United States       Prevention, Pesticides     EPA738-R-05-001
Environmental Protection   and Toxic Substances     January 2005
Agency         (7508C)
   Reregistration
   Eligibility Decision
   for 2,4-DB

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

Dear Registrant:

       This is to inform you that the Environmental Protection Agency (hereafter referred to as
EPA or the Agency) has completed its review of the available data and public comments
received related to the preliminary risk assessments for the herbicide 2,4-DB. The enclosed
Reregi strati on Eligibility Decision (RED) document was approved on January 31, 2005. Public
comments and additional data received were considered in this decision.

       Based on its review, EPA is  now publishing its Reregi strati on Eligibility Decision (RED)
and risk management decision for 2,4-DB and its associated human health and environmental
risks.  A Notice of Availability will be published in the Federal Register announcing the
publication of the RED.

       The RED and supporting risk assessments for 2,4-DB are available to the public in EPA's
Pesticide Docket OPP-2004-0220 at: http://www.epa.gov/edockets.

       The 2,4-DB RED was developed through EPA's public participation process, published
in the Federal Register on May 14, 2004, which provides opportunities for public involvement in
the Agency's pesticide tolerance reassessment and reregi strati on programs. Developed in
partnership with USDA and with input from EPA's advisory committees and others, the public
participation process encourages robust public involvement starting early and continuing
throughout the pesticide risk assessment and risk mitigation decision making process.  The
public participation process encompasses full, modified, and streamlined versions that enable the
Agency to tailor the level of review to the level of refinement of the risk assessments, as well as
to the amount of use, risk, public concern, and complexity associated with each pesticide.  Using
the public participation  process, EPA is attaining its strong commitment to both involve the
public and meet statutory deadlines.

       Please note that the 2,4-DB risk assessment and the attached RED document concern
only this particular pesticide. This RED presents the Agency's conclusions on the dietary,
drinking water, occupational and ecological risks posed by exposure to 2,4-DB alone. This
document also contains both generic and product-specific data that the Agency intends to require
in Data Call-Ins (DCIs). Note that DCIs, with all pertinent instructions, will be sent to
registrants at a later date.  Additionally, for product-specific DCIs, the first set of required
responses will be due 90 days from the receipt of the DCI letter. The second set of required
responses will be due eight months from the receipt of the DCI letter.

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       As part of the RED, the Agency has determined that 2,4-DB will be eligible for
reregi strati on provided that all the conditions identified in this document are satisfied, including
implementation of the risk mitigation measures outlined in Section IV of the document. Sections
IV and V of this RED document describe labeling amendments for end-use products and data
requirements necessary to implement these mitigation measures. Instructions for registrants on
submitting the revised labeling can be found in the set of instructions for product-specific data
that accompanies this document.

       Should a registrant fail to implement any of the risk mitigation measures outlined in this
document, the Agency will continue to have concerns about the risks posed by 2,4-DB.  Where
the Agency has identified any unreasonable adverse effect to  human health and the environment,
the Agency may at any time initiate appropriate regulatory action to address this concern.  At
that time, any affected person(s) may challenge the Agency's action.

       If you have questions on this document or the label changes necessary for reregi strati on,
please contact the Chemical Review Manager,  Mika J. Hunter, at (703) 308-0041. For questions
about product reregistration and/or the Product DCI that accompanies this  document, please
contact Venus Eagle at (703) 308-8045.
                                         Sincerely,

                                         Debra Edwards, Ph. D.
                                         Director, Special Review and
                                         Reregistration Division

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                  REREGISTRATION ELIGIBILITY
                             DECISION
                                 for
                                2,4-DB
                                List A
                             CASE 0196
                                      Approved By:

                                      Debra Edwards, Ph.D.
                                      Director, Special Review and
                                      Reregi strati on Division
                                      Date
Attachment

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Table of Contents

2,4-DB Reregistration Team	     i
Glossary of Terms and Abbreviations	     ii
Executive Summary	    iv

I. Introduction	    1
II. Chemical Overview	     3
      A. Regulatory History	     3
      B. Chemical Identification 	        3
             1. Technical 2,4-DB	     3
             2. Technical 2,4-DB-DMAS	    4
      C. Use Profile	     5
      D. Estimated Usage of Pesticide	     6
III. Summary of 2,4-DB Risk Assessments	        7
      A. Human Health Risk Assessment	        7
             1. Toxicity of 2,4-DB	    7
             2. FQPA Safety	    11
             3. Population Adjusted Dose (PAD)	    11
                   a. Acute PAD	    11
                   b. Chronic PAD	        11
             4. Exposure Assumptions	    12
             5. Dietary (Food) Risk Assessment	    12
                   a. Acute Dietary Risk	     12
                   b. Chronic (Non-Cancer) Dietary Risk	    13
                   c. Dietary Risks from Drinking Water	    14
                         i. Surface Water	     14
                         ii. Ground Water	     15
             6. Aggregate Risk	    15
                   a. Acute Aggregate Risk	    15
                   b. Chronic Aggregate Risk	    16
             7. Occupational Risk	    16
                   a. Occupational Toxicity	    17
                   b. Occupational Handler  Exposure	    18
                   c. Occupational Handler Risk Summary	    18
                   d. Occupational Post-Application Risk Summary	   20
                   e. Human Incident Data	   21
      B. Environmental Risk Assessment	    21
             1. Environmental Fate and Transport	   21
             2. Ecological Risk	    22
                   a. Risk to Birds	   24
                         i. Toxicity (Hazard) Assessment	   24
                         ii. Exposure and Risk	    24
                   b. Risk to Mammals	   25
                         i. Toxicity (Hazard) Assessment	    25
                         ii. Exposure and Risk	    26
                   c. Risk to Fish and Aquatic Invertebrates	   28

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                         i. Toxicity (Hazard) Assessment for Freshwater
                                Species	    28
                         ii. Toxicity Assessment for Estuarine/Mari ne
                                Species	   29
                         Hi. Exposure and Risk	   29
                   d. Risk to Non-Target Insects	   30
                   e. Risk to Non-Target Terrestrial Plants	   30
                   f. Risk to Non-Target Aquatic Plants	   31
                   g. Food-Chain Effects	   32
                   h. Risk to Threatened and Endangered Species	   32
                   i. Risk Characterization	       33
                   j. Ecological Incident Report	   34

IV. Risk Management, Reregistration, and Tolerance Reassessment Decision...   35
      A. Determination of Reregistration Eligibility	    35
      B. Public Comments and Responses	   35
      C. Regulatory Position	   36
             1. Food Quality Protection Act Findings	   36
                   a. "Risk Cup" Determination	   36
                   b. Determination of Safety to U.S. Population	   36
                   c. Determination of Safety to Infants and Children	    37
                   d. Endocrine Disrupter Effects	   38
                   e. Cumulative Risks	   38
             2. Tolerance  Summary	     38
                   a. Tolerances  Currently Listed and Tolerance
                         Reassessment	   40
                   b. Codex Harmonization	   42
      D. Regulatory Rationale	   42
             1. Human Health Risk Management	   42
                   a. Dietary (Food) Risk Mitigation	    42
                   b. Drinking Water Risk Mitigation	    42
                   c. Residential  Risk Mitigation	   42
                   d. Occupational Risk Mitigation	   42
                         i. Handler Exposure	   42
                         ii. Post-Application Risk Mitigation	    43
             2. Environmental Risk Management	       43
             3. Other Labeling Requirements	   43
             4. Threatened and Endangered Species Considerations	   44
                   a. The Endangered Species Program	   44
                   b. General Risk Mitigation	     44

V. What Registrants Need to Do	     45
      A. Manufacturing Use-Products	   47
             1. Additional Generic Data Requirements	     47
             2. Labeling for Technical and Manufacturing-Use Products	   47
      B. End-Use Products	         47

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             1. Additional Product Specific Data Requirements	   47
             2. Labeling for End-Use Products	   48
                   a. Label Changes Summary Table	   48

VL Appendices	   55
      A. Table of Use Patterns for 2,4-DB	   56
      B. Table of Generic Data Requirements and Studies Use to Make the
             Reregistration Decision	    103
      C. Technical Support Documents	    110
      D. Bibliography Citations	    Ill
      E. Generic Data Call-In	    144
      F. Product Specific Data Call-In	    148
      G. Batching of End-Use Products	    168
      H. List of All Registrants Sent the Data Call-In	    171
      I. List of Available Forms	    174

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                              2,4-DB Reregistration Team

Health Effects Division
Kit Farwell
Timothy Dole
Danette Drew
Felicia Fort

Environmental Fate and Effects Division
Sid Abel
Amer Al-Mudallal
Lewis Brown
Pat Jennings

Biological and Economic Analysis Division
Alan Halvorson

Registration Division
Joanne Miller
Eugene Wilson

Special Review and Reregistration Division
Robert McNally
Anne Overstreet
Mika J. Hunter

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GLOSSARY OF TERMS AND ABBREVIATIONS

a.i.             Active Ingredient
aPAD          Acute Population Adjusted Dose
APHIS         Animal and Plant Health Inspection Service
ARTF          Agricultural Re -entry Task Force
BCF           Bioconcentration Factor
CDC           Centers for Disease Control
CDPR          California Department of Pesticide Regulation
CFR           Code of Federal Regulations
ChEI           Cholinesterase Inhibition
CMBS          Carbamate Market Basket Survey
cPAD          Chronic Population Adjusted Dose
CSFII          USDA Continuing Surveys for Food Intake by Individuals
CWS           Community Water System
DCI           Data Call-in
DEEM          Dietary Exposure Evaluation Model
DL            Double layer clothing {i.e., coveralls over SL}
DWLOC       Drinking Water Level of Comparison
EC            Emulsifiable Concentrate Formulation
EDSP          Endocrine Disrupter Screening Program
EDSTAC       Endocrine Disrupter Screening and Testing Advisory Committee
EEC           Estimated Environmental Concentration. The estimated pesticide concentration in an
               environment, such as a terrestrial ecosystem.
EP             End-Use Pro duct
EPA           U.S. Environmental Protection Agency
EXAMS       Tier II Surface Water Computer Model
FDA           Food and Drug Administration
FFDCA        Federal Food, Drug, and Cosmetic Act
FIFRA          Federal Insecticide, Fungicide, and Rodenticide Act
F OB           Functional Ob servation B attery
FQPA          Food Quality Protection Act
FR             Federal Register
GL            With gloves
GPS           Global Positioning System
HIARC        Hazard Identification Assessment Review Committee
IDFS           Incident Data System
IGR           Insect Growth Regulator
IPM           Integrated Pest Management
RED           Reregistration Eligibility Decision
LADD          Lifetime Average Daily Dose
LC50           Median Lethal Concentration. Statistically derived concentration of a substance expected to cause
               death in 50% of test animals, usually expressed as the weight of substance per weight or volume
               of water, air or feed, e.g., mg/1, mg/kg or ppm.
LCO           Lawn Care Operator
LDso           Median Lethal Dose.  Statistically derived single dose causing death in 50% of the test animals
               when administered by the route indicated (oral,  dermal, inhalation), expressed as a weight of
               substance per unit weight of animal, e.g., mg/kg.
LOAEC        Lowest Observed Adverse Effect Concentration
LOAEL        Lowest Observed Adverse Effect Level
LOG           Level of Concern
LOEC          Lowest Observed Effect Concentration
mg/kg/day      Milligram Per Kilogram Per Day
MOE          Margin of Exposure
MP            Manufacturing-Use Product
MRID          Master Record Identification (number). EPA's  system of recording and tracking studies
               submitted.
MRL           Maximum Residue Level

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N/A            Not Applicable
NASS           National Agricultural Statistical Service
NAWQA        USGS National Water Quality Assessment
NG             No Gloves
NMFS           National Marine Fisheries Service
NOAEC         No Observed Adverse Effect Concentration
NOAEL         No Observed Adverse Effect Level
NPIC           National Pesticide Information Center
NR             No respirator
OP             Organophosphorus
OPP            EPA Office of Pesticide Programs
ORETF         Outdoor Residential Exposure Task Force
PAD            Population Adjusted Dose
PCA            Percent Crop Area
PDCI           Product Specific Data Call-In
PDF            USDA Pesticide Data Program
PF10            Protections factor 10 respirator
PF5             Protection factor 5 respirator
PFJED           Pesticide Handler's Exposure Data
PFH             Pre-harvest Interval
ppb             Parts Per Billion
PPE            Personal Protective Equipment
PRZM           Pesticide Root Zone Model
RBC            Red Blood Cell
RED            Reregistration Eligibility Decision
REI             Restricted Entry Interval
RfD            Reference Dose
RPA            Reasonable and Prudent Alternatives
RPM            Reasonable and Prudent Measures
RQ             Risk Quotient
RTU            (Ready-to-use)
RUP            Restricted Use Pesticide
SCI- GROW      Tier I Ground Water Computer Model
SF              Safety Factor
SL             Single layer clothing
SLN            Special Local Need (Registrations Under Section 24C of FIFRA)
STORET        Storage and Retrieval
TEP            Typical End-Use Product
TGAI           Technical Grade Active Ingredient
TRAC           Tolerance Reassessment Advisory Committee
TTRS           Transferable Turf Residues
UF             Uncertainty Factor
USDA           United States Department of Agriculture
USFWS         United States Fish and Wildlife Service
USGS           United States Geological Survey
WPS            Worker Protection Standard
                                                  111

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EXECUTIVE SUMMARY

       The Environmental Protection Agency (hereafter referred to as EPA or the Agency) has
completed its review of public comments on the human health and environmental risk
assessments for 2,4-DB and 2,4-DB-DMAS and is issuing its risk management decision.  The
Agency has decided 2,4-DB and 2,4-DB-DMAS are eligible for reregi strati on provided all
measures outlined in this document are implemented. 2,4-DB and 2,4-DB-DMAS are members
of the chlorophenoxy class of herbicides, which function by mimicking the action of auxins,
plant growth hormones. 2,4-DB and 2,4-DB-DMAS are used to control broadleaf weeds in
alfalfa, clover, soybean, peanuts, peppermint, spearmint, and birdsfoot trefoil. 2,4-DB is
manufactured as an acid and the dimethylamine salt, 2,4-DB-DMAS.  Available data indicate
that 2,4-DB-DMAS rapidly dissociates in moist soils and aquatic environments; therefore,
environmental risks were only assessed for 2,4-DB.  Environmental risks posed by use of 2,4-
DB-DMAS were considered to be equivalent to 2,4-DB. End-use products are formulated as
either a soluble, emulsifiable, or flowable concentrates (all of which are considered to be
liquids). 2,4-DB currently has tolerances of 0.2 ppm (40 CFR 180.331) in/on various
commodities  of the following crops: alfalfa, clover, mint hay, peanut, soybean, soybean hay, and
birdsfoot trefoil.  Based on available data, approximately 375,000 pounds of active ingredient are
used annually throughout the United States.

