r/EPA
            United State*
            Environmental Protection
            Agency
             Office of
             Penteidee and Toxic Subetancee
             Washington OC 20460
                                      540/RS-88-117
            Peeticidee
Guidance for the
Reregistration of
Pesticide  Products
Containing Metalaxyl
as the Active Ingredient

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                             OMB Control No.  2070-0057
                             Expires  11/89
            GUIDANCE FOR THE
  REREGISTRATION OF PESTICIDE PRODUCTS

               CONTAINING

N-(2,6-DIMETHYLPHENYL)-N-(METHOXYACETYL)
         ALANINE, METHYL ESTER
       (REFERRED TO AS METALAXYL)
        AS THE ACTIVE INGREDIENT

           CASE NUMBER:  0081

     CAS (DOCKET) NUMBER 57837-19-1

      EPA SHAUGHNESSY CODE:  113501

           .	SŁETEŁ[BER 1988
    ENVIRONMENTAL PROTECTION AGENCY

      OFFICE OF PESTICIDE PROGRAMS

        WASHINGTON, D.C.  20460

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                       TABLE OF CONTENTS
GLOSSARY OF TERMS AND ABBREVIATIONS

I.     INTRODUCTION 	  1

II.    CHEMICAL(s) COVERED BY THIS STANDARD 	  4
         A.  Description of Chemical
         B.  Use Profile
         C.  History
III.   AGENCY ASSESSMENT  	  6
         A.  Summary
      t   B.  Risk Assessment
         C.  Other Science Findings
         D.  Tolerance Reassessment

IV.    REGULATORY POSITION AND RATIONALE  	 22
         A.  Regulatory Positions and Rationales
         B.  Criteria for Registration
         C.  Acceptable Ranges and Limits
         D.  Required Labeling

V.     PRODUCTS SUBJECT TO THIS STANDARD—--—-	31
         A.  Manufacturing Use Products Containing This
             Pesticide As The Sole Active Ingredient
         B.  Manufacturing Use Products Containing This
             Pesticide As One of Multiple Active Ingredients
         C.  End Use Products Containing This Product As
             The Sole Active Ingredient
         D.  End Use Products Containing This Pesticide As
             One Of Multiple Active Ingredients

VI.    REQUIREMENT FOR SUBMISSION OF GENERIC DATA	33
         A.  What are Generic Data?
         B.  Who Must Submit Generic Data?
         C.  What Generic Data Must be Submitted?
         D.  How to Comply with DCI Requirements
         E.  Registrant Requests Regarding Data Requirements
             and Agency Responses
         F.  Test Protocols and Standards
         G.  Procedures for Requesting A Change in Test Protocol
         H.  Procedures for Requesting Extensions of Time
         I.  Data Format and Reporting Requirements
         J.  Existing Stocks Provision upon Suspension
             or Cancellations
                               -i-

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VII.   REQUIREMENT FOR SUBMISSION OF PRODUCT-SPECIFIC DATA  .   39

VIII.  REQUIREMENT FOR SUBMISSION OF REVISED LABELING ....   40

IX.    INSTRUCTIONS FOR SUBMITTAL 	   40
         A.  Manufacturing-Use Products (sole active)
         B.  Manufacturing-Use Products (multiple active)
         C.  End-Use Products (Sole active)
         D.  End-Use Products (Multiple active)
         E.  Intrastate Products
                                -11-

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                            APPENDICES

I.    DATA APPENDICES	44

      Guide to Tables

      Table A

      Table B

II.    LABELING APPENDICES  	 80

      Summary of Label Requirements and Table

    *  40 CFR 156.10 Labeling Requirements

      Physical/Chemical Hazards Labeling Statements

      Storage Instructions

      Pesticide Disposal Instructions

      Container Disposal Instructions

III.   BIBLIOGRAPHY APPENDICES  .  .  .  .  , -r-t—-.——--.  ....   144

      Guide to Bibliography

      Bibliography

IV.    FORMS APPENDICES 	   161

      EPA Form'8580-1   FIFRA S3(c)(2)(B) Summary Sheet

      EPA Form 8580-6   Certification of  Attempt to Enter Into
                        an Agreement  with Other Registrants for
                        Development of  Data

      EPA Form 8580-4   Product Specific  Data Report

      EPA Form 8570-27  Formulator's  Exemption Statement
                              -HIT

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                 GLOSSARY  OF  TERMS  AND  ABBREVIATIONS


 The  following  terms  are used throughout  this  Registration
 Standard and are  defined  here for  the  convenience  of  the  reader.

 ADI:  (Acceptable  Daily Intake)  An  acceptable  daily intake  of
      pesticide  residue based on  a  complete  data  base.

 ai:   Active ingredient

 CAS:  Chemical  Abstract Service  (number)

 EEC:  (Estimated  Environmental  Concentration) Estimated pesticide
      concentration  in the environment (terrestrial or aquatic
      ecosystem).
   t
 EP:   End-use Product

 EPA:  The Environmental Protection Agency,  also  "the  Agency"

 FIFRA:  The Federal  Insecticide, Fungicide, and  Rodenticide Act

 HOT:  Highest dose tested

       (median  lethal concentration):  a statistically derived
       concentration of a substance that can  be _expjected.-to cause
       death in 50 percent of test animals, expressed as weight
       or volume  of  test substance per volume of air  or water
       or per weight of feed  (e.g., mg/L or ppm).

       (median  lethal dose):  a statistically derived single dose
       that can be expected  to cause death  in 50 percent of animals
       when administered by  the route indicated, expressed as
       weight of  substance per unit weight  of test animal  (e.g.,
       mg/kg).

LEL:  Lowest Effect Level

MOS:  Margin of Safety -

MPI:  Maximum Permissible Intake

MRID:  Master Record Identification (number)—EPA's system of
       tracking studies used  in support of  registrations

MP:  Manufacturing-use product

NPDES:  National Pollution Discharge Elimination System

NOEL:   No Observed Effect Level—the maximum dose used in a
        test which produces no observed adverse effects.

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OPP:  The Office of Pesticide Programs (EPA)
OM:  Organic matter (used to describe soils)
ppm:  Parts per million
PADI: (Provisional Acceptable Daily Intake) An acceptable daily
      intake of pesticide residue based on a limited data base.
PAI:  Pure active ingredient
Technical:  Active ingredient as manufactured
TMRC: (Theoretical Maximum Residue Contribution)

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                       1•   INTRODUCTION

     EPA has established the Registration Standards program
in order to provide an orderly mechanism by which pesticide
products containing the same active ingredient can be reviewed
and standards set for compliance with FIFRA.  The standards
are applicable to reregistration and future applications for
registration of products containing the same active ingredient.
Each registrant of a product containing an active ingredient
subject to this Standard who wishes to continue to sell or
distribute that product must bring his product and labeling
into compliance with FIFRA, as instructed by this Standard.

     The Registration Standards program 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" criteria of FIFRA.  In its review EPA identifies

     1.  Studies that are acceptable to support the data
requirements for the currently registered uses of the pesticide.

     2.  Additional studies necessary to support continued 	 _
registration.  The additional studies may not have been
required when the product was initially registered or may be
needed to replace studies that are now considered inadequate.

     3.  Labeling revisions needed to ensure that the product
is not misbranded and that the labeling is adequate to protect
man and the environment.

     The detailed scientific review and use index which are
not contained in this document, but is available upon request1,
focuses on the pesticide active ingredient.   The scientific
review primarily discusses the Agency's evaluation of and
conclusions from available data in its files pertaining to
the pesticide active ingredient.   However, during the review
of these data the Agency is also looking for potential hazards
that may be associated with the end use products that contain
the active ingredient.   The Agency will apply the provisions
of this Registration Standard to end use products if necessary
to protect man and the environment.
     scientific reviews and use index are available from the
 National Technical Information Service,  5285 Port Royal Road,
 Springfield,  Va.   22161 or from the Order Desk (703) 487-4650,

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     EPA's reassessment results in the development of a
regulatory position,  contained in this Registration Standard,
on the pesticide and each of its registered uses.   See
Section IV - Regulatory Position and Rationale.   Based on its
regulatory position,  the Agency may prescribe a variety of
steps to be taken by registrants to maintain their registrations
in compliance with FIFRA.  These steps may include:

     1.  Submission of data in support of product registration;

     2.  Modification of product labels;

     3.  Modifications to the manufacturing process of the
pesticide to reduce the levels of impurities or contaminants;

     4.  Restriction of the use of the pesticide to certified
applicators or other specially trained individuals;

     5.  Modification of uses or formulation types; or

     6.  Specification of packaging limitations.

     Failure to comply with the data submission requirements
may result in the issuance of a Notice of Intent to Suspend.
Failure to comply with the other requirements in this Standard
may result is the issuance of a Notice of Intent to Cancel.

     In addition, in cases in which hazards to man or the
environment are identified, the Agency may initiate a special
review of the pesticide in accordance with 40 CFR Part 154
to examine in depth the risks and benefits of use of the
pesticide.  If the Agency determines that the risks of the
pesticide's use outweigh the benefits of use, the Agency
may propose additional regulatory actions, such as cancellation
of uses of the pesticide which have been determined to cause
unreasonable adverse effects on the environment.

     EPA has authority under the Data Call-in (DCI) provisions
of FIFRA sec. 3(c)(2)(B) to require that registrants submit
data to answer our questions regarding the chemical, toxicological,
and environmental characteristics and fate of a pesticide.
This Registration Standard lists the data EPA believes are
necessary to resolve our concerns about this pesticide.
These  data are listed in the Tables A, and B in Appendix  I.
Failure to comply with the DCI requirements enumerated in
this Registration Standard may result in issuance by EPA  of  a
Notice of Intent to Suspend the affected product registrations.

     Registrants are reminded that FIFRA sec. 6(a)(2) requires
them to submit factual information concerning possible unreason-
able adverse effects of a pesticide at any time that they

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become aware of such information.  Registrants must notify
the Agency of any information, including interim or preliminary
results of studies, if that information suggests possible
adverse effects on man or the environment.  This requirement
is independent of the specific time requirements imposed by
EPA for submission of completed studies called in by .the
Agency and continues as long as the products are registered
under FIFRA.

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              II.   CHEMICAL COVERED BY THIS STANDARD
A.   Description of Chemical

    The following chemical is covered by this Registration
Standard:

     Common Name:  METALAXYL
     Chemical Name:  N-(2,6-Dimethylphenyl)-N-(methoxyacetyl)
                     alanine methyl ester
     CAS Number:  57837-19-1
     OPP Shaughnessy Number:  113501
     Year  of Initial Registration:   1979
     Date  of Initial Registration Standard:   December 1981
     Empirical Formula:   Ci5H2iNOA
     Trade Name:  Ridomil, Subdue
     Description of Physical
     Characteristics of  Chemical:
                                   Apron,  Proturf
                                   Metalaxyl  is a white to
                                   odorless crystal with a
                                   bility in  water (at 20
 beige i
 solu-
°C)  of
                                   7100 ppm,  65% in
                                   55% in benzene.
                                                    methanol and
B.   Use Profile

    Type of Pesticide:   Systemic fungicide
    Pests Controlled:
    Registered Uses:
    Principal Uses;
                       Soil borne diseases caused by Pythium and
                       Phytophthpra and against foliar diseases
                       caused by Phycomycetes (downy mildews).

                      Metalaxyl is registered for use on over 100
                      agricultural crops (including more than 37
                      seed treatment uses).   Metalaxyl is also
                      registered for ornamental and turf uses.

                     Some of the principal uses are:  Ridomil®  2E
                     registered in the United States for soil use
                     for apples, avocados, citrus, conifers,
                     cotton, tobacco and tomatoes; Ridomil* 5G
                     for avocados and cotton; Subdue 2E for
                     ornamentals and turf; Apron® 25 WP and Apron®
                     Flowable (2.65 Ib/gal)  for use as a seed
                     dressing on numerous crops.   More than 90%
                     of the total poundage of metalaxyl used
                     domestically is used in the following 10
                     crops/sites:  tobacco,  turf, potatoes, orna-
                     mentals, soybean (seed treatment), onions,
                     citrus, cucurbits, tomatoes, and cotton.
    Mode of Activity:  Unknown.

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    Types Registered:  Single active ingredient products containing
                       metalaxyl are formulated as a granular  (G),
                       pelleted/tableted (P/T) (in fertilizer
                       spikes)/ wettable powder (WP), emulsif-iable
                       concentrate (EC) and flowable liquid con-
                       centrate (FlC), as well as a 90% technical
                       product.  The granular, wettable powder and
                       emulsifiable concentrate formulations are
                       also formulated as multiple active ingredient
                       products.  In addition, metalaxyl is sold
                       in combination with mancozeb, chlorotha-
                       lonil, pentachloronitrobenzene, captan, and
                       triadimefon.

    Methods of
     'Applications:  Foliar application; soil application by incor-
                    poration, surface spraying (broadcast or band),
                    drenching, sprinkler or drip irrigation; soil
                    mixing;  trunk spraying.  For agricultural seed
                    treatment metalaxyl is applied with conventional
                    slurry or mist seed treating equipment.

C.   History

    Metalaxyl was first registered in 1979.  Ciba-Geigy Corpora-
tion, Agricultural Division,  is the sole producer  and principal
supplier of metalaxyl products sold in the United  States.
Granular formulations, emulsifiable concentrate formulations,
and flowable liquid concentrate formulations are also distributed
by  O.M. Scott and Son Company, Wilbur-Ellis, and Gustafson.

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                    III.   AGENCY ASSESSMENT

A.  Summary

     This review of metalaxyl is the second intensive evaluation
of the compound.  A Registration Standard was developed in 1981
in conjunction with its initial registration.  At that time
metalaxyl was registered for non-food uses on tobacco, conifers,
ornamentals, and turf and was not registered for any food or feed
uses.  The only additional data needed to support the registered
non-food uses in 1981 were groundwater monitoring, subchronic
inhalation toxicity, phytotoxicity and storage stability.  Since
the issuance of the 1981 Registration Standard, registrations
have been approved for use on over 100 agricultural crops.  These
registrations were granted based on adequate supporting data
(including residue, acute and chronic data) at the time of
application for registration.

     In 1984, the Agency promulgated general rules at 40 CFR Part
158, which set forth the range of data which must be submitted to
EPA to support the registration or reregistration of each pesticide
under FIFRA.  Based on these revised and expanded data requirements,
the toxicity data base for metalaxyl is still virtually complete -
and in most cases is adequate to support continued registration
of existing uses.  However, some data determined to support
registration in the past only partially fullfill current data
requirements.  As a result, several studies primarily in the
disciplines of residue chemistry and environmental fate, must be
conducted and submitted to the Agency.  In addition, several new
data requirements are being imposed to characterize potential
adverse effects to marine/estuarine species.  A more detailed
discussion is contained in the remainder of this Chapter.

    o  Metalaxyl has moderate acute oral and dermal toxicity
       (toxicity category III), is slightly irritating to the
       eye (toxicity category II), and is a mild dermal irritant
       (toxicity category IV).  Metalaxyl does not cause
       dermal sensitization.  There is no information on its
       acute inhalation toxicity; these data are required.

    o  Data from rat and mouse long-term studies are sufficient
       to indicate that metalaxyl did not show an oncogenic poten-
       tial in those animals even though the Maximum Tolerated
       Dose (MTD) was not tested.

    o  The teratology study indicated no teratogenic effects or
       embryotoxicity in any of the treated groups of rats.
       Metalaxyl also did not cause embryotoxic, fetotoxic, or
       teratogenic effects in treated rabbits.

    o  In a multigeneration reproduction study with rats, no dose-
       related effects were observed throughout the three gener-
       ations with respect to toxicity or reproductive parameters.

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    o  Metalaxyl did not induce gene mutations in bacteria, yeast
       and mouse lymphoma cells in vitro with or without metabolic
       activation.  The fungicide also caused no structural or
       numerical chromosomal aberrations in tests with yeast,
       hamsters, and mice.

    o  Metabolism studies in rats indicated that single oral
       doses of metalaxyl are readily absorbed.   Approximately
       65% of the administered radioactivity is recovered in the
       urine and feces within 24 hours after dosing, and 96% is
       recovered during the 48 hours after dosing.

    o  Metalaxyl was found to be practically non-toxic acutely
       and subacutely to avian species and to present no adverse
       effects to avian and mammalian populations.
   t
    o  Because metalaxyl may affect marine/estuarine species
       such as oysters and shrimp, the Agency is requesting
       additional data.

    o  Metalaxyl does not present a hazard to endangered
       terrestrial or aquatic animal species, or plant species.

    o  Metalaxyl was found to be moderately stable (to hydrol-
       ysis) under normal environmental conditions.   The rota-
       tional crop data demonstrated the need for a  12-month ro-
       tational crop restriction because some crops  will take up
       metalaxyl residues of concern when planted 12 months or
       more after treatment of a prior crop.

    o  Previously submitted ground water monitoring  studies in-
       dicated that some parent residues of metalaxyl reached
       ground water, but these studies were found to be inade-
       quate and inconclusive.  The laboratory adsorption/de-
       sorption studies indicated that the parent compound can
       readily leach in sand,  silt loam and sandy clay loam
       soils.   Additional monitoring studies are being required.

   •  Based on the current requirements the following data are
now required to support the continued registration of metalaxyl:*

40CFR§158.120 - Product Chemistry

              o  Description of Beginning Materials  and
                   Manufacturing Process
              o  Discussion of Formation of Impurities
              o  Preliminary Analysis
              o  Certification of Ingredient Limits
              o  Analytical Methods to Verify Certified Limits
* Note that this is only a summary and complete details can be
  obtained by referring to the tables in Appendix I.

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40CFRS158.125 - Residue Chemistry
              o  Nature of the Residue in Livestock
              o  Residue Analytical Method
              o  Storage Stability Data
              o  Magnitude of the Residue (potatoes; sugar beet
                   roots; soybeans; cereal grains;  forage, fodder
                   and straw of cereal grains;  cottonseed; hops;
                   peanuts;  pineapples; sunflower seed)
40CFRS158.130 - Environmental Fate
              o  Photodegradation Studies in Water
              o  Terrestrial Field Dissipation Studies
              o  Confined Accumulation Studies on Rotational
                   Crops
              o  Ground Water Monitoring and Laboratory Leaching
                   Studies
40CFRS158.135 - Toxicology

              o  Acute Inhalation Toxicity
              o  Metabolism Studies

40CFRS158.145 - Ecological Effects

              o  Acute LCso Estuarine/Marine Organisms
                   (shrimp and oyster)

B-  Risk Assessment

    The Agency has conducted a thorough review of the scientific
data base for metalaxyl.   The conclusions and requirements
imposed as a result of this review and evaluation are summarized
in Section IH-A.   A discussion of the results of the review of
the data base is presented below.

    1.   Acute Toxicity

    Adequate data are available to determine the acute toxicity
of metalaxyl.  Technical  metalaxyl is classified in Toxicity
Category II based on eye  irritation.   Metalaxyl has a moderate
acute oral and dermal toxicity (toxicity category III) and is a
mild dermal irritant (toxicity category IV).  However, metalaxyl
does not cause dermal sensitization.

    The acute oral LDsg for rats is 669 mg/kg, for mice is 788
mg/kg,  and for hamsters is 7120 mg/kg.  The acute dermal LDso
for rabbits is greater than 6000 mg/kg with the acute dermal
in rats greater than 3170 mg/kg.
                                  8

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    No additional acute oral and dermal toxicity studies are
required.  A study on the acute inhalation toxicity of technical
grade metalaxyl is required if the technical grade material is in
a respirable form.

    A primary eye irritation study in rabbits indicated that
metalaxyl is a moderate eye irritant.  Corneal opacity cleared
after 3 days following treatment, and no other signs of irritation
were observed.  No additional eye irritation studies are required.

    Studies indicate that technical grade metalaxyl is a slight
irritant when applied to the skin of rabbits.  However, no addi-
tional skin irritation studies are required.

    No sensitization reactions were observed in guinea pigs
treated with metalaxyl.  Consequently, no additional dermal
sensitization studies are required.

    2.  Subchronic Toxicity

        a.  Subchronic Feeding

            1)  Rats

    Metalaxyl was fed to groups of male and female rats at doses
of 0, 50, 250, or 1250 ppm for 90 days.  Observed effects included
minimal hepatocellular hypertrophy in 25% of the female rats at
the highest dose level.  No other treatment related changes were
observed, and the NOEL was 250 ppm (12.5 mg/kg/day).

            2)  Mice

     Four groups,  each consisting of 85 male and female weanling
CFLP (ICI Strain 1 origin) mice,  were fed diets of metalaxyl
containing 0, 1250,  2500, or 5000 ppm.  Subsequently,  some of the
test animals were given control diets for an additional 30 days
in a recovery phase  of the experiment.  There were minimal liver
effects at the 2500  and 5000 ppm levels in males.   Effects observed
after 3 months of treatment included changes in glycogen content,
fatty vacuolization, and hypertrophy of hepatocytes.  Liver
weights were elevated in all treated animals after 90  days on the
test diets,  but no histopathological effects were reported in
livers of females or in low-dose group males.  Absolute liver
weights for test groups in the recovery phase of the study were
comparable with those of the control group at termination.  The
NOEL in this study was < 1250 ppm (187.5 mg/kg/day) with an LOEL
of 1250 ppm.

            3)  Dogs

    Technical metalaxyl was administered to groups of  male and
female beagle dogs at dietary concentrations of 0, 50, 250, or
1250 ppm for 91 days.  No mortality or treatment-related changes

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in animal behavior,  hematology, clinical chemistry, urine analysis,
or gross and microscopic observations were noted.   The NOEL is
greater than 1250 ppm.   This study is classified as Supplementary
and a new 3-month study is not required because an acceptable
6-month dog study is available.

    No additional subchronic oral studies are required.

        b.   Subchronic  Dermal

    In a 21-day dermal  toxicity study, metalaxyl was applied to
shaved intact or abraded skin of rabbits under impervious bindings.
The dosages tested were 0, 10, 100, or 1000 mg/kg/day.  Only one
animal died during the  study.  There were no significant differ-
ences between the control group and treatment groups with respect
to food consumption, body weight, hematology, clinical chemistry,
organ weights, and organ to body weight ratios.  There were also
no effects observed at  necropsy either macro- or microscopically.
The NOEL is greater than 1000 mg/kg/day (HOT).  No additional
subchronic dermal studies are required.

        c.   Subchronic  Inhalation

    A 90-day smoke inhalation study is required if pesticide
residues in the smoke of treated tobacco are greater than
0.1 ppm.

    In a preliminary study, groups of male and female rats were
exposed to the smoke from 16 cigarettes per day.  Three of the
groups were exposed to  smoke from tobacco spiked with 130, 3900,
and 13,000 ppm metalaxyl (by weight), and the fourth group was
exposed to untreated smoke for 28 days.  There were no signifi-
cant differences between treated and control groups with respect
to toxic signs, hematology, body weight, organ weight or organ-
to-body weight ratios,  and gross pathology observations.  These
results indicated that  a NOEL for exposure of rats to metalaxyl-
spiked tobacco smoke was greater than 13,000 ppm (HOT).

    In a second study,  groups of male and female rats were exposed
to smoke from standard  cigarettes spiked with 0, 130, 3900, or
13,000 ppm metalaxyl for 90 days.  Exposures were approximately
4 hours per day, 5 days per week for 13 weeks, and the animals
were exposed to the smoke of 18 cigarettes during each 252 minute
exposure.  A few animals exhibited eye irritation, but no effects
could be associated with the addition of metalaxyl to the ciga-
rettes' tobacco.  The highest concentration of metalaxyl reported
in the air during exposure was 5 ug/L, and the NOEL in this study
is greater than that level (HOT).  No additional subchronic inha-
lation toxicity studies are required.
                                10

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    3.  Chronic Feeding/Oncogenicity Studies

        a.  Chronic Feeding


            1)  Rats

     Groups of male and female Sprague-Dawley rats were fed diets
containing 0, 50, 250, or 1250 ppm metalaxyl for 2 years.   No
effects were noted with respect to toxic signs, mortality, body
weight, food consumption, ophthalmologic examination, hematology,
urinalysis or the incidence of palpable masses.

    The only effects on clinical chemistry parameters included
decreased SCOT and SGPT values at weeks 12, 25, and 51 of the
2-year feeding period in treated females.   At 78 weeks of treat-
ment there was an increase in SCOT and SGPT values in females
receiving the 250 and 1250 ppm diets, and after 104 weeks of
treatment SCOT values were comparable for treated and control
groups of both sexes.  Relative liver weight was increased in
females fed 1250 ppm at 55 weeks, and in males fed 250 or 1250
ppm at 105 weeks.  Females fed 1250 ppm also had increased
relative liver weights at 105 weeks.

    The changes in SCOT and SGPT are not toxicologically signif-
icant in view of the minor microscopic changes (periacinar vacuo-
lation of hepatocytes) and increase in relative liver weights
without a concurrent increase in absolute liver weights observed
at the highest dietary level tested.  However,  the NOEL estab-
lished in this study is 250 ppm (12.5 mg/kg/day),  and the LOEL
is 1250 ppm (62.5 mg/kg/day) for rats treated for 2 years.

            2)  Dogs

    Technical metalaxyl was fed to groups of six male and six
female beagle dogs at dietary levels of 50 or 250 ppm for 6
months.  Two additional diets containing 0 or 1000 ppm were fed
to groups containing eight animals of each sex for the same
period, and two dogs 'of each sex from those two groups were given
the 0 ppm diet for an additional 30 days (recovery phase).

    There were no mortalities or signs of toxicity observed in
the experiment,  and no gross or microscopic lesions were observed
to occur in a dose- or treatment-related manner.   There were also
no effects on hematology, urinalysis, or opthalmological parameters.
Increased alkaline phosphatase, observed in animals given the 1000
ppm diet,  was the only biochemical change noted.   In addition, the
absolute liver weights and brain/ liver weight ratios for dogs
given the highest dose level were increased.   Based on these
results the LOEL was established at 1000 ppm (25 mg/kg/day), and
the NOEL was 250 ppm (6.25 mg/kg/day).

    At the time this study was submitted a 6-month dog study
satisfied Agency requirements for a long-term nonrodent study.



                                11

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Although the Agency now requires a 12-month dog study, the Agency
is accepting the submitted study to satisfy this requirement for
metalaxyl.  No additional chronic feeding studies in rodent and
nonrodent species are required.

        b.  Oncogenicity Studies

            1)  Rats

    In the 2-year study with rats described in the preceding sec-
tion, no tumors were observed to be increased by treatment with
metalaxyl, but the minimal nature of the compound related effects
(increased relative liver weights and periacinar vacuolation of
hepatocytes) suggests that an MTD was not achieved in this study.
However, this study is considered acceptable for a rat oncogenicity
study.

            2)  Mice

    Diets containing 0, 50, 250, or 1250 ppm metalaxyl were given
to groups of male and female Swiss mice for 104 weeks.  There
were no compound-related signs of toxicity observed in the study,
and mice given the highest dose level exhibited only slight
temporary reductions in body weight gain with mean body weights
less than 10 percent below those for control group animals.  There
were no dose-related incidences of neoplastic or non-neoplastic
lesions observed in the study, with the exception of fatty infil-
tration of the liver.  Results of this study are similar to those
of the rat study in that they  indicated no MTD was achieved.  How-
ever this study is considered acceptable for a mouse oncogenicity
study.

    Although the Agency concluded that neither of the long-term
studies evaluated an MTD, the  two studies are sufficient to
indicate that metalaxyl did not show an oncogenic potential in
rats and mice for the following reasons.

    o  Doses tested in the rat and mouse studies were high enough
       to produce compound-related changes in liver weight and/
       or histology, probably  representing a pharmacologic
       response.

    o  Metalaxyl is not structurally related to known carcinogens.

    o  Available mutagenicity  studies  indicated no potential
       genotoxic activity which is consistent with the negative
       oncogenic potential demonstrated  in long-term  testing.

    o  Under  the conditions of  the long-term feeding  studies
        in  rats and mice,  there  was no  indication  of oncogeni-
       city  in either species  or sex,  at any dose  level  tested.

      No  additional oncogenicity studies  with metalaxyl  in  rats
and mice  are  required.


                                 12

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    4.   Teratology

        1)  Rats

    A study in rats evaluated doses of 0, 20, 60, and 120 mg/kg/
day.  The doses were administered to groups of pregnant rats on
gestation days 6 through 15.  There were no teratogenic effects
noted in the study, and the HOT did not clearly cause maternal
toxicity.  There were no corpora lutea counts reported and groups
of animals were sacrificed on different days of gestation at the
end of  the experiment which limited the ability of the study to
detect  developmental toxicity.  NOELs for maternal and develop-
mental  toxicity could not be established in this study, and
another study with rats was conducted.

