics
Dielectric breakdown volt
Submittal of Samples
USE PATTERN
ALL
ALL
ALL
ALL
ALL
ALL


CITATION(S)
40276602
40276602
40276602
40276602
40276602
40276602
N/A
N/A
ECOLOGICAL EFFECTS
71-1A
71-1B
71-2A
71-2B
71-3
71-4A
71-4B
71-5A
71-5B
72-1A
72-1B
Acute Avian Oral - Quail/Duck
Acute Avian Oral - Quail/Duck
TEP
Avian Dietary - Quail
Avian Dietary - Duck
Wild Mammal Toxicity
Avian Reproduction - Quail
Avian Reproduction - Duck
Simulated Field Study
Actual Field Study
Fish Toxicity Bluegill
Fish Toxicity Bluegill - TEP
A,B,C

A,B,C
A,B,C





A,B,C

00062465
N/A
00016425
00016426
N/A
DATA GAP
DATA GAP
N/A
N/A
00018722
N/A
                                     74

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       Data Supporting Guideline Requirements for the Reregistration of METOLACHLOR
REQUIREMENT
USE PATTERN
CITATION(S)
72-1C
72-1D
72-2A
72-2B
72-3A
72-3B
72-3C
72-3D
72-3E
72-3F
72-4A
72-4B
72-5
72-6
72-7A
72-7B
122-1A
Fish Toxicity Rainbow Trout
Fish Toxicity Rainbow Trout- TEP
Invertebrate Toxicity
Invertebrate Toxicity - TEP
Estuarine/Marine Toxicity - Fish
Estuarine/Marine Toxicity -
Mollusk
Estuarine/Marine Toxicity -
Shrimp
Estuarine/Marine Toxicity Fish-
TEP
Estuarine/Marine Toxicity Mollusk
-TEP
Estuarine/Marine Toxicity Shrimp
-TEP
Early Life Stage Fish
Life Cycle Invertebrate
Life Cycle Fish
Aquatic Organism Accumulation
Simulated Field - Aquatic
Organisms
Actual Field - Aquatic Organisms
Seed Germination/Seedling
Emergence
A,B,C 00018723
N/A
A,B,C 00015546
N/A
A,B,C 43044602
IN REVIEW
IN REVIEW
N/A
N/A
N/A
A,B,C 47025723
DATA GAP
N/A
N/A
N/A
N/A
N/A
                                            75

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Data Supporting Guideline Requirements for the Reregistration of METOLACHLOR
REQUIREMENT
12 2- IB Vegetative Vigor
122-2 Aquatic Plant Growth
123-1A Seed Germination/Seedling
Emergence
123- IB Vegetative Vigor
123-2 Aquatic Plant Growth
124-1 Terrestrial Field
124-2 Aquatic Field
141-1 Honey Bee Acute Contact
141-2 Honey Bee Residue on Foliage
141-5 Field Test for Pollinators
TOXICOLOGY
81-1 Acute Oral Toxicity - Rat
81-2 Acute Dermal Toxicity -
Rabbit/Rat
81-3 Acute Inhalation Toxicity - Rat
81-4 Primary Eye Irritation - Rabbit
81-5 Primary Dermal Irritation - Rabbit
81-6 Dermal Sensitization - Guinea Pig
81-7 Acute Delayed Neurotoxicity - Hen
82-1A 90-Day Feeding - Rodent
82- IB 90-Day Feeding - Non-rodent

USE PATTERN CITATION(S)
N/A
N/A
IN REVIEW
IN REVIEW
IN REVIEW
N/A
N/A
N/A
N/A
N/A
ALL 00015523
ALL 00015526
ALL 00015535
ALL 00015528
ALL 00015530
ALL 00015631
N/A
N/A
A,B 00017690,00032174
76

-------
        Data Supporting Guideline Requirements for the Reregistration of METOLACHLOR
REQUIREMENT
USE PATTERN
CITATION(S)
82-2        21-Day Dermal - Rabbit/Rat
82-3        90-Day Dermal - Rodent                   A,B
82-4        90-Day Inhalation - Rat
82-5A      90-Day Neurotoxicity - Hen
82-5B      90-Day Neurotoxicity - Mammal
83-1A      Chronic Feeding Toxicity - Rodent           A,B
83-IB      Chronic Feeding Toxicity - Non-             A,B
           Rodent
83-2A      Oncogenicity - Rat                        A,B
83-2B      Oncogenicity - Mouse                      A,B
83-3A      Developmental Toxicity - Rat               A,B
83-3B      Developmental Toxicity - Rabbit             A,B
83-4        2-Generation Reproduction - Rat            A,B
84-2A      Gene Mutation (Ames Test)                 ALL
84-2B      Structural Chromosomal                   ALL
           Aberration
84-4        Other Genotoxic Effects                   ALL
85-1        General Metabolism                       A,B
85-2        Dermal Penetration                        ALL
86-1        Domestic Animal Safety
OCCUPATIONAL/RESIDENTIAL EXPOSURE
132-1A     Foliar Residue Dissipation                  ALL
                 41833101
                 N/A
                 N/A
                 N/A
                 00001563,00042725,00084003,00117597
                 40980701

                 00129377,244166
                 000015634,00042725,00117597
                 00151941
                 00041283
                 00080897
                 00026712,00026713
                 00026712,00026713

                 43244003
                 40114401
                 41833102
                 N/A

                 41053901
                                                  77

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Data Supporting Guideline Requirements for the Reregistration of METOLACHLOR
REQUIREMENT
132- IB Soil Residue Dissipation
133-3 Dermal Passive Dosimetry
Exposure
133-4 Inhalation Passive Dosimetry
Exposure
231 Estimation of Dermal Exposure at
Outdoor Sites
232 Estimation of Inhalation Exposure
at Outdoor Sites
233 Estimation of Dermal Exposure at
Indoor Sites
234 Estimation of Inhalation Exposure
at Indoor Sites
ENVIRONMENTAL FATE
160-5 Chemical Identity
161-1 Hydrolysis
161-2 Photodegradation - Water
161-3 Photodegradation - Soil
161-4 Photodegradation - Air
162-1 Aerobic Soil Metabolism
162-2 Anaerobic Soil Metabolism
162-3 Anaerobic Aquatic Metabolism
162-4 Aerobic Aquatic Metabolism
USE PATTERN CITATION(S)
N/A
DATA GAP
N/A
N/A
N/A
N/A
N/A
N/A
A,B,C 40430201
A,B,C 40430202
A,B,C 40430203
N/A
A,B,C 41309801
A,C 41309801
A,B,C 41185701
N/A
                                     78

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	Data Supporting Guideline Requirements for the Reregistration of METOLACHLOR
 REQUIREMENT	USE PATTERN      CITATION(S)	
 163-1       Leaching/Adsorption/Desorption
 163-2       Volatility - Lab
 163-3       Volatility - Field
 164-1       Terrestrial Field Dissipation
 164-2       Aquatic Field Dissipation
 164-3       Forest Field Dissipation
 164-5       L°ng Term Soil Dissipation
 165-1       Confined Rotational Crop
 165-2       Field Rotational Crop
 165-3       Accumulation - Irrigated Crop
 165-4       Bioaccumulation in Fish
 165-5       Bioaccumulation - Aquatic
            NonTarget
 166-1       Ground Water - Small Prospective
 166-2       Ground Water - Small
            Retrospective
 166-3       Ground Water - Irrigated
            Retrospective
 201-1       Droplet Size Spectrum
 202-1       Drift Field Evaluation
 RESIDUE CHEMISTRY
                                        A,B,C
                                        A,B,C

                                        A,B,C
                                        A,B,C
                                        A,B,C
 171-4A
Nature of Residue - Plants
A,B
              40494602,40494603,40494604,40494605
              40494606
              N/A
              41309802,4148420106,413357016
              N/A
              N/A
              N/A
              41470601
              N/A
              N/A
              41154201
              N/A

              DATA GAP
N/A

RESERVED
RESERVED

42664302
                                                    79

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	Data Supporting Guideline Requirements for the Reregistration of METOLACHLOR

 REQUIREMENT	USE PATTERN      CITATION(S)	
 171-4B
Nature of Residue - Livestock
 171-4C     Residue Analytical Method - Plants
B
                                         A,B
00015423,00015424,
00015652,00015653,
00022872,00022873,
00022874,00022879,
00022880,00074898,
00074900,40766601
42644301,42652101

00015432,00015466,
00015543,00015698,
00016306,00039176,
00111693,00125227
 171-4D     Residue Analytical Method -
            Animal
                                         A,B
             00015432,00015466,
             00015543,00015698,
             00016306,00039176,
             00111693,00125227
 171-4E      Storage Stability
 171-4F      Magnitude of Residues - Potable
            H2O

 171-4G      Magnitude of Residues in Fish

 171-4H      Magnitude of Residues - Irrigated
            Crop

 171-41      Magnitude of Residues - Food
            Handling
                                         A,B
             42810601,41506501,41506491,40980702,40980
             703
             N/A
                                                       N/A

                                                       N/A


                                                       N/A
                                                    80

-------
	Data Supporting Guideline Requirements for the Reregistration of METOLACHLOR
 REQUIREMENT	USE PATTERN      CITATION(S)	
 171-4J      Magnitude of Residues -
            Meat/Milk/Poultry/Egg
 171-4K     Crop Field Trials
             N/A
            Root and Tuber Vegetables Group
             - Potatoes

             - Radishes grown for seed
            Bulb Vegetables (Allium spp.)
            Group
             - Onions
            Leafy Vegetables  (except Brassica
            vegetables) Group
             - Celery
            Brassica (cole) Leafy Vegetables
            Group
             - Cabbage
            Legume Vegetables (succulent or
            dried) Group
             - Beans (succulent and dried)
             - Peas (succulent and dried)
A
A
A
A
A
00105957, 00106191,
00109613
             none
43000101
             41551201
40644901
00064182, 00128731, 43295701
00064182, 00128731, 43295701
                                                    81

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	Data Supporting Guideline Requirements for the Reregistration of METOLACHLOR

 REQUIREMENT	USE PATTERN      CITATION(S)	
             - Soybeans
             - Lupine

            Foliage of Legume Vegetables

             - Bean vines and hay

             - Pea vines and straw

             - Soybean forage and hay
A


A

A

A
             00015399,
             00015401,
             00015405,
             00015409,
             00015541,
             00015721,
             00015726,
             00015735,
             00015761,
             00015765,
             00015769,
             00015773,
             00015779,
             00016604,
         00015400,
         00015402,
         00015406,
         00015410,
         00015542,
         00015722,
         00015727,
         00015736,
         00015762,
         00015766,
         00015770,
         00015774,
         00015780,
         00039174,
                                                                                     00015403,
                                                                                     00015407,
                                                                                     00015411,
                                                                                     00015706,
                                                                                     00015723,
                                                                                     00015728,
                                                                                     00015737,
                                                                                     00015763,
                                                                                     00015767,
                                                                                     00015771,
                                                                                     00015777,
                                                                                     00016248,
                                                                                     43178401
                   00015404,
                   00015408,
                   00015540,
                   00015719,
                   00015725,
                   00015729,
                   00015760,
                   00015764,
                   00015768,
                   00015772,
                   00015778,
                   00016427,
00128731,

00128731,

00015399,
00015403,
00015542,
00015722,
00015728,
00015733,
00015760,
00015764,
00015768,
00015772,
00015777,
43295701

43295701

00015400,
00015408,
00015706,
00015725,
00015729,
00015734,
00015761,
00015765,
00015769,
00015773,
00039174,
00015401,
00015540,
00015719,
00015726,
00015731,
00015736,
00015762,
00015766,
00015770,
00015774,
43178403
00015402,
00015541,
00015721,
00015727,
00015732,
00015737,
00015763,
00015767,
00015771,
00015775,
                                                     82

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	Data Supporting Guideline Requirements for the Reregistration of METOLACHLOR
 REQUIREMENT                               USE PATTERN      CITATION(S)
            Fruiting Vegetables (except
           cucurbits)
            Group
            - Peppers

            Stone Fruits Group
            Tree Nuts Group
            - Almonds, hulls
            Cereal Grains Group
            - Barley
            - Buckwheat
A

A
A
            00150180, 00156573,
            40557301
            40899301
            00131376
00078297
00078297
                                                  83

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	Data Supporting Guideline Requirements for the Reregistration of METOLACHLOR

 REQUIREMENT	USE PATTERN      CITATION(S)	
             - Corn, field and fresh
A
00015428, 00015429, 00015430, 00015570,
00015571, 00015572, 00015586, 00015587,
00015588, 00015589, 00015590, 00015591,
00015592, 00015593, 00015594, 00015595,
00015597, 00015598, 00015599, 00015600,
00015601, 00015602, 00015676, 00015677,
00015678, 00015679, 00015680, 00015681,
00015682, 00015683, 00015684, 00015685,
00015686, 00015687, 00015688, 00015689,
00015690, 00015691, 00015692, 00015693,
00015694, 00015704, 00015705, 00015707,
00015708, 00015709, 00015710, 00015711,
00015712, 00015713, 00015714, 00015715,
00015716, 00015717, 00015718, 00015739,
00015740, 00015741, 00015742, 00015743,
00015744, 00015745, 00015746,
00015747,00015748, 00015749, 00015750,
00015751, 00015752, 00015753, 00015754,
00015755, 00015756, 00015757, 00015786,
00015787, 00015950, 00015954, 00015955,
00016392, 00016393, 00016394, 00016395,
00016396, 00016397, 00016398, 00016399,
00016435, 00016436, 00016437, 43178401
                                                    84

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        Data Supporting Guideline Requirements for the Reregistration of METOLACHLOR
REQUIREMENT
USE PATTERN
CITATION(S)
            - Corn, field and fresh, continued
            - Millet
            -Milo
            - Oats
            -Rice
            -Rye
            - Sorghum
            - Wheat
           Forage, Fodder, and Straw of
           Cereal
            Grains Group
            - Barley, forage and straw
            - Buckwheat, forage and straw
            - Corn, forage and fodder
            - Millet, forage and straw
            - Milo, forage and straw
            - Oats, forage and straw
            - Rice, forage and straw
            - Rye, forage and straw
            - Sorghum, forage and fodder
     A
     A
     A
     A
     A
     A
     A
     A
     A
     A
     A
     A
     A
     A
     A
     A
     A
43178401
00078297
00078297
00078297
00078297
00078297
00015548, 00015549, 00015550, 00015551,
00015552, 00016607, 00016608, 00016609,
00016610, 00016990, 00016991, 00016992,
00111693
00078297
00078297
00078297
identical to corn grain
00078297
00078297
00078297
00078297
00078297
identical to sorghum grain
                                                   85

-------
        Data Supporting Guideline Requirements for the Reregistration of METOLACHLOR
REQUIREMENT
                                     USE PATTERN
             CITATION(S)
171-4L
            - Wheat, forage and straw
           Grass forage, fodder, and hay
           Group
           Non-grass Animal Feeds (forage,
            fodder, straw, and hay) Group
           Miscellaneous Commodities
            - Cotton, seed
            - Peanuts
 - Peanuts, forage and hay
 - Peanuts, hulls
 - Safflower, seed
Magnitude of the
 Residue in Processed Food/Feed
 - Beans (succulent and dried)
 - Corn, field
 - Corn, fresh
 - Cotton
 - Peanuts
 - Potato
 - Safflower
 - Sorghum,  grain
 - Sorghum,  sweet
                                          A
                                          A
A
A

A
A
A
                                                     A
                                                     A
                                                     A
                                                     A
                                                     A
                                                     A
                                                     A
                                                     A
                                                     A
             00078297
                                                      43367101
                                                      00065048, 00129058, 40980707, 43178402
                                                      00015553, 00015554, 00015555, 00015556,
                                                      00015557, 43263101
             40980705
             40980705
             40980707
             40980708
             40980704
                                                   86

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	Data Supporting Guideline Requirements for the Reregistration of METOLACHLOR
 REQUIREMENT                             USE PATTERN     CITATION(S)
           - Soybeans                            A          40980706, 41506501
                                              87

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-------
APPENDIX C.  Citations Considered to be Part of the Data
    Base Supporting the Reregistration of Metolachlor
                          89

-------
90

-------
                               GUIDE TO APPENDIX C

1.      CONTENTS OF BIBLIOGRAPHY.  This bibliography contains citations of all studies
       considered relevant by EPA in arriving at the positions and conclusions stated
       elsewhere in the Reregistration Eligibility Document. Primary sources for studies in
       this bibliography have been the body of data submitted to EPA and its predecessor
       agencies in support of past regulatory decisions. Selections from other sources
       including the published literature, in those instances where they have been considered,
       are included.

2.      UNITS OF ENTRY. The unit of entry in this bibliography is called a "study". In the
       case of published materials, this corresponds closely to an article. In the case of
       unpublished materials submitted to the Agency, the Agency has sought to identify
       documents at a level parallel to the published article from within the  typically larger
       volumes in which they were submitted. The resulting "studies" generally have a
       distinct title (or at least a single subject), can stand alone for purposes of review and
       can be described with a conventional bibliographic citation.  The Agency has also
       attempted to  unite basic documents and commentaries upon them, treating them as a
       single study.

3.      IDENTIFICATION OF ENTRIES.  The entries in this bibliography are sorted
       numerically by Master Record Identifier, or "MRID number".  This  number is unique
       to the citation, and should be used whenever a specific reference is required.  It is not
       related  to the six-digit "Accession Number" which has been used to identify volumes of
       submitted studies (see paragraph 4 (d) (4) below for further explanation).  In a few
       cases, entries added to the bibliography late in the review may be preceded by  a nine
       character temporary identifier. These  entries are listed after all MRID entries.  This
       temporary identifying number is also to be used whenever specific reference is needed.

4.      FORM OF ENTRY. In addition to the Master Record Identifier (MRID), each entry
       consists of a citation containing standard elements followed,  in the case of material
       submitted to  EPA, by a description of the earliest known submission. Bibliographic
       conventions used reflect the standard of the American National Standards Institute
       (ANSI), expanded to provide for certain special needs.

       a     Author.  Whenever the author could confidently be identified, the Agency has
             chosen to show a personal author.  When no individual was identified, the
             Agency has shown an identifiable laboratory or testing facility as the  author.
             When no author or laboratory could be identified, the Agency has shown the
             first submitter as the author.

       b.     Document date.  The date of the study is taken directly from the document.
             When the date is followed by a question mark, the bibliographer has deduced
             the date from the evidence contained in the document.  When the date appears


                                           91

-------
       as (19??), the Agency was unable to determine or estimate the date of the
       document.

c.      Title.  In some cases, it has been necessary for the Agency bibliographers to
       create or enhance a document title.  Any such editorial insertions are contained
       between square brackets.

d.      Trailing parentheses. For studies submitted to the Agency in the past, the
       trailing parentheses include (in addition to any self-explanatory text) the
       following elements describing the earliest known submission:

       (1)    Submission date.  The date of the earliest known submission appears
             immediately following the word "received."

       (2)    Administrative number.  The next element immediately following the
             word "under" is the registration number, experimental use permit
             number, petition number, or other administrative number associated
             with the earliest known submission.

       (3)    Submitter.  The third  element is the submitter.  When authorship is
             defaulted to the submitter, this element is omitted.

       (4)    Volume Identification (Accession Numbers).  The final element in the
             trailing parentheses identifies the EPA accession number of the volume
             in which the original submission  of the study appears.  The six-digit
             accession number follows the symbol "CDL," which stands for
             "Company Data Library." This accession number is in turn followed by
             an alphabetic suffix which shows the relative position of the study within
             the volume.
                                    92

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                               BIBLIOGRAPHY
MRID
CITATION
00001563     Parks, W.L.; Miller, W.  (1975) Final Report: Evaluation of a Urea Terrazole
             Fertilizer at Several Rates on Corn: Report No. 3068. (Unpublished study
             received Feb 4, 1977 under 1258-812; prepared by Univ. of Tennessee, Plant
             Science Dept., submitted  by Olin Corp., Agricultural Div., Little Rock, Ark.;
             CDL:095799-I)

00001663     Iwan, G.R. (1976) 01in-14C Terrazole Channel Catfish, Ictalurus
             punctatus(Rafinesque), Static Bioaccumulation Study. (Unpublished study
             received Oct 20, 1976 under 1258-812; prepared by Union Carbide Corp.,
             Aquatic Environmental Sciences, submitted by Olin Corp., Agricultural Div.,
             Little Rock, Ark.; CDL:228143-AB)

00015399     Seim, V.  (1975) Residue  Report: Soybeans: AG-A No. 3268 I,II,III.
             (Unpublished study received Jan 19, 1977 under 100-583; submitted by
             Ciba-Geigy Corp., Greensboro, N.C.; CDL:095747-A)

00015400     Peek, J.; Stahlberg, L.  (1975) Residue Report:  Soybeans: AG-A No. 3466 I,II.
             (Unpublished study received Jan 19, 1977 under 100-583; submitted by
             Ciba-Geigy Corp., Greensboro, N.C.; CDL: 095747-B)

00015401     Roper, J. (1975) Residue  Report: Soybeans: AG-A No. 3523 I,II,III.
             (Unpublished study received Jan 19, 1977 under 100-583; submitted by
             Ciba-Geigy Corp., Greensboro, N.C.; CDL:095747-C)

00015402     Juby, M.  (1975) Residue  Report: Soybeans: AG-A No. 3570 I,II,III.
             (Unpublished study received Jan 19, 1977 under 100-583; submitted by
             Ciba-Geigy Corp., Greensboro, N.C.; CDL:095747-D)

00015403     Pruss, S.; Ross, R.H. (1976) Residue Report: Soybeans: AG-A  No. 3650 III.
             (Unpublished study received Jan 19, 1977 under 100-583; submitted by
             Ciba-Geigy Corp., Greensboro, N.C.; CDL: 095747-E)

00015404     Peek, J.; Stahlberg, L.  (1976) Residue Report:  Soybeans: AG-A No. 3702 III.
             (Unpublished study received Jan 19, 1977 under 100-583; submitted by
             Ciba-Geigy Corp., Greensboro, N.C.; CDL: 095747-F)

00015405     Shriver, J.; Wendling, C. (1976) Residue Report: Soybeans: AG-A No. 3724
             III.  (Unpublished study including AG-A nos. 3742 II,  3743 II and 3747 II,
             received Jan 19, 1977 under 100-583; prepared in cooperation with Chemagro

                                         93

-------
                               BIBLIOGRAPHY
MRID
CITATION
             and E.I. du Pont de Nemours and Co., submitted by Ciba-Geigy Corp.,
             Greensboro, N.C.; CDL:  095747-G)

00015406     Gaspard, J. (1976) Residue Report: Soybeans: AG-A No. 3758 II.
             (Unpublished study received Jan 19, 1977 under 100-583; prepared  in
             cooperation with Chemagro, submitted by Ciba-Geigy Corp.,  Greensboro,
             N.C.; CDL:095747-K)

00015407     Westmoreland, W.G. (1976) Residue Report: Soybeans: AG-A No. 3764 II.
             (Unpublished study received Jan 19, 1977 under 100-583; prepared in
             cooperation with Chemagro, submitted by  Ciba-Geigy Corp., Greensboro,
             N.C.; CDL:095747-L)

00015408     Pruss, S.W.;  Schnappinger,  M.G. (1976) Residue Report: Soybeans: AG-A
             No. 3775 II.  (Unpublished study including AG-A no. 3776 II, received Jan
             19, 1977 under  100-583; prepared in cooperation with E.I. du Pont de
             Nemours and Co., submitted by Ciba-Geigy  Corp., Greensboro, N.C.;
             CDL:095747-M)

00015409     Peek, J.; Stahlberg, L. (1976) Residue Report: Soybeans: AG-A No. 3778  II.
             (Unpublished study including AG-A nos. 3780 II and  3782 II, received Jan  19,
             1977 under 100-583; prepared in cooperation with Chemagro and E.I. du Pont
             de Nemours and Co., submitted by Ciba-Geigy Corp., Greensboro, N.C.;
             CDL:095747-0)

00015410     Thomas, J.; Herman, D. (1976) Residue Report: Soybeans: AG-A  No. 3803
             II.  (Unpublished study including AG-A no. 3812 II,  re- ceived Jan 19, 1977
             under 100-583;  prepared in cooperation with E.I. du Pont de Nemours & Co.,
             submitted by  Ciba-Geigy Corp.,  Greensboro, N.C.;  CDL:095747-R)

00015411     Pruss, S.W.;  Luke, J.E. (1976)  Residue Report: Soybeans: AG-A No. 3885.
             (Unpublished study received Jan 19, 1977 under 100- 583; submitted by
             Ciba-Geigy Corp., Greensboro, N.C.; CDL:  095747-T)

00015423     Sumner, D.D.;  Thomas, R.D.; Cassidy, J.E. (1975)  Structure Elucidation of
             the Metabolites  of CGA-24705 in Corn: M4-68-2Y: Report No. GAAC-75012.
             (Unpublished study received Mar 26, 1975 under 5F1606; submitted by
             Ciba-Geigy Corp., Greensboro, N.C.; CDL:  094378-F)
                                        94

-------
                               BIBLIOGRAPHY
MRID
CITATION
00015424     Gross, D. (1974) Uptake, Translocation annd Degradation of CGA 24 705 in
             Corn Grown Under Controlled Conditions: Project Report No. 13/74:
             Addendum to Project Report No. 8/74.  (Unpublished study received Mar 26,
             1975 under 5F1606; prepared by Ciba-Geigy, Ltd., submitted by Ciba-Geigy
             Corp., Greensboro, N.C.;  CDL:094378-H)

00015428     Kincaid, L. (1975) Residue Report: Field Corn: AG-A No.  3383.  (Un-
             published study received Mar 26, 1975 under 5F1606; submitted by
             Ciba-Geigy Corp., Greensboro, N.C.;  CDL:094379-0)

00015429     Thomas, J.; Herman, D. (1975) Residue Report: Field Corn: AG-A No.  3501
             I,II.  (Unpublished study received Mar 26, 1975 under 5F1606; submitted by
             Ciba-Geigy Corp., Greensboro, N.C.;  CDL: 094379-P)

00015430     Kincaid, L. (1975) Residue Report: Sweet Corn: AG-A No. 3446.  (Un-
             published study received Mar 26, 1975 under 5F1606; submitted by
             Ciba-Geigy Corp., Greensboro, N.C.;  CDL:094379-T)

00015432     Ramsteiner, K.; Karlhuber, B. (1975) CGA 24705: Determination  of Total
             Residue in Material of Animal Origin.  Method no. REM 2/75  dated Feb 6,
             1975.  (Unpublished study received Mar 26,  1975  under 5F1606; prepared by
             Ciba-Geigy, Ltd., submitted by Ciba-Geigy Corp., Greensboro, N.C.;
             CDL:094379-AJ)

00015466     Aziz, S.A.; Ross, J.A. (1975) Analytical Method for the Determination of
             Residues of CGA-24705 Soybean Metabolites as CGA-37913 and CGA-49751
             by Acid Hydrolysis. Method no. AG-286 dated Jun  10,1975. (Unpublished
             study received Nov 25, 1975 under 6G1708; submitted by Ciba-Geigy Corp.,
             Greensboro, N.C.;  CDL:  094877-S)

00015523     Bathe, R. (1973)  Acute Oral LD50 of Technical CGA-24705 in the Rat: Project
             No. Siss 2979. (Unpublished study received Mar 1,  1974 under 5G1553;
             prepared by Ciba-Geigy, Ltd., submitted by  Ciba-Geigy Corp., Greensboro,
             N.C.; CDL:094220-B)

00015526     Bach, K.J. (1974) Acute Dermal LD50 Test  in  Rabbits: Contract No.
             120-2255-34.   (Unpublished study received on unknown date under 5G1553;
             prepared by Affiliated Medical Research, Inc.,  submitted by Ciba-Geigy
             Corp., Greensboro, N.C.; CDL:094220-E)

                                        95

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00015528     Sachsse, K. (1973) Irritation of Technical CGA-24705 in the Rabbit  Eye:
             Project No. Siss 2979.  (Unpublished study received Mar 1,  1974 under
             5G1553; prepared by Ciba-Geigy, Ltd., submitted by  Ciba-Geigy Corp.,
             Greensboro, N.C.; CDL:094220-G)

00015530     Sachsse, K. (1973) Skin Irritation in the Rabbit after Single Application of
             Technical CGA-24705: Project No. Siss 2979.  (Unpublished study received
             Mar 1, 1974 under 5G1553; prepared by  Ciba-Geigy, Ltd.,  submitted by
             Ciba-Geigy Corp., Greensboro, N.C.; CDL:094220-I)

00015535     Sachsse, K.; Ullmann, L. (1974) Acute Inhalation Toxicity of Technical
             CGA-24705 in the Rat: Project No. Siss 3516.  (Unpublished study received
             on unknown date under 5G1553; prepared by Ciba-Geigy,  Ltd., submitted by
             Ciba-Geigy Corp., Greensboro, N.C.;  CDL:094220-N)

00015540     Ross,  R.H. (1979) Metolachlor (Dual 8E); Chloramben  (Amiben 2E): AG-A
             No. 5173 I,II.  (Unpublished study including letter  dated May 8, 1979 from
             S.L. Harrison to Warren A. Davis, received Jun 20, 1979  under 100-583;
             prepared in cooperation with AM-CHEM Products, Inc. and Union Carbide
             Agricultural Products  Co.,  Inc., submitted by Ciba-Geigy Corp., Greensboro,
             N.C.;   CDL:238677-B)

00015541     Kern,  C.L. (1979) Metolachlor (Dual 8E); Chloramben  (Amiben 2SL):  AG-A
             No. 5218 I,II.  (Unpublished study including letter  dated May 8, 1979 from
             S.L. Harrison to Warren A. Davis, re-  ceived Jun 20, 1979  under 100-583;
             prepared in cooperation with AM-CHEM Products, Inc. and Union Carbide
             Agricultural Products  Co.,  Inc., submitted by Ciba-Geigy Corp., Greensboro,
             N.C.;  CDL: 238677-C)

00015542     Rose,  W.; Clapp, T.; Clapp, G. (1979) Metolachlor (Dual 8E); Chloramben
             (Amiben 2E):  AG-A No. 5341.  (Unpublished study including letter dated May
             8,  1979 from S.L. Harrison to Warren A.  Davis, received Jun 20, 1979 under
             100-583; prepared in cooperation with AM-CHEM Products, Inc. and Union
             Carbide Agricultural Products  Co., Inc.,  submitted by Ciba-Geigy Corp.,
             Greensboro, N.C.;  CDL:238677-D)

00015543     Cargile, N.L.; Ross, J.A. (1979) Analytical Method for  Residues of
             Metolachlor Plant Metabolites Determined as CGA-37913 and CGA- 49751
             after Acid Hydrolysis.  Method no. AG-338 dated Apr 23, 1979.

