United States        Prevention, Pesticides    EPA 738-R-98-005
         Environmental Protection    And Toxic Substances    November 1998
         Agency	(7508C)	
&EPA  Reregistration
         Eligibility Decision (RED)

         DCPA

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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 DCPA which includes
the active ingredient Dimethyl tetrachloroterephthalate. The enclosed Reregistration Eligibility
Decision (RED), which was approved on September 30, 1995 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 is due 90 days from the date of receipt
of this letter. The second set of required responses is due 8 months from the date of receipt
of this letter. Complete and timely responses will avoid the Agency taking the enforcement
action of suspension against your products.

       Please note that this RED was finalized and signed prior to August 3, 1996. On that date,
the Food Quality Protection Act of 1996 ("FQPA") became effective, amending portions of both
the pesticide law (FIFRA) and the food and drug law (FFDCA). This RED does not address any
issues raised by FQPA, and any tolerance-related statements in the RED  did not take into account
any changes in tolerance assessment procedures required under FQPA. To the extent that this
RED indicates that a change in any tolerance is necessary, that determination will be reassessed by
the Agency under  the standards set forth in FQPA before a proposed tolerance is issued. To the
extent that the RED does not indicate that a change in a tolerance is necessary, that tolerance too
will be reassessed  in the future pursuant to the requirements of FQPA.

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       If you have questions on the product specific data requirements or wish to meet with
the Agency, please contact the Special Review and Reregi strati on Division representative
Venus Eagle at (703) 308-8045. Address any questions on required generic data to the Special
Review and Reregistration Division representative Jill Bloom at (703)308-8019.
                                                        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
reregi strati on, 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 the date of this letter
(RED issuance date); otherwise, your product may be suspended.

2  TIME EXTENSIONS AND DATA WAIVER REOUESTS-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 reregi strati on determination within 14 months after the RED has been
issued.

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REREGISTRATION ELIGIBILITY DECISION

                   DCPA

                   LIST A

                 CASE 0270
           ENVIRONMENTAL PROTECTION AGENCY
             OFFICE OF PESTICIDE PROGRAMS
         SPECIAL REVIEW AND REREGISTRATION DIVISION

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                           TABLE OF CONTENTS



DCPA 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                                         5
      D.    Data Requirements                                                 6
      E.    Regulatory History                                                 7

III.   SCIENCE ASSESSMENT                                                 8
      A.    Physical Chemistry Assessment	8
            1.    Description of Chemical	8
            2.    Identification of Active Ingredient	8
            3.    Manufacturing-Use Products	9
      B.    Human Health Assessment 	9
            1.    Toxicology Assessment	9
                  a.    Acute Toxicity	9
                  b.    Subchronic Toxicity  	9
                  c.    Chronic Toxicity and Carcinogenicity	10
                  d.    Developmental Toxicity	11
                  e.    Reproductive Toxicity	11
                  f.     Mutagenicity	12
                  g.    Metabolism                                           12
                  h.    Dermal Absorption  	13
                  i.     DCPA Reference Dose (RfD) and Cancer Potency Factor .  . 14
                  j.     Hexachlorobenzene (HCB) as a DCPA Impurity	15
                  k.    Polyhalogenated dibenzo-p-dioxins/dibenzofurans as  DCPA
                        Impurities  	15
                  1.     Tetrachloroterephthalic Acid (TPA) as a DCPA Metabolite   16
            2.    Exposure Assessment 	17
                  a.    Dietary Exposure                                      17
                  b.    Drinking Water Exposure	26
                  c.    Occupational and Residential Exposure                   29
            3.    Risk Assessment 	39
                  a.    Dietary Assessment                                     39
                        (1)    Acute Dietary Risk                               39

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                          (2)    Chronic Dietary Risk                              40
                          (3)    Carcinogenic Dietary Risk  	42
                   b.     Drinking Water Assessment                              43
                          (1)    Chronic Drinking Water Risk                      43
                          (2)    Carcinogenic Drinking Water Risk	45
                   c.     Occupational and Residential Assessment                  46
                          (1)    Short Term and Intermediate Term Risk	46
                          (2)    Carcinogenic Risk	46
      C.     Environmental Assessment  	53
             1.     Ecological Toxicity Data                                        53
                   a.     Toxicity to Terrestrial Animals                            53
                          (1)    Birds, Acute and Subacute                         53
                          (2)    Birds, Chronic                                    53
                          (3)    Mammals                                        54
                          (4)    Insects	54
                   b.     Toxicity to Aquatic Animals                              54
                          (1)    Freshwater Fish                                  54
                          (2)    Freshwater Invertebrates                          55
                          (3)    Estuarine and Marine Animals	56
                   c.     Toxicity to Plants                                        56
                          (1)    Terrestrial                                       56
                          (2)    Aquatic	57
             2.     Environmental Fate                                            57
                   a.     Environmental Fate Assessment                           57
                   b.     Environmental Fate and  Transport                       58
                          (1)    Degradation                                      58
                          (2)    Mobility	59
                          (3)    Accumulation                                     60
                          (4)    Terrestrial Field Dissipation                       60
                          (5)    Spray Drift                                       61
                          (6)    Water Resources                                  61
             3.     Ecological Exposure and Risk Characterization                   65
                   a.     Nontarget Terrestrial Animals                            67
                          (1)    Birds	67
                          (2)    Mammals	68
                          (3)    Insects	70
                   b.     Nontarget Aquatic Animals                              71
                          (1)    Freshwater Fish and Invertebrates                  71
                          (2)    Estuarine Species                                 72
                   c.     Nontarget Plants                                        72
                          (1)    Terrestrial and  Semi-aquatic                       72
                          (2)    Aquatic	72

IV.   RISK MANAGEMENT AND REREGISTRATION DECISION                 74
      A.     Determination of Eligibility	74

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      B.    Determination of Eligibility Decision                                   74
            1.     Eligibility Decision                                            74
            2.     Eligible and Ineligible Uses                                     75
      C.    Regulatory Position 	75
            1.     Tolerance Discussion  	75
                   a.     HCB and dioxin/furans                                  75
                   b.     DCPA Tolerance Reassessment                           75
            2.     Tolerance Revocations and Import Tolerances                    78
            3.     Regulation of DCPA Impurities                                 79
            4.     Dietary Risk                                                 79
            5.     Drinking Water Risk                                          80
            6.     Contamination of Water Resources and Mitigation Measures       81
            7.     Occupational Risk                                            81
            8.     Residential Risk                                              82
            9.     Ecological Effects (Non-Endangered Species)                     83
            10.    Endangered Species                                           83
            11.    Spray Drift                                                  84
            12.    Labeling Rationale                                            84

V.    ACTIONS REQUIRED OF REGISTRANTS                                 90
      A.    Manufacturing-Use Products	90
            1.     Additional Generic Data Requirements	90
            2.     Labeling Requirements for Manufacturing-Use Products  	90
      B.    End-Use Products                                                   91
            1.     Additional Product-Specific Data Requirements 	91
            2.     Labeling Requirements for End-Use Products 	91
            3.     Groundwater Advisory	97
                   a.     Surface Water Advisory	97
                   b.     Spray Drift Labeling                                    97
      C.    Tolerance Revocation and Import Tolerances  	100
      D.    Existing Stocks	100

VI.   APPENDICES                                                           103
      APPENDIX  A.     Table of Use Patterns Subject to Reregistration            105
      APPENDIX  B.     Table of the Generic Data  Requirements and Studies Used to
                         Make the Reregistration Decision  	107
      APPENDIX C.     Citations Considered to be Part of the Data Base Supporting the
                         Reregistration of DCPA                                121
      APPENDIX  D.     Combined Generic and Product Specific Data Call-In      141
            Attachment  1.     Chemical Status Sheets                           161
            Attachment  2.     Combined Generic and  Product  Specific Data Call-In
                               Response Forms (Form A inserts) Plus Instructions  163
            Attachment  3.     Generic and Product Specific Requirement Status and
                               Registrant's  Response Forms  (Form  B inserts)  and
                               Instructions  	167

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      Attachment  4.     EPA Batching of End-Use Products for Meeting Data
                         Requirements for Reregistration	174
      Attachment  5.     List of All Registrants Sent This Data Call-in (insert)
                         Notice	181
      Attachment  6.     Cost Share, Data Citation Forms, Confidential Statement
                         of Formula Form and Instructions	182
APPENDIX  E.     List of Available Related Documents                     191

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DCPA REREGISTRATION ELIGIBILITY DECISION TEAM
Office of Pesticide Programs:

Biological and Economic Analysis Assessment
Ghulam All
Dennis Szuhay

Environmental Fate and Effects Assessment

Akiva Abramovitch
Michael Davy
Janice Jensen
Sharlene Matten
Daniel Rieder
Stephanie Syslo

Health Effects Assessment

Kathryn Boyle
Jeff Evans
Peg Perreault
William Smith
Brian Steinwand
Linda Taylor
Jennifer Wintersteen

Registration Support Risk Assessment

Tom Ellwanger
Joanne Miller
Eugene Wilson

Risk Management

Judith Coombs
Margery Exton
Eric Feris
Sherell Sterling
Walt Waldrop
Economic Analysis Branch
Biological Analysis Branch
Environmental Fate and Groundwater Branch
Environmental Risk Characterization Branch
Policy and Special Projects Staff
Science Analysis and Coordination Staff
Environmental Risk Characterization Branch
Environmental Risk Characterization Branch
Risk Characterization and Analysis Branch
Occupational and Residential Exposure Branch
Occupational and Residential Exposure Branch
Reregi strati on Support Chemistry Branch
Science Analysis Branch
Toxicology Branch II
Science Analysis Branch
Registration Support Branch
Fungicide-Herbicide Branch
Fungicide-Herbicide Branch
Reregi strati on Branch
Reregi strati on Branch
Reregi strati on Branch
Reregi strati on Branch
Reregi strati on Branch

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            GLOSSARY OF TERMS AND ABBREVIATIONS

ADI           Acceptable Daily Intake. A now defunct term for reference dose (RfD).
AE            Acid Equivalent
a.i.            Active Ingredient
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 (D WEL) 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
FAO/WHO     Food and Agriculture Organization/World Health Organization
FDA           Food and Drug Administration
FIFRA         Federal Insecticide, Fungicide, and Rodenticide Act
FFDCA        Federal Food, Drug, and Cosmetic Act
FQPA          Food Quality Protection Act
FOB           Functional Observation Battery
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/1, 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.
ug/g           Micrograms Per Gram
Mg/L           Micrograms per liter
mg/L           Milligrams Per Liter
MOE           Margin of Exposure
MP            Manufacturing-Use Product
MPI           Maximum Permissible Intake
                                                ill

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            GLOSSARY OF TERMS AND ABBREVIATIONS

MRID          Master Record Identification (number). EPA's system of recording and tracking studies submitted.
N/A           Not Applicable
NOEC          No Observable Effect Concentration
NPDES         National Pollutant Discharge Elimination System
NOEL          No Observed Effect Level
NOAEL        No Observed Adverse Effect Level
OP            Organophosphate
OPP           Office of Pesticide Programs
Pa             pascal, the pressure exerted by a force of one newton acting on an area of one square meter.
PADI          Provisional Acceptable Daily Intake
PAG           Pesticide Assessment Guideline
PAM          Pesticide Analytical Method
PHED          Pesticide Handler's Exposure Data
PHI            Preharvest Interval
ppb            Parts Per Billion
PPE           Personal Protective Equipment
ppm           Parts Per Million
PRN           Pesticide Registration Notice
Q*!            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
RUP           Restricted Use Pesticide
SLN           Special Local Need  (Registrations Under Section 24 © 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
TLC           Thin Layer Chromatography
TMRC         Theoretical Maximum Residue Contribution
torr            A unit of pressure needed to support a column of mercury 1 mm high under standard conditions.
WP            Wettable Powder
WPS           Worker Protection Standard
                                                IV

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EXECUTIVE SUMMARY

       This Reregi strati on Eligibility Document (RED) addresses the eligibility for reregi strati on
of pesticide products containing the active ingredient DCPA (dimethyl tetrachloroterephthalate)
which is commonly known by the trade name "Dacthal."

BACKGROUND

       DCPA, an herbicide, was originally registered under FIFRA in 1958 for use on turf
grasses for the selective preemergence control of crabgrass and other assorted weeds. Today,
there are 72 FIFRA Section 3  registrations and 11 FIFRA Section 24(c) registrations - totaling 83
product registrations. DCPA is used for selective preemergence weed control on ornamental turf
and plants, strawberries, seeded and transplanted vegetables, cotton, and field beans.

       A Registration Standard was issued for DCPA in June of 1988.  At that time, the Agency
required additional data in the areas of product chemistry,  residue chemistry, environmental fate,
toxicology, and ecological effects to continue the registration of pesticide products containing
DCPA as an active ingredient. The DCPA technical grade active ingredient was subject to a 1987
Data Call-In requiring analysis for possible dioxin/furan contamination. A DCI was also issued on
September 28, 1992 requiring DCPA occupational exposure monitoring data. This RED
document represents a complete review of the data which  has been submitted in response to the
Registration Standard and both the 1987 dioxin/furan and 1992 DCPA DCIs.

REREGISTRATION ELIGIBILITY

       The Agency is unable to make an eligibility decision for the use of DCPA on turf at this
time.  The Agency has identified several risks of regulatory concern, and will be undertaking a full
benefits assessment before determining whether this use is eligible for reregistration.  The risks of
concern include carcinogenic risk to children playing on lawns post-treatment, carcinogenic risk
through contaminated drinking water, chronic risks to wild mammalian species, including
endangered species, and acute risks to freshwater and estuarine mollusks, including endangered
species. The Agency will refine the risk estimates associated with the turf use, since a final report
regarding groundwater contamination associated with the use of DCPA on turf is expected during
the summer of 1996.

       The Agency has determined that all remaining currently registered uses of DCPA, with the
labeling changes required in Section V of this document, do not pose an unreasonable risk to
humans or the environment and are eligible for reregistration.

HEALTH EFFECTS

       The Agency's Carcinogen!city Peer Review Committee within the Office of Pesticide
Programs has classified DCPA as a Group C (possible human) carcinogen. The estimated Qt* (a

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measure of carcinogenic potential) of DCPA is 0.00149 (mg/kg/day)"1. Dietary risk from
exposure to DCPA and its two metabolites, tetrachloroterephthalic acid (TPA) and monomethyl
tetrachloroterephthalic acid (MTP) was assessed using anticipated residues and percent crop
treated data for multiple crops.

       In the absence of a complete database on the metabolites, the Agency is assuming that the
carcinogenic potential of the metabolites is the same as the parent compound.  Therefore, the Qt*
for DCPA is also used for its metabolites.

       The resulting upper bound carcinogenic risk estimate for dietary exposure was
3.5 x 10"7.  The Agency generally considers dietary risks of 1 x 10"6 and less to be negligible, and
thus does not pursue risk reduction measures for such risks. Based on this risk assessment, the
Agency concludes that DCPA does not pose a significant cancer risk to the overall U.S.
population from dietary exposure as currently registered.

       The manufacturing process of DCPA produces several known contaminants.  Of those of
toxicological  concern are hexachlorobenzene (HCB) and congeners (structurally  related
chemicals) of polyhalogenated dibenzo-p-dioxins/dibenzofurans (dioxins/furans).  Carcinogenic
risk was assessed for dietary exposure to HCB and dioxin/furans using Q^s of 1.02 (mg/kg/day)"1
and 1 x 10s, respectively. Resulting dietary risk estimates are 7.1 x 10"7 for HCB and 7 x 10"8 for
dioxin/furans. The Agency concludes that neither HCB nor dioxin/furans pose a  significant
cancer risk to the overall U.S. population through dietary exposure resulting from DCPA product
use.

       A chronic dietary risk assessment was performed to examine the most sensitive non-cancer
endpoint  observed for DCPA, which includes effects in the lungs, liver, thyroid, and thyroid
hormones in rats of both sexes as well as the eyes  of females rats. A Reference Dose (RfD) of
0.01 mg/kg/day was calculated using a 1.0 mg/kg/day No Observed Effect Level  (NOEL) from a
chronic rat study and an uncertainty factor of 100  to account for inter-species extrapolation and
intra-species variability.  When anticipated residues were used as well as percent  of crop treated
data, risk estimates did not exceed a level of concern for the general population or any population
subgroup.

       Chronic dietary  (non-cancer) risk was also assessed for exposure to 2,3,7,8-TCDD and
HCB resulting from DCPA product use. An RfD  of 0.000001 ug/kg/day was calculated for
2,3,7,8-TCDD based on a LOEL of 0.001 ug/kg/day from a three generation feeding study in rats.
An RfD of 0.0008 mg/kg/day was calculated for HCB based on a NOEL of 0.08  mg/kg/day from
a 130-week feeding study in rats. Neither of the resulting risk estimates exceeded a level of
concern for the general population or any subgroup.

       Because one of DCPA's metabolites, TPA, is a frequently detected pesticide residue in
groundwater,  both chronic and carcinogenic risk estimates were calculated to assess exposure to
DCPA and its metabolites through drinking water.  The data from five geographic regions were
                                            VI

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used to generate exposure scenarios. The greatest contamination was found at a turf site in New
York, where the annual average contamination of DCPA and its metabolites was approximately
50 ppb.  Exposure to this contamination level resulted in the highest risk estimates for both cancer
and non-cancer risk.

       The individual excess lifetime cancer risk estimate associated with the turf site is 1.7 x 10"
6. The Agency is undertaking a risk-benefit assessment to determine whether the turf use is
eligible for reregistration.  The groundwater contamination and cancer risk estimates associated
with this use will be evaluated in context of the benefits of DCPA use on turf.
Once the benefits assessment has been completed, the Agency will make a final decision regarding
the eligibility for reregistration of DCPA use on turf. The Agency will announce the eligibility
decision through a Federal Register Notice, as an amendment to this document.
       The second highest carcinogenic risk estimate is based on data from Suffolk County, New
York. The risk estimate from that site is 9.7 x 10"7. DCPA's registrant has voluntarily withdrawn
from selling the product in Suffolk, New York. Exposure values from all other sites resulted in
risks below the Agency's cancer benchmark of 1 x 10"6.

       Chronic drinking water risk is expressed as a percent of the RfD. The chronic drinking
water risk estimate was 11 percent of the RfD at this site. Based on these estimates, the Agency
concludes that DCPA and its metabolites do not currently pose a significant cancer or chronic
non-cancer risk from non-turf uses to the overall U.S. population from exposure through
contaminated drinking water.

OCCUPATIONAL AND RESIDENTIAL EXPOSURE

       DCPA is currently registered for commercial and residential use. Risk assessments were
performed to assess the individual excess lifetime cancer risk from DCPA and HCB  resulting from
occupational and residential  exposure to DCPA. The Agency will not generally allow non-dietary
risks to exceed 10"4, except in cases where EPA has determined that benefits exceed the risks.

       Risk was estimated for occupational exposures to both DCPA and HCB.  The highest risk
for both commercial applicators and private applicators is associated with the use of the wettable
powder formulation. For the commercial applicator, the highest risk for DCPA was estimated to
be 7.5 x 10'5 and for HCB (in DCPA) to be 1.9 x 10'4.  The Agency is requiring
mixer/loader/applicators using DCPA wettable powders to wear a dust-mist respirator fitted with
a TC-21 filter to mitigate this risk. Wearing a dust-mist respirator reduces the risks to 4.0  x 10"5
and 1.3 x 10'4 for DCPA and HCB respectively.

       For the private applicator, the highest risk for DCPA was estimated to be 1.6 X 10"6 and
for HCB (in DCPA) to be 4.6 X 10'6.

       Risks to children playing on a treated lawn were assessed for exposure to DCPA and
HCB. The risks from DCPA and HCB to children playing on an irrigated lawn are 5.6 x
                                           vn

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10"7 and 3.9 x 10"7, respectively.  The risks from DCPA and HCB to children playing on non-
irrigated lawns are 2.0 x 10"6 and 2.7 x 10"6, respectively. The Agency is conducting a risk/benefit
assessment to determine whether the turf use is eligible for reregi strati on.  However, in the
interim, the Agency is requiring that residential lawns be watered after DCPA product use and
that reentry not occur until sprays have dried, in an effort to mitigate risks to children.

       Risk from exposure to DCPA and HCB through worker reentry into a cucumber field was
assessed. Harvesting cucumbers immediately after application resulted in risk estimates of 1.8 x
10"4 for DCPA and 3.2 x 10"4 for HCB.  Delayed reentry periods only minimally reduced risk
estimates. However, the Agency believes that the worker exposures are overestimates.  These
scenarios were based  solely on a foliar dissipation study, not on dermal exposure studies. DCPA's
registrant is a member of a task force which will address dermal exposure for hand labor tasks
required by various crops, such as cucumber harvesting. The risk assessment will be refined when
the task force submits it dermal exposure data.

ENVIRONMENTAL FATE AND ECOLOGICAL EFFECTS

       Ecological effects risk assessments indicate that there may be a concern for endangered
mammals and mollusks exposed to DCPA.  Since the Agency is developing an Endangered
Species Protection Program designed to minimize harm to endangered species from pesticide use,
the Agency is not requiring specific mitigation measures in this document.

       The Agency concludes that non-turf uses of DCPA, labeled and used as specified in this
document, will not pose unreasonable risks to birds, insects, fish and estuarine species, or
nontarget plants.  However, the Agency is requiring additional data in the areas of avian toxicity
and reproduction, vegetative vigor, and seedling emergence to confirm these conclusions. The
Agency has concerns  regarding chronic risks to mammalian species and acute risk to mollusk
species as a result of DCPA use on turf.  Once the benefits assessment on turf has been
completed, the Agency will determine whether this use is eligible for reregi strati on.

       The Agency has concerns about contamination of groundwater by DCPA soil metabolites.
The registrant has voluntarily agreed to limit the manufacture of DCPA technical grade active
ingredient for use within the United States to current production levels.  This will help to ensure
that groundwater contamination rates do not significantly increase in the future. Since DCPA is
produced intermittently, the production limit will be set at the average of the last three production
campaigns, allowing for a 5% variance.  The Agency will enforce this production cap through
review of manufacture data which the registrant is required to submit under FIFRA,  Section 7.
The registrant will produce no more than the agreed upon limit every 3 calendar years, beginning
in January, 1997.

       A final report regarding leaching of DCPA and its metabolites to groundwater is due to
the Agency during the summer of 1996.  Once that data has been reviewed, the Agency will
reassess potential drinking water risk and evaluate the need for additional groundwater protection
                                           Vlll

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measures.

       The Agency is continuing to require all DCPA products to bear a groundwater  advisory
statement. Through the reregi strati on process, the Agency has also identified concerns for the
contamination of surface water by DCPA.  Consequently, the Agency is requiring all DCPA
products to bear a surface water advisory statement as well.

TOLERANCE REASSESSMENT

       Sufficient data were available to ascertain the adequacy of the established tolerances listed
in 40 CFR §180.185(a) and §180.185(b) for those crops for which the use of DCPA is being
supported. New tolerances will be needed for parsley, cowpea (forage and hay), and cotton gin,
byproducts under §180.185 and §180.185(b). The registrant is being required to submit residue
data on parsley, cowpea (forage  and hay), and cotton gin, byproducts. However, in lieu of
tolerances on cowpea commodities, the registrant may restrict the use of DCPA on beans to those
varieties that are used for human consumption only.

       Tolerances for animal commodities have not been established.  The available ruminant
metabolism and poultry feeding studies indicated that tolerances may be needed. The need  for
tolerances for animal commodities will be determined following review of the required data on
poultry metabolism and ruminant feeding studies.

       During the Agency's reregi strati on process, the registrant decided not to support the use
of DCPA on lettuce, soybeans, corn, and rutabagas.  The use of DCPA on these four crops has
been voluntarily cancelled. Normally, once a pesticide use is no longer registered in the U.S., the
related pesticide residue tolerance is no longer needed. It is the Agency's policy to propose
revocation of a tolerance following the deletion of a related food use from a registration, or
following the cancellation of a related food-use registration.  The Agency has the responsibility
under FFDCA to revoke a tolerance on the grounds that the Agency cannot conclude that the
tolerance is protective of public health.

       However, in the case of DCPA, the Agency is not seeking revocation of these tolerances,
as it normally would under the above policy.  The registrant is supporting rotational crop
tolerances for these four commodities, thereby allowing DCPA residues which result from use on
registered crops previously grown in the same field. The reassessed tolerances will be determined
once field rotational crop residue data has been submitted to the Agency and reviewed.
Subsequently, the tolerances of DCPA on these four commodities may be significantly reduced.

       The Agency recognizes, however, that interested parties may want to retain a tolerance
which is higher than the rotational crop tolerance (yet to be determined) in the absence of a U.S.
registration,  to allow legal importation of treated food into the U.S.  To assure that all food
marketed in  the U.S. is safe, under FFDCA, the Agency requires the same product chemistry and
toxicology data for such import tolerances (tolerances without related U.S. registrations) as are
                                           IX

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required to support U.S. food use registrations and any resulting tolerances.  In addition, the
Agency requires residue chemistry data (crop field trials) that are representative of growing
conditions in exporting countries in the same manner that the Agency requires representative
residue chemistry data from different U.S. regions to support domestic use of the pesticide and
the tolerance.

       Parties interested in supporting an existing DCPA tolerance as an import tolerance should
ensure that all of the data noted above are available to the Agency, so that the Agency may
determine whether maintenance of the tolerance would be protective of the public health.

PRODUCT REREGISTRATION

       Before reregistering the products containing DCPA, the Agency is requiring that product
specific data, revised Confidential Statements of Formula (CSF) and revised labeling be submitted
within eight months of the issuance of this document. These data include product chemistry for
each registration and acute toxicity testing. 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 reregi strati on
only when the other active ingredients are determined to be eligible for reregi strati on.

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I.      INTRODUCTION

       In 1988, the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) was amended to
accelerate the reregi strati on of products with active ingredients registered prior to November 1,
1984. The amended Act provides a schedule for the reregi strati on process to be completed in nine
years. There are five phases to the reregi strati on process. The first four phases of the process
focus on identification of data requirements to support the reregi strati on 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 reregi strati on.

       FIFRA  Section 4(g)(2)(A) states that in Phase 5 "the Administrator shall determine
whether pesticides containing such active ingredients are eligible for reregi strati on" before calling
in data on products and either reregistering products  or taking "other appropriate regulatory
action." Thus, reregi strati on 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 reregi strati on eligibility of the
registered uses  of DCPA. The document consists of six sections. Section I is the introduction.
Section II describes DCPA, 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 reregi strati on decision for DCPA. Section V discusses the
reregistration requirements for DCPA.  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
       Decision:

       !      Common Name:           DCPA, or chlorthal dimethyl

       !      Chemical Name:           Dimethyl tetrachloroterephthalate

       !      Chemical Abstracts
             Index Name:               1,4-Benzenedicarboxylic acid, 2,3,5,6-tetrachloro-
                                        ,dimethyl ester

       !      Chemical Family:          Chlorinated Benzoic Acids

       !      CAS Registry Number:     1861-32-1

       !      OPP Chemical Code:       078701

       !      Empirical Formula:        C10H6C14O4

       !      Trade and Other Names:   Dacthal®

       !      Basic Manufacturer:       ISK Biosciences
                                        5966 Heisley Road, #8000
                                        Mentor, Ohio USA
                                        44061-8000

       B.    Use Profile

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

       Type of Pesticide:    A pre-emergent herbicide used to control annual grasses and
                           broadleaf weeds.

       Use Sites:    Terrestrial Food Crops:  beans, beans (succulent, snap), beets, broccoli,
                    Brussels sprouts, cabbage, cauliflower, cole crops, collards, cress (garden)
                    cucumber, eggplant, garlic, kale, melons (cantaloupe, honeydew, and
                    water), mustards, onion, peas (southern), pepper, radish, squash (all or
                    unspecified), strawberry, sweet potato, tomato, turnip, and yam.

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              Terrestrial Food and Feed Crops:  beans, beans (dried-type), bean (mung),
              beans (succulent, lima) beans (succulent, snap), beets, eggplant, mustard,
              peas (southern), pepper, potato (white/irish), tomato, turnip, and yam.

              Terrestrial Feed Crops: alfalfa

              Terrestrial Non-Food and Outdoor Residential Sites: ornamental and/or
              shade trees, ornamental herbaceous plants, ornamental lawns and turf,
              ornamental nonflowering plants, ornamental woody shrubs and vines.
Weeds Controlled:
Broadleaves:  black nightshade, burning nettle, carpetweed,
cheeseweed, common chickweed, common lambsquarters, dodder,
field pansy, Florida pusley, groundcherry, nodding spurge, prostrate
knotweed, prostrate spurge, purple deadnettle, purslane, redroot
pigweed, whombic copperleaf, spotted deadnettle, spotted spurge,
and Virginia copperleaf.

Grasses:  annual bluegrass, barnyardgrass, browntop panicum,
goosegrass, green foxtail, Johnsongrass (free seed), large crabgrass,
lovegrass, sandbur, smooth crabgrass, witchgrass, and yellow
foxtail.
Weeds Suppressed: Broadleaves: annual sowthistle, curley dock (from seed), henbit,
                    ladysthumb, London rocket, nettleleaf goosefoot, polypogon,
                    shepherdspurse, silversheath knotweed, wild buckwheat, and
                    witch weed.

                    Grasses: giant foxtail, littleseed canarygrass, rabbitfoot fall
                    panicum, Texas panicum, and vaseygrass.
Formulation Types Registered:
              All currently registered DCPA products are single
              active ingredient (AI) Formulations:
              20.7% AI emulsifiable concentrate
              54.9% AI flowable concentrate
              1.15% to 10% AI granular
              6% AI soluble concentrate/liquid
              25% and 75% AI wettable powder
              20.7%, 75%, and 90% AI formulation intermediates
Method and Rates of Application:

       Emulsifiable Concentrate Formulations:  Apply to agricultural crops at planting,
       transplant, post-emergence, or post-transplant as soil treatment using sprayer or

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       sprinkler can at .125 gal product/1000 square feet; or apply to strawberries in early
       fall or early spring as soil treatment using sprayer or sprinkler can at. 1016 gal
       product/1000 square feet; apply to ornamental plants in early spring, late spring,
       late fall, late winter, post-emergence, or post-transplant as soil treatment using
       sprayer or sprinkler can at .125 gal product/1000 square feet;  or apply to
       ornamental lawns and turf in early fall or late summer as soil treatment using
       sprayer or sprinkler can at .1693 gal product/1000 square feet.

       Flowable Concentrate Formulations:  Apply to ornamental plants in early spring,
       early fall, or late summer via irrigation at up to 12 Ib AI/A; or apply (e.g. to
       ornamental lawns and turf) in early spring, early summer, or early fall as soil
       treatment using sprayer at up to 15 Ib AI/A.

       Granular Formulations: Apply to agricultural crops at planting or post-plant as
       broadcast or soil treatment using spreader or sprinkler can at up to 10 Ib AI/A; or
       apply at planting, post-emergence, foliar, at layby, or at transplant using  spreader
       or shaker can at .2 Ib AI/1000 square feet; or apply at planting, at transplant, post-
       plant, post-transplant, or seed bed using spreader or shaker can at up to 10.5 Ib
       AI/A; or apply at planting as broadcast using spreader, sprayer, or shaker can at 10
       Ib AI/A; apply at planting, transplant, or post-transplant as soil treatment using
       spreader at 11 Ib AI/A; or apply as foliar broadcast at .2  Ib AI/A; or apply to
       ornamental plants at planting, early spring, late summer, fall, early fall, or
       nurserystock as broadcast using spreader or shaker can at .2 to .347 Ib AI/1000
       square feet; or apply as broadcast at up to  10 Ib AI/A; or apply to ornamental
       lawns and turf in late summer, early fall, or late fall as soil treatment using spreader
       or shaker can at up to 15 Ib AI/A.

       Wettable Powder Formulations:  Apply to agricultural crops at planting,  early
       spring, layby, foliar, or transplant as soil treatment (includes soil incorporation)
       using aircraft, spreader, shaker can, or irrigation at up to 10.5 Ib AI/A; or apply to
       strawberries early spring, summer, early fall, or transplant using soil incorporate
       via spreader or aircraft or use irrigation at  up to 9 Ib AI/A; or apply to ornamental
       plants in spring, late summer, or late fall as broadcast using sprayer,  or apply in
       April, early spring, late summer, nurserystock, or transplant as soil treatment via
       aircraft, or sprayer, or use irrigation at up to 12 Ib AI/A; or apply to ornamental
       lawns and turf in late summer or early fall  as broadcast using sprayer, or  as soil
       treatment via aircraft, or sprayer,  or use  irrigation at up to 15 Ib AI/A.

Use Practice Limitations: (these do not apply to all uses on all products)

* Do not apply directly to water or wetlands (swamps, bogs, marshes, and potholes).
* Do not apply directly to water or wetlands.
* Do not apply directly to water.

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       * Do not apply through any type of irrigation system.
       * Do not discharge effluent containing this pesticide into sewage systems without
       notifying the sewage treatment plant authority (POTW).
       * Do not discharge effluent containing this product into lakes, streams, ponds, estuaries,
       oceans, or public water. (NPDES license restriction)
       * Do not feed clippings to livestock.
       * Do not feed treated foliage to livestock or graze treated areas.
       * Do not feed treated screenings or hay to livestock.
       * Do not graze livestock in treated areas.
       * Do not graze or feed forage, silage or fodder (stubble) from treated fields to dairy
       animals.
       * Do not graze treated areas or feed crop refuse to livestock.
       * Do not graze treated areas or use clippings from treated areas for feed or forage.
       * Do not graze treated areas.
       * For terrestrial uses, do not apply directly to water or to areas where surface water is
       present or to intertidal areas below the mean high water mark.
       * Groundwater restriction.
       * Keep out of lakes,  streams, and ponds.

       C.     Estimated Usage of Pesticide

       This section summarizes the best estimates available for the pesticide uses of DCPA.
These estimates are derived from a variety of published and proprietary sources available to the
Agency for 1988-1994. 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.

       DCPA is registered and labeled for use on the following crops for which there is no
reported usage: alfalfa, beans (succulent, snap) beets, cress (garden) kale, mustards, turnip, and
yam. Although not registered uses, DCPA tolerances are being maintained for four additional
crops which are sometimes grown  in fields previously treated with DCPA. Those crops are:
lettuce, soybeans, corn, and rutabagas. Table 1 below summarizes the use of DCPA by crop for
the remaining registered uses.

Table 1: Typical Annual Usage  and Percentage of Various U.S. Crops Treated with DCPA
Crop Name
BROCCOLI
BRUSSELS
SPROUT
CABBAGE
Acres Grown
/Harvested"
(000)
110
5
91
Acres Treated15
(000)
(Range)
55
0
18
83
1
23
Percentage of
Acres Treated0
(Range)
50

18
61
1
24
Active Ingredient0
(000 Lbs A.I.)
(Range)
230
1
30
300
2
50
Percentage of
Total A.I.
(Range)
14.29
0.10
2.38
20.91
0.09
2.73

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Crop Name
CANTA-
LOUPE
CAULI-
FLOWER
COLLARDS
CUCUMBER
EGGPLANT
GREEN
BEANS
GARLIC
HOT PEPPERS
HONEYDEW
ONIONS
PEPPERS
(BELL)
POTATOES
RADISHES
SQUASH
STRAW-
BERRIES
SWEET
POTATOES
TOMATOES
WATER-
MELON
SEED CROPS
GOLF
COURSES
SOD FARMS
TOTAL
Acres Grown
/Harvested"
(000)
111
55
16
172
3.4
306
26
51
26
157
68
1,379
30
69
51
83.1
450
246
1,516
1,445
152

Acres Treated15
(000)
(Range)
1
14
6
2
0
3
1
8
0
55
1
14
0
3
1

5
2
15
29
8
0
2
36
8
3
0
6
1
10
1
79
1
28
2
7
5
6
9
5
30
43
15
0
Percentage of
Acres Treated0
(Range)
1
26
41
—
1

1
16
1
38
1
—
1
5
8

—

1
2
5

3
36
50
1
3
1
2
24
2
63
2
1
2
10
12
7
1
1
2
3
10

Active Ingredient0
(000 Lbs A.I.)
(Range)
1
50
30
2
1
1
3
25
1
300
1
2
2
25
5

10
1
150
150
75
1,100
2
100
40
o
5
2
2
4
30
2
750
3
o
J
3
30
50

20
2
250
300
150
2,100
Percentage of
Total A.I.
(Range)
0.10
4.76
1.90
0.14
0.10
0.10
0.19
1.43
0.10
35.71
0.14
0.14
0.14
1.43
2.38

0.95
0.10
11.90
14.29
7.14

0.09
4.55
2.73
0.18
0.09
0.09
0.27
2.27
0.09
27.27
0.09
0.18
0.18
2.27
0.45

0.91
0.09
13.64
13.64
6.82

a Three years 1992-1994 or 1991-1993 average (with some 1992 data when available) is reported. Sources:
USDA.  Crop Production, 1994 Summary, January 1995;  USDA. Vegetables 1994 Summary, January 1995;
Department of Commerce. 1992 Census of Agriculture, Part 1, Volume 1, October 1994;  EPA Proprietary
Sources;  Gianessi L. P. and Anderson  J. E. (National Center for Food and Agricultural Policy) Pesticide Use in
U.S. Crop Production, February 1995.

b Acres Treated is calculated by multiplying the Acres Grown by the Percentage of Acres Treated.

0 Sources: EPA Proprietary Sources; Gianessi L. P. and Anderson J. E. (National Center for Food and
Agricultural Policy) Pesticide Use in U.S. Crop Production, February 1995; State of California. Pesticide Use
Report, Annual 1990; USDA. Agricultural Chemical Usage, 1993 Field Crop Summary, March 1994; USDA.
Agricultural Chemical Usage, 1992 Field Crop Summary, March 1993; USDA. Agricultural Chemical Usage,
Vegetables 1992 Summary, June 1993.
        D.     Data Requirements

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       Data requested in the June 1988 Registration Standard for DCPA include studies on
product chemistry, ecological effects, environmental fate, and residue chemistry, toxicology, and
occupational and residential exposure.  These data were required to support the uses that were
listed in the Registration Standard. Appendix B of this document includes all data requirements
reviewed to support decisions in this reregi strati on document.

       E.     Regulatory History

       DCPA was first registered under FIFRA in 1958 for use on turf grasses as an herbicide for
the selective preemergence control of crabgrass and other assorted weeds. The DCPA
Registration Standard ("EPA Guidance for Reregi strati on of Pesticide Products Containing
DCPA as the Active Ingredient"), was  issued in June,  1988.  In the 1988 Registration Standard,
the Agency listed the data required for continued registration of pesticide products that were
manufactured with DCPA. Timeframes for submitting the required data to continue the
registration of these products were set forth in that document. In addition, labeling amendments
were required to bring all registered DCPA pesticide products into compliance with existing
labeling policy of the Agency.

       Today, there are 60 FIFRA Section 3 registrations and 6 FIFRA Section 24(c)
registrations totalling 66 product registrations. There are presently two  manufacturing use
products from which all other products are formulated. ISK Biotech Corporation is the registrant
of these manufacturing-use products - Dacthal 1.92F and 90% Dimethyl-T.