    In  the second study, groups of pregnant rats were given
metalaxyl in daily doses of 0, 50, 250, or 400 mg/kg/body weight
on gestation days 6 through 15.  Doses were administered by
gavage.  Maternal toxicity was observed in dams given the 250 and
400 mg/kg/day doses as indicated by convulsions and ataxia during
the treatment period.  Fetotoxicity was indicated by an increase
in the  incidence of unossified sternebrae in fetuses from the two
highest dosed groups; no teratogenicity or embryotoxicity was
observed in any of the treated groups.  Based on these results
NOELs for maternal and developmental toxicity were established at
50 mg/kg/day, and LOELs for both types of toxicity were established
at 250  mg/kg/day.  The adult-to-developmental toxicity ratio
(A/D ratio; ratio of the adult toxicity NOEL to fetal toxicity
NOEL) is eaual to one.

        2)  Rabbits

    Metalaxyl was given to groups of pregnant rabbits on gestation
days 6  through 18.  Doses of 0, 5, 10, or 20 mg/kg/day were admin-
istered by oral intubation.  No maternal or fetal"effects associ-
ated with treatment were observed in the study.  On that basis,
the study could not be used to fully assess the potential develop-
mental  toxicity of metalaxyl in rabbits, and the study was repeated.

    The range-finding study preceding the second definitive experi-
ment with rabbits was conducted with doses of 0, 30, 100, 250, 500,
and 1000 mg/kg/day.  These doses were administered by gavage on
gestation days 6 through 18 to groups of Dutch belted rabbits.
The HOT caused 100 percent mortality (5 of the 5 treated does),
and the 500 mg/kg/day dose caused decreased group mean body weight
(7.4% below that for control animals).  Based on these results,
the highest dose selected for the main study was 300 mg/kg/day.

    The second definitive study evaluated metalaxyl at doses of
0, 30,  150, and 300 mg/kg/day administered to groups of pregnant
rabbits on gestation days 6 through 18.  Slight maternal toxicity
was noted at 300 mg/kg/day as shown by a small decrease in body
weight  (2.3%) during the 13-day treatment period.  There were no
embryotoxic, fetotoxic, or teratogenic effects associated with


                                  13

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treatment in this experiment.  Based on these results and those
from the range-finding study, the NOEL for maternal toxicity was
300 to 500 mg/kg/day, and that for developmental toxicity was
greater than 300 mg/kg/day (HDT in the main study).  The A/D
ratio suggested by these results is less than one.

    No additional teratology studies in rats or rabbits are
required.

    5*  Reproductive Toxicity Study

    In a multigeneration reproduction study, four groups of rats
were given diets containing 0, 50, 250, or 1250 ppm metalaxyl.
No dose-related effects were observed throughout the three genera-
tions with respect to signs of toxicity, mortality, body weights,
food and water consumption, mating, fertility,  duration of gesta-
tion,  or necropsy findings.  In addition,  there were no effects
on pre- and post-implantation losses, litter size,  mean litter and
fetal weights, or the incidence of fetal variations and malforma-
tions in the teratology phase of the study.  The NOEL for repro-
duction and developmental toxicity is greater than 1250 ppm based
on these observations.

     No additional reproduction toxicity studies are required. -

    6*  Mutagenicity Studies

        a.  Gene Mutation

    Three studies were conducted in Salmonella typhimurium and one
study in Escherichia cqli at concentrations rangingfrom 10 to
5000 ug metalaxyl per plate with or without metabolic activation.
No mutagenic activity was observed in these assays.

    Two assays in Saccharomyce_s cerevisiae were conducted with
concentrations of 40 to 10,000 ug/mL, and no increase in the
frequency of gene mutations for treated yeast cultures was ob-
served.  However, no response to the positive control substance,
absence of toxicity in metalaxyl treated cultures,  and low solu-
bility of the test substance in growth medium suggested that the
sensitivity of these assays was limited.

    An assay in vitro with mouse lymphoma cells also found no in-
creases in gene mutations in treated cells at concentrations
ranging from 0.125 to 1.0 mg/mL without metabolic activation or
0.0625 to 0.5 mg/mL with metabolic activation.
                             «
        b.  Structural and Numerical Chromosomal Aberrations

    The two yeast assays described above indicated that metalaxyl
did not induce mitotic gene conversion or recombination at the
concentrations tested, but those assays are considered limited
with respect to their sensitivity.  A third assay in S_. cerevisiae
also suggests that metalaxyl did not induce nondisjunction.  The
                                 14

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third study also has the same limitations mentioned above for the
other two assays.

    In an in vitro assay with Chinese hamster ovary cells exposed
to concentrations of metalaxyl ranging from 150 to 1200 ug/mL, an
increase in the number of cells with chromosomal aberrations was
observed at the HOT without liver microsomal enzyme activation
of the test substance.  There was no increase in the frequency
of cells with chromosomal aberrations when metalaxyl was added
to cultures after being treated with liver microsomal enzymes.
However, the results are inconclusive because there is not enough
enough information in the report to indicate whether metalaxyl is
detoxified by the microsomal enzymes or the exposure period in
that portion of the assay (2 hours) is too short in comparison to
that of the other phase of the experiment (17.5 hours).
  t
    Two in vivo assays were conducted with hamsters and mice.   In
the first experiment, males and females were administered metalaxyl
in two consecutive daily oral doses of 0, 595, 1190, or 2380 mg/kg/
body weight (bwt).  These doses did not increase the incidence of
bone marrow cells with nuclear anomalies (single Jolly bodies,
fragments or nuclei in erythrocytes, micronuclei in erythroblasts,
micronuclei in leucopoietic cells, and polyploid cells).  The
second assay was a dominant lethal study in which no genetic
effects were observed after administration of single oral doses
of 0, 65, or 195 mg/kg/bwt metalaxyl to male mice.   Acute oral
toxicity studies in hamsters and mice suggest that the doses
tested in the genetic toxicity assays were approximately 1/3 of
the LD5Q value for hamsters and mice.

        c.   DNA Damage

    Metalaxyl did not cause DNA damage in Bacillus subtil is (Rec
assay) at levels from 20 to 5000 ug/disk, and the fungicide did
not induce  unscheduled DNA synthesis in rat primary hepatocytes
at concentrations of 0 to 2000 ug/mL in two other experiments  or
in human fibroblasts at concentrations of 0 to 500 ug/mL.

    No additional data are necessary on any of the three required
mutagenicity studies:  gene mutation;  structural and chromosomal
aberrations,  and DNA damage.

    7.  Metabolism in Rats

    Available metabolism studies in rats more than adequately
characterize the absorption and excretion of metalaxyl in male
and female  rats at low- and high-dose  levels,  as well as clearly
describe the metabolism of the fungicide in female rats for single
dose administration.   However, an additional study to characterize
the absorption,  distribution,  and excretion of metalaxyl after
repeated dosing is needed.

    There were three metabolism studies in rats available for
review.



                               15

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    In the first study,  groups of male and female rats were given
single doses of 0.5 or 25 mg/kg radiolabeled metalaxyl (orally by
gavage).   Urine, feces,  and expired air were sampled at 24-hour
intervals for 6 days following dosing.  At the end of that time
the animals were sacrificed and tissue samples were collected.

    During the first 24  hours after dosing with either the high
or low doses, male and female rats excreted 62 to 65 percent of
the administered radioactivity.  Over the 6-day observation
period the majority of the excreted radioactivity in males was
recovered from the feces (63 to 66% of the administered dose),
while the majority of residues in females was found in the urine
(55 to 63% of the dose).  Although no metabolites were identified
in this study, their chromatographic patterns did not appear to
vary with dose or sex, and the tissue distribution observed 6 days
after dosing did not indicate that metalaxyl residues were stored
in tissues.

    The second and third studies indicated that metalaxyl is
readily absorbed by females after a single 28 mg/kg oral dose.

    The second study showed that nearly all of the administered
radioactivity (96.3%) was excreted in the urine and feces duriag
the 48 hours following treatment.  The majority (63.5% of the.
dose) was recovered in the urine which was used in identification
of metabolites; approximately 20 percent of the residues were
identified by chromatographic and spectroscopic methods.  Those
results indicated that ether and ester bonds of metalaxyl [N-(2,
6-dimethylphenyl)-N-(methoxyacetyl)-alanine methyl ester] are
hydrolyzed first to form N-(2,6-dimethylphenyl)-N-(methoxyacetyl)
alanine,  N-(2,6-dimethylphenyl)-hydroxyacetamide,  and N-(2,6-
dimethylphenyl)-hydroxyacetamide (only in free form).  Thin layer
chromatography of urine  fractions treated with glucuronidase
showed similar patterns  to those for urine not treated with the
enzyme indicating that the metabolites are excreted as uncon-
jugated or glucuronide conjugate products.  The fecal metabolites
were not characterized in this study beyond comparison of chroma-
tograms for urine and feces.

    Similar results were obtained in the third study which also
indicated that metalaxyl is metabolized in rats first by hydro-
lysis of the ester and ether bonds, by oxidation of methyl groups
of the phenyl moiety, and oxidation of the phenyl moiety itself.
Secondary metabolic pathways led to the formation of products
such as N-(2carboxy-6-methylphenyl)-N-(methoxyacetyl)-alanine
methyl ester and 4-(2,6-dimethylphenyl)-3-morpholine-2,5-dione
isomeric lactone form of the N-(2,6-dimethylphenyl)-N-(hydroxy-
acetyl) alanine as well  as glucuronic acid conjugates of these
products.  Approximately 38 percent of the administered radio-
label was unidentified.
                                 16

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    8.   Dermal Absorption Studies

    Male and female rats received dermal applications of 1 or
10 mg/kg/bwt metalaxyl dissolved in tetrahydrofuran (THF).
During the first 8 hours after treatment, approximately 30
percent of the dose was absorbed.  Only 1 percent of the applied
test substance was in the skin of the application site.  Based
on radioassay of skin washings, the absorption T]_/2 values for
males receiving the low and high doses were 12 and 20 hours,
respectively, while those for females were 13 hours for both
doses.   Residues were cleared from tissues by 72 hours following
dosing with 70 to 80 percent of the applied radioactivity being
excreted during that time.   The major route of excretion in
females was the urine, and that for males was the feces.  The
Tl/2 for excretion in males was 36 hours at the low dose and
49'hours at the high dose level, and those respective values for
females were 42 and 44 hours for low and high-dose groups.

     No additional studies on dermal absorption are required.

C.  Other Science Findings

    1.   Ecological Effects

    Metalaxyl has been found to be practically nontoxic acutely
and subacutely to avian species and to present no potential for
adverse effects to avian and mammalian populations.  Phytotoxicity
studies on green alga and duckweed indicate no detrimental effect
on aquatic plant species.  The available data demonstrate that
the technical pesticide is practically nontoxic to freshwater
aquatic species while one formulated product, Ridomil 27.9% ai EC,
is slightly toxic.  This toxicity may be due to the inherent
toxicity of the inerts in the formulation or a synergistic effect
making the active ingredient more available.   The most sensitive
organism appears to be Daphnia magna having LC5QS of 28 and 12.5
ppm on technical and formulated products, respectively.

    Chronic toxicity assays on aquatic species and fish accumula-
tion testing do not suggest that metalaxyl presents a long-term
risk in the aquatic environment (acute testing on marine fish is
waived because the LC$Q on freshwater fish is >100 ppm).  It
appears very unlikely that metalaxyl could accumulate in water or
sediments to concentrations that would pose a risk to aquatic
populations (primarily due to the low toxicity of the pesticide).

    Even though it is apparent that the use of metalaxyl presents
little risk to freshwater populations, it cannot be assumed that
the same holds true for marine/estuarine species such as oysters
and shrimp.  Several of the registered uses (citrus, cotton,
etc.) of the pesticide may result in exposure to marine/estuarine
environments.  Data on oysters and shrimp are required.
                                 17

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    2.  Endangered Species

    The registered uses of technical metalaxyl and a widely used
formulation, Ridomil® 27.9% ai EC (which appears more toxic to
aquatic organisms than the technical) do not present a hazard to
endangered terrestrial or aquatic animal species,  or plant species.
This is primarily due to metalaxyl's very low toxicity to fish and
wildlife.  Data from phytotoxicity studies on Lemma gibba and
Selena strum c a. pr i c o r n u t u m indicate no detrimental  effect to aquatic
plant species from technical metalaxyl.  The EECs  resulting from
currently registered uses are considerably below the LC$Q of the
most sensitive species tested.  At this time the threatened/en-
dangered species triggers have not been exceeded (EEC greater than
1/20 of the LCso for aquatic or 1/10 the LC^Q for  terrestrial
species).
   i
    3.  Environmental Fate

    Metalaxyl was found to be moderately stable under normal envi-
ronmental conditions.  At 20°C the calculated half-life was 200
days at pH 5 and 7, and was 115 days at pH 9.  Studies also
indicated that metalaxyl was stable to photodegradation on soil.
Test results indicated no difference between the irradiated sample
and the control sample.  The aerobic soil metabolism half-life was
determined to be about 40 days.  While other experiments demons-
trated that less than 0.5 percent of the applied metalaxyl would
be lost to volatilization, field dissipation studies showed that
metalaxyl's half-life was about 2 weeks.

    Fish accumulation was found not to exceed 7X when fish were
exposed to metalaxyl at 1 ppm in water, and residues were found
to accumulate in the nonedible portions over the edible portions
in a ratio range of 4:1 to 15:1.  Residues declined rapidly during
depuration.  In addition, a separate fish accumulation study using
catfish showed accumulation of IX and rapid depuration.

    The rotational crop data demonstrated the need for a 12-month
rotational crop restriction because some crops will take up
metalaxyl residues of concern when planted 12 months or more after
treatment of a prior crop.  Confined studies are needed to identify
all residues of concern plus field tests to determine the need
for additional inadvertent tolerances.

    Ground water monitoring studies were determined to be inade-
quate.  The results from a Florida test site do not address the
issue of metalaxyl leaching to shallow first-encountered aquifers,
but rather the possibility of leaching to deep aquifers at >200
feet.  Of the 67 samples extracted, two showed positive results:
3.1 and 4.7 ppb.  In addition, on test sites located in North
Carolina and Oregon, two years of approximately monthly samples
from three wells at each location showed no positive results,
supporting the hypothesis that metalaxyl may not be traversing
off-site at these locations.  However, wells were inadequately



                                 18

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described,  and water table depths described at 40 to 140 feet in
Oregon are  at the far end of the definition of "shallow" water
tables.

    Surface water monitoring in the Sacramento River, California,
showed seasonal concentrations of metalaxyl in two of the three
years of bi-monthly sampling.  Seasonal, in this context, refers
to spring,  summer and fall when runoff typically transports
residues of pesticide from the treated field to the surface water.
In one year, 61% of seasonal samples were positive with a range
of 0.97 to  3.5 ppb, while in the other year of positive results,
50% of seasonal samples showed positive, with a range of 0.25 to
0.43 ppb.   Samples from tap water obtained from the Sacramento
River showed no positive residues in three years of sampling.
In conclusion, surface and ground water monitoring results from
these studies were considered inconclusive and additional moni-
toring data are required.

D•  Tolerance Reassessment

    Tolerances have been published in 40 CFR 180.408 for residues
of metalaxyl on the following raw agricultural commodities (RACS):
apples, avocados, beets, beet tops, brassica (cole) leafy vege-  -
tables group [except broccoli, cabbage, and cauliflower], broccoli,
cabbage, cattle fat, cattle kidney, cattle meat, cattle meat
byproducts  (except kidney and liver), cauliflower, citrus fruit,
cottonseed, cucurbit vegetables group, eggs, fruiting vegetables
(except cucurbits) group [except tomatoes], goat fat, goat kidney,
goat liver, goat meat, goat meat byproducts (except kidney and
liver), grain crops, grass forage, hog fat, hog kidney, hog
liver, hogs meat, hog meat byproducts (except kidney and liver),
hops green, horse fat, horse kidney, horse liver, horse meat,
horses meat byproducts (except kidney and liver), leafy vegetables
(except brassica) group, legume vegetable foliage, legume vegetable
group (dry  or succulent), lettuce head, milk, onions (dry bulb),
onions (green), peanut hay, peanut vines, peanut nuts,  peanut
shells, pineapples, pineapple fodder, pineapple forage, poultry
fat, poultry kidney, poultry liver, poultry meat, poultry meat
byproducts  (except kidney and liver), potatoes, raspberries,
sheep fat,  sheep kidney, sheep liver, sheep meat, sheep meat
byproducts, soybean grain, spinach, sunflowers, sunflower forage,
and tomatoes.

    In addition, tolerances are established for indirect or  inad-
vertant residues of metalaxyl in or on the following RACs when
present as  a result of the application of metalaxyl to growing
crops:  wheat, fodder; wheat, forage; wheat, grain; wheat, straw;
and, wheat, milling fraction.

    Tolerances have also been published in 21 CFR 193.277 permit-
ting the combined residues of the fungicide metalaxyl [N-(2,6-
dimethylphenyl)-N-(methoxyacetyl) alanine methyl ester] and  its
metabolites containing the 2,6-dimethylaniline moiety,  and
N-(2-hydroxy methyl-6-methyl)-N-methoxyacetyl)-alanine methyl
                                19

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ester, each expressed as metalaxyl,  in or on the following food
commodities: citrus,  oil; potatoes,  processed (including potato
chips); and tomatoes, processed.

     There are also indirect or inadvertant tolerances for those
residues of metalaxyl in the food commodities when present therein
as a result of the application of metalaxyl to growing crops
listed in 40 CFR 180.408(a).

     A regulation is  also established under 21 CFR 561.273
permitting the combined residues  of  the fungicide metalaxyl in
the following feed commodities: apple, pomace (dry); apple,
pomace (wet); citrus, molasses; citrus, pulp; hops,  dry; legume
vegetable, cannery waste; peanut, meal; peanut,  soapstock;
potato waste, dried processed; soybean, hulls; soybean,  meal;
soybean soapstock; tomato pomace, dry; and tomato pomace,  wet.
In addition, indirect or inadvertant tolerances are  established
for indirect residues of metalaxyl in the food commodities when
present therein as a  result of the application of metalaxyl to
growing crops listed  in 40 CFR 180.408(a).

    There are no Codex tolerances for metalaxyl.  EPA has eval-
uated the following residue and toxicology data supporting the .
tolerances:

    1.  A 3-month dietary study in rats with a NOEL  at 12.5
        mg/kg bwt/day (250 ppm).

    2.  A teratology  study in rats with a NOEL to 400 mg/kg bwt
        (HOT).   Metalaxyl was not teratogenic, even  in the
        presence of maternal toxicity.

    3.  A teratology  study in rabbits with a NOEL of 300 mg/kg
        bwt (HOT).  Metalaxyl was not teratogenic,  even in the
        presence of maternal toxicity.

    4.  A Salmonella  mutagenicity study that was negative for
        reverse mutations with and without mammalian microsome
        activation.

    5.  A mouse dominant lethal study that was negative for
        rautagenicity.

    6.  A 3-generation rat reproduction study with a NOEL of
        62.5 mg/kg bwt/day (1250  ppm).

    7.  A 6-month dog feeding study with a NOEL of 6.3 mg/kg
        bwt (250 ppm).

    8.  A 2-year rat  chronic feeding/oncogenicity study with no
        compound-related oncogenic effects under the conditions
        of the study at dietary levels up to 1250 ppm.  The NOEL
        is 12.5 mg/kg bwt/day  (250 ppm) based upon slight in-
        creases in liver weight to body weight ratios at 1250 ppm.


                                  20

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    9.  A 2-year mouse oncogenicity study with no compound-related
        oncogenic effects under the conditions of the study at
        dietary levels up to 1250 ppm.

    The ADI,  based on the 6-month dog feeding study (NOEL of 6.3
mg/kg bwt/day) and a hundredfold safety factor, is calculated to
be 0.063 mg/kg/day.  The MPI for a 60kg human is calculated to
be 3.8 mg/day.

    The nature of the residue in plants is adequately understood
and analytical methodology is available in the Pesticide Analytical
Manual II (PAM II) for enforcement purposes.   The PAM II method
involves gas-liquid chromatography (GLC) with alkali flame ioniza-
tion detection (AFID), and with mass spectrometry for samples that
sh6w interference in the GLC/AFID.  A newer analytical method which
involves capillary gas chromatography using a nitrogen/ phosphorus
detector operating in the nitrogen-specific mode will be included
in PAM II.
                                21

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              IV.   REGULATORY POSITION AND RATIONALE

A.   Regulatory Positions and Rationales

     This review of metalaxyl is the second intensive evaluation
of  the compound.  A Registration Standard was developed in 1981
in  conjunction with its initial registration.  At that time
metalaxyl was registered for non-food uses on tobacco, conifers,
ornamentals, and turf and was not registered for any food or feed
uses.  The only additional data needed to support the registered
non-food uses in 1981 were groundwater monitoring, subchronic
inhalation toxicity, phytotoxicity and storage stability.   Since
the issuance of the 1981 Registration Standard, registrations
have been approved for use on over 100 agricultural crops.  These
registrations were granted based on adequate supporting data
(including residue, acute and chronic data) at the time of
application for registration.

     In 1984, the Agency promulgated general rules at 40 CFR Part
158, which set forth the range of data which must be submitted to
EPA to support the registration or reregistration of each pesticide
under FIFRA.  Based on these revised and expanded data requirements,
the toxicity data base for metalaxyl is still virtually complete ~
and in most cases is adequate to support continued registration
of  existing uses.   However, some data determined to support
registration in the past only partially fullfill current data
requirements.  As a result, several studies primarily in the
disciplines of residue chemistry and environmental fate, must be
conducted and submitted to the Agency.  In addition, several new
data requirements are being imposed to characterize potential
adverse effects to marine/estuarine species.  A more detailed
discussion is contained in the remainder of this Chapter.

    (1)  None of the risk criteria listed in 40 CFR 154.7 prescri-
bing a Special Review have been met.  Therefore, metalaxyl is not
being placed in Special Review at this time.

    Rationale;  After consideration of available toxicology data,
the Agency has determined that no reason exists for placement of
metalaxyl in Special Review at this time.

    The original reviews of a chronic rat and a mouse oncogenicity
study indicated apparent dose-related oncogenic effects by meta-
laxyl.  While this gave rise to regulatory concern, subsequent
reevaluation of the histopathology and other aspects of the study
led the Agency to conclude that the results of these studies were
negative, even though the MTD may not have been tested.  Further
testing is not warranted because the doses tested were high enough
to produce toxicity in the liver.  Metalaxyl is not structurally
related to known oncogens and available mutagenicity studies
indicate no potential genotoxic activity.  Adequate evidence thus
provides no basis for further concern over the oncogenicity of
metalaxyl.


                                 22

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    (2)  The Agency is requesting rotational crop studies and,
in order to meet the statutory standard for continued registra-
tion,  product labeling must bear a 12-month rotational crop
restriction as an interim measure.

    Rationale;  Available rotational crop studies indicate that
some crops will take up metalaxyl residues of concern when planted
12 months or more after treatment of a prior crop.  Confined
studies are needed to identify all residues of concern plus field
tests are necessary to determine the need for additional inadver-
tent tolerances.   As an interim measure, a 12-month rotational
crop interval is be required for all crops for which tolerances
have not been established.

    (3)  Additional ground water monitoring and laboratory
leaching studies are being required.

    Rationale;  The Agency determined that data submitted on
ground water monitoring are inadequate to determine leaching
potential.  The results of submitted monitoring data indicate
that some parent residues reached ground water.  Laboratory
adsorption/desorption studies indicate that parent compound can
readily leach in sand,  silt loam and sandy clay loam soils.  In-
a laboratory column leaching study, parent metalaxyl plus its.
degradates leached in sand and silt loam soils.  Also,  both
parent and degradates were shown to be sufficiently persistent
in laboratory studies to have potential to reach ground water.
Existing data, however,  are inadequate to conclude whether
metalaxyl has the potential to reach groundwater.   Therefore,
new monitoring studies and laboratory leaching studies that
conform to current testing standards are needed.

    (4)  Ground water monitoring data will receive immediate
review when submitted.

    Rationale;  Because of the potential for metalaxyl to reach
ground water, it is essential that these data be reviewed as they
are received.  This will allow the Agency to determine whether
regulatory action is warranted based on this concern.

    (5)  The Agency is requiring further data on potential adverse
effects to marine/estuarine species.

    Rationale;  Based on available toxicity studies, no adverse
effects to either endangered or nonendangered avian, mammalian,
or freshwater aquatic animal species are expected from currently
registered uses of metalaxyl.  However,  further testing is
required on marine/estuarine species to determine if currently
registered uses will result in exposure levels of concern to
these  populations.
                                23

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    (6) While data gaps are being filled, currently registered
manufacturing-use products (MP's) and end-use products (EP's)
containing metalaxyl as the sole active ingredient may be sold,
distributed, formulated, and used, subject to the terms and
conditions specified in this Standard.   Registrants must provide
or agree to develop additional data, as specified in the Data
Appendices, in order to maintain existing registrations.

    Rationale;  Under FIFRA, the Agency may elect not to cancel
or withhold registration even though data are missing or are
inadequate (see FIFRA section 3(c)(2)(B) and 3(c)(7)).  Issuance
of this Standard provides a mechanism for identifying data needs.
These data will be reviewed and evaluated, after which the Agency
will determine if additional regulatory actions are necessary.
The Agency wll consider registration of any significant new use
on a* case-by-case basis while data gaps are being filled and data
evaluated.

B.  Criteria for Registration

    To be registered or reregistered under this Standard, products
must contain metalaxyl as the sole active ingredient, bear required
labeling, and conform to the product composition, acute toxicity ~
limits, and use pattern requirements listed in this section.

C.  Acceptable Ranges and Limits

    1.   Product Composition Standard

        To be registered or reregistered under this Standard, MPs
must contained metalaxyl as the sole active ingredient.  Each MP
formulation proposed for registration must be fully described
with an appropriate certification of limits, stating maximum and
minimum amounts of the active ingredient and inert ingredients
which are present in products, as well as impurities found at
greater than 0.1 percent.

    2.   Acute Toxicity Limits

        The Agency will consider registration of technical grade
and EPs containing metalaxyl provided that the product labeling
bears appropriate precautionary statements for the acute toxicity
category in which each product is placed.

    3.   Use Patterns

        To be registered under this Standard, manufacturing-use
products must be labeled for formulation into end-use products
only for the uses listed below.  The EPA Index to pesticide
chemicals lists all registered uses, as well as approved maximum
application rates and frequencies.

           Terrestrial, food and non-food uses


                                 24

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        Metalaxyl is registered for use on at least 100 agricul-
tural crops,  as well as ornamental and turf sites.   About 37 uses
are for agricultural seed treatments.

        The following table lists the  ten major crops/sites using
metalaxyl on  food,  non-food and ornamental crops.
                                25

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USE OF METALAXYL ON TERRESTRIAL  FOOD, NONFOOD AND ORNAMENTAL CROPS
•~— -— —— • '- ——r*" *
Use Site
Tobacco








Turf





Potatoes





Ornamentals









Target Pest
Blue mold
Black shank
Pythium damp-
ing-of f





Downy mildew
Pythium blight
Pythium damp-
ing-of f
• Yellow tuft

Phytophthora
and Pythium
tuber and
storage rot
Late blight

Pythium and
Pythophthora
diseases






Formulation
& EPA Reg. No.
SAI 2 Ib/gal EC
(100-607)







SAI 2 Ib/gal EC,
(100-619), 1.21% G
(538-185), and 5% G
(100-646), and
MAI 16% EC (538-
203)
SAI 9% WP (100-658)
MAI 10% WP (100-629)




SAI 2 Ib/gal EC
(100-607) and (100-
619), 5% G (100-
646), 1.21% G (538-
185), 0.1%, 0.3%,
and 0.5% P/T
(46260-26, 46260-
27 and 46260-28)

Application
Rate
0.25 to 3.0 Ib/A








0.25-0.5 oz/1000 sq
ft for soil or
foliar application
or 0.33 to 0.66 Ib/A
for foliar applica-
tion.
0.135 to 0.2 Ib/A





0.3 to 1.5 oz/1000
sq ft of treated
soil surface.






Application
Method
Soil and foliar
applications.







Soil and foliar
application.