                                         96

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             (Unpublished study received Jun 20,  1979 under 100-583; submitted by
             Ciba-Geigy Corp., Greensboro, N.C.; CDL:238677-F)

00015546     Vilkas, A.G. (1976) Acute Toxicity of CGA-24705 Technical to the Water
             Flea,Daphnia magnaStraus. (Unpublished study received Nov 24, 1976 under
             100-587; prepared by Union Carbide Corp.,  submitted by Ciba-Geigy Corp.,
             Greensboro, N.C.;  CDL:226955-E)

00015548     Houseworth, L.D.; Rolla, H.  (1977) Residues of Metolachlor in or on
             Sorghum Resulting from Preplant Incorporated and Preemergence
             Applications: Report No. ABR-77086.  (Unpublished study received Nov 14,
             1977 under 8G2019; submitted by Ciba-Geigy Corp.,  Greensboro, N.C.;
             CDL:096625-A)

00015549     Ragsdale, D.; Peek, J. (1977) Residue Report:  Sorghum: AG-A  No. 4413
             Third Report.  (Unpublished study received Nov 14, 1977 under 8G2019;
             submitted by Ciba-Geigy Corp., Greensboro, N.C.; CDL:096626-A)

00015550     Thomas, J.; Herman, D.  (1977) Residue Report: Sorghum: AG-A  No. 4418
             Third Report.  (Unpublished study received Nov 14, 1977 under 8G2019;
             submitted by Ciba-Geigy Corp., Greensboro, N.C.; CDL:096626-B)

00015551     Turner, W.E. (1977) Residue Report: Sorghum: AG-A No.  4503 Third
             Report.  (Unpublished study received Nov 14, 1977 under 8G2019;  submitted
             by Ciba-Geigy Corp., Greensboro, N.C.; CDL:096626-C)

00015552     Holt, B.E. (1977) Residue Report: AG-A No. 4753.  (Unpublished  study
             received Nov 14, 1977 under 8G2019; submitted by Ciba-Geigy Corp.,
             Greensboro, N.C.;  CDL:096626-D)

00015553     Kahrs, R.A. (1979) Residues of Metolachlor in Peanuts Resulting from
             Preplant Incorporated or Preemergence Applications: Report No. ABR-79059.
             Summary of studies 098298-B, 098298-C, 098298-F,  098298-1 and 098298-J.
             (Unpublished study received May 18, 1979 under 100-583;  submitted by
             Ciba-Geigy Corp., Greensboro, N.C.;  CDL:098298-A)
                                        97

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00015554     Rose, W.; Coble, H. (1979) Metolachlor (Dual 8E), Naptalam + DNBP
             (Dyanap 3E): AG-A No. 4715 I,II.  (Unpublished study received May 18,
             1979 under 100-583; prepared in cooperation with IRDC,  submitted by
             Ciba-Geigy Corp., Greensboro, N.C.; CDL:098298-B)

00015555     Dill, R. (1979) Residue Report: Peanuts: AG-A No. 4742 II.  (Unpublished
             study received May 18, 1979 under 100-583; prepared in  cooperation with
             IRDC, submitted by Ciba-Geigy Corp., Greensboro, N.C.; CDL:098298-C)

00015556     McMahon, A. (1979) Residue Report: Peanuts: AG-A No. 4840 II.  (Un-
             published study received May 18,  1979 under 100-583; submitted  by
             Ciba-Geigy Corp., Greensboro, N.C.; CDL:098298-F)

00015557     McMahon, A. (1979) Metolachlor (Dual 8E): AG-A No. 4841 I,II.
             (Unpublished study received May  18, 1979 under 100-583; submitted by
             Ciba-Geigy Corp., Greensboro, N.C.; CDL:098298-I)

00015570     Taylor, D.; Shriver, J.; Guthrie, C.  (1976) Residue Report: Field Corn: AG-A
             No. 3372 II.  (Unpublished study received Jun 20,  1977 under 100-590;
             submitted by  Ciba-Geigy Corp., Greensboro, N.C.; CDL:230685-E)

00015571     Seim, V. (1976) Residue Report: Field Corn: AG-A No. 3674 II,III.
             (Unpublished study received Jun 20, 1977 under 100-590; submitted by
             Ciba-Geigy Coorp., Greensboro, N.C.; CDL:230685-G)

00015572     Chamberlain, E.;  Shriver, J.; Wendling, C. (1976) Residue Report:  Field
             Corn: AG-A NO.  3745 I,II,III. (Unpublished study received

00015572     Jun 20, 1977  under 100-590; submitted by Ciba-Geigy Corp.,  Greensboro,
             N.C.; CDL:230685-H)

00015586     Houseworth,  L.D. (1978) Residues of Metolachlor and Atrazine in or on Corn
             Resulting from the Application of Metolachlor, Metola- chlor/Atrazine Tank
             Mixes or a Metolachlor/Atrazine Pre-pack  through Center Pivot Irrigation
             Systems: Report No. ABR-78074. Summary of studies 235358-B through
             235358-J.  (Unpublished study received Oct 20, 1978 under 100-583;
             submitted by  Ciba-  Geigy Corp.,  Greensboro, N.C.; CDL:235358-A)
                                        98

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00015587     Stahlberg, L. (1978) Metolachlor (Dual 8E): AG-A No. 4870 I,  II.
             (Unpublished study received Oct 20, 1978 under 100-583; submitted by
             Ciba-Geigy Corp., Greensboro, N.C.; CDL:235358-B)

00015588     Turner, W.E.; Wiese, A.F. (1978) Metolachlor (Dual 8E): AG-A No. 4908
             I,II.  (Unpublished study received Oct 20, 1978 under 100-583; submitted by
             Ciba-Geigy Corp., Greensboro, N.C.; CDL:  235358-C)

00015589     Threewitt, T. (1978) Metolachlor  (Dual 8E): AG-A No. 4929 I,  II.
             (Unpublished study received Oct 20, 1978 under 100-583; submitted by
             Ciba-Geigy Corp., Greensboro, N.C.; CDL:235358-D)

00015590     Stahlberg, L. (1978) Metolachlor + Atrazine; Dual 8E + Aa- trex 4L: AG-A
             No. 4871 I,II. (Unpublished study received Oct 20,  1978 under 100-583;
             submitted by Ciba-Geigy Corp.,  Greensboro, N.C.; CDL:235358-E)

00015591     Stahlberg, L. (1978) Metolachlor + Atrazine (Bicep 4.5L): AG-A No.  4872
             I,II.  (Unpublished study received Oct 20, 1978 under 100-583; submitted by
             Ciba-Geigy Corp., Greensboro, N.C.; CDL:  235358-F)

00015592     Turner, W.E.; Wiese, A.F. (1978) Metolachlor + Atrazine, Dual 8E +
             Aatrex 4L: AG-A No. 4909 I,II.  (Unpublished study re- ceived Oct 20, 1978
             under 100-583; submitted by Ciba-Geigy  Corp., Greensboro, N.C.;
             CDL:235358-G)

00015593     Turner, W.E.; Wiese, A.F. (1978) Metolachlor + Atrazine (Bicep 4.5L):
             AG-A No. 4910 I,II.   (Unpublished study received Oct 20, 1978 under
             100-583; submitted by Ciba-Geigy Corp., Greensboro,  N.C.; CDL:235358-H)

00015594     Threewitt, T. (1978) Metolachlor  + Atrazine (Dual 8E + Aa- trex SOW):
             AG-A No. 4930 I,II.   (Unpublished study received  Oct 20, 1978 under
             100-583; submitted by Ciba-Geigy Corp., Greensboro, N.C.; CDL:235358-I)

00015595     Threewitt, T. (1978) Metolachlor  + Atrazine (Bicep 4.5L): AG-A  No.  4931
             I,II.  (Unpublished study received Oct 20, 1978 under 100-583; submitted by
             Ciba-Geigy Corp., Greensboro, N.C.; CDL:  235358-J)
                                        99

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00015597     Buchholz, C. (1978) Metolachlor (Dual 8E); Cyanazine (Bladex SOW): AG-A
             No. 4752 I,II. (Unpublished study received Oct 20,  1978 under 100-583;
             prepared in cooperation with Shell  Chemical Co., submitted by Ciba-Geigy
             Corp., Greensboro, N.C.;  CDL:235359-B)

00015598     Rose, W.; Monaco, T.  (1978) Metolachlor (Dual 8E); Cyanazine  (Bladex
             4WDS):  AG-A No. 4810.  (Unpublished study received Oct 20, 1978 under
             100-583; prepared  in cooperation with Shell Chemical Co., submitted by
             Ciba-Geigy Corp.,  Greensboro, N.C.;  CDL:235359-C)

00015599     Turner, W. (1978)  Metolachlor (Dual 8E); Cyanazine (Bladex SOW);
             Cyanazine (Bladex  4WDS):  AG-A No. 4864 I,II.  (Unpublished  study received
             Oct 20, 1978 under 100-583; prepared in coopera-  tion with Shell Chemical
             Co., submitted by Ciba-Geigy Corp.,  Greensboro, N.C.;  CDL:235359-D)

00015600     Stahlberg, L. (1978) Metolachlor (Dual 8E); Cyanazine (Bladex SOW):  AG-A
             No. 4875 I,II. (Unpublished study received Oct 20, 1978  under 100-583;
             prepared in cooperation with Shell Chemical Co.,  submitted by Ciba-Geigy
             Corp., Greensboro, N.C.; CDL:235359-E)

00015601     Clarkson, V.  (1978) Metolachlor (Dual 8E); Cyanazine (Bladex SOW):  AG-A
             No. 4972 I,II. (Unpublished study received Oct 20, 1978  under 100-583;
             prepared in cooperation with Shell Chemical Co.,  submitted by Ciba-Geigy
             Corp., Greensboro, N.C.; CDL:235359-F)

00015602     Wustner, D.A. (1978)  Metolachlor (Dual 8E);  Cyanazine (Bladex 4L): AG-A
             No. 6013.  (Unpublished study received Oct 20, 1978 under 100-583; prepared
             in cooperation with Shell Oil Co., submitted by Ciba-Geigy Corp.,
             Greensboro, N.C.;  CDL:  235359-G)

00015631     Sachsse,  K.; Ullmann, L.  (1977) Skin Sensitizing (Contact Allergenic) Effect in
             Guinea Pigs of Technical CGA 24705: Project  No. Siss 5726.  (Unpublished
             study received Jan  18,  1978 under  100-583; prepared by Ciba-Geigy, Ltd.,
             submitted by  Ciba-Geigy  Corp., Greensboro, N.C.; CDL:096717-F)

00015652     Sumner,  D.D.; Cassidy, J.E. (1974) The Metabolism of CGA-24705 in Corn:
             Report No. GAAC-74050.  (Unpublished study received Sep  26, 1974 under
             5G1553; submitted by  Ciba-Geigy Corp.,  Greensboro, N.C.; CDL:094217-D)
                                        100

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00015653     Gross, D. (1974) Uptake, Translocation and Degradation of CGA 24 705 in
             Corn Grown under Controlled Conditions: Project Report No. 8/74.
             (Unpublished study received Sep 26, 1974 under  5G1553; prepared by
             Ciba-Geigy, Ltd., submitted by Ciba-Geigy Corp.,  Greensboro, N.C.;
             CDL:094217-F)

00015676     Tharrington, W.H. (1974) Residue Report: Field  Corn: AG-A No. 2967.
             (Unpublished study received Sep 26, 1974 under 5G1553; submitted by
             Ciba-Geigy Corp., Greensboro, N.C.; CDL:094216-B)

00015677     Thetford, L.; Snow, J.G. (1974) Residue Report: Field Corn: AG-A No.
             2972.  (Unpublished study received Sep 26, 1974 under  5G1553; submitted by
             Ciba-Geigy Corp., Greensboro, N.C.; CDL:  094216-C)

00015678     Roper, J. (1974)  Residue Report: Field Corn:  AG-A No. 2982.  (Un-
             published study received Sep 26, 1974 under 5G1553; submitted by
             Ciba-Geigy Corp., Greensboro, N.C.; CDL:094216-D)

00015679     Schnappinger, M.G. (1974) Residue Report: Sweet Corn: AG-A No. 3005.
             (Unpublished study received Sep 26, 1974 under

00015679     5G1553; submitted by Ciba-Geigy Corp., Greensboro, N.C.; CDL:  094216-E)

00015680     Anliker, W. (1974) Residue Report: Sweet Corn: AG-A No. 3083.  (Un-
             published study received Sep 26, 1974 under 5G1553; submitted by
             Ciba-Geigy Corp., Greensboro, N.C.; CDL:094216-G)

00015681     Davidson, W.E.  (1974) Residue Report: Field Corn: AG-A  No.  3103.
             (Unpublished study received Sep 26, 1974 under 5G1553; submitted by
             Ciba-Geigy Corp., Greensboro, N.C.; CDL:094216-H)

00015682     Shriver, J.; Conterio, W.A.  (1974) Residue Report: Field Corn: AG-A No.
             3132.  (Unpublished study received Sep 26, 1974 under  5G1553; submitted by
             Ciba-Geigy Corp., Greensboro, N.C.; CDL:  094216-1)

00015683     Shriver, J.; Guthrie, C.A. (1974) Residue Report: Field Corn: AG-A  No.
             3137.  (Unpublished study received Sep 26, 1974 under  5G1553; submitted by
             Ciba-Geigy Corp., Greensboro, N.C.; CDL:  094216-J)
                                       101

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00015684    Fickle, J. (1974) Residue Report: Field Corn: AG-A No. 3141. (Un-
            published study received Sep 26, 1974 under 5G1553; submitted by
            Ciba-Geigy Corp., Greensboro, N.C.; CDL:094216-K)

00015685    Kincaid, L. (1974) Residue Report: Sweet Corn: AG-A No. 3153.  (Un-
            published study received Sep 26, 1974 under 5G1553; submitted by
            Ciba-Geigy Corp., Greensboro, N.C.; CDL:094216-L)

00015686    Ross, R.H. (1974) Residue Report: Field Corn: AG-A No. 3255.  (Un-
            published study received Sep 26, 1974 under 5G1553; submitted by
            Ciba-Geigy Corp., Greensboro, N.C.; CDL:094216-M)

00015687    Snow, J.G. (1974) Residue Report: Sweet Corn: AG-A No. 2974.  (Un-
            published study received Sep 26, 1974 under 5G1553; submitted  by
            Ciba-Geigy Corp., Greensboro, N.C.; CDL:094216-N)

00015688    Westmoreland, W.G. (1974) Residue Report: Field Corn: AG-A No. 3070.
            (Unpublished study received Sep 26, 1974 under 5G1553;  submitted by
            Ciba-Geigy Corp., Greensboro, N.C.; CDL: 094216-P)

00015689    Snow, J.G. (1974) Residue Report: Field Corn: AG-A No. 3288.  (Un-
            published study received Sep 26, 1974 under 5G1553; submitted by
            Ciba-Geigy Corp., Greensboro, N.C.; CDL:094216-Q)

00015690    Stahlberg, L.; Peek,  J. (1974) Residue Report: Field Corn: AG-A No. 3289.
            (Unpublished study received Sep 26, 1974 under 5G1553;  submitted by
            Ciba-Geigy Corp., Greensboro, N.C.; CDL: 094216-R)

00015691    Roper, J.; Thomas, J.; Herman, D. (1974) Residue Report: Field  Corn: AG-A
            No. 3298.  (Unpublished study received Sep 26,  1974  under 5G1553;
            submitted by Ciba-Geigy Corp., Greensboro, N.C.; CDL:094216-S)

00015692    Roper, J.; Thomas, J.; Herman, D. (1974) Residue Report: Field  Corn: AG-A
            No. 3299.  (Unpublished study received Sep 26,  1974  under 5G1553;
            submitted by Ciba-Geigy Corp., Greensboro, N.C.; CDL:094216-T)

00015693    Kern, C.L. (1974) Residue Report: Field Corn: AG-A No. 3325.  (Un-
            published study received Sep 26, 1974 under 5G1553; submitted by
            Ciba-Geigy Corp., Greensboro, N.C.; CDL:094216-U)

                                       102

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00015694    Juby, M. (1974) Residue Report: Field Corn: AG-A No. 3327.  (Unpub-
            lished study received Sep 26, 1974 under 5G1553; submitted by Ciba-Geigy
            Corp., Greensboro, N.C.;  CDL:094216-V)

00015698    Hormann, W.D.; Guth,  J.A.; Formica, G.; et al. (1974) CGA 24705:  Gas
            Chromatographic Determination of Total Residues in Material of Animal
            Origin (Provisional). Method no. REM 5/74 dated Jun 26, 1974.
            (Unpublished study received Sep 26,  1974 under 5G1553; prepared by
            Ciba-Geigy,  Ltd., submitted by Ciba-Geigy  Corp.,  Greensboro, N.C.;
            CDL:094216-Z)

00015704    Juby, M. (1974) Residue Report: Field Corn: AG-A No. 3328.  (Unpub-
            lished study received Sep 26, 1974 under 5G1553; submitted by Ciba-Geigy
            Corp., Greensboro, N.C.;  CDL:094216-AK)

00015705    Kern, C.L. (1974) Residue Report: Field Corn: AG-A No. 3326.  (Un-
            published study received Sep 26, 1974 under 5G1553; submitted by
            Ciba-Geigy Corp., Greensboro, N.C.; CDL:094216-AL)

00015706    Kahrs, R.A.  (1978) Summary: Residue Chemistry Data to Establish Tolerances
            for Residues of Metolachlor in Corn Forage and Fodder, Soybean Forage and
            Fodder, and  Fresh Corn, including Sweet Corn (Kernels plus Cobs, Husks
            Removed): Report No. ABR- 78028. Summary of studies 094216-B,
            094216-C, 094216-E through 094216-K, 094216-M, 094216-N, 094216-P
            through 094216-V, 094216-AK, 094216-AL,  094379-D, 094379-0, 094379-P,
            094379-T, 094379-AB,  097134-Q, 097134-S, 097134-X, 097134-AE through
            097134-AI, 097134-AO  through 097134-AT, 228126-E through 228126-H,
            228126-J,  230685-G, and 230685-H.   (Unpublished study received May 11,
            1978 under 100-583; submitted by Ciba-Geigy  Corp.,  greensboro,  N.C.;
            CDL:097133-A)

00015707    Snow, J.G.;  Tinklepaugh,  ? (1976) Residue Report:  Field Corn: AG-A  No.
            3799 II,III.  (Unpublished  study received May 11, 1978 under  100-583;
            submitted by Ciba-Geigy Corp., Greensboro, N.C.;  CDL: 097134-S)

00015708    Ross, R.H. (1978) Metolachlor (Dual 8E): AG-A No. 4855 I,II, Second
            Report.  (Unpublished study received May 11, 1978 under 100-583; submitted
            by Ciba-Geigy Corp., Greensboro, N.C.; CDL: 097134-AE)
                                       103

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00015709     Turner, W.E. (1978) Metolachlor (Dual 8E): AG-A No. 4860 I,II Second
             Report. (Unpublished study received May 11, 1978 under 100-583; submitted
             by Ciba-Geigy Corp., Greensboro, N.C.; CDL: 097134-AF)

00015710     Stahlberg, L. (1978) Metolachlor (Dual 8E): AG-A No. 4873 I,  II, 2nd
             Report. (Unpublished study received May 11, 1978 under 100-583; submitted
             by Ciba-Geigy Corp., Greensboro, N.C.; CDL: 097134-AG)

00015711     Turner, W.E. (1978) Metolachlor + Atrazine (Dual 8E + AAtrex 4L): AG-A
             No. 4861 I,II Second Report.  (Unpublished study received May  11, 1978
             under 100-583; submitted by Ciba- Geigy Corp., Greensboro, N.C.;
             CDL:097134-AH)

00015712     Stahlberg, L. (1978) Metolachlor +  Atrazine (Dual 8E + AAtrex 4L): AG-A
             No. 4874 I,II Second Report.  (Unpublished study received May  11, 1978
             under 100-583; submitted by Ciba- Geigy Corp., Greensboro, N.C.;
             CDL:097134-AI)

00015713     Buchholz, C. (1978) Metolachlor (Dual 8E): AG-A No. 4749 I, II.
             (Unpublished study received May  11, 1978 under 100-583; submitted by
             Ciba-Geigy Corp.,  Greensboro,  N.C.;  CDL:097134-AO)

00015714     Rose, W.E.; Monaco, T. (1978) Metolachlor (Dual 8E): AG-A No. 4806.
             (Unpublished study received May  11, 1978 under 100-583; submitted by
             Ciba-Geigy Corp.,  Greensboro,  N.C.;  CDL: 097134-AP)

00015715     Clarkson, V. (1978) Metolachlor (Dual 8E): AG-A No. 4974.  (Unpublished
             study received May 11,  1978 under 100-583; submitted by Ciba-Geigy Corp.,
             Greensboro, N.C.;  CDL:097134-AQ)

00015716     Buchholz, C. (1978) Metolachlor +  Atrazine (Dual 8E) + (AAtrex SOW):
             AG-A No. 4748 I,  II. (Unpublished study received May 11, 1978 under
             100-583; submitted by Ciba-Geigy Corp., Greensboro, N.C.;
             CDL:097134-AR)

00015717     Rose, W.; Monaco, T. (1978) Metolachlor + Atrazine (Dual 8E)  +  (AAtrex
             4L): AG-A No. 4807.  (Unpublished study received May 11, 1978 under
             100-583; submitted by Ciba-Geigy Corp.,  Greensboro, N.C.;
             CDL:097134-AS)

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00015718     Clarkson, V. (1978) Metolachlor, Atrazine (Dual 8E, AA-  trey SOW): AG-A
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             submitted by Ciba-Geigy Corp., Greens- boro,  N.C.;  CDL:097134-AT)

00015719     Ross, R.H.; Pruss, S. (1976) Residue Report: Soybeans: AG-A No. 3650 I,II.
             (Unpublished study received May 11, 1978 under  100-583; submitted by
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00015721     Shriver, J.; Wendling, C. (1976) Residue Report:  Soybeans: AG-A No. 3747
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00015722     Pruss, S.; Schnappinger, M.G. (1976) Residue Report: Soybeans: AG-A No.
             3775 II.  2nd report.  (Unpublished study received May 11,  1978 under
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00015723     Peek, J.; Stahlberg, L. (1976) Residue Report: Soybeans: AG-A No. 3782.
             (Unpublished study received May 11, 1978 under  100-583; submitted by
             Ciba-Geigy Corp., Greensboro, N.C.; CDL:097135-F)

00015725     Pruss, S.W.; Luke, J.E.  (1976) Residue Report: Soybeans: AG-A No. 3885.
             2nd Report.   (Unpublished study received May 11, 1978 under 100-583;
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00015726     Richards, R.F. (1976) Residue Report: Soybeans:  AG-A No. 3948. 2nd
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00015727     Shriver, J.; Wendling, C. (1976) Residue Report:  Soybeans: AG-A No. 3743.
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00015728     Schnappinger, M.G.; Pruss, S.W. (1976) Residue Report: Soybeans: AG-A
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             submitted by Ciba-Geigy Corp.,  Greensboro, N.C.; CDL:097135-K)

00015729     Peek, J.; Stahlberg, L. (1976) Residue Report: Soybeans: AG-A No. 3780.
             (Unpublished study received May 11, 1978 under 100- 583;  submitted by
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00015731     Shriver, J.; Wendling, C. (1977) Residue Report: Soybeans: AG-A  No. 3742.
             (Unpublished study received May 11, 1978 under 100-  583; prepared in
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00015732     Gaspard, J.T. (1977) Residue Report: Soybeans: AG-A No. 3758.
             (Unpublished study received May 11, 1978 under 100-583; prepared in
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00015733     Westmoreland, W.G. (1977) Residue Report: Soybeans: AG-A No. 3764.
             (Unpublished study received May 11, 1978 under 100-583; prepared  in
             cooperation with Mobay Chemical Corp. and Analytical Biochemistry
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00015734     Peek, J.; Stahlberg, L. (1977) Residue Report: Soybeans: AG-A No. 3778.
             (Unpublished study received May 11, 1978 under 100-  583; prepared in
             cooperation with Mobay Chemical Corp. and Ana-  lytical Biochemistry
             Laboratories, submitted by Ciba-Geigy  Corp., Greensboro, N.C.;
             CDL:097135-R)

00015735     Luke, J.  (1978) Metolachlor (Dual 8E): AG-A No. 4737 I,II.  (Unpublished
             study received May 11, 1978 under 100-583; sub-  mitted by Ciba-Geigy
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00015736     Kern, C. (1978) Metolachlor (Dual 8E): AG-A No. 4781 I,II. (Unpublished
             study received May 11, 1978 under 100-583; sub-  mitted by Ciba-Geigy
             Corp., Greensboro, N.C.;  CDL:097135-U)

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00015737     Herman, D. (1978) Metolachlor (Dual 8E): AG-A No. 4986 I,II. (Unpublished
             study received May 11, 1978 under 100-583; sub-  mitted by Ciba-Geigy
             Corp., Greensboro, N.C.;  CDL:097135-V)

00015739     Chamberlain, E.; Stahlberg, L. (1978) Metolachlor (Dual 8E); Atrazine
             (AAtrex SOW & 4L): AG-A No. 4790 I,II,III.  (Unpublished study received
             Mar 16, 1979 under 100-583; prepared in coopera-  tion with EN-CAS
             Laboratories, submitted by Ciba-Geigy Corp.,  Greensboro, N.C.;
             CDL:237817-B)

00015740     Luke, J.E. (1978) Metolachlor  (Dual 8E); Atrazine  (AAtrex SOW +4L): AG-A
             No. 4811 I,II,III. (Unpublished study received Mar 16, 1979 under 100-583;
             prepared in cooperation with EN-CAS An- alytical  Laboratories, submitted by
             Ciba-Geigy Corp., Greens- boro, N.C.; CDL:237817-C)

00015741     Turner, W.E.  (1978) Metolachlor (DualSE); Atrazine (AAtrex 4L): AG-A No.
             4862 I,II.  (Unpublished study received Mar 16,  1979 under 100-583; prepared
             in cooperation with Texas  Agricultural Experiment Station and EN-CAS
             Analytical Laborato-  ries,  submitted by Ciba-Geigy Corp., Greensboro, N.C.;
             CDL:  237817-D)

00015742     Dorr, J.; Buchholz, C. (1978) Metolachlor (Dual 6E); Atrazine (AAtrex 4L):
             AG-A No. 4750 I,II. (Unpublished study received Mar  16, 1979 under
             100-583; prepared in cooperation with EN-CAS An- alytical Laboratories,
             submitted by Ciba-Geigy Corp., Greens-  boro, N.C.; CDL:237817-E)

00015743     Chamberlain, E.; Stahlberg, L. (1978) Metolachlor (Dual 8E);  Atrazine
             (AAtrexSOW): AG-A No. 4791. (Unpublished study received Mar 16, 1979
             under 100-583; prepared in cooperation with EN-CAS Analytical Laboratories,
             submitted by Ciba-Geigy  Corp., Greensboro, N.C.; CDL:237817-F)

00015744     Rose, W.; Monaco, T. (1978) Metolachlor (Dual 8E); Atrazine (AAtrex 4L):
             AG-A No. 4808. (Unpublished study received Mar  16,  1979 under 100-583;
             prepared in cooperation with EN-CAS Analyti- cal  Laboratories, submitted by
             Ciba-Geigy Corp., Greensboro, N.C.; CDL:237817-G)

00015745     Chamberlain, E.; Stahlberg, L. (1978) Metolachlor + Atrazine (Bicep 4.5L):
             AG-A No. 4792 I,II,III.  (Unpublished study received Mar 16, 1979 under
             100-583; prepared in cooperation with EN-CAS Analytical Laboratories,

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             submitted by Ciba-Geigy Corp., Greensboro, N.C.; CDL:237817-H)

00015746     Luke, J.E. (1978) Metolachlor + Atrazine (Bicep 4.5L): AG-A No. 4812
             I,II,III.  (Unpublished study received Mar 16, 1979 under 100-583; prepared
             in cooperation with EN-CAS Analytical  Laboratories, submitted by Ciba-Geigy
             Corp., Greensboro,  N.C.;  CDL:237817-I)

00015747     Turner, W.E. (1978) Metolachlor + Atrazine (Bicep 4.5L): AG-A No. 4863
             I,II.  (Unpublished study received Mar 16, 1979 under  100-583; prepared in
             cooperation with Texas Agricultural Experiment Station and EN-CAS
             Analytical Laboratories, submitted by Ciba-Geigy Corp., Greensboro, N.C.;
             CDL:237817-J)

00015748     Dorr, J.; Buchholz,  C. (1978) Metolachlor +  Atrazine (Bicep  4.5L): AG-A
             No. 4751 I,II.  (Unpublished study received Mar 16,  1979 under 100-583;
             prepared in cooperation with EN-CAS Analytical Laboratories, submitted by
             Ciba-Geigy Corp., Greensboro, N.C.; CDL:237817-K)

00015749     Chamberlain, E.; Stahlberg, L. (1979) Metolachlor + Atrazine (Bicep 4.5L):
             AG-A No. 4793 A.  (Unpublished study received Mar 16, 1979 under
             100-583; prepared in cooperation with EN-CAS Analytical Laboratories,
             submitted by Ciba-Geigy Corp., Greens- boro, N.C.; CDL:237817-L)

00015750     Rose, W.; Monaco, T. (1978) Metolachlor +  Atrazine (Bicep 4.5L):  AG-A
             No. 4809. (Unpublished study received  Mar 16, 1979 under  100-583;
             prepared in cooperation with EN-CAS Analytical Laboratories, submitted by
             Ciba-Geigy Corp., Greensboro, N.C.; CDL:  237817-M)

00015751     Rose, W.; Worsham, D.; Slagowski, J.L. (1978) Metolachlor  (Dual 8E);
             Atrazine (AAtrex SOW); Paraquat (Paraquat  CL):  AG-A No. 4959 I,II.
             (Unpublished study received Mar 16,  1979 under 100-583; prepared in
             cooperation with EN-CAS Labora-  tories and Chevron Chemical Co.,
             submitted by Ciba-Geigy Corp., Greensboro, N.C.; CDL:237819-F)

00015752     Kern, C.L.; Staniforth, D.; Slagowski, J.L. (1978) Metolachlor (Dual 8E);
             Atrazine (AAtrex SOW or 4L); Paraquat  (Paraquat CL): AG-A No. 5000 I,II.
             (Unpublished study received  Mar 16, 1979 under 100-583; prepared in
             cooperation with Iowa  State Univ., EN-CAS Laboratories and Chevron
             Chemical Co., sub-  mitted by Ciba-Geigy Corp., Greensboro, N.C.;

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00015753     Schnappinger, M.G. (1979) Metolachlor (Dual 8E); Atrazine (AAtrex SOW);
             Glyphosate (Roundup 4E):  AG-A No. 4888  I,II.  (Unpublished study received
             Mar 16,  1979 under 100-583;  prepared in cooperation with EN-CAS
             Laboratories and ADC Laboratories, submitted by Ciba-Geigy Corp.,
             Greensboro, N.C.; CDL: 237819-1)