       The DCPA technical  products were subject to a June, 1987 Data Call-In Notice (DCI)
requiring analysis for polyhalogenated  dibenzo-p-dioxins/dibenzofurans (referred to as
dioxin/furans).  Data submitted by the registrant in response to the DCI reflected analysis of seven
batches of technical  DCPA for  15 dioxin/furans.  To completely comply with the requirements of
the 1987 DCI, ISK Biosciences must supply data reflecting analysis of duplicate samples spiked
with each of the 13C-labeled dioxin/furan standards at or below the EPA-required Level of
Quantitation (LOQ) for the corresponding dioxin/furan analyte. The percent recoveries shall be
50-150% and relative percent differences (RPDs) shall be <20%.  The registrant has indicated that
two samples were sent for duplicate precision analysis in April of 1991.  These data are
considered confirmatory; no further dioxin analysis will be required to fulfill reregistration data
requirements.

       Additionally, the Agency's Environmental Chemistry Laboratory analyzed DCPA technical
and end-use products for the  presence of polyhalogenated dioxin/furans. One sample out of the
15 analyzed contained 2,3,7,8-TCDD at a level exceeding the Agency's specified Level of
Quantitation (LOQ), 0.1 ppb. The registrant, ISK Biosciences, informed the Agency that the
75% FI sample which contained 2,3,7,8-TCDD had not been produced commercially in the plant,
but had been formulated under laboratory conditions to fulfill the Agency's requirement for
product samples.  The registrant stated that the sample was not representative of the DCPA

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products currently produced by ISK Biosciences.

       DCPA formulations contain hexachlorobenzene (HCB) as an impurity. The Registration
Standard required analytical data to determine residues of HCB in/on representative test crops.
HCB data, submitted from field trials with representative commodities, indicated that no residues
of HCB were present at greater than 1 ppb as the result of a Ix application of DCPA.

       Because of TPA's potential to leach to groundwater, the Agency issued a Groundwater
Advisory notice in 1992 which required all DCPA end-use products to bear the following
statement:

       Tetrachloroterephthalic acid, a breakdown product of Dacthal, is known to leach
       through soil as a result of agricultural and turf uses and has been found in
       groundwater which may be used for drinking water. Users are advised not to apply
       Dacthal to sand or loamy sand soils where the water table (groundwater) is close
       to the surface and where those soils are very permeable, i.e. well drained. Your
       local agricultural  agencies can provide further information on the type of soil in
       your area and the location of groundwater used for drinking water.

III.    SCIENCE ASSESSMENT

       A.    Physical Chemistry Assessment

             1.     Description of Chemical

       DCPA (dimethyl tetrachloroterephthalate) is a pre-emergent herbicide used to control
annual grasses and broadleaf weeds. The molecular structure of DCPA is illustrated below in
figure A.
                                     Cl

                                     cr

                                     H3ccr  ^o

       Other identifying characteristics and codes for the chemical are:

             Empirical Formula:    C10H6C14O4
             Molecular Weight:    332

             2.     Identification of Active Ingredient

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       Technical DCPA is a colorless or white crystal with a melting point of 155° C and a bulk
density of 0.75 g/cm3. It is soluble in water at only 0.5 ppm at 25° C. Relative solubility of
organic solvents is as follows: benzene>toluene>xylene>dioxane>acetone>carbon tetrachloride
(25° C).

              3.     Manufacturing-Use Products

       There are three DCPA manufacturing-use products (MPs) registered to ISK Biosciences
Corporation (formerly Fermenta ASC Corporation): a 20.7% formulation intermediate (FI; EPA
Reg. No. 50534-187), a 75% FI (EPA No. 50534-20), and a 90% FI (EPA Reg No. 50534-113).
There is also a 98% minimum technical (T; EPA File Symbol No. 50534-ROA) which is currently
in the initial registration process.

       B.     Human Health Assessment

              1.     Toxicology Assessment

       The toxicological data base on DCPA is adequate for making reregi strati on eligibility
decisions.
                    a.    Acute Toxicity

       Acute toxicity values and categories for DCPA are summarized in Table 2.

Table 2: Acute Toxicity Data3
TEST
Oral LD50»rat
Dermal LD50~rabbit
Inhalation LC50~rat
Eye irritation~rabbita
Dermal irritation~rabbita
Dermal sensitization-guinea
piga
RESULTS
>5000 mg/kg
>2000 mg/kg
>4.48 mg/L
mild irritation
mild irritation
not sensitizing
CATEGORY
IV
III
III
III
IV
~
a The dermal sensitization test was performed with a 90% technical material. All other acute
toxicity tests were performed using a 98% and a 90% technical material. The reported values are
the results from testing the 98% technical.

                    b.     Subchronic Toxicity

       In a 21-day dermal toxicity study, Charles River CD rats were dermally exposed to DCPA
doses of 0,  100, 300, or 1000 mg/kg/day. No dermal irritation at the site of application was
observed.  No adverse effects were found; therefore, the NOEL was equal to or greater than 1000

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mg/kg/day, the highest dose tested (GLN 82-2; MRID 41231803).

       CD VAF/Plus Sprague Dawley rats were given 0, 10, 50, 100, 150, or 1000 mg/kg/day of
DCPA in the diet for 90 days.  The NOEL was 10 mg/kg/day. The LOEL was 50 mg/kg/day,
based on increased liver weight and microscopic effects. The treatment-related effects were:
increased weight and centrilobular hypertrophy in the liver; increased accumulation of foamy
macrophages in the lung; increased weight, epithelial hyperplasia, and tubular hypertrophy of the
kidney; and follicular hypertrophy of the thyroid. There were slight decreases in body weight and
food consumption in high dose females only (GLN 82-1; MRID 41767901).

       Male CD-I mice were given doses of 0, 100, 199, 406, or 1235 mg/kg/day DCPA and
females were given 0, 223, 517, 1049, or 2198 mg/kg/day DCPA in the diet for 90 days.  There
were no effects other than minimal histopathological effects on the liver.  The NOEL was 406
mg/kg/day for males and 517 mg/kg/day for females. The LOEL for males was 1235 mg/kg/day
and for females was 1049 mg/kg/day, based on the liver effects (GLN 82-1; MRID 41064801).

                    c.      Chronic Toxicity and Carcinogenicity

       Beagle dogs were given 0, 2.5, 25, or 250 mg/kg/day DCPA in the feed for two years.
Adverse effects were not found.  Therefore, the NOEL was equal to or greater than 250
mg/kg/day  (GLN 83-1; MRID 00083584).

       A chronic toxicity and carcinogenicity study was conducted with Sprague Dawley CD
rats. The doses of DCPA given in the diet for two years were 0, 1,10, 50, 500 or 1000
mg/kg/day. The NOEL was 1 mg/kg/day. The LOEL was 10 mg/kg/day, with effects observed
in the lungs, liver, and thyroid; decreases in thyroid hormone levels in both sexes; and effects in
eyes in females. The specific effects were: (1) increased mortality in males at 1000 mg/kg/day
(HOT) during the  second year; (2)  either decreased body weights or decreased body weight gains
in both sexes at 1000 mg/kg/day, and in females at 500 mg/kg/day; (3) changes in hematology and
clinical chemistry parameters indicative of liver and kidney toxicity at both 500 and  1000
mg/kg/day in both sexes; (4) treatment-related increases in thyroid, liver, and kidney weights in
both sexes; (5) a dose-related increase in white foci in the lungs, which correlated with an
increased incidence of foaming macrophages in both sexes at doses of 10 mg/kg/day and higher;
(6) treatment-related exacerbation of chronic nephropathy in both sexes at 50 mg/kg/day and
higher; (7) a dose-related increase in centrilobular hepatocytic swelling in both sexes at doses of
10 mg/kg/day and higher; (8) a dose-related increase in liver neoplasms in females; (9) an increase
in follicular cell hyperplasia/hypertrophy at 10 mg/kg/day in males and at doses of 50 mg/kg/day
and higher in both sexes; (10) decreased  T4 (thyroid hormone/thyroxine) values at 10 mg/kg/day
in males, and at 50 mg/kg/day and higher in both sexes; and (11) a treatment-related increase in
thyroid follicular cell neoplasms in both sexes (GLN 83-5; MRTD 42731001).

       In another combined chronic toxicity and carcinogenicity study, CD-I mice were given
DCPA in the diet for two years.  The doses were 0,  12, 123, 435, or 930 mg/kg/day DCPA in the
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diet for males and 0, 15, 150, 510, or 1141 mg/kg/day for females.  The NOEL for systemic
effects was 435 mg/kg/day in males; 510 mg/kg/day in females.  The systemic LOEL was 930
mg/kg/day in males; 1141 mg/kg/day in females, based on liver effects. There were increased
liver weights, increased SDH (sorbital dehydrogenase) and GPT (glutamic-pyruvic transaminase)
activities, and increased incidence of hepatocyte enlargement or vacuolation in both sexes at the
high dose levels; 930 and 1141 mg/kg/day for males and females, respectively.  There was a
significant increase  in hepatocellular neoplasms in females at the high dose level of 1141
mg/kg/day. Corneal opacity was observed in this study (GLN 83-5; MRTD 40958701).

      Additionally, a  supplementary rat chronic ophthalmology study was conducted to
investigate the corneal  opacity observed in the mouse study. There was no evidence of ocular
toxicity observed in rats fed DCPA in the diet at levels up to 1000 mg/kg/day for two years
(MRID41750102).

                    d.     Developmental Toxicity

      A developmental toxicity study with Sprague Dawley rats used doses of 0, 500, 1000, or
2000 mg/kg/day given  by gavage on gestation days 6-15. No adverse effects on the maternal rats
or their offspring were  observed. Therefore, the maternal and developmental toxicity NOELs
were set at 2000 mg/kg/day, HOT (GLN 83-3; MRID 00160685).

      Two  studies were conducted with New Zealand white rabbits. In the first study, DCPA
doses of 0, 500, 1000, or  1500 mg/kg/day were given by gavage on gestation days 6-19.  There
were maternal deaths and adverse clinical signs at all dose levels. In the second study, DCPA
doses of 0, 125, 250, or 500 mg/kg/day were given by gavage on gestation days 7-19. None of
these levels produced any maternal or developmental toxicity. The second study tested dose
levels that overlapped those in the first study. Therefore, when considered together, the NOEL
for maternal  toxicity can be set at 250 mg/kg and the LOEL can be set at 500 mg/kg based  on
maternal deaths.  The developmental toxicity NOEL can be set at 500 mg/kg. Although no
developmental effects were observed at any of the higher dose levels, a higher NOEL cannot be
set based on  the limited number of litters at the higher dose levels.  (The two studies together
fulfill GLN 83-3; MRID 41054820, 41838301).

                    e.     Reproductive Toxicity

      In a two generation reproduction study, female Sprague Dawley rats were fed DCPA at
doses of 0, 63, 319, or  1273 mg/kg/day while males received doses of 45, 233, or 952 mg/kg/day
DCPA. (These doses were equivalent to 0, 1000, 5000, and 20,000 ppm food residue values,
which are used for mammalian risk assessment in the Section III under Environmental
Assessment.) No effects on reproductive performance in 2  generations with 2 litters per
generation were seen.  The maternal NOEL was 63 mg/kg/day.  The maternal LOEL was 319
mg/kg/day, based on decreased body weight/body weight gain.  The reproductive NOEL was 63
mg/kg/day. The LOEL was 319 mg/kg/day, based on decreased pup body weight. The paternal
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NOEL was set at 233 mg/kg/day,  and the LOEL was set at 952 mg/kg/day due to decreased
body-weight gain. On day 0 of the F2b litters, the diets for the low and mid-dose groups were
changed to 18 and 47 mg/kg/day respectively to be able to set a NOEL for pup body weight.  The
offspring NOEL was set at 18 mg/kg/day (200 ppm), and the LOEL was 47 mg/kg/day (500 ppm)
based on decreased body weight.  (GLN 83-4; MRID 41750103, 41905201).

                    f.     Mutagenicity

      DCPA did not induce a mutagenic response in two independently performed mouse
lymphoma forward mutation assays. The nonactivated concentration range was 7.5 to 100 //g/mL
and the S9-activated range was 15 to 200 //g/mL (GLN 84-2(a) Category I; MRID 41054822).

      In an in vitro cytogenetic assay, Chinese hamster ovary cells were exposed to DCPA at
dose levels of 0, 30, 100, 300, or 1000 //g/mL for 4 hours both with and without S-9 activation.
Cells were harvested at 12 and 18 hours.  There were no indications of a clastogenic response as a
result of exposure to test material at any dose level.  (GLN 84-2(b) Category II; MRID
41054823).

      DCPA was not genotoxic in two independently performed unscheduled DNA synthesis
(UDS) assays in which the concentration ranged from 3 to 1000 //g/mL  (GLN 84-2(b) Category
III; MRID 41054824).

      An in vitro assay for sister chromatid exchange (SCE) in Chinese hamster ovary cells was
performed at dose levels of 0, 38, 75, 150, or 300 //g/mL both with and without S9-activation.
There was no indication of a positive response; therefore, under the conditions  of this assay the
test material is negative (GLN  84-2(b) Category III; MRTD 41054825).

                    g.     Metabolism

      In one study, a single oral dose of 14C-DCPA at either 1 or 1000 mg/kg was given to
Sprague-Dawley rats (5 rats/sex/dose level). The major metabolite of DCPA in the urine of both
sexes at both dose levels was 4-carbomethoxy-2,3,5,6-tetrachlorobenzoic acid. No radiolabel was
excreted in the urine as the parent compound, DCPA. (MRID 42155501)

      There was a second study in which a single oral dose of 14C-DCPA at either 1 or 1000
mg/kg was given to Sprague-Dawley rats.  Bile was found to be a negligible excretory route for
radiolabeled DCPA. At the low dose, 61% of the administered radiolabeled DCPA was excreted
in the urine. The percent absorption (urine, blood, bile, cage rinse, and carcass) was 79% of the
administered dose. At the high dose, 55 % of the administered radiolabel was excreted in the
feces or was found in the GIT (gastro-intestinal tract).  The percent absorption was 8% of the
administered dose. (MRID 42155503)

      There was a third  study in which a single oral dose of 14C-DCPA at either 1 or 1000
                                          12

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mg/kg was given to Sprague-Dawley rats (3 rats/sex/dose level) to determine the major route of
excretion. Urine was the major route at the low dose, and feces was the major route at the high
dose.  Negligible amounts of radiolabel were found in the tissues examined at 48 hours following
dosing.  There were no significant differences observed between the sexes at either dose level.
(MRID 42155502)

       In a different study, nonradiolabeled DCPA was administered in single, daily oral doses to
Crl:CD BR VAF/Plus rats (15 rats/sex/dose level) for 14 consecutive days at either the 1  or 1000
mg/kg/day dose level. Twenty four hours after the 14th dose, a single oral dose of 14C-DCPA (1
or 1000 mg/kg) was administered to each rat. At the high dose level (both sexes), the majority of
the administered 14C-DCPA was unabsorbed and was eliminated in the feces, while at the low-
dose level (both sexes) the majority of the administered 14C-DCPA was absorbed and excreted in
the urine. Radiolabel was found in all tissues examined, and the radiolabel concentration was
higher in the high-dose rat tissue than in the same tissue at the low dose level. At 168 hours,
radiolabel was still detectable in nearly all tissues at both dose levels and in both sexes. The
elimination half-life of radiolabel was calculated to be 22-23 hours at the high dose and
approximately 18 hours at the low  dose.  (MRID 42723201, 42723202)

       In another study, Sprague-Dawley rats (5 rats/sex/dose level) were given single or
multiple (14 days) oral doses of 14C-DCPA (1 or 1000 mg/kg). The major metabolite of DCPA in
the urine of both sexes at both dose levels following both single and multiple dosing was 4-
carbomethoxy-2,3,5,6-tetrachlorobenzoic acid.  A minor metabolite was tetrachloroterephthalic
acid.  No radiolabel was excreted in the urine as the parent compound, DCPA. (MRID 42723203)
Together these studies fulfill GLN  85-1.  (MRID 43052201)

                    h.     Dermal Absorption

       A study was conducted with male Sprague-Dawley rats using doses of 4.75, 47.5, 475.0
and 1000.0 ug/cm2 of radiolabeled  DCPA with a number of each dose group sacrificed at 0.5, 1.0,
2.0, 4.0, 10.0, and 24 hours. The area of the dermal application was washed to recover
unabsorbed DCPA. The skin, blood, urine, feces, and carcass were analyzed for percent of total
DCPA applied.  At the 4.75 ug/cm2 dosing level, for the group sacrificed at 10 hours, 14.9 % of
the applied DCPA was absorbed. The percent absorption increased with duration of exposure
and generally decreased with increasing dose. (MRID 42651502)

       A complimentary study of radiolabeled HCB in DCPA with male Sprague-Dawley rats
using  dosing levels of 0.1%, 0.2%, and 0.3% (0.475, 0.950, and 1.425 ug/cm2) was conducted.
A number of each dose group  was  sacrificed at 0.5, 1.0, 2.0, 4.0, 10.0, and 24 hours.  The area of
the dermal application was washed to recover unabsorbed HCB. The skin, blood, urine, feces,
and carcass were analyzed for percent of total HCB applied. At the 0.1% dosing level, for the
group sacrificed at 10 hours, 26.46 % of the applied HCB was absorbed. The percentage of HCB
that was removed during the washing procedure, as well as the percentage remaining in the skin at
the application site decreased with  duration of exposure. The percentage of HCB in the carcass
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increased as the exposure duration increased. (MRID 42651501) These studies together fulfill
GLN 85-2.

       The Agency does not have dermal absorption data on dioxin/furans.

                    i.      DCPA Reference Dose (RfD) and Cancer Potency Factor

       Previously, the RfD for DCPA was determined to be 0.5 mg/kg/day based on a No
Observed Effect Level (NOEL) of 50 mg/kg/day in a 1963 2-year rat study. DCPA's first RfD for
DCPA was verified on February 18, 1987. However, as part of the re-registration process, newer
information was submitted to the Agency, and it was decided to re-evaluate the RfD.

       On 12/9/93 the Agency's Health Effects Division RfD Committee met and selected an RfD
of 0.01 mg/kg body wt/day, based on a NOEL of 1.0 mg/kg/day in the chronic rat toxicity study
(MRID 42731001, discussed in detail earlier). Effects were observed in lungs, liver, thyroid, and
thyroid hormones  in both sexes and the eyes in females at 10 mg/kg/day.  An uncertainty factor of
100 was used to account for the inter-species extrapolation and intra-species variability.  The
current RfD was verified on February 17,  1994 by the Agency's Office of Research and
Development, and entered into the Agency's Integrated Risk Information System (IRIS) in August
1994.  The IRIS entry indicates that the principal study was well conducted receiving a high
confidence level. The additional studies were considered to be of good quality  and generally
supportive of the principal study. Therefore, the DCPA database was given a high confidence
rating which yields a logical conclusion of high confidence in the DCPA RfD.

       The Carcinogenicity Peer Review Committee (CPRC) of the Office of Pesticide Programs
discussed DCPA on 6/29/94 and 11/16/94. The CPRC classified DCPA as Group C, possible
human carcinogen, based on evidence of increased incidence of thyroid tumors in both sexes of
the rat  (although only at an excessive dose in the female), and liver tumors in female rats and
mice, at doses which were not excessive.  It was recommended that a low dose extrapolation
model be applied to the animal data for the quantification of human risk based  on the combined
liver tumors in the female rat liver.

       DCPA's cancer potency factor was calculated using a multi-stage model (Tox_Risk
Program, version 3.5). A 3/4's scaling factor is used to account for the body weight differences
when extrapolating from rodent carcinogen bioassays to humans.  There are several
methodologies than can be used to produce good estimates of cancer potency in humans from
rodent  bioassays.  EPA, the Food and Drug Administration, and the Consumer Product Safety
Commission have  all determined that the 3/4's scaling factor would be an appropriate default
methodology. (Specific reasons for the selection and the use of the 3/4's scaling factor are
specified in the  June 5, 1992 Federal Register Notice.)  The estimated Qx* (mg/kg/day)"1 of DCPA
is 1.49  x 1Q-3.

       The CPRC agreed that the manufacturing process impurities contained in DCPA may have
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contributed to DCPA's tumor response. However, the CPRC also concluded that the tumors seen
in these studies could not be attributed solely to the presence of either impurity HCB or 2,3,7,8-
TCDD.

                    j.      Hexachlorobenzene (HCB) as a DCPA Impurity

       HCB is a recognized impurity in DCPA. The maximum level of HCB that is allowed  in
formulations of DCPA is 0.3 percent. Therefore, the risk assessments supporting this document
assume that HCB is present at a level of 0.3 percent of DCPA in the food supply and in DCPA
applied to a field.

       The Agency has classified HCB as a B2 (probable human) carcinogen, based on data sets
which showed significant increases of tumor incidence in two species:  hamsters and rats.  In the
IRIS database, the Qt* was 1.7 (mg/kg/day)"1 calculated based on hepatocellular carcinomas in
female Sprague-Dawley rats. However, since DCPA was calculated using the 3/4's scaling factor,
the Qj* for HCB was modified by multiplying by 0.6 to account for the newer factor. The
modified  Qt* used in this risk assessment was 1.02 (mg/kg/day)"1.

       The RfD for HCB is 0.0008 mg/kg body wt/day based on a NOEL of 0.08 mg/kg/day in a
130 week feeding study in rats.  (Effects observed were hepatic centrilobular basophilic
chromogenesis.)  An uncertainty factor of 100 was used to account for the inter-species
extrapolation and intra-species variability.

       The dermal absorption factor of HCB is 26.46% (see MRID 42651501 under Dermal
Absorption). At this time no other toxicological endpoints  of concern have been identified for
HCB.

                    k.     Polyhalogenated dibenzo-p-dioxins/dibenzofurans as DCPA
                           Impurities

       Polyhalogenated dibenzo-p-dioxins/dibenzofurans (dioxin/furans) are recognized
impurities of DCPA.  Of the dioxin/furans, only the 2,3,7,8-tetrachloro-dibenzo-para-dioxin
(2,3,7,8-TCDD) congener has been assigned a quantified estimate of its carcinogenic potential.
The Agency has classified 2,3,7,8-TCDD as  a B2 (probable human) carcinogen based on data sets
which showed significant increases of tumor incidence in two species: Sprague-Dawley rats and
B6C3F1 mice.  The cancer potency factor Q^ was calculated based on multiple tumor sites in the
female Sprague-Dawley rats and is therefore estimated to be 1.56 x 10s (mg/kg/day)"1. However,
since DCPA was calculated using the 3/4's scaling factor, the Qt* for 2,3,7,8-TCDD was modified
by multiplying by 0.6 to account for the newer factor. The modified Qt* used in this risk
assessment was 1 x 105 (mg/kg/day)"1.

       Enough data exists, however, regarding the potency of the other congeners to estimate
their relative potency in comparison to the 2,3,7,8-TCDD.  Therefore, in evaluating the
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toxicological significance of the dioxin/furan contamination, the Agency converts all of the
congener detection values into one value which represents the equivalent 2,3,7,8-TCDD potency.

       For example, if a product contained 10 ppb of a dioxin congener other than the 2,3,7,8-
TCDD. If that congener is considered to be only 1/10 as potent as 2,3,7,8-TCDD, the Agency
would use the equivalent of 1 ppb of 2,3,7,8-TCDD in its risk assessment.

       DCPA's registrant submitted dioxin/furan detection values to the Agency from seven batch
samples, as required in the  1987 DCI.  During the first sampling, one of the dioxin/furan
congeners was detected above the Agency specified Level of Quantitation (LOQ).  The registrant
subsequently altered their manufacturing process in an effort to reduce this contamination.
(MRID 41241801)

       Subsequent to this change, none of the dioxin/furan congeners were detected above
Agency specified LOQs in the remaining six batch samples. The 2,3,7,8-TCDD equivalency of
the dioxin/furans reported to the Agency is approximately 0.1 ppb, which would equal
0.00000001% of the DCPA formulations.  The Agency used this contamination value
(0.00000001%) to determine exposure values used in the risk assessments for DCPA's
reregi strati on eligibility evaluation. The registrant must propose certified upper limits  for all
dioxin/furan congeners for which detection values were reported to the Agency.

       The RfD for 2,3,7,8-TCDD is  0.000001 ug/kg/day based on a LOEL  of 0.001  ug/kg/day
from a three-generation feeding study in rats.  (Effects at the lowest dose tested included dilated
renal pelvises, decreased fetal weight,  and  changes in the gestational index).  An uncertainty factor
of 100 was used to account for the inter-species extrapolation and intra-species variability.  An
additional uncertainty  factor of 10 was used to account for the lack of a NOEL.  At this time, no
other toxicological endpoints of concern have been identified for 2,3,7,8-TCDD.

                     1.      Tetrachloroterephthalic Acid (TPA) as a DCPA Metabolite

       Tetrachloroterephthalic Acid (TPA) is one of two DCPA animal metabolites.  DCPA fed
to lactating goats was metabolized into both TPA and monomethyl tetrachloroterephthalic acid
(MTP). It is the TPA metabolite, however, that is found most frequently in the environment after
DCPA use. Soil metabolism converts DCPA into TPA, which is known to leach through soil and
pollute ground water.  Therefore, the registrant submitted the following additional  studies to
specifically assess the toxicity of TPA.

Subchronic Toxicity

       Disodium 2,3,5,6-tetrachloroterephthalic acid was given to Charles River CD rats in the
diet for 13 weeks.  There were 15 rats/sex/dose group using dose levels of 0, 2.5, 25,  50, or 500
mg/kg/day. There were no adverse effects in either sex at any dose level.  The NOEL is greater
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than or equal to 500 mg/kg/day, the highest dose tested.  The LOEL cannot be determined.
(GLN 82-1; MRID 00100773)

       CD Sprague-Dawley rats (10/sex/dose group) were given 2,3,5,6-tetrachloroterephthalic
acid via gavage for 30 days at dose levels of 0, 100, 500, or 2000 mg/kg/day. There were no
apparent adverse effects observed at any dose level. The NOEL is greater than or equal to 2000
mg/kg/day, the highest dose tested. The LOEL cannot be determined. (MRID 00158011)

Developmental Toxicity

       In a developmental toxicity study, 25 pregnant Charles River rats/dose group were dosed
via gavage on gestation days 6-15 with TPA at dose levels of 0, 625, 1250, or 2500 mg/kg/day.
The maternal toxicity NOEL was 1250 mg/kg/day. The maternal LOEL was set at 2500
mg/kg/day based on decreased body-weight gain and food consumption.  There were no signs of
developmental toxicity, therefore the developmental NOEL was set at 2500 mg/kg/day, the
highest dose tested. A LOEL was not determined. (GLN 83-3(a); MRID 262303)

Mutagenicity

       TPA did not induce a mutagenic response in the Ames assay or the HGPRT assay with or
without metabolic activation.  (GLN 84-2(a); MRID 262302)  In the Sister Chromatid Exchange
(SCE) assay, TPA did not induce a significant increase in the SCE frequency of Chinese Hamster
Ovary cells, both with and without metabolic activation.

       TPA did not induce an increase in unscheduled DNA synthesis. In an in vivo mouse
micronucleus assay, TPA was negative for clastogenicity in females and at best equivocal in
males.  Based on the overall weight of evidence of no mutagenic response of this compound in
other studies, as well as the lack of mutagenicity of the parent DCPA, further testing for
mutagenicity is not warranted at this time.

              2.     Exposure Assessment

                    a.      Dietary Exposure

       Tolerances for residues of DCPA in or on raw agricultural commodities are currently
expressed as the combined residues of DCPA and its metabolites monomethyl
tetrachloroterephthalate (MTP) and tetrachloroterephthalic acid (TPA) calculated as DCPA.  At
present, no tolerances exist for residues of DCPA in animal commodities.

       Although all the data requirements of the Reregi strati on Guidance have not been met at
this time, the outstanding data are considered to be confirmatory  to the reregi strati on eligibility
decision. Sufficient data are available to conduct reasonable anticipated residue assessments.
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Plant Metabolism
       The qualitative nature of the residue in plants is adequately understood based on
acceptable studies on onions, turnips, and tobacco. The residues of concern in plants are DCPA,
and its metabolites MTP and TPA which are the parent and metabolites that are currently
regulated.  (See Figure B below.)  The proposed metabolism of DCPA in plants is via ester
hydrolysis.  Studies conducted with onion and turnip indicate that the impurity HCB is not
metabolized appreciably in these plants.

       Total radioactive residues  (TRR) were 0.548 ppm in mature onion bulbs and 6.458 ppm in
onion tops treated with 14C-DCPA at Ix.  DCPA and its metabolites, MTP and TPA, accounted
for 66% and 79% of the TRR in onion tops and mature bulbs, respectively.  TRR in mature turnip
roots and tops were 4.732 and 2.015 ppm from Ix treatment with [14C]DCPA. Combined
residues of DCPA, MTP, and TPA accounted for 78-89% of the TRR in turnip  roots and tops. In
tobacco treated with 14C-DCPA, TRR in whole plants were 21-23 ppm. DCPA, MTP, and TPA
accounted for 91-98% of the radioactivity in tobacco.

Figure B:  The Chemical Structure of DCPA and its Metabolites of Concern
               Chemical name
Chemical structure
  DCPA
  Dimethyl tetrachloroterephthalate
                                                            O ^  OCH3
   Cl

   Cl

   H3ccr
                                                                     Cl
  MTP
  Monomethyl tetrachloroterephthalic acid
                                                          Cl
                                                          Cl
                                                           HO"
              Cl
                                          18

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               Chemical name
Chemical structure
  TPA
  Tetrachloroterephthalic acid
                                                          Cl   /
                                                          ci    ~      Cl
Animal Metabolism

       The nature of the residue in ruminants is adequately understood. DCPA, MTP, and TPA
are the residues of concern. A lactating goat was dosed with 14C-DCPA for 4 days.  The daily
dose was equivalent to 10 ppm in the diet, ~ Ix the theoretical maximum DCPA intake for dairy
cattle and 2x the maximum beef cattle intake. Total radioactive residues (TRR) were less than or
equal to 0.01 ppm in milk with 38.5% organosoluble (0.004 ppm). Milk residues were not further
characterized. Residues in tissues were 0.0057 ppm in loin muscle, 0.0109 ppm in leg muscle,
0.0168 to 0.0179 ppm in fat, 0.0333 ppm in liver, and 0.1007 ppm in kidney.  MTP was the
predominant residue in kidney, liver, leg muscle, and fat, accounting for 80-98% of the TRR.  The
parent compound DCPA was detected only in fat at 10-15% of TRR.  TPA was found only in
omental fat at 5% of TRR. Until adequate cattle feeding studies are available, the data from this
metabolism study will be used for estimating residues in meat and milk commodities.

       The requirement for a poultry metabolism study has not been met, and remains in effect.
Until these data are generated, the Agency will use the existing poultry feeding studies for
exposure/risk assessment based on the assumption that the residues of concern in poultry tissues
and eggs are the same as those delineated in meat and milk from the acceptable ruminant
metabolism study.

Residue Analytical Methods - Plants and Animals

       Three tolerance enforcement methods for plant commodities are published in the Pesticide
Analytical Manual (PAM), Vol. II (Section 180.185), as Methods A, B, and C.  Residue data
submitted in response to the 6/88 Guidance Document were collected using GC/EC methods
similar to the PAM, Vol. II methods. These methods are adequate for collection of DCPA, HCB,
MTP, and TPA residue data from potatoes (including processed commodities), sweet potatoes,
broccoli, celery, cucumbers, green and bulb onions, strawberries, sweet and bell peppers,
cantaloupes, tomatoes (including processed commodities), summer squash, and processed
commodities of beans and cottonseed.  The limits of detection (LOD) are 0.01 ppm each for
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DCPA, MTP, and TPA, and 0.0005 ppm for HCB.  These methods are suitable candidates for
validation procedures as enforcement methods for plant commodities.

       Another GC/EC method, similar to those submitted for plants, is available for determining
DCPA, MTP, and TPA in milk and beef fat. Recoveries of each compound using 12 samples each
of milk and beef fat fortified at 0.01-5 ppm were acceptable. The LOD is 0.01 ppm.  This method
is suitable for Agency validation and inclusion in PAM, Vol. II pending successful independent
laboratory validation. The registrant has indicated that independent laboratory validation of the
method is underway.  The registrant must submit independent laboratory validation data for
enforcement method(s) for animal commodities and submit the method(s) for Agency validation
and inclusion in PAM, Vol. II. Representative samples from adequate animal metabolism studies
must be analyzed by preferred enforcement method(s) to ascertain their ability to adequately
recover and quantify DCPA, MTP, and TPA.

      DCPA/>er se is completely recovered using PAM, Vol. I Multiresidue Protocols D and E
(PESTDATA, PAM, Vol. I, Appendix, 8/93).  Data submitted by the registrant indicate that the
TPA is not recovered by Protocols B and C. Multiresidue testing data on MTP are still required.

Storage Stability

       The results of a storage stability study on tomato processed products demonstrated that
residues of DCPA, MTP, and TPA are stable in these commodities during frozen storage for up
to 3.5 years.

       Adequate storage stability data on DCPA, MTP, TPA, and HCB residues are available for
broccoli, peppers (sweet and bell), onions (green  and bulb), radish (tops and roots), celery,
succulent beans, and sweet potatoes.  The available data from an ongoing 4-year storage stability
study indicate that these compounds are generally stable for intervals of 12 to 24 months in frozen
(-12 to -18 C) storage. The storage stability study on the above commodities encompassing
storage intervals of up to 4 years (i.e., study completion) must be submitted.

       Storage stability data supporting actual sample conditions and intervals of storage are
required for all samples from residue studies used to support tolerances.  Sample storage
information is required to validate the residue studies.

       These data are considered confirmatory to the existing evidence that residues of DCPA,
MTP  and TPA are  stable in plant matrices during frozen storage.

Magnitude of the  Residue in Plants

      Provided that the required confirmatory storage stability data support studies reviewed for
reregi strati on, all data requirements for the magnitude of DCPA and HCB residues in plants are
adequate.  Field trials have been performed representing the various conditions under which the
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pesticide can be applied. Geographical representation is adequate and a sufficient number of trials
reflecting representative formulation classes have been conducted.  Field trial data are required
depicting residues of DCPA and its metabolites in/on cowpea forage hay. Alternatively, the
registrants may restrict the use of DCPA on beans to varieties that are used for human
consumption only. Because the Agency now considers cotton gin byproducts to be a feed
commodity, data are required depicting residues of DCPA and its metabolites in/on cotton gin by-
products. Once adequate data for the cowpea and cotton commodities have been submitted and
evaluated, then suitable tolerances must be proposed.

       Adequate HCB data were submitted from field trials with representative commodities
from the following crop groups: leafy vegetables (celery), brassica leafy vegetables (broccoli),
legume vegetables (beans), fruiting vegetables (tomatoes), small fruits and berries (strawberries),
bulb vegetables (green onions), cucurbit vegetables (cucumbers, melons, and squash), and
cottonseed.  No residues of HCB were detected at > 1 ppb (the required LOQ) as the result of a
Ix application of DCPA; therefore, no additional HCB residue data are required.

Magnitude of the Residue in Processed Food/Feed

       Processing studies have been conducted on beans, cottonseed, tomatoes, and potatoes.
All data concerning the magnitude of the residue in processed food/feed commodities have been
deemed adequate to determine the extent to which residues of DCPA concentrate in food/feed
items upon processing of the raw agricultural commodity.

       DCPA residues concentrate in wet (19x) and dry (35x) tomato pomace. The Agency no
longer  considers tomato pomace to be a significant animal feed.  Therefore, no feed additive
regulations are required.

       DCPA residues also concentrate in succulent bean cannery waste (2x) and in dry potato
peel (1.9x).  The Agency no longer considers bean cannery waste a processed commodity; and
presently uses only wet potato peel residue levels to set tolerances on potato waste.  Therefore,
no feed additive tolerances are necessary for beans and potatoes.

Magnitude of the Residue in Meat, Milk, Poultry, and Eggs

       There are no established tolerances for DCPA residues in eggs, milk, animal fat, meat, and
meat by-products. The maximum theoretical daily dietary intake of DCPA for cattle is
approximately 10 ppm based on a  dairy cattle diet consisting  of 50% potato waste, 25%
cottonseed, 15% bean seed, and 10% bean forage. In a 1963  cattle feeding study DCPA feeding
levels of 200 and 20 ppm were used. At the 20 ppm feeding level, combined residues of DCPA,
MTP, and TPA were nondetectable in milk and fat. Muscle, liver, and kidney were not analyzed.
These existing cattle feeding studies are of limited usefulness  because edible tissues were not
analyzed. Furthermore, the data for milk and fat are inconsistent with the results of a recent goat
metabolism study, indicating detectable DCPA residues in milk, fat, muscle, liver, and kidney from
                                           21

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a 10 ppm (Ix) dosing level. The goat metabolism study indicates that tolerances are needed for
DCPA and its metabolites in meat and milk. Therefore, a new cattle feeding study is needed to
determine the appropriate tolerance levels.  Until the new feeding studies are received, the data
from the 1994 goat metabolism study will be used to estimate residues in meat and milk for
purposes of a human dietary risk assessment.

       Poultry feeding studies were conducted in 1973.  Residues of DCPA, MTP and TPA were
non-detectable in edible tissues from hens fed 4 ppm DCPA for 30 days. At the lOx feeding level
(40 ppm) detectable combined residues were observed only in fat at 0.14 ppm.  Combined
residues in egg yolk from the 4 ppm feeding level were 0.07 ppm on day 21 of the study.  At the
lOx feeding level, 21-day egg yolk residues were 0.26 ppm.  The existing data indicate that a
tolerance for combined residues of DCPA, MTP, and TPA in eggs may be needed. Final
judgment as to the adequacy of the existing hen feeding studies and the need for poultry
tolerances will be determined  after the requested poultry metabolism studies have been evaluated.
In the interim, data from the existing poultry feeding studies will be used to estimate residues in
poultry tissues and eggs for purposes of a human dietary risk assessment.

Confined/Field Rotational Crops

       The confined rotational crop study is adequate. Carrots, lettuce, and green beans were
grown in a greenhouse in soil  treated 11 weeks previously with 14C-DCPA.  The identified 14C-
residues were DCPA, TPA, and MTP, with TPA being the predominant residue.

       The limited field rotational crops  studies used plant-back intervals (PBIs) of 29 to 365
days in soil that had been treated at 10.5 Ibs a.i./acre (0.5x the maximum seasonal rate). Residues
of DCPA, MTP, and TPA were detected in carrot roots and tops, corn fodder and silage, oat
forage, and turnip tops planted at a 1 year FBI. These data indicated that inadvertent residue
tolerance and label amendments imposing crop rotational restrictions for DCPA treated fields will
be necessary. Any crop(s) without a registered use for which an inadvertent tolerance is desired
will require field trial data to determine the appropriate tolerance level(s) for rotated crop
commodities.  The registrant must clarify their intentions as to the specific  crop(s) to be allowed
in rotation with the crops on the label(s) and the desired plant-back intervals.