Foliar appli-
cation




Soil application
by granules or
spray applied to
soil surface or
drenches applied
near plants.
Foliar applied
to azalea.

Application
Timing
Soil applications
are preplant or at-
planting. Foliar
applications are to
begin 70 days after
planting or after
initial preplant
treatment, and
repeat every 7 days.
Apply to soil or
foliage and repeat
every 5 to 21 days.



Foliar repeated
every 14 days as
needed.



Preplanting or at-
planting or before
growth begins and
repeat at 2- to 6-
month intervals.





Remarks
Limit is
3 Ib per
season
except
for black
shank
(4 Ib/
season).

Treated
foliage
not for
livestock
consump-
tion.
Tolerance
0.5 ppm
with 7-
day pre-
harvest
interval.
Nonfood
crop use.
Higher
levels
produce
phytotox-
icity to
some
plants.

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USE OF METALAXYL ON TERRESTRIAL FOOD, NONFOOD AND ORNAMENTAL CROPS

Use Site
Soybeans
(seed
treatment )


Soybeans
( field
application)





Onions
(dry bulb,
green and
grown for
seed)


Citrus






Target Pest
Pythium damp-
ing-of f
Phytophthora
(early season
control )
Phthium damp-
ing-off and
root rot





Pythium damp-
ing-off and
downy mildew




Phytphthora
foot rot/
root rot



Formulation
& EPA Reg. No.
SAI 25% WP (100-
639), 2.65 Ib/gal
F1C (2935-427 and
7501-42), 2 Ib/gal
EC (100-626)
SAI 2 Ib/gal
EC (100-607)


5% G (100-628)



SAI 2 Ib/gal EC
(100-607)
MAI 9% WP (100-658)
& 10% WP (100-629)



SAI 2 Ib/gal EC
(100-607)
SAI 5% G (100-628)



Application
Rate
0.25 to 0.5 oz/100
Ib seed



0.6875 to 1.375 Ib/
treated acre

or
0.25 lb/13,000
linear ft of row
0.15 to 0.3 oz per
1,000 ft of row
0.135 to 0.2 Ib/A






2.0-4.0 Ib/ 'treated
acre




Application
Method
Seed treatment




Soil application
in the seed fur-
row or a 7- inch
band over the
row, or broadcast
to seed furrow or
7-inch band over
the row.
Foliar appli-
cation





Soil treatment





Application
Timing
Preplant seed
application



At-planting




At-planting


Begin when disease
threatens and con-
tinue at 14-day
intervals as needed.



Begin early season
application to soil
under canopy of
tree. Make 2 addi-
tional applications
as needed.

Remarks













Tolerance :
3 ppm dry
bulb, 10
ppm green
7-day pre-
harvest
interval.
Tolerance :
1.0 ppm
fruit, 7.0
ppm for
molasses,
oil pulp.
                         27

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                                USE OF METALAXYL ON TERRESTRIAL FOOD, NONFOOD AND ORNAMENTAL CROPS
Use Site
Cucurbits
Tomatoes
Cotton
(seed
treatment)
Target Pest
Downy mildew
Pythium damp-
ing-off
cottony leak
(Pythium)

Late blight
             Pythium damp-
             ing-off
Pythium damp-
ing-off, seed
and seedling
rot

Pythium damp-
ing-off
  Formulation
 & EPA Reg. No.
MAI 9% WP (100-658),
10% WP (100-629)
                             SAI 2 Ib/gal EC
                             (100-607)
MAI 9% WP (100-658),
   10% WP (100-629)
                SAI 2 Ib/gal EC
                (100-619) and
                (100-607), 5% G
                (100-646)
SAI 2 Ib/gal EC
(100-607), 5% G
(100-628) MAI 1% G
(100-664)

SAI 25% WP (100-
639), 2.65 Ib/gal
F1C (2935-427 and
7501-42)
Application
Rate
0.135 to 0.2 Ib/A
1.0 to 2.0 lb/ trea-
ted acre.
0.135 to 0.2 Ib/A
0.5 to 2.0 Ib/A
0.0625 to 0.125 lb/
13,000 linear ft of
row.
0.25 to 0.5 oz per
100 lb seed.
Application
Method
Foliar
Soil, broadcast
or banded on a
7-inch band.
Foliar
Soil
Soil application
at-planting in
seed furrow.
Seed treatment
Application
Timing
Begin when plants
are in two-leaf
stage, repeat at
14-day intervals
as needed.
One application at-
planting.
Begin application
when disease threat-
ens; repeat at 14-
day intervals as
needed.
Apply ' immediately
before or at-plant-
ing to soil surface.
Incorporate or
apply irrigation
water.
At-planting only
Preplanting
Remarks
Tolerance :
1 ppm
5 day pre-
harvest
interval .

Tolerance :
1.0 ppm
3 Ib/A/
season
maximum.

Tolerance :
0. 1 ppm in
cotton
seed.

                                                          28

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D.  Required Labeling

    All metalaxyl products must bear appropriate labeling as
specified in 40 CFR 162.10.  Appendix II contains information
on label requirements.

    In order to remain in compliance with FIFRA, no pesticide
product containing metalaxyl may be released for shipment by
the registrant after October 30, 1989, unless the product bears
amended labeling which complies with the specifications in this
Standard.

    In order to remain in compliance with FIFRA, no pesticide
product containing metalaxyl may be distributed, sold, offered
for sale, held for sale,  shipped, delivered for shipment, or
recedved and (having been so received) delivered or offered to
be delivered by any person after October 30, 1990, unless the
product bears amended labeling which complies with the speci-
fications in this Standard.

    In addition to the above, in order to remain in compliance
with FIFRA,  the following information must appear on the
labeling:

    1.  All  MP's and EP's must bear the following statements;

        A.   Ingredient Statement.  The ingredient statement
            for MP's and EP's must list the active ingredient
            as:

                Metalaxyl 	(  % ai)

    2.  Maufacturinq-Use Products

        A.   Use Pattern Statement.  All manufacturing-use prod-
            ucts must state that they are intended for formula-
            tion into end-use products for acceptable use
            patterns.  However, no use may be included on the
            label where the registrant fails to agree to comply
            with the data requirements in Table A for that use
            pattern.

        B.   Disposal Statements.  Because metalaxyl has not
            been designated as an acute or toxic hazardous
            waste under the Resource Conservation and Recovery
            Act (RCRA), the following is the appropriate pest-
            icide disposal statement for metalaxyl products:

                "Wastes resulting from the use  of this product
                may be disposed of on site or at an approved
                waste disposal facility."

            The labels of all products must bear the appropriate
            container disposal statement (See Appendix III).
                                29

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   C.   All  MP's  must  bear the  following  statement:

     "Do  not  discharge  effluent  containing  this  product
     into lakes,  streams, ponds,  estuaries,  oceans,  or
     public waters  unless this product  is specifically
     identified  and addressed  in an  NPDES permit.   Do
     not  discharge  effluent containing  this  product to
     sewer  systems  without previously, notifying  the
     sewege treatment plant authority.   For  guidance
     contact  your State Water  Board  or  Regional  Office
     of the EPA."

3.   End-Use Pro-duets.   All End-Use products  are  to  bear
    "the following statements on  the  label:

     "Do  not  apply  directly to water or  wetlands (swamps,
     bogs,  marshes, and potholes).   Do  not  contaminate
     water  when  disposing of equipment  washwaters."

     "Do  not  plant  any  crop which is not registered for
     use  with metalaxyl in metalaxyl treated soil  for a
     period of 12 months."
                          30

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            V.   PRODUCTS  SUBJECT TO THIS STANDARD

      All  products containing one or more of the pesticides
 identified  in Section  II.A. are subject to certain requirements
 for  data  submittal or  changes in composition, labeling or
 packaging of the product.  The applicable requirements depend
 on whether  the product  is a manufacturing or end use product
 and  whether the  pesticide is the sole active ingredient or
 one  of multiple  active  ingredients.

     Products are subject  to this Registration Standard as
 follows:

 A.   Manufacturing use products containing this pesticide as
 the  sc^le  active  ingredient are subject to:

      1.   The restrictions (if any) upon use, composition, or
      packaging listed  in  Section IV, if they pertain to the
      manufacturing use  product.

      2.   The data requirements listed in Tables A and B2

      3.   The labeling  requirements specified for manufacturing
      use  products in Section IV.

      4.   Administrative requirements (application forms, Confiden-
      tial Statement of  Formula, data compensation provisions)
      associated with reregistration.
2 Data requirements are listed in the three Tables in
Appendix I of this Registration Standard.  The Guide to
Tables in that Appendix explains how to read the Tables.

  Table A lists generic data requirements applicable to all
products containing the pesticide subject to this Registra-
tion Standard.  Table B lists product-specific data applicable
to manufacturing use products.  The data in Tables A and B
need not be submitted by an end use producer who is eligible
for the generic data exemption for that active ingredient.

  Table C lists product-specific data applicable to end use
products.  The Agency has decided that, in most cases, it
will not require the submittal of product-specific data for
end use products at this time.  Therefore most Registration
Standards do not contain a Table C.


                                  31

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B.  Manufacturing use products containing  this  pesticide
as one of multiple active ingredients are  subject  to:

    1.  The data requirements listed in Table A.

    2.  The labeling requirements specified for manufacturing
    use products in Section IV.

C.  End use products containing this pesticide  as  the
sole active ingredient are subject to:

     1.  The restrictions (if any) upon use,  composition,  or
     packaging listed in Section IV if they pertain to the
     end use product.

     2.  If eligible for the generic data  exemption^,  the
     data requirements listed in Table C.

     3.  If not eligible for the generic data exemption,  the
     data requirements listed in Table A and the data  require-
     ments listed in Table C.

     4.  The labeling requirements specified for end use
     products in Section IV.

D.  End use products containing this pesticide  as  one  of
multiple active ingredients are subject to:

     1.  If not eligible for the generic data exemption,
     the data requirements listed in Tables A and  C.
3 if you purchase from another producer and use as the
source of your active ingredient only EPA-registered products,
you are eligible for the generic data exemption for generic
data concerning that active ingredient (Table A) and product-
specific data for the registered manufacturing use product
you purchase (Table B).

     Two circumstances nullify this exemption:

     1)  If you change sources of active ingredient to an
unregistered product, formulate your own active ingredient,
or acquire your active ingredient from a firm with ownership
in common with yours, you individually lose the exemption
and become subject to the data requirements in Table A.

     2)  If no producer subject to the generic data requirements
in Table A agrees to submit the required data, all end use
producers lose the exemption, and become subject  to the data
requirements in Table A.

                                 32

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      2.   If eligible  for the generic data exemption, the
      data  requirements  listed in Table C.

      3.   The  labeling requirements specified for end use
      products  in Section IV.
       VI.  REQUIREMENT FOR SUBMISSION OF GENERIC DATA

     This portion of the Registration Standard is a notice
 issued under the authority of FIFRA sec. 3(c)(2)(B).  It
 refers to the data listed in Table A, which are required to
 be submitted by registrants to maintain in effect the regis-
 tration of products containing this active ingredient.4

 A.  what are generic data?

     Generic data pertain to the properties or effects of a
 particular active ingredient.  Such data are relevant to an
 evaluation of all products containing that active ingredient
 regardless of whether the product contains other ingredients
 (unless the product bears labeling that would make the data
 requirement inapplicable).

     Generic data may also be data on a "typical formulation"
 of a product.  "Typical formulation" testing is often required
 for ecological effects studies and applies to all products
 having that formulation type.  These are classed as generic
 data, and are contained in Table A.

 B.  Who must submit generic data?

     All current registrants are responsible for submitting
 generic data in response to a data request under FIFRA sec.
 3(c)(2)(B) (DCI Notice).  EPA has decided, however, not to
 require a registrant who qualifies for the formulator's
 exemption (FIFRA sec. 3(c)(2)(D) and S 152.85) to submit
 generic data in response to a DCI notice if the registrant
 who supplies the active ingredient in his product is complying
 with the data request.

     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 registrants who have committed to
 generate and submit the required data fail to take appropriate
 steps to meet the requirements or are no longer in compliance
 with this data requirements notice, the Agency will consider
4 Registrations granted after issuance of this Standard will
be conditioned upon submittal or citation of the data listed
in this Registration Standard.


                                33

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that both they and you are not in compliance and will normally
initiate proceedings to suspend the registrations of both
your product(s) and their product(s)  unless you commit to submit
and submit the required data in the specified timeframe.   In
such cases, the Agency generally will not grant a time extension
for submitting the data.

     If you are not now eligible for  a generic data exemption,
you may qualify for one if you change your source of supply
to a registered source that does not  share ownership in
common with your firm.  If you choose to change sources of
supply, the Confidential Statement of Formula must identify
the new source(s) and you must submit a Generic Data Exemption
Statement.
     \
     If you apply for a new registration for products containing
this active ingredient after the issuance of this Registration
Standard, you will be required to submit or cite generic data
relevant to the uses of your product  if, at the time the
application is submitted, the data have been submitted to the
Agency by current registrants.  If the required data have not
yet been submitted, any new registration will be conditioned
upon the new registrant's submittal or citation of the
required data not later than the date upon which current
registrants of similar products are required to provide such
data.  See FIFRA sec. 3(c)(7)(A).  If you thereafter fail to
comply with the condition of that registration to provide
data, the registration may be cancelled (FIFRA sec. 6(e)).

C.  What generic data must be submitted?

     You may determine which generic  data you must submit by
consulting Table A.  That table lists the generic data needed
to evaluate current uses of all products containing this
active ingredient, the uses for which such data are required,
and the dates by which the data must  be submitted to the
Agency.

D.  How to comply with PCI requirements.

     Within 90 days of your receipt of this Registration
Standard, you must submit to EPA a completed copy of the  form
entitled "FIFRA Section 3(c)(2)(B) Summary Sheet"  (EPA Form
8580-1, enclosed) for each of your products.  On that form
you must state which of the following six methods you will
use to comply with the DCI requirements:

     1.  You will submit the data yourself.

     2.  You have entered into an agreement with one or more
registrants to jointly develop (or share  in the cost of
developing) the data, but will not be submitting the data
yourself.  If you use this method, you must state  who will



                                 34

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 submit the data on  which  you  will  rely.   You  must  also  provide
 EPA with documentary evidence that an  agreement  has  been
 formed which allows you  to rely  upon the  data to be  submitted.
 Such evidence may be:   (1) your  letter offering  to join in
 an agreement and the other registrant's acceptance of your
 offer, (2) a written statement by  the  parties that an agreement
 exists,  or (3)  a written  statement by  the person who will be
 submitting the  data that  you  may rely  upon its submittal.
 The Agency will also require  adequate  assurance  that the
 person whom you state  will provide the data is taking appropriate
 steps  to secure it.   The  agreement to  produce the  data  need
 not specify all of  the terms  of  the final arrangement between
 the parties or  a mechanism to resolve  the terms.

      If  you and other  registrants  together are generating or
 submitting requested data as  a task force or  consortium, a
 representative  of the  group should request a  Joint Data
 Submitter  Number, as part of  your  90-day  response.   The
 request  must  include the  following information:

     a.  A list of  the members of  the  consortium;
     b.  The  name and  address of the designated  representative
         of the consortium, with whom  EPA will correspond
         concerning  the data;
     c.  Identity of the  Registration  Standard containing
         the  data requirement;
     d.  A list of  the products  affected  (from all members
         of the consortium);  and
     e.  Identification of the specific data  that  the con-
         sortium will  be  generating or submitting.

     The Agency will assign a number to the consortium, which
 should be  used  on all  data submittals  by  the  consortium.

     3.  You  have attempted to enter into an  agreement  to
 jointly develop dataf  but  no  other  registrant  has  accepted
 your offer.   You  request  that EPA  not  suspend  your registration
 for  non-compliance with the PCI.   EPA  has determined that,
 as  a general  policy, it will  not suspend  the  registration of
 a product  when  the  registrant has  in good faith  sought  and
 continues  to  seek to enter  into a  data development/cost
 sharing program,  but the  other registrants developing the
 data have  refused to accept its offer.  [If your offer  is
 accepted,  you may qualify  for Option 2 above  by  entering
 into an agreement to supply the data.]

     In order to qualify  for  this  method,  you  must:

     1.  File with EPA a  completed  "Certification  of Attempt
 to Enter into an  Agreement with other  Registrants  for Develop-
ment of Data" (EPA Form 8580-6, enclosed).

-------
     2.  Provide us with a copy of your offer to the other
registrant and proof of the other registrant's receipt of your
offer  (such as a certified mail receipt).   Your offer must,
at a minimum, contain the following language or its equivalent:

     [Your company name] offers to share in the burden of
     producing the data required pursuant  to FIFRA sec.
     3(c)(2)(B) in the [name of active ingredient] Registration
     Standard upon terms to be agreed or failing agreement
     to be bound by binding arbitration as provided by FIFRA
     section 3(c)(2)(B)(iii) .

The remainder of your offer may not in any way attempt to
limit this commitment.  If the other registrant to whom your
offer is made does not accept  your offer,  and if the other
registrant informs us on a DCI Summary sheet that he will
develop and submit the data required under the DCI, then you
may qualify for this option.  In order for you to avoid
suspension under this method,  you may not  later withdraw or
limit 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 in a timely manner.  If the other registrant fails to
develop the data or for some other reason  would be subject to
suspension, your registration  as well as that of the other
registrant will normally be subject to initiation of suspension
proceedings, unless you commit to submit and submit the required
data in the specified timeframe.  In such  cases, the Agency
generally will not grant a time extension  for submitting the data.

     4.  You request a waiver  of the data  requirement.  If
you believe that a data requirement does not (or should not)
apply to your product or its uses, you must provide EPA with
a statement of the reasons why you believe this is so.  Your
statement must address the specific composition or use factors
that lead you to believe that  a requirement does not apply.
Since the Agency has carefully considered  the composition and
uses of pesticide products in  determining  that a data  require-
ment applies, EPA does not anticipate that many waivers will
be granted.  A request for waiver does not extend the  time-
frames for developing required data, and if your waiver
request is denied, your registration may be suspended  if you
fail to submit the data.  The  Agency will  respond  in writing
to your request for a waiver.

     5.  You request that EPA amend your registration  by deleting
the uses for which the data are needed.  You are  not  required
to submit data for uses which are no longer on your  label.
                                 36

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      6.   You  request  voluntary cancellation of the registration
 of  your  product(s)  for  which  the data are needed.
 E.   Registrant  Requests  Regarding Data Requirements and Agency
     Responses

      All  requests  for modification of data requirements
 (inapplicability,  waiver), approval of protocols or protocol
 changes,  or  time extensions must be submitted in writing.
 The  original requirement  remains in effect unless the Agency
 has  notified you in writing that it has agreed to a change in
 the  requirement.   While  being considered by the Agency, such
 requests  for changes in  the requirements do not alter the
 original  requirements or  extend the time allowed for meeting
 the  requirement.


 F.   Test  Protocols and Standards

     All studies required  under this Notice must be conducted
 in accordance with test  standards outlined in the Pesticide
 Assessment Guidelines, unless other protocol or standards are
 approved  for use by the  Agency in writing.  All testing must
 be conducted in accordance with applicable Good Laboratory
 Practices regulations in  40 CFR Part 160.

     The Pesticide Assessment Guidelines, which are referenced
 in the Data Tables, are available from the National Technical
 Information Service (NTIS), Attn: Order Desk, 5285 Port Royal
 Road, Springfield, VA  22161 (tel: 703-487-4650).

     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 (Part 158.70).
 Please note, however, that certain OECD standards (such as
 test duration,  selection  of test species, and degradate
 identification which are  environmental fate requirements) are
 less restrictive than those in the EPA Assessment Guidelines
 listed above.  When using the OECD protocols, they should be
 be modified as appropriate so that the data generated by the
 study will satisfy the requirements of Part 158.  Normally,
 the  Agency will not extend deadlines for complying with data
 requirements when the studies were not conducted in accord
with acceptable standards.  The OECD protocols are available
 from OECD, 1750 Pennsylvania Avenue, N.W., Washington, D.C.
 20006.
                               37

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G.  Procedures for requesting a change in test protocol.

     If you will generate the required data and plan to use
test procedures which deviate from EPA's Pesticide Assessment
Guidelines or the Reports of Expert Groups to the Chemicals
Group, Organization for Economic Cooperation and Development
(OECD) Chemicals Testing Programme, you must submit for EPA
approval the protocols you propose to use.

     You should submit your protocols before beginning testing,
because the Agency will not ordinarily accept as sufficient
studies using unapproved protocols.  A request for protocol
approval will not extend the timeframe for submittal of the
data, nor will extensions generally be given to conduct
studies due to submittal of inappropriate protocols.  The
Agency* will respond in writing to your request for protocol
approval or change.

H.  Procedures for requesting extensions of time.

     If you think that you will need more time to generate
the data than is allowed by EPA's schedule, you may submit a
request for an extension of time.

     EPA will view failure to request an extension before
the data submittal response deadline as a waiver of any
future claim that there was insufficient time to submit the
data.  While EPA considers your request, you must strive to
meet the deadline for submitting the data.

     The extension request should state the reasons why you
believe that an extension is necessary and the steps you
have taken to meet the testing deadline.  Time extensions
normally will not be granted due to problems with laboratory
capacity or adequacy of funding, since the Agency believes
that with proper planning these can be overcome.  The Agency
will respond in writing to any requests for extension of time.


I.  Data Format and Reporting Requirements

    All data submitted in response to this Notice must comply
with 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 Notice 86-5 (issued
July 29, 1986).  All studies must be submitted in the form of
a  final report; a preliminary report will not be considered
to fulfill the submittal requirement.
                                38

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 J.   Existing stocks provision upon suspension or cancellation.

     The Agency has determined that if a registration is
 suspended for failure to respond to a DCI request under
 FIFRA sec.  3(c)(2)(B), an existing stocks provision for the
 registrant  is not consistent with the Act.  Accordingly, the
 Agency does not anticipate granting permission to sell or
 distribute  existing stocks of suspended product except in
 rare circumstances.  If you believe that your product will be
 suspended or cancelled and that an existing stocks provision
 should be granted, you have the burden of clearly demonstrating
 to EPA that granting such permission would be consistent with
 the Act.  The following information must be included in any
 request for an existing stocks provision:

     1.  Explanation of 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 or distribution; and

     2.  Demonstration that such a provision would be consis-
     tent with the provisions of FIFRA.
   VII. REQUIREMENT FOR SUBMISSION OF PRODUCT-SPECIFIC DATA

     Under its DCI authority, EPA has determined that certain
product-specific data are required to maintain your registrations
in effect.  Product-specific data are derived from testing
using a specific formulated product, and, unlike generic
data, generally support only the registration of that product.
All such data must be submitted by the dates specified in
this Registration Standard.

     If you have a manufacturing use product, these data are
listed in Table B.  If you have an end use product, the data
are listed in Table C.  As noted earlier, the Agency has
decided that it will not routinely require product-specific
data for end use products at this time.   Therefore, Table C
may not be contained in this Registration Standard; if there
is no Table C, you are not required to submit the data at
this time.

     In order to comply with the product specific data require-
ments, you must follow the same procedures as for generic data.
See Section VI.D through J.   You should note, however, that
product chemistry data are required for every product, and the
only acceptable responses are options VI.D.I. (submit data)
or VI.D.6.(cancellation of registration).

     Failure to comply with the product-specific data require-
ments for your products will result in suspension of the
product's registration.


                                39

-------
    VIII.   REQUIREMENT FOR SJBMITTAL OF REVISED LABELING

     FIFRA requires each product to be labeled with accurate,
complete and sufficient instructions and precautions, reflecting
the Agency's assessment of the data supporting the product
and its uses.   General labeling requirements are set out in
40 CFR 156.10  (see Appendix II - LABELING and SUMMARY).   In
addition,  labeling language specific to products containing
this pesticide is specified in Section IV.D of this Registra-
tion Standard.  Responses to this Registration Standard must
include draft  labeling for Agency review.

     Labeling  must be either typewritten text on 8-1/2 x 11
inch paper or  a mockup of the labeling suitable for storage
in 8-1/2 x 11  files.   Draft labeling must indicate the intended
colors of the  final label, clear indication of the front
panel of the label, and the intended type sizes of the text.

     If you fail to submit revised labeling as required,
which complies with 40 CFR 156.10 and the specific instructions
in Section IV.D., EPA may seek to cancel the registration of
your product under FIFRA sec. 6.


               IX.  INSTRUCTIONS FOR SUBMITTAL

     All submittals in response to this Registration Standard
must be sent to the following address:

     Office of Pesticide Programs
     OPP Mailroom  (TS-767C)
     Environmental Protection Agency
     401 M St., SW
     Washington, D.C.  20460

     Attn:  Metalaxyl Registration Standard

     All submittals in response to this Registration Standard
are non-fee items, including 90-day responses, protocols and
waiver requests, data, and revised labeling.  Submittals must
be clearly identified as being  in response to the Registration
Standard.  Under no circumstances may Registration Standard
responses be combined with other types of filings for which
fees are required.

A.  ManufacturingJJse Products  (MUPs) containing the subject
    pesticide as sole active ingredient.

    1.  Within 90  days from receipt of this document, you
must submit for each product subject  to  this Registration
Standard:

-------
        a.  -Generic Data Exemption Statement (EPA Form 8580-3)/
     if  applicable, or  the "FIFRA Section 3(c)(2)(B) Summary
     Sheet"  (EPA  Form 8580-1), with appropriate attachments.

        b.  Confidential Statement of Formula (EPA Form 8570-4).

        c.  Evidence of compliance with data compensation
     requirements of FIFRA sec. 3(c)(l)(D).  Refer to 40 CFR
     152.80-152.99.

     2.  Within 9 months from receipt of this document you
must submit:

        a.  Application for Pesticide Registration (EPA
     Form 8570-1).

     (   b.  Two copies of any required product-specific data
     (See Table B).

        c.  Three copies of draft labeling, including the
     container label and any associated supplemental labeling.

        d.  Product Specific Data Report (EPA Form 8580-4).

     3.  Within the times set forth in Table A, you must
submit all generic data, unless you are eligible for the
generic data exemption.  If for any reason any test is delayed
or aborted so that the schedule cannot be met, immediately
notify the Agency of the problem, the reasons for the problem,
and  your proposed course of action.

B.   Manufacturing Use  Products containing the subject pesticide
     in combination with other active ingredients.

     1.  Within 90 days from receipt of this document, you
must submit:

        a.  Generic Data Exemption Statement (EPA Form 8580-3),
     if applicable, or  the FIFRA sec. 3(c)(2)(B) Summary
    Sheet, with appropriate attachments (EPA Form 8580-1).

        b.  Confidential Statement of Formula (EPA Form 8570-4)

     2.  Within 9 months of receipt of this document, you must
submit:

        Three copies of draft labeling, including the container
    label and any associated supplemental labeling.

    3.  Within the time frames set forth in Table A, you must
submit all generic data, unless you are eligible for the
generic data exemption.  If for any reason any test is delayed
or aborted so that the schedule cannot be met, immediately


                                 41

-------
notify the Agency of the problem, the reasons for the problem,
and your proposed course of action.


C.  End Use Products containing the subject pesticide as sole
    active ingredient.

    1.  Within 90 days from receipt of this document, you
must submit:

        a.  Generic data exemption Statement (EPA Form 8580-3),
    if applicable, or the FIFRA Section 3(c)(2)(B) Summary
    Sheet, with appropriate attachments (EPA Form 8580-1).

        b.  Confidential Statement of Formula (EPA Form 8570-4).

    2.*  Within ^ months from receipt of this document you
must submit:

        a.  Two copies of any product-specific data, if required
    by Table C.

        b.  Product Specific Data Report (EPA Form 8580-4),
    if Table C lists required product-specific data.

        c.  Three copies of draft labeling, including the
    container label and any associated supplemental labeling.

    3.  Within the times set forth in Table A, you must
submit all generic data, unless you are eligible for the
generic data exemption.  If for any reason any test is delayed
or aborted so that the schedule cannot be met, immediately
notify the Agency of the problem, the reasons for the problem,
and your proposed course of action.


D.  End Use Products containing the subject active ingredient
    as one of multiple active ingredients

    1.  Within 90 days from receipt of this document, you
must submit:

        a.  Generic data exemption Statement (EPA Form 8580-3),
    if applicable, or the FIFRA Section 3(c)(2)(B) Summary
    Sheet, with appropriate attachments (EPA Form 8580-1).

        b.  Confidential Statement of Formula (EPA Form 8570-4).