Overall Risk  Summary

       The Agency's human heath risk assessment indicates no risks of concern. An acute
dietary risk estimate was completed for females 13-49 years old, the only population subgroup
with an acute toxicity endpoint, and is below the Agency's level of concern.  Chronic dietary risk
estimates were provided for the general U.S. population and all population subgroups. All
chronic dietary risk estimates are below the Agency's level of concern. Estimated environmental
concentrations of 2,4-DB in drinking water from surface and ground water are below the
Agency's Drinking Water Level of Concern (DWLOC). When considering aggregate risk from
exposure to food and water (2,4-DB and 2,4-DB-DMAS do not have residential uses), risk
estimates are below the Agency's level of concern.

       To address  worker risks, short-term and intermediate-term occupational scenarios were
evaluated.  All short-term and intermediate-term margins of exposure (MOEs) are below the
Agency's level of concern when applicators are wearing baseline personal protective equipment
(PPE). Short-term and intermediate-term exposures for mixers and loaders are below the
Agency's level of concern when baseline PPE and chemical resistant gloves are worn.  All
MOEs for short-term inhalation exposure are below  the Agency's level of concern with baseline
respiratory equipment (no respirators). Post-application exposure to re-entry workers is possible.
Since 2,4-DB and 2,4-DB-DMAS are applied only once or twice per season it is anticipated that
exposure will be primarily short-term. Because there is no toxicity endpoint for short-term
dermal exposures, short-term post-application risks were not assessed.  The amine salt form of
2,4-DB is a Toxicity Category I eye irritant and labels will require protective eye-wear for post-
application exposures.

       The ecological risk assessment shows that  terrestrial plants are at the greatest risk from
2,4-DB and 2,4-DB-DMAS applications. Using the  highest application rate and the Texas alfalfa

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scenario, acute threatened and endangered species levels of concern were also exceeded for
freshwater fish.  Small and medium mammalian restricted use and Federally listed threatened
and endangered species levels of concern were exceeded using the highest application rates for
alfalfa.

Dietary Risk

       Acute and chronic dietary (food) risks are below EPA's level of concern for the general
U.S. population and all population subgroups.  An unrefined acute dietary risk assessment
(assumes 100% crop treated and tolerance level residues) was conducted using the Dietary
Exposure Evaluation Model (DEEM-FCID™) and Lifeline™ models for all of the supported
2,4-DB and 2,4-DB-DMAS food uses.  Risk estimates are provided for females 13-49 years old,
the only population subgroup with a toxicity endpoint of concern. Both models showed risk
estimates below  1% of the aPAD and therefore were not of concern.

       Chronic dietary risk estimates were also made using tolerance level residues and 100%
crop treated information.  This assessment concludes that for all included commodities, the
chronic risk estimates are below the Agency's level of concern for the general U.S. population
(<1% of the cPAD) and all population subgroups ({2.2% of the cPAD) when using the DEEM-
FCID™ or Lifeline™ models.  Risks, therefore, are not of concern and no mitigation measures
are necessary.

Drinking Water Risk

       Modeling for surface water and ground water concentrations was performed for three
different crop scenarios: alfalfa, peanuts, and soybeans. Several scenarios for each crop were
chosen to represent a geographically dispersed range  of water concentrations.  The scenario that
resulted in the highest modeled concentrations was the  Texas alfalfa scenario. The estimated
concentrations from this scenario were used to determine  drinking water risk as well as aggregate
risk.
       The Agency's DWLOC for acute exposure is 18,000 |ig/L.  The estimated drinking water
concentration (EDWC) used to assess acute dietary risk in surface water is 318.68  |ig/L and 0.51
|ig/L for ground water.  The DWLOC for chronic exposure is 1050 |ig/L for the general U.S.
population and 290 jig/L for infants less than one years old.  The EDWC used to assess chronic
(non-cancer) dietary risk from surface water is 72.40  |ig/L and 0.51 |ig/L for ground water. Both
the acute and chronic estimated concentrations are below  the DWLOCs for the general U.S.
population and all population subgroups. Risks, therefore, are not of concern and no mitigation
measures are necessary.

Residential Risk

       There are no registered residential uses and no use patterns that would cause residential
exposures of 2,4-DB or 2,4-DB-DMAS; therefore, no residential risk assessment was performed.

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Aggregate Risk

       The aggregate risk assessment integrates the assessments conducted for dietary and
drinking water exposure only since there are no registered residential uses of 2,4-DB or 2,4-DB-
DMAS. As noted above, the EDWCs for both surface water and ground water are below both
the acute and chronic DWLOC, respectively. Therefore, aggregate exposure to 2,4-DB and 2,4-
DB-DMAS from food and drinking water is below the Agency's level of concern. No mitigation
measures are  necessary to reduce risks from aggregate exposures.

Occupational Risk

       To address occupational exposure, short-term inhalation, and intermediate-term
combined dermal and inhalation risks were assessed. All short-term inhalation and intermediate-
term combined  dermal/inhalation margins of exposures (MOE) are below the Agency's level of
concern when workers are wearing baseline PPE (with mixers and loaders wearing chemical
resistant gloves).

       Post-application exposure to re-entry workers is possible because 2,4-DB and 2,4-DB-
DMAS can be broadcast applied. Since 2,4-DB and 2,4-DB-DMAS are applied only once or
twice per season, it is anticipated that exposure will be primarily short-term. Since an endpoint
could not be determined for short-term dermal exposures, short-term post-application risks were
not assessed and were determined not to be of concern. The amine form of 2,4-DB is a Toxicity
Category I eye irritant and labels will require protective eye-wear for early re-entry workers.

Ecological Risk

       The Agency conducted an ecological risk assessment to determine the potential impact of
2,4-DB and 2,4-DB-DMAS use on non-target terrestrial and aquatic organisms. The Agency
used modeling to evaluate ecological risks for 2,4-DB and 2,4-DB-DMAS.

       The Agency has determined that the risks posed by 2,4-DB and 2,4-DB-DMAS to most
mammalian, avian, plant, and aquatic species will be substantially mitigated by adhering to the
best aerial application practices and by prohibiting fine application sprays.  This mitigation will
require changes to current product labeling.

Terrestrial Plants
       Potential effects on non-target terrestrial plants are most likely to occur as a result of
spray drift and runoff from aerial and ground applications. Because 2,4-DB and 2,4-DB-DMAS
are non-selective herbicides, most plants that come in contact with the chemicals are potentially
at risk. In order to reduce risks to such plants current product labels will include droplet size
restrictions to prevent adverse affects from drift and runoff.

Aquatic Organisms
       Although 2,4-DB  and 2,4-DB-DMAS are practically non-toxic to slightly toxic to
freshwater fish, modeling simulations of the Texas alfalfa scenario indicate an exceedance
(RQ=0.09) of the acute threatened and endangered freshwater species LOG based on the one in
ten year peak estimated environmental concentration. This exceedance  is likely caused by the
high runoff vulnerability of the soil in that region.  Approximately 0.6% of the alfalfa production
can be attributed to Texas agriculture (USDA agricultural statistics). Alfalfa does not grow well

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in wet soil conditions and is predominantly grown in areas that have well-drained soil.  These
data suggest the Texas alfalfa scenario is a unique situation that is likely to represent marginal
site conditions for alfalfa production in Texas as well as locations in the U.S. production area
with similar site and environmental conditions.

       All acute freshwater RQs are not of concern to the Agency.  The Agency is requiring
additional studies, as listed in Section V of this document,  to better understand the potential risk
to estuarine and marine invertebrates.

       2,4-DB and 2,4-DB-DMAS did not meet the Agency's criteria for conducting a chronic
risk assessment.  Based upon the use pattern of 2,4-DB and 2,4-DB-DMAS (one to two
applications per year), a low acute toxicity profile and rapid degradation to 2,4-D, chronic risks
to freshwater, marine, and estuarine fish are not likely to occur.  In  addition, any potential
chronic exposures resulting from 2,4-D  will be addressed in the 2,4-D RED.

Birds
       Based on the acute toxicity studies submitted for birds, there is a large differential
between the acute toxicity when 2,4-DB is administered as a single gavage or when mixed in the
feed.  When 2,4-DB was administered orally, the acute level  of concern (LOG) was exceeded for
small birds feeding on short grass and threatened and endangered species LOCs for small and
medium birds feeding on short grass, tall grass,  and broadleaf plants/insects (LDso [Median
Lethal Dose] 1536 mg/kg-bw). When birds were fed 2,4-DB that was mixed in with their feed
the LCso values were greater than 5,000 ppm. It is highly unlikely 2,4-DB concentrations would
reach this level in the environment. Therefore, the Agency is not concerned with potential acute
risks to birds.

       Chronic avian studies are generally required when compounds are highly toxic to birds in
acute studies, are used repeatedly during a single season, have a long half-life in the soil and in
the environment, have high residues in sprayed crops and seed, and have the potential to
bioaccumulate in prey species.  2,4-DB  and 2,4-DB-DMAS do not  fulfill all of these
requirements.  Therefore, the Agency has placed the chronic  bird study on reserve.

Mammals
       Predicted residues from all uses  of 2,4-DB and 2,4-DB-DMAS are below the acute LOG.
When using average labeled application rates aerially applied at one and two applications a
season for the crop scenarios modeled (alfalfa, soybeans, and peanuts), acute  levels of concern
would not likely be exceeded for mammals consuming any of the crops treated with 2,4-DB or
2,4-DB-DMAS.

       When using maximum residues and two applications  at 1.7 Ibs a.e./A, chronic
mammalian LOCs are exceeded for the  following groups:

       - Small mammals feeding on short grass, tall grass, and broadleaf plants and insects; and

       - Medium-size mammals feeding on short grass.
                                           vn

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       No mammalian chronic levels of concern were exceeded for scenarios when considering
one or two applications at a rate of 0.40 or 0.45 Ibs a.e./A (average labeled rates) and a default
half-life of 35 days.

Threatened and Endangered Species
       The risk assessment for threatened and endangered species indicates that 2,4-DB and 2,4-
DB-DMAS exceed the threatened and endangered species LOCs for the use sites listed below.

       Levels of concern for Freshwater fish were exceeded using the Texas  alfalfa scenario by
drift and runoff.  These findings are based solely on the Agency's screening level assessment and
do not constitute "may affect" findings under the Endangered Species Act.

       Threatened and Endangered levels of concern were exceeded for small mammals feeding
on short grass when using the soybean (0.40 Ibs a.e./A, aerially applied two times per year with a
21-day application interval) and peanut  (0.45 Ibs a.e./A aerially applied two times per year with a
21-day application interval) application scenarios.  These findings are based solely on the
Agency's screening level assessment and do not constitute "may affect" findings under the
Endangered  Species Act.

       Additional exceedances occurred for mammals for the following scenarios:

       -Small mammals feeding on short grass, tall grass, and broadleaf plants/insects when
       single or multiple aerial applications are made to alfalfa;

       -Medium-size mammals feeding on short grass, tall grass and broadleaf plants/insects
       when multiple aerial applications are made to alfalfa and short grass, and broadleaf
       plants/insects when a single application is made on alfalfa; and

       -Small (15 grams) and medium (35 grams) mammals when using the alfalfa application
       scenario (1.7 Ibs a.e./A, two times per year with a 30-day application interval).

       The Agency has determined that no threatened and endangered mammals weighing less
than 1000 grams inhabit alfalfa fields. Therefore, small mammals will not be affected by use of
2,4-DB and 2,4-DB-DMASin alfalfa related application scenarios.

       Levels of concern were exceeded for small and medium size birds  feeding on short grass,
 tall grass, and broadleaf plants/insects when multiple aerial applications are made to alfalfa.  As
 discussed previously, it is highly unlikely that 2,4-DB or 2,4-DB-DMAS  concentrations would
 reach an effect level in the environment.  Therefore, the Agency has determined that threatened
 and endangered birds will not be affected by use of 2,4-DB  or 2,4-DB-DMAS.

       Levels of concern were exceeded at the highest application rate for plants. Until a
 species specific assessment for endangered plants is conducted, the mitigation strategy
 articulated in this document will serve  as an interim protection to reduce  the likelihood that
 listed species will be  exposed to 2,4-DB and 2,4-DB-DMAS.  Additionally, these exceedances
 are based solely on the Agency's screening level assessment and do not constitute "may affect"
 findings under the Endangered Species Act.

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Regulatory Decision

       The Agency has completed its review and has determined that the data are sufficient to
support reregi strati on of all supported products containing 2,4-DB and 2,4-DB-DMAS. The
Agency is issuing this RED for 2,4-DB and 2,4-DB-DMAS, as announced in a Notice of
Availability published in the Federal Register.  This RED document includes guidance and time
frames for making any necessary label changes for products containing 2,4-DB and 2,4-DB-
DMAS.

Summary of Mitigation Measures

       The Agency has determined that 2,4-DB and 2,4-DB-DMAS are eligible for
reregi strati on provided the mitigation measures described in this document and the label changes
included in Table 21 in Section V of the RED are implemented.

Occupational Risk
       Label changes are necessary to comply with updated Worker Protection Standard and
other regulations. Labels will be updated to require chemical resistant gloves and protective eye-
wear for early re-entry workers. A restricted entry interval (REI) of 48 hours is required because
2,4-DB-DMAS is a Toxicity Category I eye irritant.

Ecological Risk
       The Agency has concluded that the risks posed by 2,4-DB and 2,4-DB-DMAS to most
mammalian, avian, plant, and aquatic species will be substantially reduced by adhering to best
management practices for aerial applications. In addition, labels need to specify medium to
coarse droplet size and prohibit fine sprays.