00015754     Rose, W.; Worsham, D. (1979) Metolachlor (Dual 8E); Atrazine  (AAtrex
             SOW); Glyphosate (Roundup 4E): AG-A No. 4960 I,  II.  (Unpublished study
             received Mar 16, 1979 under 100-583;  prepared in cooperation with EN-CAS
             Laboratories and ADC Laboratories, submitted by Ciba-Geigy Corp.,
             Greensboro, N.C.; CDL: 237819-J)

00015755     Searcy, S.; Herman, D.  (1979) Metolachlor (Dual 8E); Atrazine (AAtrex 4L);
             Glyphosate (Roundup 4E):  AG-A No. 4983  I,  II.  (Unpublished study received
             Mar 16,  1979 under 100-583;  prepared in cooperation with EN-CAS
             Laboratories and ADC Laboratories, submitted by Ciba-Geigy Corp.,
             Greensboro, N.C.; CDL: 237819-K)

00015756     Kern, C.L.; Staniforth, D.  (1979) Metolachlor (Dual  8E); Atrazine  (AAtrex
             SOW or 4L);  Glyphosate (Roundup 4E): AG-A No. 4999 I,  II.  (Unpublished
             study received Mar 16, 1979 under 100-583; prepared in cooperation with
             Iowa State Univ., EN-CAS Labora- tories and ADC  Laboratories, submitted
             by Ciba-Geigy Corp.,  Greensboro, N.C.; CDL:237819-L)

00015757     Dorr, J.; Buchholz, C. (1979)  Metolachlor (Dual 8E); Atrazine (AAtrex 4L);
             Glyphosate (Roundup 4E):  AG-A No. 5004. (Unpublished study received Mar
             16, 1979 under 100-583; prepared in  cooperation with EN-CAS Laboratories
             and ADC Laboratories, submitted by Ciba-Geigy Corp.,  Greensboro, N.C.;
             CDL:237819-M)

00015760     Kincaid, L. (1979) Metolachlor + Glyphosate  + Linuron; Dual 8E  +
             Roundup 4E  +  Lorox SOW: AG-A No. 4763 I,II.  (Unpublished study
             including letter  dated May 23,  1978 from J.D.  Riggleman to Robert A. Kahrs,
             received Mar 16, 1979 under 100-583; prepared in cooperation with E.I. du
             Pont de Nemours & Co., Inc. and ADC  Laboratories, submitted by
             Ciba-Geigy Corp., Greensboro, N.C.; CDL:237821-B)
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00015761     Schnappinger, M.G. (1979) Metolachlor + Glyphosate + Linuron; Dual  8E +
             Roundup 4E  + Lorox SOW: AG-A No. 4886 I,II.  (Unpublished  study
             including letter dated May 23, 1978 from J.D. Riggleman to  Robert A. Kahrs,
             received Mar 16,  1979 under 100-583; prepared in cooperation with E.I. du
             Pont de Nemours  & Co., Inc. and ADC  Laboratories, submitted by
             Ciba-Geigy Corp., Greensboro, N.C.: CDL:237821-C)

00015762     Searcy, V.; Herman, D. (1979) Metolachlor + Glyphosate + Linuron; Dual
             8E + Roundup 4E +  Lorox SOW: AG-A No. 4893 I,II.  (Unpublished study
             including letter dated May 23, 1978 from J.D. Rig- gleman to Robert A.
             Kahrs, received Mar 16, 1979 under 100-583; prepared in cooperation with
             E.I. du Pont de Nemours & Co.,  Inc. and ADC Laboratories, submitted by
             Ciba-Geigy Corp., Greensboro, N.C.; CDL:237821-D)

00015763     Rose, W.;  Worsham, D. (1979) Metolachlor  + Glyphosate + Linuron;  Dual
             8E + Roundup 4E +  Lorox SOW: AG-A No. 4956 I,II A.  (Unpublished study
             including letter dated May 23, 1978 from J.D. Rig- gleman to Robert A.
             Kahrs, received Mar 16, 1979 under 100-583; prepared in cooperation with
             Rocky Mount Experiment Station, ADC  Laboratories and E.I. du Pont de
             Nemours & Co., Inc., submitted  by Ciba-Geigy Corp.,  Greensboro, N.C.;
             CDL:237821-E)

00015764     Kincaid, L. (1979) Metolachlor (Dual 8E); Glyphosate (Roundup  4E);
             Metribuzin (Sencor SOW): AG-A No. 4765 I,II.  (Unpublished study including
             letter dated May 23, 1978 from J.D. Riggleman to Robert A. Kahrs, received
             Mar 16, 1979 under 100-583; prepared in cooperation with ADC Laboratories
             and E.I. du Pont de Nemours  & Co.,  Inc., submitted by Ciba-Geigy Corp.,
             Greensboro, N.C.;  CDL:237821-F)

00015765     Schnappinger, M.G. (1978) Metolachlor (Dual 8E); Glyphosate (Round- up
             4E); Metribuzin (Sencor SOW): AG-A No. 4887 I,II.  (Unpublished study
             including letter dated May 23, 1978 from J.D. Riggleman to Robert Kahrs,
             received Mar 16,  1979 under 100-583;  prepared in cooperation with ADC
             Laboratories  and E.I. du Pont de Nemours & Co., Inc., submitted by
             Ciba-Geigy Corp., Greens-  boro, N.C.; CDL:237821-G)

00015766     Searcy, S.; Herman, D. (1979) Metolachlor (Dual 8E); Glyphosate (Roundup
             4E); Metribuzin (Sencor SOW): AG-A No. 4895 I,II.  (Unpublished study
             including letter dated May 23, 1978 from J.D. Riggleman to Robert A. Kahrs,

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             Laboratories and E.I. du Pont de Nemours & Co., Inc., submitted by
             Ciba-Geigy Corp.,  Greensboro, N.C.; CDL:237821-H)

00015767     Rose, W.; Worsham, D. (1979) Metolachlor  (Dual 8E); Glyphosate (Roundup
             4E); Metribuzin (Sencor SOW): AG-A No. 4958 I,II A.  (Unpublished study
             including letter dated May 23, 1978 from J.D.  Riggleman to Robert A. Kahrs,
             received Mar 16, 1979 under 100-  583; prepared in cooperation with ADC
             Laboratories and E.I. du Pont de Nemours & Co., Inc., submitted by
             Ciba-Geigy Corp.,  Greensboro, N.C.; CDL:237821-I)

00015768     Kincaid, L.; Slagowski, J.L. (1978) Metolachlor + Linuron +  Para- quat;
             Dual 8E + Lorox SOW + Paraquat 2CL:  AG-A No. 4762 I,II.  (Unpublished
             study including letter dated May 23, 1978 from  J.D. Riggleman to Robert A.
             Kahrs, received Mar  16, 1979 under 100- 583; prepared in cooperation with
             Chevron Chemical  Co. and E.I.  du Pont de Nemours & Co., Inc., submitted
             by Ciba-Geigy Corp., Greensboro, N.C.; CDL:237821-J)

00015769     Searcy, V.; Herman, D.; Slagowski, J.L.  (1978) Metolachlor + Linuron +
             Paraquat: Dual 8E  + Lorox SOW + Paraquat 2CL: AG-A  No. 4892 I,II.
             (Unpublished study including letter dated  May  23, 1978 from J.D. Riggleman
             to Robert A. Kahrs, received Mar 16, 1979 under 100-583; prepared in
             cooperation with Chevron Chemical Co. and E.I. du Pont de Nemours & Co.,
             Inc., submitted by Ciba-Geigy Corp., Greensboro, N.C.; CDL:237821-L)

00015770     Schnappinger, M.G.; Slagowski, J.L. (1978)  Metolachlor + Linuron +
             Paraquat (Dual 8E  + Lorox SOW + Paraquat 2CL): AG-A No. 4915 I,  II.
             (Unpublished study including letter dated May 23, 1978 from J.D. Riggleman
             to Robert A. Kahrs, received Mar 16, 1979 under  100-583; prepared in
             cooperation with Chevron Chemical Co. and  E.I. du Pont de Nemours & Co.,
             Inc., submitted by  Ciba-Geigy  Corp., Greensboro, N.C.; CDL:237821-L)

00015771     Rose, W.; Worsham, D.; Slagowski, J.L. (1978) Metolachlor + Linuron +
             Paraquat: Dual 8E  + Lorox SOW + Paraquat 2CL: AG-A  No. 4955 I,II.
             (Unpublished study including letter dated May  23, 1978 from J.D. Riggleman
             to Robert A. Kahrs, received Mar  16, 1979 under 100-583; prepared in
             cooperation with Rocky Mount Experiment Station, Chevron Chemical Co.
             and  E.I. du Pont de Nemours & Co., Inc., submitted by Ciba-Geigy Corp.,
             Greensboro,  N.C.; CDL:237821-M)

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00015772     Kincaid, L.; Slagowski, J.L. (1978) Metolachlor (Dual 8E);  Metribuzin
             (Sencor SOW); Paraquat (2C1): AG-A No. 4764 I,II.  (Unpublished study
             including letter dated May 23, 1978 from J.D. Riggleman to Robert A. Kahrs,
             received Mar 16,  1979 under  100-583; prepared in cooperation with E.I. du
             Pont de Nemours  &  Co., Inc. and Chevron Chemical Co., submitted by
             Ciba-Geigy Corp., Greensboro, N.C.; CDL:237821-M)

00015773     Searcy, S.; Herman,  D.; Slagowski, J.L. (1978)  Metolachlor  (Dual 8E);
             Metribuzin (Sencor SOW); Paraquat (2C1): AG-A No. 4894 I,II.  (Unpublished
             study including letter dated  May 23, 1978 from J.D.  Riggleman to Robert A.
             Kahrs, received Mar 16, 1979 under 100-583; prepared in cooperation with
             E.I. du Pont de Nemours & Co., Inc.  and Chevron Chemical Co., submitted
             by Ciba-Geigy Corp., Greensboro, N.C.; CDL:237821-0)

00015774     Schnappinger, M.G.; Slagowski, J.L.  (1978) Metolachlor (Dual  8E);
             Metribuzin (Sencor SOW); Paraquat (2 Cl): AG-A No. 4916 I, II.
             (Unpublished study including letter dated May 23, 1978 from J.D. Riggleman
             to Robert A. Kahrs, received Mar 16,  1979 under  100-583; prepared in
             cooperation with E.I. du Pont de Nemours & Co., Inc. and Chevron Chemical
             Co., submitted by Ciba-Geigy Corp.,  Greensboro, N.C.; CDL:237821-P)

00015775     Rose, W.; Worsham, D.; Slagowski, J.L. (1978) Metolachlor (Dual 8E);
             Metribuzin (Sencor SOW); Paraquat (Cl): AG-A No.  4957 I,II.  (Unpublished
             study including letter dated May 23, 1978 from J.D.  Riggleman to Robert A.
             Kahrs, received Mar  16, 1979 under 100-583; prepared in cooperation with
             E.I. du Pont de Nemours & Co., Inc. and Chevron Chemical Co., submitted by
             Ciba-Geigy Corp., Greensboro, N.C.;  CDL:237821-Q)

00015777     Stahlberg, L. (1978) Metolachlor  (Dual 8E);  Naptalam +  DNBP (Dya nap 3E):
             AG-A No.  4728 I,II. (Unpublished study received Mar 16, 1979 under
             100-583; prepared in cooperation with Biospher- ics, Inc. for Uniroyal
             Chemical Co., submitted by Ciba-Geigy Corp., Greensboro, N.C.;
             CDL:237822-B)

00015778     Herman, D. (1978) Metolachlor (Dual 8E); Naptalam + DNBP (Dyanap 3E):
             AG-A No.  4896 I,II. (Unpublished study received Mar 16, 1979 under
             100-583; prepared in cooperation with Biospherics, Inc. for Uniroyal Chemical
             Co., submitted by Ciba-  Geigy Corp., Greensboro, N.C.; CDL:237822-C)
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00015779     Schnappinger, M.G. (1978) Metolachlor (Dual 8E); Naptalam +  DNBP
             (Dyanap 3E): AG-A No. 4934 I,II.  (Unpublished study received Mar 16, 1979
             under 100-583; prepared in cooperation with  Biospherics, Inc. for Uniroyal
             Chemical Co., submitted by Ciba-  Geigy Corp., Greensboro, N.C.;
             CDL:237822-D)

00015780     Dill, R. (1978) Metolachlor (Dual 8E); Naptalam + DNBP (Dyanap 3E):
             AG-A No. 5053.  (Unpublished study received Mar 16,  1979 under  100-583;
             prepared in cooperation with Biospherics, Inc. for Uniroyal Chemical Co.,
             submitted by Ciba-Geigy Corp., Greensboro,  N.C.; CDL:237822-E)

00015786     Chamberlain, E.; Taylor, T.D. (1978) Metolachlor, Dual 8E; Dicamba,
             Banvel: AG-A No. 4865 I, II.  (Unpublished study received Mar 16, 1979
             under 100-583; submitted by Ciba-Geigy Corp., Greensboro, N.C.;
             CDL:237818-E)

00015787     Chamberlain, E.; Kern, C.L.  (1978) Metolachlor, Dual  8E; Dicamba, Banvel:
             AG-A No. 4948 I,II. (Unpublished study received  Mar 16, 1979 under
             100-583; submitted by Ciba-Geigy Corp.,  Greensboro,  N.C.; CDL:237818-F)

00015950     Shriver, J.; Guthrie, C. (1975) Residue Report: Field Corn: AG-A  No. 3406
             II.  (Unpublished study received Mar 26, 1975 under  5F1606; submitted by
             Ciba-Geigy Corp., Greensboro, N.C.; CDL:  094379-AB)

00015954     Turner, W.E. (1974) Residue Report: Field Corn: AG-A No. 3057.
             (Unpublished study received Sep 26, 1974 under 5G1553; submitted by
             Ciba-Geigy Corp., Greensboro, N.C.; CDL:094216-F)

00015955     Luke, J.E.; Slagowski, J.L. (1978) Metolachlor (Dual 8E); Atrazine (AAtrex
             SOW); Paraquat (Paraquat CL): AG-A No. 4964. (Unpublished study received
             Mar 16,  1979 under 100- 583; prepared in cooperation  with EN-CAS
             Laboratories and Chev- ron Chemical Co., submitted by Ciba-Geigy Corp.,
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00016248     Richards, R.F. (1976) Residue Report: Soybeans: AG-A No. 3948.
             (Unpublished study received Jan 19, 1977 under 100-583; submitted by
             Ciba-Geigy Corp., Greensboro, N.C.; CDL:095747-U)

00016306     Hermes, P. (1972)  Biphasic Extraction of Radioactive Metabolites  from

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00016392     Houseworth,  L.D.; Rolla, H. (1977) Residues of Metolachlor and  Atrazine in
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             Liquid Fertilizer—Preplant Incorporated and Preemergence Applications:
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00016393     Seim, V. (1976) Residue Report: Field Corn: AG-A No. 3672 II-III.
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00016394     Seim, V. (1976) Residue Report: Field Corn: AG-A No. 3673 I,II,III.
             (Unpublished study received Feb 18, 1977 under 100-583; submitted by
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00016395     Ragsdale, D.; Stahlberg, L.  (1976) Residue Report: Field Corn: AG-A No.
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00016396     Taylor, T.D.; Shriver, J.; Wendling, C. (1976) Residue Report: Field Corn:
             AG-A No. 3734 I,II,III. (Unpublished study received Feb 18, 1977 under
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00016397     Shriver, J.; Wendling, C. (1976) Residue Report: Field Corn:  AG-A No. 3735
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00016398     Snow, J.G.; Tinklepaugh, ?  (1976) Residue Report: Field Corn: AG-A No.
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00016399     Thetford,  L.; Snow, J.G.; Tinklepaugh, ? (1976) Residue Report:  Sweet Corn:
             AG-A No. 3858. (Unpublished study received Feb 18, 1977 under 100-583;
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00016425     Fink, R. (1974) Final Report: Eight-Day Dietary LC50-Mallard Ducks:

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00016426     Fink, R. (1974) Final Report: Eight-Day Dietary LC50-Bobwhite  Quail:
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00016427     Kahrs, R.A. (1979) Residues of Metolachlor and Chloramben in Soybeans
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00016435     Houseworth, L.D. (1977) Residues of Metolachlor and Dicamba in or on Corn
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00016436     Chamberlain, E.; Coan, R.M. (1977) Residue Report: Field Corn: AG-A  No.
             4253 II.  (Unpublished study received Nov 10, 1977 under  100-EX-59;
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00016437     Chamberlain, E.; Kern, C.L. (1977) Residue Report: Field Corn: AG-A No.
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00016604     Shriver, J.; Wendling, C. (1976) Residue Report: Soybeans: AG-A  No. 3724.
             (Unpublished study received May 11, 1978 under 100-583; submitted by
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00016607     Cheung, M.W.; Kahrs,  R.A. (1979) Residues in Sorghum Resulting from

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             submitted by Ciba-Geigy Corp., Greensboro,  N.C.; CDL:237815-A)

00016608     Davidson, W.E. (1979) Metolachlor-Propazine (Milocep 5L):  AG-A No. 5159
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00016609     Dill, R. (1978) Metolachlor + Propazine (Milocep 5L): AG-A No. 5176 A.
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00016610     Dill, R. (1978) Metolachlor-Propazine (Milocep 5L): AG-A No. 5176 II.
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00016990     Davidson, W.E. (1978) Metolachlor + Propazine; Dual 8E + Milo- gard 4L:
             Grain Sorghum: AG-A No. 4883 II A.  (Unpublished study received Nov 24,
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             CDL:235981-B)

00016991     Chamberlain, E.; Threewitt, T. (1978) Metolachlor + Propazine;  Dual 8E +
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00016992     Turner, W.E. (1978) Metolachlor + Propazine; Dual 8E + Milogard SOW:
             Grain Sorghum: AG-A No. 4995 A. (Unpublished  study received Nov 24,
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00018722     Buccafusco, R.J.; Stiefel, C.; Sullivan, D.M.; etal. (1978) Acute  Toxicity of
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00018723     Buccafusco, R.J.; Stiefel, C.; Sullivan, D.M.  (1978) Acute Toxicity of

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00022872     Sumner, D.D.; Cassidy, J.E. (1975) The Uptake and Distribution of
             Phenyl-14C-CGA-24705  from Soil in Greenhouse Grown Soybeans:  Report
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             submitted by Ciba-Geigy Corp., Greensboro, N.C.;  CDL:095750-F)

00022873     Sumner, D.; Cassidy, J.  (1974) The Uptake and Distribution of Phen-
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00022874     Sumner, D.; Cassidy, J.  (1974) The Uptake and Distribution of Phen-
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             (Unpublished study received Sep 26, 1974 under 5F1606; submitted  by
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00022879     Szolics, I.M.; Cassidy, J.E. (1978) The Uptake  and Balance of Phen-
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             submitted by Ciba-Geigy Corp., Greensboro,  N.C.; CDL:238899-C)

00022880     Szolics, I.M.; Cassidy, J.E. (1978) The Uptake  and Balance of Phenyl
             14C-Metolachlor in Field Rotation Lettuce Planted in the  Spring: Report No.
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00026712     Bruhl, ? (1979) SN 66 752 Residues in Tobacco Plants, Cured Leaves, and
             Cigarette Smoke.  (Unpublished study received Dec 13, 1979  under
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00026713     Pitblado, R.; Hawf,  L.R.; Glaze, N.; et al. (1975) Analysis of Lima Beans for
             Possible Residues of Chloramben. (Unpublished study received May 23, 1975
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00032174     Jessup, D.C.; Arceo, R.J.; Estes, F.L.; et al. (1980) 6-Month  Chronic Oral
             Toxicity Study in Beagle Dogs: IRDC No. 382-054.  (Unpublished study
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00039174     Seim,  V.; Peek, J.; Stahlberg, L.;  et al. (1975) Residue Report: Soybeans:
             AG-A No. 3268 I,II,III.  (Unpublished study including AG-A nos. 3466  I,II,
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             by Ciba-Geigy Corp., Greensboro, N.C.; CDL:094878-A)

00039176     Ciba-Geigy, Limited (19??)  CGA 24 705  Feeding Study in Milk Cows:
             Methods. (Unpublished study received Nov 25, 1975 under 6G1708;
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00041283     Lightkep, G.E.; Christian, M.S.; Christian, G.D.; et al. (1980)  Teratogenic
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             Ciba-Geigy Corp., Greensboro,  N.C.; CDL:099630-A)

00042725     Marias, A.J.; Gesme, J.; Albanese, E.; et al. (1977) Report to Ciba-Geigy
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00062465     Fink, R.; Beavers, J.B.; Brown, R.; et al. (1981) Final Report:  Acute Oral
             LD50~Mallard Duck: Project No.  108-200.  (Unpublished study received Mar
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00064182     Ciba-Geigy Corporation (1980) [Residue of Dual 8E and Eptam 6E  on Kidney
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00074898     Szolics, I.M.; Simoneaux, B.J.;  Cassidy, J.E. (1981) The Uptake and
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00074900     Szolics, I.M.; Simoneaux, B.J.;  Cassidy, J.E. (1981) The Uptake and
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00078297     Ciba-Geigy Corporation (1981) [Tests for Residues in  Various Crops  and Soil].
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00080897     Smith, S.H.; O'Loughlin, C.K.; Salamon,  C.M.; et al. (1981) Two-generation
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00084003     Marias, A.J.; Gesme, J.; Albanese, E.; et al. (1977) Revised Final  Report to
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00105957     Ciba-Geigy Corp. (1982) Residues in or on Potato  Tubers Resulting  from 4.0
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             Dual 8E + Sencor/Lexone Tank Mix Preemergence Followed by Dual 8E at
             Layby.  (Compilation; unpublished study received Jun 25,  1982 under 100-597;
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00106191     Houseworth, L. (1979) Residues of Metolachlor and Metribuzin in Potato
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00111693     Ciba-Geigy Corp. (1979) Summary of Metolachlor Residues in Sorghum
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00117597     Tisdel, M.; MacWilliams, P.; Dahlgren, R.; et al. (1982) Carcinogenicity
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00125227     Ciba-Geigy Corp. (1975) Procyazine-Corn: Tank Mixes with CGA-24705
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00128731     Ciba-Geigy Corp. (1983) Residues in Forage and Fodder of Vegetable  Pod
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00129058     Cargile,  N. (1983) Letter sent to C.  Brinkley dated Mar 7, 1983: Dual/cotton
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40276601     Brown, R.; Lail,  L.  (1987) Technical Metolachlor: Product Chemistry Data:
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40276602     Brown, R.; Lail,  L.  (1987) Technical Metolachlor: Product Chemistry Data:
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40430201     Spare,  W. (1987) Determination of the Hydrolysis Rate Constants of
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40430202     Spare,  W. (1987) Determination of the Solution Photolysis Rate Constants and
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40494602     Spare, W. (1987) Leaching Characteristics of Parent Metolachlor: Laboratory
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40494603     Spare, W. (1987) Leaching Characteristics of Aged Metolachlor:  Laboratory
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40494606     Spare, W. (1987) The Volatilization of Metolachlor from Soil (A Laboratory
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40980701     Hazelette, J. (1989) Metolachlor Technical: Chronic Toxicity Study  in Dogs:

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40980705     Cheung, M. (1989) Residue Summary—Metolachlor Corn Processed  Fractions
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             Unpublished study prepared by Agrisearch Inc. in association with Ciba-Geigy
             Corp. 130 p.

41309802     Spare, W. (1989) Soil Metabolism of Metalochlor under Aerobic,
             Aerobic/Anaerobic, and Sterile Conditions: Lab Project Number:  1258.
             Unpublished study prepared by Agrisearch, Inc.  130 p.

41335701     Merricks, D. (1989) Metolachlor Field Dissipation Study in  Iowa-Site B:
             Final Report: Lab Project Nos. 1264-B; 1264.  Unpublished study prepared by
             Agrisearch Inc.  300 p.

41470601     Thede, B. (1990) Uptake of [Carbon 14]-Metolachlor in Rotational Crops
             grown in Soil which has been Previosly Used for  Growing Potatoes: Lab Study
             No.: ABR-90037.  Unpublished study prepared by Ciba-Geigy Corp.  74 p.

41484201     Merricks, D. (1989) Metolachlor Field Dissipation Study in Iowa- Site A:
             Amendment to Final Report: Unpublished study prepared by Ciba-Geigy
             Corp. 6 p.

41506501     Cheung, M. (1990) Metolachlor:  Response to EPA Deb Review of Residue
             Chemistry Data Submitted Under the Metolachlor Frstr: Lab Project Number:
             ABR-90045. Unpublished study prepared by  Ciba-Geigy Corp. 20 p.

41551201     Baron, J. (1990) Metalochlor: Magnitude of Residue on Celery: Lab Project
             Number: IR-4 1337. Unpublished study prepared by USDA- ARS/Beltsville
             Agriculture  Research Center.  162 p.

41833101     Mastrocco, F.; Huber, K.; Schiavo, D.; et al. (1987) Metolachlor  Technical:
             21-Day Dermal Toxicity Study in Rabbits: Lab Project Number: 862012.
             Unpublished study prepared by Ciba-Geigy Corp.  173 p.

41833102     Murphy, T. (1987)  Dermal Absorption of Metolachlor  in Rats: Lab  Project
             Number: ABR-87051.  Unpublished study prepared by Ciba-  Geigy Corp. in
             coop, with WIL  Research, Inc.  120 p.
                                        124

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                               BIBLIOGRAPHY
MRID
CITATION
42644301    Wurz, R.  (1993) Metolachlor: Validation of Analytical Method  AG-338,
            Analytical Method for the Residues of Metolachlor Plant Metabolites
            Determined as CGA-37913 and CGA-49751 after Acid Hydrolysis with
            Modifications for the Determination of Residues of Metolachlor in (carbon
            14)-treated Corn and Potatoes from

42644301    Metabolism Studies: Lab Project Number: ABR-92088.  Unpublished study
            prepared by CIBA-GEIGY Corp.  72 p.

42652101    Fleischmann,  T. (1993)  Uptake and Metabolism of (carbon  14)-Metolachlor in
            Greenhouse Grown Potatoes and Corn: Lab Project Number: ABR-92090:
            93-90. Unpublished study prepared by Ciba-Geigy Corp.  170 p.

42810601    Cheung, M. (1993) Metolachlor: Response to EPA Review of Metolachlor
            Storage Stability Data Reported in ABR-88168  (Supplement) (MRID No.
            42384401) and ABR-92042 (MRID No.  42502901): Lab Project Number:
            ABR-88168: ABR-92042.  Unpublished study prepared by Ciba-Geigy Corp.,
            Residue Chemistry Department.  97 p.

43000101    Kunkel, D. (1993) Metolachlor: Magnitude of Residue on Onion (Dry Bulb):
            Lab Project Number: 1520. Unpublished study  prepared by USDA. 288 p.

43044000    Industry Task Force II on MCPA Research (1993) Submission of Summary
            Hazard Evaluation Data in Support of FIFRA 6(a) (2) for MCPA Acid, DMA
            Salt, and 2-EH Ester.  Transmittal of 1 Study.

43178401    Grunenwald, M. (1994)  Metolachlor: Magnitude of the Residues of
            Metolachlor as CGA-37913 and CGA-49751  in or on Field Corn Following
            Preplant Incorporated (PPI) and Layby Application of Dual 8E and Dual 25G:
            Lab Project Number: ABR/93065: 130377:  42-91.  Unpublished study
            prepared by Ciba-Geigy Corp. 483 p.

43178402    Grunenwald, M. (1994)  Metolachlor: Magnitude of the Residues of
            Metolachlor as CGA-37913 and CGA-49751  in Soybeans Following PPI
            Application of Dual 25G: Lab Project Number: ABR/93063: 130375: 38-91.
            Unpublished study prepared by Ciba-Geigy Corp. 212 p.

43178403    Grunenwald, M. (1994)  Metolachlor: Magnitude of the Residues in  Cottonseed
            Following PRE or PPI Application of Dual 8E to Cotton: Lab Project Number:

                                       125

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                               BIBLIOGRAPHY
MRID
CITATION
             ABR/93061:  130373: 36-91. Unpublished study prepared by Ciba-Geigy Corp.
             258 p.

43244003     Ham, A. (1994) Metolachlor: Test for Other Genotoxic Effects in the in vivo/
             in vitro Assay for Unscheduled DNA Synthesis in  Rat Primary Hepatocytes
             with Two Timepoints: Final Report: Lab  Project Number: 15881/0/494.
             Unpublished study prepared by Hazleton Washington, Inc.  46 p.

43263101     Grunenwald,  M. (1994) Metolachlor-Magnitude of Residues in Peanuts
             Following Application of Dual 25G or 8E: (Data  submitted as alternate to
             Craven Laboratories generated data): Lab Project Number: ABR-92076.
             Unpublished study prepared by Ciba-Geigy Co. 480 p.

43295701     Grunenwald,  M. (1994) Metolachlor-Magnitude of the Residues of
             Metolachlor as CGA-37913 and CGA-49751 in Succulent and Dried

43295701     Legumes Following Preplant Incorporated (PPI) Application of Dual 8E: (Data
             Submitted as  Alternate to Craven Laboratories  Generated Data): Lab Project
             Number: ABR-93084: 39-91: 130376.  Unpublished study prepared by
             Ciba-Geigy Corp. 355 p.

43367101     Grunenwald,  M. (1994) Metolachlor: Magnitude of the Residues in Rotational
             Alfalfa and Clover Following PPI Application of Dual 8E  to Field Corn: Lab
             Project Number: ABR/93-62.  Unpublished study prepared by Ciba-Geigy
             Corp.  534 p.
                                        126

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APPENDIX D.  List of Available Related Documents
                     127

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128

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       The following is a list of available documents related to Metolachlor.  It's purpose is to
provide a path to more detailed information if it is needed.  These accompanying documents
are part of the Administrative Record for Metolachlor and are included in the EPA's Office of
Pesticide Programs Public Docket.

       1.      Appendix A

       2.      Health and Environmental Effects Science Chapters

       3.      Detailed Label Usage Information System (LUIS) Report

       4.      Metolachlor RED Fact Sheet

       5.      PR Notice 86-5 (included in this appendix)

       6.      PR Notice 91-2 (included in this appendix) pertains to the Label Ingredient
              Statement
                                          129

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130

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APPENDIX E.  PR Notices 86-5 and 91-2
                  131

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132

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PR Notice 86-5
      133

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134

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        I        UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

   /""Pno1t°                              WASHINGTON, B.C. 20460

                                            July 29, 1986

                                                                              OFFICE OF
                                         PR NOTICE 86-5            PREVENTION, PESTICIDES
                                                                     AND TOXIC SUBSTANCES

            NOTICE TO PRODUCERS, FORMULATORS, DISTRIBUTORS
                                AND REGISTRANTS

Attention:    Persons responsible for Federal registration of pesticides.