Anticipated Residues

       Table 3 lists the anticipated residues (ARs) for calculating carcinogenic and chronic, non-
carcinogenic risk of DCPA and HCB for  all raw agricultural commodities (RACs) in which DCPA
tolerances have been established.  The Dietary Risk Evaluation System (ORES) will incorporate
these residue  values, taking into account the percentage of the entire crop which is likely  to be
treated with DCPA. ARs were also calculated for animal commodities from uses of DCPA on
RACs which  are eventually fed to animals used for human consumption. The residues of concern
in both plant and animal commodities are DCPA, its metabolites (MTP and TPA), and its
contaminant,  HCB.  Residue data used to calculate anticipated residues for the RACs were
                                           22

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obtained from registrant field trials and processing studies, from monitoring data supplied by the
U.S. Food and Drug Administration, and from survey data supplied by the U.S. Department of
Agriculture.

       Tolerances are presently established for corn, soybeans, rutabagas, and lettuce although
there are no federally registered uses of DCPA on these crops. These tolerances are being
retained to cover any inadvertent residues from rotation of crops to previously DCPA-treated
fields.  As previously stated, rotational crop studies indicate the need for inadvertent residue
tolerances and label amendments imposing crop rotation restrictions for DCPA-treated fields.
The established tolerances on corn,  soybeans, rutabagas and lettuce will need to be reassessed.

       Since the Agency lacks the needed data (from additional field rotational crop studies),
ARs for corn, soybeans, and rutabagas were based on the established tolerances. Any inadvertent
residues occurring on these crops should be considerably lower.  For lettuce it was possible to
refine the estimate of anticipated inadvertent residues by combining data from field trials and
monitoring studies.

       For calculating meat, milk, poultry and eggs, the livestock diet was assumed to contain the
maximum levels of ARs of DCPA and HCB.  Cottonseed commodities were chosen since it is the
most likely of the livestock feeds to be used in a typical national livestock diet over an extended
period of time.  The transfer of DCPA to milk and livestock commodities was calculated using the
total radioactive residues (TRRs) detected in a goat metabolism study. HCB transfer to meat,
milk, poultry, and eggs was calculated using a transfer factor obtained from feeding studies of
PCNB (pentachloronitrobenzene) contaminated with HCB. It was assumed that the transfer of
HCB to animal tissues from feed would be independent of any other chemical(s) present in the
feed.

Table 3: Anticipated Residues of DCPA, its Metabolites, and HCB from Use of DCPA on
Food/Feed Crops3
Food Name
Strawberries
Horseradish
Paprika
Cantaloupes-unspecified
Cantaloupes-pulp
Honeydew melons
Watermelon
Cucumbers
Squash-summer
Squash-winter
Eggplant
Peppers-sweet, garden
Residue Data Source
DCPA
Field Trials
Field Trials
Field Trials
Field Trials

Field Trials
Field Trials
Field Trials
Field Trials
Field Trials
Field Trials
Field Trials
HCB
0.3% a.i.
0.3% a.i.
0.3% a.i.
0.3% a.i.

0.3% a.i.
0.3% a.i.
0.3% a.i.
0.3% a.i.
0.3% a.i.
0.3% a.i.
0.3% a.i.
Anticipated Residues (ppm)
DCPA, MTP
&TPA
0.22
0.81
0.17
0.25

0.08
0.20
0.08
0.16
0.16
0.11
0.17
HCB
0.00066
0.00243
0.00051
0.00075

0.00024
0.0006
0.00024
0.00048
0.00025
0.00033
0.00051
                                           23

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Food Name
Peppers-other
Chili peppers
Pimentos
Tomatoes-whole
Tomatoes-juice
Tomatoes-puree
Tomatoes-paste
Tomatoes-catsup
Broccoli
Brussels Sprouts
Cauliflower
Cabbage-green/red
Cabbage-Chinese/celery, inc.
Bok Choy
Collards
Kale
Kohlrabi
Lettuce-leafy varietiesa'b
Lettuce-unspecifieda'b
Mustard Greens3
Turnip-tops
Cress, Upland
Lettuce-head varieties3'1"
Garlic
Leeks
Onions-dry bulb (cipollini)
Onions-dehydrated or dried
Potatoes-whole
Potatoes-unspecified
Potatoes-peeled
Potatoes-dry
Potatoes-peel
Radishes-roots
Radishes-tops
Residue Data Source
DCPA
Field Trials
Field Trials
Field Trials
Field Trials
Processing
Study
Processing
Study
Processing
Study
Processing
Study
Field Trial
Field Trials
Brussels
Sprouts Data
Field Trials

Kale Data
Field Trials
Brussels
Sprouts Data
FDA
Monitoring
FDA
Monitoring
Field Trials
Field Trials
Field Trials
FDA
Monitoring
Onion Data
Field Trials
Field Trials

Field Trials

Field Trials


Field Trials
Field Trials
HCB
0.3% a.i.
0.3% a.i.
0.3% a.i.
0.3% a.i.




0.3% a.i.
0.3% a.i.
Brussels
Sprouts Data
0.3% a.i.

0.3% a.i.
0.3% a.i.
Brussels
Sprouts Data
PDF Survey
PDF Survey
FDA
Monitoring
0.3% a.i.
0.3% a.i.
PDF Survey
Onion Data
0.3% a.i.
0.3% a.i.

0.3% a.i.

0.3 % a.i.


0.3% a.i.
0.3% a.i.
Anticipated Residues (ppm)
DCPA, MTP
&TPA
0.17
0.17
0.17
0.11
0.11
0.15
0.396
0.12
0.10
0.04
0.04
0.35

0.5
0.5
0.04
0.65
0.65
1
0.775
0.36
0.65
0.02
0.57
0.02

0.25

0.25


0.07
9.12
HCB
0.00051
0.00051
0.00051
0.00033
0.00033
0.00045
0.00119
0.00036
0.0003
0.00012
0.00012
0.00105

0.0015
0.0015
0.00012
0.002
0.002
0.000625
0.002325
0.0011
0.002
0.000063
0.00103
0.000063

0.00075

0.00075


0.00021
0.027
24

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Food Name
Rutabagas-roots'5
Shallots
Sweet potatoes (including
Yams)
Turnip-roots
Corn, popb
Corn, sweetb
Corn, grain-endospermb
Corn, grain-branb
Corn, sugarb
Corn, grain-oil11
Beans-succulent, lima
Beans-succulent, green
Beans-succulent, other
Beans-succulent, yellow, wax
Beans-succulent, broadbeans
(immat. seed)
Beans-dry
Mung Beans (sprouts)
Black-eyed Peas dry
Onions-green
Cottonseed-oil
Cottonseed-meal
Soybeans-mature, seeds dryb
Soybeans-oil15
Soybeans-unspecified15
Soybeans-flour, full fatb
Soybeans-flour, low fatb
Soybeans-flour, defatted11
Milk-non-fat solids
Milk-fat solids
Milk sugar (lactose)
Beef, Goat, Sheep, Pork - meat
byproducts
Beef, Goat, Sheep, Pork -
(organ meats) - other
Beef- dried
Beef,Goat,Sheep,Pork(boneless)
-fat
Beef, Goat, Sheep, Pork (organ
meats) - kidney
Residue Data Source
DCPA
Tolerance
Field Trials
Field Trials
Field Trials
Tolerance





Field Trials




Field Trials

Field Trials
Field Trials
Field Trial
Tolerance





Goat
Metabolism
Study
Goat
Metabolism
Study
HCB
0.3%
Tolerance
0.3% a.i.
0.3% a.i.
0.3% a.i.
0.3%
Tolerance





0.3% a.i.




0.3% a.i.

0.3% a.i.
0.3% a.i.
0.3% a.i.
0.3%
Tolerance





Cattle
Feeding
Study
Cattle
Feeding
Study
Anticipated Residues (ppm)
DCPA, MTP
&TPA
2
0.57
0.64
0.275
0.05





0.26




0.09

0.36
0.57
0.02
2





0.0000006
0.000001 lc
0.0000017
0.0000006
0.0000011
0.0000057
HCB
0.006
0.00103
0.00192
0.000825
0.00015





0.00078




0.00027

0.00108
0.00103
0.00006
0.006





0.0000001
0.0000068 c
0.0000003
0.0000005
0.0000068
0.0000003
25

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Food Name
Beef, Goat, Sheep, Pork (organ
meats) - liver
Beef, Goat, Sheep, Pork
(boneless)- lean (w/o removable
fat)
Turkey, Other Poultry, Chicken
- byproducts
Turkey, Other Poultry, Chicken
- giblets (liver)
Turkey, Chicken - flesh (w/o
skin, w/o bones)
Turkey, Other Poultry, Chicken
-flesh (+skin,w/o bones)
Turkey -unspecified
Eggs-whole (36.55 yolk)
Eggs-white only
Eggs-yolk only
Residue Data Source
DCPA

Poultry
Feeding
Study
HCB

Poultry
Feeding
Study
Anticipated Residues (ppm)
DCPA, MTP
&TPA
0.0000017
0.0000006
0.0000230 c
0.0000009
0.0000009
0.0000230 c
0.0000230 c
0.0000011
0.0000009
0.0000138
HCB
0.0000003
0.0000005
0.0000084 c
0.0000028
0.0000002
0.0000084 c
0.0000084 c
0.0000001
0.0000000
0.0000028
a The residue values for these crops are based on FDA monitoring or USDA survey data, and were not adjusted for
% crop treated in the DRES analysis.

b There are no established uses on this crop; however, the registrant has expressed an interest in retaining a
tolerance to cover potential residues from rotation of this crop into fields that have been previously treated with
DCPA. The tolerance on this crop, and anticipated residues, will be reassessed in conjunction with review of
rotational crop studies and registrant proposals for inadvertent residue tolerance and rotational crop restrictions on
DCPA labels.

0 The anticipated residue on this food is assumed to be the same as for fat.

                      b.      Drinking Water Exposure

        The available information is inadequate to assess exposure to DCPA and its metabolites
on a national level. However, sufficient information is available on local detections of DCPA and
its metabolites which can be used to  extrapolate the following conclusions/generalizations. Note
that HCB and 2,3,7,8-TCDD were not considered in the drinking water assessment.  Sufficient
information on their detections was not available.

Ground Water

National Survey of Pesticides in Drinking Water Wells

       The Agency's National Survey of Pesticides in Drinking Water Wells (NPS) detected a
DCPA metabolite, TPA, in the ground water in 25 states. TPA was the most frequently detected
pesticide residue (49 detections in 1347 wells). The limit of detection (LOD) for TPA in the NPS
                                              26

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was 0.10 ug/L. The highest concentration of detected TPA was 7.20 ug/L.  DCPA was not
detected in the NFS; the LOD for DCPA was 0.06 ug/L.

State Studies

       Ground water monitoring studies for pesticides have been conducted in a number of states
and regions.  Several of these monitoring studies have also detected DCPA and/or its metabolites
in ground water.

       The occurrence of DCPA residues have been confirmed in groundwater in Suffolk
County, New York, by pesticide sampling programs conducted by the Suffolk County
Department of Health Services.  Water samples were analyzed for DCPA, its metabolites TPA
and MTP, and the manufacturing impurity HCB. DCPA degradates were detected in 56 of 213
samples (26%) analyzed from shallow private and public water supply wells. HCB was not
detected in any samples.  It should be noted that only the number of samples, including
resampling, were given and not the actual number of wells. Therefore, the number of wells for
this report was assumed to be equal to the number of samples. The average concentration of the
positive samples was  109 ug/L with the highest concentration detected being 1039 ug/L. The
limit of detection (LOD)  for the Suffolk County sampling program is 0.3 ug/L.

       This information was used to perform an  exposure assessment of groundwater in Suffolk
County. Using the average concentration of the detected samples (109 ug/L) and one-half of the
LOD (0.15 ug/L) for the non-detected samples, an average of all 213 samples can be calculated,
which is 28.768 ug/L.

Registrant Studies

       As required by the Agency, the registrant is currently performing two small-scale
groundwater monitoring  studies to  determine the potential for DCPA residues to leach to
groundwater from current uses.  Both studies (onions in California and turf in New York) began
in 1992.  The Agency received preliminary data in support of the registrant's request to terminate
the studies. To date, the  studies have been performed over a time-period of 17 months in New
York, and 22 months in California. Since these time periods are greater than a year, the Agency
used these data in assessing drinking water risk in this RED.  However, the delivery date for the
final report is July 1996.  At that time the Agency will revise its drinking water risk assessment.

       The ground water was analyzed for DCPA, TPA, and MTP. More data points were
collected in the New York study. The LOD was 0.1 ug/L; therefore, one-half of the LOD (0.05
ug/L) was used for non-detects.  When analyses were performed in duplicate, the two results
were averaged to obtain a single result.  The data did not indicate which wells were in a cluster or
the screening depth.  Therefore, the average concentrations for DCPA, for MTP, and for TPA
were calculated for each well. These averages were summed to obtain the total residues in each
well without regard for depth.
                                          27

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       At the New York site, a total of 29.4 Ibs a.i./acre was applied in three applications.  The
data are from nine wells (three clusters with three wells each). This information can be used to
perform an exposure assessment of groundwater at the turf site in New York.  The average of the
sums of DCPA, TPA, and MTP over the 17 months was 50.36 ug/L.

       At the California site, a total of 18.2 Ibs a.i./acre was applied in two applications.
However, the results of analyses from only eight wells were reported, although it was stated that
cluster wells were also used. This information can be used to perform an exposure assessment of
groundwater at the onion site in California. The average of the sums of DCPA, TPA, and MTP
over the 22 months was 12.75  ug/L.

Surface Water

       The available data on concentrations of DCPA in surface waters is limited. The U.S.
Geological Survey collected samples from two creeks in Colorado from April, 1993 to April,
1994.   Samples were collected once a month from October through March, and two or more
times per month during other months.  The reported LODs for DCPA varied from 0.002 to 0.005
ug/L.  One-half of the LOD was used for non-detects (varying 0.001 to 0.0025 ug/L.)

       One of the creeks, Lonetree Creek, drained an agricultural watershed.  The time-weighted
mean for DCPA concentration was 5.95 ug/L. The second creek, Cherry Creek, drained an urban
watershed. The time-weighted mean for DCPA concentration was 0.0078 ug/L.

Exposure Estimates

       For drinking water, exposure is calculated using the following formula:

       #  exposure = (ppb DCPA and/or metabolites in the water consumed) (10"6)(22.6)

       Water consumption is defined as all water obtained from the household tap that is
consumed either directly as a beverage or is used to prepare foods (mixing water with a can of
soup) and beverages (diluting frozen juice concentrate).  Two generally accepted default values
for water consumption are 2 liters (28.57 g/kg/day based on a 70 kg adult male) or 1.5 liters
(21.42  g/kg day based on a 70  kg adult male).  The 22.6 g/kg/day used in this calculation was
derived using water consumption values obtained from USDA's 1977-1978 Nationwide Food
Consumption Survey. It should be noted that the individuals  participating in the survey self-
reported their body weights which were then used in  calculating the 22.6 value.

       The other assumption used is that water from the same source containing the same
contaminant level  is consumed throughout a 70-year lifetime.  The second of these assumptions is
extremely conservative, since most of the U.S. population moves at  some time during their life
and does not live in the same area, drinking from the same water source for a 70-year lifetime. It
                                           28

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could be considered as either an over-estimation or an under-estimation of risk depending on the
contaminant levels in the other sources of drinking water.

Groundwater

       State Studies (Suffolk County, NY)

       Exposure = (28.768) (10-6) (22.6)

       Registrant Studies

       New York turf

       Exposure = (50.36) (10-6) (22.6)

       California onions

       Exposure = (12.75) (10-6) (22.6)

Surface Water

       Lonetree Creek

       Exposure = (5.95) (10-6) (22.6)

       Cherry Creek

       Exposure = (0.0078) (10-6) (22.6)

                     c.      Occupational and Residential Exposure

Use Patterns

       DCPA is applied with tractor mounted boom sprayers, tractor drawn granular spreaders,
shaker cans, residential push-type and whirly-bird spreaders, and by aerial application.

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

       DCPA contains small amounts of several contaminants, HCB and dioxin/furans
(represented as 2,3,7,8-TCDD). The Registration Standard required foliar dissipation data


                                            29

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(turfgrass) for both HCB and 2,3,7,8-TCDD.  A foliar dissipation study was submitted for HCB,
but not for 2,3,7,8-TCDD, with the registrant stating that 2,3,7,8-TCDD data could not be
provided due to the unavailability of analytical methodology to detect the theoretical levels of
2,3,7,8-TCDD.  The residues of 2,3,7,8-TCDD which would theoretically be present as a result of
an application of DCPA at the label rate of 10.5 Ibs a.i./acre was estimated as 5.3 x 10"13 g/ft2 or
5.74 x 10"10 ug/cm2. The Agency agreed that this residue level was much lower than  1991
analytical methods could detect; therefore, assays for 2,3,7,8-TCDD were not subsequently
required.

       Both occupational and residential exposures to DCPA and its contaminant HCB are
estimated in the following assessment.  However, exposure to 2,3,7,8-TCDD is not included.
"Worst case" exposure values for 2,3,7,8-TCDD were calculated using application rates and the
percentage of contamination only, since there are no foliar dissipation or dermal absorption data
on 2,3,7,8-TCDD.  These exposure values (shown in the risk assessment section) were used to
produce rough estimates of risk.

       Mixer/Loader/Applicator (M/L/A) exposure monitoring studies were not required in the
June, 1988 Registration Standard. However, a subsequent Data-Call-in (dated 9/25/92), did
include requirements for M/L/A exposure monitoring studies to support the application of DCPA
granulars to turf and DCPA wettable powders to various crops and turf. Protocols were
submitted and reviewed for the M/L/A studies.  At that time, the Agency determined that these
studies were no longer required based on the availability of surrogate data in the Pesticide
Handlers Exposure Database (PHED) Version 1.1 which was used in this assessment to estimate
M/L/A exposures resulting from registered uses of DCPA.  However, based on this exposure
assessment which used PHED surrogate data, confirmatory data are now required to address the
Agency's concerns for two of the exposure scenarios.

Mixer/Loader/Applicator Exposure Scenarios

       Based on the use-patterns and potential exposures previously described, ten major
exposure scenarios were identified for DCPA: (1) mixing/loading the liquid flowable formulation,
(la) mixing/loading the wettable powder formulations, (2) mixing and loading granulars for
ground applications, (3a) aerial application of liquid formulation, (3b) aerial application of
granulars, (4) applying the liquid and wettable powders with groundboom equipment, (5) applying
with a granular spreader cultivator mounted, (6a) flagger exposure to liquids, (6b) flagger
exposure to granulars, (7) applying with a shaker can, (8) applying with a backpack, (9)
mixing/loading and applying with a residential push-type spreader, and (10) mixing/loading and
applying with a whirly-bird spreader. Table 4 summarizes the parameters specific to each
exposure scenario, including a description of the actual clothing and equipment worn by all
persons being monitored in the exposure studies. Each exposure assessment in Table 5, DCPA
Exposure Values, or Table 6, HCB Exposure Values, is based on workers wearing long pants,
long-sleeve shirts, and no gloves, with the exception of the exposure assessment for
                                           30

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mixing/loading liquids, wettable powder formulations, shaker cans, and backbacks (scenarios I, la,
VII, and VIII), which includes wearing gloves in addition to long pants and long-sleeve shirts.
                                            31

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Table 4: Exposure Scenarios
Exposure Scenario
(Seen. #)
Data
Source
Clothing Scenario"
Equipment
Daily Max
Treated11 (acres)
Comments0
Mixer/Loader Exposure
Liquids (I)
Wettable Powder (la)
Granular (II)
PHED
VI. 1
PHED
VI. 1
PHED
VI. 1
Long pants, long
sleeves, chemical
resistant gloves
Long pants, long
sleeves, chemical
resistant gloves
Long pants, long
sleeves, no gloves
Open mixing for
groundboom and
aerial applications
Wettable powder
packaged in open
bags for groundboom
and aerial
applications
Open mixing for
cultivated spreader
and aerial
applications
80 acres
groundboom,
and 3 50 acres
aerial
80 acres
groundboom,
and 3 50 acres
aerial
80 acres
spreader, and
350 acres aerial
Acceptable grades;
Dermal = 59 to 122 replicates;
Inhalation = 85 replicates;
High confidence in dermal and inhalation data.
Dermal and inhalation grades A,B,C;
Dermal = 22 to 45 replicates;
Inhalation = 44 replicates;
Medium confidence in dermal and inhalation
data
All grades for dermal;
Acceptable grades for inhalation;
Dermal = 10 to 78 replicates
Inhalation = 58 replicates;
Low confidence in dermal data and high
confidence for inhalation data
Applicator Exposure
Aerial (liquids) (Ilia)
Aerial (granulars)
(nib)
Groundboom (IV)
Granular Spreader
Cultivator Mounted
(V)
PHED
VI. 1
PHED
VI. 1
PHED
VI. 1
PHED
VI. 1
Long pants, long
sleeves, no gloves
Long pants, long
sleeves, no gloves
Long pants, long
sleeves, no gloves
Long pants, long
sleeves, no gloves
Open cockpit
Open cockpit
Open Cab
Cultivator mounted
or pull-behind; Ag or
Turf; closed cab
350 acres
350 acres
80 acres
80 acres
Dermal grades A, B, C; inhalation all grades;
Dermal = 1 to 17 replicates; Inhalation = 17
replicates; Low confidence in dermal and
inhalation data
Dermal and inhalation all grades; Dermal = 4
to 13 replicates; inhalation = 13 replicates;
Low confidence in dermal and inhalation data
Acceptable grades;
Dermal = 23 to 33 replicates;
Inhalation = 22 replicates;
High confidence in dermal and inhalation data
Acceptable grades; Dermal = 24 to 25
replicates; Inhalation = 25 replicates; High
confidence in dermal and inhalation data
Flagger Exposure
Liquids (Via)
Granulars (VIb)
PHED
VI. 1
PHED
VI. 1
Long pants, long
sleeves, no gloves
Long pants, long
sleeves, no gloves
Unknown
Unknown
350 acres
350 acres
Acceptable grades; Dermal = 16 to 18
replicates; Inhalation = 18 replicates; High
confidence in dermal and inhalation data
Dermal and inhalation all grades; Dermal = 4
to 20 replicates; inhalation = 4 replicates; Low
confidence in dermal and inhalation data
Mixer/Loader/Applicator Exposure
Shaker Can (VII)
Backpack (VIII)
PHED
VI. 1
PHED
VI. 1
Long pants, long
sleeves, chemical
resistant gloves
Long pants, long
sleeves, chemical
resistant gloves
Granulars dispersed
by hand (worst case
surrogate)
Backpack sprayer
1,000ft2
residential,
5,000ft2
commercial
1 acre
residential, 5
acres commercial
Dermal and inhalation grades A, B, C; Dermal
= 15 to 16 replicates; inhalation = 16
replicates; Medium confidence in dermal and
inhalation data
Dermal grades A, B, C; acceptable inhalation
grades; Dermal = 9 to 11 reps.; inhalation = 11
replicates; Low confidence in dermal and
inhalation data
                                           32

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Exposure Scenario
(Seen. #)
Residential Push-type
Spreader (IX)
Whirly-bird spreader
(X)
Data
Source
PHED
VI. 1
PHED
VI. 1
Clothing Scenario"
Long pants, long
sleeves, no gloves
Long pants, long
sleeves, no gloves
Equipment
Rotary spreader
Belly grinder
Daily Max
Treated11 (acres)
1 acre
residential, 5
acres commercial
1 acre
Comments0
Dermal grade C; inhalation grade B;
Dermal = 15 (no head data) replicates;
Inhalation =15 replicates;
Medium confidence in dermal data and high
confidence for inhalation data
Dermal grades = 9A and 36C;
Inhalation grades = acceptable;
Dermal = 23 to 45 replicates;
Inhalation = 40 replicates;
Medium confidence in data
a Clothing scenario represents actual not simulated, exposure data.

b The value represents the maximum area or the maximum volume of spray solution which can be used in an 8 hour work
day to complete treatments for each exposure scenario of concern.

0 These grades are based on Quality Assurance/Quality Control data provided as part of the exposure studies. "Acceptable
grades" for dermal and inhalation studies are A and B as defined in Subdivision U Guidelines.  All grades that do not meet
the guidelines are listed separately. A replicate refers to data acquired during one complete work cycle. High confidence in
data indicates that there were at least 15 replicates of Grades A and B data.  Medium confidence in data indicates that there
were at least 15 replicates, but that some of the data did not meet the criteria for Grades A and B data.  Low confidence in
data indicates that there were less than 15 replicates of data.
                                                       33

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Table 5: DCPA Occupational and Residential Exposure Values
Exposure
Scenario
(Seen. #)
Dermal
Exposure31
(mg/lb ai)
Absorbed
Dermal
Exposure*2
(mg/lb ai)
Inhalation
Exposure15
(mg/lb ai)
Total
Absorbed
Exposure
(mg/lb ai)
Label
Application
Ratec (Ib
ai/acre)
Daily Max.
Treated*
(acres)
Daily Dosee
(mg/kg/day)
LADDf (mg/kg/day)
Private
Appl.*
Commercial
Appl.h
Mixer/Loader Exposure
Liquids (I)
Wettable Powder
(la)
Granulars (II)
0.04
0.2
0.01
0.0060
0.030
0.0015
0.0012
0.0434
0.0017
0.0072
0.073
0.0032
10
10
10
80
350
80
350
80
350
0.082
0.36
0.83
3.65
0.037
0.16
0.00011
NA
0.0011
NA
0.000051
NA
0.0011
0.0049
0.011
0.05
0.00051
0.0022
Applicator Exposure
Aerial (liquids)
(Ilia)
Aerial (granulars)
(nib)
Groundboom (IV)
Granular
Spreader
Cultivator
Mounted (V)
0.05
0.002
0.01
0.002
0.00745
0.00030
0.0015
0.00030
0.0003
0.0013
0.0007
0.0001
0.0078
0.0016
0.0022
0.00040
10
10
10
10
350
350
80
80
0.39
0.08
0.025
0.0046
NA
NA
0.00003
6.3 x 10'6
0.0053
0.0011
0.0003
6.3 x 10'5
Flagger Exposure
Liquids (Via)
Granulars (VIb)
0.01
0.003
0.0015
0.00045
0.0003
0.0001
0.0018
0.00055
10
10
350
350
0.09
0.028
NA
NA
0.0012
0.00038
Mixer/Loader/Applicator Exposure
Shaker Can (VII)
Backpack (VIII)
71.3
2.5
10.6
0.37
0.468
0.03
11.1
0.40
10
10
1,000ft2
5,000ft2
1,5'
0.036
0.18
0.057, 0.291
0.00005
0.00025
0.00008
5 x 10-4
0.0025
0.004
                                                         34

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Exposure
Scenario
(Seen. #)
Residential Push-
type Spreader
(IX)
Whirly-bird
Spreader (X)
Dermal
Exposure31
(mg/lb ai)
2.9
10.4
Absorbed
Dermal
Exposure*2
(mg/lb ai)
0.43
1.55
Inhalation
Exposure15
(mg/lb ai)
0.0063
0.0618
Total
Absorbed
Exposure
(mg/lb ai)
0.44
1.61
Label
Application
Ratec (Ib
ai/acre)
10
10
Daily Max.
Treated*
(acres)
1,5'
1
Daily Dosee
(mg/kg/day)
0.063,0.31'
0.23
LADDf (mg/kg/day)
Private
Appl.g
0.00009
0.00032
Commercial
Appl.h
0.0042
NA
al Dermal unit exposures are reported as the best fit mean to simulate workers wearing long pants, long-sleeve shirts, and no gloves except for
mixer/loaders/liquid/wettable powder and shaker can and backpack applicators.  The liquid and wettable powder mixer/loaders and shaker can and backpack applicators
simulate workers wearing long pants, long sleeve shirts, and chemical resistant gloves. The best fit mean is the composite total dermal exposure based on using the
geometric mean for lognormal distributed data, arithmetic mean for normal distributed data, and the median for all other distribution types. Protection factors were not
used to calculate dermal unit exposure values because sufficient data are available for PPE in these scenarios.
a2 Dermal exposure was multiplied by the dermal absorption factor (which for DCPA is 14.9%) to obtain an exposure consistent with the amount of DCPA absorbed,
not the amount of DCPA in contact with the skin.
b Inhalation Exposure Values are reported as geometric means (lognormal distributions). No adjustment has been made to simulate workers wearing dust/mist
respirators.
c Dacthal W75 Label, EPA Reg # 50534-1; Dacthal Flowable Herbicide Label, EPA Reg # 50534-10; Dacthal G-2.5 Label, EPA Reg # 50534-17; Dacthal G-5 Label,
EPA Reg # 50534-3.  The 10 Ib ai/acre application rate represents the high rate that is used on clay loams having 3-5% organic matter.  The rate of 15 Ib ai/acre was not
used in the assessment since this rate is for turfgrass.  The 15 Ib rate requires 40  to 100 gallons of water per acre for grass which is unlikely for aerial applications.
d Values represent the maximum area or the maximum volume of spray solution which can be used in a single day to complete treatments for each exposure scenario of
concern.
e Daily Dose (mg/kg/day) = Total Absorbed Exposure (mg/lb ai) * Max. Appl. Rate (Ib ai/cvcle) * Max. Treated
                                                       70kg
f Lifetime Average Daily Dose (LADD)  (mg/kg/day) = Daily Dose (mg/kg/day)  * (Work Days Per Yr/365 Days Per Year) * (35 Yrs/70 Yrs).
g Private applicator is defined as a short term exposed individual (i.e., one day).
h Commercial applicator is defined as an intermediately exposed individual (i.e.  10 days).
1  Homeowner treats 1 acre; commercial home-lawn applicator can treat 5 acres/day.
                                                                          35

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Table 6: HCB Occupational and Residential Ex|
Exposure Scenario
(Seen. #)
Dermal
Exposure"1
(mg/lb ai)
Absorbed Dermal
Exposure"2
(mg/lb ai)
posure Values
Inhalation
Exposure15
(mg/lb ai)
Total Absorbed
Exposure
(mg/lb ai)
Label
Application
Rate0 (Ib ai/acre)
Daily Max.
Treatedd
(acres)
Daily Dosee
(mg/kg/day)
LADDf (mg/kg/day)
Private
Appl.*
Commercial
Appl.h
Mixer/Loader Exposure
Liquids (I)
Wettable Powder (la)
Granulars (II)
0.04
0.2
0.01
0.011
0.053
0.0026
0.0012
0.0434
0.0017
0.012
0.096
0.0043
0.03
0.03
0.03
80
350
80
350
80
350
0.00041
0.0018
0.0033
0.014
0.00015
0.00065
5.6 x 10'7
NA
4.5 x 10'6
NA
2.1xlO'7
NA
5.6 x 10'6
2.5 x 10'5
4.5 x 10'5
1.9 x 10'4
2.1X10'6
8.9 x 10'6
Applicator Exposure
Aerial (liquids) (Ilia)
Aerial (granulars) (Illb)
Groundboom (IV)
Granular Spreader
Cultivator Mounted (V)
0.05
0.002
0.01
0.002
0.013
0.00053
0.0026
0.00053
0.0003
0.0013
0.0007
0.0001
0.013
0.0018
0.0033
0.00063
0.03
0.03
0.03
0.03
350
350
80
80
0.0020
0.00027
0.00011
2.2 x 10'5
NA
NA
1.5 x 10'7
3.0 x 10'8
2.7 x 10'5
3.7 x 10'6
1.5 x 10'6
3.0 x 10'7
Flagger Exposure
Liquids (Via)
Granulars (VIb)
0.01
0.003
0.0026
0.00079
0.0003
0.0001
0.0029
0.00089
0.03
0.03
350
350
0.00044
0.00013
NA
NA
6.0 x 10'6
1.8 x 10'6
Mixer/Loader/Applicator Exposure
Shaker Can (VII)
Backpack (VIII)
Residential Push-type
Spreader (IX)
Whirly-bird Spreader
(X)
71.3
2.5
2.9
10.4
18.9
0.66
0.77
2.75
0.468
0.03
0.0063
0.0618
19.4
0.69
0.78
2.81
0.03
0.03
0.03
0.03
1,000ft2
5,000ft2
1,5'
1,5'
1
0.00019
0.00096
0.00030,
0.00151
0.00033,
0.00171
0.0012
2.6 x 10'7
1.4 x 10'6
4.1xlO'7
4.5 x 10'7
1.6 x 10'6
2.6 x 10'5
1.4 x 10'5
2.1xlO'5
2.3 x 10'5
NA
36

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al Dermal unit exposures are reported as the best fit mean to simulate workers wearing long pants, long-sleeve shirts, and no gloves except for
mixer/loaders/liquids/wettable powder and shaker can and backpack applicators. The liquid and wettable powder mixer/loaders and shaker can and backpack
applicators simulate workers wearing long pants, long sleeve shirts, and chemical resistant gloves. The best fit mean is the composite total dermal exposure based on
using the geometric mean for lognormal distributed data, arithmetic mean for normal distributed data, and the median for all other distribution types. Protection factors
were not used to calculate dermal unit exposure values because sufficient data are available for PPE in these scenarios.
a2 Dermal exposure was multiplied by the dermal absorption factor (which for HCB is 26.46%) to obtain an exposure consistent with the amount of HCB absorbed, not
the amount of HCB in contact with the skin.
b Inhalation Exposure Values  are reported as geometric means (lognormal distributions).  No adjustment has been made to simulate workers wearing dust/mist
respirators.
0 The label application rate for HCB is 0.3 percent of the label application rate of DCPA which is taken from the Dacthal W75 Label, EPA Reg # 50534-1; Dacthal
Flowable Herbicide Label, EPA Reg # 50534-10; Dacthal G-2.5 Label, EPA Reg # 50534-17; Dacthal G-5 Label, EPA Reg # 50534-3.  The 10 Ib ai/acre application
rate represents the high rate  that is used on clay loams having 3-5% organic matter. The rate of 15 Ib ai/acre was not used in the assessment since this rate is for
turfgrass.  The 15 Ib rate requires 40 to 100 gallons of water per acre for grass which is unlikely for aerial applications.
d Values represent the maximum area or the maximum volume of spray solution which can be used in a single day to complete treatments for each exposure scenario of
concern.
e Daily Dose (mg/kg/day) = Total Exposure (mg/lb ai) * Max. Appl. Rate (Ib ai/cvcle) * Max. Treated
                                                       70kg
f Lifetime Average Daily Dose (LADD) (mg/kg/day) = Daily Dose (mg/kg/day) * (Work Days Per Yr/365 Days Per Year) * (35 Yrs/70 Yrs)
g Private applicator is defined as a short term exposed individual (i.e., one day)
h Commercial applicator is defined  as an intermediate exposed individual (i.e. 10 days)
1 Homeowner treats 1 acre; commercial home-lawn applicator can treat 5 acres/day.
                                                                          37

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Post-application Exposure

       There is a potential for exposure to persons entering a DCPA treated area after application
is complete.  One concern is potential post-application exposure arising from re-entering a treated
agricultural crop area.  Based on label use information for application of DCPA to agricultural
crops (considering methods and timing of applications), the agricultural use site with the highest
potential for post-application worker exposure is cucumbers. Foliar dissipation data for DCPA
and HCB on  cucumbers and the corresponding worker exposure levels during cucumber
harvesting are summarized in Table 7 below. These calculations incorporated the following
assumptions:  an 8 hour work day; 30 days exposure each year for a total of 35 years over a 70
year lifetime; average body weight is 70 kg.
Table 7:  Foliar Dislodgeable Residues (FDR) of DCPA and HCB on Cucumbers and
Corresponding Worker Reentry Exposure During Cucumber Harvesting
DATa
0
1
2
3
4
5
6
FDR (,ag/cm2)b
DCPA
17.4
15.0
12.9
11.1
9.5
8.2
7.0
HCB
0.025
0.018
0.013
0.010
0.007
0.005
0.004
LADD (mg/kg/day)c
DCPA
0.82
0.70
0.61
0.52
0.45
0.38
0.33
HCB
0.0012
0.0009
0.0006
0.0005
0.0003
0.0002
0.0002
a  DAT = Days After Treatment

b  FDR values were calculated using a regression analysis of dissipation data (MRID 41750105)

0  Lifetime Average Daily Dose (LADD) was calculated using the following equation:

       [FDR Cag/cm2) x (10000 cmVhr) x (1 mg/1000 Mg) x (1/70 Kg) x (8 hrs/day) x (30 days harvesting/365
       days per year) x (35 years harvesting/70 year lifetime)]

where 10,000 cmVhour is a transfer coefficient for citrus harvesters excerpted from Zweig, Leffingwell, Popendorf,
1985.