Data Requirements

       Additional confirmatory data is required to complete the reregi strati on of 2,4-DB and 2,4-
DB-DMAS.  A complete list of data gaps is presented in Appendix B (Table of Generic Data
Requirements) as well as in Appendix E (the Generic Data Call-in) at the end of this document.
                                           IX

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I.      Introduction

       The Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) was amended in 1988
to accelerate the reregi strati on of products with active ingredients registered prior to November
1, 1984 and amended again by the Pesticide Registration Improvement Act of 2003 to set time
frames for the issuance of Reregi strati on Eligibility Decisions. The amended Act calls for the
development and submission of data to support the reregi strati on of an active ingredient, as well
as a review of all submitted data by the U.S.  Environmental Protection Agency (EPA or the
Agency). Reregi strati on involves a thorough review of the scientific database 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 or not the pesticide meets the
"no unreasonable adverse effects" criteria of FIFRA.

       On August 3, 1996, the Food Quality Protection Act of 1996 (FQPA) was signed into
law.  This Act amends FIFRA to require tolerance reassessment.  The Agency has decided that,
for those chemicals that have tolerances and  are undergoing reregi strati on, the tolerance
reassessment will be initiated through this reregi strati on process.  The  Act also requires that by
2006, EPA must review all tolerances in effect on the day before the date of the enactment of the
FQPA. FQPA also amends the Federal Food, Drug, and  Cosmetic Act (FFDCA) to require a
safety finding in tolerance reassessment based on factors including consideration of cumulative
effects of chemicals with a common mechanism of toxicity.  This document presents the
Agency's revised human health and ecological risk assessments;  and the Reregi strati on
Eligibility Decision (RED) for 2,4-DB and 2,4-DB-DMAS.

       2,4-DB and 2,4-DB-DMAS  are plant growth regulators and systemic herbicides
registered for use on alfalfa, clover, peanuts, soybeans, peppermint, spearmint, and trefoil.  2,4-
DB is currently manufactured as the acid (2,4-DB) and the dimethylamine salt (2,4-DB-DMAS
or 2,4-DB-DMA). Because of similarities in metabolism and degradation in animals, plants, and
the environment, 2,4-DB and 2,4-DB-DMAS were considered equivalent in the risk assessments.
An exception is that 2,4-DB-DMAS is a Toxicity Category I severe eye irritant, and 2,4-DB is a
Category III eye irritant.  The qualitative  nature of the 2,4-DB residue  in plant and livestock
commodities is adequately understood based on acceptable metabolism studies in alfalfa,
peanuts, soybeans, dairy cows and laying hens.  Because tolerances are currently expressed as
the combined residue of 2,4-DB and 2,4-DB-DMAS, the remainder of this document will only
refer to 2,4-DB (unless specifically  noted).

       The Agency has concluded that the FQPA Safety Factor for 2,4-DB  and 2,4-DB-DMAS
should be removed (equivalent to IX) based on: (1) exposure databases are complete for 2,4-DB
and 2,4-DB-DMAS and the risk assessment for each potential exposure scenario includes all
metabolites and/or degradates of concern and, (2) the risk assessment does not underestimate the
potential  risk for infants and children.

       Risks summarized in this document are those that result only from the use of  the active
ingredients 2,4-DB and 2,4-DB-DMAS.  The Food Quality Protection Act (FQPA) requires that
the Agency consider available information concerning the cumulative  effects of a particular
pesticide's residues and other substances  that have a common mechanism of toxicity. The

                                            1

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reason for consideration of other substances is due to the possibility that low-level exposures to
multiple chemical substances that cause a common toxic effect by a common toxic mechanism
could lead to the same adverse health effect that would occur at a higher level of exposure to any
of the substances individually. Unlike other pesticides for which EPA has followed a cumulative
risk approach based on a common mechanism of toxicity, EPA has not made a common
mechanism of toxicity finding for 2,4-DB and any other substances. 2,4-DB does not appear to
produce a toxic metabolite produced by other substances.  For the purposes of this action,
therefore, EPA has not assumed that 2,4-DB has a common mechanism of toxicity with other
substances. However, 2,4-DB produces the break-down product 2,4-D, which is a registered
active ingredient.  Risks posed to humans and the environment from 2,4-D  are addressed in the
2,4-D RED. For information regarding EPA's efforts to determine which chemicals have a
common mechanism of toxicity and to  evaluate  the cumulative effects of such chemicals, see the
policy statements released by EPA's Office of Pesticide Programs concerning common
mechanism determinations and procedures for cumulating effects from substances found to have
a common mechanism on EPA's website at http://www.epa.gov/pesticides/cumulative.

       This document presents the Agency's decision regarding the reregi strati on eligibility of
the registered uses of 2,4-DB. In an effort to simplify the RED, the information presented herein
is summarized from more detailed information which can be found in the technical supporting
documents for 2,4-DB referenced in this RED. The revised risk assessments and related addenda
are not included in this document, but are available in the Pub lie Docket at
http ://www. epa.gov/edocket.

       This document consists of six sections. Section I is the introduction. Section II provides
a chemical overview, a profile of the use and usage of 2,4-DB, and its regulatory history.
Section III, Summary of 2,4-DB Risk Assessment, gives an overview of the human health and
environmental assessments, based on the data available to the Agency.  Section IV, Risk
Management, Reregi strati on, and Tolerance Reassessment Decision, presents the reregi strati on
eligibility and risk management decisions. Section V, What Registrants Need to Do, summarizes
the necessary label changes based on the risk mitigation measures outlined in Section IV.
Finally, the Appendices list all use patterns eligible for reregi strati on, bibliographic information,
related documents and how to access them, and Data Call-In (DCI) information.

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II.     Chemical Overview

       A.     Regulatory History

       2,4-DB and 2,4-DB-DMAS have been registered for use on broadleaf weeds since 1958.
Currently, there are six products containing 2,4-DB (four technical products and two end-use-
product) and 15 products containing 2,4-DB-DMAS (one formulation intermediate and fourteen
end-use-products) registered under Section 3 of the Federal Insecticide, Fungicide, and
Rodenticide Act (FIFRA).  There is one Section 24© Special Local Need (SLN) registration for
2,4-DB-DMAS use on mint in Idaho.
       B.     Chemical Identification

             1.     Technical 2,4-DB
       Common name:     2,4-DB

       Chemical name:     4-(2,4-dichlorophenoxy) butyric acid, 4-(2,4-dichlorophenoxy)
                          butanoic acid

       Chemical Family:   Chlorophenoxy herbicide

       Empirical formula:  CioHioC^Os

       CAS Registry No.:   94-82-6

       Case number:       0196

       OPP Chemical Code: 030801

       Molecular weight:   2491

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      Trade name:
Bakker Herbicide, Butoxone Herbicide
      Basic manufacturer: Aceto Agricultural Chemicals Company, A. H. Marks &
                         Company Ltd., Atanor S.A., Drexel Chemical Company
                         (suspended).

      Technical 2,4-DB acid is in the form of flakes/powder and is off-white in color. 2,4-DB
has a melting point of 113.5-117.5 ° C. The water solubility of 2,4-DB is 46 ppm at 25 °C. 2,4-
DB has a vapor pressure of 7.1 x 10~7 mm Hg at 23.6 °C.

             2.     2,4-DB-DMAS (dimethylamine salt)
      Common name:    2,4-DB-DMAS

      Chemical name:    Dimethylamine 4-(2,4-dichlorophenoxy) butyrate

      Chemical Family:   Chlorophenoxy herbicide

      Empirical formula:  C^HnC^NOs

      CAS Registry No.:  2758-42-1

      Case number:       0196

      OPP Chemical Code: 030819

      Molecular weight:  2939

      Trade name:       Butoxone Herbicide, Butyrac, Hellion

      Formulation intermediate manufacturer: AH Marks & Company Ltd

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       Technical 2,4-DB-DMAS is a light orange to brown viscous liquid. 2,4-DB-DMAS is
miscible in water. 2,4-DB-DMAS has a melting point of 117-119°.  Water solubility and vapor
pressure values were not provided in supporting documents.
       C.     Use Profile

       The following is information on the currently registered uses of 2,4-DB and 2,4-DB-
DMAS  products and an overview of use sites and application methods. A detailed table of the
uses of 2,4-DB and 2,4-DB-DMAS eligible for reregistration is contained in Appendix A.

Type of Pesticide:   Herbicide (systemic)

Summary of Use:

Food:         2,4-DB is used on alfalfa, clover, peppermint, spearmint, peanuts, soybeans, and
              birdsfoot trefoil. 2,4-DB-DMAS is used on alfalfa, peanuts, and soybeans.


Non-Food:    Agricultural fallow/idle land (2,4-DB-DMAS)

Residential:    None

Target  Pests: Used to control several broadleaf weeds, including annual morning glory,
              pigweed, prickly lettuce, and velvetleaf.

Formulation Types: All end-use products are liquids; formulated either as soluble,
                    emulsifiable, or flowable concentrates.

Method and Rates of Application:

Equipment:    Applied either as a broadcast application or a directed spray by ground or aerial
              application.

Application Rates:   Maximum  labeled application rates for food/feed crops are 1.5 Ibs
                    a.i./A (2,4-DB) and 1.7 Ibs a.e./A (2,4-DB-DMAS). Rates of 2,4-DB-
                    DMAS are expressed as acid equivalents (a.e.) in this document to
                    compare application rates of the amine salt with the acid due to the nature
                    of the  amine salt to rapidly dissociate to 2,4-DB.

              Broadcast applications of 2,4-DB and 2,4-DB-DMAS are made during the early
              growing season, whereas directed sprays are  applied during late season.

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       D.    Estimated Usage of Pesticide

       Table 1 summarizes the best estimates available for the uses of 2,4-DB.  The estimate for
total domestic use (annual poundage) is 375,000. Peanuts is the leading commodity with 30% of
2,4-DB use and 35% of acres treated.  The table below is compiled from information provided by
the Biological and Economic Analysis Division's screening level usage  report. It does not
include all crops that 2,4-DB is used on.
Table 1.  2,4-DB Usage Summary of Major Use Sites
Site
Peanuts
Alfalfa
Soybeans
Lbs. Active
Ingredient Applied
(Weighted Average)
100,000
50,000
40,000
Percent Crop
Treated
(Likely Maximum)
40
<2.5
<2.5
Percent Crop Treated
(Weighted Average)
35
< 1
< 1

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III.    Summary of 2,4-DB Risk Assessments

       The purpose of this summary is to assist the reader by identifying the key features and
findings of these risk assessments, and to help the reader better understand the conclusions
reached in the assessments. The human health and ecological risk assessment documents and
supporting information listed in Appendix C were used to formulate the safety finding and
regulatory decision for 2,4-DB and 2,4-DB-DMAS. While the risk assessments and related
addenda are not included in this document, they are available from the OPP Public Docket and
may also be accessed on the Agency's website at http://epa.gov/dockets. Hard copies of these
documents may be found in the OPP public docket under docket number OPP-2004-0220.  The
OPP public docket is located in Room 119, Crystal Mall II, 1801 Bell Street, Arlington, VA, and
is open Monday through Friday, excluding Federal holidays, from 8:30 a.m.  to 4:00 p.m.

       A.    Human Health Risk Assessment

             1.     Toxicity of 2,4-DB

       A brief overview of the toxicity studies used for determining endpoints in the dietary risk
assessments are outlined below in Table 2. Further details on the toxicity of 2,4-DB can be
found in the "2,4-DB and 2,4-DB-DMA Toxicology Chapter for RED," dated July 20, 2004;
"2,4-DB Acute and Chronic Dietary Exposure Assessments for the Reregistration Eligibility
Decision," dated July 13, 2004;  "2,4-DB and 2,4-DB-DMA Human Health Risk Assessment,"
dated July 20, 2004; and "2,4-DB and 2,4-DB-DMA - Report of the Hazard Identification
Assessment Review Committee." These documents are available on Agency's website in the
EPA Docket at http://www/epa.gov/edockets.

       The Agency has reviewed all toxicity studies submitted for 2,4-DB and has determined
that the toxicological database is sufficient for reregi strati on. The studies have been submitted to
support guideline requirements.  Major features of the toxicology profile are presented below.
Both 2,4-DB and 2,4-DB-DMAS were shown  to be of low toxicity, with the exception of an eye
irritation study with 2,4-DB-DMAS, which was Toxicity Category I due to persistent corneal
opacity, iritis, and erythema.

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Table 2. Acute Toxicity of 2,4-DB Technical
Guideline No./ Study Type
870. 1 100 Acute Oral Toxicity
870. 1200 Acute Dermal Toxicity
870. 1300 Acute Inhalation Toxicity
870.2400 Acute Eye Irritation
870.2500 Acute Dermal Irritation
870.2600 Skin Sensitization
MRID
Number
00128854
0092159
0128854
41774001
0128854
00092160
0128854
43593904
Results
LD50 = 1935mg/kg
LD50 = 1715mg/kg
LD50 = > 2000mg/kg
LC50 > 2.3 mg/L
Eye irritation with complete clearing
by day 7
No irritation
Under review
Toxicity
Category
III
III
IV
III
IV
~
Table 3. Acute Toxicity of 2,4-DB-DMAS Technical (26% active ingredient)
Guideline No./ Study Type
870. 1 100 Acute Oral Toxicity
870. 1200 Acute Dermal Toxicity
(rabbit)
870. 1300 Acute Inhalation Toxicity
870.2400 Acute Eye Irritation
870.2500 Acute Dermal Irritation
870.2600 Skin Sensitization
MRID
Number
41224401
41224402
41370101
41958001
250871
43968911
Results
LD50 = 3583 mg/kg
LD50 > 2000 mg/kg
LC50 > 7.98 mg/L
Persistent corneal opacity, iritis,
erythema
Irritation score =1.99
Under review
Toxicity
Category
III
III
IV
I
IV
	
       Toxicity endpoints and doses were selected from rat studies rather than dog studies,
because of differences in the elimination of phenoxyacetic compounds in dogs compared to other
mammalian species. 2,4-DB is eliminated from the body through the kidneys and the rate of
urinary excretion is proportional to the plasma compound concentration. Therefore, species with
a longer excretion time will have higher compound concentrations in the blood.  Because of the
limited capacity of dogs to excrete 2,4-DB, higher blood levels are seen in the dog relative to
those seen in the rat.  Consequently, effects are seen at lower dose levels in the dog than in the
rat. When comparing the plasma half-life of 2,4-DB among species, the Agency has determined
that the rat is the most representative species to use in the risk assessment.  Because of the
similarities in metabolism and degradation in animals,  plants, and the environment, 2,4-DB and
2,4-DB-DMAS were considered of equivalent toxicity in the risk assessment. Toxicity endpoints
selected for 2,4-DB, both dietary and non-dietary, are presented in Tables 4 and  5 below.