Subject:             Standard format for data submitted under the Federal Insecticide,
                    Fungicide, and Rodenticide Act (FIFRA) and certain provisions of the
                    Federal Food, Drug, and Cosmetic Act (FFDCA).

I.  Purpose

       To require data to be submitted to the Environmental Protection Agency (EPA) in a
standard format. This Notice also provides additional guidance about, and illustrations of, the
required formats.

II. Applicability

       This PR Notice applies to all data that are submitted to EPA to satisfy data
requirements for granting or maintaining pesticide registrations, experimental use permits,
tolerances, and related approvals under certain provisions of FIFRA and FFDCA. These data
are defined in FIFRA §10(d)(l). This Notice does not apply to commercial, financial, or
production  information, which are, and  must continue to be, submitted differently under
separate cover.

III. Effective Date

       This notice is effective on November 1, 1986.  Data formatted according to this notice
may be submitted prior to the effective date.  As of the effective date, submitted data packages
that do not conform to these requirements may be returned to the submitter for necessary
revision.

IV. Background

       On September 26, 1984, EPA published proposed regulations in the Federal Register
(49 FR 37956) which include Requirements for Data Submission  (40 CFR §158.32), and
Procedures for Claims of Confidentiality of Data (40 CFR §158.33). These regulations
specify the format for data submitted to EPA under Section 3 of FIFRA and Sections 408 and
4139 of FFDCA, and procedures which must be followed to make and substantiate claims of
confidentiality. No entitlements to data confidentiality are changed, either by the proposed
regulation or by this notice.

       OPP is making these requirements mandatory through this Notice to gain resource-
saving benefits from their use before the entire proposed regulation becomes final. Adequate
lead time is being provided for submitters to comply with the new requirements.

V.     Relationship of this Notice to Other OPP Policy and Guidance


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       While this Notice contains requirements for organizing and formatting submittals of
supporting data, it does not address the substance of test reports themselves. "Data reporting"
guidance is now under development in OPP, and will specify how the study objectives,
protocol, observations, findings, and conclusions are organized and presented within the study
report. The data reporting guidance will be compatible with submittal format requirements
described in this Notice.

       OPP has also promulgated a policy (PR Notice 86-4 dated April  15, 1986) that
provides for early screening of certain applications for registration under FIFRA §3. The
objective of the screen is to avoid the additional costs and prolonged delays associated with
handling significantly incomplete application packages.  As of the effective date of this Notice,
the screen will include in its criteria for acceptance of application packages the data formatting
requirements described herein.

       OPP has also established a public docket which imposes deadlines for inserting into the
docket documents submitted in connection with Special  Reviews and Registration Standards
(see 40 CFR §154.15 and §155.32).  To meet these deadlines, OPP is requiring an additional
copy of any data submitted to the docket.  Please refer to  Page 10 for more information about
this requirement.

       For several years, OPP has required that each application for registration or other
action  include a list of all applicable data requirements and an indication of how each is
satisfied—the statement of the method of support for the application.  Typically, many
requirements are satisfied by reference to data previously  submitted—either by the applicant or
by another party. That requirement is not altered by this notice, which  applies only to data
submitted with an application.

VI.    Format Requirements

       A more  detailed discussion of these format requirements follows the index on the next
page, and samples of some of the requirements are attached.  Except for the language  of the
two alternative  forms of the Statement of Data Confidentiality Claims (shown in Attachment 3)
which  cannot be altered, these samples are illustrative.  As long as the required information is
included and clearly identifiable, the form of the samples may be altered to reflect the
submitter's preference.

                                       - INDEX-
                                                                                    Text Example
                                                                                      Page  Page
A.     Organization of the Submittal Package	3     17

B.     Transmittal Document	4     11

C.     Individual Studies	  4

       C. 1  Special Considerations for Identifying Studies  	  5

D.     Organization of each Study Volume  	6     17

       D. 1 Study Title Page	7     12
       D. 2 Statement of Data  Confidentiality Claims
            (based on FIFRA §10(d)(l))   	8     13
       D. 3 Confidential Attachment	8     15
       D. 4 Supplemental Statement of Data Confidentiality
            Claims (other than those based on FIFRA §10(d)(l))   	    8     14


                                               136

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       D. 5 Good Laboratory Practice Compliance Statement	9     16

E.     Reference to Previously Submitted Data	  9

F.     Physical Format Requirements & Number of Copies	  9

G.     Special Requirements for Submitting Data to the Docket   	10
A.     Organization of Submittal Package

       A "submittal package" consists of all studies submitted at the same time for review in
support of a single regulatory action, along with a transmittal document and other related
administrative material (e.g. the method of support statement, EPA Forms 8570-1, 8570-4,
8570-20, etc.) as appropriate.

       Data submitters must organize each submittal package as described in this Notice.  The
transmittal and any other administrative material must be grouped together in the first physical
volume.  Each study included in the submittal package must then be bound separately.

       Submitters sometimes provide additional materials that are intended to clarify,
emphasize, or otherwise comment to help Product Managers and reviewers better understand
the submittal.

       -  If such materials relate to one study, they should be included as an appendix to that
       study.

       - If such materials relate to more than one study (as for example a summary of all
       studies in a discipline) or to the submittal in general, they must be included in the
       submittal package as a separate study (with title page and statement of confidentiality
       claims).

B.     Transmittal Document

       The first item in each submittal package must be a transmittal document.  This
document identifies the submitter or all joint submitters; the regulatory action in support of
which the package is being submitted--i.e., a registration application,  petition, experimental
use permit (EUPj, §3(c)(2j(B)  data call-in, §6(aj(2) submittal, or a  special review; the
transmittal date;  and a list of all individual studies included in the package in the order of their
appearance,  showing (usually by Guideline reference number) the data requirement(s)
addressed by each one.  The EPA-assigned number for the regulatory action (e.g. the
registration, EUP, or tolerance petition number) should be included in the transmittal
document as well,  if it is known to the submitter.  See Attachment 1 for an example of an
acceptable transmittal document.

       The list of included studies in the transmittal of a data submittal package supporting a
registration application should  be subdivided by discipline, reflecting the order in which data
requirements appear in 40 CFR 158.

       The list of included studies in the transmittal of a data submittal package supporting a
petition for tolerance or an application for  an EUP should be subdivided into sections A, B,
C,.... of the petition or application, as defined in 40 CFR 180.7 and 158.125, (petitions) or
Pesticide Assessment Guidelines, Subdivision I (EUPs) as appropriate.

       When a submittal package supports a tolerance petition and an application for a


                                          137

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registration or an EUP,  list the petition studies first, then the balance of the studies. Within
these two groups of studies follow the instructions above.

C.     Individual Studies

       A study is the report of a single scientific investigation, including all supporting
analyses required for logical completeness. A study should be identifiable and distinguishable
by a conventional bibliographic citation including author, date, and title.  Studies generally
correspond in scope to a single Guideline requirement for supporting data, with some
exceptions discussed in section C.I.  Each study included in a submittal package must be
bound as a separate entity.  (See comments on binding studies on page 9.)

       Each study must be consecutively paginated, beginning from the title page as page 1.
The total number of pages in the com-plete study must be shown on the study title page. In
addition (to ensure that inadvertently separated pages can be reassociated with the proper study
during handling or review) use either of the following:

       - Include the total number of pages in the complete study on  each page  (i.e., 1 of 250,
       2 of 250, ...250  of 250).

       - Include a company name or mark and study number on each page of the study, e g ,
       Company Name-1986-23.  Never reuse a study number for marking the pages of
       subsequent studies.
       When a single study is  extremely long, binding it in mul-tiple volumes is permissible
so long as the entire  study is pag-inated in a single series, and each volume is plainly identified
by the study title and its position in the multi-volume sequence.

C.I    Special Considerations  for Identifying Studies

       Some studies raise special problems in study identification, because they address
Guidelines of broader than normal scope or for  other reasons.

       a. Safety Studies. Several Guidelines require testing for safety in more than one
species. In these cases each species tested should be reported as a separate study, and bound
separately.

       Extensive supplemental reports of pathology reviews, feed analyses, historical control
data, and the like are often associated with safety studies.  Whenever possible these should be
submitted with primary  reports of the study, and bound with the primary study as appendices.
When such supplemental reports are  submitted independently of the  primary report, take care
to fully identify the primary report to which they pertain.

       Batteries of acute toxicity tests, performed on the same end use product and covered by
a single title page, may  be bound together and reported as a single study.

       b. Product Chemistry Studies.  All product chemistry data within a submittal package
submitted in support of  an end-use product produced from registered manufacturing-use
products should be bound as a single study under a single title page.

       Product chemistry data submitted in support of a technical product, other
manufacturing-use product, an experimental use permit, an import tolerance petition, or an
end-use product produced from unregistered source ingredients, should be bound as a single
study for each Guideline series (61,  62, and 63) for conventional pesticides, or for  the
equivalent subject range for biorational pesticides.  The  first of the three studies in  a complete
product chemistry submittal for a biochemical pesticide would  cover Guidelines 151-10,
151-11, and 151-12;  the second would cover Guidelines 151-13, 151-15,  and  151-16; the third

                                           138

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would cover Guideline 151-17. The first study for a microbial pesticide would cover
Guidelines 151-20, 151-21, and 151-22; the second would cover Guidelines 151-23 and
151-25; the third would cover Guideline 151-26.

       Note particularly that product chemistry studies are likely to contain Confidential
Business Information as defined in FIFRA §10(d)(l)(A), (B), or (C), and if so must be
handled as described in section D.3. of this notice.

       c.  Residue Chemistry Studies.  Guidelines 171-4, 153-3, and 153-4 are extremely
broad in scope; studies addressing residue chemistry requirements must thus be defined at a
level below that of the Guideline code.  The general principle, however, of limiting a study to
the report of a single investigation still applies fully. Data should be treated as a single study
and bound separately for each analytical method, each report of the nature of  the residue in a
single crop or animal species, and for each report of the magnitude  of residues resulting from
treatment of a single crop or from processing a single crop.  When more than one commodity
is derived from a single crop (such as beet tops and beet roots) residue data on all such
commodities should be reported as a single study. When multiple field trials  are associated
with a single crop, all such trials should be reported as a single study.

D.     Organization of Each Study Volume

       Each complete study must include all applicable elements in the list below, in the order
indicated.  (Also see Page 17.) Several  of these elements are further explained in the following
paragraphs.  Entries in the column headed "example" cite the page number of this notice
where the element is illustrated.
Element

Study Title Page

Statement of Data
Confidentiality
Claims

Certification of Good
Laboratory Practice
Flagging statements
Body of Study
Study Appendices

Cover Sheet to Confi-
dential Attachment

CBI Attachment
Supplemental Statement
of Data Confidentiality
Claims
       When Required

Always

One of the two alternative
forms of this statement
is always required

If study reports laboratory
work subject to GLP require-
ments

For certain toxicology studies (When
flagging requirements are finalized.)

Always - with an English language
translation if required.

At submitter's option

If CBI is claimed under FIFRA
            I, (B).or(C)
       Example
Page 12

Page 13



Page 16
If CBI is claimed under FIFRA
§10(d)(l)(A), (B),or  (C)

Only if confidentiality is
claimed on a basis other than
FIFRA§10(d)(l)(A),  (B), or (C)
Page 15

Page 14
                                          139

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D.I.   Title Page

       A title page is always required for each submitted study, published or unpublished.
The title page must always be freely releasable to requestors; DO NOT INCLUDE CBI ON
THE TITLE PAGE. An example of an acceptable title page is on page 12 of this notice.
The following information must appear on the title  page:

a.      Study title. The study title should be as descriptive as possible It must clearly identify
the substance (s) tested and correspond to the name  of the data requirement  as it appears in the
Guidelines.

b.      Data requirement addressed.  Include on the title page the Guideline number (s)  of the
specific requirement (s) addressed by the study.

c.      Author (s). Cite only individuals with primary intellectual responsibility for the content
of the study.  Identify them plainly as authors, to distinguish them from the performing
laboratory, study sponsor, or other names that may also appear on the title  page.

d.      Study Date.  The title page must include a single date for the study.  If parts of the
study were performed at different times, use only the date of the latest element in the study.

e.      Performing Laboratory Identification. If the study reports work done by one or more
laboratories, include  on the title page the name and address  of the performing laboratory or
laboratories, and the  laboratory's internal project number (s) for the work.  Clearly distinguish
the laboratory's project identifier from any other reference numbers provided by the study
sponsor or submitter.

f.      Supplemental Submissions.  If the study is a commentary on or supplement to another
previously submitted study, or it it responds to EPA questions raised with respect to an earlier
study, include  on the title page elements a. through d. for the previously submitted study,
along with the EPA Master Record Identifier (MRID) or Accession number of the earlier
study if you know these numbers.  (Supplements submitted in the same submittal package as
the primary study should be appended to and bound with the primary study.  Do not include
supplements to more than one study under a single  title  page).

g.       Facts of Publication.  If the study is  a reprint of a published document, identity on the
title page all relevant tacts of publication, such as the journal title, volume, issue, inclusive
page numbers, and publication date.


D.2.   Statements of Data Confidentiality Claims Under FIFRA  §10(d)(l).

       Each submitted study must be accompanied  by one of the two alternative forms of the
statement  of Data Confidentiality Claims specified  in the proposed regulation in §158.33 (b)
and (c)  (See Attachment 3). These statements apply only to claims of data confidentiality
based on FIFRA §10(d)(l)(A), (B), or (C).   Use the appropriate alternative form of the
statement  either to assert a claim of §10(d)(l) data  confidentiality (§158.33(b)) or to waive
such a claim (§158.33(c)).  In either case, the statement must be signed and dated, and must
include  the typed name and title of the official who signs it.   Do not make CBI claims with
respect to  analytical methods associated with pet-itions for tolerances or emergency
exemptions (see NOTE Pg  13).
                                          140

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D.3.   Confidential Attachment

       If the claim is made that a study includes confidential business information as defined
by the criteria of FIFRA §10(D)(1)(A), (B), or (C) (as described in D.2. above) all such
information must be excised from the body of the study and confined to a separate
study-specific Confidential Attachment. Each passage of CBI so isolated must be identified by
a reference number cited within the body of the study at the point from which the passage was
excised (See Attachment 5).

       The Confidential Attachment to a study must be identified by a cover sheet fully
identifying the parent study, and must be clearly marked "Confidential Attachment." An
appropriately annotated photocopy of the parent study  title page may be used as this cover
sheet.  Paginate the Confidential Attachment separately from the body of the study,  beginning
with page 1 of X on the title page.  Each passage confined to the Confidential Attachment
must be associated with a specific cross reference to the page(s) in the main body of the study
on which it is cited, and with a reference to the applicable passage(s) of FIFRA §10(d)(l) on
which the confidentiality claim is based.

D.4.   Supplemental Statement of Data Confidentiality Claims (See
       Attachment 4)

       If you wish to make a claim of confidentiality for any portion of a submitted study
other than described by FIFRA §10(d) (1)(A), (B), or  (C), the following provisions apply:

       - The specific information to which the claim applies must be clearly marked in the
       body or the study as subject to a claim of confidentiality.

       - A Supplemental Statement of Data Confidentiality Claims must be submitted,
       identifying each passage claimed confidential and describing in detail the basis for the
       claim.  A list of the points to address in such a statement is included in Attachment 4
       on Pg 14.

       - The Supplemental Statement of Data Confidentiality Claims must be signed and dated
       and must include the typed name and title of the official who signed it.

D.5.   Good Laboratory Practice Compliance Statement

       This statement is required if the study contains  laboratory work subject to GLP
requirements specified in  40 CFR 160. Samples of these statements are shown in Attachment
6.

E.     Reference to Previously Submitted Data

       DO NOT RESUBMIT A STUDY THAT HAS PREVIOUSLY BEEN SUBMITTED
FOR ANOTHER PURPOSE unless EPA specifically requests it.  A copy of the title page
plus the MRID number (if known) is sufficient to  allow us to retrieve the study immediately
for review. This prevents duplicate  entries in the Agency files, and saves you
the cost of sending more copies of the study. References to previously submitted studies
should not be included in  the transmittal document, but should be incorporated into  the
statemenTof the method of support for the application.

F.     Physical Format Requirements

       All elements in the data submittal package must be on uniform 8 1/2 by  11 inch white
paper, printed on one side only in black ink, with high contrast and good resolution. Bindings
for individual studies must be secure, but easily removable to permit disassembly for

                                          141

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microfilming.  Check with EPA for special instructions before submitting data in any medium
other than paper, such as film or magnetic media.

Please be particularly attentive to the following points:

       •     Do not include frayed or torn pages.

       •     Do not include carbon copies,  or copies in other than black ink.

       •     Make sure that photocopies are clear, complete, and fully readable.

       •     Do not include oversize computer printouts or fold-out pages.

       •     Do not bind any documents with glue or binding tapes.

       •     Make sure that all pages of each study, including any attachments or
             appendices, are present and in correct sequence.

       Number of Copies Required - All  submittal packages except those associated with a
Registration Standard or Special Review (See Part G below) must be provided In three
complete,  identical copies.  (The proposed regulations specified two copies; three are now
being required to expedite and reduce the cost of processing data into the OPP Pesticide
Document Management System and getting it into review.)

G.     Special Requirements for Submitting Data to the Docket

       Data submittal packages associated with a Registration Standard or Special Review
must be provided in four  copies, from one of which all material claimed as CBI has been
excised. This fourth copy will become part of the public docket for the RS or SR case.  If no
claims of confidentiality are made for the study, the fourth copy should be identical to the
other three.  When portions of a study submitted  in support or an RS or SR are claimed as
CBI, the first three copies will include the CBI material as provided in section D of this
notice.  The following special preparation is required for the fourth copy.

       •     Remove  the "Supplemental Statement of Data Confidentiality Claims".

       •     Remove  the "Confidential Attachment".

       •     Excise from the body of the study  any information you claim as confidential,
             even if it does not fall within the scope of FIFRA §10(d)(l)(A), (B), or (C).
             Do not close up or paraphrase text remaining after this excision.
             Mark the fourth copy plainly on both its cover and its title page with the phi
             "Public Docket Material - contains no information claimed as confidential".
ihrase
                                          142

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V.     For Further Information

      For further information contact John Carley, Chief, Information Services Branch,
Program Management and Support Division, (703) 305-5240.
                                      /S/

                                James W. Akerman
                                Acting Director,
                                Registration Division
Attachment 1.       Sample Transmittal Document
Attachment 2.       Sample Title Page for a Newly Submitted Study
Attachment 3.       Statements of Data Confidentiality Claims
Attachment 4.       Supplemental Statement of Data Confidentiality Claims
Attachment 5.       Samples of Confidential Attachments
Attachment 6.       Sample Good Laboratory Practice Statements
Attachment 7.       Format Diagrams for Submittal Packages and Studies
                                        143

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                                 ATTACHMENT 1
        ELEMENTS TO BE INCLUDED IN THE TRANSMITTAL DOCUMENT*
1.     Name and address of submitter (or all joint submitters**)
+ Smith Chemical Corporation                    Jones Chemical Company
 1234 West Smith Street           -and-        5678 Wilson Blvd
 Cincinnati, OH 98765                          Covington, KY 56789

+ Smith Chemical Corp will act as sole agent for all submitters.
2.     Regulatory action in support of which this package is submitted
Use the  EPA identification number (e.g.  359-EUP-67) if you know it. Otherwise describe the
type of request (e.g. experimental use permit, data call-in - of xx-xx-xx date).
3.     Transmittal date
4.     List of submitted studies
      Vol 1. Administrative materials -  forms, previous corres-pondence with Project
             Managers, and so forth.
      Vol 2. Title of first study in the submittal (Guideline No.)
      Vol n  Title of nth study in the submittal (Guideline
                    No.)
      *     Applicants commonly  provide this information in a tran-smittal letter.  This
             remains an acceptable  practice so long as all four elements are included.
      *     Indicate which of the joint submitters is empowered to act on behalf of all joint
             submitters in any matter concerning data compensation or subsequent use or
             release of the data.

Company Official:    	
                          Signature                        Name
Company Name
Company Contact:
                   Name                     Phone
                                        144

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                       ATTACHMENT 2
SAMPLE STUDY TITLE PAGE FOR A NEWLY SUBMITTED STUDY
                          Study Title
           (Chemical name) - Magnitude of Residue on Corn
                        Data Requirement
                        Guideline 171-4
                            Author
                         John C. Davis
                       Study Completed On
                        Januarys, 1979
                      Performing Laboratory
                  ABC Agricultural Laboratories
                       940 West Bay Drive
                      Wilmington, CA 39897
                      Laboratory Project ID
                          ABC 47-79
                          Page 1 of X
             (X is the total number of pages in the study)
                              145

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                                ATTACHMENT 3

              STATEMENTS OF DATA CONFIDENTIALITY CLAIMS

1. No claim of confidentiality under FIFRA §10(d)(l)(A),(B), or (C).

           STATEMENT OF NO DATA CONFIDENTIALITY CLAIMS
   No claim  of  confidentiality is made for any information  contained in this
   study on  the basis  of its falling within the scope  of  FIFRA
   6§10(d)(1)(A),  (B),  or (C).

   Company 	

   Company Agent:  	Typed Name	 Date:	

   	Title	  	Signature	
2. Claim of confidentiality under FIFRA §10(d)(l)(A), (B), or (C).
   Information  claimed confidential on the basis of  its  falling within the
   scope of  FIFRA §10(d)(1)(A),  (B), or  (C) has been removed to a
   confidential  appendix,  and is cited by cross-reference  number in the body
   of the  study.

    Company: 	

    Company  Agent:  	Typed Name	 Date:	

   	Title	  Signature 	
               STATEMENT OF DATA CONFIDENTIALITY CLAIMS

NOTE: Applicants for permanent or temporary tolerances should note that it is OPP policy
that no permanent tolerance, temporary tolerance, or request for an emergency exemption
incorporating an analytical method,  can be approved unless the applicant waives all claims of
confidentiality for the analytical method.  These analytical methods are published in the FDA
Pesticide Analytical Methods Manual, and therefore cannot be claimed as confidential. OPP
implements this policy by returning submitted analytical methods, for which confidentiality
claims have been made, to the submitter, to obtain the confidentiality waiver before they can
be processed.
                                       146

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                                  ATTACHMENT 4

       SUPPLEMENTAL STATEMENT OF DATA CONFIDENTIALITY CLAIMS
       For any portion of a submitted study that is not described by FIFRA §10(d)(l)(A), (B),
or (C), but for which you claim confidential treatment on another basis, the following
information must be included within a Supplemental Statement of Data Confidentiality Claims:

       •     Identify specifically by page and line number (s) each portion of the study for
             which you claim confidentiality.

       •     Cite the reasons why the cited passage qualifies for confidential treatment.

       •     Indicate the length of time—until a specific date or event, or permanently—for
             which the information should be treated as confidential.

       •     Identify the measures taken to guard against undesired disclosure of this
             information.

       •     Describe the extent to which the information has been disclosed, and what
             precautions have been taken in connection with those disclosures.

       •     Enclose copies of any pertinent determinations of confidentiality made by EPA,
             other Federal agencies, of courts concerning this information.

       •     If you assert that disclosure of this information would be likely to result in
             substantial harmful effects to you, describe those harmful effects  and explain
             why they should be viewed as substantial.

       •     If you assert that the information in voluntarily submitted, indicate whether you
             believe disclosure of this information might tend to lessen the availability to
             EPA of similar information in the future, and if so, how.
                                          147

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                                   ATTACHMENT 5

             EXAMPLES OF SEVERAL CONFIDENTIAL ATTACHMENTS

Example 1. (Confidential word or phrase that has been deleted from the study)
    CROSS REFERENCE NUMBER 1       This cross reference number is used in the study in place of the
                                     following paragraph (s) at the  indicated volume and page
                                     references.
    DELETED WORDS OR PHRASE:              Ethylene Glycol
    PAGE         LINES  REASON FOR THE DELETION                      FIFRA
    REFERENCE
     6            14     Identity of Inert Ingredient                           §10(d)(C)
    28           25
    100           19
Example 2. (Confidential paragraph(s) that have been deleted from the study)
 CROSS REFERENCE NUMBER 5       This cross reference number is used in the study in place of the
                                   following paragraph (s) at the indicated volume and page
                                   references.
  DELETED PARAGRAPH(S) :
        (                                                                  )
        (      Reproduce the deleted paragraph (s) here                              )
 PAGE         LINES  REASON FOR THE DELETION               FIFRA REFERENCE
  20.           2-17    Description of the quality control process         § 1 0 (d) ( 1) (C)
Example 3. (Confidential pages that have been deleted from the study)
 CROSS REFERENCE NUMBER  7       This cross reference number is used in the study in place of the
                                   following paragraph (s) at the indicated volume and page
                                   references.
 DELETED PAGES(S): are attached immediately behind this page

 PAGES        REASON FOR THE DELETION               FIFRA REFERENCE
 35-41.        Description of product manufacturing process             § 10 (d) (1) (A)
                                          148

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                             ATTACHMENT 6.

            SAMPLE GOOD LABORATORY PRACTICE STATEMENTS

Example 1.
     This  study meets the requirements for 40 CFR Part  160

           Submitter 	

           Sponsor   	
Example 2.
    This study does not meet the  requirements of 40  CFR  Part 160, and
    differs  in the following ways:

    1.	

    2.	

    3.	

          Submitter	

          Sponsor	
          Study Director_
Example 3.
    The submitter of this study was neither the sponsor of this study nor
    conducted  it, and does not know whether it has been conducted in
    accordance with 40 CFR Part 160.

          Submitter
                                    149

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               ATTACHMENT  7.

     FORMAT OF THE SUBMITTAL PACKAGE
        Transmittal Document

            Related Administrative Materials
            (e.g. Method of Support Statement, etc.)

                   Other materials about the submittal
            	(e.g., summaries of groups of studies
                   to aid in their review).

                            Studies submitted as unique
                            to the format below.
       FORMAT OF SUBMITTED STUDIES
• Study title page.

     • Statement of Confidentiality Claims.

           . GLP and flagging* statements - as appropriate.

                  Body of the study, with English
                  language translation if required.
                      Appendices to the study.
                           Title Page of the Confidential
                           Attachment.
                             Confidential Attachment.
       :—"]'       _.	:"";	. Supplemental Statement
          i...-r--'''       i       of Confidentiality Claims

             •	" * When flagging requirements
                      are finalised.

 Documents which must be submitted as
 appropriate to meet established requirements.
       Documents submitted at submitter's option.
LEGEND
                       150

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PR Notice  91-2
      151

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152

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                  UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                                       WASHINGTON, D.C.  20460
                                                                            OFFICE OF
                                                                     PREVENTION, PESTICIDES
                                                                     AND TOXIC SUBSTANCES
                                  PR NOTICE 91 -2

          NOTICE TO MANUFACTURERS, PRODUCERS, FORMULATORS,
                        AND REGISTRANTS OF PESTICIDES

ATTENTION: Persons Responsible for Federal Registration of Pesticide Products.

SUBJECT: Accuracy of Stated Percentages for Ingredients
Statement

I. PURPOSE:

       The purpose of this notice is to clarify the Office of Pesticide Program's policy with
respect to the statement of percentages in a pesticide's label's ingredient statement.
Specifically, the amount (percent by weight) of ingredient(s) specified in the ingredient
statement on the label must be stated as the nominal concentration of such ingredient(s),  as that
term is defined in 40 CFR 158.153(i). Accordingly, the Agency has established the nominal
concentration as the only acceptable label claim for the amount of active ingredient in the
product.

II. BACKGROUND

       For some time the Agency has accepted two different methods  of identifying on the
label what percentage is claimed for the ingredient (s) contained in a pesticide. Some applicants
claimed a percentage which represented a level between the upper and the lower certified
limits. This was referred to as the nominal concentration. Other applicants claimed the lower
limit as the percentage of the ingredient(s) that would be expected to be present in their
product at the end or the product's shelf-life. Unfortunately, this led to a great deal of
confusion among the regulated industry, the regulators, and the consumers as to exactly  how
much of a given ingredient was in a given product. The Agency has established the nominal
concentration as the only acceptable label claim for the amount of active ingredient in the
product.

       Current regulations require that the percentage listed in the active ingredient statement
be as precise as possible reflecting good manufacturing practices 40 CFR 156.10(g)(5). The
certified limits required for each active ingredient are intended to encompass any such "good
manufacturing practice" variations 40 CFR 158.175(c)(3).

       The upper and lower certified limits, which must be proposed in connection with a
product's registration, represent the amounts of an ingredient that may legally be present 40
CFR 158.1/5.  The lower certified limit is used as the enforceable lower limit for the product
composition according to FIFRA section 12(a)(l)(C), while the nominal concentration
appearing on the  label would be the routinely achieved concentration used for calculation of
dosages and dilutions.

       The nominal concentration would in fact state the greatest degree of accuracy that is
warranted with respect to actual product composition because the nominal concentration would
be the amount of active ingredient typically found in the product.

       It is important for registrants to note that certified limits for active ingredients are not
considered to be trade secret  information under FIFRA section 10 (b).  In this respect the
certified limits will be routinely provided by EPA to States for enforcement purposes, since

                                         153

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the nominal concentration appearing on the label may not represent the enforceable
composition for purposes or section 12(a)(l)(C).

III. REQUIREMENTS

       As described below under Unit V.  " COMPLIANCE SCHEDULE," all currently
registered products as well as all applications for new registration must comply with this
Notice by specifying the nominal concentration expressed as a percentage by weight as the
label claim in the ingredient(s) statement and equivalence statements if applicable (e.g.,
elemental arsenic, metallic zinc, salt of an acid). In addition, the requirement for performing
sample analyses of five or more representative samples must be fulfilled. Copies of the raw
analytical data must be submitted with the nominal ingredient label  claim. Further information
about the analysis requirement may be found in the 40 CFR 158.170. All products are
required to provide certified limits for each active, inert ingredient, impurities of toxicological
significance (i.e., upper limit(s) only) and on a case by case basis as specified by EPA. These
limits are to be set based on representative sampling and chemical analysis (i.e., quality
control) of the product.

       The format of the ingredient statement must conform to 40 CFR 156-Labeling
Requirements For Pesticides  and Devices.

       After July 1,  1997, all pesticide ingredient Statements must be changed to
nominal concentration.

IV. PRODUCTS THAT REQUIRE EFFICACY DATA

       All pesticides  are required to be efficacious. Therefore, the certified lower limits may
not be lower then the minimum level to achieve efficacy. This is extremely important for
products which are intended to control pests which threaten the public health, e.g., certain
antimicrobial  and rodenticide products. Refer to 40 CFR 153.640.

       In those cases where efficacy limits have been established, the Agency will not accept
certified lower limits  which are below that level for the shelf life of the product.