    2.  Within 9 months from the receipt of this document, you
must submit:

    Three copies of draft labeling, including the container
    label and any associated supplemental  labeling.


                                 42

-------
    3.  Within the times set forth in Table A, you must
submit all generic data, unless you are eligible for the
generic data exemption.  If for any reason any test is delayed
or aborted so that the schedule cannot be met, immediately
notify the Agency of the problem, the reasons for the problem,
and your proposed course of action.
E.  Intrastate Products

    Applications for full Federal registration of intrastate
products were required to be submitted no later than July 31,
1988.   Unless an application for registration was submitted
by that date, no product may be released for shipment by the
producer after July 31, 1988.
                                 43

-------

-------
  APPENDIX I




DATA APPENDICES
           44

-------

-------
                            TGUIDE-1

                        GUIDE TO TABLES

      Tables A and B contain listings  of  data  requirements
 for the pesticides covered by this  Registration  Standard.

      Table A contains  generic data  requirements  that  apply  to
      the pesticide in  all products,  including data  requirements
      for which a "typical formulation"  is  the test  substance.

      Table B contains  product-specific  data requirements  that
      apply only to a manufacturing  use  product.


      The data tables are  generally  organized  according  to 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 out in the Pesticide  Assessment  Guidelines,
 which are available from  the National Technical  Information  -
 Service,  5285 Port Royal  Road,  Springfield, VA  22161.

 2.   Test Substance (Column 2).   This  column lists the composition
 of  the  test substance  required to be  used  for the test, as
 follows:

      TGAI  = Technical  grade  of  the  active  ingredient
      PAI =  Pure active ingredient
      PAIRA = Pure  active  ingredient,  radio labeled
      TEP =  Typical end use  formulation
      MP  =    Manufacturing use product
      EP  =    End  use product

 Any  other  test  substances,  such as  metabolites,  will  be
 specifically named in  Column 2  or in  footnotes to the table.

 3.   Use  pattern  (Column 3).   This column indicates  the use
 patterns to which  the  data requirement  applies.  Use  patterns
 are  the  same as  those  given  in  40 CFR Part 158.  The  following
 letter designations  are used for the  given use patterns:

      A * Terrestrial,  food
      B a Terrestrial,  non-food
      C = Aquatic,  food
      D = Aquatic,  non-food
      E = Greenhouse, food
      F = Greenhouse, non-food                  >- .
      G » Forestry
      H = Domestic  outdoor
      I = Indoor

Any other  designations  will  be  defined  in  a footnote  to the  table.


                                  45

-------
                            TGUIDE-2

 4.  Does EPA have data? (Column 4).  This column indicates one
 of three answers:

      YES - EPA has data in its files that satisfy this data
      requirement.  These data may be cited by other registrants
      in accordance with data compensation requirements of
      Part 152, Subpart E.

      PARTIALLY - EPA has some data in its files,  but such data
      do not fully satisfy the data requirement.   In some cases,
      the Agency may possess data on one of two required species,
      or may possess data on one test substance but not all.
      The term may also indicate that the data available to
      EPA are incomplete.  In this case,  when the data are
      clarified,  or additional details of the testing submitted
      by the original data submitter, the data may be determined
 ^     to be acceptable.   If this is the case,  a footnote to
      the table will usually say so.

      NO - EPA either possesses no data which are sufficient
      to fulfill the data requirement,  or the data which EPA
      does possess are flawed scientifically in a manner that
      cannot be remedied by clarification or additional infor-r.
      mation.

 5.   Bibliographic citation (Column 5).  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
 Appendices for a complete citation of the study.

 6.   Must additional data be submitted? (Column 6).  This
 column  indicates whether the data must be submitted to the
 Agency.   If column 3 indicates that the Agency already has
 data, this column will  usually indicate NO.   If column 3
 indicates that the Agency has only partial data or no data,
 this column will usually indicate YES.  In some cases, even
 though  the Agency does  not have the data, EPA will not require
 its  submission because  of  the unique characteristics of the
 chemical; because data  on another chemical can be used to
 fulfill  the data requirement; or because the data requirement
 has  been waived  or reserved.   Any such unusual situations
 will be  explained in a  footnote to the table.

 7.   Tiaefraae for submission (Column 7).  If column 5 requires
 that data be submitted,this column indicates when the data
 are  to be submitted,  based on the issuance date of the Regis-
 tration  Standard.   The  timeframes are those established either
 as a result of a previous  Data Call-in letter, >or.,. standardized
 timeframes established  by PR Notice 85-5 (August 22, 1985).

 8.   Footnotes (at the end of each table).  Self-explanatory.



                                  46

-------
                                                      TABLE  A
                                        GENERIC DATA  REQUIREMENTS  FOR METALAXYL
     Data Requirement
Composition1  Pattern
        Does EPA Have
        Data to Satisfy
        This Require-
        ment?  (Yes, No Bibliographic
        or Partially)     Citation
                                                                                  -Must Additional
                                                                                   Data Be Submitted
                                                                            Time Period
                                                                            After EPA
                                                                            Notification
                                                                                   Under FIFRA Section  to Report
                              3(c)(2)(B)?
                                    Data3
§158.120 Product Chemistry

Product Identity and Composition

61-1 - Product Identity
         and Disclosure of
         Ingredients
      TGAI
61-2 - Description of Beginning   TGAI
         Materials and Manufac-
         turing Process

61-3 - Discussion of Formation    TGAI
         of Impurities

Analysis and Certification of
Product Ingredients

62-1 - Preliminary Analysis       TGAI
         of Product Samples

62-2 - Certification of           TGAI
         Ingredient Limits

62-3 - Analytical Methods         TGAI
         to Verify Certified
         Limits
All
                All
                All
                All


                All


                All
Yes
          Partially
00104498  4
               00104498
          Partially      00104498
                         00104483
          Partially
          No
          Partially
                                                            No
                                                            Yes-
                                   Yes6
                                     6 Months
                                                                             6 Months
00104483
40435001
00104498
Yes?
Yes8,9
YeslO
12 Months
12 Months
12 Months
                                                                47,

-------
                                                  TABLE A
                                  GENERIC DATA REQUIREMENTS FOR METALAXYL
Data Requirement
                Use2
Compositionl  Pattern
Does EPA Have
Data to Satisfy
This Require-
nent?  (Yes,  No
or Partially)
Bibliographic
 Citation
Must Additional
Data Be Submitted
Under FIFRA Section
3(c)(2)(B)?
Time Period
After EPA
Notification
to Report
Data3
§158. 120 Product Chemistry (continued)

Physical and Chemical Characteristics
63-2
63-3
63-4
63-5
63-6
63-7
63-8
63-9
63-10
63-11
63-12
63-13
- Color
- Physical State
- Odor
- Melting Point
- Boiling Point
- Density, Bulk Density,
or Specific Gravity
- Solubility
- Vapor Pressure
- Dissociation Constant
TGAI
TGAI
TGAI
TGAI
TGAI
TGAI
TGAI or PAI
PAI
TGAI or PAI
- Octanol/Water Partition TGAI
Coefficient
- PH
- Storage Stability
TGAI
TGAI
All Yes
All Yes
All Yes
All Yes
All N/AH
All Yes
All Yes
All Yes
All Yes
All Yes
All Yes
All Yes
00104483
00104483
00104483
00104483

00104483
00104483
00104483
00104483
40435001
40435001
00104483
No
No
No
No
No
No
No
No
No
No
No
No
                                                  48

-------
                                                       TABLE A
                                       GENERIC DATA REQUIREMENTS FDR METALAXYL
                                                   Does EPA Have                                       Time Period
                                                   Data to Satisfy             *  Must Additional      After EPA
                                                   This Require-                  Data Be Submitted    Notification
                                           Use2    nent?  (Yes, No Bibliographic  Under FIFRA Section  to Report
     Data Requirement       Composition1  Pattern   or Partially)     Citation     3(c)(2)(B)?          Data3
§158.120 Product Chemistry (continued)

Other Requirements;

64-1 - Submittal of Samples      N/A       N/A          N/A             N/A12          No                N/A
                                                      49

-------
                                              FOOTNOTES FDR PREVIOUS TABLE A

 I/ The 90% technical is the only registered metalaxyl manufacturing-use product.   Composition:  TGAI = technical grade
 ~~  of the active ingredient;  PAI = pure active ingredient.
 2/ The use patterns are coded as follows:   "A" for  Terrestrial,  Food Crop;  "B" for-Terrestrial, Non-Foods,; "C" for
    Aquatic, Food Crop,  "D" for Aquatic, Non-Food;  "E" for  Greenhouse, Food Crop;  "F" for Greenhouse, Non-Food;
    "G" for Forestry; "H" for  Domestic Outdoor; and  "I" for Indoor.
 3/ Data must be submitted within the indicated time frames which begin upon receipt of the Guidance Document.
 4/ Information obtained from desk references.
 5/ Complete information must be provided regarding  the nature of the process (batch or continuous), the relative
    amounts of beginning material and the order in which they are added, the chemical equations for each intended
    reaction, equipment  used to produce each intermediate and the final product,  reaction conditions, the duration
    of each step of the  process, purification procedures, and quality control measures.  In addition, the name and
    address of the manufacturer, producer,  or supplier of each beginning material must be provided, along with in-
    formation regarding  the properties of each beginning material used to manufacture each product.  In order to
    assess the potential for contamination  with nitrosamines, a{description of manufacturing process conditions
    favoring formation of nitrosamines must be provided.        |
 6/ A detailed discussion of all impurities that are or may be present at >^ 0.1%,  based on knowledge of the beginning
    materials, chemical  reactions (intended and side) in the manufacturing process, and any contamination during and
    after production must be submitted.  This discussion must also address the possible formation of nitrosamines
    from metalaxyl and its impurities.
 7/ Five or more representative samples must be analyzed for the amount of active ingredient and each impurity for
    which a certified limit is required.  Complete  validation data (accuracy, precision) must be submitted for each
    analytical method used.
 8/ Available data do not meet the requirements of  40 CFR 158.120, Part 62-2.
 9/ Upper and lower limits for metalaxyl must be provided,  certified, and validated by sample analysis using
    analytical procedures for  which accuracy and precision  data have been provided.  Upper limits for each impurity
    present at ^0.1% (w/w), and for each "toxicologically  significant" impurity present at < 0.1% (w/w) must be
    provided, certified, and validated by sample analysis using analytical procedures for which accuracy and
    precision data have  been provided.  All nitrosamines must be identified and quantified in six samples of each
    product; two samples of each must be analyzed shortly after production and 6 months after production.  A method
    sensitive to 1 ppm of N-nitroso contaminants must be used.   An upper limit must be provided (and certified) for all
    nitrosamines found.   Certifications should be submitted on EPA Form 8570 (Rev.  2-85).
lO/ Analytical methods must be provided to determine the active ingredient and each toxicologically significant
    impurity (including  nitrosamines) for which a certified limit is required.  Each method must be accompanied
    by validation studies indicating its accuracy and precision.   These methods must be suitable for enforcement
    of certified limits.
ll/ Not required; a solid at room temperature.
12/ N/A = Not applicable.



                                                               50    '

-------
                                                       TABLE A
                                       GENERIC DATA REQUIREMENTS FOR METALAXYL
     Data Requirement
Composition^
Does EPA Have
Data to Satisfy
This Require-
ment?  (Yes, No
or Partially)
§158.125 Residue Chemistry

171-2 - Chemical Identity4

171-3 - Directions for Use

171-4 - Nature of Residue25
          (metabolism)

      - Plants
      - Livestock

171-4 - Residue Analytical
          Method

        - Plant and Animal
    TGAI
    PAIRA
    PAIRA
     TGAI and
    Metabolites
                    (See Index)
     Yes
     No
 Partially
Bibliographic
 Citation
Must Additional
Data Be Submitted
Under FIFRA Section
3(c)(2)(B)?2
                                                                                                       Time Period
                                                                                                       After EPA
                                                                                                       Notification
                                                                                                       to Report
                                                                                                       Data3
00071603,00071604,
00071605,00071606
00071607,00071608,
00071609,00071610,
00114379,00128102
00071622,00071623,
00071676,00104656,
00148440,00157740,
                                          Yes5
                                      6 Months
                                                             No
                                                                                        Yes
                                                                           18 Months
      Yes'
                                                                           15 Months
171-4 - Storage Stability
     PAI or TEP,    Partially
    and Metabolites
                    00148440
                                                                                                       18  Months
                                                              51

-------
                                                       TABLE A
                                       GENERIC DATA REQUIREMENTS FOR METALAXYL
     Data Requirement
Composition-1
§158.125 Residue Chemistry

171-4 - Magnitude of the25
          Residue—Residue
          Studies for Each
          Food Use

      - Crop Field Trials

      - Crop Group #1 - Root
          Tuber Vegetables
          Group

        o  Beets

        o  Potatoes

        o  Sugar Beet Roots

      - Crop Group #2 - Leaves
          of Root and Tuber
          Vegetables Group

        o  Beet Greens

        o  Sugar Beet Tops
      TEP

      TEP
Does EPA Have
Data to Satisfy
This Require-
ment?  (Yes, No
or Partially)
 Yes

 Partially

 No
                    Yes

                    No
Bibliographic
 Citation
  00128102

  00071616
                     00128102
Must Additional
Data Be Submitted
Under FIFRA Section
3(c)(2)(B)?2
Time Period
After EPA
Notification
to Report,
Data3
                                                          No
                     Yes11
                     24 Months

                     24 Months
                     No

                     No12
                                                               52

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                                                       TABLE A
                                       GENERIC DATA REQUIREMENTS FDR METALAXYL
     Data Requirement
Composition1
Does EPA Have
Data to Satisfy
This Require-
ment?  (Yes,  No
or Partially)
Bibliographic
 Citation
Must Additional
Data Be Submitted
Under FIFRA Section
3(c)(2)(B)?2
Time Period
After EPA
Notification
to Report
Data3
§158.125 Residue Chemistry  (con't)

171-4 - Magnitude of the
          Residue—Residue
          Studies for Each
          Food Use (cont'd)

      - Crop Group #3 - Bulb
          Vegetables Group

        o  Onions
      - Crop Group #4  - Leafy
          Vegetables Group

        o  Lettuce
        o  Spinach


        Crop Group  #5  - Brassica
          Leafy Vegetables Group

        o  Broccoli

        o  Cabbage

        o  Cauliflower
                         Yes
                         Yes
                         Yes
                         Yes

                         Yes

                         Yes
                  00071615,00098428
                  00130694,00148103
                  00071615,00097511
                  00114377,00130695

                  00071672,00114378
                  00130695
                  00071615,00130773

                  00071615,00130773

                  00071615,00130773
                       No
                       No
                       No
                       No

                       No

                       No
                                                     53

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                                                       TABLE A
                                       GENERIC DATA REQUIREMENTS EDR METALAXYL
     Data Requirement
Composition*
Does EPA Have
Data to Satisfy
This Require-
ment?  (Yes, No
or Partially)
  Bibliographic
   Citation
Must Additional
Data Be Submitted
Under FTFRA Section
3(c)(2)(B)?2
Tine Period
After EPA
Notification
to Report
Data3
§158.125 Residue Chemistry (cpnt'd)

171-4 - Magnitude of the
          Residue—Residue
          Studies for Each
          Food Use (cont'd)

      - Crop Group #6 - Legume
          Vegetables Group
           Soybeans
        Crop Group #7 - Foliage
          of the Legume
          Vegetables Group

        Crop Group #8 - Fruiting
          Vegetables Group

        Crop Group #9 - Curcubit
          Vegetables Group

        Crop Group #10 - Citrus
          Fruits Group

        Crop Group #11 - Pome
          Fruits Group

        o  Apples
      TEP
                     Yes
Partially
                     Yes
                     Yes
                     Yes
                    Yes
                 00129003
00071672,00104390
00148440

00129003
                 00148103,00148440
                 00157480

                 00071615,00098428
                 00130693,00148103

                 00117969,00133020
                 00148440
       No


       Yes13


       No




       No


       No


       No
 18 Months
                    Yes
                 00126315,00141519
                   i
                          No
                                                       54

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               TABLE A
GENERIC DATA REQUIREMENTS FOR METALAXYL
	 [— 	
I
{
I -1
Data Requirement Composition1
§158.125 Residue Chemistry (cont'd)
171-4 - Magnitude of the
Re s idue — Res idue
Studies for Each
Food Use (cont'd)
- Crop Group #12 - Small TEP
Fruits and Berries
Group
o Raspberries
- Crop Group #13 - Cereal TEP
Grains Group
- Crop Group #14 - Forage, TEP
Fodder, and Straw of
Cereal Grains Group
- Miscellaneous Commodities
o Avocados
o Cottonseed TEP
o Hops TEP
o Peanuts TEP
Does EPA Have
Data to Satisfy
This Require-
ment? (Yes, No
or Partially)








Yes
Partially

Partially



Yes
Partially
Partially
Partially
Time Period
Must Additional After EPA
Data Be Submitted Notification
Bibliographic Under FIFRA Section to Report
Citation 3(c)(2)(B)?2 Data3








00127769 No
00128102,00071672 Yes 18 Months14
00104387,00114376 24 Months1^
00128102 Yes 18 MonthsIS
6 Months17


00074488 No
00109402 Yes18 24 Months
00079433 Yes19 24 Months
00128738 Yes20 24 Months
              55

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                                                       TABLE  A
                                        GENERIC DATA  REQUIREMENTS FDR METALAXYL
     Data Requirement
Composition-^
Does EPA Have
Data to Satisfy
This Require-
ment?  (Yes, No
or Partially)
Bibliographic
 Citation
Must Additional
Data Be Submitted
Under FIFRA Section
3(c)(2)(B)?2
Time Period
After EPA
Notification
to Report
Data3
§158.12J5 Residue Chemistry (cont*d)

171-4  - Magnitude of the
          Residue—Residue
          Studies for Each
          Food Use (cont'd)

      - Miscellaneous Commodities (cont'd)

        o  Pineapples            TEP

        o  Sunflower Seed        TEP

        o  Tobacco

      - Nonbearing Orchard Groups

        o  Pome Fruit            TEP

        o  Stone Fruit           TEP

        o  Tree Nuts             TEP

      - Meat/Milk/Poultry/Eggs
Partially
Partially
No
No
No
Yes
00109472 Yes^1
00128102 Yes22
00148440 No
No2 3
No23
No23
00071674,00114376, Reserved24
24 Month
24 Month
                                                                 00100753,00071673
                                                     56

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                                                       TABLE A
                                        GENERIC DATA REQUIREMENTS EDR METALAXYL
FOOTNOTES:
 I/ Test Substance:  TGAI = Technical  grade of  the active  ingredient;  PAIRA = Pure active  ingredient,  radiolabeled;
    TEP = Typical end-use product;  EP  = End-use product.
 2/ The use patterns are coded as follows:  "A"  for Terrestrial,  Food Crop;  "B" for Terrestrial,  Non-Foods,;  "C"  for
    Aquatic, Food Crop; "D" for [Aquatic, Non-Food; "E"  for Greenhouse,  Food Crop;  "F"  for  Greenhouse,  Non-Food;
    "G" for Forestry; "H" for Domestic Outdoor;  and  "I"  for  Indoor.
 V Timeframe for submission is from date of  registrants receipt of  registration  standard.
 4/ Refer to Product Chemistry Data Requirement tables.
 5/ The registrant must propose (i) a  label amendment that specifies a maximum seasonal  use rate or maximum number of
    applications per season for dry bulb onions (based on  the available data,  we  recommend a maximum of four applica-
    tions per season); and (ii) a preharvest  interval following  registered/proposed  use  of metalaxyl on members  of
    the Fruiting Vegetables (except Curcurbits)  Groups  (based on the available data, we  recommend a 7-day preharvest
    interval).   Also, refer to footnote 17  for  additional  required label amendments  for  wheat as a rotational crop.
 _§/ Metabolism studies must be submitted utilizing ruminants and poultry in which animals  must be dosed for a minimum
    of 3 days with -l^c] metalaxyl  at  a level sufficient to  make residue identification  and quantification possible.
    Milk and eggs must be collected twice daily during  the dosing period.   Animals must  be sacrificed  within 24  hours
    of the final dose.  The distribution and  characterization of residues must be determined in  milk,  eggs,  liver,
    kidney, and muscle and also skin and gizzard for hen.  If the metabolism of metalaxyl  in ruminants or_ poultry is
    found to differ from that in rats,  or with  each  other, then  swine  metabolism  data  may  be required.   Data reflecting
    solvent extraction of residues  are also required.   Representative  samples from the above described tests must also
    be analyzed by current enforcement methods  to ascertain  the  validity of these methods.
 7/ Metalaxyl metabolites containing the 2,6-dimethylaniline moiety  and CGA-94689 in or  on crop  samples must be
    subjected to analysis by multiresidue protocols.  Protocols  for  Methods I, II, III,  and IV are available from
    the National Technical Information Service  under Order No. PB-203734/AS.
 8/ The storage intervals and conditions of samples  used to  support  all established  tolerances for residues must be
    submitted.   These data must be  accompanied  by data  depicting the percent decline in  residues at the times and under
    the conditions specified.   (No  additional stability  studies  are  required for  plant commodities stored at 5 °F
    [-15 °C] for up to 12 months.)   On receipt  of these  data, the adequacy of the aforementioned tolerances will be
    evaluated.
 9_/ All residue data requested in this Standard must be  accompanied  by data regarding  storage length and conditions
    of storage of samples analyzed.  These  data must be  accompanied  by data depicting  the  stability of residues  under
    the conditions and for the time intervals specified, with the exception of plant commodities stored at 5 °F
    (-15 °C) for up to 12 months.
10/ Data must be submitted depicting metalaxyl  residues  of concern in  chips,  granules  or flakes,  and wet and dry potato
    peel processed from potatoes bearing measurable, weathered residues.   If residues  concentrate in any of these
    processed commodities,  appropriate food/feed additive  tolerances must be proposed.

                                                                  i

                                                      57

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                                                        TABLE A
                                        GENERIC DATA REQUIREMENTS FOR METALAXYL
FOOTNOTES (cont'd):
ll/ Data must be submitted depicting total metalaxyl residues of concern in molasses processed from sugar beets bearing
    measurable, weathered residues to support the established tolerance of 1.0 ppm in molasses.  In addition, data  must
    be submitted depicting metalaxyl residues of concern in dehydrated pulp and refined sugar processed from sugar
    beets bearing measurable, weathered residues.  If residues are found to concentrate in either of these processed
    commodities, appropriate food/feed additive tolerances must be proposed.
12_/ Data from garden beets are adequate to support sugar beets.
13/ The registrant must propose tolerances for total metalaxyl residues in or on soybean forage, hay, and straw.
    We recommend a tolerance of 8 ppm, toxicological considerations permitting, based on the available data.
14/ Data must be submitted depicting metalaxyl residues of concern in or on the grain of field corn harvested from
    seed treated with the 25% WP formulation at 0.5 oz ai/100 Ib of seed.
15/ Data must be submitted depicting metalaxyl residues of concern in milled products and grain dust from the milling
    process of:  field corn (starch, crude and refined oils from wet milling, and grits, meal, flour, crude and refined
    oils from dry milling); rice (hulls, bran, polished rich); and sorghum (flour, starch) grains bearing measurable,
    weathered residues.  If residues concentrate during processing in any of these commodities, then appropriate food/
    feed additive tolerances must be proposed.
16/ Data must be submitted depicting metalaxyl residues of concern in or on field corn forage and fodder grown from
    seed treated with the 25% WP formulation at 0.5 oz ai/100 Ib of seed.
IT/ The registrant must propose specific time restrictions with respect to the last application of the 2 Ib/gal
    EC formulation to the primary crops and planting of the rotational wheat crop.  Based on the available data, we
    recommend an interval of 14 days.
18_/ Data must be submitted depicting concentration of metalaxyl residues of concern during processing of cottonseed
    hulls, meal, crude oil, refined oil, and soapstock derived from cottonseed bearing measurable, weathered residues.
    (Exaggerated application rates may be necessary to obtain these levels on the cottonseed.)  If concentration occurs
    during processing, the registrant must propose appropriate food/feed additive tolerances.
19_/ The Agency has established interim tolerances for metalaxyl in dried and spent hops at 50.0 ppm with an expiration
    date of October 28, 1988.  Additional residue data have been submitted and are currently under review.  Based
    on these data revised tolerances may need to be proposed and established.
20_/ Data must be submitted depicting metalaxyl residues of concern in or on nuts, hulls, hay, and vines from soil
    applications of a G formulation at 0.25 Ib ai/A (at-planting) and 1.0 Ib ai/13,000 linear ft of row (at pegging).
    Tests must be conducted in AL (15%), GA (49%), NC (10%), OK (4%), and VA (6%), States which collectively produced
    ca. 84% of 1984 U.S. peanut product.
21/ Data must be submitted from a processing study depicting metalaxyl residues of concern in pineapple juice and
    pineapple bran (chopped, dehydrated pineapple tops and shells) processed from pineapple fruit bearing measurable,
    weathered residues.  If residues concentrate in any of these processed commodities, then appropriate food/feed
    additive tolerances must be proposed.

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                                                        TABLE A
                                        GENERIC DATA REQUIREMENTS FOR METALAXYL
FOOTNOTES (ccnt'd):
22/ Data must be submitted depicting metalaxyl residues of concern in meal, hulls, crude oil and refined oil processed
    from sunflower seed bearing measurable,  weathered residues.   If residues concentrate in any of these commodities
    then appropriate food/feed additive tolerances must be proposed.
23/ Considered "non-food use."
24/ Presently, the nature of the residue in  animals is not adequately understood.  On receipt of the data requested in
    the section entitled "Nature of the Residue in Animals," the appropriate nature of tolerances for residues in animal
    products will be determined and, with consideration for any newly found metabolites of toxicological concern, the
    adequacy of the available data regarding the magnitude of the residue in animal commodities (milk, poultry, eggs,
    fat, meat, liver, and kidney) will be determined.
25/ For nature of the residue in plants and  magnitude of the residue in crops, the timeframes for submitting data are 18
    or 24 months, as appropriate, commencing with the first planting season following the receipt of the Registration
    Standard.