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Table 4. Toxicological Endpoints for 2,4-DB (Dietary)
Exposure
Scenario
Acute Dietary
(Females 13-49
years of age)
Acute Dietary
(General
population
including infants
and children)
Chronic Dietary
(All populations)
Dose for Risk
Assessment and
Uncertainty Factor
NOAEL=62.5
mg/kg/day
UF=100
Acute RfD = 0.6
mg/kg/day
None
NOAEL= 3 mg/kg/day
UF= 100
Chronic RfD = 0.03
mg/kg/day
Special FQPA Safety
Factor and Level of
Concern
FQPA SF = IX
aPAD = acute RfD
FQPA SF
= 0.6 mg/kg/day
N/A
FQPA SF = IX
cPAD = chronic RfD
FQPA SF
= 0.03 mg/kg/day
Study and Toxicological Effects
(MRID #)
Rat developmental toxicity.
LOAEL = 125 mg/kg/day based on
skeletal variations/malformations,
reduction is size of eyes, post-
implantation loss. Endpoint based on a
single dose. (41382701)
No endpoint attributable to a single dose
from oral toxicity studies.
Chronic/carcinogenicity study in rats.
LOAEL = 30 mg/kg/day based on
decreased body weight gain and food
consumption in females. (40257501)
UF = uncertainty factor, FQPA SF = Special FQPA safety factor, NOAEL = no observed adverse effect level,
LOAEL = lowest observed adverse effect level, PAD = population adjusted dose, (a = acute, c = chronic) RfD =
reference dose, MOE = margin of exposure, N/A = Not Applicable

       No neurotoxicity studies were available for 2,4-DB or 2,4-DB-DMAS.  Clinical signs
suggestive of neurotoxicity occurred only at lethal doses.  The Agency concluded that these
effects were not indicative of neurotoxicity resulting from exposure to 2,4-DB and 2,4-DB-
DMAS. There was no indication of toxicity to the central nervous system in developmental
and/or reproductive studies.

       There was no indication of prenatal susceptibility  in the developmental rat studies with
2,4-DB and 2,4-DB-DMAS; with both chemicals,  developmental effects occurred at doses two-
fold higher than the doses that caused maternal toxicity. There was no prenatal susceptibility in
the rabbit developmental toxicity study with 2,4-DB because no developmental toxicity
occurred.

       There was qualitative, but not quantitative susceptibility in the 2-generation reproduction
study with 2,4-DB because offspring mortality occurred at a dose where parental toxicity was
less severe (decreased food consumption and  body weight, increased food conversion ratio,
increased  water consumption, organ weight changes, and macroscopic renal findings including
kidney pallor and cortical scarring). The parental and offspring NOAELs were 30 mg/kg/day.

       It was concluded that there was low concern for the qualitative susceptibility because the
offspring toxicity was well characterized and  was accompanied by maternal toxicity;  there was a
clear NOAEL/LOAEL for offspring toxicity;  and the endpoint selected for long-term risk
assessments (NOAEL = 3mg/kg/day in the chronic rat study) was considerably lower and would
address the concerns for offspring toxicity seen in this study. Therefore, there were no residual
uncertainties for pre- and/or post-natal toxicity.

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General Toxicity Observations
       In subchronic and chronic toxicity studies with 2,4-DB, some form of liver toxicity was
noted.  This included decreased liver function, increased liver weights, increased levels of liver
enzymes, hepatocyte hypertrophy, icterus, and pale livers.

       Kidney toxicity was noted in several studies.  Effects included changes in kidney weight,
kidney infarcts, tubular degeneration, and an increase in blood urea nitrogen concentrations.
       Other toxicity included decreased hematological parameters, changes in heart weight,
spots on the heart, and inflamed lacrimal glands (2,4-DB-DMAS).

       No systemic toxicity was noted in 21-day dermal studies in rabbits with either 2,4-DB or
2,4-DB-DMAS, although local dermal  irritation occurred in the dermal study with 2,4-DB-
DMAS.

Short-term Dermal
       An endpoint was not selected for short-term dermal exposures because there was no
systemic toxicity observed in the subchronic dermal toxicity study and there were no
developmental toxicity concerns.

Short-term Inhalation
       For short-term inhalation scenarios an oral NOAEL of 31 mg/kg/day was selected from
an oral rat developmental toxicity study during which decreased body weight, body weight gain,
food consumption, and clinical signs (emaciation, few feces) were observed in the dams with a
LOAEL of 62.5 mg/kg/day.

Intermediate-term Dermal and Inhalation
       For intermediate-term dermal and inhalation scenarios an oral NOAEL of 15.8  mg/kg/day
was selected from a subchronic oral toxicity study in  rats during which decreased body weight
gain, increased liver and kidney weight and microscopic changes were observed with a LOAEL
of 50 mg/kg/day.

Dermal Absorption
       A dermal absorption factor of 23% was selected for converting dermal exposures to oral
equivalent doses. This value was derived from a dermal absorption study in rats.

Carcinogenicity Classification
       The Agency has concluded that 2,4-DB is classified as "not likely to be a human
carcinogen"; therefore, no carcinogenic dietary analysis is required.

Mutagenicity Potential
       The Agency concluded that there is not a concern for mutagenicity resulting from
exposure to 2,4-DB or 2,4-DB-DMAS.

Endocrine Disruption Potential
       EPA is required under the Federal Food Drug and Cosmetic Act (FFDCA), as amended
by FQPA, to develop a screening program to determine whether certain substances (including all
pesticide active and other ingredients) "may have an effect in humans that is similar to an effect
produced by a naturally occurring estrogen, or other such endocrine effects as the Administrator
may designate." 2,4-DB has properties that could indicate Endocrine Disrupting Chemical

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(EDC) properties. These include decreased body weights and altered liver function in mice
exposed to 2,4-DB.  When the appropriate screening and/or testing protocols being considered
under the Agency's Endocrine Disrupting Screening Program (EDSP) have been developed, 2,4-
DB may be subjected to additional screening and/or testing to better characterize effects related
to endocrine disruption.

              2.     FQPA Safety Factor

       The FQPA Safety Factor (as required by the Food Quality Protection Act of 1996) is
intended to provide an additional 10-fold safety factor (10X), to protect for special sensitivity in
infants and children to specific pesticide residues in food, drinking water, or residential
exposures, or to compensate for an incomplete database.  The FQPA Safety Factor has been
removed (i.e., reduced to IX) for 2,4-DB based on: (1) exposure databases are complete for 2,4-
DB and 2,4-DB-DMAS and the risk assessment for each potential exposure scenario includes all
metabolites and/or degradates of concern and, (2) the risk assessment does not underestimate the
potential risk for infants and children. The FQPA Safety Factor assumes that the exposure
databases (food, drinking water,  and residential) are complete, the risk assessment for each
potential exposure scenario includes all metabolites and/or degradates of concern, and does not
underestimate the potential risk for infants and children.  These criteria have been met for 2,4-
DB and 2,4-DB-DMAS. Based on the analysis of submitted developmental toxicity studies, the
Agency determined that no special FQPA Safety Factor was needed since there were no residual
uncertainties for pre- and/or postnatal toxicity.
              3.     Population Adjusted Dose (PAD)

       Dietary risk is characterized in terms of the Population Adjusted Dose (PAD), which
reflects the reference dose (RfD), either acute or chronic, that has been adjusted to account for
the FQPA Safety Factor (SF). This calculation is performed for each population subgroup. A
risk estimate that is less than 100%  of the acute or chronic PAD is not of concern.

                    a.     Acute PAD

       Acute dietary risk for 2,4-DB is assessed by comparing acute dietary exposure estimates
(in mg/kg/day) to the acute Population Adjusted Dose (aPAD). Acute dietary risk is expressed
as a percent of the aPAD. The aPAD is the acute reference dose (0.6 mg/kg/day) modified by
the FQPA safety factor.  The acute reference dose was derived from a developmental toxicity
study in rats in which both the NOAEL (62.5 mg/kg/day) and the LOAEL (125 mg/kg/day) were
determined. Acute dietary exposure was estimated only for females ages  13-49 because
available studies did not show a toxicity endpoint attributable to a single exposure  for the general
population. The 2,4-DB aPAD is 0.6 mg/kg/day based on a reference dose of 0.6 mg/kg/day,
and incorporating the FQPA safety factor of IX.

                    b.     Chronic PAD

       Chronic dietary risk for 2,4-DB is assessed by comparing chronic  dietary exposure
estimates (in mg/kg/day) to the chronic Population Adjusted Dose (cPAD).  Chronic dietary risk
is expressed as a percent of the cPAD.  The cPAD is the chronic reference dose (0.03 mg/kg/day)

                                           11

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modified by the FQPA safety factor.  The cPAD was derived from a combined rat
chronic/carcinogenicity study, in which 2,4-DB was administered to rats for 24 months to test the
carcinogenic and chronic toxicity potential of the chemical. The chronic LOAEL was
determined to be 30 mg/kg/day based on decreased body weight and food consumption in female
rats. Consideration was given to using an endpoint from the chronic dog study.  As previously
discussed, because the dog is believed to be more sensitive to toxicity from 2,4-DB than the rat,
the Agency has determined it is appropriate to use endpoints from available rat studies to assess
potential risks in the risk assessment. The 2,4-DB cPAD is 0.03 mg/kg/day based on a reference
dose of 0.03 mg/kg/day, which includes the incorporation of the FQPA safety factor (IX) for the
overall U.S. population or any population subgroups.

              4.     Exposure Assumptions

       Acute and chronic dietary exposure assessments were conducted using the Dietary
Exposure Evaluation Model software with the Food Commodity Intake Database (DEEM-
FCID™), Version 1.3 and the Lifeline™ Model Version 2.0.  Both models use food
consumption data from the USDA's Continuing Surveys of Food Intakes by Individuals (CSFII)
from 1994-1996 and 1998. The CSFII data are based on the reported food consumption by more
than 20,000 individuals over two non-consecutive survey days. For acute exposure estimates,
individual one-day food consumption data are used on an individual-by-individual basis. For the
chronic exposure assessment, consumption data are averaged for the entire U.S. population and
within population subgroups.
             5.     Dietary (Food) Risk Assessment

                    a.     Acute Dietary Risk

       Generally, a dietary risk estimate that is less than 100% of the acute or chronic PAD does
not exceed the Agency's risk concerns. A summary of acute and chronic risk estimates are
shown in Tables 5 and 6.

       A screening-level (tolerance level and 100% crop treated [% CT] were assessed) acute
dietary risk assessment was conducted for all supported 2,4-DB food uses.  Dietary risk estimates
are provided for females 13-49 years old, the only population subgroup for which an endpoint
was selected.  The results using the DEEM-FCID1  and Lifeline M models showed risk
estimates at the 95th percentile of exposure to be <1% of the aPAD regardless of the model used
and therefore were not of concern.

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Table 5. Acute Dietary Exposure and Risk
Population
Subgroup
Females
13 -49 years
old
Acute Dietary
(95th Percentile)
DEEM-FCID1M
Dietary
Exposure
(mg/kg/day)
0.000467
% aPAD
0.08
LifelineTM
Dietary Exposure
(mg/kg/day)
0.000614
% aPAD
0.102
                    b.     Chronic (Non-cancer) Dietary Risk

       Tolerance level residues and 100% CT assumptions were also used to determine the
screening-level chronic dietary exposure and risk estimates. This assessment concluded that for
all included commodities, the chronic risk estimates are below the Agency's level of concern for
the general U.S. population (<1% of the cPAD) and all population subgroups (<2.2% of the
cPAD for infants less than 1 year old, the most highly exposed subgroup) when using DEEM-
FCIDTM and Lifeline™ models.

Table 6. Chronic Dietary Exposure and Risk
Population
Subgroup*
General U.S.
Population
All Infants
(< 1 year old)
Children
1-2 years old
Children
3-5 years old
Children
6- 12 years old
Youth
13-19 years old
Adults
20-49 years old
Adults
50+ years old
Females
13 -49 years old
Chronic Dietary
DEEM-FCID1M
Dietary Exposure
(mg/kg/day)
0.000242
0.000661
0.000548
0.000535
0.000373
0.000238
0.000197
0.000153
0.000185
% cPAD
0.8
2.2
1.8
1.8
1.2
0.8
0.7
0.5
0.6
LifelineTM
Dietary Exposure
(mg/kg/day)
0.000232
0.000554
0.000539
0.000505
0.000346
0.000224
0.000198
0.000191
0.000228
% cPAD
0.8
1.8
1.8
1.7
1.2
0.7
0.7
0.6
0.8
*The values for the highest exposed population for each type of risk assessment are bolded
                                           13

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                    c.     Dietary Risk from Drinking Water

       Drinking water exposure to pesticides can occur through ground and surface water
contamination.  In assessing drinking water risks, EPA considers acute (one day), chronic (long-
term) and, if applicable, cancer (overall) exposure, and uses either modeling or monitoring data,
if available, to estimate those risks.  To determine the maximum contribution from water allowed
in the diet, EPA first looks at how much of the overall allowable risk is contributed by food and
then calculates a "drinking water level of comparison"  (DWLOC) to determine whether modeled
or monitored exposure estimates exceed the allowable risk level.  Estimated drinking water
concentrations (EDWCs) that are above the corresponding DWLOC exceed the Agency's level
of concern.

       No degradation products of 2,4-DB were included in this assessment. The major
degradate of 2,4-DB is 2,4-D.  2,4-D is a registered active ingredient.  2,4-D was found at a
maximum of 5.0-15% of applied 2,4-DB in soil dissipation studies. The annual use of 2,4-DB is
less than 1% of the annual use of 2,4-D (375,00 pounds vs.  46 million pounds).  According to
data from the U.S.  Geographical Survey reported in the Environmental Fate and Effects Revised
Risk Assessment for 2,4-DB dated July 20, 2004, 2,4-D is used throughout the entire country.
The use of 2,4-DB is  restricted to discrete areas of the country, which overlap areas of 2,4-D  use.
Therefore, drinking water exposure to  2,4-D will be addressed in the 2,4-D RED.

Because 2,4-DB-DMAS rapidly dissociates in water to form 2,4-DB, the Agency used
environmental fate data for 2,4-DB as  bridging data for 2,4-DB-DMAS.  The mobility of 2,4-DB
in mineral soils was classified as very  mobile to moderately mobile.