V. COMPLIANCE SCHEDULE

       As described earlier, the purpose of this Notice is to make the registration process
more  uniform and more manageable for both the agency and the regulated community. It is
the Agency's  intention to implement the requirements of this notice as smoothly as possible so
as not to disrupt or delay the Agency's high priority programs, i.e., reregistration, new
chemical,  or fast track (FIFRA section 3(c)(3)(B). Therefore,  applicants/registrants are
expected to comply with the requirements of this Notice as follows:

       (1)    Beginning July 1, 1991, all new product registrations submitted to the Agency
             are to comply with the requirements of this Notice.

       (2)    Registrants having products subject to reregistration under FIFRA section 4 (a)
             are to comply with the requirements of this Notice when specific products are
             called in by the Agency under Phase V of the Reregistration Program.
                                          154

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       (3)    All other products/applications that are not subject to (1) and (2) above will
             have until July 1, 1557, to comply with this Notice. Such applications should
             note "Conversion to Nominal Concentrations on the application form. These
             types Or amendments will not be handled as "Fast Track" applications but will
             be handled as routine requests.

VI. FOR FURTHER INFORMATION

Contact Tyrone Aiken  for information or questions concerning
this notice on (703) 308-7031.


                                             /s/
                                 Anne E. Lindsay, Director
                                 Registration Division (H-7505C)
                                         155

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156

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APPENDIX F.  Combined Generic and Product Specific
                  Data Call-In
                       157

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158

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                 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
          0
         f                            WASHINGTON, D.C. 20460
                         GENERIC AND PRODUCT SPECIFIC
                              DATA CALL-IN NOTICE
CERTIFIED MAIL
Dear Sir or Madam:

       This Notice requires you and other registrants of pesticide products containing the
active ingredient identified in Attachment A of this Notice, the Data Call-In Chemical Status
Sheet, to submit certain data as noted herein to the U.S. Environmental Protection Agency
(EPA, the Agency). These data are necessary to maintain the continued registration of your
product(s) containing this active ingredient. Within 90 days after you receive this Notice you
must respond as set forth in Section III below. Your  response must state:

       1.     How you will comply with the  requirements set forth in this Notice and its
             Attachments 1 through 7; or

       2.     Why you believe you are exempt from the requirements listed in this Notice and
             in Attachment 3 (for both generic and product specific data),  the Requirements
             Status and Registrant's Response Form, (see section III-B); or

       3.     Why you believe EPA should not require your submission of data in the manner
             specified by this Notice (see section III-D).

       If you do not respond to this Notice, or if you do not satisfy EPA that you will comply
with its requirements or should be exempt or excused from doing so, then the registration of
your product(s)  subject to this Notice will be subject to suspension. We have provided a list of
all of your products subject to this Notice in Attachment 2. All products are listed on both the
generic  and product specific Data Call-In Response Forms.  Also included is a list of all
registrants who  were sent this Notice (Attachment 6).

       The authority for this Notice is section 3(c)(2)(B) of the Federal Insecticide, Fungicide
and Rodenticide Act as amended (FIFRA), 7 U.S.C. section 136a(c)(2)(B).  Collection of this
information is authorized under the Paperwork Reduction Act by OMB Approval No.
2070-0107 and 2070-0057  (expiration date 3-31-96).

       This Notice is divided into six sections and seven Attachments. The Notice itself
contains information and instructions applicable to all Data Call-In  Notices.  The Attachments
contain  specific  chemical information and instructions. The six sections of the Notice are:
                                         159

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Section I     -      Why You are Receiving this Notice
Section II     -      Data Required by this Notice
Section III    -      Compliance with Requirements of this Notice
Section IV    -      Consequences of Failure to Comply with this Notice
Section V     -      Registrants' Obligation to Report Possible Unreasonable Adverse Effects
Section VI    -      Inquiries and Responses to this Notice

      The Attachments to this Notice are:

      1 -    Data Call-In Chemical Status Sheet
      2 -    Generic Data Call-In and Product Specific Data Call-In Response Forms with
             Instructions
      3 -    Generic Data Call-In and Product Specific Data Call-In Requirements Status
             and Registrant's Response Forms with Instructions
      4 -    EPA Grouping of End-Use Products for Meeting Acute Toxicology Data
             Requirements for Reregistration
      5 -    EPA Acceptance Criteria
      6 -    List of Registrants Receiving This Notice
      7 -    Cost Share and Data Compensation Forms


SECTION I. WHY YOU ARE RECEIVING THIS NOTICE

      The Agency has reviewed existing data for this active ingredient (s) and reevaluated the
data needed to support continued registration of the subject active ingredient(s). This
reevaluation identified additional data necessary to assess the health and safety of the continued
use of products containing this active ingredient(s). You have  been sent this Notice because
you have product (s)  containing the subject active ingredients.


SECTION II. DATA REQUIRED BY THIS NOTICE

II-A. DATA REQUIRED

      The data required by this Notice are specified in the Requirements Status and
Registrant's Response Forms: Attachment 3 (for both generic  and product specific data
requirements).  Depending on the results of the studies required in this  Notice, additional
studies/testing may be required.

II-B. SCHEDULE FOR SUBMISSION OF DATA

      You are required to submit the data or otherwise satisfy the data requirements specified
in the Requirements Status and Registrant's Response Forms (Attachment 3) within the
timeframes provided.

II-C. TESTING PROTOCOL

      All studies required under this Notice must be conducted in accordance with test
standards outlined in the Pesticide Assessment Guidelines for those studies for which
guidelines have been established.

      These EPA Guidelines are available  from the National Technical Information Service
(NTIS),  Attn: Order Desk, 5285 Port Royal Road, Springfield,  Va 22161 (Telephone  number:
703-487-4650).
                                         160

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       Protocols approved by the Organization for Economic Cooperation and Development
(OECD) are also acceptable if the OECD recommended test standards conform to those
specified in the Pesticide Data Requirements regulation (40 CFR § 158.70). When using the
OECD protocols, they should be modified as appropriate so that the data generated by the
study will satisfy the requirements of 40 CFR § 158. Normally, the Agency will not extend
deadlines for complying with  data requirements when the studies were not conducted in
accordance  with acceptable standards. The OECD protocols are available from  OECD, 2001 L
Street,  N.W., Washington, D.C. 20036 (Telephone number 202-785-6323;  Fax telephone
number 202-785-0350).

       All new studies and proposed protocols submitted in response to this Data Call-In
Notice  must be in accordance with Good Laboratory Practices [40 CFR Part 160].

II-D.   REGISTRANTS RECEIVING PREVIOUS SECTION 3(c)(2)(B) NOTICES ISSUED
       BY THE AGENCY
       Unless otherwise noted herein, this Data Call-in does not in any way supersede or
change the requirements of any previous Data Call-ln(s), or any other agreements entered into
with the Agency pertaining to such prior Notice. Registrants must comply with the
requirements of all Notices to avoid issuance of a Notice of Intent to Suspend their affected
products.


SECTION III.      COMPLIANCE WITH REQUIREMENTS OF THIS NOTICE

       You must use the correct forms and instructions when completing your response to  this
Notice.  The type of Data  Call-In you must comply with (Generic or Product Specific) is
specified in item number 3 on the four Data Call-in forms (Attachments 2 and 3).

III-A.  SCHEDULE FOR  RESPONDING TO THE AGENCY

       The appropriate responses initially required by this Notice for generic and product
specific data must be submitted to the Agency within  90 days after your receipt of this Notice.
Failure to adequately respond to this Notice within 90 days of your receipt will be a basis for
issuing a Notice of Intent to Suspend (NOIS) affecting your products. This and other bases for
issuance of NOIS due to failure to comply with this Notice are presented in Section IV-A and
IV-B.

III-B.  OPTIONS FOR RESPONDING TO THE AGENCY

       1. Generic Data Requirements

       The options for responding to this Notice for generic data requirements are: (a)
voluntary cancellation, (b) delete use(s), (c) claim generic data exemption, (d)  agree to satisfy
the generic data requirements imposed by this Notice or (e) request a data waiver (s).

       A discussion of how to respond if you choose  the Voluntary Cancellation option, the
Delete Use(s) option or the Generic Data Exemption option is presented below. A discussion
of the various options available for satisfying the generic data requirements of this Notice is
contained in Section III-C. A discussion of options relating to requests for data waivers is
contained in Section III-D.

       Two forms apply to generic data requirements, one or both of which must be  used in
responding to the Agency, depending upon your response.  These two forms are the
Data-CalHn Response Form, and the Requirements Status  and Registrant's Response Form,
(contained in Attachments  2 and 3, respectively).

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       The Data Call-in Response Forms must be submitted as part of every response to this
Notice. The Requirements Status and Registrant's Response Forms also must be submitted if
you do not qualify for a Generic Data Exemption or are not requesting voluntary cancellation
of your registration^). Please note that the company's authorized representative is required to
sign the first page of both Data Call-In Response Forms and the Requirements Status and
Registrant's Response Forms (if this form is required) and initial any subsequent pages. The
forms contain separate detailed instructions  on the response options.  Do not alter the printed
material. If you have questions or need assistance in preparing your response,  call or write the
contact person (s) identified in Attachment 1.

       a.     Voluntary Cancellation -

       You may avoid the requirements of this Notice by requesting voluntary cancellation of
your product (s) containing the active ingredient that is the subject of this Notice. If you wish
to voluntarily cancel your product, you must submit completed Generic and Product Specific
Data Call-in Response Forms (Attachment 2), indicating your election of this option.
Voluntary cancellation is item number 5 on both Data Call-In  Response Form(s). If you
choose this option, these are the only forms that you are required to complete.

       If you chose to voluntarily cancel your product, further sale and distribution of your
product after the effective date of cancellation must be in accordance with the  Existing Stocks
provisions of this Notice, which are contained in Section IV-C.

       b.     Use Deletion -

       You may avoid the requirements of this Notice by eliminating the uses of your product
to which the requirements apply. If you wish to amend your registration to delete uses, you
must submit the Requirements Status and  Registrant's Response Form (Attachment 3),  a
completed application for amendment, a copy of your proposed amended labeling, and all
other information required for processing the application.  Use deletion is option number 7
under item 9 in the instructions for the Requirements Status and Registrant's Response Forms.
You must also complete a Data Call-In Response Form by signing the certification,  item
number 8.  Application forms for amending registrations may be obtained from the
Registration Support Branch, Registration Division, Office of Pesticide Programs, EPA, by
calling (703)     ~~-~
       If you choose to delete the use(s) subject to this Notice or uses subject to specific data
requirements, further sale, distribution, or use of your product after one year from the due
date of your 90 day response, is allowed only if the product bears an amended label.

       c.     Generic Data Exemption -

       Under section 3(c)(2)(D) of FIFRA, an applicant for registration of a product is
exempt from the requirement to submit or cite generic data concerning an active ingredient if
the active ingredient in the product is derived exclusively from purchased, registered pesticide
products containing the active ingredient. EPA has concluded, as an exercise of its discretion,
that it normally will not suspend the registration of a product which would qualify and
continue to qualify for the generic data exemption in section 3(c)(2)(D)  of FIFRA. To qualify,
all of the following requirements must be met:

       (i). The active ingredient in your registered product must be present solely because of
       incorporation of another registered product which contains the subject active ingredient
       and is purchased from a source not connected with you;
                                          162

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       (ii).  Every registrant who is the ultimate source of the active ingredient in your
       product subject to this DCI must be in compliance with the requirements of this Notice
       and must remain in compliance; and

       (iii). You must have provided to EPA an accurate and current " Confidential Statement
       of Formula" for each of your products to which this Notice applies.

       To apply for the Generic Data Exemption you must submit a completed Data Call-in
Response Form, Attachment 2 and all supporting documentation.  The Generic Data Exemption
is item number 6a on the Data Call-in Response Form. If you claim a generic data exemption
you are not required to compiete the Requirements Status and Registrant's Response Form.
Generic Data Exemption cannot be selected as an option tor responding to product specific
data requirements.

       If you are granted a Generic  Data Exemption, you rely on the efforts of other persons
to provide the Agency with the required  data. If the registrant^) who have committed to
generate and submit the required data fail to take appropriate  steps to meet requirements or are
no longer in compliance with this Data Call-In Notice, the Agency will consider that both they
and you are not compliance and will normally initiate proceedings to suspend the registrations
of both your and their product(s), unless you commit to submit and do submit the required
data within the specified time. In such cases the Agency generally will not grant a time
extension for submitting the data.

       d.     Satisfying the Generic Data Requirements of this Notice

       There are various options available to satisfy the generic data requirements of this
Notice. These options are discussed  in Section III-C.l. of this Notice and comprise options 1
through 6 of item 9 in the instructions for the Requirements Status and Registrant's Response
Form and item 6b on the Data Call-In Response Form,  if you choose item 6b (agree to satisfy
the generic data requirements), you must submit the Data Call-In  Response Form and the
Requirements  Status and Registrant's Response Form as weii  as any other information/data
pertaining to the option chosen to address the data requirement. Your response must be on the
forms marked "GENERIC" in item number 3.

       e.     Request for Generic Data Waivers.

       Waivers for generic data are  discussed in Section III-D.l.  of this Notice and are
covered by options 8 and 9 of item 9 in the instructions for the  Requirements Status and
Registrant's Response Form.  If you  choose one of these options, you must submit both forms
as well as any other information/data pertaining to the option  chosen to address the data
requirement.
       2. Product Specific Data Requirements

       The options for responding to this Notice for product specific data are:  (a) voluntary
cancellation, (b) agree to satisfy the product specific data requirements imposed by this Notice
or (c) request a data waiver (s).

       A discussion of how to respond if you choose the Voluntary Cancellation option is
presented below.  A discussion of the various options available for satisfying the product
specific data requirements of this Notice is contained in Section III-C.2. A discussion of
options relating to requests for data waivers is contained in Section III-D.2.
                                          163

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       Two forms apply to the product specific data requirements one or both of which must
be used in responding to the Agency, depending upon your response. These forms are the
Data-Call-in Response Form, and the Requirements Status and Registrant's Response Form,
for product specific data (contained in Attachments Z and 3, respectively).  1 he Data CallTn
Response Form must be submitted as part of every response to this Notice. In addition, one
copy of the Requirements Status and Registrant's Response Form also must be submitted for
each product listed on the Data Caii-ln Response Form uniess the voluntary cancellation option
is selected.  Please note  that the company's authorized representative is required to sign the
first page of the Data Call-in Response Form and Requirements Status and Registrant s
Response Form (if this form is required) and initial any subsequent pages. 1 he forms contain
separate detailed instructions on the response options.  Do not alter the printed material. If you
have questions or need assistance in preparing your response,  call or write the contact
person(s) identified in Attachment  1.

       a.     Voluntary Cancellation

       You  may avoid the requirements of this Notice by requesting voluntary cancellation of
your product (s) containing the active ingredient that is the subject of this Notice. If you wish
to  voluntarily cancel your product, you must submit a completed Data Call-in Response Form,
indicating your election  of this option. Voluntary cancellation is item number b on both the
Generic and Product Specific Data Call-in Response Forms. If you choose this
option, you  must complete both Data Call-In response forms.  These  are the only forms that
you are required to complete.

       If you choose to  voluntarily cancel  your product, further sale and distribution of your
product after the effective date of cancellation must be in accordance with the  Existing  Stocks
provisions of this Notice which  are contained in Section  IV-C.

       b.     Satisfying the Product Specific Data Requirements of this Notice.

       There are various options available to satisfy the  product specific data requirements  of
this Notice.  These options are discussed in Section III-C.2. of this Notice  and  comprise
options 1 through 6 of item 9 in the instructions for the  product specific Requirements  Status
and Registrant's Response Form and item numbers 7a and 7b  (agree  to satisfy the product
specific data requirements for an MUP or EUP as applicable)  on the product specific Data
Call-in Response Form. Note that the  options available for addressing product specific  data
requirements differ slightly from those options for fulfilling generic data requirements.
Deletion of a use(s) and the low volume/minor use option are not valid options for fulfilling
product specific data requirements. It is important to ensure that you are using the correct
forms and instructions when completing your response to the Reregistration Eligibility
Decision document.

       c.     Request for Product Specific Data Waivers.

       Waivers for product specific data are discussed in Section III-D.2.  of this Notice and
are covered  by option 7  of item 9 in the instructions for the  Requirements Status and
Registrant's Response Form. If you choose this option,  you must submit the  Data Call-In
Response Form and the  Requirements Status and Registrant's Response  Form  as well as any
other information/data pertaining to the option  chosen to address the data requirement.  Your
response must be on the forms marked "PRODUCT SPECIFIC"  in item number 3.
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III-C SATISFYING THE DATA REQUIREMENTS OF THIS NOTICE

       1.     Generic Data

       If you acknowledge on the Generic Data Call-In Response Form that you agree to
satisfy the generic data requirements (i.e. you select item number 6b), then you must select
one of the six options on the Generic Requirements Status and Registrant's Response Form
related to data production for each data requirement. Your option selection should be entered
under item number 9,  "Registrant Response." The six options related to data production  are
the first six options discussed under item 9 in the  instructions for completing the Requirements
Status and Registrant's Response Form. These six options are listed
immediately below with information in parentheses to guide you to additional instructions
provided in this Section. The options are:

       (1)    I will generate and submit data within the specified timeframe (Developing
             Data)
       (2)    I have entered into an agreement with one or more registrants to develop data
             jointly (Cost Sharing)
             I have made offers to cost-share (Offers to Cost Share)
             I am submitting an existing study that has not been submitted previously to the
             Agency by anyone (Submitting an Existing  Study)
       (5)    I am submitting or citing data to upgrade a study classified by EPA as partially
             acceptable and upgradeable (Upgrading a Study)
       (6)    I am citing an existing study that EPA has classified as acceptable or an  existing
             study that has been submitted but not reviewed by the Agency (Citing an
             -i-i.-i.   Oj_1\                                      OJVO
             Existing Study)

Option 1. Developing Data

       If you choose to develop the required data it must be in conformance with Agency
deadlines and with other Agency requirements as  referenced herein and in the attachments. All
data generated and submitted must comply with the Good  Laboratory Practice (GLP) rule (40
CFR Part 160), be conducted according to the Pesticide Assessment Guidelines  (PAG)  and be
in conformance with the requirements  of PR  Notice 86-5.  In addition, certain studies require
Agency approval of test protocols in advance of study initiation. Those studies for which a
protocol must be submitted have been  identified in the Requirements Status and  Registrant's
Response Form and/or footnotes to the form. If you wish to use a protocol which differs from
the options discussed in Section II-C of this Notice, you must submit a detailed description of
the proposed protocol and your reason for wishing to use it. The Agency  may choose to  reject
a protocol not specified in Section II-C. If the Agency rejects your protocol you will be
notified in writing, however, you should be aware that rejection of a proposed protocol will
not be  a basis for extending the deadline for submission of data.

       A progress report must be submitted for each study within 90 days from the date  you
are required to commit to generate or undertake some other means to address that study
requirement, such as making an offer to cost share or agreeing to share in the cost of
developing that study.  This  90-day progress  report must include the date the study was or will
be initiated and, for studies to be started within 12 months of commitment, the name and
address of the laboratory(ies) or individuals who are or will be conducting the study.

       In addition, if the time frame for submission of a final report is more than 1 year,
interim reports must be submitted at 12 month intervals from  the date  you are required to
commit to generate or otherwise address the requirement for the study. In addition to the other
information  specified in the preceding  paragraph, at a minimum, a brief description  of current
activity on and the status of the study must be included as well as  a full
description of any problems  encountered since the last progress report.


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       The time frames in the Requirements Status and Registrant's Response Form are the
time frames that the Agency is allowing tor the submission of completed study reports or
protocols. The noted deadlines run from the date of the receipt of this Notice by the registrant.
If the data are not submitted by the deadline, each registrant is subject to receipt of a Notice of
Intent to Suspend the affected registration(s).

       If you cannot submit the data/reports to the Agency in the time required by this Notice
and intend to seek additional time to meet the requirements(s), you must submit a request to
the Agency which includes:  (1)  a detailed description of the expected difficulty and (2)  a
proposed schedule including alternative dates for meeting such requirements on a step-by-step
basis. You must explain any technical or laboratory difficulties and provide documentation
from the laboratory performing the testing.  While EPA is considering your request, the
original deadline remains. The Agency will respond to your request in writing. If EPA does
not grant your request, the original deadline remains. Normally, extensions can be requested
only in cases of extraordinary testing problems beyond the expectation or control of the
registrant. Extensions will not be given in submitting the 90-day responses. Extensions will
not be considered if the request for extension is not made in a timely fashion; in no event shall
an extension request be considered if it is submitted at or after the lapse of the subject
deadline.

Option 2. Agreement to Share in Cost to Develop Data

       If you choose to enter into an agreement to share in the cost of producing the required
data but will not be  submitting the data yourself, you must provide the name of the registrant
who will be submitting the data. You must also provide EPA with documentary evidence that
an agreement has been formed.  Such evidence may be your letter offering to join in an
agreement and the other registrant's acceptance of your offer, or a written statement by the
parties that an agreement exists. The agreement to produce the data need not specify all of the
terms of the final arrangement between the parties or the mechanism to resolve the terms.
Section 3(c)(2)(B) provides that if the parties cannot resolve the terms of the agreement they
may resolve their differences through binding arbitration.

Option 3. Offer to Share in the  Cost of Data Development

       If you have made an offer to pay in an attempt to enter into an agreement or amend an
existing agreement to meet the requirements of this Notice and have been unsuccessful, you
may request EPA (by selecting this option) to exercise its discretion not to suspend your
registration (s), although you do not comply with the data submission requirements of this
Notice.  EPA has determined that as a general policy, absent other relevant considerations, it
will not suspend the registration of a product of a registrant who has in good faith sought and
continues to seek to enter into a joint data development/cost sharing program,  but the other
registrant^) developing the data has refused to accept the offer. To qualify for this option, you
must submit documentation to the Agency proving that you have made an offer to another
registrant (who has an obligation to submit data)  to share in the burden of developing that
data. You must also submit to the Agency a completed EPA Form 8570-32,  Certification of
Offer to Cost Share in the Development of Data, Attachment 7. In addition, you must
demonstrate that the other registrant to whom the offer was made has not accepted your offer
to enter into a cost-sharing agreement by including a  copy of your offer and proof of the other
registrant's receipt of that offer (such as a certified mail receipt). Your offer must, in addition
to anything else, offer to share in the burden of producing the data upon terms to be agreed to
or, failing agreement, to  be bound by binding arbitration as provided by FIFRA section
3(c)(2)(Bj(iii) and must not qualify this offer. The other registrant must also inform EPA of its
election of an option to develop and submit the data required by this Notice by submitting a
Data Call-In Response  Form and a Requirements Status and Registrant's Response Form
committing to develop  and submit the data required by this Notice.


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       In order for you to avoid suspension under this option, you may not withdraw your
offer to share in the burden of developing the data. In addition, the other registrant must fulfill
its commitment to  develop and submit the data as required by this Notice. If the other
registrant fails to develop the data or for some other reason is subject to suspension,  your
registration as well as that of the other registrant normally will be subject to initiation of
suspension proceedings, unless you commit to submit, and do submit, the required data in the
specified time frame. In such cases, the Agency generally will not grant a time extension for
submitting the data.

Option 4. Submitting an Existing Study

       If you choose to submit an existing study in response to this Notice, you must
determine that the  study satisfies the requirements imposed by this Notice.  You may  only
submit a study that has not been previously submitted to the Agency or previously cited by
anyone. Existing studies are studies which predate issuance of this Notice. Do not use this
option if you are submitting data to upgrade a study.  (See Option 5).

       You should be aware that if the Agency determines that the study is not acceptable, the
Agency will require you to comply with this Notice, normally without an extension of the
required date of submission. The Agency may determine at any time that a study is not valid
and needs to be repeated.


       To meet the requirements of the DCI Notice for submitting an existing study, all of the
following three criteria must be clearly Met:

       a.     You must certify at the time that the existing study is submitted that the raw
              data and specimens from the study are available for audit and review and you
              must identify where they are available. This must be done in accordance with
              the requirements of the Good Laboratory Practice  (GLP) regulation, 40  CFR
              Part 160. As stated in 40 CFR  160.3 'Raw data' means any laboratory
              worksheets, records, memoranda, notes, or exact copies thereof, that are the
              result of original observations and activities of a study and are necessary for the
              reconstruction and evaluation of the report of that study. In the event that exact
              transcripts of raw data have been prepared (e.g., tapes which have been
              transcribed verbatim, dated, and verified accurate by signature), the exact copy
              or exact transcript may be substituted for the original source as raw data. 'Raw
              data' may include photographs, microfilm or microfiche copies, computer
              printouts, magnetic media, including dictated observations, and recorded data
              from automated instruments." The term "specimens", according to 40 CFR
              160.3, means "any material derived from a test system for examination or
              analysis."

       b.     Health and safety studies completed after May 1984 also must  also contain all
              GLP-required quality assurance and quality control information, pursuant to the
              requirements or 40 CFR Part 160. Registrants also must certify at the  time of
              submitting the existing study that such GLP information is available for post
              May 1984 studies by including an appropriate statement on or  attached to the
              study signed by an authorized official or representative of the registrant.

       c.     You must certify that each study fulfills the acceptance criteria for the Guideline
              relevant to the study provided in the FIFRA Accelerated Reregistration Phase 3
              Technical Guidance and that the study has been conducted according to the
              Pesticide Assessment Guidelines (PAG) or meets the purpose of the PAG (both
              available from NTIS). A study not conducted according to the PAG may be
              submitted to the Agency for consideration if the registrant believes that the


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             study clearly meets the purpose of the PAG. The registrant is referred to 40
             CFR 158.70 which states the Agency's policy regarding acceptable protocols. If
             you wish to submit the study, you must, in addition to certifying that the
             purposes of the PAG are met by the study, clearly articulate the rationale why
             you believe the study meets the purpose of the PAG, including copies of any
             supporting information or data. It has been the Agency's experience that studies
             completed prior to January 1970 rarely satisfied the purpose of the PAG and
             that necessary raw data usually are not available for such studies.

       If you submit an existing study,  you must certify  that the study  meets all requirements
of the criteria outlined  above.

       If EPA has previously reviewed a protocol for a study you are submitting, you must
identify any action taken  by the Agency on the protocol and must indicate, as part of your
certification, the manner  in which all Agency comments, concerns, or issues were addressed
in the final protocol and study.

       If you know of  a study pertaining to any requirement in this Notice which does not
meet the criteria outlined above but does contain factual information regarding unreasonable
adverse effects, you must notify the Agency of such a study. If such study is in the Agency's
files, you need only cite it along with the notification. If not in the Agency's files, you must
submit a summary and  copies as required by PR Notice 86-5.

Option 5. Upgrading a  Study

       If a study has been classified as  partially acceptable and upgradeable, you may submit
data to upgrade that study. The  Agency will review the data submitted  and determine if the
requirement is satisfied. If the Agency decides the requirement is not satisfied, you may still
be required to submit new data normally without any time extension. Deficient, but
upgradeable studies will normally be classified as supplemental.  However, it is important to
note that not all studies classified! as supplemental are upgradeable. If you have questions
regarding the classification of a study or whether a study may be upgraded, call or write the
contact person listed in Attachment 1. If you submit data to upgrade an existing study you
must satisfy or supply information to correct all deficiencies in the study  identified by EPA.
You must provide  a clearly articulated rationale" of how the deficiencies have been remedied or
corrected and why the study should be rated as acceptable to EPA. Your  submission must also
specify the MRID  number (s) of the study which you are  attempting to upgrade and must be in
conformance with  PR Notice 86-5.

       Do  not submit additional data for the purpose of upgrading a study classified as
unacceptable and determined by the Agency as not capable of being upgraded.

       This option also should be used  to cite data that has been previously submitted to
upgrade a study, but has not yet been reviewed by the Agency. You must provide the MRID
number of  the data submission as well as the MRID nurriber of the study  being upgraded.

       The criteria for  submitting an existing study, as specified in Option 4 above, apply to
all data submissions intended to upgrade studies.  Additionally, your submission of data
intended to upgrade studies must be accompanied by a certification that you comply with  each
of those criteria, as well as a certification regarding protocol compliance  with Agency
requirements.

Option 6. Citing Existing Studies

       If you choose to cite a study that has been previously submitted to EPA, that study
must have been previously classified by EPA as acceptable, or it must be a study which has


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not yet been reviewed by the Agency. Acceptable toxicology studies generally will have been
classified as "core-guideline" or "core-minimum." For ecological effects studies, the
classification generally would be a rating of "core." For all other disciplines the classification
would be "acceptable." With respect to any studies for which you wish to select this option,
you must provide the MRID number of the study you are citing and, if the study has been
reviewed by the Agency, you must provide the Agency's classification of the study.

       If you are citing a study of which you are not the original data submitter, you must
submit a completed copy of EPA Form 8570-31, Certification with Respect to Data
Compensation Requirements.

       2. Product Specific Data

       If you acknowledge on the product specific Data Call-in Response Form that you agree
to satisfy the product specific data requirements (i.e. you select option Ya or Yb), then you
must select one of the six options on the Requirements Status and Registrant's Response Form
related to data production for each data requirement. Your option selection should be entered
under item number  9, "Registrant Response." The six options related to data production are
the first six options discussed under item 9 in the instructions for completing the Requirements
Status and Registrant's Response  Form.  These six options are listed immediately below with
information in parentheses to guide registrants to additional instructions provided in this
Section. The options are:

       (1)     I will generate and submit data within the specified time-frame (Developing
              Data)
       (2)     I have entered into an agreement with one or more registrants to develop data
             jointly (Cost Sharing)
              I have made offers to cost-share (Offers to Cost Share)
              I am submitting an existing study that has not been submitted previously to the
              Agency by anyone (Submitting an Existing Study)
       (5)     I am submitting or citing data to upgrade a study classified by EPA as partially
              acceptable and upgradeable (Upgrading a Study)
       (6)     I am citing an existing study that EPA has classified  as acceptable or an  existing
              study that has been
              submitted but not reviewed by the Agency (Citing an Existing Study)

Option 1. Developing Data — The requirements for developing product specific data are the
same  as those described for generic data  (see Section III.C.I, Option 1) except that normally
no protocols or progress reports are required.

Option 2. Agree to  Share in Cost to Develop Data — If you enter into an agreement to  cost
share, the same requirements apply to product specific data as to generic data (see Section
III.C.I, Option 2).  However, registrants may only choose this option for  acute toxicity data
and certain efficacy data and only if EPA has indicated  in the attached data tables that your
product and at least one other product are similar  for purposes of depending on
the same data. If this is the case, data may be generated for just one of the products in  the
group. The registration number of the product for which data will be submitted must be noted
in the agreement to cost share  by the registrant selecting this option.