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               TABLE A
GENERIC DATA REQUIREMENTS FDR METALAXYL
Data Requirement Composition^
§158.135 Toxicology
ACUTE TESTING:
81-1 - Acute Oral - Rat TGAI
81-2 - Acute Dermal - Rabbit TGAI
81-3 - Acute Inhalation - Rat TGAI
81-4 - Eye Irritation - Rabbit TGAI
81-5 - Dermal Irritation - TGAI
Rabbit
81-6 - Dermal Sensitization - TGAI
Guinea Pig
81-7 - Delayed Neurotoxicity - TGAI
Hen
SUBCHRONIC TESTING:
82-1 - 90-Day Feeding
- Rodent TGAI
- Non-rodent TGAI
Does EPA Have
Data to Satisfy
This Require-
Use2 rrent? (Yes, No
Pattern or Partially)
A,B Yes
A,B Yes
A,B No
A,B Yes
A,B Yes
A,B Yes
A,B No
A,B Yes
A,B Yes
Time Perkx
Must Additional After EPA
Data Be Submitted Notificati<
Bibliographic Under FIFRA Section to Report
Citation 3(c)(2)(B)? Data3 ,
00063990,00063991 No
00154308
00063993,00063994 No
Yes 9 Months
00084108 No
00084107 No
00084109 No
No4
00084110,00148087 No
00084111 No
                60

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               TABLE A
GENERIC DATA REQUIREMENTS FDR METALAXYL
Does EPA Have Time Period
Data to Satisfy * Must Additional After EPA
This Require- Data Be Submitted Notification
Use2 nent? (Yes, No Bibliographic Under FIFRA Section to Report
Data Requirement Composition1 Pattern or Partially) Citation 3(c)(2)(B)? Data3
§158.135 Toxicology (cont'd)
SUBCHRONIC TESTING (cont'd):
82-2 - 21-Day Dermal
82-3 - 90-Day Dermal
82-4 - 90-Day Inhalation

82-5 - 90-Day Neurotoxicity
CHRONIC TESTING:
83-1 - Chronic Toxicity
2 Species:
- Rodent, and
- Nonrodent
83-2 - Oncogenicity Study
2 Species:
- Rat, and
- Mouse
TGAI A,B Yes 00072394 No
TGAI A,B No No5
TGAI A,B Yes 00109471,00103564 No

TGAI A,B No No6

TGAI A,B Yes 00098481 No
TGAI A,B Yes 00071598 No

TGAI A,B Yes 00098481,00013209 No
TGAI A,B Yes 00103354,00150094 No
                61

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                                                        TABLE A
                                        GENERIC DATA REQUIREMENTS FOR METALAXYL
     Data Requirement
Composition^-  Pattern
        Does EPA Have                ^                      Time Period
        Data to Satisfy                Must Additional      After EPA
        This Require-                  Data Be Submitted    Notification
        ment?  (Yes, No  Bibliographic Under FIFRA Section  to Report
        or Partially)     Citation     3(c)(2)(B)?          Data3
§158.135 Toxicology (cent1d)

CHRONIC TESTING (cont'd):

83-3 - Teratogenicity
       2 Species:

       - Rat, and

       - Rabbit
      TGAI

      TGAI
83-4 - Reproduction - Rat         TGAI

MUTAGENICITY TESTING;

84-2 - Gene Mutation (Ames Test)  TGAI


84-2 - Structural Chromosomal     TGAI
         Aberration
A,B

A,B


A,B



A,B


A,B


A,B
Yes

Yes


Yes



Yes


Yes


Yes
84-2 - Other Mechanisms of        TGAI
         Mutagenicity

SPECIAL TESTING:

85-1 - General Metabolism    PAIR OR PAIRA  A,B       Partially
00161405,00144423       No

00161404,00144372       No
00144371

0071600                 No
                                        00084113,00154301,       No
                                        00154302,00103362

                                        00103361,0084114         No
                                       00154302,00154306,      No
                                       00154663,00103363
                                        00071613,00071614,      Yes?
                                        00098084
                                                            24 Months

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                                                         TABLE A
                                         GENERIC DATA REQUIREMENTS FOR METALAXYL
FOOTNOTES:
j/ Composition:  TGAI = Technical grade active ingredient; PAI = Pure active ingredient; PAIRA = Pure active ingredient,
   radiolabeled; Choice = Choice of several test substances determined on a case-by-case basis.
2/ The use patterns are coded as follows:  A = Terrestrial, Food Crop; B = Terrestrial, NonFoods,; C = Aquatic, Food Crop;
   D = Aquatic, Nonfood; E = Greenhouse, Food Crop; F = Greenhouse, Nonfood; G = Forestry; H = Domestic Outdoor; I =.
   Indoor; IP = Industrial Preservative.
V Data must be submitted within the indicated time frames which begin upon receipt of the Guidance Document.
4/ Metalaxyl is not an organophosphate or a metabolite or degradation product thereof, so a study is not required.
V The study is not required because the 21 day dermal study showed no significant toxicological effects.
6/ Since an acute neurotoxicity study is not required for this compound and there is no evidence of neurotoxicity in
   mammalian species, this study is not required.
7/ A repeated dose study of the absorption, distribution, and excretion and a study identifying metabolites in male
   rats is needed.
                                                             63

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               TABLE A
GENERIC DATA REQUIREMENTS FOR METALAXYL
Use2
Data Requirement Composition1 Pattern
§158.145 Wildlife and
Aquatic Organisms
AVIAN AND MAMMALIAN TESTING
71-1 - Acute Avian Oral TGAI A,B
Toxicity
71-2 - Avian Subacute Dietary
Toxicity
- Upland Game Bird, and TGAI A,B
- Waterfowl TGAI A,B
71-3 - Wild Mammal Toxicity TGAI A,B
71-4 - Avian Reproduction TGAI A,B
71-5 - Simulated and Actual
Field Testing
- Mammal TEP A,B
- Birds TEP A,B
Does EPA Have
Data to Satisfy Must Additional
This Require- Data Be Submitted
ment? (Yes, No Bibliographic Under FIFRA Section
or Partially) Citation 3(c)(2)(B)?



Yes 00077334 No



Yes 00077335 No
Yes 00063989 No
No No
No No4


No No
No No
Time Period
After EPA
Notification
to Report
Data3















                 64

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                                                  TABLE A
                                  GENERIC DATA REQUIREMENTS FOR METALAXYL
Data Requirement
                Use2
Composition!  Pattern
Does EPA Have
Data to Satisfy
This Require-
ment?  (Yes, No
or Partially)
              Must Additional
              Data Be Submitted
Bibliographic Under FIFRA Section
 Citation     3(c)(2)(B)?
Time Period
After EPA
Notification
to Report
Data3
S158.145 Wildlife and
Aquatic Organisms (cont'd)
AQUATIC ORGANISM TESTING
72-1 - Freshwater Fish Toxicity
- Coldwater Fish Species
(Trout) and
(2
- Warmwater Fish Species
(Bluegill)
(2
72-2 - Acute Toxicity to Fresh-
water Invertebrates
(2
72-3 - Acute LCso Estuarine and
Marine Organisms
- Fish
(2
- Oyster

TGAI
TEP
Ib/gal
TGAI
TEP
Ib/gal
TGAI
TEP
Ib/gal
i
|
TGAI
'TEP
Ib/gal
TGAI
TEP

A,B
A,B
EC)
A,B
A,B
EC)
A,B
A,B
EC)

A,B
A,B
EC)
A,B
A,B

Yes
Yes
Yes
Yes
Yes
Yes

No
No
No
NO

00071303,00100447 No
00072396 No
00071302,00100446 No
00071301 No
00100448,00071306 No
0071304 No

No5
No5
Yes6 12 Months
Yes? 12 Months
                          (2  Ib/gal EC)
                                                    65

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                                                       TABLE A
                                        GENERIC DATA  REQUIREMENTS FOR METALAXYL

S158
Use2
Data Requirement Compositionl Pattern
.145 Wildlife and
Does EPA Have
Data to Satisfy
This Require-
ment? (Yes, No
or Partially)

Must Additional
Data Be Submitted
Bibliographic Under FIFRA Section
Citation 3(c)(2)(B)?

Time Period
After EPA
Notification
to Report
Data3

Aquatic Organisms (cont'd)
AQUATIC ORGANISM TESTING (cont'd)
72-3
72-4
- Acute Toxicity to Estuarine
and Marine Organisms
- Shrimp TGAI A,B
TEP A,B
(2 Ib/gal EC)
- Fish Early Life Stage
- Freshwater TGAI A,B
- Estuarine TGAI A,B
- Aquatic Invertebrate
Life Cycle
- Freshwater TGAI A,B
- Estuarine TGAI A,B
No
No
Yes
No
Yes
No
Yes6
Yes?
00071308 No
No
00071307 No
ReservedS
12 Months
12 Months
72-5 - Fish Live Cycle

       - Freshwater  and
           Estuarine
TGAI
A,B
No
                                                      No
                                                         66

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                                                        TABLE A
                                        GENERIC DATA REQUIREMENTS FOR METALAXYL
                                                    Does EPA Have                                       Time Period
                                                    Data to Satisfy                Must Additional      After EPA
                                                    This Reouire-                  Data Be Submitted    Notification
                                            Use2    ment?  (Yes,  No  Bibliographic Under FIFRA Section  to Report
     Data Requirement       Compositionl  Pattern   or Partially)     Citation     3(c)(2)(B)?          Data3


S158.145 Wildlife and
Aquatic Organisms (cont'd)

AQUATIC ORGANISM TESTING (cont'd)

72-6 - Aquatic Organism           TGAI      A,B          Yes9                             No
         Accumulation


72-7 - Simulated or Actual Field
         Testing

       - Aquatic Organisms         TEP      A,B          No                               No
 I/ Composition:  TGAI = Technical grade of the active ingredient;  TEP = Typical end-use product.
 2/ The use patterns are coded as follows:   A = Terrestrial, Food Crop; B = Terrestrial, Nonfood Crop; C = Aquatic,
    Food Crop; D = Aquatic, Nonfood; E = Greenhouse, Food Crop; F = Greenhouse, Nonfood; G = Forestry; H = Domestic
    Outdoor; I = Indoor.
 V Data must be submitted within the indicated time frames which begin upon receipt of the Guidance Document.
 4/ Avian reproduction studies are not required due to the very low acute toxicity, no evidence of bioaccumulation,
    and the lack of persistence in field dissipation studies.
 J>/ Waived due to LC^QS on freshwater fish  {> 100 ppm).
 6/ Required to support citrus and; cotton uses.
 7/ Acute freshwater testing indicates this formulated product is more toxic to aquatic organisms than the
    technical grade.
 J3/ Reserved pending results of acute estuarine testing on the technical and formulated products.
 9/ Refer to Science EAB chapter which can  be obtained.   Please refer to page 1 of this document for instructions.

                                  !                                   i

                                                          67

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                                                        TABLE A
                                        GENERIC DATA REQUIREMENTS FOR METALAXYL
     Data Requirement
                Use2
Compositionl  Pattern
Does EPA Have
Data to Satisfy
This Require-
ment?  (Yes, No
or Partially)
              Must Additional
              Data Be Submitted
Bibliographic Under FIFRA Section
 Citation     3(c)(2)(B)?
Time Period
After EPA
Notification
to Report
Data3
§158.155 Nontarqet Insect

NONTARGET INSECT TESTING - POLLINATORS;

141-1 - Honey Bee Acute        TGAI
          Contact LD5Q

141-2 - Honey Bee - Toxicity    TEP
          of Residues on
          Foliage

141-4 - Honey Bee Subacute      TEP
          Feeding Study

141-5 - Field Testing for       TEP
          Pollinators

NONTARGET INSECT TESTING -
AQUATIC INSECTS;

142-1 - Acute Toxicity to   (Reserved)5
          Aquatic Insects

142-2 - Aquatic Insect Live (Reserved)5
          Cycle Study

142-3 - Simulated or Acutal (Reserved)5
          Field Testing for
          Aquatic Insects
                             Yes
                             No
                             No
                             No
                   40276701
                   No
                                    No*

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                                                        TABLE A
                                        GENERIC DATA REQUIREMENTS FOR METALAXYL
                                                    Does EPA Have                 _                      Time Period
                                                    Data to Satisfy               Must Additional       After EPA
                                                    This Require-                 Data Be Submitted    Notification
                                            Use2     ment?  (Yes,  No  Bibliographic Under FIFRA Section  to Report
     Data Requirement       Composition*   Pattern    or  Partially)     Citation     3(c)(2)(B)?          Data3


S158.155 Nontarget Insect (cont'd)

143-1 - NONTARGET INSECT     (Reserved)5
thru    TESTING - PREDATORS
143-3 - AND PARASITES
 I/ Composition:  TGAI = Technical grade  of  the active ingredient;  TEP = Typical  end-use product.
 2/ The use patterns are coded asjfollows:   A = Terrestrial,  Food Crop;  B = Terrestrial, Nonfood;  C = Aquatic,
    Food Crop; D = Aquatic, Nonfood;  E =  Greenhouse,  Food Crop;  F = Greenhouse, Nonfood; G = Forestry; H = Domestic
    Outdoor; I = Indoor.         ;
 3/ Data must be submitted within the indicated time  frames which begin upon receipt of the Guidance Document.
 4/ The results of the Honey Bee acute contact LDso study shows  that metalaxyl  is practically non-toxic to
    honey bees and further testing is not required.
 5/ Reserved pending Agency decision  as to whether the data requirement should be established.
                                                           69

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                                                       TABLE A
                                       GENERIC DATA REQUIREMENTS FOR METALAXYL
Data Requirement
Does EPA Have - Time Period
Data to Satisfy Must Additional After EPA
This Require- Data Be Submitted Notification
Use2 ment? (Yes, No Bibliographic Under FIFRA Section to Report
Compositionl Pattern or Partially) Citation 3(c)(2)(B)? Data3
§158.130 Environmental Fate
DEGRADATION STUDIES-LAB:
161-1 - Hydrolysis
Photodeqradat ion
161-2 - In Water
161-3 - On Soil
161-4 - In Air
METABOLISM STUDIES-LAB:
162-1 - Anerobic Soil
162-2 - Anaerobic Soil
162-3 - Anaerobic Aquatic
163-4 - Aerobic Aquatic
MOBILITY STUDIES:
TGAI or PAIRA A,B Yes 00104493 No

TGAI or PAIRA A,B NO Yes 9 Months
TGAI or PAIRA A Yes 00100456 No
TGAI or PAIRA N/A No No4
TGAI or PAIRA A,B Yes 00104494 No
TGAI or PAIRA A Yes 00104494 No
TGAI or PAIRA N/A NO No4
TGAI or PAIRA N/A NO NO4

163-1 - Leaching and
          Adsorption/
          Desorption
TGAI or PAIRA   A,B
Yes
00100464,00100465,
00100466
No
                                                       70

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                                             TABLE  A
                             GENERIC DATA REQUIREMENTS FOR METALAXYL
Data Requirement
§158.130 Environmental Fate
MOBILITY STUDIES (cont'd):
163-2 - Volatility (Lab)
164-3 - Volatility (Field)
DISSIPATION STUDIES-FIELD:
164-1 - Soil
164-2 - Aquatic (Sediment)
164-3 - Forestry
164-4 - Combination and
Tank Mixes
165-5 - Soil, Long-Term
ACCUMULATION STUDIES:
165-1 - Rotational Crops
(Confined)
165-2 - Rotational Crops
Composition^-
(cont'd)
TEP
TEP
TEP
TEP
TEP
TEP
1
!
| TEP
i
i
f>AIRA
TEP
Use2
Pattern
A
N/A
A,B
N/A
N/A
A

A
A
A
Does EPA Have
Data to Satisfy
This Require-
ment? (Yes, No
or Partially)
Yes
No
No
No
No
No

No
No
Partially
Time Period
Must Additional After EPA
Data Be Submitted Notification
Bibliographic Under FIFRA Section to Report
Citation 3(c)(2)(B)? Data3
00100455 No
No4
Yes 27 Months
No4
No4
No5

No6
Yes 39 Months
00104376,00104381, Reserved7
(Field)
00104382,00104383,
00104384,00104385
                                                 71

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                                                        TABLE A
                                        GENERIC DATA REQUIREMENTS FOR METALAXYL
     Data Requirement
                Use2
Composition!  Pattern
Does EPA Have
Data to Satisfy
This Require-
ment?  (Yes, No
or Partially)
               Must Additional
               Data Be Submitted
 Bibliographic Under FIFRA Section
  Citation     3{c)(2)(B)?
              Time Period
              After EPA
              Notification
              to Report
              Data3
S158.130 Environmental Fate (cont'd)

ACCUMULATION STUDIES (cont'd);

165-3 - Irrigated Crops          TEP

165-4 - In Fish             TGAI or PAIRA

165-5 - In Aquatic Nontarget     TEP
          Organisms
                 N/A

                 A,B

                 N/A
     NO

     Yes

     No
00100468,00100470
No
                                                           72

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                                                  TABLE A
                                  GENERIC DATA REQUIREMENTS FOR METALAXYL
Data Requirement
                Use2
Composition1  Pattern
                                              Does EPA Have
                                              Data to Satisfy
                                              This Require-
                                                       Must Additional
                                                       Data Be Submitted
                                              ment?   (Yes, No  Bibliographic Under FIFRA Section
                                                    or  Partially)
Citation
3(c)(2)(B)?
Ground Water Monitoring
  Studies
                                                   NO
Time Period
After EPA
Notification
to Report
Data3
§158.140 Reentry Protection
132-1 - Foliar Dissipation
132-1 - Soil Dissipation
133-3 - Dermal Exposure
133-4 - Inhalation Exposure
§158.142 Spray Drift
201-1 - Droplet Size Spectrum
202-1 - Drift Field Evaluation
Monitoring Studies

TEP
TEP
TEP
TEP

TEP
TEP


A,B
A,B
A,B
A,B

A,B
A,B


NO
NO
NO
NO

NO
NO


NO
NO
Conditional8
Conditional8

No9
NO*




27 Months
27 Months




                                                                              6  Months/
                                                                             24  Months

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                                                        TABLE A
                                        GENERIC DATA REQUIREMENTS FOR METALAXYL
FOOTNOTES:
 I/ Composition:  TGAI = Technical grade of the active ingredient;  PAIRA = Pure active ingredient, radiolabeled;
    TEP = Typical end-use product.
 2/ The use patterns are coded as follows:   A = Terrestrial, Food Crop;  B = Terrestrial, NonFood,; C = Aquatic, Food
    Crop; D = Aquatic, Nonfood; E = Greenhouse, Food Crop;  F = Greenhouse, Nonfood; G = Forestry; H = Domestic Outdoor;
    I = Indoor.
 V Data must be submitted within the indicated timeframes, which begin  upon receipt of the Guidance Document.
 4_/ Not required based on the use pattern of metalaxyl.
 V Tank mix data requirements are not being imposed by this Standard.
 6/ Soil long-term study is not required because of the dissipation rate of metalaxyl.
 7/ Data are reserved pending the results of the confined rotational crop study.
 8/ Human-exposure monitoring data may be submitted at the registrant's  option.  If dermal exposure data are submitted,
    inhalation exposure data must also be submitted.
 9/ Data are not required based on the moderate acute inhalation toxicity of metalaxyl.
IS/ A small-scale retrospective ground-water study is required.  The registrant must submit a protocol for Agency
    approval six months after receipt of the Guidance Document.  The timeframe for submission of the study will be
    24 months after Agency approval of the protocol.
                                                           74

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                                                      TABLE B
                    PRODUCT SPECIFIC DATA REQUIREMENTS FOR MANUFACTURING-USE PRODUCTS CONTAINING METALAXYL
     Data Requirement
Composition-'
  Use2
Pattern
Does EPA Have
Data to Satisfy
This Require-
ment?  (Yes, No Bibliographic
or Partially)     Citation
§158.120 Product Chemistry

Product Identity and Composition

61-1 - Product Identity          MP
         and Disclosure of
         Ingredients

61-2 - Description of Beginning  MP
         Materials and Manufac-
         turing Process

61-3 - Discussion of Formation   MP
         of Impurities

Analysis and Certification of
Product Ingredients

62-1 - Preliminary Analysis      MP
         of Product Samples

62-2 - Certification of          MP
         Ingredient Limits

62-3 - Analytical Methods        MP
         to Verify Certified
         Limits
                All
                All
                All
                All
                All
            Yes
            Partially
            Partially
            No
                 00104498  4
                 00104498  4
                All       Partially      00104498
                                         00104483
00104483
40435001
  Partially      00104498
               Must Additional
               Data Be Submitted
               Under FIFRA Section
               3(c)(2)(B)?
                    No
                    Yes5
                                               Yese
                                     Yes
                                               Yes
                                                                10
Time Period
After EPA
Notification
to Report
Data3
 6 Months
                                                      6 Months
12 Months


 6 Months


12 Months
                                                        75

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                                       TABLE B
PRODUCT SPECIFIC DATA REQUIREMENTS FOR MANUFACTURING-USE PRODUCTS CONTAINING METALAXYL
Use2
Data Requirement Composition1 Pattern
Does EPA Have Tine Period
Data to Satisfy __ Must Additional After EPA
This Require- Data Be Submitted Notification
ment? (Yes, No Bibliographic Under FIFRA Section to Report
or Partially) Citation 3(c)(2)(B)? Data3
§158. 120 Product Chemistry (continued)
Physical and Chemical Characteristics
63-2
63-3
63-4
63-5
63-6
63-7
63-8
63-9
63-10
63-11
63-12
63-13
- Color
- Physical State
- Odor
- Melting Point
- Boiling Point
- Density, Bulk Density,
or Specific Gravity
- Solubility
- Vapor Pressure
- Dissociation Constant
- Octanol/Water Partition
Coefficient
- pH
- Storage Stability
MP
MP
MP
MP
MP
MP
MP
MP
MP
MP
MP
MP
All
All
All
All
All
All
All
All
All
All
All
All
Yes
Yes
Yes
Yes
N/A11
Yes
Yes
Yes
Yes
Yes
Yes
Yes
00104483
00104483
00104483
00104483

00104483
00104483
00104483
00104483
40435001
40435001
00104483
No
No
No
No
No
No
No
No
No
No
No
No
                                      76

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                                                       TABLE  B
                PRODUCT SPECIFIC DATA REQUIREMENTS FOR MANUFACTURING-USE PRODUCTS CONTAINING METALAXYL
                                                   Does  EPA Have                '                      Time Period
                                                   Data  to  Satisfy                Must Additional      After EPA
                                                   This  Require-                  Data Be Submitted    Notification
                                            Use2    ment?  (Yes, No Bibliographic  Under  FIFRA Section  to Report
     Data Requirement       Composition*  Pattern   or Partially)     Citation     3(c)(2)(B)?          Data3
§158.120 Product Chemistry (continued)

Other Requirements;

64-1 - Submittal of Samples      MP         N/A          N/A            N/A12          No                N/A
                                                          77

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                                              FOOTNOTES FOR PREVIOUS TABLE B

 I/ The 90% technical is the only registered metalaxyl manufacturing-use product.   Composition:  TGAI = technical grade
    of the active ingredient; PAI = pure active ingredient.
 2/ The use patterns are coded as follows:   "A" for Terrestrial,  Food Crop; "B" for Terrestrial, Non-Foods,; "C" for
    Aquatic, Food Crop, "D" for Aquatic, Non-Food;  "E" for Greenhouse, Food Crop;  "F" for Greenhouse, Non-Food;
    "G" for Forestry; "H" for Domestic Outdoor; and "I" for Indoor.
 3/ Data must be submitted within the indicated time frames which begin upon receipt of the Guidance Document.
 4/ Information obtained from desk references.
 5/ Complete information must be provided regarding the nature of the process (batch or continuous), the relative
    amounts of beginning material and the order in  which they are added, the chemical equations for each intended
    reaction, equipment used to produce each intermediate and the final product, reaction conditions, the duration
    of each step of the process, purification procedures, and quality control measures.  In addition, the name and
    address of the manufacturer, producer,  or supplier of each beginning material  must be provided, along with in-
    formation regarding the properties of each beginning material used to manufacture each product.  In order to
    assess the potential for contamination with nitrosamines, a description of manufacturing process conditions
    favoring formation of nitrosamines must be provided.
 6/ A detailed discussion of all impurities that are or may be present at >^ 0.1%,  based on knowledge of the beginning
    materials, chemical reactions (intended and side) in the manufacturing process, and any contamination during and
    after production must be submitted.  This discussion must also address the possible formation of nitrosamines
    from metalaxyl and its impurities.
 7/ Five or more representative samples must be analyzed for the amount of active  ingredient and each impurity for
    which a certified limit is required.  Complete  validation data (accuracy, precision) must be submitted for each
    analytical method used.
 8/ Available data do not meet the requirements of  40 CFR 158.120, Part 62-2.
 9/ Upper and lower limits for metalaxyl must be provided, certified, and validated by sample analysis using
    analytical procedures for which accuracy and precision data have been provided.  Upper limits for each impurity
    present at >^ 0.1% (w/w), and for each "toxicologically significant" impurity present at < 0.1% (w/w) must be
    provided, certified, and validated by sample analysis using analytical procedures for which accuracy and
    precision data have been provided.  All nitrosamines must be identified and quantified in six samples of each
    product; two samples of each must be analyzed shortly after production, 3 months after production and 6 months
    after production.  A method sensitive to 1 ppm  of N-nitroso contaminants must  be used.  An upper limit must be
    provided (and certified) for all nitrosamines found.   Certifications should be submitted on EPA Form 8570
    (Rev. 2-85).
10/ Analytical methods must be provided to determine the active ingredient and each toxicologically significant
    impurity (including nitrosamines) for which a certified limit is required.  Each method must be accompanied
    by validation studies indicating its accuracy and precision.   These methods must be suitable for enforcement
    of certified limits.
ll/ Not reauired; a solid at room temperature.
12/ N/A = Not applicable.


                                                              78

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                                                       TABLE B
                 PRODUCT SPECIFIC DATA REQUIREMENTS FOR MANUFACTURING-USE PRODUCTS CONTAINING METALAXYL
Does EPA Have - Time Period
Data to Satisfy Must Additional After EPA
This Require- Data Be Submitted Notification
Use2 ment? (Yes, No Bibliographic Under FIFRA Section to Report
Data Requirement Compositionl Pattern or Partially) Citation 3(c)(2)(B)? Data3
§158.
ACUTE
81-1
81-2
81-3

81-4

81-5

81-6
135 Toxicology
TESTING:
- Acute Oral - Rat MP A,B No
- Acute Dermal MP A,B No
- Acute Inhalation
- Rat MP A,B No
- Primary Eye Irritation
- Rabbit MP A,B No
- Primary Dermal Irritation
- Rabbit MP A,B No
- Dermal Sensitization MP A,B No
Yes 6 Months
Yes 6 Months

Yes 6 Months

Yes 6 Months

Yes 6 Months
Yes 6 Months
         Guinea Pig
I/ Composition:   MP = Manufacturing-use product.
2/ The use patterns are coded as follows:   A  =  Terrestrial,  Food  Crop;  B = Terrestrial,  NonFood,  C = Aquatic,  Food
   Crop; D = Aquatic, Nonfood; E = Greenhouse,  Food  Crop;  F  = Greenhouse, Nonfood;  G = Forestry;  H = Domestic  Outdoor;
   I = Indoor.
3/ Data must be submitted within the indicated  time  frames which  begin  upon  receipt of the Guidance Document.

                                                             79

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    APPENDIX II




LABELING APPENDICES
               80

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                           SUMMARY-1

                         LABEL CONTENTS

      HO CPR 162.10 requires  that  certain specific labeling
 statements appear at  certain locations on the label.  This
 Is  referred to as format labeling.  Specific label items listed
 below are keyed to the  table at the end of this Appendix.

      Item 1.   PRODUCT NAME - The  name, brand or trademark is
 required to be located  on the front panel, preferably centered
 in  the upper part of  the panel.   The name of a product will
 not be accepted if it is false or misleading.

      Item 2.   COMPANY NAME AND ADDRESS - The name and address
 of  the registrant or  distributor  Is required on the label.
 The name and address  should  preferably be located at the
 bottom of the front panel or at the end of the label text.
   (
      Item 3.   NET CONTENTS - A net contents statement is
 required on all labels  or on the  container of the pesticide.
 The preferred location  is the  bottom of the front panel
 immediately above the company  name and address, or at the end
 of  the label  text.  The  net  contents must be expressed in the
 largest suitable  unit,  e.g.,  "1 pound 10 ounces" rather than
 "26 ounces."  In addition to  English units, net contents may
 be  expressed  in metric  units.  [40 CPR I62.10(d)]

      Item 4.   EPA REGISTRATION NUMBER - The registration
 number assigned to the  pesticide  product must appear on the
 label,  preceded by the  phrase  "EPA Registration No.," or "EPA
 Reg.  No."  The registration  number must be set in type of a
 size  and  style similar  to other print on that part of the
 labej.  on  which it appears and  must run parallel to it.  The
 registration  number and  the  required identifying phrase must
 not  appear  in such a  manner  as to suggest or imply recommendation
 or  endorsement of the product  by  the Agency.
 [40  CPR I62.10(e)]

     Item  5.   EPA  ESTABLISHMENT NUMBER - The EPA establishment
 number, preceded  by the  phrase "EPA Est.n is the final" estab-
 lishment  at which the product  was produced, and may appear
 In  any  suitable location on  the label or Immediate container.
 It must also  appear on  the wrapper or outside container of
 the  package if the EPA  establishment number on the Immediate
 container cannot  be clearly  read  through such wrapper or container.
 [40  CPR I62.10(f)]

     Item  6A.  INGREDIENTS  STATEMENT - An Ingredients statement
 Is  required on  the front  panel.  The Ingredients statement must
contain the name  and percentage by weight of each active ingredient
and  the total  percentage  by  weight.of all Inert ingredients.
The preferred  location is  immediately below the product name.
The  Ingredients statement must run parallel with, and be clearly
distinguished  from, other  text on the panel.  It must not be
placed  in the  body of other  text.  [40 CPR I62.10(g)3
                                    81

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                            SUMMARY-2

     Item 6B.  POUNDS PER GALLON STATEMENT - For liquid agricul-
 tural formulations, the pounds per gallon of active Ingredient
 must be indicated on the label.

     Item 7.  FRONT LABEL PRECAUTIONARY STATEMENTS - Front panel
 precautionary statements must be grouped together, preferably
 within a block outline.  The table below shows the minimum type
 size requirements for various size labels.