                           i.     Surface Water

       Modeling: Estimated surface water (drinking water) concentrations are based on two
models coupled together, PRZM and EXAMS.  The PRZM/EXAMS modeling was performed
with index reservoir scenarios and percent cropped area adjustment factors.  The PRZM/EXAMS
combined model provides a Tier II assessment that includes refined assumptions.  The estimated
drinking water concentrations (EDWCs) have been calculated for two types of dietary risk
assessment: (1) acute or peak concentration; and (2) non-cancer chronic concentration.
Modeling of surface water concentrations was performed using alfalfa, peanuts, and soybean
application scenarios.  Several scenarios for each crop were chosen to represent a geographically
dispersed range of surface water concentrations in areas representative of where 2,4-DB is  used.
The Agency calculated 318.68 |ig/L for the 1 in 10 year peak  concentration (acute) and 72.40
Hg/L for the 1 in 10 year annual daily  average concentration (chronic non-cancer).  These
estimated concentrations were from the Texas alfalfa crop scenario. The acute DWLOC is
18,000 |ig/L for women ages 13-49 (the only group with an endpoint of concern). The chronic
DWLOC for the general population is  1,050 |ig/L and 290 |ig/L for infants less than one year of
age.  Since the EDWCs are less than the DWLOCs, both acute and chronic estimated
concentrations of 2,4-DB in surface water are below the Agency's level  of concern.

       Monitoring:  Monitoring data were available for 2,4-DB from the United States
Geological Survey (USGS) National Water-Quality Assessment (NAWQA) Program, USEPA
STOrage and RETrieval System for Water and Biological Monitoring Data (STORET), and from

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the USGS Reservoir and Finished Water Pilot Monitoring Study. Frequency of these detections
was not sufficient to calculate average concentrations of 2,4-DB.

       The highest annual maximum concentration of 2,4-DB detected in surface water
monitoring data was 0.83 jig/L from the NAWQA data at Reed Wash near Mack, Colorado, with
the next highest being 0.81 |ig/L from the STORET data at Big Limestone Creek near
Limestone, Tennessee. Both monitored concentrations of 2,4-DB are below the Agency's level
of concern.

                           ii.      Ground Water

       Modeling: The SCI-GROW model was used to estimate potential ground water
concentrations.  SCI-GROW is a screening tool, or Tier 1 model for ground water.  It is based on
a regression approach which relates the concentrations found in ground water in Prospective
Ground Water studies to aerobic soil metabolism rate and soil-water partitioning properties of
the chemical.  The SCI-GROW model estimated the concentration of 2,4-DB in drinking water
from shallow  ground water sources to be 0.51 ng/L.  Because the EDWC of 0.51 |j,g/L is less
than the acute DWLOC for women 13-49 (18,000  ng/L), the chronic DWLOC for the general
population (1,050 |ig/L),and the chronic DWLOC  for infants less than one year (209 ng/L);
concentrations of 2,4-DB in ground water are not of concern to the Agency.  This concentration
can be used for both acute and chronic exposure estimates, and is below the Agency's level of
concern.

        Monitoring:  2,4-DB was reported once in the NAWQA ground water data at a
concentration of 0.06 |J,g/L and was not detected in STORET data.  This value is below the
Agency's level of concern for both acute and chronic (non-cancer) risks.

       For more information on drinking water risks and the calculations of the DWLOCs, see
the Water Exposure section of the "Human Health Risk Assessment (Revised)," dated July 20,
2004.

             6.     Aggregate Risk

       The Food Quality Protection Act amendments to the  Federal Food, Drug, and Cosmetic
Act (FFDCA, Section 408(b)(2)(A)(ii)) require "that there is a reasonable certainty that no harm
will result from aggregate exposure to pesticide  chemical residue, including all anticipated
dietary exposures and other exposures for which there are reliable information."  Aggregate
exposure will  typically include exposures from food, drinking water, residential uses of a
pesticide, and other non-occupational sources of exposure. Since there are no residential uses for
2,4-DB, aggregate assessments included exposure  to food and drinking water only.

                    a.     Acute Aggregate Risk

       An acute DWLOC was calculated only for females 13-49 years of age because this was
the only population subgroup for which an acute dietary endpoint was  selected. Results using
the DEEM-FCIDTM and Lifeline™ models showed risk estimates at the 95th percentile of
exposure to be less than one percent of the aPAD for this population subgroup, and therefore
were not of concern.  As shown in Table 7, the DWLOC is 18,000 |ig/L and the EDWC is 0.51
                                           15

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|ig/L for ground water and 318 |ig/L for surface water. Taking into consideration the two
components of aggregate exposure discussed above, acute aggregate risk estimates are below the
Agency's level of concern.

Table 7. Acute Aggregate Exposure
Population
Subgroup


Females 13-49
Acute
PAD
mg/kg/day

0.6 mg/kg
Food
Exposure
mg/kg/day

0.000467
Target Max
Water
Exposure
mg/kg/day
0.600
Ground
Water
EDWC
|Ig/L
0.51
Surface
Water
EDWC
Jlg/L
318.68
DWLOC
|Ig/L


18,000
                    b.     Chronic Aggregate Risk

       Chronic aggregate risk was considered by aggregating chronic food and drinking water
exposure.  For chronic dietary risk, the most highly exposed population subgroup was all infants
less than one year old. For this population subgroup, the chronic dietary exposure was less than
2.2% of the cPAD. As shown in Table 8, the DWLOC for this subgroup is 290 |ig/L and the
EDWC for ground water is 0.51 |ig/L for ground water and is 72 |ig/L for surface water.
Because the EDWCs are below the DWLOC, aggregate dietary and drinking water exposure is
below the  Agency's level of concern.
Table 8. Chronic Aggregate Exposure
Population
Subgroup
U.S. Population
(total)
All infants
(< 1 year)
Chronic
PAD
mg/kg/day
0.03
0.03
Food
Exposure
mg/kg/day
0.000242
0.000661
Target Max
Water
Exposure
mg/kg/day
0.030
0.029
Ground
Water
EDWC
Jlg/L
0.51
0.51
Surface
Water
EDWC
|Ig/L
72.40
72.40
DWLOC
Jlg/L
1050
290
              7.     Occupational Risk

       Workers can be exposed to a pesticide through mixing, loading, and/or applying a
pesticide, or re-entering treated sites. Occupational handlers of 2,4-DB and 2,4-DB-DMAS
include workers in agricultural areas and workers in right-of-way areas.  Occupational risk for all
of these potentially exposed populations is measured by a Margin of Exposure (MOE) which
determines how close the occupational exposure comes to a No Observed Adverse Effect Level
(NOAEL) from toxicological studies. In the case of 2,4-DB, MOEs greater than 100 are not of
concern to the Agency. This MOE includes the standard safety factors of 10X for intraspecies
variability (i.e. differences among humans) and 10X for interspecies variability (differences
between humans and animals).  For workers entering a treated site, MOEs are calculated for
each day after application to determine the minimum length of time required before workers can
safely re-enter.

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       Occupational risk is assessed for exposure at the time of application (termed "handler"
exposure) and is assessed for exposure following application, or post-application exposure.
Application parameters are generally defined by the physical nature of the formulation (e.g.,
formula and packaging), by the equipment required to deliver the chemical to the use site, and by
the application rate required to achieve an efficacious dose. Post-application risk is assessed for
re-entry activities such as scouting, irrigating, pruning, and harvesting, and is based primarily on
dermal exposure estimates.  Occupational risks were assessed only for exposures from liquid
formulations. Although there are several forms of 2,4-DB and 2,4-DB-DMAS products, all are
considered liquids for the purpose of occupational exposure.

       For more information on the  assumptions and calculations of potential risk of 2,4-DB to
workers, see the Occupational Exposure Assessment (Section 4.6) in the "Human Health Risk
Assessment (Revised)," dated July 20, 2004 and the "Revised Occupational and Residential
Exposure and Risk Assessment for the RED Document," dated July 19, 2004.
                    a.     Occupational Toxicity

       Because 2,4-DB and 2,4-DB-DMAS are very similar in their toxicity profiles, one set of
endpoints can be used to evaluate occupational risks for both forms. Table 9 provides a listing of
the toxicological endpoints used in the 2,4-DB occupational risk assessment.
Table 9: Toxicological Endpoints Used for Occupational Risk Assessment
Exposure
Scenario
Dermal
Short-term
Dermal
Intermediate-term
Inhalation
Short-term
Inhalation
Intermediate-term
Dermal Absor ption
Factor
Dose or Factor Used in
Risk Assessment
None
OralNOAEL= 15.8
mg/kg/day*
NOAEL = 31 mg/kg/day+
OralNOAEL = 15.8
mg/kg/day
23 percent of the oral dose
Study and Toxicological Effects
(MRID #)
Quantification not required. There is no systemic toxicity
via the dermal route and there are no developmental
toxicity concerns.
Subchronic rat toxicity. LOAEL = 50 mg/kg/day based
on decreased body weight gain, increased relative
liver/kidney weight and microscopic changes.
(00104739)
Rat Developmental toxicity. LOAEL = 62.5 mg/kg/day
based on decreased maternal body weight, body weight
gain, and food consumption, and clinical signs
(emaciation, fewfeces). (42536101, 4259201, 41382701)
The same study and endpoint was used as for
intermediate -term dermal exposure (see above).
Dermal absorption study in rats with 2,4-DB DMAS
(44729501).
* Since an oral NOAEL was selected, a dermal absorption factor should be used in route to route extrapolation.
+ Inhalation absorption is assumed to be equivalent to oral absorption (100 percent default value).
                                           17

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                    b.     Occupational Handler Exposure

       Occupational handler risk estimates have been assessed for both short- and intermediate-
term exposure durations. Because 2,4-DB is typically applied once or twice per season it is
anticipated that 2,4-DB exposures would be primarily short-term. Because a toxicity endpoint
for short-term dermal exposures was not determined, only short-term inhalation exposures to
handlers were assessed.  To address the limited possibility that intermediate exposures could
occur, intermediate-term risks were assessed using the intermediate-term oral endpoint and
dermal absorption factor of 23%.

       The Agency has determined that there are potential exposures to individuals who mix,
load, apply, and otherwise handle 2,4-DB during the usual use patterns associated with the
pesticide's use.  Based on the use patterns, the following exposure scenarios were assessed:

(1)    mixing/loading liquid formulations;
(2)    applying sprays by aerial application;
(3)    applying sprays with ground boom equipment;
(4)    flagger for aerial applications.
              c.     Occupational Handler Risk Summary

       Occupational Handler Exposure Assumptions
       Exposure analyses were performed using the Pesticide Handlers Exposure Database
(PHED) as tabulated in the PHED Surrogate Exposure Guide of August 1998.  A description of
PHED is included in Appendix A of the "Revised Occupational and Residential Exposure and
Risk Assessment for the Reregi strati on Eligibility Decision (RED) Document".  Handler
exposures are also calculated in Appendix A. Only inhalation exposures were assessed for short-
term risks because there  is no dermal endpoint for short-term exposures. Both inhalation and
dermal exposures were assessed for intermediate-term risks and these exposures were combined
because the endpoints were based on the same study. The target MOE is 100 for both short and
intermediate-term exposures. Scenarios with an MOE less than 100 indicates a risk of concern.

       The following assumptions and factors were used in order to complete the exposure and
risk assessments for occupational handlers:

       • The average work day is 8 hours;

       • The daily acreage treated was taken from EPA Science Advisory Council for Exposure
       Standard Operating Procedure #9 "Standard Values for Daily Acres Treated in
       Agriculture," revised July 5, 2000.  These values are listed in Table 7 of the Occupational
       and Residential Risk Assessment;

       • The maximum label application rates are used to assess short-term risks because it is
       possible that these rates would be used for one to thirty consecutive days.

       • The average application rates were  used to assess intermediate-term risks because it is
       highly unlikely that maximum label rates would be used for more that thirty consecutive
       days;

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       • A body weight of 70 kg was assumed because the endpoint is not gender specific;

       • The inhalation absorption rate is 100% and dermal absorption rate is 23%;

       • Baseline PPE includes long sleeve shirts, long pants and no gloves or respirator;

       • Single Layer PPE includes baseline PPE with chemical resistant gloves;

       • Aerial applicators utilize closed cockpit aircraft and do not wear chemical resistant
       gloves; and

       • All three formulations of 2,4-DB and 2,4-DB-DMAS are considered liquids when
       determining occupational exposure and risk.
Summary of Risk Estimates for Handlers
       All of the short-term inhalation MOEs exceed 100 with baseline PPE. Respiratory
protection is not needed. All of the intermediate-term mixer/loader combined MOEs exceed 100
if single layer PPE (i.e. baseline clothing with chemical resistant gloves) is worn. The
intermediate-term MOEs for applicators also exceed 100 with baseline work clothing.
Intermediate-term handler exposures are less likely to occur because 2,4-DB is applied only once
or twice per season.  Metabolism studies in rats also indicated that most of the 2,4-DB dose is
excreted within 24 hours through the urine and feces.  The MOEs for handlers are summarized in
Tables 10 and 11.
Table 10. Occupational Handler Short-Term Risk Summary
Exposure Scenario
Mix/Load Liquids for
Aerial
Mix/Load Liquids for
Ground boom
Aerial Application
Ground boom Application
Crop
Alfalfa, Clover
Mint
Peanuts (SW), Soybeans
Peanuts (SE)
Alfalfa, Clover, CRPA
Mint
Peanuts (SW), Soybeans
Peanuts (SE)
Alfalfa, Clover
Mint
Peanuts (SW), Soybeans
Peanuts (SE)
Alfalfa, Clover, CRPA
Mint
Peanuts (SW), Soybeans
Peanuts (SE)
Label Application
Rate (Ib a.e./acre)
1.5
0.75
0.4
0.25
1.5
0.75
0.4
0.25
1.5
0.75
0.4
0.25
1.5
0.75
0.4
0.25
Acres/Day
1200
1200
1200
1200
200
200
200
200
1200
1200
1200
1200
200
200
200
200
Baseline
Inhalation
MOE
1,000
2,000
3,800
6,000
6,000
12,000
23,000
36,000
18,000
35,000
66,000
110,000
9,800
20,000
37,000
59,000
                                           19