Option 3. Offer to Share in the Cost of Data Development —The same requirements for
generic data (Section lll.C.l.,  Option 3) apply to this option. This option  only applies to acute
toxicity and certain efficacy data as described in option  2 above.

Option 4. Submitting an Existing Study — The same requirements described for generic data
(see Section lll.C.l" Option 4) apply to  this option for product specific data.
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Option 5. Upgrading a Study — The same requirements described for generic data (see Section
llI.C.l., Option b) apply to this option for product specific data.

Option 6. Citing Existing Studies — The same requirements described for generic data (see
Section 111.0.17, Option 6) apply to this option for product specific data.

       Registrants who select one of the above 6 options must meet all of the requirements
described in the instructions  for completing the Data Call-in Response Form and the
Requirements Status and Registrant's Response Form, and in the generic data requirements
section  (lll.C.l.), as appropriate.


III-D REQUESTS FOR DATA WAIVERS

       1.     Generic Data

       There are two types of data waiver responses to this Notice. The first is a request for a
low volume/minor use waiver and the second is a waiver request based on your belief that the
data requirement(s) are not appropriate for your product.

       a.     Low Volume/Minor Use Waiver

             Option  8 under item 9 on the Requirements Status and Registrant's Response
       Form. Section 3(c)(2)(A) of FIFRA requires EPA to consider the appropriateness of
       requiring data for  low volume, minor use pesticides.  In implementing this provision,
       EPA considers low volume  pesticides to be only those active ingredients whose total
       production volume for all pesticide registrants is small. In determining whether to grant
       a low volume,  minor  use waiver,  the Agency will consider the extent, pattern and
       volume of use, the economic incentive to conduct the testing, the importance of the
       pesticide, and the  exposure  and risk from use of the pesticide. If an active ingredient is
       used for both high volume and low volume uses, a low volume exemption will not be
       approved. If all uses of an active ingredient are low volume and the combined volumes
       for all uses are also low, then an exemption may be granted, depending on review of
       other information  outlined below. An exemption will not be granted if any registrant of
       the active ingredient elects to conduct the testing. Any registrant receiving a low
       volume minor use waiver must remain within the sales figures in their forecast
       supporting the waiver request in order to remain qualified for such waiver. If granted a
       waiver, a registrant will be  required, as a condition of the waiver, to submit annual
       sales reports. The Agency will respond to requests for waivers in writing.

             To apply for a low volume, minor use waiver, you must submit the following
       information, as applicable to your  product(s), as part of your 90-day  response to this
       Notice:

             (i). Total company sales (pounds and dollars) of all registered product(s)
       containing the active  ingredient. If applicable to the active ingredient, include foreign
       sales for those products that are not registered in this country but are applied to sugar
       (cane or beet), coffee, bananas, cocoa, and other such crops. Present the above
       information by year for each of the past five years.

             (ii) Provide an estimate of the sales (pounds and dollars) of the active
       ingredient for each major use site. Present the above  information by year for each of
       the past five years.
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       (iii)  Total direct production cost of product (s) containing the active ingredient
by year for the past five years. Include information on raw material cost, direct labor
cost, advertising, sales and marketing, and any other significant costs listed separately.

       (iv)  Total indirect production cost (e.g. plant overhead,  amortized plant and
equipment) charged to product (s) containing the active ingredient by year for the past
five years. Exclude all non-recurring costs that were directly related to the active
ingredient, such as costs of initial registration and any data development.

       (v)  A list of each data requirement for which you seek a waiver. Indicate the
type of waiver sought and the estimated cost to you (listed separately for each data
requirement and associated test) of conducting the testing needed to fulfill each of these
data requirements.

       (vi)  A list of each data requirement for which you are not seeking any waiver
and the estimated cost to you (listed separately for each data requirement and associated
test) of conducting the testing needed to fulfill each of these data requirements.

       (vii)  For each of the next ten years, a year-by-year forecast of company sales
(pounds and dollars) of the active ingredient, direct production  costs of product (s)
containing the active ingredient (following the parameters in item 2 above), indirect
production costs of product(s) containing the  active ingredient (following the
parameters in item 3 above),  and costs of data development pertaining to the active
ingredient.

       (viii)  A description of the importance and unique benefits of the active
ingredient to users.  Discuss the use patterns and the effectiveness of the active
ingredient relative to registered alternative chemicals and non-chemical control
strategies. Focus on benefits  unique to the active ingredient, providing information that
is as quantitative as possible.  If you do not have quantitative data upon which to base
your estimates, then present the reasoning used to derive your estimates. To assist the
Agency in determining the degree of importance of the active ingredient in terms of its
benefits, you should provide  information on any of the following factors, as applicable
to your product(s):  (a) documentation of the usefulness of the active ingredient in
Integrated Pest Management,  (b) description of the beneficial impacts on the
environment of use  of the active ingredient, as opposed to its registered alternatives,
(c) information on the breakdown of the active  ingredient after  use and on its
persistence in the environment, and (d) description of its usefulness against a pest(s) of
public health significance.

       Failure to submit sufficient information  for the Agency to make a determination
regarding a request for a low volume/minor use waiver will result in denial of the
request for a waiver.

b.      Request for Waiver of Data

       Option 9, under Item  9, on the Requirements Status and Registrant's Response
Form. This option may be used if you believe that a particular data requirement should
not apply because the requirement is inappropriate. You must submit a rationale
explaining why you believe the data requirements should not apply. You also must
submit the current label(s) of your product(s) and, if a current copy of your
Confidential Statement of Formula is not already on file you must submit a current
copy.

       You will be  informed of the Agency's decision in writing. If the Agency
determines that the data requirements of this Notice are not appropriate to your


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       product(s), you will not be required to supply the data pursuant to section 3(c)(2)(B). If
       EPA determines that the data are required Tor your product(s)  you must choose a    ~~
       method or meeting the requirements of this Notice within the time frame provided by
       this Notice. Within 30 days or your receipt or the Agency's written decision, you must
       submit a revised Requirements Status and Registrant s Response Form indicating the
       option chosen.

       2. Product Specific Data

             If you request a waiver for product specific data because you believe it is
       inappropriate, you must attach a complete justification for the request including
       technical  reasons,  data and references to relevant EPA regulations, guidelines or
       policies.  (Note: any supplemental data must be submitted in the format required by PR
       Notice 86-5). This will be the only opportunity to  state the reasons or provide
       information in support of your request. If the Agency approves your waiver request,
       you will not be required to supply the data pursuant to section 3(c)(2)(B)  of FIFRA. If
       the Agency denies your waiver request, you must choose an option for  meeting the data
       requirements of this Notice within 30 days of the receipt of the Agency's decision.
       You must indicate and submit the option chosen on the product specific Requirements
       Status and Registrant's Response Form. Product specific data requirements for product
       chemistry, acute toxicity and efficacy (where appropriate) are required  for all products
       and the Agency would grant a waiver only under extraordinary circumstances. You
       should also  be aware that submitting a waiver request will not automatically extend the
       due date for the study in question. Waiver requests submitted~without adequate
       supporting rationale will be denied and the original due date will remain in force.


SECTION IV.       CONSEQUENCES OF FAILURE TO COMPLY WITH THIS
                    JMUTICE

IV-A  NOTICE OF INTENT TO SUSPEND

       The Agency may issue a Notice of Intent to Suspend products subject to this Notice due
to failure by a registrant to comply with the requirements of this Data Call-In Notice, pursuant
to FIFRA section 3 (c) (2) (B). Events which may be the basis for issuance of a Notice of Intent
to Suspend include, but are not limited to, the following:

       1.     Failure to respond  as required by this Notice within 90 days of your receipt of
             this Notice.

       2.     Failure to submit on the required schedule an acceptable proposed or final
             protocol when such is required to be submitted to the Agency for review.

       3.     Failure to submit on the required schedule an adequate progress report on a
             study as required by this Notice.

       4.     Failure to submit on the required schedule acceptable data as required by this
             Notice.

       5.     Failure to take a required action or submit adequate information pertaining to
             any option chosen to address the data requirements  (e.g., any required action or
             information pertaining to submission or citation of existing studies or offers,
             arrangements, or arbitration on the sharing of costs or the formation of Task
             Forces, failure to comply with the terms of an agreement or arbitration
             concerning joint data development or failure to comply with any terms of a data
             waiver).

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       6.     Failure to submit supportable certifications as to the conditions of submitted
             studies, as required by Section III-C of this Notice.

       7.     Withdrawal of an offer to share in the cost of developing required data.

       8.     Failure of the registrant to whom you have tendered an offer to share in the cost
             of developing data and provided proof of the registrant's receipt of such offer
             or failure of a registrant on whom you rely for a generic data exemption either
             to:

             i.  Inform EPA of intent to develop and submit the data required  by this Notice
             on a Data Call-in Response Form and a Requirements Status and Registrant's
             Response Form.

             ii. Fulfill the commitment to develop and submit the data as required by this
             Notice; or

             iii.  Otherwise take appropriate steps to meet the requirements stated in this
             Notice,

             unless you commit to submit and do submit the required data in the specified
             time frame.

       9.     Failure to take any required or appropriate steps, not mentioned above, at any
             time following the issuance of this Notice.

IV-B.  BASIS FOR DETERMINATION THAT SUBMITTED STUDY IS
       UNACCEPTABLE

       The Agency may determine that a study (even if submitted within the required time) is
unacceptable and constitutes a basis for issuance of a Notice of Intent to Suspend. The grounds
for suspension include, but are not limited to, failure  to meet any of the following:

       1)     EPA requirements specified in the Data Call-In Notice or other documents
       incorporated by reference (including, as applicable, EPA Pesticide  Assessment
       Guidelines,  Data Reporting Guidelines, and GeneTox Health Effects Test Guidelines)
       regarding the design, conduct, and reporting of required studies. Such requirements
       include, but are not limited to, those relating to test material, test procedures, selection
       of species, number of animals, sex and distribution of animals,  dose and effect levels  to
       be tested or attained, duration of test,  and, as applicable, Good Laboratory Practices.

       2)     EPA requirements regarding the submission of protocols, including the
       incorporation of any changes required by the Agency following review.

       3)     EPA requirements regarding the reporting of data, including the manner of
       reporting, the completeness of results, and the adequacy of any required supporting (or
       raw) data, including, but not limited to, requirements  referenced or included in this
       Notice or contained in  PR 86-5. All studies must be submitted in the  form of a final
       report; a preliminary report will not be considered to fulfill the submission
       requirement.

IV-C   EXISTING STOCKS OF SUSPENDED OR CANCELLED PRODUCTS

       EPA has statutory authority to permit  continued sale, distribution and use of existing
stocks of a  pesticide product which has been suspended or cancelled  if doing so  would be
consistent with the  purposes of the Act.


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       The Agency has determined that such disposition by registrants of existing stocks for a
suspended registration when a section 3 (c) (2) (B) data request is outstanding generally would
not be consistent with the Act's purposes. Accordingly, the Agency anticipates granting
registrants permission to sell, distribute,  or use existing stocks of suspended product(s) only in
exceptional circumstances. If you believe such disposition of existing stocks of your product (s)
which may be suspended for failure to comply with this Notice should be permitted, you have
the burden of clearly demonstrating to EPA that granting such permission would be consistent
with the Act. You also must explain why an "existing stocks" provision is necessary,  including
a statement of the quantity of existing stocks and your estimate of the  time required for their
sale, distribution, and use. Unless you meet this burden, the Agency will not consider any
request pertaining to the continued sale,  distribution, or use of your existing stocks after
suspension.

       If you request a voluntary cancellation of your product(s) as a response to this Notice
and your product is in full compliance with all Agency requirements, you will have, under
most circumstances,  one year from the date your 90 day response to this Notice is due, to sell,
distribute, or use existing stocks. Normally, the Agency will allow persons other than the
registrant such as independent distributors, retailers and end users to sell, distribute or use
such existing stocks until the stocks are exhausted. Any sale, distribution or use of stocks of
voluntarily cancelled products containing an active ingredient for which the Agency has
particular risk concerns will be determined on a case-by-case basis.

       Requests for voluntary cancellation received after the 90 day response period required
by this Notice will not result in the agency granting any additional time to sell, distribute, or
use existing stocks beyond a year from the date the 90 day response was due, unless you
demonstrate to the Agency that you are in full compliance with all Agency requirements,
including the requirements of this Notice. For example, if you decide  to voluntarily cancel
your registration six months before a 3-year study is scheduled to be submitted, all progress
reports and other information necessary to establish that you have been conducting the study in
an acceptable and good faith manner must have been submitted to the  Agency,  before EPA
will consider granting an existing stocks  provision.


SECTION V.       REGISTRANTS'  OBLIGATION TO REPORT POSSIBLE
                    LJJMREASONABLE ADVERSE EFFECTS

       Registrants are reminded that FIFRA section 6 (a) (2) states that if at any time after a
pesticide is registered a registrant has additional factual information regarding unreasonable
adverse effects on the environment by the pesticide, the registrant shall submit the information
to the Agency. Registrants must notify the Agency of any factual information they have, from
whatever source, including but not limited to interim or preliminary results of studies,
regarding unreasonable adverse effects on man or the environment. This requirement
continues as long as the products are registered by the Agency.


SECTION VI.       INQUIRIES AND RESPONSES TO THIS NOTICE

       If you have any questions regarding the requirements and procedures established by
this Notice, call the contact person(sj  listed in Attachment 1, the Data Call-in Chemical Status
Sheet.

       All responses to this Notice must include completed Data Call-in Response Forms
(Attachment 2|and completed Requirements Status and Registrant's Response Forms
(Attachment 3), for both (generic and product specific data)  and any other documents required
by this Notice, and should be submitted to the contact person(s) identified in Attachment 1.  If


                                          174

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the voluntary cancellation or generic data exemption option is chosen, only the Generic and
Product Specific Data Call-in Response Forms need be submitted.

       The Office of Compliance (OC) of the Office of Enforcement and Compliance
Assurance (OECA), EPA, will be monitoring the data being generated in response to this
Notice.

                                 Sincerely yours,
                                 Lois A. Rossi, Director
                                 Special Review and
                                  Reregistration Division
Attachments
       The Attachments to this Notice are:

       1 -    Data Call-In Chemical Status Sheet
       2 -    Generic Data Caii-ln and Product Specific Data Call-In Response Forms with
             Instructions
       3 -    Generic Data Call-In and Product Specific Data Call-In Requirements Status
             and Registrant's Response Forms with Instructions
       4 -    EPA Batching of End-Use Products for Meeting Acute Toxicology Data
             Requirements for Reregistration
       5 -    EPA Acceptance Criteria
       6 -    List of Registrants  Receiving This Notice
       7 -    Confidential Statement of Formula, Cost Share and Data Compensation Forms
                                          175

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176

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Attachment 1. Chemical Status Sheets
                177

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178

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METOLACHLOR DATA CALL-IN CHEMICAL STATUS SHEET

INTRODUCTION

      You have been sent this Generic  Data Call-In Notice because you have product(s)
containing Metolachlor.

      This Generic Data Call-In Chemical Status Sheet, contains an overview of data
required by this notice, and point or contact tor inquiries pertaining to the reregistration of
Metolachlor.  This attachment is to be used in conjunction with (1) the Generic Data Call-In
Notice, (2) the Generic Data Call-In Response  Form (Attachment 2), (3) the Requirements
Status and Registrant's Form (Attachment 2), (4) a list of registrants receiving this DCI
(Attachment 4), (5) the EPA Acceptance Criteria (Attachment 5), and (6) the Cost Share and
Data Compensation Forms in replying to this Metolachlor Generic Data Callln (Attachment
F).  Instructions and guidance accompany each form.

DATA REQUIRED BY THIS NOTICE

      The additional data requirements needed to complete the generic database for
Metolachlor are contained in the Requirements Status and Registrant's Response, Attachment
C. The Agency has concluded that additional occupational and residential exposure data on
Metolachlor are needed. These data are needed to fully complete the reregistration of all
eligible Metolachlor products.

INQUIRIES AND RESPONSES TO THIS NOTICE

      If you  have any questions regarding the generic data requirements and procedures
established by this Notice, please contact Jane Mitchell at (703) 308-8061.

      All responses to this Notice for the generic data requirements should be submitted to:

             Jane Mitchell, Chemical Review Manager
             Reregistration Branch
             Special Review and Registration Division (H7508W)
             Office of Pesticide Programs
             U.S. Environmental Protection Agency
             Washington, D.C.   20460

             RE:  Metolachlor
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METOLACHLOR DATA CALL-IN CHEMICAL STATUS SHEET

INTRODUCTION

       You have been sent this Product Specific Data Call-In Notice because you have
product(s) containing Metolachlor.

       This Product Specific Data Call-In Chemical Status Sheet  contains an overview of data
required by this notice, and point of contact tor inquiries pertaining to the reregistration of
Metolachlor.  This attachment is to be used in conjunction with (1) the Product Specific Data
Call-In Notice, (2) the Product Specific Data  Call-In Response Form (Attachment 2), (3) the
Requirements Status and Registrant's Form (Attachment 3), (4) EPA's Grouping of End-Use
Products  for Meeting Acute Toxicology Data Requirement (Attachment 4), (5) the  EPA
Acceptance Criteria  (Attachment 5), (o) a list of registrants receiving this DCI (Attachment  6)
and (7) the Cost Share and Data Compensation Forms in replying to this Metolachlor Product
Specific Data Call-In (Attachment 7).  Instructions and guidance accompany each form.

DATA REQUIRED BY THIS NOTICE

       The additional data requirements needed to complete the database for  Metolachlor are
contained in the Requirements Status and Registrant's Response, Attachment  3. The Agency
has concluded that additional data on Metolachlor are needed tor specific products. These data
are required to be submitted to the Agency within the time frame listed.  These data are
needed to fully complete the reregistration of all eligible Metolachlor products.

INQUIRIES AND RESPONSES TO THIS NOTICE

       If you have any questions regarding the generic database of Metolachlor, please contact
Jane Mitchell at (703) 308-8061.

       If you have any questions regarding the product specific data requirements and
procedures established by  this Notice, please contact Veronica Dutch at (703) 308-8585.

       All responses to this Notice for the Product Specific data requirements should be
       submitted to:

             Veronica Dutch
             Chemical Review Manager Team 81
             Product Reregistration Branch
             Special Review and Reregistration Branch 7508W
             Office of Pesticide Programs
             U.S. Environmental Protection Agency
             Washington, D.C. 20460

             RE: Metolachlor
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Attachment 2. Combined Generic and Product Specific
   Data Call-In Response Forms Plus Instructions
                        181

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182

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   Instructions For Completing The "Data Call-in Response Forms" For The Generic And
                             Product Specific Data Call-In


INTRODUCTION

These instructions apply to the Generic and Product Specific "Data Call-In Response Forms"
and are to be used by registrants to respond to generic and product specific Data Call-Ins as
part of EPA's Reregistration Program under the Federal Insecticide, Fungicide, and
Rodenticide Act. The type of data call-in (generic or  product specific) is indicated in item
number 3 ("Date and Type of DCI") on  each form. BOTH "Data Call-In Response" forms
must be completed.

Although the form  is the same for both generic and product specific data, instructions for
completing these forms are different.  Please read these instructions carefully before filling out
the forms.

EPA has developed these forms individually for each registrant,  and has preprinted these
forms with a number of items.  DO NOT use these forms for any other active ingredient.

Items 1 through 4 have been preprinted on the form.  Items 5 through 7 must be completed by
the registrant as appropriate. Items 8 through 11 must be completed by the registrant before
submitting a response to the Agency.

The public reporting burden for this collection of information is  estimated to average 15
minutes per response, including time for reviewing instructions,  searching existing data
sources, gathering and maintaining the data needed, and completing and reviewing the
collection of information. Send comments  regarding the burden estimate or any other aspect of
this collection of information, including suggestions for reducing this burden, to Chief,
Information Policy  Branch, Mail  Code 213o, U.S. Environmental Protection Agency,  401 M
St., S.W., Washington, D.C. 20460; and to the Office of Management and Budget,
Paperwork Reduction Project 2070-0107, Washington, D.C. 20503.
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INSTRUCTIONS FOR COMPLETING THE DATA CALL-IN RESPONSE FORMS
Generic and Product Specific Data Call-in


Item l.ON BOTH FORMS: This item identifies your company name, number and address.

Item 2.ON BOTH FORMS: This item identifies the case number, case name, EPA chemical
number and chemical name.

Item 3.ON BOTH FORMS: This item identifies the type of Data Call-in.  The date of
issuance is date stamped.

Item 4.ON BOTH FORMS: This item identifies the EPA product registrations relevant to
the data call-in.  Please note that you are also responsible for informing the Agency of your
response regarding any product that you believe may be covered by this Data Call-In but that
is not listed by the Agency in Item 4. You must bring any such apparent omission to the
Agency's attention within the period required for submission of this response form.

Item 5.ON BOTH FORMS: Check this item for each product registration you wish to cancel
voluntarily. If a registration number is listed for a product for which you previously requested
voluntary cancellation, indicate in Item 5 the date of that request. Since this Data Call-in
requires both generic and product specific data, you must complete item 5 on both Data Call-
in response forms.  You  do not need to complete any item on the Requirements Status and
Registrant's Response Forms.

Item 6a.ON THE GENERIC DATA FORM: Check this Item if the Data Call-in is for
generic data as indicated  in Item 3 and you are eligible for a Generic  Data Exemption for the
chemical listed in Item 2  and used in the subject product.  By electing this exemption, you
agree to the terms and conditions of a Generic Data Exemption as explained in the Data
Call-in Notice.

If you are eligible for or  claim a Generic Data Exemption, enter the EPA registration Number
of each registered source of that active ingredient that you use in your product.

Typically,  if you purchase an EPA-registered product from one or more other producers
(who, with respect to the incorporated product, are in compliance with this and any other
outstanding Data Call-In  Notice), and


INSTRUCTIONS FOR COMPLETING THE DATA CALL-IN RESPONSE FORMS
Generic and Product Specific Data Caii-in


incorporate that product into all your products, you may complete this item for all products
listed on this form. If, however, you produce the active ingredient yourself, or use any
unregistered product (regardless of the fact that some of your sources are registered), you may
not claim a Generic Data Exemption and you may not select this item.

Item 6b.ON THE GENERIC DATA FORM: Check this Item if the Data Call-in is for
generic data as indicated  in Item 3 and if you are agreeing to satisfy the generic data
requirements of this  Data Call-In. Attach the Requirements Status and Registrant's Response
Form that indicates how you will satisfy those requirements.
                                         184

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NOTE: Item 6a and 6b are not applicable for Product Specific Data.

Item 7a.ON THE PRODUCT SPECIFIC DATA FORM:  For each manufacturing use
product (MUP) for which you wish to maintain registration, you must agree to satisfy the data
requirements by responding  "yes."
April 3, 1995
Item Tb.For each end use product (EUP) for which you wish to maintain registration, you
must agree to satisfy the data requirements by responding "yes."

FOR BOTH MUP and EUP products

You should also respond "yes" to this item (7a for MUP's and 7b for EUP's) if your product
is identical to another product and you qualify for a data exemption.   You must provide the
EPA registration numbers of your source (s); do  not complete the Requirements Status and
Registrant's Response form. Examples of such products include repackaged products and
Special Local Needs (Section 24c) products which are identical to federally registered
products.

If you are requesting a data waiver, answer "yes" here; in addition, on the "Requirements
Status and Registrant's Response" form under Item 9, you must respond with option 7 (Waiver
Request) for each study for which you are requesting a waiver.

NOTE: Item 7a and 7b are not applicable for Generic Data.


INSTRUCTIONS FOR COMPLETING THE DATA CALL-IN RESPONSE FORMS
Generic and Product Specific Data Call-in


Item 8.ON BOTH FORMS: This certification statement must be signed by an authorized
representative of your company and the person signing must include  his/her title.  Additional
pages used in your response must be initialled and dated in the space provided for the
certification.

Item 9.ON BOTH FORMS: Enter the date of signature.

Item 10.ON BOTH FORMS:  Enter the name of the person EPA should  contact with
questions regarding your response.

Item 11.ON BOTH FORMS:  Enter the phone number of your  company contact.
   Note:    You may provide additional information that does not fit on this form in a signed letter that accompanies your response. For example, you
          may wish to report that your product has already been transferred to another company or that you have already voluntarily cancelled this
          product. For these cases, please supply all relevant details so that EPA can ensure that its records are correct.
                                          185

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186

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Attachment 3. Generic and Product Specific Requirement
Status and Registrant's Response Forms and Instructions
                          187

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188

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                              Instructions For Completing
                                          The
                  "Requirements Status and Registrant's Response Forms"
                    For The Generic and Product Specific Data Call-in


INTRODUCTION

       These instructions apply to the Generic and Product Specific "Requirements Status and
Registrant's Response Forms" and are to be used by registrants to respond to generic and
product specific Data Call-in's as part of EPA's reregistration program under the Federal
Insecticide, Fungicide, and Rodenticide Act.  The type of Data Call-In (generic or product
specific) is indicated in item number 3 ("Date and Type of DCI") on each form.  Both
"Requirements Status and Registrant's Response" forms must be completed.

       Although the form is the same for both product specific and generic data, instructions
for completing the forms differ slightly.  Specifically,  options for satisfying product specific
data requirements do not include (1) deletion of uses or (2) request for a low  volume/minor
use waiver.  Please read these instructions carefully before filling out the forms.

       EPA has developed these forms individually for each registrant, and has preprinted
these forms to include certain information unique to this chemical. DO NOT  use these forms
for any other active ingredient.

       Items 1 through 8 have been preprinted on the  form.  Item 9 must be completed by the
registrant as appropriate. Items 10 through 13 must be completed by the registrant before
submitting a response to the Agency.

       The public reporting burden for this collection  of information is estimated to average
30 minutes per response, including time for reviewing instructions,  searching existing data
sources, gathering and maintaining the data needed, and completing and reviewing the
collection of information. Send comments regarding the burden estimate or any other aspect of
this collection of information, including suggestions for reducing this burden, to Chief,
Information Policy Branch, Mail Code 213TH U.S. Environmental Protection Agency, 401  M
St., S.W., Washington,  D.C. 20460; and to the Office of Management and Budget,
Paperwork Reduction Project 2070-0107, Washington, D.C. 20503.
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INSTRUCTIONS FOR COMPLETING THE "REQUIREMENTS STATUS AND
REGISTRANT'S RESPONSE FORMS"	
Generic and Product Specific Data Call-in


Item 1.       ON BOTH FORMS:  This item identifies your company name, number and
             address.

Item 2.       ON THE GENERIC DATA FORM:  This item identifies the case number,
             case name, EPA chemical number and chemical name.

             ON THE PRODUCT SPECIFIC DATA FORM:  This item identifies the
             case number, case name, and the EPA Registration Number of the product for
             which the Agency is requesting product specific data.

Item 3.       ON THE GENERIC DATA FORM:  This item identifies the type of Data
             Call-In.  The date of issuance is date stamped.

             ON THE PRODUCT SPECIFIC DATA FORM:  This item identifies the type
             of Data Call-In. The date of issuance is also date stamped.  Note the unique
             identifier number (ID#) assigned by the Agency. This ID number must be used
             in the transmittal document for any data submissions in response to this Data
             Call-In Notice.

Item 4.       ON BOTH FORMS:  This item identifies the guideline reference number of
             studies required. These guidelines, in addition to the requirements specified in
             the Data Call-in Notice, govern the conduct of the required studies. Note that
             series 61 and 62 in product chemistry are now listed under 40 CFR 158.155
             through 158.180, Subpart c.

Item 5.       ON BOTH FORMS:  This item identifies the study title associated with the
             guideline reference number and whether protocols and 1, 2, or 3-year progress
             reports are required to be submitted in connection with the study.  As noted in
             Section III of the Data Call-In Notice, 90-day progress reports are required for
             all studies.

             If an asterisk appears in Item  5, EPA has attached information relevant to this
             guideline reference number to the Requirements Status and Registrant's
             Response Form.
INSTRUCTIONS FOR COMPLETING THE "REQUIREMENTS STATUS AND
REGISTRANT'S RESPONSE HJRMS"
Generic and Product Specific Data Caii-ln

Item 6.       ON BOTH FORMS:  This item identifies the code associated with the use
             pattern of the pesticide. In the case of efficacy data (product specific
             requirement), the required study only pertains to products which have the use
             sites and/or pests indicated.  A brief description of each code follows:

             A     Terrestrial food
             B     Terrestrial feed
             C     Terrestrial non-food
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Item 7.
Item 8.
D      Aquatic food
E      Aquatic non-food outdoor
F      Aquatic non-food industrial
G      Aquatic non-food residential
H      Greenhouse food
I      Greenhouse non-food crop
J      Forestry
K      Residential
L      Indoor food
M     Indoor non-food
N      Indoor medical
0      Indoor residential

ON BOTH FORMS:  This item identifies the code assigned to the substance
that must be used for testing. A brief description of each code  follows:
             EUP
             MP
             MP/TGAI

             PAI
             PAI/M
             PAI/PAIRA

             PAIRA
             PAIRA/M
             PAIRA/PM

             TEP
             TEP	%

             TEP/MET
             TEP/PAI/M

             TGAI
             TGAI/PAI

             TGAI/PAIRA

             TGAI/TEP

             MET
             IMP
             DEGR
                   End-Use Product
                   Manufacturing-Use Product
                   Manufacturing-Use Product and Technical Grade Active
                   Ingredient
                   Pure Active Ingredient
                   Pure Active Ingredient and Metabolites
                   Pure Active Indredient or Pute Active
                   Ingredient Radiolabelled
                   Pure Active Ingredient Radiolabelled
                   Pure Active Ingredient Radiolabelled and Metabolites
                   Pure Active Ingredient Radiolabelled and Plant
                   Metabolites
                   Typical End-Use Product
                   Typical End-Use Product, Percent Active Ingredient
                   Specified
                   Typical End-Use Product and Metabolites
                   Typical End-Use Product or Pure Active Ingredient and
                   Metabolites
                   Technical Grade Active Ingredient
                   Technical Grade Active Ingredient or Pure Active
                   Ingredient
                   Technical Grade Active Ingredient or Pure Active
                   Ingredient    Radiolabelled
                   Technical Grade Active Ingredient or Typical End-Use
                   Product
                   Metabolites
                   Impurities
                   Degradates
                   See: guideline comment
This item completed by the Agency identifies the time frame allowed for
submission of the study or protocol identified in item 5.

ON THE GENERIC DATA FORM:  The time frame runs from the date of
your receipt of the Data Call-In notice.

ON THE PRODUCT SPECIFIC DATA FORM: The due date for
submission of product specific studies begins from the date stamped on the letter
transmitting the Reregistration Eligibility Decision document, and not from the
                                        191

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              date of receipt.  However, your response to the Data Call-in itself is due 90
              days from the date of receipt.

Item 9.        ON BOTH FORMS:  Enter the appropriate Response Code or Codes to show
              how you intend to comply with each data requirement. Brief descriptions of
              each code follow. The Data Call-In Notice contains a fuller description of each
              of these options.