    Size of Label        Signal Word          "Keep Out of Reach
    on Front Panel       Minimum Type Size       of Children"
    in Square Inches     All Capitals          Minimum Type Size

    5 and under                6 point              6 point
    above 5 to 10             10 point           •  . 6 point
    above 10 to 15            12 point              8 point
    above 15 to 30            14 point             10 point
         30                   18 point             12 point
    Item 7A.  CHILD HAZARD WARNING STATEMENT - The statement
"Keep Out of Reach of Children" must be located on the front
panel above the signal word except where contact with children
during distribution or use is unlikely.  [40 CFR I62.10(h) (1) ( 11)]

    Item 7B.  SIGNAL WORD - The signal word (DANGER, WARNING,
or CAUTION) is required on the front panel immediately below
the child hazard warning statement.  [40 CFR 162.10 (h)(l)(i)]

    Item 7C.  SKULL & CROSSBONES AND WORD "POISON" - On products
assigned a toxicity Category I on the basis of oral, dermal,
or Inhalation toxicity, the word "Poison" shall appear on the
label in red on a background of distinctly contrasting color and
the skull and crossbones shall appear in immediate proximity to
the word POISON.  [40 CFR 162. 10(h) (1) (1) ]

    Item 7D.  STATEMENT OF PRACTICAL' TREATMENT - A statement
of practical treatment (first aid or other) shall appear on
the label of pesticide products in toxicity Categories I,
II, and III.  [40 CFR I62.10(h) (1) (ill)]

    Item 7E.  REFERRAL STATEMENT - The statement "See Side
(or uack) Panel for Additional Precautionary Statements" is
required on the front panel for all products, unless all
required precautionary statements appear on the front panel.
[40 CFR I62.10(h)(l)(iil)]

    Item 8.  SIDE/BACK PANEL PRECAUTIONARY LABELING - The
precautionary statements listed below must appear together
on the label under the heading "PRECAUTIONARY STATEMENTS."
The preferred location is at the top of the side or back
panel preceding the directions for use, and It Is preferred
that these statements be surrounded by a block outline.  Each
of the three hazard warning statements must be headed by the
appropriate hazard title.  [40 CFR I62.10(h)(2)].
                                       82

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                           SUMMARY-3

     Item 8A.   HAZARD TO  HUMANS  AND DOMESTIC  ANIMALS  - Where  a
 hazard exists  to  humans  or domestic animals, precautionary
 statements are required  Indicating the particular  hazard, the
 route(s) of exposure and the precautions to  be  taken to  avoid
 accident, injury  or damage.  [HO CPR I62.10(h)(2)(1)3

     Item 8B.   ENVIRONMENTAL HAZARD - Where a hazard  exists to
 non-target organisms excluding  humans and domestic animals,
 precautionary  statements are required stating the  nature of
 the hazard and the  appropriate  precautions to avoid  potential
 accident, injury, or damage.  [*40 CPR I62.10(h) (2) (ii)]

     Item 8C.   PHYSICAL OR CHEMICAL HAZARD -  PLAMMABILITY
 Precautionary  statements relating to flammability  of a product
 are required to appear on the label if it meets  the  criteria
 in the PHYS/CHEM  Labeling Appendix. The requirement  is
 based on the results of  the flashpoint determinations and
 flame extension tests required  to be submitted  for all products.
 These statements  are to  be located in the aide/back  panel
 precautionary  statements section, preceded by the  heading
 "Physical/Chemical  Hazards."  Note that no signal  word is
 used in conjunction with the flammability statements.

     Item 9A.   RESTRICTED USE CLASSIFICATION  - PIPRA  sec. 3(d)
 requires that  all pesticide formulations/uses be classified
 for either general  or restricted use.  Products  classified
 for restricted use  may be limited to use by  certified applicators
j>r persons under  their direct supervision (or may  be subject
 to other restrictions that may  be imposed by regulation).

     In the Registration  Standard, the Agency has (1) indicated
 certain formulations/uses are to be restricted  (Section  IV
 indicates why  the product has been classified for  restricted
 use);  or (2) reserved any classification deci'slon  until
 appropriate data  are submitted.

     The Regulatory  Position and Rationale states whether
 products containing this active ingredient are  classified
 for restricted use.   If  they are restricted  the  draft label(s)
 submitted to the  Agency  as part of your application  must
 reflect this determination (see below).

      If you do not  believe that your product should  be classified
 for restricted use,  you  must submit any Information  and
 rationale with your application for reregiatratlon.   During
 the Agency*s review of your application, your proposed classi-
 fication determination will be  evaluated In  accordance with
 the provisions of 40 CPR I62.11(e).  You will be notified  of
 the Agency's classification decision.
                                      83

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                          SUMMARY -4

     Classification Labeling Requirements

     If your product has been classified for restricted use,
the following label requirements apply:

     1.  All uses restricted.

         a.  The statement "Restricted Use Pesticide" must
     appear at the top of the front panel of the label.  The
     statement must be set in type of the same minimum size
     as required for human hazard signal word (see table in 40
     CFR
         b.  Directly below this statement on the front panel,
     a summary statement of the terms of .restriction must
   t  appear (including the reasons for restriction if specified
     in Section I).  If use is restricted to certified applicators,
     the following statement is required:  "For retail sale
     to and use only by Certified Applicators or persons
     under their direct supervision and only for those uses
     covered by the Certified Applicator's Certification."

     2.  Some but not all uses restricted.  If the Regulatory    '  .
Position and Rationale states that some uses are classified
for restricted use, and some are unclassified, several courses
of action are available:

          a.  You may label the product for Restricted use.
     If you do so, you may include on the label uses that
     are unrestricted, but you may not distinguish them
     or. the label as being unrestricted.

          b.  You may delete all restricted uses from your
     label and submit draft labeling bearing only unrestricted
     uses .

          c.  You may "split" your registration, i.e., register
     two separate products with Identical formulations, one
     bearing only unrestricted uses, and the other bearing
     restricted uses.  To do so, submit two applications for
     reregistratlon, each containing all forms and necessary
     labels.  Both applications should be submitted simul-
     taneously.  Note that the products will be assigned
     separate registration numbers.

    Item 9B.  MISUSE STATEMENT - All products must bear the
misuse statement, "It is a violation of Federal law to use
this product in a manner Inconsistent with its labeling."
This statement appears at the beginning of the directions
for use, directly beneath the heading of that section.
                                     84

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                           SUMMARY-5

     Item  10A.  REENTRY STATEMENT - If a reentry interval
 has  been  established  by  the Agency, it must be included on
 the  label.   Additional worker protection statements may be
 required  in  accordance with PR Notice 83-2, March 29, 1983.

     Item  10B.  STORAGE AND DISPOSAL BLOCK -  All labels are
 required  to  bear storage and disposal statements.  These
 statements are developed for specific containers, sizes, and
 chemical  content.  These instructions must be grouped and
 appear under the heading "Storage and Disposal" in the directions
 for use.  This heading must be set In the same type sizes as
 required  for the child hazard warning.  Refer to Appendix II,
 STOR, PEST/DIS, and CONT/DIS to determine the storage and
 disposal  instructions appropriate for your products.

    Item  IOC.  DIRECTIONS  FOR USE - Directions for use must
 be stated in terms which can be easily read and understood by
 the average  person likely  to use or to supervise the use of
 the pesticide.  When followed, directions must be adequate to
 protect the public from fraud and from personal injury and to
 prevent unreasonable adverse effects on the environment.
 [40 CFR 162.10]


                     COLLATERAL LABELING

    Bulletins, leaflets,  circulars, brochures, data sheets,
flyers,  or other written or graphic printed matter which is
referred To on the label  or which is to accompany the product
are termed collateral labeling.   Such labeling may not bear
claims or representations  that differ In substance from those
accepted in connection with registration of the product.  It
should be made part of the response to this notice and submitted
for review.
                                      85

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 PRECAUTIONARY ITATEMEMT8
   HAZARDS TO HUMANS
   d OOMEBTC ANMAtS)
       OANOCJI
  ENMRONMENTAl HAZARDS
  PHYSCAL Off CHtMCAL
     HAZARDS
   pntOTONt POR UM
Ik* ttoMM * H«rt tar
Ml n*u* k • Mmv
   M-fiMTNV STATEMENT
   STORAGE AND
   r DISPOSAL
 STOAAOf'
CHOP:
                              RESTRICTED USE
                                  PESTICIDE
                              (reason for clasnlfyinp.)
                               1HCIR OI«BCt «UPe«VUION MO OMLT K* TOOBE
                          oveno IT me comneo APPUCATCM>I cnmncATicw
                                                       CM
                              PRODUCT
                                   NAME
                           ACTMI NOMEOCNT:
                           MCKT NOREOCNT8:

                           TOTAL:
                                               10000%
                           TWO MOOUCT CONTAM8  LM Of  PW OAUON
                          KEEP OUT OF REACH OF CHILDREN
                             DANGER —POISON
                               STATEMENT OF PfUCTCAL TREATMENT
                        F8WAOOWEO:
                        f M EYE8
                        SEE SOE PANEL POM AOOmONAL PMCAUTDNANV STATEMENTS
                        MfOBY! -
                        TOWN. IT ATE
                        ISTABU8HMENT NO.
                                 NET r-QMt»MT«
                                                               C«OP:
                                                               CHOP:
                                                               CROP:
                                                                CMOP:
                                                                  WAMANTY STATEMENT
                                         n x

-------
                      I
                    !':
                  !>!i
                              • a

                              11!
                              I;
                                      A
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                                      *«

                                      5
                                         i
     SSSf
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                          mo

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                 SUMMARY-6
LABELING REQUIREMENTS OP THE PIFRA, AS AMENDED
ITEM
1
2
3
li
5
6A
6B
7
7A
7B
LABEL ELEMENT
Product name
Company name
and address
Net contents
EPA Reg. No.
EPA Eat. ta.
Ingredients
statement
Pounds/gallon
* statement
Front panel
precautionary
statements
Keep Out of Reach
of Children
(Child hazard
Naming)
Signal word
TROBmCltY'"
Of REQUIREMENT
products
products
All products
All products
All products
All products
Liquid products
where dosage
given as IDS.
al/unit area
All products
All products
All products
	 PLACEMENT 6N LABEL 	 1
REQUIRED
Front panel
None
None
None
None
Front panel
Front panel
Front panel
Front panel
Front panel
tTOFEHHEU
Center front
panel
Bottom front
panel or end
of label text
Bottom front
panel or end
of label text
Front panel
Front panel,
Immed lately
before or
following
Reg. No.
immediately
following
product name
Directly below
the main
Ingredients
statement

Above signal
word
Immediately
below child
hazard
warning
COMMENTS

If registrant is not the producer, mur.t
be qualified by "Packed for . . .,"
•'Distributed by. . .."etc.
May be in metric units in addition to
U.S. units
Must be in similar type size and run
parallel to other type.
May appear on the container Instead o.
the label.
Text must run parallel with other texi.
on the panel.

All front panel precautionary statement/I
must be grouped together, preferably
blocked. •
Note type size requirements.
Note type size requirements.
                      88

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SUMMARY-?
ITEM
••s
7C
TD
7E
b
HA
8B
LABEL ELEMENT
Skull & cross-
booea and word
POISON (In red)
Statement or
Practical
Treatment or
Plrat Aid
Referral
statement
V
Side/back panel
precautionary
statements
Hazards to
humans and
domestic
animals
Environmental
hazards
APPLICABILITY —
OP REQUIREMENT
products
which are Cat-
egory I based
on oral, der-
mal , or Inhala-
tion toxlclty
products
In Categories
I, II, and III
All products
where pre-
cautionary
labeling
appears on
other than
front panel.
All products
All products
In Categories
I, II, and III
All products
I 	 PLACEMENT ON LABEL 	 1
RETIRED
Front panel
Category I:
Front panel
unless refer-
ral statement
Is used.
Others;
Grouped with
side panel
precautionary
statements.
Front panel
None
None
None
FK&KERRED
Both In close
proximity to
signal word
Front panel
for all.
1

Tbp or side
of back panel
preceding
directions
for use
Same as above
Same as above
COMMENTS


*
Must be grouped under the headings In
8A, 8B, and 8C; preferably blocked.
Must be preceded by appropriate signal
word.
Environmental hazards Include bee
caution where applicable.
  89

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SUMMARY-8
ITEM
86
9A
9B
10A
10B
IdC
LABEL ELEMENT
Physical or
chemical
hazards
Restricted
block
Misuse
statement
Reentry
statement
Storage and
disposal block
s,
Directions
for use 	
APPLICABILITY
OP REQUIREMENT
All pressurized
products, others
with flash
points under
150°P
All restricted
products
All products
Fft Notice B3-2
or as determined
by the Agency
All products
All products
PLACEMENT ON LABEL
REQUIRED
None
Top center
of front
panel
Inmediately
following
heading of
directions
for use
In the
directions
for use
In the
directions
for use
None
FHEMSHHKL)
Same as above
Preferably
blocked

Immediately
after misuse
statement
Inmediately
before
specific
directions
for use or
at the end of
directions
for use
None
COMMENTS
Refer to Appendix II guide
PHYS/CHEM
Includes a statement of the terms of
restriction. The words "RESTOICTED U
PESTICIDE" must be same type size as
signal word.
Required statement is:
"It is a violation of Federal law
to use this product in a manner
inconsistent with its labeling."

Must be set apart and clearly distin-
guishable from from other directions
for use.
Refer to Appendix II guides STOR.
CONT/DIS, and PEST/DIS for further
information and required statements.
May be In metric as well as U.S. unit..
  90

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 fi 162.10  Labeling requirement*.
   (a)  General—<1)  Content*  of  the
 label Every  pesticide products «h*Mi
 bear a label  containing the informa-
 tion specified by the Act and the regu-
 lations in this Part. The contents of a
 label must show clearly  and promi-
 nently the following:
 .it) The name, brand, or trademark
 under which the product Is sold as pre-.
 scribed In paragraph (b) of this sec-
 tion;
  (U) The name and address  of the
 producer,  registrant,  or  person for
 whom produced as prescribed In para-
 graph (c) of this section:
  (111) The net contents as  prescribed
 in paragraph (d) of this section;
  (iv)   The   product   registration
number as prescribed in paragraph (e)
of this section:

-------
  Environmental Protection Agency
                             § 162.10
    (v)  The  producing  establishment
  number as prescribed in paragraph g statement
concerning  the composition  of  the
product;
  (11)  A false or nti«i*«ai»tŁ statement
concerning  the effectiveness of  the
product as a pesticide or device;
  (ill) A false or tn1«l**'*<"g statement
about the value of the  product for
purposes other than as a pesticide or
device;
  (iv) A false or "•<*i*«"«"y comparison
with other pesticide* or devices;
  (v)  Any «*-Vftrr~*t directly  or indi-
rectly implying that the pesticide or
device is r^oofnin^TKtf*^ or endorsed by
any agency of  the Federal Govern-
ment;
  (vi)  The name of a pesticide  which
contains two or more principal  active
                                                     92

-------
§ 162.10
                                                40 CFR Ch. I (7-1-35 Edition)
   ingredients if -the name suggests one
   or more  but not all such principal
   active ingredients  even though the
   names of  the other ingredients are
   stated elsewhere in the labeling;
    (vii) A 'true statement used in such a
   way as to give a false or misleading im-
   pression to the purchaser;
    (viii) Label disclaimers which negate
  or detract from labeling statements re-
  quired under the Act and these regula-
  tions;
    (ix) Claims as to  the safety of the
  pesticide  or its ingredients, including
  statements such as "safe," "nonpoison-
  ous," "noninjurious," "harmless" or
  "nontoxic  to_Jiumans and pets"  with
  or without such a qualifying phrase as
  "when used as directed"; and
   (x) Non-numerical and/or compara-
  tive statements on the safety  of the
  product, including but not limited to:
   (A)  "Contains  all  natural Ingredi-
  ents":
   (B) "Among the least toxic chemi-
  cals known"
   (C) "Pollution approved"
   (6) Final printed labeling, (i) Except
  as provided in paragraph (aX6)(ii) of
  this  section,  final  printed  labeling
 must be submitted and accepted prior
 to registration. However, final printed
 labeling need not  be  submitted until
 draft label texts have been provision-
 ally accepted by the Agency.
   (II)  Clearly legible  reproductions or
 photo reductions will  be accepted for
 unusual labels such  as  those silk-
 screened directly onto glass or metal
 containers or large bag or drum labels.
 Such reproductions must be of micro-
 film reproduction quality.
   (b) A'arn*,  brand, or trademark. (1)
 The name, brand, or trademark under
 which  the  pesticide  product la sold
 shall appear on the front panel of the
 label
  (2) No name, brand, or trademark
 may appear on the label which:
  (1) Is false or miilfailfnc. or
  (11) Has not been approved by  the
 Administrator through registration or
 supplemental registration at an addi-
 tional name pursuant to f 16X6(bX4).
  (c) Name and address of producer.
 registrant,  or penon for whom pro-
 duced. An  unqualified "«*TH* myj  ad-
dress given on the  label shall be con-
sidered as the name and address of  the
                                     producer. If the registrant's name ap-
                                     pears on the label and the registrant is
                                     not the producer, or if the name of the
                                     person  for whom  the  pesticide was
                                     produced appears on the label, it must
                                     be qualified by appropriate wording
                                     such as "Packed for ' •  V "Distribut-
                                     ed by •  • V or "Sold by • • •" to show
                                     that the name is not that of the pro-
                                     ducer.
                                      (d) Net leeight or measure of con-
                                     tents. (1) The net weight or measure
                                     of content  shall  be exclusive of  wrap-
                                     pers or other materials and shall be
                                     the  average content unless explicitly
                                     stated as a mtnimutn quantity.
                                      <2)  If the pesticide Is a liquid, the
                                     net  content statement shall  be in
                                     terms of liquid measure at 68* P <20*C>,
                                    and shall be expressed in conventional
                                    American units of fluid ounces, pints.
                                    quarts, and gallons.
                                      (3) If  the  pesticide is solid or  semi-
                                    solid, viscous or pressurized, or is a
                                    mixture of liquid and  solid, the net
                                    content statement shall be in terms of
                                    weight  expressed   as   avoirdupois
                                    pounds and ounces.
                                      (4) In  all cases, net content shall be
                                    stated in terms of the largest suitable
                                    units. Le., "1 pound  10 ounces" rather
                                    than "26 ounces."
                                      (5) In addition to the required units
                                    specified, net content   may be ex-
                                    pressed in metric units.,
                                     (6) Variation above minimum  con-
                                   tent or around an average is permissi-
                                   ble only to the extent that it repre-
                                   sents deviation unavoidable in good
                                   manufacturing   practice.   Variation
                                   below a stated minimum is not permit-
                                   ted. In no case shall., the average con-
                                   tent of the packages in a «hipm*>*it fall
                                   below the stated average content.
                                     (e)   Product  registration  number.
                                   The registration  number ««««g™** to
                                   the pesttdde product at the time of
                                   registration  «H«J|  appear on ttw IV**?.
                                   preceded by the  phrase "EPA Regis-
                                   tration No.," or the phrase "EPA Reg,
                                   No." The registration «m»*^n' thfiM be
                                   set in type of a ate *rvi style •fa*» to
                                   other print  on that put of the label
                                   on which It appears and shall run par-
                                   allel to It.  The  registration number
                                   and the  required identifying phrase
                                   shall not appear in such a manner as
                                   to suggest or imply recommendation
                                                93

-------
   Environmental Protection Agency
                             § 162.10
  or endorsement of the product by the
  Agency.
    (f)  Producing establishments regis-
  tration number. The producing estab-
  lishment registration  number preced-
  ed by the .phrase "EPA Est.". of the
  final establishment at which the prod-
  uct was produced may appear in any
  suitable location on the label or imme-
  diate container. It must appear on the
  wrapper or  outside container of  the
  package if the EPA establishment reg-
  istration  number  on  the  immediate
  container  cannot  be clearly  read
  through such wrapper or container.
   (g) Ingredient statement— <1) Gener-
  aL The label of each pesticide product
  must bear a statement which contains
  the name and percentage by weight of
  each active Ingredient, the  total per-
  centage by weight of all Inert ingredi-
  ents: and  if the pesticide contains ar-
  senic In any  form, a statement of the
  percentages of total and water-soluble
  arsenic calculated  as  elemental   ar-
 senic. The active Ingredients must be
 designated by the term  "active Ingredi-
 ents" and  the inert Ingredients by the
 term "inert Ingredients." or the singu-
 lar forms of these  terms when appro-
 priate.  Both  terms shall be  In  the
 same type size, be aligned to the same
 margin and be equally prominent. The
 statement  "Inert Ingredients, none" is
 not required for  pesticides which con-
 tain  100 percent  active ingredients.
 Unless  the ingredient statement is a
 complete analysis of the pesticide, the
 term "analysis" shall not be used as a
 heading for the ingredient statement.
  (2) Position of ingredient statement
 (i)  The ingredient statement Is nor*
 mally required on the front panel of
 the label. If there  is an outride con-
 tainer or wrapper through which the
 ingredient statement cannot be dearly
read, the ingredient ff*fltfrnCTft
also appear on such outside ~*
or wrapper. If the ste or form of the
package makes  it  impracticahle to
place the ingredient fftntfrnifot on the
front panel of the  label,  permission
may  be granted  for  the  ingredient
statement to appear elsewhere,
  (11) The text of the ingredient state-
ment must run  parallel with other
text on the panel oh which it appears,
and  must  be clearly  distinguishable
  from and  must not be placed in the
  body of other text.
   (3) Names to  be  used in ingredient
  statement. The name used for each in-
  gredient   shall  be  the   accepted
  common name,  if  there  is  one.  fol-
  lowed by  the  chemical  name.  The
  common name may be used alone only
  if it is well known. If no common name
  has been  established,  the  chemical
  name alone shall be used.  In no case
  will the use of-a trademark or proprie-
  tary name be permitted unless such
 name has been accepted as a common
 name by the Administrator under the
 authority of Section 25
-------
   § 162.10

    (h)  Warnings  and precautionary
   statements.  Required  warnings  and
   precautionary statements concerning
   the  general  areas  of  toxicological
   hazard  Including hazard to children.
   environmental hazard.'and physical or
  chemical hazard fall Into two groups;
  those required on the front panel of
  the  labeling and  those  which  may
  appear  elsewhere.  Specific require-
  ments concerning content, placement.
          40 CFR Ch. I (7-1-85 Edition)

  type size,  and prominence are given
  below.
   (1) Required front panel statements.
  With  the  exception  of  the  child
  hazard warning statement, the text re- ,
  quired on the front panel of the label
  is determined by the Toxicity Categor
  ry of the pesticide. The category is as-
  signed on  the basis of the  highest
  hazard shown by any of the indicators
  in the table below:

H&zard jnrirrtnm



\




\
lfc» Bfl «WVf SWfcMfrM 5O
me/kg.
IMTto MV< kviutai 3
mg/ste.
1 w fc. ^*4 htr^jnij 4rm
»"»*» 	
GOtTMAM! CORMHV
 TT ahaH besur on ^fr*
 front panel the alfnal word "Warn-
 ing."
  (C) TbzieUy Cattoory OL AH pe*O-
 cide prodncti  maednc *t» criteria of
 Toxldty Category HZ atufl bear on
 the front panel the sicnal word •Cau-
 tion,'*
   Toxictt* Category 17. AH peKt-
dde products  nvrttrn the criteria of
Toxlctty Catecory 17 shall bear on the
front panel the a1«nal word -Caatton,-
  (E) Cfce o/ ti&uU vords, Use of any
signal woroXs) associated with a higher
Toxicity Category to  not permitted
except when the  Agency determines
 vent unreasonable  adverse effects on
 man or the environment. In no case
 shall more than one human  hazard
 signal word appear on the front panel
 of a label.
  (U) Child hazard warning. Every pes-
 ticide product label shall bear on the
 front panel the statement "keep out of
 reach of  children."   Only   in  cases
 where the likelihood of contact  with
 children during distribution. market-
 Ing. storage or use is demonstrated by
 the applicant to be extremely remote.
 or if the natters of the pesticide is such
 that it is approved  for-use on infants
 or *™*+fi ***'flT1, *T**r fch* Administra-
 tor waive this reqiiirement.
  (ill) Statement of  practical treat*
           Toxicity  Category  L  A
          of practical treatment OQnt
aid or other) shall appear on the front
panel of the label of afl pesticides fan-
ing Into Toxicity Category I on the
baste of oral, tnhtlsftnn or dermal tox-
ktty.  Tne  Agency  mar,  "howerer«
permit  rfamniMa  rmriations in the
cal treatment to tome icfqqice
as "See statement of practical treat-
ment on back panel'* appears on  the
                                                95

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  Environmental Protection Agency
                                                         § 162.10
  front panel near the  word "Poison"
  and the skull and crossbones.
    (B) Other toxicity  categories. The
  statement of practical treatment is not
  required on the front panel except as
  described in paragraph 
-------
   § 162.10
                                                   40 CFR Ch. I  (7-1-35 Edition)
   stances under which they are required
   follow:
    (A)  If a pesticide intended for out-
   door use contains an active ingredient
   with a mammalian acute oral LD« of
   100 or less, the statement "This Pesti-
   cide is Toxic to Wildlife" is required.
    
-------
   Environmental Protection Ag«ncy

   for use only by manufacturers of prod-
   ucts other than pesticide products in
   their regular manufacturing processes.
   provided that:
    U) The label clearly shows that  the
  product  Is intended for use only in
  manufacturing processes and specifies
  the type**Mng of pesti-
 cide products  which are intended for
 use only by fonnulators in preparing
 pesticides for  sale to the public, pro-
 vided that:
  (J)  There  is information  readily
 available to the formulators on the
 composition, toxictty. *n*ttnH> of use,
applicable  restrictions or
and  effectiveness of  the product for
pesttdde purposes;
  (2) The label dearly states that the
product  is  intended  for use  only in
manufacturinc*  formulating;
or repacking for use as a pesticide and
specifies the type(s) of pesticide prod-
ucts involved:
  (J) The product as finally manufac-
tured.  formulated,  y*M"*gd, or repack-
aged is registered: and
                             § 162.10

       The Administrator  determines
  that such directions are not necessary
  to  prevent  unreasonable adverse  ef-
  fects on man or the environment.
   (2) Contents of Directions for Use.
  The directions for use shall include
  the following,  under the headings "Di-
  rections for Use":
   (i) The statement of use classifica-
  tion as prescribed in 162.KKJ) immedi-
  ately under the  heading "Directions
  for Use,"
   (ii) Immediately  below the  state-
 ment of  use classification, the state-
 ment "It Is a violation of Federal law
 to use this product in a manner incon-
 sistent with its labeling/1   •.
   (ill) The site
-------
    (E)  For restricted use pesticides,  a
  statement that the  pesticide may be
  applied under the direct supervision of
  a certified applicator who is not phys-
  ically present at the site of application
  but   nonetheless  available  to  the
  person applying the pesticide,  unless
  the Agency  has determined that the
  pesticide  may only be applied  under
  the direct supervision of a certified ap-
  plicator who is physically present.
   (F)   Other pertinent  information
  which  the Administrator determines
  to  be necessary for the protection of
  man and the environment.
   (j)  Statement  of  Use  Classification.
  By October 22. 1976. all pesticide prod-
  ucts must bear on their labels a state-
  ment of use classification as described
  in paragraphs (J) (1) and (2) of this
  section. Any pesticide 'product  for
  which some uses are classified for gen-
  eral use and  others for restricted  use
  shall be separately labeled  according
  to the labeling standards set forth in
  this subsection, and shall be marketed
  as separate   products. with  differen-
  registration numbers, one bearing di-
  rections only for general use
-------
                           PHYS/CHEM-1

                    PHYSICAL/CHEMICAL HAZARDS
Criteria
I.  Pressurized Containers
    A.
Flashpoint at or below
20°P; or if there is a
flashback at any valve
opening.
    B.
Flashpoint above 20°F
and not over 80°F; or
if the flame extension
is more than 18 inches
long at a distance of
6 inches from the
valve opening.

All Other Pressurized
Containers
II.   Non-Pressurized Containers

    A.   Flashpoint at or below
        20°F.
    B.   Flashpoint above 20°F
        and not over 80°F.

    C.   Flashpoint over 80°F
        and not over 150°F.

    D.   Flashpoint above
        150°F.
                              Required Label Statement
Extremely flammable.
Contents under pressure.
Keep away from fire, sparks,
and heated surfaces.  Do not
puncture or incinerate
container.  Exposure to
temperatures above 130°F
may cause bursting.

Flammable. 'Contents under
pressure.  Keep away from
heat, sparks, and flame.  Do
not puncture or incinerate
container.  Exposure to
temperatures above 130°F
may cause bursting.

Contents under pressure.
Do not use or store near
heat or open flame.  Do not
puncture or incinerate
container.  Exposure to
temperatures above 130°F
may cause bursting.
                              Extreme-ly flammable.  Keep
                              away from fire, sparks, and
                              heated surfaces.