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Exposure Scenario
Mix/Load Liquids for
Aerial
Flag Aerial Application
Crop
Alfalfa, Clover
Mint
Peanuts (SW), Soybeans
Peanuts (SE)
Alfalfa, Clover
Mint
Peanuts (SW), Soybeans
Peanuts (SE)
Label Application
Rate (Ib a.e./acre)
1.5
0.75
0.4
0.25
1.5
0.75
0.4
0.25
Acres/Day
1200
1200
1200
1200
1200
1200
1200
1200
Baseline
Inhalation
MOE
1,000
2,000
3,800
6,000
3,400
6,900
13,000
21,000
Table 11. Occupational Handler Intermediate-Term Risk Summary
Exposure Scenario
Mix/Load Liquids for
Aerial


Mix/Load Liquids for
Ground boom


Aerial Application


Ground boom Application


Flag Aerial Application


Crop
Alfalfa, Clover
Mint
Peanuts
Soybeans
Alfalfa, Clover
Mint
Peanuts
Soybeans
Alfalfa, Clover
Mint
Peanuts
Soybeans
Alfalfa, Clover
Mint
Peanuts
Soybeans
Alfalfa, Clover
Mint
Peanuts
Soybeans
Average
Application Rate
(Ib a.e./acre)
0.55
0.75
0.24
0.13
0.55
0.75
0.24
0.13
0.55
0.75
0.24
0.13
0.55
0.75
0.24
0.13
0.55
0.75
0.24
0.13
Acres/
Day
1200
1200
1200
1200
200
200
200
200
1200
1200
1200
1200
200
200
200
200
1200
1200
1200
1200
Baseline
Combined
MOE
2.5
1.8
5.7
11
15
11
34
64
1400
1000
3200
5800
2500
1900
5800
11000
580
430
1300
2500
Single Layer
Combined
MOE1
260
190
590
1100
1500
1100
3600
6600
NA
NA
NA
NA
2500
1900
5800
11000
540
400
1200
2300
 Baseline plus chemical resistant gloves
Values in bold are of concern to the Agency
                     d.     Occupational Post-application Risk Summary

       Post-application exposure to re-entry workers is possible because 2,4-DB can be applied
foliarly, on the surface of the labeled crops.  Post-application activities include irrigation and
scouting, which can result in dermal exposures.  The exposures  were assessed using the
intermediate-term dermal endpoint, standard assumptions and average daily rates.  All of the
post-application MOEs are above the target MOE of 100 on Day 0.  It should be noted, however,

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that 2,4-DB-DMAS is a Toxicity Category 1 eye irritant which requires a 48-hour REI according
to the Worker Protection Standard (WPS).

                     e.     Human Incident Data

       In evaluating incidents to humans, the Agency reviewed reports from the National Poison
Control Centers (PCC), the Agency's Office of Pesticide Program's Incident Data System (IDS),
California Department of Pesticide Regulation, and the National Pesticide Telecommunications
Network (NPTN).

       There were a total of 7 reported incidents due to exposure to 2,4-DB. The majority of
incidents resulted from misuse and exposure resulted in some form of dermal irritation.

       The OPP Incident Data System reported 2 separate incidents. The first occurred in 1991,
when 2,4-DB was misused on soybeans resulting in plant damage and health effects. No further
information concerning the health effects was reported.  The second incident occurred in 1993,
when a hose broke and a worker was sprayed in the face.  The worker was hospitalized the
following day after experiencing unspecified symptoms. No further information concerning the
case was reported.

       Five exposure incidents were reported to Poison Control Centers from 1993-2001. Three
of the five exposures reported some type of dermal reaction. The most serious case reportedly
involved misuse with symptoms of flushed skin and blisters. One other case reported rash and
another reported swelling and skin irritation. Two of the cases were seen in a health care facility
and none were hospitalized.
B.     Environmental Risk Assessment

       A summary of the Agency's environmental risk assessment is presented below. 2,4-DB
has several registered use sites: alfalfa, soybeans, peanuts, clover, peppermint, spearmint, and
trefoil. The following risk characterization is intended to describe the magnitude of the
estimated environmental risks for 2,4-DB use sites and any associated uncertainties.

       For detailed discussions of all aspects of the environmental risk assessment, see the
"Environmental Fate and Effects Division Revised Risk Assessment for 2,4-DB and 2,4-DB-
DMAS Reregi strati on Eligibility Document (Revised)", dated December 13, 2004.

              1.     Environmental Fate and Transport

       Available data indicate that 2,4-DB-DMAS rapidly dissociates in moist soils and aquatic
environments, therefore, ecological risks were only assessed for 2,4-DB. Consequently,
application rates are expressed in pounds of acid equivalents (a.e.) rather than pounds of active
ingredient (a.i.) per acre.  Bridging data were submitted by the registrant demonstrating that 2,4-
DB-DMAS, a salt, rapidly dissociates when exposed to moisture to form 2,4-DB and
dimethylamine. It is very important to note,  however, that 2,4-DB-DMAS could persist under
dry soil conditions.  In soil environments 2,4-DB dissipation appears to be dependent on leaching
and on oxidative microbial-mediated degradation to CO2 . In mineral soils 2,4-DB's metabolism

                                           21

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half-life is 24.5 days. Additionally, 2,4-DB was found to be stable to anaerobic metabolism in
mineral soils, meaning 2,4-DB will not undergo biodegradation in anaerobic soils.  The mobility
of 2,4-DB in mineral soils was classified as very mobile to moderately mobile. The main path of
dissipation in aquatic environments is photodegradation.  The half-life for 2,4-DB in aquatic
environments ranges from 6.3 to 17.2 days in different pH solutions.

       The primary route of dissipation is transformation with the major transforming products
being 2,4-D (with a maximum concentration of 5.0-15% of the applied) and 2,4-D Phenol (2,4-
DP) (with a maximum concentration of 5.0-27.3 % applied). In the top  soil layer (0-15 cm) 2,4-
DB and its transformation products were detected.

       Studies indicated the dissipation of 2,4-D depends on oxidative microbial-based
mineralization, photodegradation in water, and leaching.  2,4-D has a low binding affinity in
mineral soils and sediment.  The major volatile  degradate of 2,4-D in soil and aquatic
environments was COz . The mobility of 2,4-D in supplemental soil studies was classified as
intermediately mobile to very mobile in "sieved" mineral soils. Aged radio labeled  residues of
2,4-D appeared to be immobile in supplemental soil column studies. For a complete discussion
of 2,4-D see the "Environmental Fate and Effects Division's Risk Assessment for the
Reregi strati on Eligibility Document for 2,4-D", dated May 24, 2004.  This document is available
via the Internet at http://www.epa.gov/edockets.

       2,4-DB has a vapor pressure of 6.37 x 10"5 Torr.  2,4-DB is not expected to be volatile
under normal use conditions.  Laboratory volatility studies are requested on a case by case basis
for compounds with vapor pressure of 10"4 to 10"6 Torr. These data are reserved  at this time.

       2,4-DB is not expected to bioaccumulate because it is ionic (anion under  most
environmental conditions).  The ionic nature of the compound will increase the water soluble
nature of the compound and hence will lower the octanol to water coefficient.  Octanol is an
organic solvent that is used as a surrogate for natural organic matter.  A low octanol to water
coefficient means that 2,4-DB will not accumulate in the octanol, and, therefore, is not likely to
bioaccumulate.

              2.     Ecological Risk

       The Agency's ecological risk assessment compares toxicity endpoints from ecological
toxicity studies to estimated environmental concentrations (EECs) based on environmental fate
characteristics and pesticide use data. To evaluate the potential risk to non-target organisms
from the use of 2,4-DB products, the Agency calculates a Risk Quotient (RQ), which is the ratio
of the EEC to the most sensitive toxicity endpoint values, such as the median lethal  dose (LDso)
or the median lethal concentration (LCso).  These RQ values are then compared to the  Agency's
levels of concern (LOCs) which indicate whether a chemical, when used as directed, has the
potential to cause adverse effects on non-target  organisms. When the RQ exceeds the LOG for a
particular category, the Agency presumes a risk of concern to that  category of organisms. The
LOCs and the  corresponding risk presumptions  are presented in Table 12.

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Table 12. LOCs and Associated Risk Presumptions
IF...
THEN the Agency presumes...
Mammals and Birds
The acute RQ > LOG of 0.5
The acute RQ >LOC of 0.2
The acute RQ > LOG of 0.1
The chronic RQ > LOG of 1
Acute risk
Risk that may be mitigated through restricted use
Acute effects may occur in Threatened and Endangered Species
Chronic risk and Chronic effects may occur in Threatened and
Endangered Species
Fish and Aquatic Invertebrates
The acute RQ > LOC of 0.5
The acute RQ > LOG of 0.1
The acute RQ >LOC of 0.05
The chronic RQ > LOC of 1
Acute risk
Risk that may be mitigated through restricted use
Acute effects may occur in Threatened and Endangered Species
Chronic risk and Chronic effects may occur in Threatened and
Endangered Species
Terrestrial and Aquatic Plants
The acute RQ > LOC of 1
Acute risk and Acute effects may occur in Threatened and
Endangered Species
       For a more detailed explanation of the ecological risks posed by the use of 2,4-DB, please
refer to the Revised Environmental Fate and Effects Risk Assessment for 2,4-DB dated
December 13, 2004. This document is available on the internet at http://www.epa.gov.edockets.

       The 2,4-DB risk assessment approach included an evaluation of available surface water
and groundwater monitoring data as  well as environmental modeling.  The approach has relied
on model predictions rather than monitoring data for EECs due to the non-targeting nature of the
available 2,4-DB monitoring data. Specific uses chosen for modeling include alfalfa (grown in
California, Minnesota, North Carolina, Pennsylvania, and Texas), soybeans (grown in
Mississippi and Georgia) and peanuts (grown in North Carolina and Georgia).  These crops were
also chosen to represent a wide geographic area, thus encompassing a variety of environmental
conditions. All application rates and ecotoxicity results were adjusted to acid equivalents
accounting for molecular weight differences.  Risks to aquatic organisms and terrestrial
organisms are assessed based on modeled estimated environmental concentrations (EECs).

       The Agency has concluded that 2,4-DB presents the greatest potential risks to (1)
terrestrial non-target plants through spray-drift and runoff into  adjacent areas where these plants
are present; (2)  small and medium size mammals through direct application to treated fields; (3)
small and medium size birds through direct applications to treated fields; and (4) to threatened
and endangered freshwater fish through spray drift and  runoff from use on alfalfa.  These
findings are based solely on the Agency's screening level assessment and do not constitute "may
affect" findings under the Endangered  Species Act.
                                           23

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                     a.     Risk to Birds

                           i.      Toxicity (Hazard) Assessment

       Based on the acute toxicity studies submitted for birds, there is a large differential
between the acute toxicity when 2,4-DB is administered as a single gavage or when mixed in the
feed.  This disparity in mortality between the two types of studies suggests that the dietary matrix
may reduce the toxicity of 2,4-DB. It is shown that when the chemical is mixed with the diet the
test species will be exposed throughout the day despite the fact that nearly all of the chemical
will be consumed early during the feeding period.

       For 2,4-DB and 2,4-DB-DMAS administered to birds at a test concentration in the diet of
5,000 ppm, no definitive LCso values were determined for the two bird species tested, Bobwhite
quail and Mallard duck.  This indicates that it would take some undetermined value greater than
5,000 ppm to kill at least 50% of the birds tested.  Since no definitive LCso values for subacute
dietary toxicity to birds were established, potential acute risks to birds from single and multiple
aerial applications were determined based on the oral gavage results of 1536 mg/kg-bw.

       Chronic bird studies are generally required when compounds are highly toxic in acute
studies, are used repeatedly during a single season, have a long half-life in the soil and in the
environment in general, have high residues in sprayed crops and seed, and have the potential to
bioaccumulate in prey species.  2,4-DB and 2,4-DB-DMAS do not fulfill all of these criteria, and
the Agency has decided to "reserve" chronic avian studies for 2,4-DB and 2,4-DB-DMAS for the
following reasons: 2,4-DB and 2,4-DB-DMAS show medium toxicity to birds in acute studies;
2,4-DB and 2,4-DB-DMAS do not have excessively long half-lives in soil or aquatic
environments;  and, 2,4-DB  and 2,4-DB-DMAS are not expected to biaccumulate in prey species.
                           ii.     Exposure and Risk

       Acute
       Based on the acute oral gavage study using the technical grade material on Bobwhite
quail (LDso 1536 mg/kg-bw), acute LOCs were exceeded for small birds (i.e., 20 gram) feeding
on short grass, categorizing 2,4-DB as slightly toxic.  Effects observed in this study included
reduction in body weight and feed consumption along with some depression and wing droopsy of
the animals. Subacute dietary toxicity tests were conducted on waterfowl (Mallard duck) and
upland game bird (Bobwhite quail).  According to the toxicity studies conducted, the technical
grade material is categorized as practically non-toxic to birds with non-definitive LCso range of
1000 to >5000. Acute RQs are listed in Table 13.

       Even though exceedances for birds trigger Restricted Use Classification for 2,4-DB and
2,4-DM-DMAS, these exceedances were the result of gavage studies which are not
representative of exposure to birds in the field.  These exceedances would, therefore, be
inappropriate to use for regulatory purposes.

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Table 13. Acute Avian Risk Quotients (RQs)
Food Type
Short Grass
Tall Grass
Broadleaf forage, small insects
Weight Class (mg)
20
100
20
100
20
100
Acute RQ
0.62
0.28
0.29
0.13
0.25
0.11
RQs in this table were calculated for the maximum labeled application rate of 1.7 Ibs a.e./acre twice per year.  RQs
for other application rates are a linear function of the listed RQs. For example, to calculate the RQ for a rate of 0.85
Ib a.e./acre, multiply the listed RQs by 1A (since 0.85 Ib a.e./acre is 1A the listed application rate of 1.7 Ibs a.e./acre).
                     b.      Risk to Mammals

                            i.     Toxicity (Hazard) Assessment

       Toxicity tests indicate 2,4-DB is "slightly toxic" to mammals exposed for short periods.
To evaluate the acute risk to mammals, RQs were calculated using the minimum LDso obtained
from the acute oral studies (1,470-2,330 mg a.e./kg-bw, 2,4-DB-DMAS) and the maximum
labeled rate (1.7 Ibs a.e./acre).  In contrast, sub-chronic toxic effects were observed in studies
using dogs with dietary concentrations of 2,4-DB as low as 8 mg a.e./kg-diet. Effects observed
included weight increase  of selected organs, decreased body weight, and decreased hematology
parameters. Other 2,4-DB mammalian  sub-chronic studies had treatment related effects with
NOAELs ranging from 30 to 700 mg a.e./kg-diet and LOAELs ranging from 50 to 2000 mg
a.e./kg-diet.