       Option 1.     ON BOTH FORMS:  (Developing Data)  I will conduct a new study  and
                    submit it within the time frames specified  in item 8 above. By indicating
                    that I have chosen this option, I certify that I will comply with all the
                    requirements pertaining to the conditions for submittal of this study as
                    outlined in the Data Call-In Notice and that I will provide the protocols
                    and progress reports required in item 5 above.

       Option 2.     ON BOTH FORMS:  (Agreement to Cost Share) I have entered into an
                    agreement with one or more registrants to develop  data jointly. By
                    indicating that I have chosen this option, I certify that I will comply with
                    all the requirements pertaining to sharing in the cost of developing data
                    as outlined in the Data Call-In Notice.

                           However, for Product Specific Data, I understand that this
                    option is available for acute toxicity or certain efficacy  data ONLY if
                    the Agency indicates in an attachment to this notice that my product is
                    similar enough to another product to qualify for this option. I certify that
                    another party in the agreement is committing to submit or provide the
                    required data; if the required study is not submitted on  time, my product
                    may be  subject to suspension.

       Option 3.     ON BOTH FORMS:  (Offer to Cost Share) I have made an offer to
                    enter into an agreement with one or more  registrants to develop data
                    jointly.  I am also submitting a completed  "Certification of offer to Cost
                    Share in the Development of Data" form.  I am submitting evidence that
                    I have made  an offer to another registrant  (who has an obligation to
                    submit data)  to share in the cost of that data.  I am  including a  copy of
                    my offer and proof of the other registrant's receipt of that offer.  I  am
                    identifying the party which is committing to submit or provide the
                    required data; if the required study is not submitted on  time, my product
                    may be  subject to suspension. I understand that other terms under Option
                    3 in the Data Call-In Notice apply  as well.

                           However, for Product Specific Data, I understand that this
                    option is available only for acute toxicity or certain efficacy data and
                    only if the Agency indicates in an attachment to this Data Call-In Notice
                    that my product is similar enough to another product to qualify for  this
                    option.

       Option 4.     ON BOTH FORMS:  (Submitting Existing Data)  I will submit an
                    existing study by the specified due date that has never before been
                    submitted to  EPA.  By indicating that I have chosen this option, I certify
                    that this study meets all the requirements pertaining to the conditions  for
                    submittal of existing data outlined in the Data CalHn Notice and I have
                    attached the needea supporting information along with this response.
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Options.     ON BOTH FORMS:  (Upgrading a Study) I will submit by the
             specified due date, or will cite data to upgrade a study that EPA has
             classified as partially acceptable and potentially upgradeable.  By
             indicating that I have chosen this option, I certify that I have met all the
             requirements pertaining to the conditions for submitting or citing
             existing data to upgrade a study described in the Data Call-in Notice. I
             am indicating on attached correspondence the Master Record
             Identification Number (MRID) that EPA has assigned to the data that I
             am citing as well as the MRID of the study I am attempting to upgrade.

Option 6.     ON BOTH FORMS:  (Citing a Study)  I am citing an existing study
             that has been previously classified by EPA as acceptable, core, core
             minimum,  or a study that has not yet been reviewed by the Agency. If
             reviewed, I am providing the Agency's  classification of the study.

                    However, for Product Specific Data, I am citing another
             registrant's study.  I understand that this option is available ONLY for
             acute toxicity or certain efficacy data and ONLY if the cited study was
             conducted on my product, an identical product or a product which the
             Agency has "grouped"  with one or more other products for purposes of
             depending  on the same  data. I may also choose this option if I am citing
             my own data. In either  case, I will provide the MRID or Accession
             number (s). If I cite another registrant's data, I will submit a completed
             "Certification With Respect To Data Compensation Requirements"
             form.

FOR THE GENERIC DATA FORM ONLY:  The following three options
(Numbers 7,8, and U) are responses that apply only to the 'Requirements Status
and Registrant's Response Form" for  generic data.

Option 7.     (Deleting Uses)  I am attaching an application for amendment to my
             registration deleting the uses for which the data are required.

Option 8.     (Low Volume/Minor Use Waiver Request) I have read the statements
             concerning low volume-minor use data waivers in the Data Call-In
             Notice and I request a low-volume minor use waiver of the data
             requirement.  I am attaching a detailed justification to support this waiver
             request including, among other things, all information required to
             support the request. I understand that, unless modified by the Agency in
             writing, the data requirement as stated in the Notice governs.

Option 9.     (Request for Waiver of Data) I have read the statements concerning data
             waivers other than lowvolume minor-use data waivers in the Data
             Call-In Notice and I request a waiver of the data requirement. I  am
             attaching a rationale explaining why I believe the data requirements do
             not apply. I am also submitting a copy of my current labels. (You must
             also submit a copy of your Confidential Statement of Formula if not
             already on file with EPA). I understand that, unless modified by the
             Agency in writing, the  data requirement as stated in the Notice governs.
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       FOR PRODUCT SPECIFIC DATA: The following option (number 7) is a
       response that applies to the "Requirements Status and Registrant's Response
       Form" for product specific data.

       Option 7.      (Waiver Request) I request a waiver for this study because it is
                     inappropriate tor my product. I am attaching a complete justification for
                     this request, including technical reasons, data and references to relevant
                     EPA regulations, guidelines or policies. [Note:  any supplemental data
                     must be submitted in the format required by P.R. Notice 86-5]. I
                     understand that this is my only opportunity to state the reasons or
                     provide information in support of my request. If the Agency approves
                     my waiver request,  I will not be required to  supply the data pursuant to
                     Section 3(c) (2) (B)  of FIFRA. If the Agency denies my waiver request,
                     I must choose a method of meeting the data requirements of this Notice
                     by the due date stated by this  Notice. In this case, I must, within 30
                     days-of my receipt of the Agency's written decision, submit a revised
                     "Requirements Status"  form specifying the option chosen. I  also
                     understand that the deadline for submission of data as  specified by the
                     original Data Call-In notice will not change.

Item 10.      ON BOTH FORMS: This item must be  signed by an authorized representative
              of your company. The person signing must include  his/her title,  and must initial
              and date all other pages of this  form.

Item 11.      ON BOTH FORMS: Enter the date of signature.

Item 12.      ON BOTH FORMS: Enter the name of the person EPA should contact with
              questions regarding your response.

Item 13.      ON BOTH FORMS: Enter the phone number of your company contact.
   NOTE:   You may provide additional information that does not fit on this form in a signed letter that accompanies this your response. For example,
          you may wish to report that your product has already been transferred to another company or that you have already voluntarily cancelled
                                           194

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Attachment 4. EPA Batching of End-Use Products for
   Meeting Data Requirements for Reregistration
                       195

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196

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EPA'S BATCHING OF METOLACHLOR PRODUCTS FOR MEETING ACUTE
TOXICITY DATA REQUIREMENTS FOR REREGISTRATION

       In an effort to reduce the time, resources and number of animals needed to fulfill the
acute toxicity data requirements for reregistration of products containing the active ingredient
metolachlor, the Agency has batched products which can be considered similar for purposes of
acute toxicity. Factors considered in the sorting process include each product's active and
inert ingredients (identity, percent composition and biological activity), type of formulation
(e.g., emulsifiable concentrate, aerosol, wettable powder, granular, etc.), and labeling (e.g.,
signal word, use classification, precautionary labeling, etc.). Note that the Agency is not
describing batched products as  substantially similar'  since some products within a batch may
not be considered chemically similar  or have identical use patterns.

       Using available information, batching has been accomplished by the process described
in the preceding paragraph. Notwithstanding the batching process, the Agency reserves the
right to require,  at any time, acute toxicity data for an individual product should the need
arise.

       Registrants of products within a batch may choose to cooperatively generate, submit or
cite a single battery of six acute toxicological studies to represent all the products within that
batch.  It is the registrants' option to  participate in the process with all other registrants, only
some of the other registrants,  or only their own products within a batch,  or to generate all the
required  acute toxicological studies for each  of their own products.  If a registrant chooses to
generate  the data for a batch, he/she must use one of the products within the batch as the test
material. If a registrant chooses to rely upon previously submitted acute toxicity data, he/she
may do so provided that the data base is complete and valid by  today's standards (see
acceptance criteria attached), the formulation tested is considered by EPA to be similar for
acute toxicity, and the formulation has not been significantly altered since submission and
acceptance of the acute toxicity data.  Regardless of whether new data is generated or  existing
data is referenced, registrants must clearly identify the test material by EPA Registration
Number. If more than one confidential statement of formula (CSF) exists for a product, the
registrant must indicate the formulation actually tested by identifying the corresponding CSF.

       In deciding how to meet the product specific data requirements, registrants must follow
the directions given in the Data Call-In Notice and its attachments appended to the RED.  The
DCI Notice contains two response forms which are to be completed and submitted to the
Agency within 90 days of receipt.  The first  form, "Data Call-In Response," asks whether the
registrant will meet the data requirements for each product. The second form, "Requirements
Status and Registrant's Response," lists the product specific data required for each product,
including the  standard six acute toxicity tests. A registrant who wishes to participate in a
batch must decide whether he/she will provide the data or depend on someone else to do so.
If a registrant supplies the data to  support a batch of products, he/she must select one of the
following options: Developing Data (Option 1), Submitting an Existing Study (Option 4),
Upgrading an Existing Study (Option 5j or Citing an Existing Study (Option 6).  If a
registrant depends on another's data,  he/she must choose among:  Cost Sharing  (Option 2),
Offers to Cost Share (Option 3) or Citing an Existing Study (Option 6).  If a registrant does
not want to participate in a batch,  the choices are Options 1,  4, 5 or 6.  However, a registrant
should know that choosing not to  participate  in a batch does not preclude other registrants in
the batch from citing his/her studies and offering to cost share (Option 3) those studies.
                                          197

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The table below shows six batches of registrations.
BATCH NO.
1
2

3

4


5





EPA REG. NO.
&
SLN REG. No.
100-645
100-710
NE 930003
3125-366
ID 900002
62719-239
62719-240
100-627
100-638
100-712
100-597
100-688
100-691
100-711
AZ 830005
FL 900002
% OF METOLACHLOR & OTHER
ACTIVE INGREDIENTS
35.6% - Metolachlor
27.4% - Atrazine
34.8% - Metolachlor
27.4% - Atrazine
35.6% - Metolachlor
27.4% - Atrazine
70.0% - Metolachlor
15.0% - Metribuzin
70.0% - Metolachlor
15.0% - Metribuzin
79.9% - Metolachlor
2.1% - Flumetsulam
79.9% - Metolachlor
2.6% - Flumetsulam
15.0% -Metolachlor
25.0% - Metolachlor
25.0% - Metolachlor
86.4% - Metolachlor
85.1% -Metolachlor
85.1% -Metolachlor
84.4% - Metolachlor
86.4% - Metolachlor
85.1% -Metolachlor
FORMULATION TYPE
Emulsiflable Concentrate
Soluble Concentrate
Emulsiflable Concentrate
Emulsiflable Concentrate
Emulsiflable Concentrate
Emulsiflable Concentrate
Emulsiflable Concentrate
Granular
Granular
Granular
Emulsiflable Concentrate
Emulsiflable Concentrate
Emulsiflable Concentrate
Emulsiflable Concentrate
Emulsiflable Concentrate
Emulsiflable Concentrate
BATCH NO.
5
(cont.)





EPA REG. NO.
&
SLN REG. No.
FL 930001
LA 880005
NC 920005
NM 850004
NM 860004
NY 900001
OK 860003
% OF METOLACHLOR & OTHER
ACTIVE INGREDIENTS
86.4% - Metolachlor
86.4% - Metolachlor
86.4% - Metolachlor
86.4% - Metolachlor
86.4% - Metolachlor
86.4% - Metolachlor
86.4% - Metolachlor
FORMULATION TYPE
Emulsiflable Concentrate
Emulsiflable Concentrate
Emulsiflable Concentrate
Emulsiflable Concentrate
Emulsiflable Concentrate
Emulsiflable Concentrate
Emulsiflable Concentrate
                                    198

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BATCH NO.

6



EPA REG. NO.
&
SLN REG. No.
OR 910007
OR 930022
TX 830011
VA 920004
WI 890002
WI 940001
100-673
NC 920004
VA 920005
WA 910004
% OF METOLACHLOR & OTHER
ACTIVE INGREDIENTS
86.4% - Metolachlor
86.4% - Metolachlor
86.4% - Metolachlor
86.4% - Metolachlor
86.4% - Metolachlor
86.4% - Metolachlor
86.4% - Metolachlor
86.4% - Metolachlor
86.4% - Metolachlor
86.4% - Metolachlor
FORMULATION TYPE
Emulsiflable Concentrate
Emulsiflable Concentrate
Emulsiflable Concentrate
Emulsiflable Concentrate
Emulsiflable Concentrate
Emulsiflable Concentrate
Emulsiflable Concentrate
Emulsiflable Concentrate
Emulsiflable Concentrate
Emulsiflable Concentrate
       The following two tables show registrations which were not batched for various
reasons such as additional active ingredients not found in any other registrations, significant
differences in the inert ingredients, and significant differences in the concentrations of active
and inert ingredients.
EPA REG. NO.
&
SLN REG. No.
100-587
100-590
100-665
% OF METOLACHLOR & OTHER ACTIVE
INGREDIENTS
95.0% - Metolachlor
27.5% -Metolachlor
20.8% - Atrazine
0.5% - Metolachlor
FORMULATION TYPE
Technical
Emulsiflable Concentrate
Granular
EPA REG. NO.
&
SLN REG. No.
100-715
100-716
100-731
100-747
100-748
% OF METOLACHLOR & OTHER ACTIVE
INGREDIENTS
4.0% - Metolachlor
1 . 0% - Simazine
22.0% - Metolachlor
22.0% - Cyanazine
36.6% - Metolachlor
17.4% - Atrazine
55.0% - Metolachlor
30.6% - Metolachlor
23.2% -Atrazine
FORMULATION TYPE
Granular
Emulsiflable Concentrate
Emulsiflable Concentrate
Water Dispersible Granular
Water Dispersible Granular
                                            199

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EPA REG. NO.
&
SLN REG. No.
241-328
10182-134
% OF METOLACHLOR & OTHER ACTIVE
INGREDIENTS
68.5%-Metolachlor
2.74% - Imazethapyr
22.70%-Metolachlor
7.84% - Paraquat Dichloride
FORMULATION TYPE
Soluble Concentrate
Emulsiflable Concentrate
200

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Attachment 5. EPA Acceptance Criteria
                201

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202

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                                                 SUBDIVISION D
Guideline                  Study Title

Series 61          Product Identity and Composition
Series 62          Analysis and Certification of Product Ingredients
Series 63          Physical and Chemical Characteristics
                                                       203

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                                         61 Product Identity and Composition


ACCEPTANCE CRITERIA


Does your study meet the following acceptance criteria?

1.	     Name of technical material tested (include product name and trade name, if appropriate).

2.	     Name, nominal concentration, and certified limits (upper and lower) for each active ingredient and each intentionally-
           added inert ingredient.

3.	     Name and upper certified limit for each impurity or each group of impurities present at > 0.1% by weight and for
           certain lexicologically significant impurities (e.g., dioxins, nitrosamines) present at < 0.1%.

4.	     Purpose of each active ingredient and each intentionally-added inert.

5.	     Chemical  name from Chemical Abstracts index of Nomenclature and Chemical Abstracts Service (CAS) Registry
           Number for each active ingredient and, if available, for each intentionally-added inert.

6.	     Molecular, structural, and empirical formulas, molecular weight  or weight range, and any company assigned
           experimental or internal code numbers for each active ingredient.

7.	     Description of each beginning material in the manufacturing process.
           	  EPA Registration Number if registered;
                  for other beginning materials, the following:
           	  Name and  address of manufacturer or supplier.
           	  Brand name, trade name or commercial designation.
           	  Technical specifications or data sheets by which manufacturer or supplier describes composition, properties or
                  toxicity.

8.	Description of manufacturing process.
           	  Statement of whether  batch or continuous process.
           	  Relative amounts of beginning materials and order in which they are added.
           	  Description of equipment.
           	  Description of physical conditions (temperature, pressure, humidity) controlled in each step and the parameters
                  that are maintained.
           	  Statement of whether process involves intended  chemical reactions.
           	  Flow chart with chemical equations for each intended chemical reaction.
           	  Duration of each step  of process.
           	  Description of purification procedures.
           	  Description of measures taken to assure quality  of final product.

9.	     Discussion of formation of impurities based on established chemical  theory addressing (1) each impurity which may
           be present at _>_ 0.1% or was found at _>_ 0.1% by product analyses and  (2) certain lexicologically significant impurities
           (see #3).
                                                         204

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                                  62 Analysis and Certification of Product Ingredients


                                               ACCEPTANCE CRITERIA

The following criteria apply to the technical grade of the active ingredient being reregistered.  Use a table to present the information
in items 6, T, and 8.

Does your study meet the following acceptance criteria?

 1.	    Five or more representative samples (batches in case of batch process)  analyzed for each active ingredient and all
           impurities present at > 0.1%.
 2.	    Degree of accountability or closure > ca 98%.
 3.	    Analyses conducted for certain trace tdxTcTmpurities at lower than 0.1% (examples, nitrosamines in the case of products
           containing dinitroanilines  or  containing secondary or tertiary amines/alkanolamines plus nitrites;   polyhalogenated
           dibenzodioxins and dibenzofurans).  [Note  that in the case of nitrosamines both fresh and stored samples must be
           analyzed.].
 4.	    Complete and detailed description of each step in analytical method used to analyze above samples.
 5.	    Statement of precision and accuracy of analytical method used to analyze above samples.
 6.	    Identities and quantities (including mean and standard deviation) provided for each analyzed ingredient.
 7.	    Upper and lower certified limits proposed for each active  ingredient and intentionally added inert along with explanation
           of now the limits were determined.
 8.	    Upper certified limit proposed for each impurity present at > 0.1% and for certain lexicologically significant impurities
           at < 0.1% along with explanation of how limit determine!!.
 9.	    Analytical methods to verify certified limits of each active ingredient and impurities (latter not required if exempt from
           requirement of tolerance or if generally recognized as safe by FDA) are fully described.
10.	    Analytical methods (as discussed in #9) to verify certified limits validated  as to their precision and accuracy.
                                                          205

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                                       63 Physical and Chemical Characteristics

                                              ACCEPTANCE CRITERIA


The following criteria apply to the technical grade of the active ingredient being reregistered.

Does your study meet the following acceptance criteria?

63-2 Color
    	    Verbal description of coloration (or lack of it)
    	    Any intentional coloration also reported in terms of Munsell color  system

63-3 Physical State
    	    Verbal description of physical state provided using terms such as "solid, granular, volatile liquid"
    	    Based on visual inspection at about 20-25° C

63-4 Odor
    	    Verbal description of odor (or lack of it) using terms such as "garlic-like, characteristic of aromatic compounds"
    	    Observed at room temperature

63-5 MeltingPoint
    	    Reported in °C
    	    Any observed decomposition reported

63-6 Boiling Point
    	    Reported in °C
    	    Pressure  under which B.P. measured reported
    	    Any observed decomposition reported

63-7 Density, Bulk Density, Specific Gravity
    	    Measured at about 20-25° C
    	    Density of technical grade active ingredient reported in g/ml or the specific gravity of liquids reported with reference
            to water at 20° C. [Note: Bulk density of registered products~~may be reported in lbs/ft3 or Ibs/gallon.]

63-8 Solubility
    	    Determined in distilled water and representative polar and non-polar solvents, including those used in formulations and
            analytical methods for the pesticide
    	    Measured at about 20-25° C
    	    Reported in g/100 ml (other units like ppm acceptable if sparingly  soluble)

63-9 Vapor Pressure
    	    Measured at 25° C (or calculated by extrapolation from measurements made at higher temperature if pressure too low
            to measure  at 25° C)
    	    Experimental procedure described
    	    Reported in mm  Hg (torr) or other conventional units

63-10 Dissociation Constant
    	    Experimental method described
    	    Temperature of measurement specified  (preferably about
            20-2B°C)

63-11 Octanol/water Partition Coefficient
    	    Measured at about 20-25° C
    	    Experimentally determined and description of procedure provided  (preferred method-45 Fed. Register 77350)
    	    Data supporting  reported value provided

63-12 pH
    	    Measured at about 20-25° C
    	    Measured following dilution or dispersion in distilled water

63-13 Stability
    	    Sensitivity to metal ions and metal determined
    	    Stability at normal and elevated temperatures
    	    Sensitivity to sunlight determined
                                                         206

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                                                 SUBDIVISION F
Guideline          Study Title

 81-1             Acute Oral Toxicity in the Rat
 81-2             Acute Dermal Toxicity in the Rat, Rabbit or Guinea Pig
 81-3             Acute Inhalation Toxicity in the Rat
 81-4             Primary Eye Irritation in the Rabbit
 81-5             Primary Dermal Irritation Study
 81-6             Dermal Sensitization in the Guinea Pig
                                                       207

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                                         81-1  Acute Oral Toxicity in the Rat


                                              ACCEPTANCE CRITERIA


Does your study meet the following acceptance criteria?

 1.	Identify material tested (technical, end-use product, etc).
 2.	At least 5 young adult rats/sex/group.
 3.^	Dosing, single oral may be administered over 24 hrs.
 4.*!	Vehicle control if other than water.
 5.	Doses tested,  sufficient to determine a toxicity category or a limit dose (5000 mg/kg).
 6.	Individual observations at least once a day.
 7.	Observation period to last at least 14 days, or until all test animals appear normal whichever is longer.
 8.	Individual daily observations.
 9.	Individual body weights.
10.	Gross necropsy on all animals.
                        Criteria marked with an * are supplemental and may not be required for every study.
                                                         208

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                             81-2  Acute Dermal toxicity in the Rat, Rabbit or Guinea Pig


                                              ACCEPTANCE CRITERIA


Does your study meet the following acceptance criteria?

 1.	Identify material tested  (technical, end-use product, etc).
 2.	At least 5 animals/sex/group.
 3.^	Rats 200-300 gm, rabbits 2.0-3.0 kg or guinea pigs 350-450 gm.
 4.	Dosing, single dermal.
 5.	Dosing duration at least 24 hours.
 6.^	Vehicle control,  only if toxicity of vehicle is unknown.
 7.1	Doses tested, sufficient to determine a toxicity category or a limit dose (2000 mg/kg).
 8.	Application site clipped or shaved at least 24 hours oefore dosing.
 9.	Application site at least 10% of body surface area.
10.	Application site covered with a porous nonirritating cover to retain test material and to prevent
       ingestion.
11.	Individual observations at least once a day.
12.	Observation period to last at least 14 days.
13.	Individual body weights.
14.	Gross necropsy  on all animals.
                        Criteria marked with an * are supplemental and may not be required for every study.

                                                         Lj\J\J

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                                       81-3 Acute Inhalation Toxicity in the Rat


                                              ACCEPTANCE CRITERIA


Does your study meet the following acceptance criteria?

 1.	Identify material tested (technical, end-use product, etc).
 2.	Product is a gas, a solid which may produce a significant vapor hazard based on toxicity and expected use  or contains
         particles of inhalable size for man (aerodynamic diameter 15 pm or less).
 3.	At least 5 young adult rats/sex/group.
 4.	Dosing, at least 4 hours by inhalation.
 5.	Chamber air flow dynamic, at least 10 air changes/hour, at least 19% oxygen content.
 6.	Chamber temperature,  22° C (+_2°), relative humidity 40-60%.
 7.	Monitor rate of air flow.
 8.	Monitor actual concentrations of test material in breathing zone.
 9.	Monitor aerodynamic particle size for aerosols.
10.	   Doses tested, sufficient to determine a toxicity category or a limit dose (5 mg/L actual concentration of respirable
         substance).
11.	   Individual observations at least once a day.
12.	   Observation period to last at least 14 days.
13.	   Individual body weights.
14.	   Gross necropsy on all animals.
                                                         210

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                                       81-4  Primary Eye Irritation in the Rabbit


                                              ACCEPTANCE CRITERIA


Does your study meet the following acceptance criteria?

 1.	Identify material tested (technical, end-use product, etc).
 2.	Study not required if material is corrosive, causes severe
         dermal irritation or has a pH of < 2 or > 11.5.
 3.	6 adult rabbits.
 4.	Dosing, instillation into the conjunctival sac of one eye
         per animal.
 5.	Dose, 0.1 ml if a liquid; 0.1 ml or not more than 100 mg if a solid, paste or particulate substance.
 6.	Solid or granular test material ground to a fine dust.
 7.	Eyes not washed for at least 24nours.
 8.	Eyes examined and graded for irritation before dosing and
         at 1, 24, 48 and 72 hr, then daily until eyes are normal
         or 21  days  (whichever is shorter).
 9.^	Individual daily observations.
                        Criteria marked with an * are supplemental and may not be required for every study.

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                                        81-5  Primary Dermal Irritation Study

                                              ACCEPTANCE CRITERIA


Does your study meet the following acceptance criteria?

 1.	Identify material tested (technical, end-use product, etc).
 2.	Study not required if material is corrosive or has a pH of <7. or  > 11.5.
 3.	6 adult animals.
 4.	Dosing, single dermal.
 5.	Dosing duration 4 hours.
 6.	Application site shaved or clipped at least 24 hours prior to dosing.
 7.	Application site approximately 6 cm2.
 8.	Application site covered with a gauze patch held in place with nonirritating tape.
 9.	Material removed, washed with water, without trauma to application site.
10.	   Application site examined and graded for irritation at 1, 24, 48 and 72 hr, then daily until normal or 14 days (whichever
         is snorter).
11.^	Individual daily observations.
                        Criteria marked with an * are supplemental and may not be required for every study.

                                                         Lj i Lj

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                                     81-6 Dermal Sensitization in the Guinea Pig

                                              ACCEPTANCE CRITERIA
Does your study meet the following acceptance criteria?
1.	Identify material tested (technical, end-use product, etc).
2.	Study not required if material is corrosive or has a
       pHof <2of >11.5.
3.	une oflhe following methods is utilized:
       	Freund's complete adjuvant test
       	Guinea pig maximization test
       	Split adjuvant technique
       	Buehler test
       	Open epicutaneous test
       	Mauer optimization test
       	Footpad technique in guinea pig.
4.	Complete description of test.
5.^	Reference for test.
6C	Test followed essentially as described in reference document.
7.	Positive control included (may provide historical data conducted within the last 6 months).
                        Criteria marked with an * are supplemental and may not be required for every study.

                                                         Lj i O

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214

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Attachment 6. List of All Registrants Sent This Data Call-In Notice
                              215

-------
216

-------
Attachment 7. Cost Share, Data Compensation Forms, Confidential Statement of
                     Formula Form and Instructions
                                 217

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218

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220

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Instructions for Completing the Confidential Statement of Formula

The Confidential Statement of Formula (CSF) Form 8570-4 must be  used. Two legible, signed
copies of the form are required. Following are  basic instructions:

     a.  All the blocks on the form must be filled in and answered completely.

     b.        If any block is not applicable, mark it N/A.

     c.        The CSF must be signed, dated and the telephone number of the responsible party
              must  be provided.

     d.        All applicable information which  is on the product specific data submission must
              also be reported on the CSF.

     e.        All weights reported under item  7 must be in pounds  per  gallon for liquids and
              pounds per cubic feet for solids.

     f.        Flashpoint must be in degrees Fahrenheit and flame extension in inches.

     g.        For all  active  ingredients,  the  EPA Registration  Numbers  for the  currently
              registered source products must be reported under column 12.

     h.        The Chemical Abstracts Service (CAS) Numbers for all actives and inerts and all
              common names for the trade names must be reported.

     i.        For the  active ingredients, the percent purity of the source products must be
              reported under column 10 and must be exactly the same  as on the source  product's
              label.
     j.        All the weights  in columns 13.a. and  13.b.  must be  in pounds, kilograms, or
              grams. In no case will volumes be  accepted. Do not mix  English and metric system
              units  (i.e., pounds and kilograms).

     k.        All the items under column 13.b. must total 100 percent.

     1.        All items under columns  14.a. and 14.b. for the active ingredients must represent
              pure active form.

     m.      The upper and lower certified limits for ail active and inert ingredients must follow
              the 4CI CFR 158.175 instructions. An explanation must be provided if the proposed
              limits are different than standard  certified limits.

     n.        When new CSFs are  submitted  and approved,  all previously submitted CSFs
              become obsolete for that specific  formulation.
                                         221

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222

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    r/EPA
United States  Environmental  Protection  Agency
            Washington,  DC  20460
   CERTIFICATION OF  OFFER  TO  COST
SHARE  IN THE  DEVELOPMENT OF  DATA
Form Approved

OMB No.  2070-0106
         2070-0057
Approval  Expires 3-31-96
 Public reporting burden for this collection of information is estimated to average 15 minutes per response, including
 time for reviewing instructions, searching existing data sources, gathering and maintaining the data needed, and
 completing and reviewing the collection of information. Send comments regarding the burden estimate or any other
 aspect of this collection of information, including suggestions for reducing this burden, to Chief, Information Policy
 Branch, PM-223, U.S. Environmental Protection Agency, 401 M St., S.W., Washington, DC 20460; and to the Office
 of Management and Budget, Paperwork Reduction Project (2070-0106), Washington, DC 20503.

 Please fill In  blanks below.
Company Name
Product Name
Company Number
EPA Reg. No.
 I Certify that:

 My company is willing to develop and submit the data required by EPA under the authority of the Federal
 Insecticide, Fungicide and Rodenticide Act (FIFRA), if necessary. However, my company would prefer to
 enter into an agreement with one or more registrants to develop jointly or share in the cost of developing
 data.