       Another concern is potential post-application exposure arising from re-entering turf areas following
application of DCPA (e.g., residential lawns and recreational areas).
                                             38

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        Table 8 (Foliar Dislodgeable Residues of DCPA) and Table 9 (Foliar Dislodgeable Residues of HCB)
summarize the residue dissipation data on turf and the corresponding exposure levels for children (ages 2 - 12)
playing on treated lawns.  The data necessary to assess a toddler's (age  1 -2) exposure are not available.
                                                   39

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Table 8:  Foliar (turf) Dislodgeable Residues (FDR) of DCPA, Total (Dermal and Oral)
DCPA Exposure to Children Following Application of Dacthal W-75 to Turfgrass
Sampling Interval
(hr/days post- treatment)
1HAT
2 HAT
6 HAT
1DAT
24 hour TWAd
2 DAT
3 DAT
7 DAT
14 DAT
14 Day TWAe
Average Annual'
Irrigated*
FDR
(ug/cm2)
4.15
1.67
1.48
1.29
1.46
1.33
1.20
0.79
0.67
0.85

Total DCPA Exposure to
Children (mg/kg/day)a-b-c
2.35
0.89
0.84
0.73
0.82
0.75
0.68
0.45
0.38
0.48
0.018
Nonirrigated
FDR
(ug/cm2)
3.64
4.26
4.60
5.56
5.27
4.83
2.16
3.35
2.22
2.94

Total DCPA Exposure to
Children (mg/kg/day)a-b-c
2.06
2.41
2.60
3.14
2.98
2.73
1.22
1.89
1.26
1.66
0.064
   HAT = Hours After Treatment    DAT = Days After Treatment
TWA = Time Weighted Average
* An irrigated lawn was watered 1 hour after the application of DCPA with 1/2 inch of water.

a Total exposures were calculated by adding the results of the equations listed in footnotes b and c below.

b Dermal + oral exposure for children (ages 2-6) was calculated using:  [(FDR jig/cm2) x (0.0314 m2/kg/day) x (10,000 cm2/!
m2)/l,000 Mg/mg] + [(FDR jig/cm2 x 321.5 cm2)/17 kg/day/1,000 Mg/mg].

c Dermal + oral exposure for children (ages 7 - 12) was calculated using: [(FDR jig/cm2) x (0.0221 m2/kg/day) x (10,000 cm2/!
m2)/l,000 Mg/mg] + [(FDR jig/cm2 x 361.5 cm2)/31 kg/day/1,000 Mg/mg].

d The 24 hour TWA was calculated using:
sum (FDR jig/cm21 HAT x 1 hr, FDR jig/cm2 2 HAT x 1 hr, FDR jig/cm2 6 HAT x 4 hrs, FDR jig/cm21 DAT x 18 hrs)/24 hrs.

e The 14 day TWA was calculated using:
sum (FDR jig/cm2 24 hr TWA x 1  day, FDR 2 DAT x 1 day, FDR 3 DAT x 1 day, FDR 7 DAT x 4 days, FDR 14 DAT x 7
days)/14 days.

f The Average Annual was calculated using:
(14 Day TWA x 14 days)/365 days/year.
                                                  40

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Table 9: Foliar (turf) Dislodgeable Residues (FDR) of HCB, Total (Dermal and Oral) HCB
Exposure to children Following Application of Dacthal W-75 to Turfgrass
Sampling Interval
(hr/days post- treatment)
1HAT
2 HAT
6 HAT
1DAT
24 hour TWAd
2 DAT
3 DAT
7 DAT
14 DAT
14 Day TWAe
Average Annual'
Irrigated*
FDR
(ug/cm2)
0.0035
0.0014
0.0013
0.0004
0.0007
0.0042
0.0009
0.0004
0.0000
0.0005
0.0000
Total HCB Exposure to
Children (mg/kg/day)3-^
2.0xlO-3
8 x ID'4
7.3 x ID'4
2.2 x ID'4
4.1 x 10 4
2.4 x ID'3
S.lxlO'4
2.2 x 10-4
0
3.0 x 10 4
1.0 x 10 5
Nonirrigated
FDR (ug/cm2)
0.0091
0.0024
0.0033
0.0028
0.0031
0.0185
0.0044
0.0024
0.0006
0.0028
0.0001
Total HCB Exposure to
Children (mg/kg/day)3-^
5.2 xlO'3
1.4xlO-3
1.9xlO-3
1.6xlO-3
1.8 x 10 3
l.OxlO-2
2.5 xlO'3
1.4xlO-3
3.4 x 10-4
1.6 x 10 3
7.0 x 10 5
HAT = Hours After Treatment
       DAT = Days After Treatment
TWA = Time Weighted Average
* An irrigated lawn was watered 1 hour after the application of DCPA with 1/2 inch of water.

a Total exposures were calculated by adding the results of the equations listed in footnotes b and c below.

b Dermal + oral exposure for children (ages 2-6) was calculated using:
[(FDR jig/cm2) x (0.0314 m2/kg/day) x (10,000 cm2/! m2)/l,000 Mg/mg] + [(FDR jig/cm2 x 321.5 cm2)/17 kg/day/1,000 M

c Dermal + oral exposure for children (ages 7 - 12) was calculated using:
[(FDR ng/cm2) x (0.0221 m2/kg/day) x (10,000 cm2/! m2)/l,000 Mg/mg] + [(FDR jig/cm2 x 361.5 cm2)/31 kg/day/1,000 Mg/mg].

d The 24 hour TWA was calculated using:  sum (FDR |ig/cm21 HAT x 1 hr, FDR |ig/cm2 2 HAT x 1 hr, FDR jig/cm2 6 HAT x
4hrs,
FDR jig/cm21 DAT x 18 hrs)/24 hrs.

e The 14 day TWA was calculated using:  sum (FDR jig/cm2 24 hr TWA x 1 day, FDR 2 DAT x 1 day, FDR 3 DAT x 1 day,
FDR 7 DAT x 4 days, FDR 14 DAT x 7 days)/14 days.

f The Average Annual was calculated using: (14 Day TWA x 14 days)/365 days/year.
               3.
Risk Assessment
                       a.      Dietary Assessment

                              (1)     Acute Dietary Risk

        An acute (one day) dietary risk assessment was not required. The NOELs in the studies
appropriate for selecting this endpoint were too high to be of concern; therefore, an appropriate
toxicological endpoint of concern was not identified.
                                                41

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                           (2)    Chronic Dietary Risk

       To calculate chronic dietary risk, the RfDs (0.01 mg/kg/day for DCPA, 0.0008 mg/kg/day
for HCB, and 0.000001 ug/kg/day for 2,3,7,8-TCDD) are used. It was assumed that DCPA
(including the impurities HCB and TCDD) is uniformly distributed in the commodity supply,
however, it was not assumed that the entire commodity nationwide was treated with DCPA.
Percent crop treated (%CT) information was  obtained from a variety of published and proprietary
sources for 1988 - 1994. This information was presented previously in Table 1.

       Currently, there are no registrations for use on lettuce, soybeans, corn, and rutabagas;
however, these four DCPA tolerances are being retained to cover any inadvertent residues from
rotation of crops in previously DCPA-treated fields.  Percent crop treated for soybeans,
rutabagas, corn, sweet corn, and lettuce were estimated. This was done by estimating the
approximate number of acres that are treated with DCPA in a year (excluding seed crops, golf
courses, and sod farms) which is 440,000 acres.  It was then assumed that each of these 440,000
acres was rotated to soybeans. Since over 61 million acres of soybeans are grown each year, the
resulting %CT is less than  1% (440,000/61,000,000).  If all 440,000 DCPA treated acres are
rotated to sweet corn, then the %CT is 59% 440,000/798,000 total sweet corn acreage). For
corn grain, 1% was used since over 78 million acres of corn are grown each year. For rutabagas,
100% CT was used since the acres grown is less than 440,000. For lettuce, 100% CT as stated in
footnote A of Table 3 was used.

       The Agency was able to establish that there are no reported uses of DCPA for all dry
beans and peas. Therefore, a default value of 1% was used. One hundred percent CT was
assumed if data were not available.

       Two chronic dietary risk assessments (for DCPA and HCB) were performed.  The first
analysis can be considered a worst case analysis.  To calculate a Theoretical Maximum Residue
Contribution (TMRC), tolerance level residues (as specified in Table 30: Tolerance Reassessment
Summary) were used for DCPA.  There are no tolerances for HCB; therefore, "tolerance level"
residues for HCB were calculated by multiplying the DCPA tolerance by 0.3%.

       A pending tolerance for parsley (4 ppm) was included since monitoring data indicate that
DCPA is being found on parsley.  Currently, there are not any registered uses for lettuce,
soybeans, corn and rutabagas; however, these four DCPA tolerances are being retained to cover
any inadvertent residues from rotation of crops in previously DCPA-treated fields. There are no
tolerances for DCPA in meat, milk, poultry, or eggs; however, metabolism and feeding studies
indicate the probable need.  Residue levels were estimated for meat, milk, poultry, or eggs using
total radioactive residues from a goat metabolism study and a poultry feeding study.  These
estimated residues (see Table 3: Anticipated Residues) are the best information available at this
time.
                                           42

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       "Worst Case" Chronic Dietary Exposure from DCPA

       The TMRC was calculated for the U.S. population and 22 subgroups.

       Subgroup                   ExposureCmg/kg/dav)          %Reference Dose
       U.S. population                   0.007446                  74
       Non-nursing Infants (< 1 yr)        0.010580                  106
       Children (1-6 yr)                  0.012878                  129
       Children (7-12 yr)                 0.010361                  104

       All other subgroups were less than 100% of the RfD.

       "Worst Case" Chronic Dietary Exposure from HCB as an Impurity in DCPA

       The TMRC was calculated for the U.S. population and 22 subgroups.

       Subgroup                         Exposuredng/kg/day)         %Reference Dose
       U.S. population                          0.000024                  3
       Non-Nursing Infants ( < 1 yr)              0.000037                  5
       Children (1-6)                            0.000041                  5

       All other subgroups were less than 5% of the RfD.

       In a second analysis, "More Realistic Case" Chronic Dietary Exposure,  the anticipated
residues in Table 3 were used in the calculation. This is considered to be a more realistic scenario
since the residue data were obtained from field trials and surveys. As previously discussed, ARs
could not be calculated for corn, soybeans, and rutabagas and are therefore included at tolerance
level.  Parsley also is included at the proposed tolerance level because monitoring data have
indicated the presence of DCPA residues on parsley in the food supply.

       "More Realistic Case" Chronic Dietary Exposure from DCPA

       The Anticipated Residue Contribution (ARC) was calculated for the U.S. population and
       22 subgroups.

       Subgroup                         Exposuredng/kg/day)         %Reference Dose
       U.S. population                          0.000233                  2
       Non-Hispanic blacks                      0.000305                  3

       All other subgroups were less than 3% of the RfD.
                                           43

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       "More Realistic Case" Chronic Dietary Exposure from HCB as an Impurity of DCPA

       The ARC was calculated for the U.S. population and 22 subgroups.

       Subgroup                         Exposuredng/kg/day)          %Reference Dose
       U.S. population                          <0.0000007                0.09
       Non-Hispanic Others                      <0.000001                 0.1

       All other subgroups were less than 1% of the RfD.

       Thus, in the more realistic scenario in which anticipated residues and percent crop treated
refinements are used in estimating chronic dietary risk, the % Reference Dose for both DCPA and
its impurity HCB are less than 100 for the U.S. population and all subgroups.

       Neither DCPA nor its impurity HCB pose a significant chronic dietary risk for uses that
are currently registered or for uses such as meat, milk, poultry, or eggs which may need to be
established.

"Worst Case" Chronic Dietary Exposure from  2,3,7,8-TCDD as an Impurity in DCPA

       A chronic dietary risk for TCDD was calculated for the general population of the U.S.
only.  To estimate exposure, the TMRC (Theoretical Maximum Residue Contribution) of
0.007446 mg/kg/day for exposure to DCPA in the diet was used.  Exposure to 2,3,7,8-TCDD in
the diet can be estimated by multiplying DCPA exposure by the percent of 2,3,7,8-TCDD in the
formulation.

       (0.007446)(0.0000000001) =  7.446 x 10'13 mg/kg/day

       Using an RfD of 0.000001 ug/kg/day (0.000000001 mg/kg/day), the percent RfD can be
estimated as 0.07%.

                           (3)     Carcinogenic Dietary Risk

Carcinogenic Risk from DCPA

       The upper bound carcinogenic risk from food uses of DCPA for the general U.S.
population was estimated using anticipated residues and the following equation:

                 Upper Bound Cancer Risk = Dietary Exposure (ARC) x Qx*

       Based on a Qt* of 0.00149 (mg/kg/day)"1, the upper bound carcinogenic risk was
estimated to be 3.5 x 10"7.
                                          44

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       For reasons previously stated, soybeans, corn, rutabagas, lettuce, parsley, meat, milk,
poultry, and eggs were included in this estimate of carcinogenic risk.  The contributions to the risk
from these commodities are soybeans (1  x 10"8), corn (1.1 x 10"8), rutabagas (8 x 10"9), lettuce
(2.2 x 10'7), parsley (2.2 x 10'8), and meat, milk, poultry, and eggs (3 x 10'11).

Carcinogenic Risk from HCB as an Impurity in DCPA

       The upper bound carcinogenic risk from food uses of HCB for the general U.S. population
was estimated using the following equation:

              HCB Upper Bound Cancer Risk = Dietary Exposure (ARC) x Qx*

       Based on a  Qx* of 1.02 (mg/kg/day)"1, the upper bound cancer risk was estimated to be
    ,-7
7x10

       As with the DCPA risk assessment, soybeans, corn, rutabagas, lettuce, parsley, meat, milk,
poultry, and eggs were included in this estimate of carcinogenic risk. HCB does not pose a
significant risk of excess life time carcinogenic risk to the overall U.S. population with an upper
bound estimate of 7 x 10"7. In this risk assessment the estimate of upper bound carcinogenic risk
from HCB could be considered to be an over-estimate of actual  risk. This is due to the
assumption that residues of HCB are present at the certified upper limit, 0.3%, in all DCPA
formulations.

Carcinogenic Risk for 2.3.7.8-TCDD as an Impurity in DCPA

       To estimate exposure, the TMRC of 0.007446 mg/kg/day for exposure to DCPA in the
diet was used.  Exposure to 2,3,7,8-TCDD in the diet can be estimated by multiplying DCPA
exposure by the percent of 2,3,7,8-TCDD in the formulation.

       (0.007446)(0.0000000001) = 7.446 x 10'13 mg/kg/day

       Carcinogenic risk can be estimated by multiplying the 2,3,7,8-TCDD exposure by its
cancer potency factor.

       (7.446 x 1Q-13)(1 x 105) = 7 x ID'8

                    b.     Drinking Water Assessment

                           (1)     Chronic Drinking Water Risk

       Drinking water chronic risk was calculated using the following formula:

       Risk = % RfD = [Exposure/RfD](100) where:
                                           45

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       # the RfD for DCPA (0.01 mg/kg/day) is used for DCPA, TPA, and MTP. A complete
       database exists only for DCPA. Without a complete database for each metabolite, Agency
       policy is to use a default assumption that each metabolite is no more or less toxic than the
       parent; and, as previously stated

       # exposure = (ppb DCPA and/or metabolites in the water consumed) (10"6)(22.6)

Groundwater

State Studies (Suffolk County, NY)

       %RfD = [(28.768) (10'6)  (22.6)7(0.01)](100)
              = 6.5%

Registrant Studies

       New York turf

       %R£D  = [(50.36) (ID'6) (22.6)7(0.01)](100)
              = 11%

       California onions

       %R£D  = [(12.75) (ID'6) (22.6)7(0.01)](100)
              = 3%

Surface Water

       Lonetree Creek

       %R£D  = [(5.95) (ID'6) (22.6)7(0.01)](100)
              = 1%

       Cherry Creek

       Risk   = [(0.0078) (10'6) (22.6)7(0.01)](100)
              = 0.002%

       The highest %RfD was 11% at the New York turf site.  Even if this drinking water risk
were to be combined with the chronic  dietary risk, the total %RfD would be much less than  100.
                                           46

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                           (2)    Carcinogenic Drinking Water Risk

       Carcinogenic risk for drinking water was calculated using the following formula.

       Risk = Exposure x Qx* where:

       # the Qt* for DCPA, 0.00149 (mg/kg/day)'1 is used for DCPA, TPA, and MTP.  A
       complete database exists only for DCPA. Without a complete database for each
       metabolite, Agency policy is to use a default assumption that each metabolite is no more
       or less carcinogenic than the parent; and as previously stated

       # exposure = (ppb DCPA and/or metabolites in the water consumed) (10"6)(22.6)

Groundwater

State Studies (Suffolk County, NY)

       Risk  = (28.768)(10-6)(22.6)(0.00149)
             = 9.7x ID'7

Registrant Studies

       New York turf

       Risk  = (50.36)(10-6)(22.6)(0.00149)
             = 1.7x ID'6

       California onions

       Risk  = (12.75)(10-6)(22.6)(0.00149)
             = 4.3x ID'7

Surface Water

       Lonetree Creek

       Risk  =(5.95)(10-6)(22.6)(0.00149)
             = 2xlQ-7

       Cherry Creek

       Risk  = (0.0078)(10-6)(22.6)(0.00149)
             = 2.6x ID'10
                                           47

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       Generally, the information available to the Agency does not identify a population
consuming drinking water equal to or greater than 50 ug/L (DCPA and metabolites) for a period
of 70 years.  It should be noted that the highest concentration of detected TPA in the NFS was
7.20 ug/L, and there were no detections of DCPA.

       Consumption of drinking water obtained from groundwater at the New York turf site may
be a worst case scenario.  If drinking water were to be obtained solely from this source
(containing DCPA and its metabolites at 50 ug/L) then the carcinogenic risk would be 1.7 x 10"6.
The Agency  will be refining this risk estimate, since it has been based on preliminary information
and could change based on final groundwater data due to the Agency in the summer of 1996.

       The information available to the Agency indicates that the NOELs for TPA would be
higher than those of DCPA for similar studies.  However, adequate information to estimate a
health advisory level for TPA is not available. As previously stated, a complete database exists
only for DCPA, and it was necessary for the  Agency to default to the DCPA database for the
TPA (and MTP) metabolites.

                    c.      Occupational and Residential Assessment

                           (1)     Short Term and Intermediate Term Risk

       A short term (1-7 days) occupational or residential risk assessment was not required
because the NOEL for the 21 day dermal study is greater than 1000 mg/kg/day.  Additionally, no
appropriate toxicological endpoint of concern was identified.

       An intermediate term (1 week to several months) occupational or residential risk
assessment was not required. The NOELs in the studies appropriate for selecting this endpoint
were too high to be of concern; therefore, an appropriate toxicological endpoint of concern was
not identified.

                           (2)     Carcinogenic Risk

       Using the exposures presented in Table 8, the carcinogenic risk after exposure to foliar
dislodgeable residues of DCPA following an application of Dacthal W-75 to turfgrass was
calculated using the following formula:

              Risk = [[Average annual exposure (mg/kg/day)] [play exposure interval (10
              yrs)/average lifetime (70 yrs)]] x [Q^O.00149 (mg/kg/day)"1)] x [dermal
              absorption factor (0.149)].

       For irrigated lawns the average annual risk estimate for children playing on a treated lawn
is 5.6 x 10"7.  For non-irrigated lawns the average annual risk for children playing on a treated
lawn is 2.0 x 10'6.
                                           48

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       A similar formula was used to calculate the carcinogenic risk after exposure (Table 9) to
foliar dislodgeable residues of HCB following an application of Dacthal W-75 to turfgrass:

              Risk = [[Average annual exposure (mg/kg/day)] [play exposure interval (10
              yrs)/average lifetime (70 yrs)]] x [Q^l.Ol mg/kg/day)"1)] x [dermal absorption
              factor (0.2646)].

       For irrigated lawns the average annual risk from HCB as an impurity of DCPA for
children playing on a treated lawn is 3.9 x 10"7. For non-irrigated lawns the average annual risk
for toddlers and children playing on a treated lawn is 2.7 x 10"6.

       As previously stated, the Agency does not have the foliar residue data to calculate
exposure to 2,3,7,8-TCDD following an application of Dacthal W-75 to turfgrass.  However, a
rough estimation of the risk for children ages 2-12 playing on non-irrigated turf at 1 hour after
treatment was 3.9 x 10"7.

       The carcinogenic risk for the previously identified occupational  and residential scenarios
are given in Table 10 for DCPA and in Table 11 for HCB. The highest estimated risk for a
commercial applicator is for the wettable powder scenario. For the commercial mixer/loader
(assuming 350 acres) the risk for DCPA was estimated to be 7.5 x 10"5  and for HCB (in DCPA)
to be 1.9x 10'4.

       These risks could be mitigated by the use of a dust mist respirator with a TC-21C filter.
The application of an 80% protection factor for the inhalation exposure component of treating
350 acres yields an LADD (mg/kg/day) of 0.027 for DCPA and  1.3 x 10'4 for HCB. The
corresponding carcinogenic risk would be 4.0 x 10"5 for DCPA and 1.3  x  10"4 for HCB.

       The scenario with the highest risk for a private applicator for exposure to DCPA is also
the wettable powder scenario (assuming 80 acres are treated).  For DCPA the risk is 1.6 x 10"6.
The scenarios with the highest risk for a private applicator for exposure to HCB are the wettable
powder scenario (assuming 80 acres treated), the shaker can scenario (5000 ft2), and the whirly-
bird scenario with corresponding risk estimates of 4.6 x 10"6, 1.4 x 10"6, and 1.6 x 10"6. The
Agency is requiring additional handler studies for these scenarios.

       Risk for several of the M/L/A scenarios for exposure to TCDD was  estimated using an
application rate of 10"9, which is the DCPA label application rate of 10 multiplied by the TCDD
exposure values of 0.00000001%.  The risk for the  whirly-bird scenario was 2 x 10"8 and for the
wettable powder scenario, commercial applicator (300 acres) was 1.6 x 10"6. It should be
emphasized that these can be considered as overestimates due to the lack  of a dermal absorption
factor and the use of 0.00000001% of the DCPA formulation.

       Foliar dissipation data for DCPA and HCB  on cucumbers and corresponding worker
exposure and risk during cucumber harvesting are summarized in Table 12.  The highest risk for
                                           49

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exposure to DCPA is 1.8 x 10"4 and for exposure to HCB (in DCPA) is 3.2 x 10"4 both at zero
days after treatment.  The risk values decrease as the days after treatment increase.  The exposure
and risk levels in  12 were calculated based on very conservative assumptions regarding transfer
of foliar dislodgeable residues (FDRs) to fieldworkers during harvesting and the number of days
of exposure per year at each FDR level (i.e., 30 days of exposure per year at each FDR level).

       The Agency also lacks the FDR data to calculate TCDD exposure during cucumber
harvesting.  However, a rough estimation for zero days after treatment is  8 x 10"6, which should
be considered as an overestimation since a very conservative transfer factor was used and no
dermal absorption factor was available.
                                           50

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Table 10: DCPA Occupational and Residential Carcinogenic Risk Values (based upon
exposure values from Table 5)
Exposure Scenario (Seen. #)
Riska
Private Appl.b
Commercial Appl.c
Mixer/Loader Risk
Liquids (I)
Wettable Powder (la)
Granulars (II)
80A: 1.6xlO-7
80A: 1.6xlO-6
80A: 7.6 xlO'8
80A: 1.6xlO-6
350A: 7.3 xlO'6
80A: 1.6xlO-5
350A: 7.5 xlO'5
80A: 7.6 xlO'7
350A: 3.3 x 10'6
Applicator Risk
Aerial (liquids) (Ilia)
Aerial (granulars) (Illb)
Groundboom (IV)
Granular Spreader Cultivator Mounted (V)
NA
NA
4.5 xlO'8
9.4 x ID'9
7.9 xlO'6
1.6xlO-6
4.5xlO-7
9.4 x ID'8
Flagger Risk
Liquids (Via)
Granulars(VIb)
NA
NA
l.SxlO-6
5.7 xlO'7
Mixer/Loader/Applicator Risk
Shaker Can (VII) 1000ft2
Shaker Can (VII) 5000ft2
Backpack (VIII)
Residential Push-type Spreader (IX)
Whirly-bird Spreader (X)
7.3 x ID'8
3.7 xlO'7
1.2xlO-7
1.3xlO-7
4.8 xlO'7
7.3 x ID'7
3.7 xlO'6
6.0 xlO'6
6.3 xlO'6
NA
a Risk= [LADD (mg/kg/day)] * [Qj* of 0.00149 (mg/kg/day)'1]

b Private applicator is defined as a short term exposed individual (i.e., one day).

c Commercial applicator is defined as an intermediate exposed individual (i.e. 10 days).
                                                51

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Table 11: HCB Occupational and Residential Carcinogenic Risk Values (based upon
exposure values from Table 6)
Exposure Scenario (Seen. #)
Riska
Private Appl.b
Commercial
Appl.c
Mixer/Loader Risk
Liquids (I)
Wettable Powder (la)
Granulars (II)
80A: 5.7x10-'
80A: 4.6 xlO'6
80A: 2.1 x ID'7
80A: 5.7 xlO'6
350A: 2.6 xlO-5
80A: 4.6 xlO'5
350A: 1.9xlO-4
80A: 2.1 x ID'6
350A: 9.1xlO-6
Applicator Risk
Aerial (liquids) (Ilia)
Aerial (granulars) (Illb)
Groundboom (IV)
Granular Spreader Cultivator Mounted (V)
NA
NA
1.5x10-'
S.lxlO'8
2.8 xlO-5
3.8xlO-6
l.SxlO-6
S.lxlO'7
Flagger Risk
Liquids (Via)
Granulars (VIb)
NA
NA
e.ixio-6
l.SxlO-6
Mixer/Loader/Applicator Risk
Shaker Can (VII) 1000 ft2
Shaker Can (VII) 5000 ft2
Backpack (VIII)
Residential Push-type Spreader (IX)
Whirly-bird Spreader (X)
2.6 xlO-7
1.4xlO-6
4.2 x ID'7
4.6xlO-7
1.6xlO-6
2.6 xlO-5
1.4xlO-5
2.1xlO-5
2.3xlO-5
NA
a Risk = LADD (mg/kg/day)] * [Qj* of 1.02 (mg/kg/day)'1]

b Private applicator is defined as a short term exposed individual (i.e., one day)

c Commercial applicator is defined as an intermediate exposed individual (i.e. 10 days)
                                                52

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Table 12:  Foliar Dislodgeable Residues (FDR) of DCPA and HCB on Cucumbers and the
Worker Reentry Exposure and Risk During Cucumber Harvesting
Corresponding
DAT
0
1
2
3
4
5
6
FDR Og/cm2)a
DCPA
17.4
15.0
12.9
11.1
9.5
8.2
7.0
HCB
0.025
0.018
0.013
0.010
0.007
0.005
0.004
LADD (mg/kg/day)b
DCPA
0.82
0.70
0.61
0.52
0.45
0.38
0.33
HCB
0.0012
0.0009
0.0006
0.0005
0.0003
0.0002
0.0002
Risk Levels0
DCPA
l.SxlO'4
1.6xlO-4
1.3xlO-4
1.2xlO-4
9.9xlO'5
8.5xlO-5
7.3 x ID'5
HCB
3.2 x ID'4
2.3 x ID'4
1.6xlO-4
1.3xlO-4
8.9xlO-5
6.3xlO'5
S.lxlO'5
DAT = Days After Treatment
The calculations use the following assumptions: 8 hour work day, 30 days exposure each year for a total of 35 years over a 70
year lifetime, average body weight of 70 kg

a FDR values were calculated using a regression analysis of dissipation data (MRID 417501-05)

b Lifetime Average Daily Dose (LADD) was calculated using the following equation:
       [FDR Og/cm2) x (10000 cm2/hr) x (1 mg/1000 ^g) x (1/70 Kg) x (8 hrs/day) x (30 days harvesting/365 days per year)
       x
       (35 years harvesting/70 year lifetime)]
where 10,000 cm2/hour is a transfer coefficient for citrus harvesters excerpted from Zweig, Leffingwell, Popendorf, 1985.

c Risks for DCPA and HCB were calculated using the following equation:
       [LADD (mg/kg/day) x Ql * (mg/kg/day)"1 x (Dermal Absorption Factor)
The Qj* value for DCPA is 0.00149 (mg/kg/day)-' and for HCB is 1.02 (mg/kg/day)-1.
The dermal absorption factor for DCPA is 0.149 and for HCB is 0.2646

Additional Occupational/Residential Exposure Studies

Handler Studies

       The Agency does not have handler exposure  studies for three of the occupational
scenarios for which DCPA is used.  The Agency used  surrogate data from the Pesticide Handler's
Exposure Database to estimate a handler's exposure to DCPA and HCB in these scenarios.
Resulting risk estimates are in the 10"4 to 10"6 range, with a great amount of uncertainty associated
with those values.  Therefore, the registrant is being required to submit handler exposure studies
for three scenarios to confirm that these uses are eligible for reregistration.  The three scenarios
are listed below.

              loading/applying granular formulations  using whirly-bird spreader equipment,
       •      mixing/loading wettable powder formulations to support aerial applications, and
              loading/applying granular formulations  using a shaker can.

       A dermal exposure study (Guideline  231) and an inhalation exposure study (Guideline
232) are being required for each of these scenarios.  These studies should be conducted
concurrently; i.e.,  dermal and inhalation samples should be collected from the same handler and at
the same site during each trial for both DCPA and HCB exposure. Requirements  for such studies
are addressed in subdivision U of the Pesticide Assessment Guidelines.
                                              53

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Post-Application Studies

       The registrant must submit post-application exposure studies as confirmatory data for
reregistration.  Requirements for such post-application exposure studies are addressed by
Subdivision K of the Pesticide Assessment Guidelines. Post-application/reentry exposure studies
are required as confirmatory data to determine definitive REIs for crop/use sites on which DCPA
is registered for use.  The REIs established in this document will be adjusted accordingly upon
submission of the additional data.  Studies are required for:

       • Low crops (such as cucumber)
       • Residential sites (turfgrass)

       Requirements for post-application/reentry exposure studies are addressed by Subdivision
K of the Pesticide Assessment Guidelines. The required data include:

              * 133-3       Post-application Dermal Passive Dosimetry Exposure
              * 133-4       Post-application Inhalation Passive Dosimetry Exposure

              *Guidelines 133-3 and 133-4 may be reserved at this time pending completion of
              the databases on agricultural and residential postapplication/reentry exposure
              currently being developed by the Agricultural Reentry Task Force and Outdoor
              Residential Exposure Task Force, provided the registrant is a member of both
              Task Forces.
                                            54

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       c.
Environmental Assessment
              1.      Ecological Toxicity Data

       The Agency has adequate data to assess the hazard of DCPA to nontarget terrestrial
organisms, although the guideline requirements for avian reproduction are not fulfilled; and plant
seedling emergence, germination and vegetative vigor are only partially fulfilled (i.e., the risk
assessment was completed with supplemental data).

                     a.      Toxicity to Terrestrial Animals

                            (1)    Birds, Acute and Subacute

       In order to establish the toxicity of DCPA to birds, the following tests are required using
the technical grade material: one avian single-dose oral (LD50) study on one species (preferably
mallard or bobwhite quail); two subacute dietary studies (LC50) on one species of waterfowl
(preferably the mallard duck) and one species of upland game bird (preferably bobwhite quail).

Table 13: Avian Acute Oral Toxicity
Avian Acute Oral Toxicity Findings
Species
Northern Bobwhite
% A. I.
100
LD50 mg/kg)
>2,250
MRIDNo
41155705
Toxicity
Category
practically
nontoxic
Fulfills Guideline
Requirement
yes
Table 14: Avian Subacute Oral Dietary Toxicity
Avian Subacute Dietary Toxicity Findings
Species
Northern Bobwhite
Mallard
% A. I.
100
100
LC50 (ppm)
>5,620
>5,000
MRIDNo.
41155706
41155707
Toxicity Category
practically nontoxic
practically nontoxic
Fulfills Guideline
Requirement
yes
yes
1 This study is classified as supplemental.

       These results indicate that DCPA is practically nontoxic to avian species on an acute oral
and subacute dietary basis. The guideline requirements are fulfilled. (MRTD 411557705,
41155706, and 41155707)

                            (2)    Birds, Chronic

       Avian reproduction studies are required when birds may be exposed repeatedly or
continuously through persistence, bioaccumulation, or multiple applications, or if mammalian
reproduction tests indicate reproductive hazard. DCPA is persistent enough to result in chronic
exposure to birds.
                                            55

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       However, no data were available on the effect of DCPA on reproduction of the quail and
mallard duck.  Therefore, the Agency requires that an avian reproduction study be conducted in
order to quantify the chronic risks of DCPA use to avian species.  The guideline requirements for
avian reproduction testing are not satisfied.
                           (3)
Mammals
       Wild mammal testing is required on a case-by-case basis, depending on the results of the
lower tier studies such as acute and subacute testing, intended use pattern, and pertinent
environmental fate characteristics. In most cases, however, a rat acute oral LD50 is used as a small
mammal surrogate to estimate toxicity to mammals.  This LD50 is reported below.

Table 15: Mammalian Acute Oral Toxicity
Mammalian Acute Oral Toxicity Findings
Species
Rat (small mammal surrogate)
% A.I.
90
LD50 (mg/kg)
>5,000
MRID
No.
41054808
Toxicity
Category
practically
nontoxic
Fulfills Guideline
Requirement
Yes
       The available mammalian data indicate that DCPA is practically nontoxic to small
mammals on an acute oral basis. (MRID 41054808)
                           (4)
Insects
       A honey bee acute contact LD50 study is required if the proposed use will result in honey
bee exposure.

Table 16: Nontarget Insect Acute Toxicity
Nontarget Insect Acute Contact Toxicity Findings
Species
Honey Bee
% A.I.
99.6
LD50 fj.g
a.i./bee
>230
MRID No.
00009181
Toxicity Category
practically nontoxic
Fulfills Guideline Requirement
Yes
       There is sufficient information to characterize DCPA as practically nontoxic to bees. The
       guideline requirement is fulfilled. (MRID 00009181)

                     b.     Toxicity to Aquatic Animals

                           (1)    Freshwater Fish

       In order to establish the toxicity of a pesticide to freshwater fish, the minimum data
required on the technical grade of the active ingredient are two freshwater fish toxicity studies.
One study must use a coldwater species (preferably the rainbow trout), and the other must use a
warmwater species (preferably the bluegill sunfish).
                                           56

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Table 17:  Freshwater Fish Acute Toxicity
Freshwater Fish Acute Toxicity Findings
Species
Rainbow trout


Bluegill sunfish


% A.I.
2.5
75
75
75
75
96.7
LC50
(ppm)
>180
30
>6.6
>320
>120
>96.7
MRID No.
00107142
40227001
41054826
00045822
40227002
41054827
Toxicity Category
practically nontoxic
slightly toxic

practically nontoxic
practically nontoxic
slightly toxic
Fulfills Guideline
Requirement
No1
Yes
Yes
No1
Yes
Yes
 This study is classified as supplemental.

       The results of the 96-hour acute toxicity studies indicate that DCPA is probably no more
than slightly toxic to fish. The guideline requirements are fulfilled. (MRID 41054827, 00107142,
40227001, 00045822, 40227002 and 41054826)
                            (2)
Freshwater Invertebrates
       The minimum testing required to assess the hazard of a pesticide to freshwater
invertebrates is a freshwater aquatic invertebrate toxicity test, preferably using first instar
Daphnia magna or early instar amphipods, stoneflies, mayflies, or midges.
Table 18:  Freshwater Invertebrate Toxicity
                             Freshwater Invertebrate Toxicity Findings

Species
Daphnia magna






Chironomus plumous

Gammarus pseudolimnaeus


% A.I.
tech.
75
75

75

75
tech.
75
tech.
75
LC50
(ppm)
>100
138
27

30

47
>100
138
138
138

MRID No.
40098001
40226901
078701 40098001
40098001

40098001

40098001
40098001
40098001
40098001

Toxicity Category
practically nontoxic
practically nontoxic
slightly toxic

slightly toxic

slightly toxic
practically nontoxic
practically nontoxic
practically nontoxic
practically nontoxic
Fulfills Guideline
Requirement
Yes
Yes
Yes

Yes

Yes
Yes
Yes
No1
No1
1 This study is classified as supplemental.

       There is sufficient information to characterize DCPA as slightly toxic to practically
nontoxic to aquatic invertebrates. The guideline requirement is fulfilled. (MRID 40098001,
40226901)
    This study is classified as supplemental.
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                            (3)    Estuarine and Marine Animals

       Acute toxicity testing with estuarine and marine organisms is required when an end-use
product is intended for direct application to the marine/estuarine environment or is expected to
reach this environment in significant concentrations. The terrestrial uses of DCPA may result in
exposure to the estuarine environment.

       The requirements under this category include a 96-hour LC50/EC50 for an estuarine fish, a
96-hour LC50 for shrimp, and either a 48-hour embryo-larvae study or a 96-hour shell deposition
study with oysters.

Table 19:  Estuarine/Marine Acute Toxicity
Estuarine/Marine Acute Toxicity Findings
Species
Eastern oyster shell deposition
Brown Shrimp
Sheepshead minnow
% A.I.
tech.
tech.
tech.
EC/LC50
(ppm)
0.62
>1.0
>1.0
MRID No.
40098001
40098001
40098001
Toxicity Category
highly toxic
moderately toxic
moderately toxic
Fulfills Guideline
Requirement
Yes
Partial1
Partial1
1 These studies are classified as supplemental because no LC50 was obtained. However, they provide sufficient information to show that the LC50 for
these species is greater than 1 ppm, which approximates maximum solubility.

       There is sufficient information to characterize DCPA as moderately to highly toxic to
nontarget estuarine and marine organisms.  The guideline requirement is fulfilled. (MRID 078701)

                     c.      Toxicity to Plants

                             (1)    Terrestrial

       Currently, terrestrial plant testing (seedling emergence and vegetative vigor) is required
for herbicides which have terrestrial non-residential outdoor use patterns and appear to move off-
site of application through volatilization (vapor pressure 2.5 x 10"6 torr at 25 C) or drift (aerial
or irrigation); and/or which may have endangered or threatened plant species associated with the
site of application. The above conditions apply for DCPA (refer to Section IV.C.3, Endangered
Species).
       Tier II toxicity data on the technical/TEP material for the most sensitive species is listed
below:
Table 20:  Nontarget Terrestrial Plant Toxicity
Nontarget Terrestrial Plant Toxicity Findings
Test and Species
Seedling emergence and germination (tomato)
Vegetative vigor (soybean)
% A.I.
tech.
tech.
EC25
>7.5 Ibs ai/acre
>7.5 Ibs ai/acre
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       The studies submitted for seedling emergence and germination and vegetative vigor have
been classified as supplemental. The Agency did not use these data for risk assessment purposes
since tolerant species were used. Further, the Agency is requiring that additional nontarget
testing not be conducted with these same species. See Data Requirements section of DCPA
RED for discussion.

       The guideline requirements are not fulfilled. (MRID 41564901, 41440101)

                           (2)    Aquatic

       Currently, aquatic plant testing is required for any herbicide which has outdoor non-
residential terrestrial uses that may move off-site of application by runoff (solubility >10 ppm in
water), by drift (aerial or irrigation), or is applied directly to aquatic use sites (except residential)
as in the case of DCPA.  The following species must be tested:  Selenastrum  capricornutum,
Lemna gibba, Skeletonema costatum, Anabaenaflos-aquae, and a freshwater diatom.

       Tier II toxicity data on the technical/TEP material is listed below:

Table 21: Nontarget Aquatic Plant Toxicity
Nontarget Aquatic Plant Toxicity Findings
Species
Navicula pelliculosa (Freshwater diatom)
Lemnagibba
Selenastrum capricornutum
Skeletonema costatum
Anabaena flos-aquae
% A.I.
98.4
98.4
98.0
98.4
98.4
EC50(ppm)
>11.0
>11.0
>12.38
>11.0
>11.0
       The guideline requirements are fulfilled. (MRID 41155714, 42836102, 42882401,
42836103, 4236101, and 41054829)

              2.     Environmental Fate

                    a.     Environmental Fate Assessment

       The Agency has sufficient data to define the environmental fate of DCPA. Biodegradation
is the primary dissipation process for DCPA.  Under laboratory conditions, the half-life is
approximately 15-30 days, but longer half-lives have been reported in the field. Parent DCPA is
not especially persistent or mobile.  Tetrachloroterephthalic acid (TPA or di-acid) is the only
significant DCPA metabolite, with monomethyl tetrachloroterephthalic acid (mono-acid) as a
minor metabolite. TPA is unusually mobile and persistent in the field. Data suggest that TPA will
leach to groundwater wherever DCPA is used, regardless of soil properties.

       Volatilization from soil  is also a major dissipation route for parent DCPA. Volatilization
appears to be the source of DCPA residues on crops to which it has not been applied. The
maximum distance that DCPA may move  following volatilization is not known, but drift has been
reported in the published literature.  Under warm conditions in fields with high soil moisture
levels, volatilization may be the major dissipation route for DCPA. More typically, volatilization
                                           59

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probably accounts for 20-40 percent of DCPA loss.  For TPA, leaching is the major dissipation
route.

       TPA does not appear to be phytotoxic, as weed control occurs rapidly after application of
DCPA and control declines with the decline of parent DCPA concentration in the soil.