       Prenatal toxic effects were observed in prenatal developmental toxicity studies using rats
and rabbits. Of these studies the lowest maternal NOAEL was 30 mg a.e./kg bw/day based on
decreased body weight and food consumption.  The lowest developmental NOAEL was 31.25
mg a.e./kg/day, based on  litter resorption, decreased fetal weight, and altered growth.

       Chronic toxic effects of 2,4-DB and 2,4-DB-DMAS were observed in a 2-generation
reproduction study with rats  where the NOAEL was determined  to be 300 mg a.e./kg-day,  for
both the parental and reproductive endpoints. The parental NOAEL was based on increased
water consumption (females), decreased food consumption, decreased body weight, increased
food consumption ratio (females), organ weight changes and microscopic renal findings.  The
reproductive NOAEL was based on decreased pup weight and gain during lactation. No toxic
effects were observed in the offspring, so an offspring NOAEL of 300 mg a.e./kg-diet was
determined.
                                            25

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                           ii.     Exposure and Risk

       Acute
       Predicted residues from the applications of 2,4-DB from all uses do not result in
exceedance of the Acute LOG.  However, exceedances of the restricted use and threatened and
endangered species LOCs for small and medium size mammals do occur for certain food items
when using the alfalfa application scenario (1.7 Ib a.e./A, 2 times per year with a 30 day
application interval).

       For small and medium mammals, RQ exceedances which trigger Restricted Use
Classification for 2,4-DB and 2,4-DB-DMAS were identified. The Agency has determined that
these small exceedances result from a conservative assessment and are not representative of
actual exposure.  These RQ exceedances would, therefore, be inappropriate to use for regulatory
purposes.  In addition, exceedances for threatened and endangered species are based solely on
the Agency's screening level assessment and do not constitute "may affect" findings under the
Endangered Species Act.  Therefore, regulatory action does not need to be taken for threatened
and endangered mammals. Acute RQs are listed in Table 14.

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Table 14. Acute RQs for Mammals Using Maximum and Mean EECs (LD50=1470 mg/kg)
Site/Rate
(in Ibs a.i./A)
CAAlfalfa/1.71bsa.i./A
2 times per year
30-day application interval
(Maximum EECs)
CA Alfalfa/ 1.7 Ibs a.i./A
2 times per year
10-day application interval
(Mean EECs)
Alfalfa/1.71bsa.i./A
(Maximum EECs)
Alfalfa/1.71bsa.i./A
(Mean EECs)
Peanuts/ 0.45 Ibs a.i./A
2 times per year
21 day application interval
(Maximum EECs)
Peanuts/ 0.45 Ibs a.i./A
2 times per year
21 -day application interval
(Mean EECs)
Peanuts/ 0.45 Ibs a.i./A
(Maximum EECs)
Peanuts/ 0.45 Ibs a.i./A
(Mean EECs)
Soybean/ 0.4 Ibs a.i./A
2 times per year
21 -day application interval
(Maximum EECs)
Soybean/ 0.4 Ibs a.i./A
2 times per year
21 -day application interval
(Mean EECs)
Soybean/ 0.4 Ibs a.i./A
(Maximum EECs)
Soybean/ 0.4 Ibs a.i./A
(Mean EECs)
Weight
Class
15
35
1000
15
35
1000
15
35
1000
15
35
1000
15
35
1000
15
35
1000
15
35
1000
15
35
1000
15
35
1000
15
35
1000
15
35
1000
15
35
1000
Herbivore/Insectivore Maximum Acute RQs Organized by Food
Source
Short Grass
0.41
0.28
0.06
0.14
0.10
0.02
0.26
0.18
0.04
0.09
0.06
0.01
0.12
0.08
0.02
0.04
0.03
0.01
0.07
0.05
0.01
0.02
0.02
«0.01
0.10
0.07
0.02
0.04
0.03
0.01
0.06
0.04
0.01
0.02
0.02
«0.01
Tall Grass
0.19
0.13
0.03
0.06
0.04
0.01
0.12
0.08
0.02
0.04
0.03
0.01
0.05
0.04
0.01
0.02
0.01
«0.01
0.03
0.02
0.01
0.01
0.01
«0.01
0.05
0.03
0.01
0.02
0.01
«0.01
0.03
0.02
«0.01
0.01
0.01
«0.01
Broadleaf
plants/Insects
0.23
0.16
0.02
0.08
0.05
0.01
0.15
0.10
0.02
0.05
0.03
0.01
0.07
0.05
0.01
0.02
0.02
«0.01
0.04
0.03
0.01
0.01
0.01
«0.01
0.06
0.04
0.01
0.02
0.01
«0.01
0.03
0.02
0.01
0.01
0.01
«0.01
Fruits/Pods/Large
insects
0.03
0.02
«0.01
0.01
0.01
«0.01
0.02
0.01
«0.01
0.01
0.01
«0.01
0.01
0.01
«0.01
«0.01
«0.01
«0.01
0.01
«0.01
«0.01
O.01
«0.01
«0.01
0.01
«0.01
«0.01

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       Chronic
       Chronic mammalian LOCs are exceeded for the maximum residues and two applications
of 1.7 Ibs a.e./A to alfalfa with a 30-day application interval for small mammals feeding on short
grass (RQ = 2.1), tall grass (RQ = 1.0), and broadleaf plants and insects (RQ = 1.2), and,
medium-size mammals feeding on short grass (RQ = 1.4). For a single application to alfalfa at
the same rate and the maximum residues, the chronic LOG for small mammals feeding on short
grass is exceeded (RQ = 1.36). All other scenarios examined resulted in RQs below the
Agency's level of concern.

                     c.      Risk to Fish and Aquatic Invertebrates

                            i.      Toxicity (Hazard) Assessment for Freshwater Species

       2,4-DB is classified as practically non-toxic to slightly toxic to freshwater fish under
acute exposure with definitive LDso values ranging from 2,000 ppb to 18,000 a.e. ng/L. Toxicity
studies conducted using 2,4-DB-DMAS demonstrate that it is classified as slightly toxic to
freshwater fish under acute exposure with a definitive LDso value of 3,134 a.e. |J,g/L.

       Two freshwater invertebrate toxicity studies were conducted using 2,4-DB. Based on the
results of these  studies, 2,4-DB is classified as slightly toxic to freshwater invertebrates on an
acute basis, with LDso values ranging from 15,000 ppb to 25,000 a.e.  |J,g/L.  For toxicity studies
conducted using 2,4-DB-DMAS, this herbicide is categorized as slightly toxic to freshwater
invertebrates with a definitive LCso value of 2,321 a.e.
       Chronic early life- stage and life- stage toxicity studies were not conducted for freshwater
fish and invertebrates. 2,4-DB and 2,4-DB-DMAS did not meet the Agency's criteria for
conducting a chronic risk assessment.  Based upon use patterns (one to two applications per
year), a low acute toxicity profile, and rapid degradation to 2,4-D, chronic risks to freshwater
fish and invertebrates are not likely to occur. In addition, any potential chronic exposures
resulting from 2,4-D will be addressed in the 2,4-D RED.

       Acute freshwater fish risk assessments using rainbow trout (LCso = 2,000) for aerially
applied 2,4-DB resulted in RQs below the Agency's level of concern for each crop scenario with
the exception of the Texas Alfalfa scenario. Although this scenario was used in the risk
assessment, the Agency feels that it provides a conservative assessment of the potential risks
associated with 2,4-DB use on Texas alfalfa. For a complete discussion of the Texas Alfalfa
scenario please read the environmental risk characterization section on page 36 of this
document.  In  addition, all acute freshwater invertebrate RQs are below the Agency's level of
concern.  Table 15 summarizes toxicity endpoints used to assess risks to fish and aquatic
invertebrates.

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Table 15. Summary of Endpoints for 2,4-DB Acute Aquatic Toxicity Studies
2,4-DB
Organism 1 Endpoint
2,4-DB DMAS
Organism 1 Endpoint
Freshwater Fish
Rainbow Trout
LC50 = 2000 ppb
Rainbow trout
LC50 = 3134ppb
Freshwater Invertebrate
Stonefly
(Pteronarcys sp.)
LC50 = 15,000 ppb
No data available
No data available
Full description of ecotoxicity studies available in Appendix C of EFED chapter
Toxicity value was converted to the "acid equivalents"

                           ii.     Toxicity Assessment for Estuarine/Marine Species

       2,4-DB did not meet the Agency's criteria for conducting a chronic risk assessment for
estuarine and marine species.  Based on the use patterns (one to two applications per year), a low
acute toxicity profile for freshwater species, and rapid degradation to 2,4-D, chronic risks to
marine and estuarine species are not likely to occur.
                            iii.    Exposure and Risk

       Aquatic estimated environmental concentrations for the aquatic ecological exposures
were estimated using PRZM/EXAMS modeling that uses the standard field pond scenario and a
Tier 2 screening model designed to estimate pesticide concentrations found in water at the edge
of the field.  Although 2,4-DB is classified as practically non-toxic to slightly toxic to freshwater
fish, PRZM/EXAM simulations for the Texas alfalfa scenario indicate an exceedance (RQ =
0.09) of the acute threatened and endangered freshwater fish species LOG based on the 1 in 10
year peak EEC. This exceedance is likely caused by the high runoff vulnerability for the Texas
alfalfa scenario coupled with the highest use rate for 2,4-DB (1.7 Ibs a.e./A). 2,4-DB is expected
to move off-site dissolved in runoff waters due  to the low soil to water partitioning coefficients.
The soil type of the Texas site is a sandy loam that is characterized by its high water table and
slow hydraulic conductivity.  Furthermore, the  USDA runoff vulnerability for the region
encompassing Milan County, TX is high. These findings are based solely on EPA's screening
level assessment and do not constitute "may affect" findings under the Endangered Species Act.
For a further discussion of the Texas Alfalfa scenario please see the environmental risk
characterization section on page 36.

       The 2,4-DB risk assessment assessed risks to aquatic organisms based on modeled
Environmental Concentrations (EECs).  The EECs used are presented in Table 16.
                                            29

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Table 16. PRZM/EXAMS Estimated Concentrations of 2,4-DB in Surface Water for
Aquatic Exposure
Crop Scenario
CA Alfalfa
MN Alfalfa
NC Alfalfa
PA Alfalfa
TX Alfalfa
MS Soybean
NC Peanut
GA Soybean
GA Peanut
Application rate
(Ib a.e./Acre)
for 2 Applications
1.71ba.e./A
1.71ba.e./A
1.71ba.e./A
1.71ba.e./A
1.71ba.e./A
0.40 Ib a.e./A
0.45 Ib a.e./A
0.40 Ib a.e./A
0.45 Ib a.e./A
Interval
Between
Applications
(Days)
30
30
30
30
30
21
21
21
21
Peak
Cone.
(ppb)
20.19
37.61
81.12
44.78
182.6
14.52
23.36
16.70
16.18
60 Day
Cone.
(Ppb)
17.44
34.66
72.97
40.76
156.9
12.57
18.07
14.57
14.79
                     d.      Risk to Non-Target Insects

       Guideline ecotoxicity tests indicate that 2,4-DB is "practically non-toxic" to honey bees.
An acute toxicity study with 2,4-DB acid yielded a 48-hour LDso = 14.5 |j,g a.e./bee.

                     e.      Risk to Non-Target Terrestrial Plants

       To assess risk to non-target terrestrial plants, several representative plant species were
exposed to technical formulations of 2,4-DB and 2,4-DB-DMAS.  Of the species tested, carrots
(dicot) and onions (monocot)  were chosen to be used in risk assessment because of their
sensitivity to 2,4-DB.  In order to assess risks to non-endangered plants, estimated environmental
concentrations were compared to concentrations that would kill 25% of the test population
(EC2s). To assess risks to threatened and endangered plants, estimated environmental conditions
were compared to concentrations that would kill 5% of the test population (ECos).

       The greatest potential  for risks is to terrestrial non-target plants from technical
formulations of 2,4-DB from  spray drift and runoff to areas adjacent to or near treated fields.
Spray drift of 2,4-DB may potentially damage plants through direct contact (demonstrated
through vegetative vigor studies) or through runoff and soil deposition during seedling
emergence (demonstrated by seedling emergence studies).  Runoff of 2,4-DB may potentially
cause phytotoxicity to sprouting seeds and seedlings in areas receiving runoff downslope of
application areas including wetlands. Potential risks to plants from exposures to the technical
formulations outlined in this assessment may underestimate potential risks from the formulated
product because formulations often include additives that enhance  performance and thus
potential for risks.

       Potential effects on non-target terrestrial plants are most likely to occur as a result of
spray drift from aerial and ground applications.  2,4-DB applied according to label directions as a
liquid spray  for ground or aerial applications may impact non-target plants for some distance

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from the application site depending on droplet size, wind speed, direction, and other factors.
Additionally, 2,4-DB product labels do not specify a required or recommended droplet size for
spray applications. Based on the screening assessment of drift exposures, potential risks to non-
target terrestrial plants from 2,4-DB exposures occur as either drift from ground spray at a
distance of 25 ft from the edge of the field, or as an aerial exposure across a swath 175 feet from
the edge of the field.  This information is based on generalized spray drift modeling that assumes
when chemicals are applied by ground equipment, the potential drift area will be 1% of the
application rate. For aerial applications, the potential drift area is assumed to be 5% of the
application rate.