                              Flammable.  Keep away from
                              heat and open flame.

                              Do not use or store near
                              heat and open flame.

                              None required.
                                     too

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                             STOR-1

              STORAGE  INSTRUCTIONS FOR PESTICIDES

 Heading:

 All  products  are  required  to bear specific label instructions
 about  storage and disposal.  Storage and disposal instructions
 must be grouped together in  the directions for use portion of
 the  label  under the heading  STORAGE AND DISPOSAL.  Products
 intended solely for domestic use need not include the heading
 "STORAGE AND  DISPOSAL."

 Storage Instructions;

 All  product labels are required to have appropriate storage
 instructions.  Specific storage instructions are not prescribed.
 Each registrant must develop his own storage instructions,
 considering,  when applicable, the following factors:

 1.   Conditions of storage  that might alter the composition or
     usefulness of the pesticide.  Examples could be temperature
     extremes, excessive moisture or humidity, heat, sunlight,
     friction, or  contaminating substances or media.

 2.   Physical  requirements  of storage.which might adversely      '  _
     affect the container of the product and Its ability to
     continue  to function properly.  Requirements might include
     positioning of the container in storage, storage or damage
     due to stacking, penetration of moisture, and ability to
     withstand shock or friction.

 3.   Specifications for handling the pesticide container,
     Including movement of  container within the storage area,
     proper opening and closing procedures (particularly for
     opened containers), and measures to minimize exposure
    while opening or closing container.

 K.   Instructions  on what to do if the container Is damaged in
    any way, or If the pesticide is leaking or has been
    spilled, and  precautions to minimize exposure If damage occurs

5.  General precautions concerning locked storage, storage In
    original container only, and separation of pesticides
    during storage to prevent cross-contamination of other
    pesticides, fertilizer, food, and feed.

6.  General storage instructions for household products should
    emphasize storage In original container and placement In
    locked storage areas.
                                  101

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                                 PEST/DIS-1

              PESTICIDE DISPOSAL  INSTRUCTIONS

 The label  of all  products, except those Intended solely for domestic
 use, must  bear explicit instructions about pesticide disposal.  The
 statements listed below contain  the exact wording that must appear on
 the label  of these products:

 1.   The labels of all products,  except domestic use, must contain the
 statement,  "Do not contaminate water, food, or feed by storage or disposal.

 2.   Except  those  products Intended solely for domestic use, the labels
 of  all products that contain active Ingredients that are Acute Hazardous
 Wastes or are assigned to Toxicity Category I on the basis of oral or
 dermal toxicity,  or Toxicity Category I or n on the basis of acute
 inhalation  toxicity must bear the following pesticide disposal statement:

   *  "Pesticide wastes are acutely hazardous.  Improper disposal of
     excess  pesticide, spray mixture, or rlnsate is a violation of Federal
     Law.  If these wastes cannot be disposed of by use according to
     label instructions, contact your State Pesticide or Environmental
     Control  Agency, or the Hazardous Waste representative at the nearest
     EPA Regional  Office for guidance."

 3.   Tiie labels  of all products, except those intended for domestic use,
 containing active or inert ingredients that are Toxic Hazardous Wastes
 or meet any  of  the criteria in 40 CPR 261, Subpart C for a hazardous
waste must bear the following pesticide disposal statement:.

     "Pesticide  wastes are toxic.  Improper disposal of excess pesticide,
     spray mixture, or rlnsate is a violation of Federal Law.  If these
    wastes cannot be disposed of by use according to label Instructions,
     contact your State Pesticide or Environmental Control Agency, or the
     Hazardous Waste representative at the nearest EPA-.Regional Office
    for guidance."

 1».  Labels for  all other products, except those Intended for domestic
use, must bear  the following pesticide disposal statement:

     "Wastes resulting from the use of this product may be disposed of on
     site or at  an approved waste disposal facility."

5.  Products Intended for domestic use only must bear the following
disposal statement:  "Securely wrap original container In several layers
of newspaper and discard In trash."
                                      102

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                          CONT/DIS-1

               CONTAINER DISPOSAL INSTRUCTIONS

    The label of each product must bear container  disposal
instructions appropriate to the type of container.

    1.  Domestic use products must bear one  of  the following
container disposal statements:
Container Type
Statement
Non-aerosol products
(bottles, cans, Jars)
Non-aerosol products
(bans)
Aerosol products
Do not reuse container (bottle, can, Jar).
Rinse thoroughly before discarding in trash.
Do not reuse bag. Discard bag in trash.
Replace cap and discard containers in
trash. Do not incinerate or puncture.
  i  2.  All other products must bear container disposal  instructions,
based on container type,  listed below:
 Container Type
 Statement
Metal
containers
(non-aerosol)
Plastic containers
Glass containers
Fiber drums
with liners
Paper and
plastic bags
Compressed gas
cylinders
Triple rinse (or equivalent). Then offer
for recycling or reconditioning, or puncture
and dispose of in a sanitary landfill, or i>y
other procedures approved by state and local
authorities.
Triple rinse (or equivalent). Then offer
for .recycling or reconditioning, or puncture
and dispose of in a sanitary landfill, or
incineration, or, If allowed by state and
local authorities, by burning. If burned,
stay out of smoke.
Triple rinse (or equivalent). Then dispose
of in a sanitary landfill or by other
approved state and local procedures.
Completely empty liner by shaking and
tapping aides and bottom to loosen clinging
particles. Empty residue into application
equipment. Then dispose of liner in a
sanitary landfill or by incineration if
allowed by state and local authorities.
If drum Is contaminated and cannot be
reused1, dispose of In the same manner.
Completely empty bag into application
equipment. Then dispose of empty bag in
a sanitary landfill or by incineration,
or, if allowed by State and local
authorities, by burning. If burned, stay
out of smoke.
Return empty cylinder for reuse (or
similar wording)
    Manufacturer may  replace  this  phrase with one  Indicating
    whether and how fiber  drum  may be  reused.
                                   103

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      APPENDIX III




BIBLIOGRAPHIC APPENDICES
              104

-------
                        BIBGUIDE-1

          GUIDE TO USE OF THIS BIBLIOGRAPHY
 CONTENT OF BIBLIOGRAPHY.  This bibliography contains
 citations of all studies  considered relevant by EPA in
 arriving at the positions and conclusions stated elsewhere
 in  the Standard.  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, will be  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
 uripublished 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 attempted also 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 at any time 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 a further explana-
 tion.  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 identifier 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
standards of the American National Standards Institute
 (ANSI),  expanded to provide for certain special needs.
                                  105

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                        BIBGUIDE-2

a.  Author.  Whenever the Agency could confidently identify
    one, 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 author.  As a last resort, the Agency has shown
    the first submitter as author.

b.  Document Date.  When the date appears as four digits
    with no question marks, the Agency took it directly
    from the document.  When a four-digit date is followed
    by a question mark,  the bibliographer deduced the
    date from evidence in the document.  When the date
    appears as (19??), the Agency was unable to determine
    or estimate the date of the document.
  t
c.  Title.   In some cases,  it has been necessary for
    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 fol-
    lowing 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,
         following the phrase "submitted by."  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,"  standing 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.
         For example,  within accession number 123456, the
         first study would be 123456-A; the second, 123456-
         B;  the 26th,  123456-Z; and the 27th, 123456-AA.
                                 106

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          BIBLIOGRAPHY OF STUDIES CONSIDERED IN SUPPORT
                OF REGISTRATION UNDER THE STANDARD

       Registration Standards Case Number 0081:  Metalaxyl
All studies in this bibliography are usable only with the
permission of their submitter under the provisions of FIFRA
§3(c)(1)(D)(i),  for the ten-year period beginning with the date
of the first product registration under this standard.

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                       OFFICE OF PESTICIDE PROGRAMS
                    REGISTRATION STANDARD BIBLIOGRAPHY
       Citations Considered to be Part of the Data Base Supporting
                Registrations Under the Metalaxyl Standard
   MRID           CITATION

00063989 Fink,  R.; Beavers,  J.B.; Brown,  R.  (1977)  Final Report: Eight-Day
            Dietary LC50—Mallard Duck:  Project No.  108-148.   (Unpublished
            study received Jul 13, 1978  under 100-EX-62; prepared by Wild-
            life International,  Ltd.  and Washington College,  submitted by
            Ciba-Geigy Corp.,  Greensboro, N.C.; CDL:234439-H)

00063990 Sachsse,  K. ;  Bathe, R.  (1976) Acute Oral LD50 in the Rat of Tech-
            nical  CGA  48988: Project No.  Siss 5388.   (Unpublished study re-
            ceived Jul 13, 1978  under 100-EX-62; prepared by Ciba-Geigy,
            Ltd.,  Switzerland, submitted by Ciba-Geigy Corp., Greensboro,
            N.C.;  CDL:234439-1)

00063991 Sachsse,  K.;  Bathe, R.  (1976) Acute Oral LD50 in the Mouse of
            Technical  CGA 48988: Project No. Siss 5388.  (Unpublished study
            received Jul 13, 1978 under 100-EX-62;  prepared by Ciba-Geigy,
            Ltd.,  Switzerland, submitted by Ciba-Geigy Corp., Greensboro,
            N.C.;  CDL-.234439-J)

00063993 Sachsse,  K.;  Ullmann, L. (1978)  Acute Dermal LD50 in the Rabbit
            of Technical CGA 48988: Project No. 408378—Siss 6547.  (Unpub- '
            lished study received Jul 13, 1978 under 100-EX-62; prepared by
            Ciba-Geigy, Ltd.,  Switzerland, submitted by Ciba-Geigy Corp.,
            Greensboro, N.C.; CDL:234439-L)

00063994 Sachsse,  K.;  Bathe, R.  (1976) Acute Dermal LD50 in the Rat of
            Technical  CGA 48988: Project No. Siss 5388.  (Unpublished study
            received Jul 13, 1978 under 100-EX-62;  prepared by Ciba-Geigy,
            Ltd.,  Switzerland, submitted by Ciba-Geigy Corp., Greensboro,
            N.C.; CDL:234439-M)

00071301 U.S. Environmental Protection Agency,  Animal Biology Laboratory
            (1979) Ridomil 2%: Bluegill (Lepomis macrochirus): Test #
            2411.   (Unpublished study; CDL:244183-B)

00071302 U.S. Environmental Protection Agency,  Terrestrial & Aquatic Biology
            Laboratory (1979) Ridomil Tech: Bluegill (Lepomis macro-
            chirus): Test ft 2413.  (Unpublished study; CDL:244183-E)

00071303 U.S. Environmental Protection Agency, Terrestrial & Aquatic Biology
            Laboratory (1979) Ridomil Tech: Rainbow Trout (Salmo gaird-
            neri): Test # 2414.    (Unpublished study; CDL:244183-F)

00071304 U.S. Environmental Protection Agency, Terrestrial & Aquatic Biology
            Laboratory (1979) Ridomil 2%: Daphnia magna: Test # 2416.
            (Unpublished study; CDL:244183-G)

00071306 U.S. Environmental Protection Agency, Terrestrial & Aquatic Biology
            Laboratory (1979) Ridomil Tech: Daphnia magna: Test #  2415.
            (Unpublished study; CDL:244183-1)
                                     1D8

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                       OFFICE OF PESTICIDE PROGRAMS
                    REGISTRATION STANDARD BIBLIOGRAPHY
       Citations Considered to be Part of the Data Base Supporting
                Registrations Under the Metalaxyl Standard
   MRID           CITATION

00071307 LeBlanc, G.A.; Mastone, J.; Altshul, L.; et al. (1980) The Chronic
            Toxicity of CGA-48988 to the Water Flea (Daphnia magna): Re-
            port | BW-80-5-668.  (Unpublished study received Jan 23, 1981
            under 100-607; prepared by EG & G, Bionomics, submitted by Ciba-
            Geigy Corp., Greensboro, N.C.; CDL:244183-J; 244782)

00071308 LeBlanc, G.A.; Mastone, J.; Wilson, B.F.; et al. (1980) The Toxic-
            ity of CGA-48988 to Fathead Minnow (Pimephales promelas)
            Eggs and Fry: Report f BW-80-4-642.  (Unpublished study received
            Jan 23, 1981 under 100-607; prepared by EG & G,  Bionomics,  sub-
            mitted by Ciba-Geigy Corp., Greensboro, N.C.; CDL:244183-K;
            244782)
  (
00071598 Beck, L.S. ; DeWard, J.; Kitchen, D.N.; et al. (1981) Six Month
            Chronic Oral Toxicity Study with CGA-48988 Technical in Beagle
            Dogs: Project No. 1545.  (Unpublished study received Apr 15,
            1981 under 100-607; prepared by Elars Bioresearch Laboratories,
            Inc., submitted by Ciba-Geigy Corp., Greensboro, N.C.; CDL:
            070016-A)

00071600 Cozens, D.D.; Allen, P.A.; Clark, R.; et al.  (1980) Effect of CGA
            48-988 on Reproductive Function of Multiple Generations in the
            Rat: CBG 181/80254.  (Unpublished study received Apr 15, 1981
            under 100-607; prepared by Huntingdon Research Centre, England,
            submitted by Ciba-Geigy Corp., Greensboro, N.C.; CDL:070015-A)

00071603 Honeycutt, R.C.; Fischer,  W.C.; Madrid, S.; et al.  (1980) Uptake,
            Balance and Metabolism of Phenyl-14C-CGA-48988 in Field
            Grown Potatoes: M11-69-14P, 14S; Report No. ABR-80042.  (Unpub-
            lished study received Apr 15, 1981 under 100-607; submitted by
            Ciba-Geigy Corp., Greensboro, N.C.; CDL:070018-C)

00071604 Honeycutt, R.C.; Cassidy,  J.E. (1980) Translocation of Phenyl-
            14C-CGA-48988 and Metabolites from Leaves into Potato Tubers:
            M11-69-12P,  12S; Report No. ABR-80048.   (Unpublished study re-
            ceived Apr 15, 1981 under 100-607; submitted by Ciba-Geigy
            Corp., Greensboro,  N.C.; CDL:070018-D)

00071605 Gross,  D. (1977) Metabolism of CGA 48 988 in Field Grown Potato
            Plants: Project Report 30/77.  (Unpublished study received Apr
            15,  1981 under 100-607; prepared by Ciba-Geigy Ltd., Switzer-
            land, submitted by Ciba-Geigy Corp., Greensboro,  N.C.;
            CDL:070018-F)

00071606 Gross,  D. (1978) Metabolism of CGA 48 988 in Grapevine: Project Re-
            port 11/78.   (Unpublished study received Apr 15,  1981 under 100-
            607; prepared by Ciba-Geigy Ltd., Switzerland,  submitted by
            Ciba-Geigy Corp., Greensboro, N.C.; CDL:070018-F)
                                     109

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                       OFFICE OF PESTICIDE PROGRAMS
                    REGISTRATION STANDARD BIBLIOGRAPHY
       Citations Considered to be Part of the Data Base Supporting
                Registrations Under the Metalaxyl Standard
   MRID           CITATION

00071607 Gross,  D. (1979)  Identification of Metabolites of CGA 48 988 (Ri-
            domil in Grapevine:  Project Report 06/79.   (Unpublished
            study received Apr 15,  1981 under 100-607;  prepared by Ciba-
            Geigy Ltd.,  Switzerland,  submitted by Ciba-Geigy Corp., Greens-
            boro, N.C. ;  CDL: 070018-<3)

00071608 Gross,  D. (1979)  Fate of CGA 48 988 in Lettuce: Project Report 38/
            79.   (Unpublished study received Apr 15,  1981 under 100-607;
            prepared by  Ciba-Geigy Ltd., Switzerland,  submitted by Ciba-
            Geigy Corp., Greensboro,  N.C.;  CDL:070018-H)

00071609 Gross,  D. (1979)  Identification of Metabolites of CGA 48 988 (Ri-
   1         domil) in Field Grown Potato Plants: Project Report 39/79.
            (Unpublished study received Apr 15, 1981  under 100-607; prepared
            by Ciba-Geigy  Ltd.,  Switzerland, submitted by Ciba-Geigy Corp.,
            Greensboro,  N.C.; CDL:070018-1)

00071610 Gross,  D. (1980)  Identification of Degradation Products of CGA
            48988 (Ridomil) in Lettuce: Project Report 38/80.  (Unpub-
            lished study received Apr 15, 1981 under  100-607; prepared by
            Ciba-Geigy Ltd.,  Switzerland, submitted by Ciba-Geigy Corp.,
            Greensboro,  N.C.; CDL:070018-J)

00071613 Hanfoock, H. (1977) Distribution, Degradation and Excretion of CGA
            48 988 in the  Rat: Project Report 18/77.   (Unpublished study
            received Apr 15,  1981 under  100-607; prepared by Ciba-Geigy
            Ltd., Switzerland, submitted by Ciba-Geigy Corp., Greensboro,
            N.C.; CDL:070018-M)

00071614 Hambock, H. (1978) Metabolism of CGA 48 988  in the Rat: Project Re-
            port 26/78.   (Unpublished study received Apr 15, 1981 under
            100-607; prepared by Ciba-Geigy Ltd., Switzerland, submitted by
            Ciba-Geigy Corp., Greensboro, N.C.; CDL:070018-N)

00071615 Ciba-Geigy Corporation (1980) Study of Metalaxyl (Ridomil 2E) Res-
            idue Tolerances in Cottonseed,  Soybeans,  Wheat, and Certain Veg-
            etable Crops:  AG-A 5457 I.   (Compilation; unpublished study,
            including AG-A 5725, 5456 I, 5545 I, II..., received Apr 15,
            1981 under 100-607;  CDL:070019-A)

00071616 Ciba-Geigy Corporation (1981) Study of Various Compounds for Res-
            idue Tolerances in Potatoes: AG-A  4601.  (Compilation; unpub-
            lished study/  including AG-A 4614, 4615,  4903..., received Apr
            15,  1981 under 100-607; CDL:070020-A)

00071622 Balasubramanian,  K.  (1980) Analytical method for the Determination
            of Total Residues of Metalaxyl  in  Animal Tissues, Milk and Eggs
            as  2,6-Dimethylaniline.  Method no. AG-349 dated Nov 25, 1980.
            (Unpublished study received  Apr  15,  1981 under  100-607; submit-
            ted by Ciba-Geigy Corp., Greensboro, N.C.; CDL:070022-L)
                                    110

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                       OFFICE OF PESTICIDE PROGRAMS
                    REGISTRATION STANDARD BIBLIOGRAPHY
       Citations Considered to be Part of the Data Base Supporting
                Registrations Under the Metalaxyl Standard
   MRID           CITATION

00071623 Balasubramanian, K. (1980) Analytical Method for the Determination
            of Total Residues of Metalaxyl in Oil Seed Fractions as 2,6-Di-
            methylaniline.  Method no. AG-350 dated Dec 18, 1980.  (Unpub-
            lished study received Apr 15, 1981 under 100-607; submitted by
            Ciba-Geigy Corp., Greensboro, N.C.; CDL:070022-M)

00071672 Ciba-Geigy Corporation (1981) Series of Tests Performed with
            Metalaxyl on Various Crops: AG-A 5638.  (Compilation; unpub-
            lished study, including AG-A nos. 5639 I,II, 5754 I,II, 5805
            I,II, ..., received Apr 15, 1981 under 100-607; CDL:070021-A)

00071673 Seim, V.W.; Thomas, W.A.  (1980) Biological Report For CGA-48988:
   '         Residue Test in Laying Hens: Report No. Biol-80009.  (Unpub-
            lished study received Apr 15, 1981 under 100-607; submitted by
            Ciba-Geigy Corp., Greensboro, N.C.; CDL:070021-B)

00071674 Seim, V.; Thomas, W.; Brown, G. (1980) Biological Report for CGA-
            48988: Residue Test in Lactating Cows: Report No. Biol-79009.
            (Unpublished study received Apr 15, 1981 under 100-607; submit-
            ted by Ciba-Geigy Corp., Greensboro, N.C.; CDL:070021-C)

00071676 Balasubramanian, K.; Ross, J.A. (1981) Comparison of Analyses of
            Potato Tubers Treated with Metalaxyl Using the Parent Method
            AG-325 and the Total Method AG-348: Report No. ABR-80056.  (Un-
            published study received Apr 15,  1981 under 100-607; submitted
            by Ciba-Geigy Corp., Greensboro,  N.C.; CDL:070021-E)

00072394 Calkins, J.E.; Morgan, J.M.; Casey,  H.W.; et al.  (1980) A 21-day
            Subacute Dermal Toxicity Study in Albino Rabbits with CGA-48988
            Technical: Study No. 410-0226.   Rev.  (Unpublished study re-
            ceived Jan 23, 1981 under 100-607; prepared by Whitaker Corp.,
            submitted by Ciba-Geigy Corp.,  Greensboro, N.C.; CDL:244182-A)

00072396 U.S.  Environmental Protection Agency, Terrestrial & Aquatic Biology
            Laboratory (1979) Ridomil 2%: Rainbow Trout (Salmo gaird-
            neri): Test # 2417.  (Unpublished study; CDL:244183-C)

00074488 Ciba-Geigy Corporation (1981) Residues of Metalaxyl in Avocados
            Resulting from Soil Surface Granular,  Soil Drench, and Drip
            Fungigation Applications: Report No. ABR-81016.   (Compilation;
            unpublished study received Jun 9, 1981 under 100-607; CDL:
            070151-A)

00077334 Fink, R.; Beavers,  J.B.;  Brown, R.  (1977) Final Report: Acute Oral
            LD50—Mallard Duck: Project No.  108-149.  (Unpublished study re-
            ceived Jul 13, 1978 under 100-EX-62? prepared by Wildlife Inter-
            national, Ltd. in cooperation with Washington College,  submitted
            by Ciba-Geigy Corp., Greensboro,  N.C.; CDL:234439-D)
                                       111

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                       OFFICE OF PESTICIDE PROGRAMS
                    REGISTRATION STANDARD BIBLIOGRAPHY
       Citations Considered to be Part of the Data Base Supporting
                Registrations Under the Metalaxyl Standard
   MRID           CITATION

00077335 Fink,  R.; Beavers,  J.B.;  Brown,  R.  (1977)  Final Report:  Eight-Day
            Dietary LC50—Bobwhite Quail: Project No.  108-147.   (Unpublished
            study received Jul 13, 1978 under 100-EX-62; prepared by Wild-
            life International,  Ltd.  and Washington College,  submitted by
            Ciba-Geigy Corp.,  Greensboro, N.C.;  CDL:234439-F)

00079433 Kahrs,  R.A. (1981)  Residues  of Metalaxyl in Hops Resulting from
            Soil Drench Applications: Report No.  ABR-81024.   (Unpublished
            study received Jul 15, 1981 under 100-607;  submitted by Ciba-
            Geigy Corp., Greensboro,  N.C.; CDL:070188-A)

00084107 Sachsse,  K.;  Ullmann, L.  (1976)  Skin Irritation in the Rabbit af-
   t         ter Single Application of Technical  CGA 48988: Project No. Siss
            5388.   (Unpublished study received Jul  13,  1978 under 100-EX-
            62; prepared by Ciba-Geigy, Ltd., Switzerland, submitted by
            Ciba-Geigy Corp.,  Greensboro, N.C.;  CDL:234428-E)

00084108 Sachsse,  K.;  Ullmann, L.  (1975)  Eye Irritation in the  Rabbit of
            Technical  CGA 48988:  Project No. Siss 5388.  (Unpublished study
            received Jul 13, 1978 under 100-EX-62;  prepared by  Ciba-Geigy,  -
            Ltd.,  Switzerland, submitted by Ciba-Geigy Corp., Greensboro,
            N.C.;  CDL:234428-F)

00084109 Sachsse,  K.;  Ullmann, L.  (1976)  Skin Sensitizing (Contact Aller-
            genic) Effect in Guinea Pigs of Technical  CGA 48988:  Project
            No. Siss 5388.  (Unpublished study received Jul 13, 1978 under
            100-EX-62; prepared by Ciba-Geigy, Ltd., Switzerland, submitted
            by Ciba-Geigy Corp.,  Greensboro, N.C.;  CDL:234428-G)

00084110 Drake, J.C. (1977) 3 Months Dietary Study in Rats in Compound CGA
            48 988.  (Unpublished study received Jul 13, 1978 under 100-
            EX-62; prepared by Ciba-Geigy, Ltd., Switzerland, submitted by
            Ciba-Geigy Corp.,  Greensboro, N.C.;  CDL:234428-H)

00084111 Finn,  J.P.; Rider, L.; Briggs, K.; et al.  (1977) CGA 48.988: 91 Day
            Dietary Toxicity Study in Beagle Dogs:  Report No. 653/380/4.
            (Unpublished study received Jul 13,  1978 under 100-EX-62; pre-
            pared by Hazleton Laboratories Europe,  Ltd., submitted by Ciba-
            Geigy Corp., Greensboro,  N.C.; CDL:234428-1)

00084113 Ami,  P.; Muller, D.  (1978)  Salmonella/Mammalian-microsome Muta-
            genicity Test with CGA 48 988:  (Test for Mutagenicity Properties
            in Bacteria).  (Unpublished study received Jul 13,  1978 under
            100-EX-62; prepared by Ciba-Geigy, Ltd., Switzerland, submitted
            by Ciba-Geigy Corp.,  Greensboro, N.C.;  CDL:234428-K)

00084114 Fritz, H.  (1978) Dominant Lethal Study—CGA 48 988 Tech.: Mouse:
            (Test for Cytotoxic or Mutagenic Effects on Male Germinal
            Cells).  (Unpublished study received Jul 13,  1978 under 100-
            EX-62; prepared by Ciba-Geigy, Ltd., Switzerland, submitted by
            Ciba-Geigy Corp., Greensboro, N.C.;  CDL:234428-L)
                                          112

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                       OFFICE OF PESTICIDE PROGRAMS
                    REGISTRATION STANDARD BIBLIOGRAPHY
       Citations Considered to be Part of the Data Base Supporting
                Registrations Under the Metalaxyl Standard
   MRID           CITATION

00097511 Ciba-Geigy Corporation (1981) Residues of Ridomil in Lettuce.
            (Compilation; unpublished study received Apr 1, 1982 under
            100-EX-71; CDL:070732-A)

00098084 Clair, M.; Fouillet, X. (1977) RU 22974: Formulation: Decis EC 2.5;
            Formulation: Decis ULV: Acute Toxicity in the Rabbit by Percu-
            taneous Administration: IFREB—R 770258/A.  (Translation; unpub-
            lished study received Mar 25, 1982 under 2E2663; prepared by
            Institut Francais de Recherches et Essais Biologiques, France,
            submitted by American Hoechst Corp., Somerville, N.J.; CDL:
            070734-J)

00098428 Kahrs, R.A. (1982) Metalaxyl—Melons, Cucumbers, Squash, Green
            Onions, Bulb Onions, Potatoes—Supportive Data Requested by EPA:
            Report No. ABR-82014.   (Unpublished study received Apr 7, 1982
            under 1F2500; submitted by Ciba-Geigy Corp., Greensboro, N.C.;
            CDL:070765-A)

00098481 Ashby, R.; Whitney, J.C.; Bhatt, A.; et al. (1980) Cga 48 988:
            Toxicity and Oncogenicity in Dietary Administration to Rats for -
            Two Years: 80/CIA009/315.  Final rept.  (Unpublished study
            received Apr 15, 1982 under 1F2500; prepared by Life Science Re-
            search, England, submitted by Ciba-Geigy Corp., Greensboro,
            N.C.; CDL:070767-A; 070768; 070769)

00100446 Buccafusco, R.; Stiefel,  C.; Fratus, G.; et al. (1978) Acute
            Toxicity of CGA-48988 Technical to Bluegill (Lepomis macro-
            chirus): Report #BW-78-12-381.  (Unpublished study received Feb
            21, 1979 under 100-601; prepared by EG & G,  Bionomics,  submitted
            by Ciba-Geigy Corp., Greensboro,  NC; CDL:236854-A)

00100447 Buccafusco, R.; Stiefel,  C.; Fratus, G.; et al. (1978) Acute
            Toxicity of CGA-48988 Technical to Rainbow Trout (Salmo gaird-
            neri): Report #BW-78-12-376.  (Unpublished study received Jan
            25, 1979 under 100-601; prepared by EG & G,  Bionomics,  submitted
            by Ciba-Geigy Corp., Greensboro,  NC; CDL:236854-B)