       Concentrations of DCPA reported in fish exposed to DCPA through volatility drift alone
(38 ppb) raise concerns about exposure of endangered freshwater mollusks to DCPA.  Substantial
amounts of DCPA could be available for runoff for several weeks post-application.  Most DCPA
runoff will generally occur in the form of adsorption to eroding soil as opposed to dissolution in
runoff water. DCPA could be  somewhat persistent in many surface waters,  particularly those
with low microbiological activities and long hydrological residence times.

       TPA appears to be substantially more persistent than parent DCPA and exhibits low
soil/water  partitioning. Therefore, substantial quantities of TPA should be available for runoff for
a longer period than the parent DCPA.

       TPA is extremely mobile and can leach to ground water under many different conditions.
Although contrary to the environmental chemistry and environmental fate data which indicate that
parent DCPA would not be very mobile,  it appears that under certain conditions both  the DCPA
parent and the mono-acid can also find their way into the ground water.  The persistence of TPA
in ground  water is not known.

       The lifetime Health Advisory for DCPA in drinking water is currently established at 4000
|ig/L (ppb).  DCPA and/or TPA have been reported in four percent of ground water (206 wells of
4917) in ground water monitoring studies conducted in 24 states. Concentrations of TPA ranged
from trace levels to 1477 ppb.  The maximum parent DCPA concentration reported is  7.7 ppb.
Concentrations of DCPA residues have all been below the current lifetime Health Advisory.

                    b.     Environmental Fate and Transport

                           (1)     Degradation

       Hydrolysis.  DCPA was stable in water for 36 days at pH 5, 7, and 9. (MRID 00114648)

       Photolysis in water. DCPA was stable to photolysis in unbuffered water. After the
equivalent of 191 12-hour exposure days, less than 10 percent of the parent  DCPA had
photolyzed.  (MRID 41508607)

       Photolysis on soil. DCPA was stable to photolysis on soil.  In an early study, DCPA was
stable under a sunlamp having  "297 nm in wavelength." After 38.5  days equivalent of radiation on
a glass bead surface, 95.7 percent of the applied was present as parent DCPA. With the same
sunlamp and DCPA on silica gel in the presence of a photosensitizer (unnamed), 90.8 percent
remained as DCPA after the equivalent of 168 days of exposure. The primary photoproduct was
monomethyl tetrachloroterephthalic (MTP or mono-acid) at 5.2 percent. No photodegradation
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occurred under black light and fluorescent light, shown to be similar to natural sunlight in the
range of wavelengths where DCPA absorbs light. (MRID 41508608, accession number 093786)

       Aerobic soil metabolism. DCPA will undergo microbial degradation and is enhanced by
warmer temperatures and increased soil water content. Parent half-life was estimated at 18-37
days. After 197 days, virtually all of the parent DCPA had been converted into TPA, although
small amounts of monomethyl tetrachloroterephthalic acid (MTP) were also identified. DCPA did
not degrade in steam-sterilized soil. Wettasinghe and Tinsley (1993) confirmed these results, with
a half-life of 16.6 days at 25  C and 12.6 percent water content.  Decreasing the temperature to 5
 C and the water constant to 9.6 percent decreased the rate of degradation, giving a half-life of
289 days (Walker 1978, cited by Wettasinghe and Tinsley).  Choi et. al. (1988, cited by
Wettasinghe and Tinsley) confirmed these observations, reporting a half-life of parent DCPA at
11-16 days at medium  soil moisture and 25  C. For the DCPA degradates, the mono-acid had a
half-life of 2.8 ±0.1 days. However, TPA was very persistent.  There was virtually no
degradation of TPA during a 300 day study. (MRID 00114649, 41648801)

       Anaerobic soil metabolism. Anaerobic soil conditions slowed DCPA degradation only
slightly, with estimated half-lives of 37-59 days. TPA was also the final degradate under anaerobic
conditions. (MRID 00114651, 41648802).

                           (2)    Mobility

       Leaching/adsorption/desorption. Although not fully acceptable, the study of parent
DCPA strongly suggests that DCPA is not mobile. In an unaged column leaching study, the sand
portion of the soil  may have been removed by sieving through too fine a mesh, resulting in a finer
soil fraction and making the parent compound appear less mobile.  For the  degradates of DCPA,
both TPA and MTP are highly mobile in all soils.  (MRID 41648803, 41648804,  41648805,
42262602)

       Aged column leaching.  DCPA residues were shown to leach through soil, with the
leachate containing primarily TPA. In this early study, soil columns were prepared with 2 g of
treated soil aged 30 days placed atop  a 12 inch column. The columns were leached with 1/2 inch
of water a day for 45 days. In two sandy loams, one pH 5.9 and the other pH 8.0, DCPA residues
were shown to leach. The residue found in the leachate was overwhelmingly TPA. Leaching was
much more extensive in the high pH soil: 85.2 percent of the applied was found in the leachate.
(MRID 00114650)

       Lab and field volatility. Based on a relatively low Henry's constant
(2.2 x 10"6  atm-m3/mol) and moderately to relatively high soil/water partitioning, DCPA does not
appear to have a high volatilization potential from soil. Nevertheless, several published studies
have shown that parent DCPA is volatile, especially from moist or wet soil.

       Nash and Gish  (1989) suggested that DCPA volatilization may be adsorption and diffusion
controlled, which would explain the poor predictability of volatilization from vapor pressure. At a
temperature of 35  C, volatility accounts for the majority of the applied DCPA.
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       Majewski et.al. (1991) suggested that in the early phase after application, volatilization is
the primary dissipation route for DCPA. They measured a total DCPA loss of between 1.27 and
1.59 kg per hectare out of 7 kg per hectare applied. They also found that DCPA volatilization flux
was very dependent upon the soil surface moisture content. High fluxes occurred immediately
following irrigation. Approximately 36 to 52 percent of the total measured DCPA loss from soil
was accounted for by volatilization and 26 percent by breakdown in soil during the 21 days of air
sampling.

       Ross et. al. (1990) estimated that 10 percent of the DCPA applied was lost to the
atmosphere within 21 days of application.  This group investigated DCPA volatility because
DCPA residues have been found repeatedly on a variety of produce samples to which it had not
been applied in California.  They concluded that these detections may have been due to DCPA
volatilization and drift. Volatilization accounted for 29 percent of the DCPA lost from soil in this
study. Although DCPA moved off target both as a gas and on particles, 62 to 93 percent of the
atmospheric residues were in the vapor phase when the field was wet. Field moisture in this  case
may have reduced the number of airborne dust particles as well as promoted DCPA volatilization.

                           (3)    Accumulation

       Fish bioaccumulation. DCPA bioaccumulates significantly in bluegill sunfish with
bioconcentration factors (BCFs) of 1894, 777, and 2574 in whole fish, edible tissue, and viscera,
respectively. Depuration appears to be complete after 14 days. Little metabolism or degradation
of DCPA occurs in fish tissues, although there is a detectable  amount of demethylation. (MRTD
41155716,41197602)

                           (4)    Terrestrial Field Dissipation

       Gilroy, CA: Bareground plots of loam soil were treated up to three times with DCPA
(75% WP), at 7.0-10.5 Ibs. a.i. per application. DCPA was detected to 18-inches, the maximum
sampling depth, in all of the plots, while the  mono-acid was not detected below 6 inches in any
plot. However, TPA was detected as deep as 60 inches 552 days after the single treatment and up
to 96 inches 552 days after the double treatment.  TPA was found at 0.03  ppm at the  72  inch
depth 552 days after the triple treatment.  (MRTD 41508609)

       This study was rejected for the large variation of DCPA concentrations with time. DCPA
did not degrade steadily with time, but increased and decreased erratically until a significant
reduction in concentration was noted in all experiments after about 185 days.  The study  author
calculated a half-life of 35 days for all plots based on DCPA residues in the upper 18 inches  of
soil, but the erratic decline  curves meant that half-life determinations were not statistically
significant. The study author suggested that detections of parent DCPA below the surface layer
were most likely due to sample contamination with surface soil. The study was considered
supplemental.

       Greenfield, CA: Bareground plots of sandy loam soil were treated up to three times with
DCPA (75% WP), at 7.0-10.5 Ibs. a.i. per application. DCPA was detected to 18-inches, the
maximum sampling depth,  in all of the plots, while the mono-acid was not detected below 6

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inches in any plot. TPA was detected at 48 inches. In the plot treated three times, parent DCPA
was again detected in the 15-18 inch layer. The mono-acid was not found below 6 inches, while
TPA was found at 18 inches (the lowest layer sampled).

       This study was rejected for the large variation of DCPA concentrations with time. DCPA
did not degrade steadily with time, but increased and decreased erratically until a significant
reduction in concentration was noted in all experiments between about 60 and about 120 days.
The study author calculated half-lives of 44 days for the single application plot, 86 days for the
double application plot, and  126 days for the triple application plot, but the erratic decline curves
meant that half-life determinations were not statistically significant. The study author suggested
that detections of parent DCPA below the surface layer were most likely due to sample
contamination with surface soil.  The study was considered supplemental. The data requirement
is not satisfied.  (MRID 41508609, 41508610)

                           (5)     Spray Drift

       Droplet size spectrum (Guideline 201-1) and drift field evaluation (Guideline 202-1) data
are required for DCPA, as the 75 percent wettable powder formulation may be applied by aircraft.
Since the registrant, ISK Biosciences, is a member of the Spray Drift Task Force, the Agency will
not require  droplet size spectrum or drift field evaluation data at this time. The registrant may
satisfy these data requirements through the Spray Drift Task Force unless required by the Agency
in advance  of the Task Force's final report.

                           (6)     Water Resources

                                  (a)     Ground Water

       Detections of parent DCPA have been reported.  This is contrary to the environmental
chemistry and environmental fate data of parent DCPA which indicate that parent DCPA would
not be mobile.  TPA (the di-acid metabolite of DCPA) is extremely mobile and can leach to
ground water under many different conditions. Although the  persistence of TPA in ground water
is not known, indications are that TPA is quite persistent. The mono-acid can also find its way
into the ground water. However,  TPA is the major degradate found in ground water.

       The lifetime Health Advisory for parent DCPA in drinking water is currently  established at
4000 |ig/L (ppb). DCPA or TPA and the mono-acid degradate have been detected in ground
water in 24 states. Concentrations of DCPA degradates ranged from trace levels to  1477 ppb.
The maximum parent DCPA concentration reported is 7.7 ppb. Concentrations of DCPA residues
have all been below the current lifetime Health Advisory.

       National Survey of Pesticides in Drinking Water Wells (NFS): The Agency initiated
the National Survey of Pesticides in Drinking Water Wells (NFS) to determine the frequency of
community water systems (CWS) and rural drinking water wells (RDW) nationwide  were
contaminated by pesticides and nitrate-nitrogen (USEPA, 1990).  DCPA and TPA were included
in the suite  of pesticides analyzed in the NFS. Parent DCPA was not detected in the NFS.
However, TPA was the most commonly detected pesticide residue by the NFS.  There were 31

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CWS (5.5 percent of CWS 564 wells) and 18 RDW (2.3 percent of the 783 RDW wells) wells
with detections (49 or 3.7 percent of 1347 wells) of TPA in twenty-two states.  States with
confirmed detections were AK, CA, CO, CT, IA, IL, IN, MA, MI, MN, MO, NH, NJ, NM, NY,
OH, PA, RI, SD, VA, and WI. Maximum values of TPA were 7.2 ppb in CWS wells and 2.4 ppb
in RDW wells. The median of the detectable values were 0.34 ppb and 0.38 ppb for the CWS and
RDW wells, respectively.

       State Studies. Approximately 157 wells (4.4 percent) of 3570 wells sampled in the
various state ground-water monitoring studies (excluding registrants prospective studies) have
detected parent DCPA residues.  The 157 wells were located in seven (CA, IA, MA, NY, OR,
WA, and WI) states.

       Of the 3570 wells mentioned above, only parent DCPA was analyzed for in 2229 of the
wells.  For the remaining 1341 wells, analysis included both parent DCPA and TPA. For these
wells, TPA was detected in 11.3 percent of the wells. The highest TPA value reported was 1039
ppb, which occurred in Suffolk County, New York. Suffolk County is highly vulnerable to
ground water contamination as the frequency of detections for other pesticides is also quite high.
Reported average and median DCPA residue concentrations for the New York data were 109 ppb
and 13.2 ppb, respectively. The highest reported TPA value in Oregon was 986 ppb (Cox, 1991).
The average TPA concentration reported for three wells in Wisconsin was 256 ppb.  Generally,
the maximum reported values were 15 ppb or less.

       Both Suffolk County, New York, and Treasure Valley in Malheur County, Oregon, may
represent examples of "hotspots." More than half (116 wells out of 206) of the wells with
confirmed DCPA detections occurred in these two areas.  The California Department of Food and
Agriculture conducted a seven county study which may also be considered a hot spot, as 18 wells
of 60 were confirmed to be contaminated with DCPA residues, with an additional 33 wells having
unconfirmed detections.

       Registrant studies.  The registrant is currently conducting two small-scale ground water
monitoring studies: on onions in California and on turf in New York. Although only a portion of
data have been collected and analyzed to date, the ground water monitoring results are
informative. As expected, TPA was detected most frequently and in the highest concentrations;
however, both DCPA and the monoacid were detected in higher than expected frequency,
although much lower concentrations. DCPA parent was detected in 16 and 26 percent of the
wells in New York and California, respectively; the mono-acid was detected in 12 and 29 percent
of the wells in New York and California, respectively.  Preferential flow and transport
mechanisms may have contributed to presence of these residues in ground water.

       Other Observations and Concerns. Environmental fate data indicate that DCPA
degradation is slower under cooler conditions compared to warmer conditions.  This factor may
at least partially explain the greater frequency of detections in New York and Oregon (cool) in
comparison to California (warm) conditions.  Seventeen states with DCPA residue detections
could be classified as states with cooler temperatures (AK, CT, IA, IL, IN, MA, MI, MN, NH,
NJ, NY, OH, OR, PA, RI, SD, and WI). States considered "warm" states with detections were
California, Colorado, and New Mexico. Irrigation also is potentially a factor affecting the degree

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of leaching in California, Colorado, and New Mexico, and should not be ruled out in the other
states.  Other environmental factors which can influence the transport of chemicals to ground
water are the amount, intensity, frequency, and temporal distribution of precipitation.

       Summary. The state and NFS studies found DCPA or TPA in 4.2 percent (excluding
repeated samples) of the 4917 wells sampled and analyzed for either DCPA or TPA.  TPA was
found in 7.6 percent of the 2688 wells sampled and analyzed for that metabolite, and parent
DCPA was detected in 0.12 percent.  DCPA and its metabolites were detected in a total of
twenty-four states. Parent DCPA residues were detected in the New York, Iowa, and
Washington state studies, but no residues were found in those states where sampling was done for
the NFS.

       The maximum values of DCPA reported  by all studies were less than the LHA of 4000
ppb. The maximum value found of TPA in the NFS was 7.2 ppb. DCPA was not found.
Maximum TPA residue values reported (in ppb) by state are: California, 15 (326 for registrant
sponsored study); Iowa, 0.03; Massachusetts, 1.07; New York, 1039 (1477 for registrant
sponsored study); Oregon, 986; and Washington, 1.1.

                                  (b)    Surface Water

       Substantial amounts of DCPA could be available for runoff for  several weeks post-
application (aerobic soil metabolism half-lives of 18-37 days). The intermediate soil/water
partitioning of DCPA (Freundlich Kads values of 5.5,  32.1, 9.4, and 70.3; SCS database Koc of
5000) indicates that DCPA runoff will occur via both dissolution in runoff water and adsorption
to eroding soil. The resistance of DCPA to abiotic hydrolysis and to direct photolysis in water
coupled with only a moderate susceptibility to aerobic biodegradation and a lower susceptibility to
anaerobic biodegradation (anaerobic metabolism half-life 37-59 days) indicates that DCPA will be
somewhat persistent in many surface waters, particularly those with low microbiological activities
and long hydrological residence times. Although the magnitude of its Henry's constant (2.2 X 10"6
atm-m3/mol) is sufficient to indicate some moderate susceptibility to volatilization from water, it
does not appear to be high enough for volatilization to rapidly remove DCPA from surface
waters. The intermediate soil/water partitioning of DCPA indicates that it will be both dissolved in
the water column and adsorbed to suspended and bottom sediment. However, concentrations
should  be greater on suspended and bottom sediment than in the water  column.

       The primary degradate of DCPA is tetrachloroterephthlate acid (TPA). TPA appears to be
substantially more persistent than dacthal and exhibits low soil/water partitioning.  Therefore,
substantial quantities of TPA should be available for runoff for a longer period than the parent
DCPA. Unlike DCPA, most TPA runoff should be in the form of dissolution in runoff water. TPA
should  also persist longer in most surface waters than DCPA, and unlike DCPA, exist primarily
dissolved in the water column.

       According to the pre-1988 listings in STORET, DCPA was detected in 386 of 1995
surface water samples at a 85th percentile of detections of 0.39 ug/L, and a maximum
concentration of 8.5 ug/L.
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       The available data on concentrations of DCPA in surface waters is limited. Although most
detections have been below 1 ug/L, concentrations of 30, 40, and 100 ug/L were reported in a
stream draining a small agricultural watershed in Colorado.

       The USGS (Kimbrough and Litke 1995) collected samples from Cherry Creek at Denver,
CO and from Lonetree Creek at Greely, CO from April 1993 through April 1994. Samples were
collected once a month from October through March, and two or more times per month during
other months. Reported method detection limits for DCPA varied from 0.002 to 0.005 ug/L. In
Cherry Creek which drains a primarily urban watershed, DCPA was detected in 14 of 25 samples
at concentrations ranging from 0.004 to 0.029 ug/L. Five of the samples had DCPA
concentrations > 0.020 ug/L. In Lonetree Creek which drains a primarily agricultural watershed,
DCPA was detected in 21 of 25 samples at concentrations ranging from 0.002 to 100 ug/L.
Eight of the samples had DCPA concentrations > lug/L (30,  1.9, 2.4, 40, 8.9, 6.0, 2.6, and 100
ug/L). The highest concentrations were in samples collected in May 1993 and in April 1994.

       The USGS (MacCoy, Crepeau, and Kuivila 1995) collected samples daily from the San
Joaquin River at Vernalis, and three times per week from the Sacramento River at Sacramento
from October 1992 through September 1993. Samples collected two days in a row from the San
Joaquin River were combined for analysis unless they were collected during runoff events.
Samples were collected close to the center of the rivers with depth integrating samplers. The
samples were filtered through 0.7 u filters and analyzed by  GC/mass spectrometry. The reported
method detection limits for DCPA were 0.063 ug/L and 0.044 ug/L for the San Joaquin and
Sacramento River samples, respectively. DCPA was not detected in any of the Sacramento River
water samples. DCPA was not analyzed for in samples collected from the San Joaquin River from
October 1992 through mid-January 1993. In 176 samples collected from mid-January 1993
through September 1993 that were analyzed for DCPA, the compound was detected in 42
samples, but only 2 of the detections were above the reported method detection limit of 0.063
ug/L (0.091 ug/L and 0.181 ug/L).

       The state of Kansas (Robbins 1987) reported DCPA detections in their surface waters.
Over a period of 13 years from 1973 to 1986, DCPA was detected in 21 samples at
concentrations ranging from 0.03 to 5.6 ug/L with a mean detected concentration of 0.49 ug/L.
The Kansas river and stream sampling network includes up to 110 sampling stations, but no
information was provided on the number of samples collected, where the samples were collected,
the  sampling intervals or the detection limit.

       Washington State (Davis 1993) reported DCPA concentrations ranging from 0.006 to
12.1 ug/L in samples collected from various surface waters in 1992 and 1993. The four
concentrations > 1 ug/L (1.24, 2.2, 3.9 and 12.1 ug/L) were all in samples collected  from
agricultural watersheds east of the Cascades. No information was provided on the number of
samples collected, the sampling intervals or the detection limit.

       DCPA is not currently regulated under the Safe Drinking Water Act (SDWA). Therefore,
no MCL has been established for it, and water supply systems are not required to sample and
analyze for it. However, it has high 1-10 day drinking water HAs (80,000 ug/L), a high lifetime
drinking water HA  (4000 ug/L), and an intermediate soil/water partitioning that should make the

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primary treatment process employed by most water supply systems somewhat effective in
removing it. Consequently, DCPA does not appear to pose a direct substantial risk to surface
source drinking water. Although the low soil/water partitioning of the TPA degradate should
make its removal by primary methods ineffective, no drinking water HAs have been established
for TPA.

             3.     Ecological Exposure and Risk Characterization

       Explanation of the Risk Quotient (RQ) and the Level of Concern (LOC):  The Levels
of Concern are criteria used to indicate potential risk to nontarget organisms. The criteria
indicate that a chemical, when used as directed, has the potential to cause undesirable effects on
nontarget organisms.

       There are two general categories of LOC (acute and chronic) for each of the four
nontarget faunal groups and one category (acute) for each of two nontarget floral groups. In
order to determine if an LOC has been exceeded, a risk quotient must be derived and compared to
the LOC. A risk quotient is calculated by dividing an appropriate exposure estimate, e.g. the
estimated environmental  concentration (EEC), by an appropriate toxicity test effect level, e.g. the
LC50.

       The acute effect levels typically are:

              !      EC25 for terrestrial plants;
              !      EC50 for aquatic plants and invertebrates;
              !      LC50 for fish and birds; and
              !      LD50  for birds and mammals.

       The chronic test results are:

              !      NOEL (No Observable Effect Level) for avian and mammal reproduction
                    studies; and
              !      NOEL or MATC (Maximum Allowable Toxicant Concentration), which is
                    the geometric mean of the NOEL and the LOEL (Lowest Observable
                    Effect Level) for chronic aquatic studies.

       When the risk quotient exceeds the LOC for a particular category, risk to that particular
category is presumed to exist. Risk presumptions are presented below along with the
corresponding LOCs.
                                          67

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Table 22:  Levels of Concern (LOCs)
              Levels of Concern (LOG) and Associated Risk Presumption1
       SPECIES               LOC

       Mammals, Birds
       If the
       acute RQ               >0.5
       acute RQ               >0.2
       acute RQ               >0.1
       chronic RQ              >1
      Fish, Aquatic Invertebrates
      If the
      acute RQ               >0.5
      acute RQ               >0.1
      acute RQ               >0.05
      chronic RQ             >1
      Plants
      If the
      RQ
      RQ
PRESUMPTION
High acute risk
Risk that may be mitigated through restricted use
Endangered species may be affected acutely
Chronic risk, endangered species may be affected
chronically,
High acute risk
Risk that may be mitigated through restricted use
Endangered species may be affected acutely
Chronic risk, endangered species may be affected
chronically
High risk
Endangered plants may be affected
1  Currently, no separate criteria for restricted use or chronic effects for plants exist.

Table 23:  Established Levels of Concern (LOCs)
Established Levels of Concern (LOCs)
Risk
Endpoint/Scenario
Mammalian acute
Mammalian chronic
Avian acute
Avian chronic
Aquatic acute
Aquatic chronic
Non-target insects
Non-target plants
Quotient
EEC/LC50
EEC/LEL*
EEC/LC50
EEC/LEL*
EEC/LC50
EEC/LEL*
Not Quantified
EEC/EC25orEC50
Non-Endangered LOC
0.5
1.0
0.5
1.0
0.5
1.0
N/A
1.0
Endangered LOC
0.1
1.0
0.1
1.0
0.05
1.0
N/A
1.0
        LEL= Lowest Effect Level.  The LEL is a theoretical level which is a value somewhere between the NOEL and the LOEL.
                                                  68

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69

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                     a.      Nontarget Terrestrial Animals

                            (1)     Birds

Acute Risks to Birds

       Definitive LC50 values are not available for birds.  The available data indicate the LC50 is
greater than 5,620 ppm.  It is not considered useful to calculate risk quotients using a "greater
than" value, since the resulting quotient is not an indication of likely acute effects.  The maximum
concentration on food items from the maximum  application rate (15 Ib a.i./acre for turf) would
probably not exceed 3,600 ppm. This is significantly less than the dietary concentration that did
not kill any birds. Therefore, it may be reasonable to conclude that DCPA represents minimal
acute risk to birds including endangered species.

       However, there is uncertainty in this conclusion, since the standard risk assessment
procedure used by the Agency is to apply a safety factor to the avian LC50 values to determine
potential risk.  These safety factors are applied to accommodate possible greater sensitivity of
birds other than those tested and to protect a greater portion of the bird population than 50
percent.

       As stated above, the estimated residues on short grass for turf use are approximately
3,600 ppm.  These residues potentially exceed the LOG of 0.5 (3,600 ppm/>5,620 ppm = 0.6) for
avian acute risk if the LC50 is indeed close to 5,620 ppm.  Normally, when such exposure exceeds
an LOG of 0.5, a conclusion of high risk to birds is made.  When exposure exceeds an LOG of
0.2, a restricted use classification is warranted. If exposure exceeds 0.1, effects to endangered
birds are presumed. However, the LC50 is greater than 5,620 ppm.  Therefore, it cannot be
presumed that the LOG has in fact been exceeded, as the Agency does not know what the true
LC50 value is.

       To address this question, the registrant must conduct a special dietary study with mallard
ducks at higher test levels. If that test shows the  LC50 is substantially greater than 5,000 ppm,
(e.g., at least greater than 18,000 ppm), it would be possible to conclude with a very high degree
of certainty that use rates up to 15 Ib a.i./acre do not represent an acute risk to birds, including
endangered species.

Chronic Risks to Birds

       Long-term exposure to birds is possible since DCPA is persistent. Such exposure is
possible not only from turf treatment, but also on other use sites. Even though the application is
to bare ground, residual seeds, and  other food  items may be contaminated and provide a food
source for some birds. The Agency cannot provide a risk assessment for chronic affects to birds
because of lack of chronic data on birds.  The  Agency requires an avian reproduction study for
mallard duck and bobwhite quail so that chronic effects to birds can be assessed.
                                            70

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                           (2)    Mammals

       Small mammal risk is addressed using acute oral LD50 values converted to estimate a LC50
value for dietary exposure. The estimated LC50 is derived using the following formula:

                           LC50 = LD;o x body weight (g)
                                  food consumed per day (g)

Table 24: Small Mammal Food Consumption
Small Mammal Food Consumption in PPMs
(Based on an LDSO = >5,000 mg/kg)
Small Mammal
Meadow vole
Adult field mouse
Least shrew
Body Weight in
Grams
46 gms
13 gms
5 gms
% of Weight
Eaten Per Day
61%
16%
110%
Food Consumed Per
Day in Grams
28.1 gms
2.1 gms
5.5 gms
Estimated LCSO
Per Day (ppm)
>8,185
>30,952
>4545
The above table is based on information contained in Principles of Mammalogy by D. E. Davis and F. Golly,
published by Reinhold Corporation, 1963.

Acute Risks to Mammals
       The estimated LC50 is then compared to the residues listed above to calculate a risk
quotient (EEC/LC50). The table below indicates the risk quotients for application of DCPA at the
highest application rate of 15 Ib a.i./A on turf.

Table 25: Mammalian Dietary Risk Quotients on Turf
Mammalian Dietary Risk Quotients on Turf
(based on Dietary RQ = EEC/Lowest LC50)
Mammal Type
Meadow vole consuming range grasses
Adult field mouse consuming seeds
Least shrew consuming forage and insects
Food Item
short grasses
leafy crops 1875
short grass 3600
seeds
small insects
Residues
(ppm)
3600
180
870
Risk Quotient
<.43
<.23
<.12
<.006
<0.19
       The table below indicates the risk quotients for application of DCPA at the application
rate of 10.5 Ib a.i./A on vegetables and cotton.
                                           71

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Table 26: Mammalian Dietary Risk Quotients on Vegetables and Cotton
Mammalian Dietary Risk Quotients on Vegetables and Cotton
(based on Dietary RQ = EEC/Lowest LC,n)
Mammal Type
Meadow vole consuming range grasses
Adult field mouse consuming seeds
Least shrew consuming forage and insects
Food Item
short grasses
leafy crops 1313
short grass 2520
seeds
small insects
Residues
(ppm)
2520
126
609
Risk Quotient
<.31
<.16
<.08
<.004
<0.13
       The LOG for high acute risk (0.5) to mammals has not been exceeded.  Residues on short
grass when divided by the meadow vole LC50 do result in a risk quotient which exceeds the LOG
(0.2) for restricted use. Also, endangered mammals exposed to areas treated with DCPA may be
affected (RQ for endangered species LOG of 0.1).

Chronic Risks to Mammals

       The table below indicates the Chronic risk quotients for application of DCPA at various
application rates. For purposes of establishing chronic risk, the two-generation reproduction
study on rats was used, with a NOEL of 1,000 ppm/day. The LOEL for this study was 5,000
ppm/day, resulting in weight loss and an increase in stillborn births. (MRIDs 41905201,
41750103)

Table 27: Mammalian  Chronic Risk Quotients
Mammalian Chronic Risk Quotients
(based on Dietary RQ = EEC/1,000 ppm NOEL)
Use Rate
Ib a.i./A(Crop)
15 (on turf)
10.5 (on vegs & cotton)
10.5 (on vegs & cotton)
9 (on strawberry)
Food Item
short grass
leafy crops
short grass
leafy crops
Residues
3600
1313
2520
1125
Risk
Quotient
3.6
1.3
2.5
1.1
LOC
1
1
1
1
       For ground application to vegetables, cotton, and strawberries, the risk quotients in the
above table may be misleading, overstating the potential risks. This is because for these crops, the
treated area is usually free of vegetation before DCPA is applied.  Alternatively, if the crop is
present during treatment, the spray is directed past the foliage to treat only the bare ground.
Therefore, minimal chronic risk to mammals is concluded for these crops.
                                          72

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       Aerial application (cotton and vegetables) would result in treatment of crop foliage of
cotton and vegetables. However, the maximum level of residues (about 780 ppm) does not
exceed the NOEL for mammals.

       For turf, on the other hand, both aerial and ground treatment is applied to newly emerged
grass or established turf.  So, using maximum residues on typical food items for mammals, the risk
quotients exceed the chronic LOG.

       Other factors are  considered when determining the extent of risk and the certainly that
chronic effects will occur. Uncertainty stems both from using laboratory toxicity test results, and
from limitations in estimating actual exposure.

       1.  The study, from which the chronic NOEL was derived was a 2-generation rat
       reproduction study. It is not known at what duration of exposure at 5000 ppm would be
       required to result in the observed effects. Relatively short exposure to some chemicals has
       been known to cause delayed effects.

       2.  There is a large gap between the NOEL (1000 ppm) and the LOEL (5000 ppm).  It is
       not known at what concentration between those test levels adverse effects may actually
       occur.  The estimated residues exceed the NOEL, but do not exceed the LOEL.

       3.  It is assumed that other mammals would have different sensitivities than the
       representative test organism (laboratory rat). It is not known if wild mammals would be
       more or less sensitive. If they are more sensitive, even the lower residue levels may result
       in sublethal or reproductive risk.
       4.  It is not known how long the residues will last on mammalian food items. It is unlikely
       they will last the full 2 or so months that the rat 2-generation study lasted, especially at
       levels exceeding the NOEL.

       5.  Not all vegetation would contain residue levels exceeding the NOEL.  In turf, where
       the predominant vegetation type is short grass, risk from consumption of maximum or
       typical residues exceed the LOG for chronic risk. Therefore, mammals grazing on treated
       turf would have a high probability of ingesting food items with residues exceeding the
       NOEL of 1000 ppm.  However, in other crop areas, where application is to bare ground,
       the potential for exposure is minimal.

       There seems to be moderate probability that chronic effects to mammals will occur.  It is
not clear how significant this risk is ecologically.  It is possible that endangered mammals may be
affected from turf use.

                           (3)     Insects
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              For beneficial insects, it appears that there will be minimum adverse effects (LD50 >230
       ug/bee) since it is practically nontoxic to bees.

                           b.     Nontarget Aquatic Animals

              Below are Estimated Environmental Concentrations from a 10 hectare watershed basin
       runoff into an hectare pond 6 feet deep after one application.  The exposures are in ppb and are
       derived from a computer program (GENEEC) using Koc values, aerobic soil metabolism half-life,
       and solubility and use rates.

              For calculating the risk quotient (RQ), the exposure (EEC) will be divided by the toxicity
       values of the organisms (fish LC50=30 ppm, aquatic invertebrates LC50=27 ppm and estuarine
       species LC50=0.62 ppm). Since the invertebrates and freshwater fish share a similar LC50 value,
       the toxicity value in the RQ formula will be LC50 = 27 ppm. The RQ is derived from EEC/LC50.
       Below is a table of risk quotients and risk criteria for DCPA:

Table 28: Application Rate with EEC and Risk Quotient for Aquatic Organisms (including endangered
species)



Use Sites
Strawberries

Broccoli, Cabbage, Cauliflower, Kale, Field
Beans, Mung Beans, Snap Beans, Cowpeas,

Potatoes, Yams, Radish, Tomato, Eggplant,
Pepper, Cotton, Watermelon, Cantaloupe,
Cucumber, Squash, Newly Seeded Turf
Established Turf

Maximum Application
Rate
(Ib ai/A)

9.0

10.5




15.0

Method of
Application


ground
aerial
ground


aerial

ground
aerial
EEC (ppb)



33
45
38


53

55
76
RQ1 Freshwater Fish &
Invertebrates


<0.05
<0.05
<0.05


<0.05

<0.05
<0.05
RQ1 Estuarine
Species


0.052
0.07
0.06


0.08

0.09
0.12
       1       High acute risk RQs 0.5, Restricted use RQ s 0.1, Endangered Species RQs 0.05.

                           (1)    Freshwater Fish and Invertebrates

       Application of DCPA will not result in risk that exceeds any of the LOCs for freshwater fish or
invertebrates.  There are no data available to assess the risks to freshwater mollusks. Therefore, in the absence
of data and because the mollusk was the most sensitive aquatic species, it may be appropriate to use the results
from testing with estuarine species to assess risk to freshwater mollusks.  LOCs for restricted use were exceeded
for estuarine mollusks by the turf use when applied aerially. LOCs for endangered mollusk species were
exceeded for all use scenarios.
                                                  74

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                            (2)    Estuarine Species

       Application of DCPA will not result in risk that exceeds any of the LOCs for estuarine species. LOCs for
restricted use were exceeded for estuarine mollusks by the turf use when applied aerially. LOCs for endangered
mollusk species were exceeded for all use scenarios.

                    c.      Nontarget Plants

                            (1)    Terrestrial and Semi-aquatic

              Nontarget terrestrial plants inhabit non-aquatic areas. Nontarget "semi-aquatic" plants are plants
that usually inhabit low-lying wet areas that may or may not be dry in certain times of the year. These plants are
not obligatory aquatic plants in that they do not live in a continuously aquatic environment.  The terrestrial and
"semi-aquatic" plants are exposed to pesticides from runoff, drift or volatilization.
       With the available data, given the fact that little or no effect was seen at the 9 Ib ai/acre application rate,
LOCs would not be exceeded for terrestrial plants. Since there is little confidence that the test data reflect the
potential toxicity of DCPA to terrestrial plants, numerical estimates of risk will not be made.  Calculating
exposure and calculating risk quotients based on what is considered misleading data would yield equally
misleading risk conclusions.

It is recommended that additional (Guideline 123-1 a & b) vegetative vigor and seedling emergence studies (tier
II) be done with sensitive species.

                            (2)     Aquatic

              Runoff exposure is from preliminary EEC (GENEEC).  Spray drift is assumed to be 5 percent of
the application rate.

       The risk assessment made for aquatic vascular plants is from the surrogate duckweed Lemna gibba.
Algae and diatom risk assessment are useful indicators to determine impact to food sources of aquatic organisms.
The EC50 values are similar for algae, diatoms and Lemna gibba.  Therefore, the RQ will reflect all aquatic
species from the toxicity value of EC50= 11 ppm.
                                                  75

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Table 29: Application Rate & EECs & Risk Quotients for Nontarget Aquatic Plant Species (including
endangered species)


Use Site
strawberries

broccoli, cabbage, cauliflower, kale,
collards, field bean, cowpeas, snap
bean, mung bean, horseradish, onion,
potato, radish, sweet potato, yams,
cotton, tomato, eggplant, pepper,
cucumber, squash, watermelon,
cantaloupe, newly seeded turf
established turf

Maximum
Application Rate
(Ib ai/A)
9

10.5






15

Method of
Application

ground
aerial
ground



aerial


ground
aerial
Estimated Environmental
Concentration
(ppb)
33
45
38



53


55
76
Risk Quotient* for
Aquatic Plants
(EEC/EC!0)
<1
<1
<1



<1


<1
<1
       * Endangered and non-endangered plants species have the same LOG which is 1.0.

             From the available data, minimal adverse impact is expected for aquatic plants from the
       labeled uses of DCPA.
                                                  76

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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 ingredient
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 DCPA. 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 DCPA
under the conditions specified in the RED. Appendix B identifies the generic data requirements
that the Agency reviewed as part of its determination of reregistration eligibility of DCPA, 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 DCPA and to determine that DCPA can be used without resulting in
unreasonable adverse effects to humans and the environment, if used according to the labels as
amended by this RED.  The Agency therefore finds that all products containing DCPA as the
active ingredient are eligible for reregistration under the conditions specified in this RED.  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, published scientific literature, etc. and the data identified in Appendix B.
Although the Agency has found that all uses of DCPA are eligible for reregistration under the
conditions specified in this RED, it should be understood that the Agency may take additional
appropriate regulatory action, and/or require the submission of additional data to support the
registration of products containing DCPA, if new information comes to the Agency's attention or
if the data requirements for registration (or the guidelines for generating such data) change.

       B.     Determination of Eligibility Decision

              1.      Eligibility Decision

       Based on the reviews of the generic  data for the active ingredient DCPA, the Agency has
sufficient information on the health effects of DCPA and on its potential for causing adverse
effects in fish and wildlife and the environment.

       The Agency concludes that products containing DCPA for all non-turf uses are eligible for
reregistration. The Agency has determined  that  such DCPA products, labeled and used as
specified in this Reregistration Eligibility Decision, will not pose unreasonable risks or adverse
effects to humans or the environment.
                                            77

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              2.     Eligible and Ineligible Uses

       The Agency is unable to make an eligibility decision regarding the use of DCPA on turf at
this time. The Agency has identified several risks of regulatory concern associated with DCPA's
turf use. These risks include carcinogenic risk (from DCPA and its impurities) to children playing
on lawns post-treatment, carcinogenic risk posed through contaminated drinking water, chronic
risks to wild mammalian species (including endangered species), and acute risks to estuarine and
freshwater mollusks.  The Agency will conduct a risk-benefits assessment before determining
whether DCPA's use on turf is eligible for reregi strati on. The Agency will also refine some of the
risk estimates, as a final report regarding leaching of DCPA and its metabolites to groundwater
will be submitted to the Agency during the summer of 1996.

       The Agency will announce the eligibility decision for the turf use through a Federal
Register Notice, as an amendment to this document.