 My firm has offered in writing to enter into such an agreement.  That offer was irrevocable and included an
 offer  to be bound  by arbitration decision under  section 3(c)(2)(B)(iii) of FIFRA if final agreement on  all
 terms could not be reached otherwise.  This offer was made to the following firm(s) on the  following
 date(s):
  Name of Flrm(s)
                                                                            Date of Offer
Certification:
I certify that I am duly authorized to represent the company named above, and that the statements that I  have made on
this form and all attachments therein are true, accurate, and complete. I acknowledge that any knowingly false or
misleading statement may be punishable by fine or imprisonment or both under applicable law.
Signature of Company's Authorized Representative
Date
Name and Title (Please Type or Print)
 EPA Form 8570-32 (5/91)    Replaces EPA Form 8580, which is obsolete-
                                                 223

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224

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United States Environmental Protection Agency -ceo ST**
Washington, DC 20460 ^ _g*J
f S3EZ *
CERTIFICATION WITH RESPECT TO % HiaJIUPi .|-
DATA COMPENSATION REQUIREMENTS **»< mot«>°
Form Approved
OMB No. 2070-01 07,
2070-0057
Approval Expires
3-31-96
Public reporting burden for this collection of information is estimated to average 15 minutes per response, including time for
reviewing instructions, searching existing data sources, gathering and maintaining the data needed, and completing and reviewing th
collection of information. Send comments regarding the burden estimate or any other aspect of this collection of information,
including suggestions for reducing this burden to Cnief Information Policy Branch, PM-233, U.S. Environmental Protection
Agency, 40TM St., S.W., Washington, DC 20460; and to the Office of Management and Budget, Paperwork Reduction Project
(2070-0106), Washington, DC 20503.
Please fill in blanks below.
Company Name
Product Name
Company Number
EPA Reg. No.
I Certify that:
1 . For each study cited in support of registration or reregistratiion under the Federal Insecticide Fungicide and Rodenticide Act
(FIFRA) that is an exclusive use study, I am the original data submitter, or I have obtained the written permission of the original
data submitter to cite that study.
2. That for each study cited in support of registration or reregistration under FIFRA that is NOT an exclusive use study, I am the
original data submitter, or I have obtained the written permission of the original data submitter, or I have notified in writing the
companv(ies) that submitted data I have cited and have offered to: (a) Pay compensation for those data in accordance with section
3(c)(1 )(F) and 3(c](2)(D) of FIFRA; and (b) Commence negotiation to determine which data are subject to the compensation
requirement of FlFRA and the amount of compensation due, if any. The companies I have notified are. (check one)
f ] The companies who have submitted the studies listed on the back of this form or attached sheets, or indicated on the attached
"Requirements Status and Registrants' Response Form,"
3. That I have previously complied with section 3(c)(1)(F) of FIFRA for the studies I have cited in support of registration or
reregistration under FIFRA.
Signature
Date
Name and Title (Please Type or Print)
GENERAL OFFER TO PAY: I hereby offer and agree to pay compensation to other persons, with regard to the registration
or reregistration of my products, to the extent required by FIFRA section 3(c)(1)(F) and 3(c)(2)(D).
Signature
Date
Name and Title (Please Type or Print)
EPA Form 8570-31 (4-96)
                                                              225

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APPENDIX G. FACT SHEET
          227

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228

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                  United States              Prevention, Pesticides        EPA-738-F-95-007
                  Environmental Protection      And Toxic Substances        April 1995
                  Agency	(7508W)	

                  R.E.D.   FACTS
                  Metolachlor
      PGStJCJdG       All pesticides sold or distributed in the United States must be
RGTGClistration  registered by EPA, based on scientific studies showing that they can be used
                  without posing unreasonable risks to people or the environment.  Because of
                  advances in scientific knowledge, the law requires that pesticides which
                  were first registered years ago be reregistered to ensure that they meet
                  today's more stringent standards.
                       In evaluating pesticides for reregistration, EPA obtains and reviews a
                  complete set of studies from pesticide producers, describing the human
                  health and environmental effects of each pesticide.  The Agency imposes
                  any regulatory controls that are needed to effectively manage each
                  pesticide's risks.  EPA then reregisters pesticides that can be used without
                  posing unreasonable risks to human health or the environment.
                       When a pesticide is eligible for reregistration, EPA announces this and
                  explains why in a Reregistration Eligibility Decision (RED) document. This
                  fact sheet summarizes the information in the RED document for
                  reregistration case 0001, metolachlor.

    USG ProfilG       Metolachlor is a broad spectrum herbicide used for general weed
                  control in many agricultural food and feed crops  (primarily corn, soybeans
                  and sorghum), and on lawns and turf, ornamental plants, trees, shrubs and
                  vines, rights of way, fencerows and hedgerows, and in forestry. The
                  emulsifiable concentrate formulation is most commonly used, but granular
                  formulations also are available. Ground application is the use method of
                  choice for all sites, although aerial, irrigation, and chemigation application
                  methods also are permitted.
                       Use practice limitations prohibit applying metolachlor in greenhouses
                  or other enclosed structures, on muck or peat soils, on sweet potatoes or
                  yams, to trees or vines transplanted less than 30 days (and only after
                  depressions around the trees and vines have been filled in), on sand or
                  loamy sand soils,  to trees or vines that will bear harvestable fruit within 12
                  months, to Taloka Silt Loam, on English peas in Northeastern U.S.,  and on
                  sorghum grown under dry-mulch tillage.  They also prohibit grazing
                  livestock in treated areas, feeding or grazing cover crops grown in treated
                  orchards,  and grazing or  feeding peanut forage or fodder to livestock for 30
                  days following application.

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    Regulatory
         History
Human Health
  Assessment
     Metolachlor was first registered in the U.S. in 1976 for general weed
control on turf. This pesticide was the subject of EPA's first Registration
Standard, in March 1980.  The Agency issued a second Registration
Standard for metolachlor in January 1987, and Data Call-In notices in
December 1993 and May 1994.

Toxicity
     Metolachlor displayed a low level of toxicity in acute tests. It is
slightly toxic by the oral, dermal, and inhalation routes, and has been placed
in Toxicity Category III  (the second-lowest of four categories) for these
effects.  It is non-irritating to the eyes and skin (Toxicity Category IV), but
is positive for skin sensitization in guinea pigs.
     While  a three-month subchronic feeding study in beagle dogs
produced no effects, a six-month study resulted in reduced body weight
gains and food consumption in the high dose dogs.  A dermal toxicity study
using New Zealand white rabbits resulted in increased bilirubin, increased
liver weights in males, and  increased kidney weights in females. In a
chronic feeding study using beagle dogs, metolachlor caused decreased body
weight gain.
     Metolachlor has been evaluated for carcinogenic activity in both rats
and mice.  No treatment-related cancer effects were observed in two studies
using mice.  In studies using rats, metolachlor caused a significant increase
in liver nodules and carcinomas in high dose females.  In  1991,  the
Agency's HED Peer Review Committee recommended that metolachlor be
classified as a Group C possible human carcinogen, based on increases in
liver tumors in the female rat.  However, a Peer Review conducted in July
1994 recommended a margin of exposure (MOE) approach to assessing
chronic risk since there was no supportable mutagenicity concern, and in
light of new information on the relative metabolism of metolachlor
indicating that formation of the derivative presumed to  be  the ultimate
carcinogen actually is very low.
     Metolachlor shows some evidence of causing developmental toxicity
effects in rats but none in rabbits.  It was not mutagenic in several tests.
Dietary Exposure
     People may be exposed to residues of metolachlor through the diet.
Tolerances or maximum residue limits have been established for residues
in/on a variety of food and feed commodities including corn, cotton,
peanuts, pod crops, potatoes, safflower, sorghum, soybeans, stone fruits,
tree nuts, nonbearing citrus and grapes, and cabbage; straw, forage and
grain of barley, buckwheat, oats, rice, rye,  and wheat; several types of
peppers; and eggs, milk, and the fat, meat and meat byproducts of poultry,
cattle, goats, hogs, horses, and sheep (please see 40 CFR  180.368(a),(b)
and (c)).

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      Sufficient data are available to determine the adequacy of most
established tolerances.  (Certain studies generated by Craven Laboratories
are being replaced.)  However, some tolerances need to be revoked, some
need to be replaced,  and some separate ones need to be established to bring
them  up to date with current commodity definitions.
      New food/feed additive tolerances are needed  for processed potatoes
(dry peel, wet peel, granules, and waste from processing) and soybean
hulls, and,  based on  some replacement studies, will  likely be needed for
peanuts.  Under the Delaney clause of the Federal Food, Drug, and
Cosmetic Act (FFDCA), however,  food and feed additive tolerances may
not be established for pesticides that induce cancer in man or animals.
Although its cancer-causing potential in humans is weak, EPA still considers
metolachlor to be a chemical that "induces cancer" within the meaning  of
the Delaney clause.  Therefore, under current policy EPA would not issue
these  food and feed additive tolerances, and would not continue in effect
tolerances for the associated raw agricultural commodities potatoes,
soybeans, and peanuts.
      EPA currently  is evaluating its policies regarding pesticide tolerances,
registrations, and the Delaney clause in light of ongoing legal challenges.
Because of these issues, the Agency is unable to make a reregistration
eligibility decision at this time regarding the potato,  soybean, and peanut
uses of metolachlor.
      EPA has assessed the dietary risk posed by metolachlor. The
Anticipated Residue  Concentration (ARC) for the overall U.S. population
represents less than 0.2% of the Reference Dose (RfD),  or amount believed
not to cause adverse  effects if consumed daily over a 70-year lifetime.   The
most highly exposed subgroup, non-nursing infants less than one year old,
has an ARC which represents less than 0.6% of the  RfD. This low fraction
of the allowable RfD is considered to be an acceptable dietary exposure risk.
Occupational and Residential Exposure
      Based on current use patterns, handlers (mixers, loaders and
applicators) may be exposed to metolachlor during normal use of both
granular and liquid formulations.  The potential for  post-application
exposure also exists for people entering treated sites. For many uses of
metolachlor, however, this potential is diminished since the herbicide is
incorporated into the soil following application.  For post-emergent
applications, especially applications to turf, there is  more of a risk of post-
application exposure.
      Because  metolachlor  is a possible human carcinogen and systemic
toxicity may result from intermediate exposure (one week to several
months), EPA assessed exposure and risk to workers using several major
exposure scenarios.  Margins of Exposure (MOEs) for subchronic systemic
effects are unacceptable (less than  100) for mixers/loaders during aerial
applications of liquid metolachlor.  In addition,  MOEs for

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                      mixers/loaders/applicators during ground applications of liquid metolachlor
                      are acceptable only when certain personal protective equipment (PPE)
                      (gloves and coveralls) is worn by those handlers.
                           To mitigate these risks to metolachlor handlers, EPA is requiring use
                      of a closed mixing and loading system by mixers/loaders supporting aerial
                      applications of liquid formulations.  In addition, mixers/loader/applicators
                      must wear appropriate PPE--chemical-resistant gloves and coveralls over
                      short-sleeved shirts and short pants—during/supporting ground applications
                      of liquid metolachlor formulations.
                           Post-application exposures  do not appear to pose an unreasonable risk
                      to people entering treated areas, as long as they do not reenter immediately
                      after application.  Therefore, for all  uses within the scope of the Worker
                      Protection Standard (WPS), EPA is requiring a 24-hour restricted entry
                      interval (REI), strengthening the interim 12-hour REI in place  until now, as
                      well as PPE for workers who enter treated areas before the REI has
                      expired.
                           For uses outside the scope of the WPS,  EPA is requiring, for liquid
                      applications, a prohibition on entry until sprays have dried, and for granular
                      applications, a prohibition on entry until dusts have settled or the treated
                      area is dry following watering-in.
                      Human  Risk Assessment
                           Metolachlor is of low acute toxicity but can cause dermal sensitization.
                      It is classified as a  "Group C," possible human carcinogen based on
                      increases in liver tumors in the female rat.  Metolachlor also shows some
                      evidence of causing developmental toxicity in rats.
                           Although people may be exposed to residues of metolachlor through
                      the diet, dietary risks appear to be minimal.  Systemic toxicity  risks to
                      certain handlers (mixers/loaders/applicators) are of concern from
                      intermediate exposure to metolachlor, but will be mitigated by requiring use
                      of closed mixing and loading systems for aerial applications of  liquid
                      formulations,  and use of certain minimum, baseline PPE (gloves  and
                      coveralls) for all handlers during ground use of liquid formulations. To
                      reduce post-application exposure and risk, a more stringent 24-hour REI is
                      being imposed, as is early entry PPE.

Environmental   Environmental Fate
   AsSGSSITIGnt        Parent metolachlor appears to be moderately persistent to persistent.
                      It ranges from mobile to highly mobile in different soils, and has been
                      detected in ground water.  Metolachlor is stable to hydrolysis under normal
                      environmental conditions.  Degradation is dependent on microbially
                      mediated and abiotic processes.   Five major degradates have been identified.
                           Metolachlor has the potential to range from a moderately mobile to a
                      highly mobile material in different types of soil.  It is persistent in surface
                      soil with a half-life in the 6-12 inch soil layer ranging from 7 to 292 days.

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Detections were made as far as the 36-48 inch soil layer in some tests.
Metolachlor has a low potential to bioaccumulate in fish.
      Residues of metolachlor have been detected in ground water in 20
states. Detections in three states have been found to contain residues that
exceed the lifetime Health Advisory of 100 ppb for metolachlor. In five
other states, concentrations in well water exceed 10% of the Health
Advisory Level (HAL).  Because of these detections,  EPA is concerned
about the degradation of water quality that occurs in metolachlor use areas.
      Metolachlor is among the top five pesticides found in surface water in
the mid-western corn belt. It is detected in a high percentage of surface
water samples collected from numerous locations within the corn belt for
several months post-application.  Comparable levels are found in streams,
rivers, and reservoirs.
      It appears unlikely that metolachlor concentrations will exceed the 1-
10 day or lifetime  Health Advisory levels.  Although metolachlor is not yet
formally regulated by the Safe Drinking Water Act, water supply systems
are required to sample and analyze for it. EPA will review these data when
they become available.
Ecological Effects
      Metolachlor is practically nontoxic to birds on both an acute and a
subacute dietary basis.  New  avian reproduction studies are required to
determine its chronic toxicity to birds. Metolachlor is moderately toxic to
freshwater fish on an acute basis. It is slightly toxic to aquatic  invertebrates
on an acute basis.  A reproduction study is required to confirm that chronic
risks to aquatic invertebrates  are similar to risks to fish.  Metolachlor is
slightly toxic to estuarine fish in acute exposures. Since metolachlor is a
herbicide, potential risk to nontarget plants is likely.
Ecological Effects Risk Assessment
      Metolachlor is registered for many outdoor uses.  Acute as well as
chronic exposures to nontarget organisms can result from direct
applications, spray drift, and  runoff from treated areas.
      The level of concern (LOG) for endangered birds is exceeded  at an
application rate of 6 Ibs active ingredient (ai) per acre.  In addition, the
LOG is exceeded for waterfowl at 6 Ibs. ai/acre in short grass.
      In addition,  the endangered species LOG is exceeded for small
mammals  eating short grass at an application rate of 2 Ibs/acre. The
endangered species and restricted use LOCs are  exceeded for small
mammals  eating short grass at an application rate of 4 Ibs./acre and higher.
      Although no acute effects to aquatic organisms are expected as a result
of exposure to metolachlor in deeper water, freshwater fish (the most
sensitive aquatic species) trigger the endangered species LOG in a shallow
water body one foot deep or less. Risk to non-target plants also is expected.
      In summary, endangered species levels of concern are exceeded in
some circumstances for birds, small mammals, and endangered fish.

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   Risk Mitigation
  Additional Data
          Required
Limitations may be imposed on the use of metolachlor in the future to
protect threatened and endangered species when EPA implements the
Endangered Species Protection Program.

     EPA is requiring the following risk mitigation measures for
metolachlor, as discussed earlier:
°  An environmental hazard statement is required on product labeling to
protect endangered plants.
°  Metolachlor will be considered a candidate for classification as a
restricted use pesticide for groundwater concerns when the Restricted Use
Rule for Ground Water goes into  effect.
°  Since metolachlor has been detected in ground water  as a result of normal
agricultural use, EPA will consider metolachlor as a candidate for state
management plans when the State Management Plan rule is promulgated.
0  The ground water advisory on existing product labels must be modified
to reflect current advisory language.
°  A surface water advisory also  is required since metolachlor can
contaminate surface water through ground spray drift and run-off.
°  Interim spray drift advisory language must be placed  on product labels.
°  Metolachlor products applied as liquids that have uses within the scope of
the WPS warrant the establishment of minimum PPE requirements for
handlers.  In addition, mixers and loaders must use closed mixing systems to
support aerial applications (see discussion above).
°  EPA also is requiring a strengthened 24-hour REI for uses that are within
the scope of the WPS.
°  Early entry PPE for dermal protection also is required for emulsifiable
concentrate formulations.
°  Certain entry restrictions also  are required for uses outside the scope of
the WPS and for homeowner use products.
°  To protect ground water, EPA  is requiring two small-scale prospective
ground water studies on  metolachlor,  as well as a report on the results of a
19-state monitoring program.
Label statements also are required to reduce mixing and loading risks.

     EPA is requiring the following generic  studies for  metolachlor to
confirm its regulatory assessments and conclusions: a Foliar Residue
Dissipation study and a Dermal Passive Dosimetry Exposure study for use
on residential turf. The  Agency also  is requiring product-specific data
including product chemistry and acute toxicity studies, revised Confidential
Statements of Formula (CSFs), and revised labeling for  reregistration.
Product Labeling
     All metolachlor end-use products must comply with EPA's current

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            ChangGS   pesticide product labeling requirements, and with the following (for detailed
RGCjUJrGd               labeling instructions, please see the metolachlor RED):
                          Personal Protective Equipment (PPE) Requirements for Pesticide
                          Handlers
                               Sole-active-ingredient products must be revised to adopt the PPE
                          requirements set forth in this section. Any conflicting PPE requirements on
                          current labeling must be removed.  Multiple-active-ingredient products must
                          compare these handler PPE requirements to those on current labeling and
                          retain the more protective.
                               Handler PPE for Occupational-Use Products (products NOT
                               intended primarily for home use):
                          Minimum (Baseline) Personal Protective Equipment Requirements: Some
                          uses of metolachlor are within the scope of the Worker Protection Standard
                          (WPS)  and some are outside its scope.  The minimum (baseline) PPE
                          requirements pertain to both the WPS and nonWPS uses by occupational
                          handlers, since potential exposure is similar.
                               Granular Formulations: The Agency is establishing no minimum
                          (baseline) PPE for WPS and nonWPS uses of metolachlor products
                          formulated as granules.
                               EC Formulations: The minimum (baseline) PPE for all WPS and
                          nonWPS occupational uses of metolachlor products formulated as liquids is:
                               "Applicators and other handlers must wear:
                               —Coveralls over short-sleeved shirt and short pants
                               —Chemical-resistant gloves (see instructions * below)
                               —Chemical-resistant footwear plus socks
                               —Chemical-resistant headgear for  overhead exposure
                               —Chemical-resistant apron when cleaning equipment, mixing, or
                               loading"  (see instructions ** below)
                               * The glove statement for metolachlor is the statement established
                          through instructions in Supplement Three of PR Notice 93-7.
                               ** The words "mixing,  or loading"  may be removed if the product is
                          formulated as "ready-to-use."
                          Actual End-Use Product Personal Protective Equipment Requirements: The
                          PPE that would otherwise be established based on the acute toxicity of each
                          end-use product must be compared to the minimum (baseline) PPE specified
                          above, and the more protective must be  placed on product labeling.
                          Placement in Labeling: The PPE must  be placed on end-use product
                          labeling in the location specified in PR Notice 93-7, and the format and
                          language of the PPE requirements must be the same as specified there.
                               Products Intended Primarily for Homeowner Use:

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EPA is not establishing minimum (baseline) handler PPE for metolachlor
end-use products intended primarily for homeowner use.  Any necessary
PPE will be established based on the acute toxicity of the end-use product.
Placement in Labeling:  PPE requirements, if any, must be placed on end-
use product labeling immediately following the precautionary statements in
"Hazards to Humans (and domestic animals)."

Entry Restrictions
      Sole-active-ingredient products must be revised to adopt the entry
restrictions set forth in this section. Any conflicting entry restrictions on
current labeling must be removed.  Multiple-active-ingredient products must
compare the entry restrictions set forth in this section to those on current
labeling and retain the more  protective.  A specific time-period in hours or
days is considered more protective than "sprays have dried" or "dusts have
settled."
      Occupational-Use Products (products NOT intended primarily for
      home use):
           -Uses Within the Scope of the WPS:
Restricted-Entry Interval:  A 24-hour restricted entry interval (REI) is
required for uses within the scope of the WPS on all end-use products.
Early-Entry Personal Protective Equipment (PPE):
      EC Formulations:   The PPE required for early entry  following
applications of the emulsifiable concentrate is:
           —coveralls over short-sleeve shirt and short pants,
           —chemical-/resistant  gloves,
           —chemical-resistant footwear plus socks,
           —chemical-resistant headgear for overhead  exposures.
      Granular Formulations:   The PPE required for  early entry following
applications of granular formulation is:
           —coveralls,
           —chemical-resistant gloves,
           —shoes plus socks.
Placement in Labeling: The REI must be inserted into  the standardized  REI
statement and the PPE required for early entry must be inserted into the
standardized early entry PPE statement required by Supplement Three of PR
Notice 93-7.
           -Uses Not Within the Scope of the WPS:
For liquid applications:
      "Do not enter or allow others to enter the treated area until
      sprays have  dried."
For granular applications:

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      "Do not enter or allow others to enter the treated area until dusts
      have settled. If soil incorporation is required following the
      application, do not enter or allow others to enter the treated area
      (except those persons involved in the incorporation) until the
      incorporation is complete. If the incorporation is accomplished
      by watering-in,  do not enter  or allow others to enter the treated
      area until the surface is dry following the watering-in."
Placement in Labeling:
      If WPS uses also are on label: Follow instructions in PR Notice 93-7
for establishing Non-Agricultural Use Requirements box and place
appropriate nonWPS entry restriction in that box.
      If no WPS uses are  on label:  Add appropriate nonWPS entry
restriction to labels of all  end-use products, except products primarily
intended for homeowner use, in a section in the Directions For Use with the
heading: "Entry Restrictions:"
      Products Primarily Intended for Home Use:
For liquid applications:
      "Do not enter or allow others to enter the treated area until
      sprays have dried."
For granular applications:
      "Do not enter or allow others to enter the treated area until dusts
      have settled. If soil incorporation is required following the
      application, do not enter or allow others to enter the treated area
      (except those persons involved in the incorporation) until the
      incorporation is complete. If the incorporation is accomplished
      by watering-in,  do not enter  or allow others to enter the treated
      area until the surface is dry following the watering-in."
Placement in Labeling: Add entry restriction to labels of products primarily
intended for homeowner use in section in Directions For Use with the
heading: "Entry Restrictions:"

Other Labeling Requirements
      The Agency is requiring the following labeling statements on all
metolachlor end-use products intended primarily  for occupational use:
Application  Restrictions:
      "Do not apply this product in a way that will  contact workers or other
      persons, either directly or through drift.  Only protected handlers may
      be in the area during application."
Engineering Controls:
      "Mixers and loaders supporting aerial applications are required to use
      closed systems.  The closed system must be  used in a manner that
      meets  the requirements listed in the Worker Protection Standard
      (WPS) for agricultural pesticides (40 CFR  170.240(d) (4). When

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     using the closed system, the mixers' and loaders' PPE requirements
     may be reduced or modified as specified in the WPS."
     "When handlers use closed systems, enclosed cabs, or aircraft in a
     manner that meets the requirements listed in the Worker Protection
     Standard (WPS) for agricultural pesticides (40 CFR 170.240(d) (4-6),
     the handler PPE requirements may be reduced or modified as
     specified in the WPS."
User Safety Requirements:
     "Follow manufacturer's instructions for cleaning/maintaining PPE.  If
     no such instructions for washables, use detergent and hot water.  Keep
     and wash PPE separately from other laundry."
User Safety Recommendations:
     "Users should wash hands before eating, drinking,  chewing gum,
     using tobacco, or using the toilet."
     "Users should remove clothing immediately if pesticide gets inside.
     Then wash thoroughly and put on clean clothing."
     "Users should remove PPE immediately after handling this product.
     Wash the outside of gloves before removing. As soon as possible,
     wash thoroughly and change into clean clothing."
Skin Sensitizer Statement:
     Because metolachlor is classified as a skin sensitizer, EPA is requiring
     the following statement in the  "Hazards to Humans (and Domestic
     Animals)"  section of the Precautionary Statements on the labeling of
     all end-use products:
     "This product may cause skin  sensitization reactions in some people."
Soil Incorporation Statement:
     Registrants may add the following statement to their labeling in the
Agricultural Use Requirements box immediately following the restricted
entry interval:
     "Exception: if the product is soil-incorporated, the Worker Protection
     Standard, under certain circumstances, allows workers to enter the
     treated area if there will be no contact with anything that has been
     treated."
Environmental Hazard Statement
     "Do not apply directly to water, or to areas where surface water is
     present or to  intertidal areas below the mean high-water mark.  Do not
     contaminate water when disposing of equipment wash water or
     rinsate."
Rotational Crops Restriction
     "Do not rotate to food or feed crops other than those listed on this
     label."
Ground Water Labeling/Mitigation;  Mixing/Loading
                        10

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     The following language regarding mixing/loading setbacks must
appear in Precautionary Statements in the Environmental Hazards section of
the label:
     "This product may not be mixed or loaded within 50 ft. of perennial
     or  intermittent streams and rivers, natural or impounded lakes and
     reservoirs. This product may not be mixed/loaded or used within 50
     ft.  of all wells, including abandoned wells, drainage wells, and sink
     holes.  Operations that involve mixing, loading, rinsing, or washing of
     this product into or from pesticide handling or application equipment
     or  containers within 50 ft. of any well are prohibited unless  conducted
     on  an impervious pad constructed to withstand the weight of the
     heaviest load that may be positioned on or moved across the pad.
     Such a pad shall be designed and maintained to contain any product
     spills or equipment leaks, container or equipment rinse or wash-water,
     and rain water that may fall on the pad.   Surface water shall not be
     allowed to either flow over or from the pad, which means the  pad
     must be  self-contained.  The pad shall be sloped to facilitate material
     removal.  An unroofed pad shall be of sufficient capacity to  contain at
     a minimum 110% of the capacity of the largest pesticide container or
     application equipment on the pad. A pad that is covered by  a roof of
     sufficient size to completely exclude precipitation from contact with
     the pad shall have  a minimum containment capacity of 100% of the
     capacity of the largest pesticide container or application equipment on
     the pad.  Containment capacities as described above shall be
     maintained at all times. The above-specified minimum containment
     capacities do not apply to vehicles when  delivering pesticide shipments
     to the mixing/loading site."
Ground Water Advisory
     The following ground water advisory language must be placed on all
metolachlor labels:
     "This chemical is known to leach through soil into ground water under
     certain conditions as a result  of agricultural use.  Use of this chemical
     in areas where soils are permeable, particularly where the water table
     is shallow, may result in ground-water contamination."
Surface Water Advisory
     The following surface water advisory language must be placed on all
metolachlor labels:
     "Metolachlor can contaminate surface water through ground spray
     drift.  Under some  conditions, metolachlor may also have a high
     potential for runoff into surface water (primarily via dissolution in
     runoff water), for several months post-application.  These include
     poorly draining or wet soils with readily visible slopes toward adjacent

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      surface waters, frequently flooded areas, areas over-laying extremely
      shallow ground water, areas with in-field canals or ditches that drain
      to surface water,  areas not separated from adjacent surface waters
      with vegetated filter strips, and areas over-laying tile drainage systems
      that drain to surface water."
Endangered Plants Labeling
      The following is  required in the general information section of label:
      "Do not apply under conditions which favor runoff or wind erosion of
      soil containing this product to non-target areas."
      To prevent off-site movement due to run-off or wind erosion:
      "Avoid treating powdery dry or light sand soils when conditions are
      favorable for wind erosion. Under these conditions,  the soil surface
      should first be settled by rainfall or irrigation."
      "Do not apply to impervious substrates such as paved or highly
      compacted surfaces."
      "Do not use tailwater from the first flood or furrow irrigation of
      treated fields to treat non-target crops unless at least  1/2 inch of
      rainfall has occurred between application and the first irrigation."
Spray Drift  Labeling
      The following language must be placed on the label of each product
that can be applied aerially:
      "Avoiding spray drift at the application site is the responsibility of the
      applicator.  The interaction of many equipment-and-weather-related
      factors determine the potential for spray drift.  The applicator and the
      grower are responsible for considering  all these factors when making
      decisions.
      "The following drift management requirements must be followed to
      avoid off-target drift movement from  aerial applications to agricultural
      field crops.  These requirements do not apply to forestry applications,
      public health uses or to applications using dry formulations.
      1.    The distance of the  outer most nozzles on the boom must not
      exceed 3/4 the length of the wingspan or rotor.
      2.    Nozzles must  always point backward parallel with the air stream
      and never be pointed downwards more  than 45 degrees.
      Where states have more stringent regulations, they should be
      observed.
      "The applicator should be familiar with and take into account the
      information covered in the Aerial Drift Reduction Advisory
      Information."
      Aerial drift reduction advisory information must be contained in
product labeling.  See the metolachlor RED document for this additional
required labeling.
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 Regulatory
Conclusion
   For More
Information
     The use of currently registered products containing metolachlor, in
accordance with labeling amended to reflect the risk mitigation measures
imposed by this RED,  generally will not pose unreasonable risks or adverse
effects to humans or the environment.  Therefore, all uses of these products,
except on potatoes,  soybeans, and peanuts, are eligible for reregistration.
     EPA is unable to make a reregistration eligibility decision regarding
the potato, soybean, and peanut uses because,  under current policy, the food
and feed additive tolerances needed  to support these uses appear to be barred
by the Delaney clause in the FFDCA.
     Metolachlor products with eligible uses will be reregistered once the
required product-specific data, revised Confidential Statements of Formula,
and revised labeling are received and accepted by EPA.

     EPA is requesting public comments on the Reregistration Eligibility
Decision (RED) document for metolachlor during a 60-day time period, as
announced in a Notice of Availability published in the Federal  Register. To
obtain a copy of the RED document or to submit written comments, please
contact the Pesticide Docket, Public Response and Program Resources
Branch, Field Operations Division (7506C), Office of Pesticide Programs
(OPP), US EPA, Washington, DC 20460, telephone            703-305-
5805.
                      Electronic copies of the RED and this fact sheet can be downloaded
                 from the Pesticide Special Review and Reregistration Information System at
                 703-308-7224. They also are available on the Internet on EPA's gopher
                 server, GOPHER.EPA. GOV, or using ftp on FTP.EPA.GOV,  or using
                 WWW (World Wide Web) on WWW.EPA.GOV.
                      Printed copies of the RED and fact sheet can be obtained from EPA's
                 National Center for Environmental Publications and Information
                 (EPA/NCEPI), PO Box 42419,  Cincinnati, OH 45242-0419, telephone
                 513-489-8190, fax 513-489-8695.
                      Following the comment period, the metolachlor RED document also
                 will be available from the National Technical Information Service (NTIS),
                 5285 Port Royal Road, Springfield, VA 22161, telephone 703-487-4650.
                      For more information  about EPA's pesticide reregistration program,
                 the metolachlor RED, or reregistration of individual products containing
                 metolachlor, please contact the Special Review and Reregistration Division
                 (7508W), OPP, US EPA,  Washington,  DC 20460, telephone
                 703-308-8000.
                      For information about the health  effects of pesticides, or for assistance
                 in recognizing and managing pesticide poisoning symptoms, please contact
                 the National Pesticides Telecommunications Network (NPTN). Call toll-

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free 1-800-858-7378, between 8:00 am and 8:00 pm Eastern Standard
Time, Monday through Friday.
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