00100448 Suprenant,  D. (1978) Acute Toxicity of CGA-48988 to the Water Flea
            (Daphnia magna): Report IBW-78-12-364.  (Unpublished study re-
            ceived Jan 25,  1979 under 100-601; prepared by EG & G,  Biono-
            mics,  submitted by Ciba-Geigy Corp., Greensboro,  NC; CDL:
            236854-C)

00100455 Burkhard, N. (1977) Volatilization of CGA-48988 from Soil under
            Laboratory Conditions:  Project Report 29/77.  (Unpublished
            study received Apr 26,  1979 under 100-600; prepared by Ciba-
            Geigy, Ltd., Switzerland,  submitted by Ciba-Geigy Corp., Greens-
            boro,  NC; CDL:238231-D)

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                       OFFICE OF PESTICIDE PROGRAMS
                    REGISTRATION STANDARD BIBLIOGRAPHY
       Citations Considered to be Part of the Data Base Supporting
                Registrations Under the Metalaxyl Standard
   MRID           CITATION

00100464 Guth,  J.  (1976)  Leaching Model Study with the Fungicide CGA-48988
            in Four Standard Soils:  Project Report 30/76.   (Unpublished
            study received Apr 26, 1979 under 100-600; prepared by Ciba-
            Geigy, Ltd.,  Switzerland,  submitted by Ciba-Geigy Corp.,  Greens-
            boro,  NC; CDL:238232-A)

00100465 Guth,  J.  (1978)  Leaching Characteristics of Aged 14C-CGA 48988
            (Ridomil) Residues in Two Standard Soils: Project Report  33/78.
            (Unpublished  study received Apr 26, 1979 under 100-600;  pre-
            pared by Ciba-Geigy,  Ltd., Switzerland, submitted by Ciba-Geigy
            Corp., Greensboro, NC; CDL:238232-B)

00100466 Guth,  J.  (1978)  Adsorption and Desorption of CGA 48988 (Ridomil)
            in Various Soil Types: Project Report 35/78.   (Unpublished
            study received Apr 26, 1979 under 100-600; prepared by Ciba-
            Geigy, Ltd.,  Switzerland,  submitted by Ciba-Geigy Corp.,  Greens-
            boro,  NC; CDL:238232-C)

00100468 Ladd,  S.; Wilson,  W.  (1979) Accumulation and Elimination of  14C-
            residues by Bluegill Sunfish ... Exposed to 0-14C-CGA-48988:
            Report #BW-78-10-328.  (Unpublished study received Apr 26, 1979
            under 100-600; prepared by EG & G,  Bionomics;  submitted by
            Ciba-Geigy Corp.,  Greensboro, NC; CDL:238232-E)

00100470 Ladd,  S.; Enos,  J. (1979) Kinetics of Phenyl-14C-CGA in a Model
            Aquatic Ecosystem: Report #BW-79-2-401.  (Unpublished study
            received Apr  26, 1979 under 100-600; prepared by EG & G,  Bio-
            nomics, submitted by Ciba-Geigy Corp., Greensboro, NC; CDL:
            238232^3)

00100753 Ciba-Geigy Corp. (1982)  Residues of Metalaxyl in Cattle and
            Goats.  (Compilation; unpublished study received May 11,  1982
            under 1F2500; CDL:070836-A)

00103354 McSheehy, T.; Macrae, S.; Whitney, J.  (1981) CGA 48 988: Oncogen-
            icity in Dietary Administration to Mice for Two  Years: LSR Re-
            port No.: 80/CIA008/442.  (Unpublished study received Jun 11,
            1982 under 100-607; prepared by Life Science Research, Eng.,
            submitted by  Ciba-Geigy Corp., Greensboro, NC; CDL:247660-B)

00103361 Langauer, M.; Muller, D. (1979) Nucleus Anomaly Test in Somatic
            Interphase Nuclei: CGA 48 988: Chinese Hampster  (Test for
            Mutagenic Effects on Bone Marrow Cells): No.  of  Experiment 78-
            3007.   (Unpublished study received Jun 11, 1982  under 100-607;
            prepared by Ciba-Geigy, Ltd., Switz., submitted by Ciba-Geigy
            Corp., Greensboro, NC; CDL:247661-D)
                                      114

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                       OFFICE OF PESTICIDE PROGRAMS
                    REGISTRATION STANDARD BIBLIOGRAPHY
       Citations Considered to be Part of the Data Base Supporting
                Registrations Under the Metalaxyl Standard
   MRID           CITATION

00103362 Strasser, F. (1982) L5178Y/TK+/-Mouse Lymphoma Mutagenicity Test:
            CGA 48 988 (In vitro Test for Mutagenic Properties of Chemical
            Substances in Mammalian Cells): No. of Experiment 811258.  (Un-
            published study received Jun 11, 1982 under 100-607; prepared
            by Ciba-Geigy, Ltd., Switz., submitted by Ciba-Geigy Corp.,
            Greensboro,  NC; CDL:247661-E)

00103363 Puri, E.  (1982) Autoradiographic DNA Repair Test on Rat Hepato-
            cytes: CGA 48 988 (In vitro Test for DNA-damaging Properties):
            No. of Experiment 811259.  (Unpublished study received Jun 11,
            1982 under 100-607; prepared by Ciba-Geigy, Ltd., Switz., sub-
            mitted by Ciba-Geigy Corp., Greensboro, NC; CDL:247661-F)
  t
00103564 Modin, J. (1969) Residues in fish, wildlife, and estuaries.  Pesti-
            cides Monitoring Journal 3(1):1-7.   (Available from:  Superin-
            tendent of documents, U.S.  Government Printing Office, Washing-
            ton, DC  20402; published study; CDL:091969-AX)

00104376 Ballantine, L.  (1979) Rotational Crop Data Submitted in Support of
            Conditional  Registration for Ridomil (Metalaxyl) Use on Tobacco:
            Report No. ABR-79099.  (Unpublished study received Oct 31, 1979
            under 100-607; submitted by Ciba-Geigy Corp.,  Greensboro, NC;
            CDL.-241243-A)

00104381 Fischer,  W.; Cassidy, J. (1978) Uptake and Characterization of
            Phenyl-14C-CGA-48988 and Its Soil Metabolites in Rotation Let-
            tuce,  M6-69-8PR, 8SR: Report No. ABR-78078.  (Unpublished study
            received Oct 31, 1979 under 100-607; submitted by Ciba-Geigy
            Corp., Greensboro, NC; CDL:241243-G)

00104382 Fischer,  W.; Cassidy, J. (1979) Uptake and Characterization of
            Phenyl-14C-CGA-48988 and Its Soil Metabolites in Field Rota-
            tion Spring Oats, M6-69-4PR, 4SR: Report No. ABR-79002.  (Unpub-
            lished study received Oct 31, 1979 under 100-607; submitted by
            Ciba-Geigy Corp., Greensboro, NC; CDL:241243-H)

00104383 Fischer,  W.; Cassidy, J. (1979) Uptake and Characterization of
            Phenyl-14C-CGA-48988 and Its Soil Metabolites in Field Rota-
            tion Corn, M6-69-6PR, 6SR:  Report No.  ABR-79004.  (Unpublished
            study received Oct 31, 1979 under 100-607; submitted by Ciba-
            Geigy Corp., Greensboro,  NC; CDL:241243-1)

00104384 Hamilton, T.; Fischer, W.; Cassidy, J. (1979) Uptake and Character-
            ization of Phenyl-14C-CGA-48988 and Its Soil Metabolites in
            Field Rotation Soybeans,  M6-69-7PR, 7SR: Report No. ABR-79003.
            (Unpublished study received Oct 31, 1979 under 100-607; sub-
            mitted by Ciba-Geigy Corp., Greensboro, NC; CDL:241243-K)

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                       OFFICE OF PESTICIDE PROGRAMS
                    REGISTRATION STANDARD BIBLIOGRAPHY
       Citations Considered to be Part of the Data Base Supporting
                Registrations Under the Metalaxyl Standard

   MRID           CITATION

00104385 Hamilton,  T.;  Fischer, W.; Cassidy,  J. (1979) Uptake and Character-
            ization of Phenyl-14C-CGA-48988 and Its Soil Metabolites in
            Field Rotation Sugar Beets, M6-69-5PR, 5SR: Report No. ABR-
            79005.   (Unpublished study received Oct 31, 1979 under 100-607;
            submitted by Ciba-Geigy Corp., Greensboro, NC; CDL-.241243-L)

00104387 Ciba-Geigy Corp.  (1979) Residues of CGA-48988 on Wheat, Rye,  For-
            age and Other Crops.  (Compilation; unpublished study received
            Oct 31, 1979 under 100-607; CDL:241243-N)

00104390 Ciba-Geigy Corp.  (1979) Residue Studies of CGA-48988 on Soybeans
            and Other Crops.   (Compilation; unpublished study received Oct
            31, 1979 under 100-607; CDL:241243-Q)

00104483 Ciba-Geigy Corp.  (1978) [Chemical Data on the Fungicide Ridomil].
            (Compilation;  unpublished study received Jul 13, 1978 under
            100-EX-63;  CDL:234427-A)

00104493 Burkhard,  N.  (1976)  Hydrolysis of CGA-48988 under Laboratory Con-
            ditions: Project  Report 26/76.  (Unpublished study received
            Jul 13, 1978 under 100-EX-62; prepared by Ciba-Geigy, Ltd.,
            Switz., submitted by Ciba-Geigy Corp., Greensboro, NC; CDL:
            234438-C)

00104494 Ellgehausen, H. (1977) Distribution of the Non-extractable Radio-
            activity between  Different Soil Organic Matter Fractions of a
            Field Soil  Treated with 14C-labeled CGA 48988 (Addendum to
            Project Report 55/77): Project Report 56/77.  (Unpublished
            study received Jul 13, 1978 under 100-EX-62; prepared by Ciba-
            Geigy,  Ltd., Switz., submitted by Ciba-Geigy Corp., Greensboro,
            NC; CDL:234438-G)

00104498 Ciba-Geigy Corp.   (1978) Chemistry of CGA-48988 Technical.  (Com-
            pilation;  unpublished study received Sep 5, 1978 under 100-601;
            CDL:235062-A)

00104656 Ciba-Geigy Corp.  (1978) Ridomil 2E Fungicide Residue Study—
            Potatoes.   (Compilation; unpublished study received Sep 5, 1978
            under 100-EX-l; CDL-.097389-A)

00109402 Ciba-Geigy Corp.  (1981) Metalaxyl—Cotton In-furrow Applications of
            Ridomil 2E and 5G Including Mixtures with PCNB: Report No. ABR-
            81046.   (Compilation; unpublished study received Jul 28, 1982
            under 100-607; CDL.-247934-A)

00109471 Coate, W.  (1982)  Correction Pages and Addendum: Subchronic Inhala-
            tion Study in Rats: CGA-48988: Project No. 483-202.  (Unpublished
            study received Aug 12, 1982 under 1F2500; prepared by Hazleton
            Laboratories America, Inc., submitted by Ciba-Geigy Corp.,
            Greensboro, NC; CDL:071032-A)

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                       OFFICE OF PESTICIDE PROGRAMS
                    REGISTRATION STANDARD BIBLIOGRAPHY
       Citations Considered to be Part of the Data Base Supporting
                Registrations Under the Metalaxyl Standard
   MRID           CITATION

00109472 Ciba-Geigy Corp.  (1982)  Metalaxyl Residues in Pineapple Resulting
            from a Preplant Dip Application of Ridomil 2E.   (Compilation;
            unpublished study received Aug 12, 1982 under 100-607;  CDL:
            071034-A)

00114376 Ciba-Geigy Corp.  (1982)  Metalaxyl—Rotational Wheat:  Report # ABR-
            82061.  (Compilation; unpublished study received Sep 23, 1982
            under 100-607; CDL:071104-A)

00114377 Ciba-Geigy Corp.  (1982)  Metalaxyl—Lettuce: Report #  ABR-82060.
            (Compilation;  unpublished study received Sep 23,  1982 under 100-
            607; CDL:071106-A)

00114378 Ciba-Geigy Corp.  (1982)  Metalaxyl—Spinach: Report #  ABR-82050.
            (Compilation;  unpublished study received Sep 23,  1982 under 100-
            607; CDL:071107-A)

00114379 Collins,  P.;  Williams,  S.;  Cassidy, J.  (1982) Metabolism of Phen-
            yl-14C-CGA-48988 in Greenhouse Head Lettuce: Report No.  ABR-
            82054.  (Unpublished study received Sep 23, 1982 under 100-607;.
            submitted  by Ciba-Geigy  Corp., Greensboro, NC;  CDL:071108-A)

00117969 Cheung, M.; Manuli, P.  (1982) Metalaxyl—Citrus: Residues Resulting
            from Soil  or Trunk-spray Applications of Ridomil 2E: Report
            No.  ABR-82069.  (Unpublished study received Nov 16, 1982 under
            100-607; submitted by Ciba-Geigy Corp., Greensboro, NC;  CDL:
            071238-A)

00126315 Ciba-Geigy Corp.  (1983)  Summary of Section D: Metalaxyl—Ap-
            ples.   (Compilation;  unpublished study received Mar 7,  1983
            under 100-607; CDL:071476-A)

00127769 Ciba-Geigy Corp.  (1983)  Metalaxyl—Red Raspberries: Residues
            Resulting  from Soil Application of Ridomil 2E or 5G.  (Compi-
            lation; unpublished study received Mar 7,  1983 under 100-607;
            CDL:071478-A)

00128102 Ciba-Geigy Corp.  (1982)  Metalaxyl (Apron 2E)  Seed Treatments.
            (Compilation;  unpublished study received Feb 3, 1983 under
            100-626; CDL:071388-A)

00128738 Ciba-Geigy Corp.  (1983)  Summary of Section D: Metalaxyl—Peanuts:
            Residue Reports.  (Compilation; unpublished study  received Jun
            29,  1983 under 100-607;  CDL:071718-A)

00129003 Ciba-Geigy Corp.  (1983)  Summary of Section D: Metalaxyl—Pod Vege-
            tables.  (Compilation; unpublished study received  Jun 23,  1983
            under 3F2918;  CDL:071711-A)
                                     137

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                       OFFICE OF PESTICIDE PROGRAMS
                    REGISTRATION STANDARD BIBLIOGRAPHY
       Citations Considered to be Part of the Data Base Supporting
                Registrations Under the Metalaxyl Standard
   MRID           CITATION

00130693 Ciba-Geigy Corp.  (1983) Residue Summary: Metalaxyl—Cucumbers,
            Melons, and Squash.   (Compilation; unpublished study received
            Aug 19, 1983 under 100-607; CDL:251019-A)

00130694 Ciba-Geigy Corp.  (1983) Residue Summary: Metalaxyl—Green and Dry
            Bulb Onions.  (Compilation; unpublished study received Aug 19,
            1983 under 100-607;  CDL:251020-A)

00130695 Ciba-Geigy Corp.  (1983) Residue Summary: Metalaxyl—Lettuce and
            Spinach.  (Compilation; unpublished study received Aug 19, 1983
            under 100-607; CDL-.251021-A)

001,30773 Ciba-Geigy Corp.  (1983) Residue Summary: Metalaxyl—Broccoli, Cab-
            bage and Cauliflower.   (Compilation; unpublished study received
            Aug 26, 1983 under 100-607; CDL:071918-A)

00132009 Hardisty, J. (1983)   Toxicity and Oncogencity Dietary Administration
            of GGA 48988 to Rats for Two Years: Part 1.  (Unpublished study
            received Oct 12,  1983 under 100-607; prepared by Experimental
            Pathology Laboratories, Inc.  Submitted by Ciba-Geigy Corp.
            Greensboro,  N.C.;  CDL:251487-A)

00133020 Ciba-Geigy Corp.  (1983) Metalaxyl—Citrus Residues Resulting from
            Soil Applications  of Ridomil 5G.  (Compilation; unpublished
            study received Dec 8,  1983 under 100-628; CDL:251988-A)

00141519 Ciba-Geigy Corp.  (1984) Metalaxyl—Apples: [Residue Chemistry
            Data].  Unpublished compilation.  77 p.

00144371 Laughlin, K. (1984) Range-finding Teratology Study in Rabbits:
            [Metalaxyl]: 382-097.   Unpublished study prepared by Interna-
            tional Research and Development Corp.  52 p.

00144372 Laughlin, K. (1984) Teratology Study in Rabbits: [Metalaxyl]:
            382-098.  Unpublished study prepared by International Research
            and Development Corp.   78 p.

00144423 Leng, J. (1985) Teratology Study in Rats:[Metalaxyl]: Study No.
            382-100.  Unpublished study prepared by International Research
            and Development Corp.   94 p.

00148087 Ashby, R.; Fowler, J.; Finn, J. (1985) Metalaxyl Technical : Com-
            bination 30-day to 90-day Subchronic Dietary Toxicity Study
            in Albino Mice: Final Report: Addendum 1 : Supplementary Cli-
            nical -, Macro- and Micro- Pathology: Report No. 85/CIA064/180.
            Unpublished study prepared by Life Science Research Limited.
            733 p.
                                       Mb-

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                       OFFICE OF PESTICIDE PROGRAMS
                    REGISTRATION STANDARD BIBLIOGRAPHY
       Citations Considered to be Part of the Data Base Supporting
                Registrations Under the Metalaxyl Standard
   MRID           CITATION

00148103 Ciba-Geigy Corp.  (1985)  Metalaxyl (Ridomil 2E and Ridomil MZ58)  in
            All Crops:  Comparison Studies on Ground Vs. Aerial Treatments:
            [Residue Data].   Unpublished compilation.   88 p.

00148440 Ciba-Geigy Corp.  (1985)  Metalaxyl (Ridomil 5G) in All Crops: Cross-
            over Comparison  Studies of Ridomil 2E and 5G.  Unpublished com-
            pilation.  577 p.

00150094 Hardisty, J. (1985) Metalaxyl: Oncogenicity in Dietary Administra-
            tion to Mice for Two  Years: Pathology Report Study Number
            CIA/008/48988.  Unpublished study prepared by Experimental
            Pathology Laboratories, Inc.  946 p.
  i
00154301 Deparade, E. (1985) SalmDnella/Mammalian-microsome Mutagenicity
            Test: Test  No.:  851007.  Unpublished study prepared by Ciba-
            Geigy Ltd.   18 p.

00154302 Moriya, M.; Ohta, T.;  Shirasu, Y. (1981) Report on Mutagenicity
            Study with  CG-48988 in a Microbial System.  Unpublished study
            prepared by Institute of Environmental Toxicology.  6 p.

00154306 Puri,  E. (1985) Autoradiographic DNA Repair Test on  Rat Hepato-
            cytes: Test Material: CGA 48 988: Supplement to the Report
            (dated January 19,  1982): Test No.: 811259.  Unpublished study
            prepared by Ciba-Geigy Ltd.  37 p.

00154308 Thomann, P.; Pericin,  C. (1977) Acute Oral LD50 in the Chinese
            Hamster of  CGH4A 48 988: No.. PH 2.634.  Unpublished study pre-
            pared by Ciba-Geigy Ltd.  3 p.

00154663 Puri,  E. (1982) Autoradiographic DNA Repair Test on  Human Fibro-
            blasts: CGA 48 988: (In vitro Test for DNA-damaging Proper-
            ties): No.  of Experiment: 811660.  Unpublished study prepared by
            Ciba-Geigy  Ltd.   23 p.

00157480 Ciba-Geigy Corp.  (1984)  [Residue Chemistry: Methods  and Summary  of
            Results: Metalaxyl].   Unpublished compilation.  280 p.

00157740 Rohm and Haas  Co. (1986) Product Chemistry of: Kerb  3.3F Flowable
            Agricultural Herbicide:.  Unpublished study.  4p.

00161404 Fritz, P. (1984)  Expanded Report on a Segment II Reproduction
            Study in the Rabbit with CGA-48988 Technical (Test for Terato-
            genic or Embryotoxic  Effects): Study No. 784868.   Unpublished
            study prepared by Ciba-Geigy, Corp.  459 p.

00161405 Fritz, P. (1984)  Expanded Report on the Segment II Reproduction
            Study with  CGA-48988  Technical in the Rat (Test for Teratogenic
            or Embryotoxic Effects): Study No. 227716.  Unpublished study
            prepared by Ciba-Geigy Corp.  359 p.
                                     119

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                      OFFICE OF PESTICIDE PROGRAMS
                    REGISTRATION STANDARD BIBLIOGRAPHY
       Citations  Considered  to be Part of the Data Base Supporting
               Registrations Under  the Metalaxyl Standard
   MRID           CITATION

40276701 Hoxter,  K.; Jaber, M.  (1987) An Acute Contact Toxicity Study with
            the Honey  Bee: Metalaxyl: Study No.  108-282.  Unpublished study
            prepared by Wildlife International, Ltd.  18p.

40435001 Ciba-Geigy Corp.  (1982) Product Chemistry for Product Containing
            Metalaxyl.  Unpublished study.  4p.
                                     120

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  APPENDIX IV




FORMS  APPENDICES
           121

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                                                                               OMB Aporovil No. 20OO-0468 (Expires 12-31-83)  -
                  FIFHA SECTION 3(C)(2)(B) SUMMARY SHEET
                                                                                       EPA REGISTRATION NO.
  PRODUCT NAME
  APPLICANT'S NAME
                                DATE GUIDANCE DOCUMENT ISSUED
   With retptct to tht roquiremtnt to lubmit "gtntric" data impoad by tht FIFRA action 3(C)(2)(B) notict containtd in tht rtfrrtnetd
   Guidanct Oocumtm. I tm rttpondirtf in tht following mtflntr.
      Q1. I will lubmit dra in t tuntty mmntf to atofy tht following nquirtmtnu. If flit Mt proctdum I will ua dtviatt from (or tri not
           tptcifitd in) tht fltaatrat'on Guidtlina or tht Protocols rantaintd in tht Rtpora of Exptn Group* to tht Chtmicals Group, OECD
           Cntmicats Tating Programme, I tndea tht protocol! thtt I will ua:
     Q 2.  I htvt tntwrtd into tn torttmtnt with ont or mort othtr rtfittnmn undtr FIFRA action 3(C)(2)(BHii) to satisfy tht following data
           rtquirimtnts. Tht ttm, and tny rtquirtd protocols, will bi submintd to EPA by:
  NAME OF OTHER REGISTRANT
     CD 3. I mdoa t compltttd "Ctnifwrtion of Attempt to Enttr Into in Agntmtnt with Othtr Rtgistrinu for Otvtlopmtnt of Data" with
          resptct to tht following dra rtquiramtno:
     D 4. I nquat thtt you ummd my rtfiftration by otltting flu following UOM (this option • not mittolt to applicants for ntw products):
     O 5. I rtquon voluntory ctncolwlion of ttM raoittretJon of thit product fTlw option is not ntjitoMt to applicants for ntw products.)
REGISTRANT'S AUTHORIZED RIPRCSCNTATIVC
SPA r-v rsao-i n»."r)
SIGNATURE
                                                   DATE
                                                          ^  122

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                                                                                 OMB Appro*,/ No. XO&O4GS
CERTIFICATION OF ATTEMPT TO ENTER
INTO AN AGREEMENT WITH OTHER REGISTRANTS
(To ««//r>. aftlfyALL *»»•«*»*) FOR DEVELOPMENT OF DATA
1. 1 am duly authorized to represent the following firm(s) who ara subiact to tha require-
mams of a Notica undor FIFRA Saction 3(c)(2)(B) containad in a Guidanca Oocumtnt
to submit data concarning tha active ingradiant:
NAME OP FIRM




OUIOANCf DOCUMENT OATI
ACTIVE INOMEOIENT
IPA COMPANY NUMBER




(This firm or group of firms is referred to balow as "my firm".)
 2. My firm is willing to davolop and submit tha data as raquirad by that Notica, if necessary. However, my firm would prafer to ft
    into an agreement with ona or mort othtr rtgistrants to davalop jointly, or to sharo in tha cost of developing, the following rtqu
    Kams or data:
 X  My firm has offtrad In writing to afflar into audi an agreement Capias of tha offan an attached. That offor was Imuacabls and inctodad an offer n
    Mimd by an arbitration decision undar FIF BA Saction 3(e)(2)(B)(i« If final agnamant on oN farms could not ba raacnad otharwiss. This offar was w
    to tha following firmis) on tha (oOowing dao
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EPA Reg. No.
PRODUCT SPECIFIC DATA EEPORT



            Date
Guidance Document for
Registration
Guideline No.
$158.120
FRQDXT
CHEMISTRY
61-1
61-2
61-3
62-1
62-2
62-3
63-2
63-3
63-4
6: -5
63-6
63-,'
63-8
63-9
63-10 -
63-11
63-12
Name of Test

Identity of
Ingredients
Statement of
composition
Discussion of
formation of
Ingredients
Preliminary
analysis
Certification of
limits
Analytical methods
for enforcement
limits
Color
Physical state
Odor
Melting point
Boiling point
Density* bulk-
density, or
specific gravity
solubility
Vapor pressure
Dissociation
constant
Octanol/water
partition
coefficient
PH
lest not
required
for my
product
listed
above
(check
below)


















I am complying with
data requirements by
Citing MRLD
Number or
EPA Accession
Number


















Submit-
ting
Data .
(At-
tached)


















(For EPA Use Cnly)
Accession Numbers
Assigned


















                                       124

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Registration
Guideline No.
63-13
63-14
63-15
63-16
63rl7
63-18
63-19
. 63-20
63-21
515^.135
TOXICOLOGY
81-1
81-2
81-3
81-4
81-5
81-6
Name of Test
Stability
Oxidizing/reducing
reaction
Flannabillty
Explodablllty
Storage stability
Viscosity
Mlscibility
Corrosion
characteristics
Dielectric break-
down voltage

Acute oral
toxlclty, rat
Acute dermal
toxlcity, rabbit
Acute inhalation,
toxlcity, rat
Prljnary eye
irritation, rabbit
Primary dermal
irritation
Dermal sensitiza-
tlon
Test not
required
for my
product
listed
above
(check
below)
















I am complying with
data requirements by
Citing MRID
Number or
EPA Accession
Number














'

Submit-
ting
Data
(At-
tached)
















(For EPA Use Oily)
Accession Numbers
Assigned









• -






125

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                                              CMB Approval No. 2070-0057
                                              Expiration Date 11/30/89
                          GENERIC DATA EXEMPTION STATEMENT

 EPA Product Registration Number: 	

 Registrant's Name and Address:   	
     As an authorized representative of the registrant of the product identified
 above, I certify that:

     (1)  I have read and am familiar with the terms of the Notice from EPA dated
               concerning a requirement for submission of "generic" data on the
 active Ingredient ______________ named under FIFRA Section 3(c)(2)(B).

     (2)  Jfy firm requests that EPA" not suspend the registration of our product,
 despite our lack of Intent to submit the generic data in question, on the grounds
 that the product contains the active ingredient solely aa the result of the
 incorporation Into the product of another product which contains that active
 ingredient, which is registered under PIPRA Section 3, and which Is purchased by
 us  from another producer.

     (3)  An accurate Confidental Statement of Fonnula(CSF) for the above-identlfiea
 product is attached to this statement.  That formula statement indicates, by
 company name, registration number, and product name, the source of the subject
 active ingredient in my firm's product, or

 The CSP dated _ on file with EPA is complete, current and accurate and
 contains the information requested on the current CSP Fora No. 857CM.  The
 registered source(s) of the above named active Ingredient in my product(s) is/are
_ and their registration number(s) Is/are _  .

     My firm will apply for an amendment to the registration prior to changing
 the source of the active ingredient in our product.
         I  understand,  and agree on behalf of my firm,  that if at any time any
portion of  this  Statement is  no longer true, or If my firm fails to comply with
the undertakings made in this Statement,  my firm's product's registration may be
suspended under  FIFRA Section 3(c)(2)(B).

    (5)  I  further understand that If my  firm is granted a generic data exemption
for the product, my  firm relies on the efforts of other persons to provide the
Agency with the  required generic data. If the registrant(s) who have committed
to generate and  submit  the required data  fall to take appropriate steps to meet
requirements or  are  no  longer In compliance with this Notice's data requirements,
the Agency  will  consider that both they and my firm are not In compliance and
will normally initiate  proceedings to suspend the registrations of my firm's
product (a)  and their product(s), unless my firm ccmndta to submit and submits
the required data in the specified time frame.  I understand that, In such cases,
the Agency  generally will not grant a time extension for submitting the data.
Registrant's authorized representative:
                                               (signature)

Dated:
                                                 (Typed)
EPA Ponfl 8570-27                            | 26

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