       C.      Regulatory Position

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

              1.     Tolerance Discussion

                    a.     HCB and dioxin/furans

       Although DCPA end-use formulations may contain minute amounts of HCB and
dioxin/furans as impurities, tolerances for contaminants are not established on food commodities.
The Food and Drug Administration (FDA) and the U.S. Department of Agriculture routinely
monitors the food supply. Unacceptable levels of such contaminants would be identified by the
FDA and affected crops would be removed from the market. However, the FDA monitoring
program to date has not found any crops treated with DCPA to show residues of HCB.

                    b.     DCPA Tolerance Reassessment

       Tolerances  are currently established for DCPA in or on beans, peas, cantaloupes, corn,
cottonseed, cress, cucumbers, eggplant, garlic, honeydew melons, horseradish, lettuce, onions
(green and dry bulbs), peppers, pimentos, potatoes, rutabagas, soybeans, squash (summer and
winter), strawberries, sweet potato, tomatoes, turnips, Brassica (cole), watermelon, yams, and
radish.

Tolerances Listed Under 40 CFR §180.185(a):

       The tolerances listed in 40 CFR §180.185(a) are for combined residues of DCPA and its
metabolites monomethyl tetrachloroterephthalic acid (MTP)  and tetrachloroterephthalic acid
                                           78

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(TPA). A summary of the DCPA tolerance reassessment and modifications in commodity
definitions are presented in Table 30.

       Sufficient data are available to ascertain the adequacy of the established tolerances listed in
40 CFR §180.185(a) for the following commodities: beans which include black-eyed peas
(succulent and dried), cantaloupes, cottonseed, cress, cucumbers, eggplant, garlic, honeydew
melons, horseradish, onions, peppers, pimentos, potatoes, squash (summer and winter),
strawberries, sweet potatoes, yams, tomatoes, turnips, brassica leafy vegetables, and watermelons.

       ISK Biosciences Corp. is not supporting uses of DCPA on lettuce, soybeans, corn and
rutabagas. EPA will reassess the existing tolerances for residues in/on these crops on completion
of the review of the confined/field rotational crop studies. However, preliminary examination of
these studies indicates the need for inadvertent residue tolerance on crops rotated to DCPA-
treated fields.

Tolerances Listed Under 40 CFR §180.185(b)

       The tolerances listed in 40 CFR §180.185(b) are for a regional registration as defined in
40 CFR §180.1(n) for the combined residues of DCPA and its metabolites MTP and TPA in/on
radish roots and tops.  Sufficient data are available to ascertain the adequacy of these established
tolerances.

       The tolerance for cress (upland) listed under 40 CFR §180.185(a) was established for a
regional registration and should therefore be listed under 40 CFR §180.185(b).

New Tolerances Required Under 40 CFR §180.185:

       The updated Livestock Feeds Table (9/95) indicates that data depicting residues of DCPA
and its metabolites in or on cotton gin byproducts (gin trash), cowpea forage, and hay are
required. The registrant must propose tolerances for these commodities once adequate data have
been submitted and evaluated. In lieu of tolerances on cowpea commodities, the registrant may
restrict the use of DCPA on beans to those varieties that are used for human consumption only.

       Tolerances for animal commodities have not been established. The available ruminant
metabolism and poultry feeding studies indicate  that tolerances may be needed.  The need for
tolerances for animal commodities will be determined following review of the required data on
poultry metabolism and ruminant feeding studies.

New Tolerances Proposed Under 40 CFR §180.185(b):

       A tolerance for parsley at four ppm, with a regional registration for California only, has
been proposed for the combined residues of DCPA and its metabolites MTP and TPA. The
petitioner has been required to submit residue data for DCPA residues in/on parsley flakes
processed from DCPA-treated parsley.
                                           79

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Table 30: Tolerance Reassessment Summary
Commodity
Current Tolerance
(ppm)
Tolerance
Reassessment (ppm)
Comment/Correct Commodity
Definition
Tolerances listed under 40 CFR 180.185(a):
Beans, field dry
Beans, mung, dry
Beans, snap, succulent
Peas, southern, black-eyed
Cantaloupes
Corn, field (forage and
fodder)
Corn, sweet (forage and
fodder)
Corn, pop (forage and
fodder)
Corn, sweet (K+CWHR)
Corn, grain (including field
and pop)
Cottonseed
Cress, upland
Cucumbers
Eggplant
Garlic
Honeydew melons
Horseradish
Lettuce
Onions (green and dry bulbs)
Peppers
Pimentos
Potatoes
Rutabagas
2
1
0.4
0.05
0.2
1
1
1
1
1
2
2
1
2
2
2
2
2
1
TBD

0.2
1
1
1
1
1
2
TBD
1
2
Revoke
2
TBD
A single tolerance for residues
in/on beans (dried and
succulent) is
appropriate/Beans, dried and
succulent
—
No registered uses exist.
Tolerances will be reassessed in
conjunction with review of field
rotational crop studies.

Cotton, undelinted seed
Tolerance should be
appropriately listed under 40
CFR§180.185(b).
...
—
...
—
...
No registered uses exist.
Tolerances will be reassessed in
conjunction with review of field
rotational crop studies.
...
—
The peppers tolerance applies
to pimentos. A separate
pimentos tolerance is not
necessary.
—
No registered uses exist.
Tolerances will be reassessed in
conjunction with review of field
rotational crop studies.
                                      80

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Commodity
Soybeans
Squash (summer and winter)
Strawberries
Sweet potato
Tomatoes
Turnips, greens
Turnip, root
Vegetables, leafy, Brassica
(cole)
Watermelon
Yams
Current Tolerance
(ppm)
2
1
2
2
1
5
2
5
1
2
Tolerance
Reassessment (ppm)
TBD
1
2
2
1
5
2
5
1
2
Comment/Correct Commodity
Definition
No registered uses exist.
Tolerances will be reassessed in
conjunction with review of field
rotational crop studies.
—
...
—
...
Turnip, tops
...
...
...
—
Tolerances listed under 40 CFR 180.185(b):
Radish, root
Radish, tops
2
15
2
15
—
—
New Tolerances Required under 40 CFR 180.185:
Cowpea, forage
Cowpea, hay
Cotton gin, byproducts
None
None
None
TBD
TBD
TBD
Data are required.
Data are required.
Data are required.
New Tolerances Proposed under 40 CFR 180.185(b)
Parsley
None
TBD
A 4 ppm tolerance with
regional registration has been
proposed (PP#OE3883).
Additional data are required.
 Codex Harmonization

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

              2.     Tolerance Revocations and Import Tolerances

       During the Agency's reregi strati on process, the registrant decided not to support the use
of DCPA on lettuce, soybeans, corn, and rutabagas.  The use of DCPA on these four crops has
been voluntarily cancelled. Normally, once a pesticide use is no longer registered in the U.S., the
related pesticide residue tolerance is no longer needed. It is the Agency's policy to propose
revocation of a tolerance following the deletion of a related food use from a registration, or
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following the cancellation of a related food-use registration. The Agency has the responsibility
under FFDCA to revoke a tolerance on the grounds that the Agency cannot conclude that the
tolerance is protective of public health.

       However, in the case of DCPA, the Agency is not seeking revocation of these tolerances,
as it normally would under the above policy.  The registrant is supporting rotational crop
tolerances for these four commodities, thereby allowing DCPA residues which result from use on
registered crops previously grown in the same field. The reassessed tolerances will be determined
once field rotational crop residue data has been submitted to the Agency and reviewed.
Subsequently, the tolerances of DCPA on these four commodities may be significantly reduced.

       The Agency recognizes, however, that interested parties may want to retain a tolerance
which is higher than the rotational crop tolerance (yet to be determined) in the absence of a U.S.
registration, to allow legal importation of treated food into the U.S.  To assure that all food
marketed in the U.S. is safe, under FFDCA, the Agency requires the same product chemistry and
toxicology data for such import tolerances (tolerances without related U.S. registrations) as are
required to support U.S. food use registrations and any resulting tolerances. In addition, the
Agency requires residue chemistry data (crop field trials) that are representative of growing
conditions in exporting countries in the same  manner that the Agency requires representative
residue chemistry data from different U.S. regions to support domestic use of the pesticide and
the tolerance.

       Parties interested in  supporting an existing DCPA tolerance as an import tolerance should
ensure that all of the data noted above are available to the Agency, so that the Agency may
determine whether maintenance of the tolerance would be protective of the public health.

              3.      Regulation of DCPA Impurities

       The Agency requires pesticide registrants to establish a certified upper limit for each
"impurity of toxicological significance associated with the active ingredient and found to be
present in any sample  of the product" (40 CFR part 158.175).  These certified limits, once
accepted by  the Agency, become legally binding levels representing the maximum allowable
contamination of associated DCPA formulations. The Agency has identified HCB and all of the
15 dioxin/furan congeners for which DCPA was analyzed as being of toxicological significance.

       There is an existing  certified upper limit for HCB of 0.3% and a preliminary certified
upper limit for the 2,3,7,8-TCDD congener. However, the registrant must propose certified
upper limits for each of the  remaining dioxin/furans for which a positive detection was reported to
the Agency.

              4.      Dietary Risk

       Acute dietary risk assessments were not necessary since there were no acute toxicological
endpoints of concern for DCPA or its impurities. Chronic and carcinogenic dietary risk was
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assessed, however, due to exposure to DCPA, HCB, and dioxin/furans. Chronic risk estimates
for the U.S. population and all subgroups were well below 100% of the RfD for DCPA, HCB,
and dioxin/furans. Based on these estimates, the Agency concludes that DCPA use does not pose
a significant chronic dietary risk.

       Carcinogenic risk estimates for exposure to DCPA, HCB, and dioxin/furans through food
were 3.5 x 10"7, 7 x 10"7,  and 7 x 10"8, respectively. All of these risk estimates are within the
range (zero to 1 x 10"6) generally considered to be negligible by the Agency.  Thus, the Agency
concludes that DCPA use does not pose a significant excess lifetime cancer risk.

             5.     Drinking Water Risk

       Risk due to exposure to DCPA and its metabolites which have been detected in ground
and surface water was assessed. The Agency is concerned that the public may be exposed to
DCPA and its metabolites through drinking water.  Since there is no Maximum Contaminant
Level (MCL) established for DCPA or its metabolites, there is no enforceable federal regulatory
oversight of DCPA and its metabolites in public drinking water systems. Therefore, the Agency
assumed that the public may be exposed to the contamination levels found in ground and surface
water.

       The Agency's  Office of Water has established a Health Advisory (HA) for DCPA at 4000
ppb. Although not enforceable, a HA benchmarks the concentration of DCPA in drinking water
that is not expected to cause any adverse non-carcinogenic  effects over a lifetime with a margin of
safety. The current HA was calculated using an RfD of 0.5 mg/kg/day based on a 1963 two year
rat study. Newer studies reviewed in this document have led to the RfD being lowered to 0.01
mg/kg/day.

       If a new HA were to be calculated with the revised  RfD of 0.01 mg/kg/day, the HA would
likely decrease to 70 ppb. The Agency calculated this lowered HA estimate based on the
following formula, which uses default assumptions for body weight, amount of water consumed,
and the relative source contribution for DCPA exposure.

       RfD(70 kgVO.2 RSO = 70 ug/1 (ppb)
       (2 L/day)

       The information regarding the reevaluation of DCPA's RfD will be forwarded to the Office
of Water for HA recalculation as resources permit.

       The Agency assessed both chronic (non-cancer) and carcinogenic risk due to exposure to
DCPA and its metabolites through contaminated ground and surface water.  The Agency used
annual contamination averages from five geographic regions as potential drinking water exposure
values.  The highest annual average was  50 ppb in New York from a turf study. Although this
represents approximately 71% of the HA, it only corresponds to 11% of RfD. Even if part of this
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population were exposed to the maximum 3% of the RfD from other dietary sources, the chronic
dietary risk would still be considered minimal.

       Individual excess lifetime cancer risk from the New York turf site was 1.7 x 10"6.  The
next highest risk estimate is based on data from Suffolk County, New York. The risk estimate
from that site is 9.7 x 10"7.  DCPA's registrant has voluntarily withdrawn from selling the product
in Suffolk, New York. Exposure values from all other sites resulted in risks below the Agency's
cancer benchmark of 1 x 10"6.

       Based on these estimates, the Agency concludes that DCPA and its metabolites do not
currently pose a significant cancer or chronic non-cancer risk from non-turf'uses to the overall
U.S. population from exposure through contaminated drinking water.

              6.      Contamination of Water Resources  and Mitigation Measures

       One of DCPA's metabolites, TPA, is known to leach to groundwater. TPA has been a
frequently detected pesticide residue in groundwater studies.  The Agency is continuing to require
all DCPA products to bear a groundwater advisory statement.

       In addition, the registrant has voluntarily agreed to limit the manufacture of DCPA
technical grade active ingredient for use within the U.S. to current production levels. This will
help to ensure that contamination rates do not significantly increase in the future.  Since DCPA is
produced intermittently, the production limit will be set at the average of the last three production
campaigns, allowing for a 5% variance.  The Agency will enforce this production cap through
review of manufacture data which the registrant is required to submit under FIFRA, Section 7.
The registrant will produce no more than the agreed upon limit every 3  calendar years, beginning
in January, 1997.

       The registrant has also voluntarily agreed to drop the fall turf application from their labels
in order to reduce the usage of DPCA.  This will lower the maximum application rate  on turf from
15 Ibs. active ingredient/Acre to 12 Ibs. active ingredient/Acre. There are additional groundwater
data due to the Agency in the summer of 1996.  Once those data are reviewed, the Agency will
reassess potential drinking water risk and evaluate the need for additional groundwater protection
measures.

       Through the reregi strati on process, the Agency has also identified concerns for the
contamination of surface water by DCPA. Consequently, the Agency is requiring all DCPA
products to bear a surface water advisory statement as well. Refer to Section V of this document
for the language of the groundwater and surface water advisories.

              7.      Occupational Risk

       Risk assessments were performed to assess the individual excess lifetime cancer risk from
DCPA and HCB resulting from occupational exposure to DCPA.  The Agency will not generally
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allow non-dietary risks to exceed 10"4, except in cases where EPA has determined that benefits
exceed the risks.

       The highest risk for both commercial applicators and private applicators (farm owners) is
associated with the use of the wettable powder formulation.  For the commercial applicator, the
risk for DCPA was estimated to be 7.5 x 10'5 and for HCB (in DCPA) to be 1.9 x 10'4.  The
Agency is requiring mixer/loader/applicators using DCPA wettable powders to wear a dust-mist
respirator fitted with a TC-21 filter to mitigate these risks. Wearing a dust-mist respirator reduces
the risks to 4.0 x 10'5 and 1.3 x 10'4 for DCPA and HCB, respectively.

       For the private applicator, the risk for DCPA was estimated to be 1.6 X 10"6 and for HCB
(in DCPA) to be 4.6 X 10"6. The Agency concludes DCPA does not pose a significant individual
excess lifetime cancer risk for occupational (commercial and private) applicators.

       Risk from exposure to DCPA and HCB through worker reentry into a cucumber field was
assessed. Harvesting cucumbers one day after application resulted in risk estimates of 1.8 x 10"4
for DCPA and 3.2 x 10"4 for HCB. Longer reentry periods only minimally reduced risk estimates.
However, the Agency believes that the worker  exposures are overestimates.  These scenarios
were based solely on a foliar dissipation study,  not on dermal exposure studies. DCPA's
registrant is a member of a task force which will address dermal exposure for hand labor tasks
required by various crops, such as cucumber harvesting. The risk assessment will be refined when
the task force submits it dermal exposure data.

       Only rough estimates of risk for occupational exposure to dioxin/furans were calculated,
since there are no foliar dissipation or dermal absorption data for dioxin/furans. The Registration
Standard required foliar dissipation data for both HCB and dioxin/furans.  However, the registrant
asserted that the dioxin/furan data could not be  provided due to the unavailability of analytical
methodology to detect the expected levels  of dioxin/furans.  The Agency agreed that the
theoretical residue level was lower than 1991 analytical methods could detect.

       The wettable powder scenario produced the highest dioxin/furan risk for
mixer/loader/applicators with a 1.6 x 10"6 estimate.  Workers entering the cucumber harvesting
field at zero days after treatment were estimated to be exposed to a 8 x 10"6 risk. Both of these
risk estimates should be considered as overestimates since conservative assumptions were made in
estimating these exposures.

              8.      Residential Risk

       Risks to children playing on a treated lawn were assessed for exposure to DCPA and
HCB.  These risks were estimated by assuming a child would be exposed to a DCPA product
applied to their lawn once a year. The exposure is assumed to be present for 14 continuous days
following treatment. The scenario presumed a child might play outdoors several times a day and
not receive a bath until 10 hours after the first play period. It was further assumed that children
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between the ages of 2 and 6 weigh 17 kilograms and weigh 31 kilograms between the ages of 6
and 12.

       The resulting risks from DCPA and HCB to children playing on an irrigated lawn are 5.6 x
10"7 and 3.9 x 10"7, respectively.  The risks from DCPA and HCB to children playing on non-
irrigated lawns are 2.0 x 10"6 and 2.7 x 10"6, respectively. Based in part on these estimates, the
Agency has  decided to assess the benefits from turf use before making an eligibility decision.
However, to reduce risks to children in the interim period, the Agency is requiring DCPA labels
to recommend residential lawns be watered after DCPA product use and that reentry not occur
until the grass has dried.

       The rough estimation of risk from dioxin/furans to children playing on non-irrigated lawn
one hour after treatment is 3.9 x  10"7.  Again, dioxin/furan risk values could be overestimated
since neither foliar dissipation or dermal absorption data are available for dioxin/furans.

              9.      Ecological Effects (Non-Endangered Species)

       Current risk estimates indicate minimal acute risks to birds from DCPA use. However,
there is uncertainly regarding the actual LC50 values available for birds.  To  address this concern,
the Agency is requiring a dietary study using mallard ducks. In addition, long-term exposure to
birds is possible; yet there are no data on DCPA to assess chronic effects to  birds.  Consequently,
the Agency is requiring avian reproduction studies using the mallard duck and bobwhite quail so
that chronic effects to birds can be assessed.

       Levels of Concern (LOCs) regarding chronic effects to mammals are exceeded for all four
use scenarios.  In the three crop scenarios, the risk is overstated because DCPA is applied as a
pre-emergent herbicide, when the land is free of vegetation. If the crop has  emerged,  DCPA
sprays would be directed past the foliage to treat the bare ground. Therefore, the Agency does
not expect to see substantial mammalian exposure to DCPA through grazing on or near cropland.
       The remaining use for which the mammalian chronic LOG is exceeded is turf.
The restricted use LOG for freshwater and estuarine mollusks is also exceeded by the turf use,
aerial application. In the interim period while the Agency assesses benefits from the turf use,
spray drift advisory language is being required which may mitigate the risk to mollusk species.

       Numerical estimates of risk were not calculated for terrestrial and semi-aquatic nontarget
plant species. Since little or no effect was seen at 9 Ibs a.i./acre application rate in the toxicity
study, LOCs are not likely to be exceeded. Since it is unlikely that a herbicide would not affect
plant species, the Agency is requiring additional testing of sensitive species in the areas of
vegetative vigor and seedling emergence.  Minimal adverse impact is expected for aquatic plants
from DCPA use.

              10.     Endangered Species
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       The Agency has concerns about the exposure of threatened and endangered mammal and
mollusk species to DCPA as discussed above in the Section III.  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
modifications or a generic product label statement, requiring users to consult county-specific
bulletins. These bulletins would provide information about specific use limitations to protect
endangered and threatened species in the county. Consultations with the Fish and Wildlife
Service may be necessary to assess risks to newly listed species or from existing or proposed new
uses.

       The Agency plans to publish a description of the Endangered Species Program in the
Federal Register in the future. 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.

              11.    Spray Drift

       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 DCPA product
labels/labeling as specified in Section V of this document.  Once the Agency completes its
evaluation of the new data base submitted by the Spray Drift Task Force, a membership of U.S.
pesticide registrants, the Agency may impose further refinements in spray drift management
practices to further reduce off-target drift and risks associated with this drift.  Actions taken to
reduce spray drift will help to mitigate contamination of surface water, reduce risk to estuarine
species, and reduce harm to nontarget crops and plants.

              12.    Labeling Rationale

THE WORKER PROTECTION STANDARD (WPS)

Scope of the Worker Protection Standard

       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,
fiber plants, trees, turf grass, flowers, shrubs, ornamentals, and seedlings). Uses within the scope
include not only uses on plants, but also uses on the soil or planting medium the plants are (or will
be) grown in.
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       Current registered uses of DCPA include uses within the scope as well as some uses
outside the scope of the Worker Protection Standard for Agricultural Pesticides (WPS). Those
that are outside the scope of the WPS include:

       •       on plants grown for other than commercial or research purposes, which may
              include homeowner uses; and

              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).

Compliance with the WPS

       Any product whose labeling can be reasonably interpreted to permit 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,
              the labeling of all products within the scope of those notices must meet the
              requirements of the notices when the products 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, the labeling of all products within the scope of those notices  must meet the
              requirements of the notices when the products are distributed or sold by any
              person.

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

       Current labels for end-use products containing DCPA do not include engineering control
requirements for mixers, loaders, or applicators, such as closed mixing systems or closed tractor
cabs.

       For each end-use product, PPE  requirements for pesticide handlers are set during
reregi strati on in one of two ways:
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1. If EPA determines that no regulatory action must be taken as the result of the acute effects or
other adverse effects of an active ingredient, the PPE for pesticide handlers will be based on the
acute toxicity of the end-use product. For occupational-use products, PPE must be established
using the process described in PR Notice 93-7 or more recent EPA guidelines.

2. If EPA determines that regulatory action on an active ingredient must be taken as the result of
very high acute toxicity or to certain other adverse effects, such as allergic effects or delayed
effects (cancer, developmental toxicity, reproductive effects, etc.):
       #      In the RED for that active ingredient, EPA may  establish minimum or "baseline"
              handler PPE requirements  that pertain to all or most 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 the 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.

       Personal protective equipment requirements usually are set by specifying one or more pre-
established PPE units - sets of items that  are almost  always required together. For example, if
chemical-resistant gloves are required, then long-sleeve shirts,  long pants, socks, and shoes are
assumed and are also included in the required minimum attire.  If the requirement is for two layers
of body protection (coveralls over a long- or short-sleeve shirt and long or short pants), the
minimum must also include (for all handlers) chemical-resistant footwear and chemical-resistant
headgear for overhead exposures and (for mixers, loaders, and  persons cleaning equipment)
chemical-resistant aprons.

       Occupational-Use Products

       EPA has determined that regulatory action regarding the establishment of active-
ingredient-based minimum PPE requirements for occupational  handlers must be taken for DCPA.
 For handlers, the exposure/risk assessments assumed that chemical-resistant gloves were worn in
the following handler scenarios:  (1)  mixers/loaders using liquid formulations, (2) mixers/loaders
using wettable powder formulations, (3) mixer/loader/applicators applying by shaker can, and (4)
mixers/loaders/applicators applying by backpack sprayer. Therefore, chemical-resistant gloves
will be required for occupational handlers in these scenarios.

       EPA notes that the only data available for assessing exposure for cultivator mounted
granular spreaders (scenario V) were  studies in which the applicator was inside an enclosed cab.
The risk levels for this exposure scenario are quite low (9.4 x 10"9 for DCPA and 3.1 x 10"8 for
HCB for private applicators; and 9.4 x 10'8 for DCPA and 3.1 x 10'7 for HCB for commercial
applicators); therefore, enclosed tractor cabs will not be required for application of DCPA by
cultivator mounted granular spreaders.

       WPS and NonWPS Uses:
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       Since potential handler exposure is similar for WPS and nonWPS uses, there is only one
set of active-ingredient-based minimum (baseline) PPE requirements for occupational uses of
DCPA (specified in Section V). These requirements must be followed in the labeling of all DCPA
end-use products intended primarily for occupational use.
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       Homeowner-Use Products

       EPA is not establishing minimum (baseline) handler PPE for DCPA end-use products that
are intended primarily for homeowner uses, because the Agency has determined that the
frequency, duration, and degree of exposure by such users do not warrant such risk mitigation
measures.

Entry Restrictions

Occupational-Use Products (WPS Uses)

       Current registered uses of DCPA include uses within the scope, as well as uses outside the
scope of the Worker Protection Standard for Agricultural Pesticides (WPS).

       Restricted Entry Interval — Under the Worker Protection Standard (WPS), interim
restricted entry intervals (REI) for all uses within the scope of the WPS are based on 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
REIs established by the Agency prior to the promulgation of the WPS: (1) product-specific REIs
established on the basis of adequate data, and (2) interim REIs that are longer than those that
would be established under the WPS.

       For occupational end-use products containing DCPA as an active ingredient, a 12-hour
restricted-entry interval will be established 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 DCPA is categorized as toxicity category IV for acute dermal toxicity,
category IV for acute oral  toxicity, category III for acute inhalation toxicity, category III for eye
irritation potential, and category IV for  dermal irritation and the results of the post-application
risk assessment for agricultural crops indicates that regulatory action beyond the 12-hour REI is
not warranted.  However, since DCPA and HCB are both quantifiable carcinogens, DCPA is not
a candidate for reducing the REI from 12 hours to 4 hours.

       Early-Entry PPE  — The WPS establishes very specific restrictions on entry by workers to
areas that remain under a restricted-entry interval if the entry involves contact with treated
surfaces. Among those restrictions is a prohibition of routine entry to perform hand labor tasks
and the  requirement that personal protective equipment be worn.  Personal protective equipment
requirements for persons who must enter areas that remain under a restricted-entry interval are
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based on the toxicity concerns about the active ingredient. The requirements are set in one of two
ways.

       1.      If EPA determines that no regulatory action must be taken as the result of the
              acute effects or other adverse effects of an active ingredient, it establishes the
              early-entry PPE requirements on the basis of the acute dermal toxicity category,
              skin irritation potential category, and eye irritation potential category of the active
              ingredient.

       2.      If EPA determines that regulatory action on an active ingredient must be taken as
              the result of very high acute toxicity or to certain other adverse effects, such as
              allergic effects or delayed effects (cancer, developmental toxicity, reproductive
              effects), it may establish early-entry PPE requirements that are more stringent than
              would be established otherwise.

       Since DCPA is classified as category IV for skin irritation potential and IV for acute
dermal toxicity, and EPA has determined that no regulatory action must be taken due to the acute
effects or other adverse effects of DCPA, the PPE for dermal protection required for early entry is
the minimum early-entry PPE permitted under the WPS: coveralls, chemical-resistant gloves,
socks, and shoes. Since DCPA is classified as toxicity category III for eye irritation potential, no
protective eyewear is required.

       WPS Notification Statement:

       Under the WPS, the labels of some pesticide products must require employers to notify
workers about pesticide-treated areas orally as well as by posting of the treated areas.  The
reregistration process also may decide that a product requires this type of "double notification."

       EPA has determined that double notification is not required for DCPA end-use products.

       Occupational-Use Products  (NonWPS Uses)

        Since EPA has concerns about immediate post-application exposures to persons after
nonWPS occupational uses of DCPA, it is establishing entry restrictions for all nonWPS
occupational uses of DCPA end-use products. For specific requirements, refer to Section V of
this document.

       Homeowner-Use Products

       Since EPA has concerns about immediate post-application exposures to persons after
homeowner applications of DCPA, it  is establishing entry restrictions for all homeowner uses of
DCPA end-use products. For specific requirements, refer to Section V of this document.
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Other Labeling Requirements

       The Agency is also requiring other use and safety information to be placed on the labeling
of all end-use products containing DCPA. For the specific labeling statements, refer to Section V
of this document.
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V.     ACTIONS REQUIRED OF REGISTRANTS

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

       A.     Manufacturing-Use Products

              1.     Additional Generic Data Requirements

       The generic data base supporting the reregi strati on of DCPA for the above eligible uses
has been reviewed and determined to be substantially complete. However, confirmatory data are
required in the areas of residue chemistry, ecological effects, and occupational exposure, as listed
below. The Data Call-In Notice in the Appendices outlines the specific data requirements and the
time frames for submission of the data.

       Guideline             Study
       133-3               Post-application dermal passive dosimetry exposure
       133-4               Post-application inhalation passive dosimetry exposure
       231                 Dermal exposure study
       232                 Inhalation exposure study
       171 -4(b)             Poultry Metabolism
       171-4(e)              Storage Stability
       171 -4(j)             Cattle Feeding study
       171-4(j)             Poultry Feeding study (on reserve pending review of poultry
                           metabolism study)
       71-4(a)             Avian Reproduction - Quail
       71-4(b)             Avian Reproduction - Mallard duck
       123-1 (a)              Seedling  emergence
       123-l(b)             Vegetative vigor (using sensitive species)

              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 use(s): 	
 (fill blank only with those uses that are being supported by MP registrants)."

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

PPE/Engineering Control Requirements for  Pesticide Handlers

       For sole-active-ingredient end-use products that contain DCPA, the product labeling
must be revised to adopt the handler personal protective equipment/engineering control
requirements set forth in this section. Any conflicting PPE requirements on the current labeling
must be removed.

       For multiple-active-ingredient end-use products that contain DCPA, the handler
personal protective equipment/engineering control requirements set forth in this section must be
compared to the requirements on the current labeling and the more protective must be retained.
For guidance on which requirements are considered more protective, see PR Notice 93-7.

Products Intended Primarily for Occupational Use (WPS and nonWPS)

       Minimum (Baseline) PPE/Engineering Control Requirements

       EPA is establishing minimum (baseline) PPE for some occupational uses of DCPA. These
minimum (baseline) PPE are listed below. PPE for all formulations not listed below will be based
on the toxicity of the end-use products as  assessed during product reregi strati on.
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             For liquid concentrate formulations:
             Mixers and loaders must wear:
             —Long-sleeve shirt and long pants,
             —Socks plus shoes,
             —Chemical-resistant gloves*.

             For wettable powder formulations:
             Mixers, loaders, and applicators must wear:
             —Long-sleeve shirt and long pants,
             —Socks plus shoes,
             —Chemical-resistant gloves*.
             —a dust mist respirator with a TC-21C filter

             For applications using a shaker can or backpack sprayer:
             Applicators must wear:
             -Long-sleeve shirt and long pants,
             —Socks plus shoes,
             -Chemical-resistant gloves*.

             * For the glove statement, use the statement established for DCPA through the
             instructions in  Supplement Three of PR Notice 93-7.

       Determining PPE Requirements for End-use Product Labels

       The PPE that would be established on the basis of the acute toxicity category of the end-
use product must be  compared to the active-ingredient-based minimum (baseline) personal
protective equipment 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 requirements 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

       Minimum (baseline) PPE Requirements

       EPA is not establishing active-ingredient-based minimum (baseline) handler PPE for
DCPA end-use products that are intended primarily for homeowner use.
                                          96

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       Determining PPE Requirements for End-Use Product Labels

       Any necessary PPE for each DCPA end-use product intended primarily for homeowner
use will be established on the basis of the end-use product's acute toxicity category.

       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)."

Entry Restrictions

       For sole-active-ingredient end-use products that contain DCPA, the product labeling
must be revised to adopt the entry restrictions set forth in this section. Any conflicting entry
restrictions on the current labeling must be removed.

       For multiple-active-ingredient end-use products that contain DCPA, the entry
restrictions set forth in this section must be compared to the entry restrictions on the current
labeling and the more protective must be retained. A specific time period in hours or days is
considered more protective than "sprays have dried" or "dusts have settled."

Products Intended Primarily for Occupational Use

       WPS Uses

       Restricted-entry interval:

       A 12-hour restricted-entry interval (REI) is required for uses within the scope of the WPS
on all DCPA end-use products.

       Early-entry personal protective equipment (PPE):

       The PPE required for early entry is:
             - coveralls,
             — chemical-resistant gloves, and
             — 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.
                                           97

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       NonWPS uses

       Entry restrictions:

       The Agency is establishing the following entry restrictions for nonWPS occupational uses
of DCPA end-use products:

       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 restrictions in that box.

       If no WPS uses are on the label ~ Place the appropriate nonWPS entry restrictions in
       the Directions for Use, under the heading "Entry Restrictions."

Products Intended Primarily for Homeowner Use

       Entry restrictions: The Agency is establishing the following entry restrictions for all
homeowner uses of DCPA end-use products:

Entry Restrictions for Home Use Products

       For liquid and granular formulations:

       "This product must be watered in following application. Do  not allow persons or pets to
       enter the treated area until the grass is dry following watering-in."

       Placement in labeling: Place the appropriate entry restrictions in the Directions for Use,
       under the heading "Entry Restrictions."
                                            98

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Other Labeling Requirements for End-Use Products

Products Intended Primarily for Occupational Use

       The Agency is requiring the following labeling statements to be located on all end-use
products containing DCPA that are 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."

       User Safety Requirements:

              (Registrants: select this if coveralls are required for pesticide handlers on the end-
              use product label:!

              "Discard clothing or other absorbent materials that have been drenched or heavily
              contaminated with this product's concentrate. Do not reuse them."

              (Registrants: select this always:!

              "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. As
                    soon as possible, wash thoroughly and change into clean clothing."

       Engineering Controls:

              "When handlers use closed  systems, or 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
                                           99

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              handler PPE requirements may be reduced or modified as specified in the
              WPS."

       Soil Incorporation Statement:

       Registrants must 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."

Products Intended Primarily for Home Use

       Application Restrictions

              "Do not apply this product in a way that will contact any person or
              pet, either directly or through drift. Keep people and pets out of
              the area during application."

       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."

              (Registrants: select this only if gloves and/or protective eyewear are required for
              homeowner users: I

              #      "Users should remove protective clothing and equipment
                     immediately after handling this product. Wash the outside of
                     gloves before removing. Keep  and wash protective clothing
                     and equipment  separately from other laundry."

ADDITIONAL LABELING REQUIREMENTS

       The use directions for DCPA on beans prohibit grazing in treated areas and the feeding of
treated plant material or refuse to livestock. Under current Agency policy, label restrictions
prohibiting the feeding of bean forage and straw/hay to livestock are inappropriate. The registrant
must delete restrictions prohibiting the feeding of bean forage and hay/straw to livestock from all
labels. However, the registrant may restrict the uses of DCPA on beans to those varieties that are
used for human consumption only.
                                           100

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       When end-use product DCIs are developed (e.g., at issuance of the RED), EPA should
require that all end-use product labels (e.g., multiple active ingredient labels, SLNs, and products
subject to the generic data exemption) be amended such that they are consistent with the basic
producer labels.

              3.      Groundwater Advisory

       All DCPA end-use products must continue to bear the following groundwater advisory:

       Tetrachloroterephthalic acid, a breakdown product of Dacthal, is known to leach through
       soil as a result of agricultural and turf uses and has been found in groundwater which may
       be used for drinking water. Users are advised not to apply Dacthal to sand or loamy sand
       soils where the water table (groundwater) is close to the surface and where those soils are
       very permeable, i.e. well drained. Your local agricultural agencies can provide further
       information on the type of soil in your area and the location of groundwater used for
       drinking water.

                     a.      Surface Water Advisory

       All DCPA end-use products must bear the following surface water advisory:

       DCPA can  contaminate surface water through spray drift.  Under some conditions,
       DCPA may also have a high potential to contaminate surface water through runoff
       (via both dissolution in runoff water and adsorption to eroding soil) for several
       weeks post-application. Users are advised not to apply Dacthal to poorly draining
       or wet soils with readily visible sloping towards adjacent surface waters, frequently
       flooded areas, areas over-laying extremely shallow groundwater, areas with in-field
       canals or ditches that drain to surface water, areas not separated from adjacent
       surface waters with vegetated filter strips,  and highly erodible soils.
aerially:
                     b.      Spray Drift Labeling

       The following language must be placed on each label for products which can be applied
              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.
                                           101

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              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.

       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.
                                           102

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 !      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
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
                             103

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              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
              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.     Tolerance Revocation and Import Tolerances

       The use of DCPA on pimentos is being voluntarily canceled as part of the Agency's
reregi strati on eligibility decision regarding this pesticide.  It is the Agency's  policy to propose
revocation of a tolerance, and/or food/feed additive regulation, following the deletion of a related
food use from a registration, or following the cancellation of a related food-use registration.  As a
result, any parties interested in supporting the tolerance/regulation for import purposes in the
absence of a registered U.S. use should notify the Agency as soon as possible.

       In  responding, the Agency will provide detailed information on the outstanding data
requirements for these tolerances and/or regulations.  The Agency will consider commitments
made to generate data to support such tolerances/regulations and the timeliness of data
submissions in its assessment of whether the tolerances/regulations should be retained. Persons
interested  in establishing a new tolerance for import purposes only, or retaining a current
tolerance for import purposes following cancellation of the related use, must submit a petition,
along with the appropriate supporting data.

       D.     Existing Stocks

       Registrants may generally distribute and sell products bearing old labels/labeling for 26
months from the date of the issuance of this Reregi strati on 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.
                                           104

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       The Agency has determined that registrants may distribute and sell DCPA 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.
                                           105

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106

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VI. APPENDICES
       107

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108

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             APPENDIX A - Table of Use Patterns Subject to Reregistration
 Appendix A is 169 pages long and is not being included in this RED.  Copies of Appendix A are
available upon request per the instructions in Appendix E.
                                         109

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110

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                                GUIDE TO APPENDIX B

              Appendix B contains listings of data requirements which support the reregi strati on
for active ingredients within the case DCPA covered by this Reregi strati on Eligibility Decision
Document. It contains generic data requirements that apply to DCPA 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
              O     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.
                                           Ill

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112

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                         APPENDIX B
  Data Supporting Guideline Requirements for the Reregistration of DCPA
REQUIREMENT
  USE      CITATION(S)
PATTERN
PRODUCT CHEMISTRY
61-1        Chemical Identity
61-2A      Start. Mat. & Mnfg. Process
61-2B      Formation of Impurities
62-1        Preliminary Analysis
62-2        Certification of limits
62-3        Analytical Method
63-2        Color
63-3        Physical State
63-4        Odor
63-5        Melting Point
63-6        Boiling Point
63-7        Density
63-8        Solubility
63-9        Vapor Pressure
63-10      Dissociation Constant
63-11      Octanol/Water Partition
63-12      pH
63-13      Stability
63-14      Oxidizing/Reducing Action
63-15      Flammability
63-16      Explodability
63-17      Storage stability
63-18      Viscosity
63-19      Miscibility
63-20      Corrosion characteristics
  ALL     DATA GAP
  ALL     00156951,40958804,
           41054801, 41241801, DATA
           GAP
  ALL     00156951,40958808
  ALL     Partially Satisfied
  ALL     DATA GAP
  ALL     DATA GAP
  ALL     41054802
  ALL     40958812
  ALL     40958814
  ALL     41054804
  ALL     WAIVED
  ALL     40958816
  ALL     41155701,40958818
  ALL     41054805,40958819
  ALL     WAIVED
  ALL     40958820
  ALL     40958821
  ALL     41155703
  ALL     DATA GAP
           N/A
  ALL     41155703
  ALL     40958822
           N/A
           N/A
  ALL     DATA GAP
                                    113

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  Data Supporting Guideline Requirements for the Reregistration of DCPA
REQUIREMENT
63-21
64-1
ECOL
71-1A
71-1B
71-2A
71-2B
71-3
71-4A
71-4B
71-5A
71-5B
72-1A
72-1B
72-1C
72-1D
72-2A
72-2B
72-3A
72-3B
72-3C
Dielectric breakdown volt
Submittal of Samples
,OGICAL EFFECTS
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
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
USE
PATTERN


ALL

ALL
ALL

A, B, C, D,
E, F, J, K
A, B, C, D,
E, F, J, K


A, B, C, D,
E, F, J, K

ALL
ALL
ALL
ALL
ALL
A, B, C, D,
E, F, J, K
A, B, C, D,
E, F, J, K
CITATION(S)
N/A
N/A
41155705
N/A
41155706
41155707
N/A
DATA GAP
DATA GAP
RESERVED
RESERVED
41054827
N/A
00107142, 41054826
41054826
40098001
40098001
40098001
40098001
40098001
72-3D     Estuarine/Marine Toxicity Fish-
          TEP
N/A
                                  114

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Data Supporting Guideline Requirements for the Reregistration of DCPA
REQUIREMENT
72-3E
72-3F
72-4A
72-4B
72-5
72-6
72-7A
72-7B
122-1A
122-1B
122-2
123-1A
123-1B
123-2
124-1
124-2
141-1
141-2
141-5
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
Vegetative Vigor
Aquatic Plant Growth
Seed Germination/Seedling
Emergence
Vegetative Vigor
Aquatic Plant Growth
Terrestrial Field
Aquatic Field
Honey Bee Acute Contact
Honey Bee Residue on Foliage
Field Test for Pollinators
USE
PATTERN








A, B, C, D,
E, F, J, K
A, B, C, D,
E, F, G, J,
K
A, B, C, D,
E, F, G, J,
K
A, B, C, D,
E, F, G, J,
K
A, B, C, D,
E, F, G, J,
K



A, B, C, D,
J,K


CITATION(S)
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
41054829, 41564901,
PARTIALLY SATISFIED
41440101, SUPPLEMENTAL
41054829, 41155714,
42882401, 41836101,
42836102, 42836103
DATA GAP
DATA GAP
RESERVED
RESERVED
RESERVED
00009181
N/A
N/A
                              115

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  Data Supporting Guideline Requirements for the Reregistration of DCPA
REQUIREMENT
  USE
PATTERN
CITATION(S)
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

82-1B      90-Day Feeding - Non-rodent
82-2       21-Day Dermal - Rabbit/Rat
82-3       90-Day Dermal - Rodent
82-4       90-Day Inhalation - Rat
82-5A      90-Day Neurotoxicity - Hen
82-5B      90-Day Neurotoxicity - Mammal
83-1A      Chronic Feeding Toxicity -
           Rodent
83-1B      Chronic Feeding Toxicity -
           Non-Rodent
83-2A      Oncogenicity - Rat
83-2B      Oncogenicity - Mouse
83-3A      Developmental Toxicity - Rat
83-3B      Developmental Toxicity - Rabbit
83-4       2-Generation Reproduction -
           Rat
  ALL     41054808,41054808,
           41054809, 41155710
  ALL     41054811,41054812,
           41054813, 41155709
  ALL     00127905,41054814,
           41155710, 41750101
  ALL     00163578,41054815,
           41054816, 41155711
  ALL     41054817, 41054818, 41155712
  ALL     00150207

           N/A

  ALL     00100773,41064801,
           41767901, 41790901
           N/A
  ALL     41231803, 41231804, 41231805
           N/A
           N/A
           N/A
           N/A
  ALL     40958701, 41349101, 41750102

  ALL     00083584

  ALL     42731001
  ALL     40958701,41349101
  ALL     00160685
  ALL     41054820, 41064802, 41838301
  ALL     41750103,41905201
                                     116

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  Data Supporting Guideline Requirements for the Reregistration of DCPA
REQUIREMENT
                                 USE
                               PATTERN
                                                    CITATION(S)
84-2A
84-2B

84-4
85-1
Gene Mutation (Ames Test)
Structural Chromosomal
Aberration
Other Genotoxic Effects
General Metabolism
                                           ALL
                                           ALL

                                           ALL
                                           ALL

85-2        Dermal Penetration                ALL
86-1        Domestic Animal Safety
OCCUPATIONAL/RESIDENTIAL EXPOSURE
132-1A     Foliar Residue Dissipation
132-1B     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
                              A, B, C, D,
                               H, I, J, K
                              A, B, C, D,
                               H, I, J, K

                              A, B, C, D,
                              H, J, K, L,
                               M,N, O
                                  All
                              A, B, C, D,
                               E, F, G, J
00100775
41054821, 41054822,
41054823, 41054824,
41054825, 41038301
41054822, 41054824, 42038301
42155501, 42155502.
42155503, 42723201,
43052201, 43723202, 43723203
42651501, 42651502
N/A
                                                    DATA GAP [DCI'S issued
                                                    September 1992 and October
                                                    1995]
                                                    N/A
                                                    DATA GAP [DCI's issued
                                                    September 1992 and October
                                                    1995]
                                                    DATA GAP [DCI issued
                                                    October 1995
                                          N/A

                                          N/A

                                          N/A

                                          N/A
                                                    N/A
                                                    00114648
                                                    41508607
                                    117

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Data Supporting Guideline Requirements for the Reregistration of DCPA
REQUIREMENT
161-3
161-4
162-1
162-2
162-3
162-4
163-1
163-2
163-3
164-1
164-2
164-3
164-5
165-1
165-2
165-3
165-4
165-5
166-1
166-2
166-3
201-1
202-1
Photodegradation - Soil
Photodegradation - Air
Aerobic Soil Metabolism
Anaerobic Soil Metabolism
Anaerobic Aquatic Metabolism
Aerobic Aquatic Metabolism
Leaching/Adsorption/
Desorption
Volatility - Lab
Volatility - Field
Terrestrial Field Dissipation
Aquatic Field Dissipation
Forest Field Dissipation
Long Term Soil Dissipation
Confined Rotational Crop
Field Rotational Crop
Accumulation - Irrigated Crop
Bioaccumulation in Fish
Bioaccumulation - Aquatic
NonTarget
Ground Water - Small
Prospective
Ground Water - Small
Retrospective
Ground Water - Irrigated
Retrospective
Droplet Size Spectrum
Drift Field Evaluation
USE CITATION(S)
PATTERN
A, B, C, J 41508608
N/A
A, B, C, D, 41648801
E, H, I, J,
K
A, B, C 00114651, 41648802
N/A
N/A
A, B, C, D, 41648803. 41648804,
E, F, G, H, 41648805, 42262602
I,J,K
RESERVED
RESERVED
A, B, H, I IN REVIEW
RESERVED
RESERVED
A, B, C, D, IN REVIEW
E,J,K
A, B, C, D IN REVIEW
RESERVED
N/A
A, B, C, D, 41155716, 41197602
E, F, G, J
N/A
N/A
N/A
N/A
RESERVED
RESERVED
                              118

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  Data Supporting Guideline Requirements for the Reregistration of DCPA

REQUIREMENT
   USE      CITATION(S)
 PATTERN
RESIDUE CHEMISTRY
171-4A     Nature of Residue - Plants

171-4B     Nature of Residue - Livestock
171-4C     Residue Analytical Method -
           Plants
171-4D     Residue Analytical Method -
           Animal

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

171-4J     Magnitude of Residues-
           Meat/Milk/Poultry/Egg

171-4K     Crop Field Trials

           Root and Tuber Vegetables
           Group

           - Horseradish
A, B, D, H,   00058377, 00114677,
   K, L     40259101, 42298301, 42298302

A, B, D, H,   00057629, DATA GAP
    L

A, B, D, E,   00010026, 00114642,
   K, L     00114643, 00114644,
            OO114654, 00121864,
            00123748, 40259001,
            41550701, 42155505,
            42155506, 42155507,
            42155508, 42155509,
            42155510, 42218904,
            42218905, 42245701,
            42271801, 42218901,
            42218906, 43406401, DATA
            GAP

A, B, D, H,   00058378, 00114643,
    K       43406401, DATA GAP

A, B, D, E,   00121864, 41750107,
  H, K, L    42218901, 42444001, DATA
            GAP

            N/A
            N/A

            N/A


            N/A
A, B, D, H,   00038919, 00058378,
    K      00114643, DATA GAP
A, B, D, H,   00058377
    K
                                     119

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  Data Supporting Guideline Requirements for the Reregistration of DCPA

REQUIREMENT
   USE      CITATION(S)
 PATTERN
           - Potatoes


           - Radish, root


           - Rutabagas


           - Sweet potato


           - Turnip root


           - Yams


           Leaves of Roots and Tuber
           Vegetables Groups

           - Radish, tops


           - Turnip, tops


           Bulb Vegetables Group

           - Garlic


           - Onions (green and dry   bulb)
A, B, D, H,  00018299, 00090259, 00114678
    K

A, B, D, H,  00121864
    K

A, B, D, H,  PP3E1388
    K

A, B, D, H,  00090259, 00114678, 00114681
    K

A, B, D, H,  00090259
    K

A, B, D, H,  00090259, 00114678, 00114681
    K
A, B, D, H,  00121864
    K

A, B, D, H,  00090259
    K
A, B, D, H,  00090259, 00130562
    K

A, B, D, H,  00090259,00114631,
    K      00114681,42155508
           Leafy Vegetables Group
           (except Brassica)
           - Cress, upland
           - Lettuce

           - Parsley

           Brassica Leafy Vegetables
           Group
A, B, D, H,  00033087, 00090259
    K

A, B, D, H,  00033087, 00090259, 42155506
    K

A, B, D, H,  41550701, DATA GAP
    K
                                    120

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  Data Supporting Guideline Requirements for the Reregistration of DCPA

REQUIREMENT
   USE      CITATION(S)
 PATTERN
           - Broccoli


           - Brussels sprouts


           - Cabbage


           - Cauliflower


           - Collards


           -Kale


           - Mustard greens


           Legume Vegetables (succulent or
           dried) Group

           - Beans, succulent and   dried


           - Peas


           - Soybeans


           Foliage of Legume Vegetables
           Group

           - Beans, forage and
           hay/straw

           - Soybeans, forage and   hay


           Fruiting Vegetables (except
           cucurbits) Group

           - Eggplant


           - Peppers
A, B, D, H,   00090259, 00114681
    K

A, B, D, H,   00090259
    K

A, B, D, H,   00090259, 00114681
    K

A, B, D, H,   00090259, 00114681
    K

A, B, D, H,   00090259
    K

A, B, D, H,   00090259
    K

A, B, D, H,   00090259
    K
A, B, D, H,   00017975, 00058377,
    K      00090259,00114678

A, B, D, H,   00017975, 00058377,
    K      00090259,00114678

A, B, D, H,   00017975, 00058377,
    K      00090259,00115678
A, B, D, H,   0090259, 00114678, Data Gap
    K

A, B, D, H,   00058377
    K
A, B, D, H,   00090259, 42155510
    K

A, B, D, H,   00090259, 00114680, 42155510
    K
                                     121

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  Data Supporting Guideline Requirements for the Reregistration of DCPA

REQUIREMENT
   USE      CITATION(S)
 PATTERN
           - Pimentos


           - Tomatoes


           Cucurbit Vegetables Group

           - Cucumbers


           - Cantaloups


           - Honeydew melons


           - Squash (summer and
           winter)

           - Watermelons


           Small Fruits and Berries Group

           - Strawberries


           Cereal Grains Group

           - Corn, field and pop


           Forage, Fodder, and Straw of
           Cereal Grains Groups

           - Corn, forage and   fodder


           Miscellaneous Commodities
A, B, D, H,   00090259, 00114680, 42155510
    K

A, B, D, H,   00090259, 00114679,
    K      00114680, 42218904, 42218905
A, B, D, H,   00090259, 42155507,
    K

A, B, D, H,   00090259, 42218903
    K

A, B, D, H,   00090259, 42218903
    K

A, B, D, H,   00090259, 42245701
    K

A, B, D, H,   00090259, 42218903
    K
A, B, D, H,   00090259, 42155509
    K
A, B, D, H,   00072099
    K
A, B, D, H,   00072099
    K
           - Cottonseed
A, B, D, H,   00114642, 00114678, 00114681
    K
171-4(1) Magnitude of the Residues in Processed Food/Feed
           - Beans (succulent/dried)


           - Corn, field
A, B, D, H,   42218902
    K

A, B, D, H,
    K
                                     122

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  Data Supporting Guideline Requirements for the Reregistration of DCPA

REQUIREMENT
   USE     CITATION(S)
 PATTERN
          - Cottonseed
          - Potato
A, B, D, H,  42218906
    K

A, B, D, H,  42271801
    K


171-5
171-6
171-7
171-13
- Soybeans
- Tomatoes
Reduction of Residues
Proposed Tolerance
Support for Tolerance
Analtyical Reference Standard
A, B, D, H,
K
A, B, D, H,
K





42218905
N/A
N/A
N/A
N/A
                                  123

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124

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                  GUIDE TO APPENDIX C

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 Reregi strati on 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.

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.

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.

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 as (19??), the Agency was unable to determine or estimate the
       date of the document.
                             125

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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.
                             126

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                                BIBLIOGRAPHY
MRID
CITATION
00009181     Atkins, E.L., Jr.; Anderson, L.D.; Greywood, E.A. (1969) Effect of
             Pesticides on Apiculture: Project No. 1499.  (Unpublished study received Jul 29,
             1976 under 352-342; prepared by Univ. of California—Riverside, Dept. of
             Entomology, submitted by E.I. du Pont de Nemours & Co., Wilmington, Del.;
             CDL:224800-C)

00010026     Manning, P.B.; Olney, C.E.; Quinn, J.G.; et al. (1963) Direct gas chromatographic
             method for herbicide residues suitable for electron-capture detection.  Pesticide
             Research Bulletin 3(2):6-8. (Also~In~unpublished submission received Sep 1963
             under 464367; submitted by Dow Chemical U.S.A., Midland, Mich.; CDL:
             101380-A).

00107142     McCann, J. (1972) e'Dacthal G-2.5 Herbicide: Rainbow Trout (Salmo gairdneri)*:
             Test No. 481. (U.S. Agricultural Research Service, Pesticides Regulation Div.,
             Animal Biology Laboratory; unpublished study; CDL:130357-A)

00017975     Stallard, D.E. (1970) Residue Analyses and Procedure: eXinuron*. (Unpublished
             study received Feb 17, 1970 under 677-285; submitted by Diamond Shamrock
             Agricultural Chemicals, Cleveland, Ohio; CDL:004253-U)

00018299     Stallard, D.E. (1970) Residue Analyses and Procedure.  (Unpublished study
             received Nov 12, 1970 under unknown admin, no.; submitted by Diamond
             Shamrock Agricultural Chemicals, Cleveland, Ohio; CDL:123816-E)

00033087     Manning, P.B.; Kerr, T.W.; Olney, C.E.; et al. (1964) ^Residue Study*.
             (Unpublished study including published data, received Jan 14, 1965 under
             100-471; prepared in cooperation with Univ. of Rhode Island, Agricultural
             Experiment Station and Gaspro, Ltd., submitted by Ciba-Geigy Corp.,
             Greensboro, N.C.; CDL: 000459-F)

00038919     Gutenmann, W.H.; Lisk, D.J. (1966) Metabolism of Daconil and Dacthal
             pesticides in lactating cows.  Journal of Dairy Science 49 (10): 1272-1276.
             (Also~In~unpublished submission received Feb 25, 1976 under 6F1749; submitted
             by Diamond Shamrock Agricultural Chemicals, Cleveland, Ohio; CDL:096457-K)

00057629     Reno, F.E.; Stanovick, R. (1974) Final Report: Meat and Milk Residue Study in
             Dairy Cows: Project No. 200-223. (Unpublished study received on unknown date
             under 3F1417; prepared by Environmental Sciences Corp., submitted by Diamond
             Shamrock Agricultural Chemicals, Cleveland, Ohio; CDL:093787-C)

00058377     Diamond Shamrock Agricultural Chemicals (1973) ^Residue Studies of Dacthal in
             Various Crops*. (Compilation; unpublished study received Jun 29, 1973 under
             3F1417; CDL:093787-D)
                                         127

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                                BIBLIOGRAPHY
MRID
CITATION
00058378     Szalkowski, M.B. (1973) Evaluation of the Potential for Dacthal and Its
             Metabolites To Accumulate in Chicken Eggs and Tissues during 30 Days of
             Dietary Exposure. (Unpublished study received Jun 29, 1973 under 3F1417;
             submitted by Diamond Shamrock Agricultural Chemicals, Cleveland, Ohio;
             CDL:093787-E)

00072099     Diamond Shamrock Corporation (1968) Hexachlorobenzene Residue Data.
             (Compilation; unpublished study received Dec 10, 1968 under 9F0780;
             CDL:091340-C)

00083584     Hazleton, L.W.; Dieterich, W.H. (1963) Final Report: Two-year Dietary
             Feeding—Dogs.  (Unpublished study received Dec 15, 1963 under PP0411;
             prepared by Hazleton Laboratories, Inc., submitted by Diamond Shamrock
             Agricultural Chemicals, Cleveland, Ohio; CDL:090443-T)

00090259     Hazleton Laboratories (1963) ^Residue Data for Cabbage and Various Other
             Crops Treated With Dacthal*. (Compilation; unpublished study received Dec 18,
             1963 under PP0411; CDL:090445-A)

00100773     Goldenthal, E.; Wazeter, F.; Jessup, D.; et al. (1977) Ninety Day Toxicity Study in
             Rats: 0DTX 76-0010*: 239-044. (Unpublished study received May 12, 1982
             under 677-290; prepared by International Research and Development Corp.,
             submitted by Diamond Shamrock Agricultural Chemicals, Cleveland, OH;
             CDL:247439-A)

00100775     Kouri, R.; Parmar, A.; Kuzava, J.;  et al. (1977) Activity of DTX77-0004 in the
             Dominant Lethal Assay in Rodents for Mutagenicity: Project No. T1077. Final
             rept.  (Unpublished study received May 12,  1982 under 677-290; prepared by
             Microbiological Assoc., submitted  by Diamond Shamrock Agricultural Chemicals,
             Cleveland, OH;  CDL:247439-C)

00114631     Diamond Shamrock Agricultural Chemicals (1973) Residue Data: eDacthal*.
             (Compilation; unpublished study received May 10, 1973 under 677-166;
             CDL:004224-B)

00114642     Diamond Alkali Co. (1967) Results of Tests on the Amount of Residue
             Remaining: e'Dacthal*. (Compilation; unpublished study received Jan 9, 1968
             under 8F0640; CDL:091112-B)

00114643     Diamond Alkali Co. (1964) 0Study: Dacthal Residue on Selected Crops.
             (Compilation; unpublished study received on unknown date under PP0411;
             CDL:092698-A)
                                        128

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                                BIBLIOGRAPHY
MRID
CITATION
00114644     Diamond Alkali Co. (1967) ^Residues of Dacthal in Cottonseed*. (Compilation;
             unpublished study received Dec 28, 1967 under 8F0640; CDL:092934-A)

00114648     Szalkowski, M. (1975) The Effect of Light, Temperature, and pH on the
             Hydrolysis of Dacthal. (Unpublished study received Mar 23, 1976 under 3F1417;
             submitted by Diamond Shamrock Chemical Co., Cleveland, OH; CDL:095189-D)

00114649     Duane, W. (1976) Aerobic Soil Metabolism of Dacthal. (Unpublished study
             received Mar 23, 1976 under 3F1417; submitted by Diamond Shamrock Chemical
             Co., Cleveland, OH; CDL:095189-F)

00114651     Duane, W. (1976) Anaerobic Soil Metabolism of Dacthal.  (Unpublished study
             received Mar 23, 1976 under 3F1417; submitted by Diamond Shamrock Chemical
             Co., Cleveland, OH; CDL:095189-H)
00114654     Interregional Research Project No. 4 (1975) Results of Tests on the Amount of
             Residues Remaing, Including a Description of the Analytical Methods Used:
             e'Dacthal*.  (Compilation; unpublished study received Nov 21, 1975 under
             6E1711;CDL:095363-A)

00114677     Limpel, L. (1962) Letter sent to Diamond Alkali Co. dated Sep 13, 1962;
             Radioautographic studies of HCB and Dacthal applied to cotton plants.
             (Unpublished study received Nov 21, 1962 under unknown admin, no.; prepared
             by Boyce Thompson Institute for Plant Research, Inc., submitted by Diamond
             Shamrock Agricultural Chemicals, Cleveland, OH; CDL:119453-A)

00114678     Diamond Shamrock Agricultural Chemicals (1962)  Summary of Status of Residue
             Data: e'Dacthal*. (Compilation; unpublished study received Nov 21,  1962 under
             677-139; CDL:119455-A)

00114679     Stallard, D. (1961) Dacthal Herbicide Residue Studies on Tomatoes. (Unpublished
             study received Dec 12, 1961 under unknown admin, no.; submitted by Diamond
             Shamrock Agricultural Chemicals, Cleveland, OH; CDL:119456-A)

00114680     Diamond Shamrock Agricultural Chemicals (1961)  e'Study: Dacthal Residue on
             Selected Crops*. (Compilation; unpublished study received Oct 31, 1961 under
             unknown admin, no.; CDL:119457-A)

00114681     Diamond Shamrock Agricultural Chemicals (1962)  e'Study: Dacthal Residue on
             Selected Crops*. (Compilation; unpublished study received Dec 10, 1962 under
             unknown admin, no.; CDL:119459-A)
                                        129

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                                BIBLIOGRAPHY
MRID
CITATION
00121864    Diamond Shamrock Agricultural Chemicals (1981) The Results of Tests on the
             Amount of DCPA Residues Remaining in or on Radish, Including a Description of
             the Analytical Method Used.  (Compilation; unpublished study received Dec 17,
             1982 under 677-166; CDL:071286-A)

00123748    Priddle, W.; Stallard, D.; Skinner, W. (1964) Determination of Residues of
             Dacthal Herbicide in Vegetables and Agronomic Crops. (Unpublished study
             received Apr 10, 1973 under 3E1388; prepared by Diamond Alkali Co., submitted
             by Interregional Research Project No. 4, New Brunswick, NJ; CDL:093701-A)

00127905    Thackara, 1; Rinehart, W. (1977) An Acute Inhalation Toxicity Study of
             DTX-77-0049 in the Rat: Project No. 77-1933. (Unpublished study received Apr
             18, 1983 under 677-457; prepared by Bio/dynamics, Inc., submitted by Diamond
             Shamrock Agricultural Chemicals, Cleveland, OH; CDL:250016-A)

00130562    Jespersens Lab  (1975) e'Efficacy of Dacthal on Garlic*. (Compilation; unpublished
             study received Feb 5, 1981 under 667-166; CDL:244287-A)

00150207    Auletta,  C. (1984) Dermal Sensitization Study (Closed-patch Repeated Insult) in
             Guinea Pigs with Technical Dacthal: Report Number 5285-84. Unpublished study
             prepared by Bio/dynamics, Inc. 78 p.

00156951    SDS Biotech Corp. (1986) Dacthal 1.92 F: Technical DCPA Impurity: Response
             to EPA Letter of January 15,  1986: ?Results and Analyses for 2,3,7,8-TCDD#.
             Unpublished compilation. 213 p.

00158011    Major, D. (1985) A 30-day Oral Intubation Study in Rats with
             Tetrachloroterephthalic Acid: SDS 954: Document No. 665-5TX-84-0007001.
             Unpublished study prepared by SDS Biotech Corp. 269 p.

00160685    Ford, W. (1986) A Teratology Study in Rats with Technical DCPA: Document
             No. 712-5TX-85-0039-003: Report SDS-893.  Unpublished study prepared by
             SDS Biotech Corp. in cooperation with Argus Research Laboratories, Inc. 194 p.

00163578    Major, D. (1983) Primary Eye Irritation Study in Albino Rabbits with 90%
             Dimethyl-T: Document No. 628-5TX-83-0042-002.  Unpublished study prepared
             by SDS Biotech Corp. in cooperation with SISA Toxicological Laboratories, Inc.
             54 p.

40098001    Mayer, F.; Ellersieck, M. (1986) Manual of Acute Toxicity: Interpretation and
             Data Base 410 Chemicals and 66 Species of Fresh-Water Animals. US Fish &
             Wildlife Service; Resource Publication (160): 579  p.
                                         130

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                                BIBLIOGRAPHY
MRID
CITATION
40259001     Schuldt, P.; Burchfield, H.; Stallard, W.; et al. (1961) Colorimetric determination
             of micro amounts of dimethyl tetrachloroterephthalate. Contributions from Boyce
             Thompson Institute for Plant Research, Inc. 21:163-173.

40259101     Limpel, E. (1961) Memorandum sent to Diamond Alkali Co. dated Dec 4, 1961:
             Studies with Dacthal Herbicide, Tagged with ?Carbon 14# and ?Carbon 136#,
             Applied to Field Grown Crops. Prepared by Boyce Thompson Institute for Plant
             Research, Inc.  13 p.

40958701     Lucas, F.; Killeen, J. (1988) A Combined Chronic Toxicity and Tumorigenicity
             Study in Mice with  Technical DCPA: Document No. 1098-85-0057-TX-002.
             Unpublished study prepared by Huntingdon Research Centre, Ltd. in cooperation
             with Ricerca, Inc. 2276 p.
40958801     Burton, R. (1988) 75% Dimethy-T: Product Identity and Disclosure of
             Ingredients. Unpublished study prepared by Fermenta Plant Protection Co. 7 p.

40958802     Burton, R. (1988) 90% Dimethyl-T: Product Identity and Disclosure of
             Ingredients. Unpublished study prepared by Fermenta Plant Protection Co. 7 p.

40958803     Burton, R. (1988) Dacthal 1.92F: Product Identity and Disclosure of Ingredients.
             Unpublished study prepared by Fermenta Plant Protection Co. 8 p.

40958804     Resetar, J. (1985) DCPA Technical: Description of Beginning Materials and
             Manufacturing Process. Unpublished study prepared by Fermenta Plant Protection
             Co. 74 p.

40958808     Magee, T.  (1989) Formation of Impurities in DCPA Technical. Unpublished study
             prepared by Ricerca, Inc.  12 p.

40958812     Sweetapple, G. (1988) DCPA Technical-Determination of Physical State: Lab ID:
             Document No. 1081-88-0113-AS-001.  Unpublished study prepared by Ricerca,
             Inc. 30 p.

40958814     Sweetapple, G. (1988) DCPA Technical-Determination of Odor: Lab ID:
             Document No. 1081-88-0114-AS-001.  Unpublished study prepared by Ricerca,
             Inc. 31  p.

40958816     Sweetapple, G. (1988) DCPA Technical-Determination of Bulk Density:
             Document No.: 1081-88-0227-AS-001. Unpublished study prepared by Ricerca,
             Inc. 35  p.
                                         131

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                                BIBLIOGRAPHY
MRID
CITATION
40958817     Sweetapple, G. (1988) DCPA Manufacturing-use Products-Determination of
             Density: Document No.: 1081-88-0236-AS-001. Unpublished study prepared by
             Ricerca, Inc. 38 p.

40958818     Formanik, 1; Walls, G. (1988) Solubility of DCPA (SDS-893) in Water:
             Document No.: 1609-87-0046-AS-002.  Unpublished study prepared by Ricerca,
             Inc. 23 p.

40958819     DePablo, R.; Harrington , D. (1984) Vapor Pressure of Dimethyl
             Tetrachloroterephthalate. Unpublished study. 6 p.

40958820     Banzer, 1; Korsch, B.; Cryberg, R. (1987) Octanol/Water Partition Coefficient
             Studies: DCPA.  Unpublished study. 17 p.

40958821     Thomas, E. (1988) DCPA Technical-Determination of pH: Document No.
             1081-88-0121-AS-001. Unpublished study prepared by Ricerca, Inc. 35 p.

40958822     Sweetapple, G. (1988) DCPA Manufacturing-use Products-Determination of
             Impact Explodability: Document No.: 1081-88-0131-AS-001. Unpublished study
             prepared by Ricerca, Inc. 32 p.

41054801     Burton, R. (1989) Submission of Additional Information Description of Beginning
             Materials and Manufacturing Process: DCPA Technical: Doc. No.
             PC-89-RPB-001-01. Unpublished study prepared by Fermenta Plant Protection
             Co. 11 p.

41054802     Sweetapple, G. (1989) DCPA Technical Determination of Color: Doc. No.
             1081-88-0112-AS-001. Unpublished study prepared by Ricerca, Inc. 26 p.

41054804     Sweetapple, G. (1988) DCPA Technical Determination of Melting Point: Doc. No.
             1081-88-0115-AS-001. Unpublished study prepared by Ricerca Inc. 24 p.

41054805     Lorence, P.; Walls, G. (1989) DCPA Determination of Vapor Pressure: Doc. No.
             1081-88-0105-AS-001. Unpublished study prepared by Ricerca, Inc. 68 p.

41054808     Shults, S.; Roblin, M.; Killeen, J. (1989) Acute Oral Toxicity Study in Rats with
             Technical DCPA: Doc. No. 3224-89-0001-TX-001. Unpublished study prepared
             by Ricerca, Inc.  19 p.

41054809     Shults, S.; Major, D. (1982) Acute Oral Toxicity Study in Albino Rats with
             Dacthal W-75: Doc. No. 567-5TX-82-0012-002.  Unpublished study prepared by
             Diamond Shamrock Corp. 41 p.
                                        132

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41054811     Shults, S.; White, T.; Killeen, J. (1989) Acute Dermal Toxicity Study in Albino
             Rabbits with Technical DCPA: Doc. No. 3224-890002-TX-001. Unpublished
             study prepared by Ricerca, Inc. 25 p.

41054812     Shults, S.; Major, D. (1987) Acute Dermal Toxicity Study in Albino Rabbits with
             Dacthal W-75: Doc. No. 567-5TX-82-0013-002. Unpublished study prepared by
             Diamond Shamrock Corp. 51 p.

41054813     Shults, S.; Wilson, N.; Killeen, J.  (1987) Acute Dermal Toxicity (LD50) Study in
             Albino Rabbits with Dacthal Flowable Herbicide: Doc. No.
             1475-87-0008-TX-001.  Unpublished study prepared by Ricerca, Inc. 23 p.

41054814     Shults, S.; Wilson, N.; Killeen, J.  (1988) Acute Inhalation Toxicity of Dacthal
             Flowable Herbicide: Doc. No. 1475-87-0015-TX002. Unpublished study prepared
             by Huntingdon Research Centre Ltd.  19 p.

41054815     Shults, S.; Roblin, M.; Killeen, J.  (1989) Primary Eye Irritation Study in Albino
             Rabbits with Technical DCPA: Doc. No. 3224-890004-TX-001. Unpublished
             study prepared by Ricerca, Inc. 27 p.

41054816     Shults, S.; Wilson, N.; Killeen, J.  (1987) Primary Eye Irritation Study in Albino
             Rabbits with Dacthal Flowable Herbicide: Doc. No.  1475-87-0010-TX-001.
             Unpublished study prepared by Ricerca, Inc. 31 p.

41054817     Shults, S.; White, T.; Killeen, J. (1989) Primary Dermal Irritation Study in Albino
             Rabbits with Technical DCPA: Doc. No. 3224-890003-TX-001. Unpublished
             study prepared by Ricerca, Inc. 18 p.

41054818     Shults, S.; Wilson, N.; Killeen, J.  (1987) Primary Dermal Irritation Study in Albino
             Rabbits with Dacthal Flowable Herbicide: Doc. No.  1475-87-0009-TX-001.
             Unpublished study prepared by Ricerca, Inc. 17 p.

41054820     Chun, J.; Lucas, F.; Killeen, J. (1989) A Teratology Study with Technical DCPA
             in Rabbits: Proj. ID 87-3204.  Unpublished Ricerca Document
             1116-87-0067-TX-002 prepared by Bio/dynamics Inc.  775 p.

41054821     Mizens, M.; Killeen, J. (1988) Salmonella/Mammalian-Microsome Plate
             Incorporation Mutagenicity Assay (Ames Test) with and without Metabolic
             Activation with Technical Dimethyl Tetrachloroterephthalate (DCPA): Proj. ID
             T5554.501014.  Unpublished Ricerca Document 1488-87-0029-TX-002 prepared
             by Microbiological Associates Inc.  178 p.
                                         133

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41054822    Mizens, M.; Killeen, J. (1988) L5178Y TK+/Mouse Lymphoma Forward Mutation
             Assay with Technical Dimethyl Tetrachloterephthalate (DCPA): Proj. ID
             T5554.701020. Unpublished Ricerca Document 1488-87-0030-TX-002 prepared
             by Microbiological Associates, Inc. 170 p.

41054823    Mizens, M.; Killeen, J. (1988) In vitro Chromosomal Aberration Assay in Chienese
             Hamster Ovary (CHO) Cells with Technical Dimethyl Tetrachloroterephthalate
             (DCPA): Proj. ID T5554.337002. Unpublished Ricerca Document
             1488-87-003 l-TX-002 prepared by Microbiological Associates, Inc.  130 p.

41054824    Mizens, M.; Killeen, J. (1988) Unscheduled DNA Synthesis Assay in Rat Primary
             Hepatocytes with Technical Dimethyl Tetrachloroterephthalate (DCPA): Proj. ID
             T5554.380009. Unpublished Ricerca Document 1488-87-0032-TX-002 prepared
             by Microbiological Associates, Inc.  137 p.

41054825    Mizens, M.; Killeen, J. (1988) In vitro Sister Chromatid Exchange (SCE) Assay in
             Chinese Hamster Ovary (CHO) Cells with Technical Dimethyl
             Tetrachloroterephthalate (DCPA): Proj. ID T5554.334001. Unpublished Ricerca
             Document 1488-87-0033-TX-002 prepared by Microbiological Associates, Inc.
             135 p.

41054826    Shults, S.;  Wilson, N.  (1989) Static, Acute Toxicity (LC50) Study in Rainbow
             Trout with Technical DCPA (Dimethyl 2,3,5,6-Tetrachloroterephthalate): Doc.
             No. 690-5TX-84-0046-002. Unpublished study prepared by SDS Biotech Corp.
             64 p.

41054827    Shults, S.;  Wilson, N.  (1985) Static, Acute Toxicity (LC50) Study in Bluegill with
             Technical DCPA (Dimethyl 2,3,5,6-Tetrachloroterephthalate): Doc. No.
             690-5TX-84-0047-002. Unpublished study prepared by  SDS Biotech Corp. 64 p.
41054829    Shults, S.; Wilson, N. (1985) Algal Growth Inhibition Study in Scenedesmus
             subspicatus with Technical DCPA (Dimethyl 2,3,5,6-Tetrachloroterephthalate):
             Doc. No. 688-5TX-84-0049-002. Unpublished study prepared by SDS Biotech
             Corp. 54 p.

41064801    Ford, W. (1986) A 90-Day Dietary Study in Mice with Technical DCPA:
             Document No. 696-5TX-84-0082-002.  Unpublished study prepared by SDC
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41064802    Mizens, M. (1985) A Teratology Dose Range-Finding Study in Rats with
             Tetrachloroterephalic Acid (SDS-954): Document No. 687-5TX-84-0034-002.
             Unpublished study prepared by SDS Biotech Corp.  120 p.
                                         134

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41155701     Rose, K. (1989) DCPA-Determination of Solubility: Document No.
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41155702     Lorence, P.; Walls, G. (1989) DCPA-Determination of Octanol/Water Partition
             Coefficient: Project ID 1081-89-0012-AS. Unpublished study prepared by
             Ricerca, Inc. 40 p.

41155703     Sanders, J. (1989) DCPA-Determination of Stability: Project ID
             1081-88-0122-AS-001.  Unpublished study prepared by Ricerca, Inc.  48 p.

41155705     Shults, S.; Roblin, M.; Killeen, J. (1989) Acute Oral Toxicity (LD 50) Study in
             Bobwhite Quail with Technical DCPA: Project ID 230112.  Unpublished study
             prepared by Wildlife International Ltd. 61 p.

41155706     Shults, S.; Roblin, M.; Killeen, J. (1989) Dietary (LC50) Study in Bobwhite Quail
             with Technical DCPA: Project ID 230-110 and 890018. Unpublished study
             prepared by Wildlife International Ltd. in association with Ricerca, Inc.  113 p.

41155707     Shults, S.; Roblin, M.; Killeen, J. (1989) Dietary (LC50) Study in Mallard Ducks
             with Technical DCPA: Project IDs 230-111 and 890017. Unpublished study
             prepared by Wildlife International, Ltd. in association with Ricerca, Inc. 114 p.

41155709     Major, D.; Laveglia, J.; Killeen, J. (1983) Acute Dermal Toxicity (LD50) Study in
             Albino Rabbits with 90 percent Dimethyl-T: Document No.
             628-5TX-83-0040-002.  Unpublished study prepared by SISA Toxicological
             Laboratories, Inc.  72 p.

41155710     Banzer, C. (1977) An Acute Inhalation Toxicity Study of DTX-77-0049 in the
             Rat: Document No. 000-5TX-77-0049-001. Unpublished study prepared by
             Bio/Dynamics, Inc. 18 p.

41155711     Major, D.; Laveglia, J.; Killeen, J. (1983) Primary Eye Irritation Study in Albino
             Rabbits with 90 percent Dimethyl-T: Document No. 628-5TX-83-0042-002.
             Unpublished study prepared by SISA Toxicological Laboratories, Inc.  76 p.

41155712     Major, D.; Laveglia, J.; Killeen, J. (1983) Primary Dermal Toxicity Study in Ablino
             Rabbits with 90 percent Dimethyl-T: Document No. 628-5TX-83-0041-002.
             Unpublished study prepared by SISA Toxicological Laboratories, Inc.  62 p.

41155714     Hughes, J. (1989)  The Toxicity of DCPA (Dacthal/Dimethyl
             Tetrachloroterephthalate) to Selenastrum capricornutum: Project ID
             140101-1100-1. Unpublished study prepared by Malcolm Pirnie, Inc. 26 p.
                                         135

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41155715    Szalkowski, M.; Marciniszyn, J.; Killeen, J. (1981) Accumulation, Distribution and
             Depuration of ^Carbon 14*-Residues of... (Dacthal, DS-893) in Channel Catfish
             (Ictalurus punctatus) Under Static Aquatic Conditions: Document No.
             139-4EI-81-0015-002.  Unpublished study prepared by Analytical Bio Chemistry
             Laboratories, Inc. 76 p.

41155716    Szalkowski, M.; Stallard, D.; Killeen, J. (1980) Accumulation, Distribution and
             Depuration of ^Carbon 14*-Dacthal (DS-893) inBluegill Sunfish (Lepomis
             macrochirus) under Flow Through Aquatic Conditions: Document No.
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41197602    Szalkowski, M.; Marciniszyn, J.;Killeen,  J.  (1981) Characterization and
             Quantitation of (Carbon-14)-Residues in  Water and Fish Exposed to
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             Flow Through Aquatic System: Document No. 142-4EI-81-0017-002.
             Unpublished study prepared by Analytical Bio-Chemistry Laboratories, Inc. 80 p.

41231803    Lucas, F.; Chun, J.; Killeen, J. (1989) A 21-Day Repeated Dose Dermal Toxicity
             Study in Rats with Technical DCPA: Project ID 880231. Unpublished study
             prepared by Ricerca, Inc. in association with Experimental Pathology Laboratories,
             Inc. and WIL Research Laboratories, Inc. 289 p.

41231804    Lucas, F.; Roblin, M.; Killeen, J. (1989) A Pilot 21-Day Repeated Dose Dermal
             Toxicity Study in Rats with Technical DCPA: Project ID 88-0229. Unpublished
             study prepared by Ricerca, Inc.  53 p.

41231805    Lucas, F.; Roblin, M.; Killeen, J. (1989) A Dose Range-finding Study for a 21-Day
             Repeated Dose Dermal Toxicity Study in Rats with Technical DCPA: Project ID
             88-0230.  Unpublished study prepared by Ricerca, Inc.  57 p.

41241801    Burton, R.; Mizner, D.; Pudwill, C.; et al. (1989) Isomer Specific Analyses for
             Polychlorinated Dioxins/Furans in Dimethyl Tetrachloroterephthalate
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             Laboratory.  671 p.

41349101    Serrone, D.; Lucas, F.; Killeen, J. (1990)  A Chronic Opthalmology Study in Rats
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             Unpublished study prepared by Ricerca, Inc. 62 p.

40958801    Burton, R. (1988) 75% Dimethy-T: Product Identity and Disclosure  of
             Ingredients.  Unpublished study prepared by Fermenta Plant Protection Co. 7 p.
                                         136

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40958802    Burton, R. (1988) 90% Dimethyl-T: Product Identity and Disclosure of
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40958803    Burton, R. (1988) Dacthal 1.92F: Product Identity and Disclosure of Ingredients.
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41416801    Burton, R.; Mizner, D.; Luksemburg, W. (1990) Additional Information for the
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41440101    Backus, P.; Crosby, K.; Schollenberger, (1990) Effect of DCPA on Vegetative
             Vigor of Plants (Tier 2): Lab Project No: 89-0128. Unpublished study prepared by
             Ricerca, Inc. 29 p.

41508607    Korsch, B. (1990) A Photolysis Study of ^Carbon 14*-Dimethyl
             Tetrachloroterephthalate in Water: Lab Project Number: 89-0366:
             349689-0366-EF-001: SDS-893. Unpublished study prepared by Ricerca, Inc.
             119 p.

41508608    Korsch, B. (1990) A Photolysis Study of ^Carbon 14*-Dimethyl
             Tetrachloroterephthalate on Soil: Lab Project Number: 89-0365:
             349589-0365-EF-001: SDS-893. Unpublished study prepared by Ricerca, Inc.
             115 p.

41550701    Baron, J. (1988) DCPA: Magnitude of Residue on Parsley: Lab Project Number:
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41564900    Fermenta ASC Corp. (1990) Submission of Phytotoxicity Data in Support of
             DCPA Registration Standard.  Transmittal of 1 study.

41564901    Backus, P.; Crosby, K. (1990) Effect of DCPA on Seed Germination/ Seedling
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41648801    Doran,  T. (1990) Response to EPA Review: Aerobic Soil Metabolism of Dacthal:
             Lab Project Number: 000/3EF/76/2083/001. Unpublished Study prepared by
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41648802    Doran,  T. (1990) Response to EPA Review: Anaerobic Soil Metabolism of
             Dacthal: Lab Project Number: 000/3EF/76/2082/001. Unpublished study prepared
             by Ricerca, Inc. 40 p.
                                         137

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41648803     Korsch, B. (1988) Adsorption and Desorption of Dimethyl
             Tetrachloroterephthalate to Soils: Lab Project Number: 1701/87/00997
             EF/001/001. Unpublished study prepared by Ricerca, Inc.  64 p.

41648804     Korsch, B.; Kapostasy, W. (1990) Adsorption and Desorption of Monomethyl
             Tetrachloroterephthalate to Soils: Lab Project Number: 1736/88/0005/EF/001.
             Unpublished study prepared by Ricerca, Inc.  8 p.

41648805     Korsch, B.; Kapostasy, W. (1989) Adsorption and Desorption of
             Tetrachloroterephthalic Acid to Soils: Lab Project Number: 17357
             88/0004/EF/001.  Unpublished study prepared by Ricerca, Inc. 64 p.

41648806     Eilrich, G.; Hurto, K. (1990) Dissipation Study of Foliar Dislodgeable Residues of
             DCPA and HCB Following Application of Dacthal W-75 Turf to Turfgrass: Lab
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41750101     Shults,  S.; Killeen, J. (1990) Acute (Four-Hour) Inhalation Toxicity (LC50) Study
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41750102     Benz, G.; Lucas, F.; Killeen, J.; et al. (1990) A Chronic Opthalmology Study In
             Rats With Technical DCPA: Lab Project Number: 88-0042:
             3018-88-0042-TX-003. Unpublished study prepared by Ricerca, Inc. 767 p.

41750103     Benz, G.; Lucas, F.; Lovell, R. (1990) A Two Generation Reproduction Study in
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             Unpublished study prepared by Ricerca, Inc.  2408 p.

41750107     Formanik, J. (1990) Determination of Residues of DCPA (Dimethyl
             Tetrachloroterephthalate, SDS-36991), Its Degredation Products And HCB On
             Tobacco: Lab Project Number: 3423-89-0262: 3-89-0262 CR-001-001.
             Unpublished study prepared by Ricerca, Inc.  50 p.

41767901     Lucas, F.; Benz, G. (1991) A 90-Day Feeding Study in Rats with Technical
             DCPA: Lab Project Number: 89-0208. Unpublished study prepared by Ricerca,
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41790901     Lucas, F.; Killeen, J. (1990) A 28-Day Feeding Study in Rats with Technical
             DCPA: Lab Project Number: 89-0034. Unpublished study prepared by Ricerca,
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                                         138

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41838301     Lucas, F. (1991) Identification of Material Tested in the Study, "A Teratology
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41905201     Lucas, F. (1991) Report Addendum Number One: A Two Generation
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42038301     ISK Biotech Corp. (1991) Information to Upgrade Mutagenicity Studies with
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42052601     Yeh, L. (1991) DCPA:  Test Substance Characterization: Lab Project Number:
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42052602     Douglass, M. (1991) Dimethyl Tetrachloroterephthalate (...) Reference Substance
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42052603     Douglass, M. (1991) Methyl Pentachlorobenzoate (...) Reference Substance
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42052604     Douglass, M. (1991) Dimethyl 2,3,5-Trichloroterephthalate (...) Reference
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42052605     Yeh, L. (1991) 4-Carbomethoxy-2,3,5,6-Tetrachlorobenzoic Acid (...) Reference
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42052607     Douglass, M. (1991) Dimethyl 3,5,6-Trichloro-2-Methoxyterephthalate (...)
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42052608     Douglass, M. (1991) Hexachlorobenzene (...) Reference  Substance
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42155501     Medvedeff, E.; Liu, Y.; Marciniszyn, I;  et al. (1991) Study to Identify the
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42155502    Magee, T.; Marciniszyn, 1; Killeen, J. (1991) Study to Determine the Major
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42155503    Ho, M.; Marciniszyn, J.; Killeen, J. (1991) Study of the Biliary Excretion of
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42155505    King, C.; Prince, P.; Bailee, D. (1991) Determination of Residues of DCPA, Its
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42155506    King, C.; Prince, P.; Bailee, D. (1991) Determination of Residues of DCPA, Its
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42155507    Bailee, D.; Cassidy, P.; Dillon, K. (1991) Determination of Residues of DCPA, Its
             Degradation Products and HCB on Cucumbers : Lab Project Number:
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42155508    King, C.; Prince, P.; Bailee, D. (1991) Determination of Residues of DCPA, Its
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42155509    Formanik, J. (1991) Determination of Residues of DCPA, Its Degradation
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42155510    King, C.; Prince, P.; Bailee, D. (1991) Determination of Residues of DCPA, Its
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             3812-90-013 l-CR-001.  Unpublished study prepared by Ricerca, Inc.  477 p.

42218901    Rose, C. (1992) Residues of DCPA, It's Manufacturing Impurity HCB and It's
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             Lab Project Number: 3692-90-0314.  Unpublished study prepared by Ricerca, Inc.
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42218902    Balle, D. ; Cassidy, P. ; Dillon, K. (1991) Residues of DCPA, It's Degradation
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                                         140

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42218904     Formanik, J. (1991) Determination of Residues of DCPA, It's Degradation
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42218905     Formanik, J. (1991) Determination of Residues of DCPA, It's Degradation
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42218906     Rose, C. ; Zgodinski, J. (1992) Determination of Residues of DCPA, It's
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42245701     Formanik, J. (1991) Determination of the Residues of DCPA (Dimethyl
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42262601     Liu, Y.; Magee, T.; Marciniszyn, J.; et al. (1992) Study to Evaluate the
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42271801     Cassidy, P.; Dillon, K.; Bailee, D. (1991) Residues of DCPA (Dimethyl
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42298301     Korsch, B.; Doran, T. (1992) A Plant Metabolism Study with ^carbon
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42298302     Korsch, B.; Doran, T. (1992) A Plant Metabolism Study with 0carbon
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42444001     Ver Hey, M. (1992) Food and Drug Administration Pesticide Analytical Manual,
             Volume 1 Testing of 2,3,5,6-Tetrachloroterephtalic Acid (TPA): Final Report: Lab
             Project Number: ISK-1178.  Unpublished study prepared by Colorado Analytical
             Research and Development Corp.  164 p.

42651501     Ho, M.; Johnson, D.; Leveglia, J. (1993) Dermal Absorption of (carbon 14)-
             Hexachlorobenzene in Male Sprague-Dawley Rats: Effects of Varying
             Concentrations in Dacthal W-75: Lab Project Number: 3699-90-0318-AM-001:
             90-0318. Unpublished study  prepared by Ricerca, Inc. 235 p.

42651502     Liu, Y.; Savides,  M.; Johnson, D.; et al. (1993) Dermal Absorption of (carbon
             14)-DCPA in Male Sprague-Dawley Rats: Effects of Varying Concentrations: Lab
             Project Number: 3416-91-0322-AM-001: 91-0322.  Unpublished study prepared
             by Ricerca, Inc. 418 p.

42723201     Liu, Y.; Marciniszyn, J.; Killeen, J.; et al. (1992) Study of the Distribution,
             Excretion and Pharmacokinetics of Radiolabel following Repeated Oral
             Administration of DCPA to Sprague-Dawley Rats: Lab Project Number:
             3415-90-033 l-AM-001. Unpublished study prepared by Ricerca, Inc.  507 p.

42723202     Liu, Y.; Marciniszyn, J.; Killeen, J.; et al. (1993) Study of the Distribution,
             Excretion and Pharmacokinetics of Radiolabel following Repeated Oral
             Administration of DCPA to Sprague-Dawley Rats: Report Amendment No. 1: Lab
             Project Number: 3415900331AM001001. Unpublished study  prepared by
             Ricerca, Inc. 26 p.

42723203     Liu, Y.; Savides,  M.; Johnson, D.; et al. (1993) Study to Identify the Metabolites
             of (carbon 14)-DCPA in Rat Urine: Lab Project Number:  3886-91-0100-AM-001.
             Unpublished study prepared by Ricerca, Inc. 188 p.
42731001     Lucas, F.; Mizens, M.; Laveglia, J. (1993) A Combined Chronic
             Toxicity/Oncogenicity Study in Rats with DCPA: Lab Project Number:
             3339-90-0005-TX-006.  Unpublished study prepared by Ricerca, Inc.  6562 p.

42836102     Hughes, J.; Balcom, P. (1993) The Toxicity of DCPA Technical to Anabaena
             flos-aquae: Lab Project Number: B038-033-1. Unpublished study prepared by
             Malcolm Pirnie, Inc.  24 p.

42882401     Hughes, J.; Balcom, P.; Alexander, M. (1993) The Toxicity of DCPA Technical to
             Navicula pelliculosa: Lab Project Number:  B038-033-2. Unpublished study
             prepared by Malcolm Pirnie, Inc. 25 p.
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                                BIBLIOGRAPHY

MRID                         CITATION
43052201     Andre, J. (1993) Supplemental Data to Study of the Distribution, Excretion, and
             Pharmacokinetics of Radiolabel following Repeated Oral Administration of DCPA
             to Sprague-Dawley Rats: Lab Project Number: TX-93-JCA-001-001:
             3415-90-0331-AM-OO1-001. Unpublished study prepared by Ricerca, Inc. 11 p.

43192401     Mayo, H.; Owens, E.  (1994) Dacthal Data Call-in Samples: Supplement to MRID
             #40402101: Lab Project Number: PC/94/HM/001/ 001.  Unpublished study
             prepared by ISK Biosciences Corp.  13 p.

43406401     Formanik, J. (1994) Method for the Determination of Residues of DCPA and Its
             Degradation Products in Milk and Beef Fat: Lab Project Number:
             6065/94/0163/MD/001: 94/0163.  Unpublished study prepared by Ricerca, Inc. 52
             P-
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                   UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                                      WASHINGTON, D.C. 20460
                                                                            OFFICE OF
                                                                      PREVENTION, PESTICIDES
                                                                       AND TOXIC SUBSTANCES
                        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 6; 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 5).

       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
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information is authorized under the Paperwork Reduction Act by OMB Approval No. 2070-0107
and 2070-0057 (expiration date 3-31-99).

       This Notice is divided into six sections and six 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:

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 (Form A)
       3 -    Generic Data Call-In and Product Specific Data Call-In Requirements Status and
             Registrant's Response Forms with Instructions (Form B)
       4 -    EPA Batching of End-Use Products for Meeting Acute Toxicology Data
             Requirements for Reregistration
       5 -    List of Registrants Receiving This Notice
       6 -    Cost Share and Data Citation 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 ingredient(s).
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.
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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:
703-605-6000).

       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-In(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).
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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-Call-in
Response Form, and the Requirements Status and Registrant's Response Form, (contained in
Attachments 2 and 3, respectively).

       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(s). 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.

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       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) 308-8358.

       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;

       (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  complete the Requirements Status and Registrant's Response Form. Generic

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Data Exemption cannot be selected as an option for 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(s) 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 well 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.

       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 2 and 3, respectively).  The Data Call-In

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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 Call-In Response Form unless 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. 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 a completed Data Call-In Response Form.
indicating your election of this option. Voluntary cancellation is item number 5 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. 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 Reregi strati on 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)
       (3)     I have made offers to cost-share (Offers to Cost Share)
       (4)     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

       If you choose to develop the required data it must be in conformance with Agency
guidelines 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

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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.

       The time frames in the Requirements Status and Registrant's Response Form are the time
frames that the Agency is allowing for 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

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request EPA (by selecting this option) to exercise its discretion not to suspend your
registration(s), although you did 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(s)
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 6.  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)(B)(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.

       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:
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       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 must also contain all
              GLP-required quality assurance and quality control information pursuant to the
              requirements of 40 CFR Part 160. Registrants also must certify at the time of
              submission of 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 Reregi strati on 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
              documents 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
              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.

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       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 a 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 number 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 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.
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       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 7a or 7b), 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)
       (3)    I have made offers to cost-share (Offers to Cost Share)
       (4)    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.l, 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.l,
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 III.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.
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Option 4. Submitting an Existing Study — The same requirements described for generic data (see
Section III.C.l., Option 4) apply to this option for product specific data.

Option 5. Upgrading a Study - The same requirements described for generic data (see Section
III.C.L, Option 5) apply to this option for product specific data.

Option 6. Citing Existing Studies - The same requirements described for generic data (see
Section III.C.l., 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 (III.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:

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       (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.

       (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

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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 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 for your product(s). you must choose a method of meeting the
requirements of this Notice within the time frame provided by this Notice. Within 30 days
of your receipt of 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.
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SECTION IV.      CONSEQUENCES OF FAILURE TO COMPLY WITH THIS
                    NOTICE

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).

       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:

              a. 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.

              b. Fulfill the commitment to develop and submit the data as required by this
              Notice; or
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              c. 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.

       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,

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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
              UNREASONABLE 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(s) 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 the voluntary
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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
                                   Reregi strati on Division
Attachments
       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 Batching of End-Use Products for Meeting Acute Toxicology Data
             Requirements for Reregistration
       5 -    List of Registrants Receiving This Notice
       6 -    Confidential Statement of Formula. Cost Share and Data Citation Forms
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DCPA DATA CALL-IN CHEMICAL STATUS SHEET

INTRODUCTION

      You have been sent this Product Specific Data Call-In Notice because you have product(s)
containing DCPA.

      This Product Specific Data Call-In Chemical Status Sheet contains an overview of data
required by this notice, and point of contact for inquiries pertaining to the reregi strati on of DCPA.
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) a list of registrants receiving this DCI (Attachment
5) and (6) the Cost Share and Data Citation Forms in replying to this DCPA Product Specific Data
Call-In (Attachment 6).  Instructions and guidance accompany each form.

DATA REQUIRED BY THIS NOTICE

      The additional data requirements needed to complete the database for DCPA are contained
in the Requirements Status and Registrant's Response. Attachment 3. The Agency has concluded that
additional data on DCPA are needed for 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 DCPA products.

INQUIRIES AND RESPONSES TO THIS NOTICE

      If you have any questions regarding this product specific data requirements and procedures
established by this Notice, please contact Venus Eagle at (703) 308-8045.

      All responses to this Notice for the Product Specific data requirements should be submitted
      to:
             Venus Eagle
             Chemical Review Manager Team 81
             Product Reregistration Branch
             Special Review and Reregistration Branch (7508C)
             Office of Pesticide Programs
             U.S. Environmental Protection Agency
             Washington, D.C. 20460

             RE: DCPA
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DCPA DATA CALL-IN CHEMICAL STATUS SHEET

INTRODUCTION

      You have been sent this Generic Data Call-In Notice because you have product(s) containing
DCPA.

      This Generic Data Call-In Chemical Status Sheet, contains an overview of data required by
this notice, and point of contact for inquiries pertaining to the reregi strati on of DCPA.   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 3), (4) a list of registrants receiving this DCI (Attachment 5), and (5) the Cost Share
and Data Citation Forms  in replying to this DCPA Generic Data Call In (Attachment 6).  Instructions
and guidance accompany each form.

DATA REQUIRED BY THIS NOTICE

      The additional data requirements  needed to complete the generic database for DCPA are
contained in the Requirements Status and Registrant's Response. Attachment 3. The  Agency has
concluded that additional product chemistry data on DCPA are needed.  These data are needed to
fully complete the reregi strati on of all eligible DCPA 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 Jill Bloom at (703) 308-8019.

      All responsades to this Notice for the generic data requirements should be submitted to:

             Jill Bloom, Chemical Review Manager
             Reregistration Branch, II
             Special Review and Registration Division (7508C)
             Office of Pesticiafde Programs
             U.S. Environmental Protection Agency
             Washington, D.C.  20460
             RE:  DCPA
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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 Reregi strati on Program under the Federal Insecticide, Fungicide, and Rodenticide Act.   If
you are an end-use product registrant only and have been sent this DCI letter as part of a RED
document you have been sent just the product specific "Data Call-In Response Forms." Only
registrants responsible for generic data have been sent the generic data response form.  The type
of Data Call-In (generic or product specific) is indicated in item number 3 ("Date and Type
of DCI") on each form.

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 2137, 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 1.       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.

ItemS.       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 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.

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INSTRUCTIONS FOR COMPLETING THE DATA CALL-IN RESPONSE FORMS
Generic and Product Specific Data Call-In
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.

             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."

Item 7b.      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.
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 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 canceled this product. For these cases, please supply all
        relevant details so that EPA can ensure that its records are correct.
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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 reregi strati on program under the Federal Insecticide,
Fungicide, and Rodenticide Act.   If you are an end-use product registrant only and have been
sent this DCI letter as part of a RED document you have been sent just the product specific
"Requirements Status and Registrant's Response Forms." Only registrants responsible for generic
data have been sent the generic data response forms.  The type of Data Call-In (generic or
product specific) is indicated in item number 3 ("Date and Type of DCI") on each form.

       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 2137,  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.
                                          171

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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, Subpartc.

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.
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    INSTRUCTIONS FOR COMPLETING THE "REQUIREMENTS STATUS AND
                        REGISTRANT'S RESPONSE FORMS"

Generic and Product Specific Data Call-In

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
             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
             O     Indoor residential

Item 7.       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                End-Use Product
             MP                 Manufacturing-Use Product
             MP/TGAI           Manufacturing-Use Product and Technical   Grade Active
                                 Ingredient
             PAI                 Pure Active Ingredient
             PAI/M              Pure Active Ingredient and Metabolites
             PAI/PAIRA         Pure Active Indredient or Pute Active
                                 Ingredient Radiolabelled
             PAIRA             Pure Active Ingredient Radiolabelled
             PAIRA/M           Pure Active Ingredient Radiolabelled and Metabolites
             PAIRA/PM         Pure Active Ingredient Radiolabelled and Plant Metabolites
             TEP                Typical End-Use Product
             TEP	%          Typical End-Use Product, Percent Active Ingredient
                                 Specified
             TEP/MET           Typical End-Use Product and Metabolites
                                          173

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             TEP/PAI/M          Typical End-Use Product or Pure Active Ingredient and
                                  Metabolites
             TGAI               Technical Grade Active Ingredient
             TGAI/PAI           Technical Grade Active Ingredient or Pure Active
                                  Ingredient
             TGAI/PAIRA        Technical Grade Active Ingredient or Pure Active
                                  Ingredient Radiolabelled
             TGAI/TEP           Technical Grade Active Ingredient or Typical End-Use
                                  Product
             MET                Metabolites
             IMP                 Impurities
             DEGR              Degradates
             *                    See: guideline comment

Item 8.       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 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 Shared 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.
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                     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 Shared 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 Call-In Notice  and I have
              attached the needed supporting information along with this response.

Options.      ON BOTH FORMS: (Upgrading  a Studv^) 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 Studv^) I am citing an existing study that
              has been previously classified by EPA as acceptable, core, core minimum,
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             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 9) 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.

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 for 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

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                      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 this product. For these
                                             177

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EPA'S BATCHING OF DACTHAL; DCPA; DIMETHYL TETRACHLORO-
TEREPHTHALATE; 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 reregi strati on of products containing DCPA as the active
ingredient, 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 registrant's 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 5) or Citing an Existing Study (Option 6). If a registrant depends on another's data,

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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.

       Sixty-two registered products were found which contain DCPA as the active ingredient.

       There are only two wettable powder products.  One, EPA Reg.  # 228-222, will not be
batched because it contains 25% AI. The other, EPA Reg. # 4-296, will not be batched because it
is a wettable powder product containing 75% AI.

       One product, EPA Reg. # 50534-10, will not be batched because of insufficient CSF.

       The remaining products have been placed into three Tables.
Table I consisting of three batches in accordance with the active and inert ingredients, type of
formulation, and current labeling.  Table II  consists of unbatched fertilizer products.  Table III
consists of miscellaneous unbatched products.

                                        TABLE I

              Batch 1 identifies concentrated and/or technical products.

              Batch 2 identifies those products with low levels of DCPA.

              Batch 3 identifies emulsifiable concentrate products.

                                        TABLE II

       These fertilizer-containing products are not being batched. Formulations may change,
which would also  change their acute toxicity. The Agency is developing a policy for the
regulation of fertilizers containing pesticides.

                                       TABLE III

              Miscellaneous unbatched products.


TABLE I

       Batch 1 (Concentrates)

        A representative database for these products is summarized here:
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       Data Required
Toxicitv Category    Classification
       Acute Oral (§81-1)
       Acute Dermal (81-2)
       Acute Inhal. (81-3)
       Eyelrr. (§81-4)
       Dermal Irr. (§81-5)
       Dermal Sens. (§81-6)
       IV
       III
       IV
       III
       IV
Non-sensitizing
       A
       A
       A
       A
       A
       A
* Denotes data review available
EPA Reg. #
2-296
407-338
677-290
9198-24
11684-2
50534-1
50534-20
50534-28
50534-113*
% Active Ingredient
90.0
100.0
75.3
75.3
75.3
79.0
79.0
75.0
90.0
Formulation Type
G
G
G
G
G
G
G
G
G
      Batch 2 (low levels of DCPA).

      A representative database for these products is summarized here:
      Data Required
      Acute Oral (§81-1)
      Acute Dermal (81-2)
      Acute Inhal. (81-3)
      Eyelrr. (§81-4)
      Dermal Irr. (§81-5)
      Dermal Sens. (§81-6)
Toxicitv Category
       IV
       IV
       IV
       IV
       IV
Non-sensitizing
Classification
       G
       G
       G
       G
       G
       G
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* Denotes data review available
EPA Reg. #
4-300
16-42
239-2532*
407-317
407-416
512-237
538-128
538-235
557-1998
572-193
572-237
588-235
769-911
802-441
829-165
961-273
961-278
1386-610
2217-617
7001-275
8590-377
8660-22
8660-33
8660-62
8660-98
9198-1
% Active Ingredient
6.7
6.7
13.3
5.0
6.7
9.2
5.0
5.0
5.75
6.4
6.9
5.6
5.6
5.0
5.0
5.0
6.7
5.0
2.5
5.0
5.0
7.0
2.3
2.5
5.0
2.9
Formulation Type
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
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EPA Reg. #
10107-82
10107-86
10370-272
32802-14
32802-27
33955-474
50534-3
50534-17
% Active Ingredient
5.0
2.5
3.4
3.5
5.6
2.5
5.6
3.4
Formulation Type
G
G
G
G
G
G
G
G
       Batch 3 (emulsifiable concentrate products).

       There are no toxicity data for these products.
EPA Reg. #
1769-246
50534-187
% Active Ingredient
6.0
21.4
Type of Formulation
EC
EC
TABLE II (Fertilizers; not batched)

       Table II identifies products that were not batchable, but were not placed in a "No Batch"
group; The products in this category contain significant amounts of fertilizer.  Many of these
fertilizer components may change from time to time as the registrant sees fit.

       Since as much as 96% of these formulations may vary, the Agency does not believe it is
possible to batch them. Since the formulation of these products may vary, a set of acute toxicity
studies conducted on one of them may not consistently represent that product's acute toxicity
potential.  Registrants of products in Table II who certify that they do not vary the inert or
fertilizer components of their products may request that their products be batched with other
similar products. The Agency does not believe that requesting acute data on all fertilizer
combinations is sensible.  The Agency is in the process of developing a policy that addresses
labeling for these products.

       No toxicity studies are available for these products.
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EPA Reg. #
238-157
538-87
802-503
802-576
3234-28
7001-270
8378-13
3442-TNE
8660-100
10107-4
11648-2
32802-6
32802-17
42957-83
% Active Ingredient
3.9
6.3
4.0
2.6
3.3
3.1
5.0
3.2
6.7
2.0
1.2
4.7
6.8
4.7
Formulation Type
G
G
G
G
G
G
G
G
G
G
G
G
G
G
TABLE III  Miscellaneous products not batched, either because of dissimilar concentrations of
AI or lack of formulation information.

       No toxicity studies are available for these products.
EPA Reg. #
228-222
4-296
50534-10
%AI
25.0
75.0
NA
Type of Formulation
WP
WP
NA
Key

EC = Emulsifiable Concentrate
FC = Flowable Concentrate
G = Granular
WP = Wettable Powder
                                          183

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184

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Attachment       5. List of All Registrants Sent This Data Call-In (insert) Notice
THIS PAGE MUST BE REMOVED PRIOR TO PRINTING AND REPLACED WITH
THE REGISTRANT LISTING PRODUCED FROM THE DCI MODULE.
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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 40 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.


                                          186

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1
 o
                      United States Environmental Protection Agency
                                  Washington, D.C. 20460
                            Certification of Offer to Cost
                         Share in the Development of Data
  Form Approved
OMB No. 2070-0106,
    2070-0057
 Approval Expires
     3-31-99
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-233, 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
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 firms on the following
date(s):
Name of Firm(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
                                               189

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Name and Title (Please Type or Print)
                                                                    190

-------
EPA Form 8570-32 (5/91) Replaces EPA form 8580 which is obselete
                                                                   191

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                                          UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                                                                   401 M Street, S.W.
                                                               WASHINGTON,  D.C.  20460
  Paperwork Reduction Act Notice: The public reporting burden for this collection of information is estimated to average 1.25 hours per response for registration
  and 0.25 hours per response for reregistration and special review activities, including time for reading the instructions and completing the necessary forms. Send
  comments regarding burden estimate or any other aspect of this collection of information, including suggestions for reducing the burden to: Director, OPPE
  Information Management Division (2137), U.S. Environmental Protection Agency, 401 M Street, S.W., Washington, DC 20460.
  Do not send the completed form to this address.
                                             Certification with Respect to Citation of Data
Applicant's/Registrant's Name, Address, and Telephone Number
Active Ingredient(s) and/or representative test compound(s)
General Use Pattern(s) (list all those claimed for this product using 40 CFR Part 158)
EPA Registration
Number/File Symbol
Date
Product Name
     NOTE: If your product is a 100% repackaging of another purchased EPA-registered product labeled for all the same uses on your label, you do not need to
  submit this form. You must submit the Formulator's Exemption Statement (EPA Form 8570-27).
         I am responding to a Data-Call-in Notice, and have included with this form a list of companies sent offers of compensation (the Data Matrix form should
         be used for this purpose).
                                         SECTION I: METHOD OF DATA SUPPORT (Check one method only)
         I am using the cite-all method of support, and have included with this form
         a list of companies sent offers of compensation (the Data Matrix form
         should be used for this purpose).
I am using the selective method of support (or cite-all option
under the selective method), and have included with this form a
completed list of data requirements (the Data Matrix form must be
used).
                                                     SECTION II: GENERAL OFFER TO PAY
  [Required if using the cite-all method or when using the cite-all option under the selective method to satisfy one or more data requirements]

         I hereby offer and agree to pay compensation, to other persons, with regard to the approval of this application, to the extent required by FIFRA.
                                                          SECTION III: CERTIFICATION
           I certify that this application for registration, this form for reregistration, or this Data-Call-in response is supported by all data submitted or cited in the
  application for registration, the form for reregistration, or the Data-Call-in response. In addition, if the cite-all option or cite-all option under the selective method is
  indicated in Section I, this application is supported by all data in the Agency's files that (1) concern the properties or effects of this product or an identical or
  substantially similar product, or one or more of the ingredients in this product; and (2) is a type of data that would be required to be submitted under the data
  requirements in effect on the date of approval of this application if the application sought the initial registration of a product of identical or similar composition and
  uses.

           I certify that for each exclusive use study cited  in support of this registration or reregistration, that I am the original data submitter or that I have obtained
  the written permission of the original data submitter to cite that study.

           I certify that for each study cited in support of this registration or reregistration that is not an exclusive use study, either: (a) I  am the original data
  submitter; (b) I have obtained the permission of the original data submitter to use the study in support of this application; (c) all periods of eligibility for
  compensation have expired for the study; (d) the study is in the public literature; or (e) I have notified in writing the company that submitted the study and have
  offered (I) to pay compensation to the extent required  by sections 3(c)(1)(F) and/or 3(c)(2)(B) of FIFRA; and (ii) to commence negotiations to determine the
  amount and terms of compensation, if any, to be paid for the use of the study.

           I certify that in all instances where an offer of compensation is required, copies of all offers to pay compensation and evidence of their delivery in
  accordance with sections 3(c)(1)(F) and/or 3(c)(2)(B) of FIFRA are available and will  be submitted to the Agency upon request. Should I fail to produce such
  evidence to the Agency upon request, I understand that the Agency may initiate action to deny, cancel or suspend the registration of my product in conformity with
  FIFRA.

           I certify that the statements I have made on this form and all attachments to it 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
Date
Typed or Printed
Name and Title
EPA Form 8570-34 (9-97) Electronic and Paper versions available. Submit only Paper version.
                                                                       192

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                                                       UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                                                                             401 M Street, S.W.
                                                                        WASHINGTON, D.C. 20460
                                                                                                                                      Form Approved OMB No. 2070-0060
 Paperwork Reduction Act Notice: The public reporting burden for this collection of information is estimated to average 0.25 hours per response for registration activities and 0.25 hours per response for
 reregistration and special review activities, including time for reading the instructions and completing the necessary forms.  Send comments regarding the burden estimate or any other aspect of this collection of
 information, including suggestions for reducing the burden to: Director, OPPE Information Management Division (2137), U.S. Environmental Protection Agency, 401 M Street, S.W., Washington, DC 20460. Do not
 send the form to this address.
                                                                                 DATA MATRIX
 Date
EPA Reg No./File Symbol
                                                                                                                   Page   of
Applicant's/Registrant's Name & Address
Product
 Ingredient
 Guideline Reference Number
                                                   Note
Guideline Study Name
EPA Form 8570-35 (9-97) Electronic and Paper versions available. Submit only Paper version.
Copy
                                                      Public File
                                                                                193

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194

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Form Approved OMB No. 2070-0060
/X\ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
^^J 401 M Street, S.W.
WASHINGTON, D.C. 20460
Paperwork Reduction Act Notice: The public reporting burden for this collection of information is estimated to average 0.25 hours per response for registration activities and 0.25 hours per response for
reregistration and special review activities, including time for reading the instructions and completing the necessary forms. Send comments regarding the burden estimate or any other aspect of this collection of
information, including suggestions for reducing the burden to: Director, OPPE Information Management Division (2137), U.S. Environmental Protection Agency, 401 M Street, S.W., Washington, DC
20460. Do not send the form to this address.
DATA MATRIX
Date
Applicant's/Registrant's Name & Address
EPA Reg No./File Symbol
Page of
Product
Ingredient
Guideline Reference Number















Guideline Study Name















MRID Number















Signature
Submitter















Status















Name and Title
Note















Date
EPA Form 8570-35 (9-97) Electronic and Paper versions available. Submit only Paper version.
Agency Internal Use Copy
                                                                                          195

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                                                                INSTRUCTIONS FOR DATA MATRIX
INSTRUCTIONS:  Identify all data submitted or cited and all submitters from whom permission has been received or to whom offers to pay have been sent by entering sufficient
information in the attached matrix (photocopy and attach additional pages as necessary). Complete all columns; omission of essential information will delay approval of the
registration/reregistration.  On each page enter the date, Applicant's/Registrant's name,  EPA Registration Number or application file symbol of the product, ingredient,  page number, and
total number of pages.

The Data Compensation Form entitled "Certification with Respect to Citation of Data" and the Data Matrix will be publicly available, except for the Guideline Reference Number, Guideline
Study Name, and MRID Number columns after the registration/reregistration of this product has been granted or once this form is received in response to a Data-Call-in Notice. However,
the information in the Guideline  Reference Number, Guideline Study Name, and MRID Number columns is available through the Freedom of Information Act in association with the EPA
Registration Number.

Ingredient:  Identify the active ingredient(s) in this product for which data are cited.  The active ingredient(s) are to be identified by entering the chemical name and the CAS registry
number.  Begin a new page for each separate active ingredient for which data are cited.  If bridging data from a related  chemical or representative test compound are cited, enter the
identity of that chemical/representative test compound including the EPA Registration Number/File Symbol if appropriate.

        If the cite-all method is  used for all data supporting this particular ingredient, enter "CITE-ALL" in the Guideline Reference Number column and leave the Guideline Study Name
column blank. If the cite-all method is used for a  particular Guideline Reference Number enter "CITE-ALL" in the MRID Number column on the line for that Guideline Reference Number.
In either case, enter all submitters to whom offers  to pay have been sent on subsequent  lines.  [Note:  if the selective method of support is used and written authorization (letter of
permission) is provided, the individual Guideline Reference Number, Guideline Study Name, and MRID Number columns must still be completed.]  Otherwise:

Guideline Reference Number:  Enter on separate lines in numerical order the Guideline Reference Numbers from 40 CFR Part 158 for all studies cited to support the
registration/reregistration for this ingredient.

Guideline Study Name:  For each Guideline  Reference Number cited, enter the corresponding Guideline Study Name.

MRID Number:  For each individual  study cited in support of a Guideline Reference Number and Guideline Study Name, enter the Master Record Identification (MRID) Number listed in
the Pesticide Document Management System (PDMS).  Enter only  one MRID Number on each line.  Note that more than one MRID Number may be required per Guideline Reference
Number.  Note:  Occasionally a  study required to maintain a registration/reregistration is  not associated with a Guideline Reference Number and Guideline Study Name. In such case,
enter the MRID Number(s) for the study(ies).

Submitter: Using the most recent Data Submitters List, identify the Original  Data Submitter with their current address for each study  cited. The EPA assigned company number or other
abbreviation may be used. Clearly explain any variations (alternate addresses,  data owners not on the Data Submitters List, etc.) in footnotes to this table.

Status:  Enter one of the following codes for each study cited, as appropriate:

OWN:           I am the Original Data Submitter for this study.

EXC:           I have obtained written permission of the Original Data Submitter to cite this exclusive-use study in support of this application.

PER:           I have obtained the permission of the Original Data Submitter to use this study in support of this application.

OLD:           The study was submitted more than 15 years ago and all periods of compensation have expired.

PL:             The study is in the public literature.

PAY:           I have notified in writing the Original Data Submitter or, if the cite-all method is used, all companies listed  in the most current Data Submitters List for this ingredient,
                and have offered (a) to pay compensation in accordance with  FIFRA sections 3(c)(1 )(F) and/or 3(c)(2)(B), and (b) to commence negotiations to determine the amount
                and terms of compensation,  if any, to be paid for  the use of the study(ies).

GAP:           This Guideline data requirement is a data gap as  defined in 40 CFR sections 152.83(a) and 152.96.

FOR:           I am taking the formulator's exemption for this ingredient only. Other columns of this line should  be marked "NA".  However, if this product is to be
                registered/reregistered for additional uses for which the purchased EPA registered ingredient is not supported, additional data must be submitted or cited here to support
                those uses.


                                                                                196

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Note:            If additional explanation is needed, enter a footnote number in this column and attach the corresponding explanation.
                                                                                 197

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APPENDIX E.  List of Available Related Documents
                 198

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       The following is a list of available documents for DCPA that may further assist you in
responding to this Reregistration Eligibility Decision document. These documents may be obtained
by the following methods:

Electronic
File format:   Portable Document Format (.PDF) Requires Adobe® Acrobat or compatible reader.
             Electronic copies are available on our website at www.epa.gov/REDs, or contact
             Connie Childress at (703) 308-8074.

       1.     PR Notice 86-5.

       2.     PR Notice 91-2 (pertains to the Label Ingredient Statement).

       3.     A full copy of this RED document.

       4.     A copy of the fact sheet for DCPA.


       The following documents are part of the Administrative Record for DCPA and may included
in the EPA's  Office of Pesticide  Programs Public Docket.  Copies of these documents are not
available electronically, but may be obtained by contacting the person listed on the Chemical Status
Sheet.

       1.     Health and Environmental Effects Science Chapters.

       2.     Detailed Label Usage Information System (LUIS) Report.

       The following Agency reference documents  are not available electronically, but may be
obtained by contacting the person listed on the Chemical Status Sheet of this RED document.

       1.     The Label Review Manual.

       2.     EPA Acceptance Criteria

       3.     Appendix A - Table of Use Patterns Subject to Reregistration
                                          199

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