       Acute non-endangered terrestrial plant RQs and acute threatened and endangered species
plant RQs are presented in Table 17 and 18.
Table 17. Acute Non -Endangered Terrestrial Plant RQs from 2,4-DB Exposure From Use
on Alfalfa, Peanuts, and Soybeans at the Maximum and Average Rates Based on Seedling
Emergence EQs of 0.0059 Ibs a.e./A for Carrots (dicot) and a Vegetative Vigor EQs of
0.081 Ibs a.e./A for Onions (monocot)

Site/Rate
in Ibs a.e./A
Alfalfa
1.7 Ibs a.e./A
Alfalfa
0.55 Ibs
a.e./A
Peanuts
0.45 Ibs
a.e./A
Peanuts
0.1 3 Ibs
a.e./A
Soybeans
0.4 Ibs a.e./A
Soybeans
0.29 Ibs
a.e./A
Emergence
Adjacent to Treated Sites
Ground
Unincorporated
8.64
2.80
2.29
0.66
2.03
1.47
Aerial
17.86
5.78
4.73
1.37
4.20
3.05
Emergence
Semi-aquatic Sites
Ground
Unincorporated
60.51
19.58
16.02
4.63
14.24
10.32
Aerial
48.98
15.86
12.97
3.75
11.53
8.36
Vegetative Vigor
Ground
Unincorporated
0.21
0.07
0.06
0.02
0.05
0.04
Aerial
1.05
0.34
0.28
0.08
0.25
0.18
                    f.      Risk to Non-Target Aquatic Plants

       A study was submitted analyzing the ecotoxicity effects of 2,4-DB-DMAS on green
algae.  Because a NOAEL was not reported for aquatic plants, an £€25 value could not be
established.  Therefore, the LOAEL value was used for evaluating ecotoxicological effects of
2,4-DB-DMAS and 2,4-DB on this species of algae.  The LOEL (lowest observable  effect level)
value was 0.932 mg a.e./L at which no adverse effects were observed.     Using two annual
                                           31

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applications at labeled rates, acute levels of concern were not exceeded for aquatic non-vascular
plants using green algae as the representative test species.

                     g.      Food-Chain Effects

       2,4-DB is not expected to bioaccumulate because of its ionic nature. Possible food-chain
effects could occur as a result of damage to non-target terrestrial plants.  Reproduction
abnormalities are among the injuries that can occur after exposure to this herbicide. In the case
of sterility and non-viable seed production, these cases may initiate a decrease in seed population
and persist within the plant populations in subsequent years. Plant material serves as  a primary
food source  for many species of animals.  If the available plant material  (including seeds) is
reduced due to the effects of 2,4-DB, this may have negative effects through the food chain.
                     h.      Risk to Threatened and Endangered Species

       The risk assessment for threatened and endangered species indicates that 2,4-DB and 2,4-
DB-DMAS exceed the threatened and endangered species LOCs for the use sites listed below.

       Levels of concern for Freshwater fish were exceeded using the Texas alfalfa scenario by
drift and runoff.  These findings are based solely on the Agency's screening level assessment and
do not constitute "may affect" findings under the Endangered Species Act.

       Threatened and Endangered levels of concern were exceeded for small mammals feeding
on short grass when using the soybean (0.40 Ibs a.e./A, aerially applied two times per year with a
21-day application interval) and peanut (0.45 Ibs a.e./A aerially applied two times per year with a
21-day application interval) application scenarios.  These findings are based solely on the
Agency's screening level assessment and do not constitute "may affect" findings under the
Endangered Species Act.

       Additional exceedances occurred for mammals for the following scenarios:

       -Small mammals feeding on short grass, tall grass, and broadleaf plants/insects when
       single or multiple aerial applications are made to alfalfa;

       -Medium-size mammals feeding on short grass, tall grass and broadleaf plants/insects
       when  multiple aerial applications are made to alfalfa and short grass, and broadleaf
       plants/insects when a single application is made on alfalfa; and

       -Small (15 grams) and medium (35 grams) mammals when using the alfalfa application
       scenario (1.7 Ibs a.e./A, two times per year with a 30-day application interval).

       The Agency has determined that no threatened and endangered mammals weighing less
than 1000 grams inhabit alfalfa fields.  Therefore, small mammals will not be affected by use of
2,4-DB and 2,4-DB-DMASin alfalfa related application scenarios.

       Levels of concern were exceeded for small and medium size birds feeding on short grass,
 tall grass, and broadleaf plants/insects when multiple aerial applications are made to alfalfa. As
 discussed previously, it is highly unlikely that 2,4-DB or 2,4-DB-DMAS concentrations would

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 reach an effect level in the environment.  Therefore, the Agency has determined that threatened
 and endangered birds will not be affected by use of 2,4-DB or2,4-DB-DMAS.

       Levels of concern were exceeded at the highest application rate for plants. Until a
 species specific assessment for endangered plants is conducted, the mitigation strategy
 articulated in this document will serve as  an interim protection to reduce the likelihood that
 listed species will be exposed to 2,4-DB and 2,4-DB-DMAS. Additionally, these exceedances
 are based solely on the Agency's screening level assessment and do not constitute "may affect"
 findings under the Endangered Species Act.

Table 18. Acute Threatened and Endangered Terrestrial Plant RQs from 2,4-DB Exposure
From Use on Alfalfa, Peanuts, and Soybeans at the Maximum and Average Rates Based on
Seedling Emergence ECos of 0.00045 Ibs a.e./A for Carrots (dicot) and a Vegetative Vigor
ECos of 0.012 Ibs a.e./A for Onions (monocot)

Site/Rate
in Ibs a.e./A
Alfalfa
1.7 Ibs a.e./A
Alfalfa
0.55 Ibs
a.e./A
Peanuts
0.45 Ibs
a.e./A
Peanuts
0.1 3 Ibs
a.e./A
Soybeans
0.4 Ibs a.e./A
Soybeans
0.29 Ibs
a.e./A
Emergence
Adjacent to Treated Sites
Ground
Unincorporated
113.33
36.67
30.00
8.67
26.67
19.33
Aerial
234.22
75.78
62.00
17.91
55.11
39.96
Emergence
Semi-aquatic Sites
Ground
Unincorporated
793.33
256.67
210.00
60.67
186.67
1135.33
Aerial
642.22
207.78
170.00
49.11
151.11
109.56
Vegetative Vigor
Ground
Unincorporated
1.42
0.46
0.38
0.11
0.33
0.24
Aerial
7.08
2.29
1.88
0.54
1.67
1.21
                    i.      Risk Characterization

       To characterize ecological risks from applications to alfalfa in Texas, the Texas Alfalfa
scenario, which was developed from studies in Milan County, TX, was used.  This scenario used
an application rate of 1.7 Ibs a.e./A with two applications per season 30-days apart. The soil type
of this area in Texas is a sandy loam that is highly susceptible to runoff. Alfalfa production is
generally limited to well-drained soils due to a stand reduction or loss in wet soil conditions.  In
Texas, alfalfa is generally grown in the western panhandle area, where this type of soil is not
common.  Risk estimates using this scenario result in risk quotients that exceed the Agency's
level of concern for freshwater fish, small and medium-size mammals,  small and medium-size
birds, and non-target terrestrial plants.  This scenario results in a conservative estimate of risk
because these findings are based solely on the Agency's screening level assessment and do not
constitute "may affect" findings under the Endangered Species Act.
                                           33

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       To evaluate acute risks to mammals, both mean and maximum estimated environmental
concentrations (EECs) were used. Both the mean and the maximum (upper-bound) values are
based on Kenaga degradation models for foliar pesticide residues.  The upper-bound residues are
based on the 90th percentile values of the maximum residues as observed on foliage. Likewise,
the mean values are based on the mean residues observed. The application rate is multiplied by
the upper-bound residue for a specific crop at time zero, and then a model is used to calculate
the degradation over time to  determine the existing residue.  Generally the mean residue values
are approximately 65% less than the upper bound values and there is roughly an equal decline in
the RQs. Both values were used to characterize exceedances.  For example, for the California
alfalfa scenario, there are exceedances for both maximum and  mean residues.  This suggests that
even a reduction in residue, possibly as a result from a reduction in application rate, RQs are still
above the Agency's level of concern.

       The greatest risk from 2,4-DB applications is to  non-target terrestrial plants.  2,4-DB is a
non-selective herbicide that can potentially harm plants that are not intended to come in contact
with the chemical.  Due to the nature of the  chemical it is difficult to completely eliminate risks
to plants without reducing the application rate to a level  that would not be effective to control
target weeds.
                    j.     Ecological Incident Reports

       There are presently no reported incidents in the Environmental Incident Information
System (EIIS) database. The lack of reported incidents cannot be considered evidence of lack of
hazard. Incident reporting is a voluntary process and no attempt has been made to actively
investigate if mortality  of wildlife and non-target plants is occurring on fields treated with 2,4-
DB.

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IV.    Risk Management, Reregistration, and Tolerance Reassessment Decision

       A.     Determination of Reregistration Eligibility

       Section 4(g)(2)(A) of FIFRA calls for the Agency to determine, after submission of
relevant data concerning an active ingredient, whether or not products containing the active
ingredient are eligible for reregistration. The Agency has previously identified and required the
submission of the generic (i.e., active ingredient-specific) data required to support reregistration
of products containing 2,4-DB and 2,4-DB-DMAS as active ingredients.  The Agency has
completed its review of these generic data, and has determined that the data are sufficient to
support reregistration of all  supported products containing 2,4-DB and 2,4-DB-DMAS.

       The Agency has completed its assessment of the dietary, occupational, drinking water,
and ecological risks associated with the use of pesticide products containing the active
ingredients 2,4-DB and 2,4-DB-DMAS. Based on a review of these data and on public
comments on the Agency's  assessments for the active ingredients 2,4-DB and 2,4-DB-DMAS,
the Agency has sufficient information on the human health and ecological effects of 2,4-DB to
make decisions as part of the tolerance reassessment process under FFDCA and reregistration
process under FIFRA, as amended by FQPA. The Agency has determined that 2,4-DB and 2,4-
DB-DMAS containing products are eligible for reregistration provided that: (i) current data gaps
and confirmatory data needs are addressed; (ii) the risk mitigation measures outlined in this
document are adopted; and (iii) label amendments are made to reflect these measures. Label
changes are described in Section V.  Appendix A summarizes the uses of 2,4-DB and 2,4-DB-
DMAS that are eligible for reregistration.  Appendix B identifies the generic data requirements
that the Agency reviewed as part of its determination of reregistration eligibility of 2,4-DB and
2,4-DB-DMAS, and lists the submitted studies that the Agency found acceptable.  Data  gaps are
identified as generic data requirements that have not been satisfied with acceptable data.

       Based on its evaluation of 2,4-DB and 2,4-DB-DMAS, the Agency has determined that
2,4-DB and 2,4-DB-DMAS products, unless labeled and used as specified in this document,
would present risks inconsistent with FIFRA. Accordingly, should a registrant fail to implement
any of the risk mitigation measures identified in this document, the Agency may take regulatory
action to address the risk concerns from the use of 2,4-DB and 2,4-DB-DMAS.  If all  changes
outlined in this document are incorporated into the product labels, then all current risks for 2,4-
DB and 2,4-DB-DMAS will be substantially mitigated for the purposes of this determination.

       B.     Public Comments and Responses

       Through the Agency's public participation process, EPA worked with stakeholders and
the public to reach the regulatory decisions for 2,4-DB and 2,4-DB-DMAS.  During the public
comment period on the risk assessments, which closed on September 30, 2004, the Agency
received  comments from the California Regional Water Quality Control Board (CWQCB), San
Francisco Bay Region.  These comments in their entirety are  available in the public docket,
http://docket.epa.gov/edkpub/index.isp, (OPP-2004-0220). The submitted letter was sent to the
Office of Prevention, Pesticides, and Toxic Substances, divisions within the Office of Pesticide
Programs, Office of Water,  Office of Wetlands, Oceans,  and Watersheds, as well as regional
offices. In their comment, the CRWQCB suggested that the Agency perform a cumulative

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ecological risk assessment for phenoxy herbicides. At this time the Agency has determined that
2,4-DB and 2,4-DB-DMAS do not have a common mode of action with other phenoxy
herbicides and, therefore, a cumulative assessment was not performed. The CRWQCB also
commented on the Agency's coordination with the Office of Water to develop water quality
criteria in accordance with the Federal Clean Water Act. This comment has already been sent to
the Office of Water and the Agency continues to coordinate on these efforts.

       A task force consisting of some of the registrants also submitted comments to the Agency
during Phase 1, the error only comment period. The Agency's responses to these comments are
incorporated into the revised chapters and are available in the public docket.
       C.    Regulatory Position

             1.     Food Quality Protection Act Findings

                    a.     "Risk Cup" Determination

       As part of the FQPA tolerance reassessment process, EPA assessed the risks associated
with 2,4-DB and 2,4-DB-DMAS. The Agency has concluded that the tolerances for 2,4-DB and
2,4-DB-DMAS (expressed only as tolerances for 2,4-DB) meet the FQPA safety standards and
that the risk from dietary (food sources only) exposure is within the "risk cup."  An aggregate
assessment was conducted for exposures through food and drinking water. A residential
assessment was not conducted or included in the aggregate assessment because there are
currently no registered residential uses for 2,4-DB or 2,4-DB-DMAS.  The Agency has
determined that the human health risks from these combined exposures are within acceptable
levels.  In reaching this determination, EPA has considered the available information on the
special sensitivity of infants and children, as well as aggregate exposure from food and water.

                    b.     Determination of Safety to U.S.  Population

       As part of the FQPA tolerance reassessment process, EPA assessed the risks associated
with 2,4-DB and 2,4-DB-DMAS. The Agency has determined that the established tolerances for
2,4-DB, with amendments and changes as specified in this document, meet the safety standards
under the FQPA amendments to section 408(b)(2)(D) of the FFDC A, and that there is  a
reasonable certainty no harm will result to the general population or any subgroup from the use
of 2,4-DB and 2,4-DB-DMAS. In reaching this conclusion, the Agency has  considered all
available information on the toxicity, use practices and exposure scenarios, and the
environmental behavior of 2,4-DB and 2,4-DB-DMAS.

       Acute risks from drinking water exposures are not of concern.  Monitoring and modeling
software have been used to estimate ground and surface water concentrations.  An acute
Drinking Water Level of Concern (DWLOC) was calculated only for females 13-49 years of age
because this was the only  population subgroup  for which an endpoint was selected.  The
DWLOC calculated to assess the surface water contribution to acute (non-cancer) dietary
exposure is 18,000 [ig/L.  The surface water estimated drinking water concentration (EDWC)
(318.68 |j,g/L ) is less than the acute DWLOC, indicating that acute exposure to 2,4-DB in
drinking water from surface water sources is below the Agency's level of concern.  The
groundwater EDWC (0.51 ng/L) is also less than the acute DWLOC, indicating that acute

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exposure to 2,4-DB in drinking water from groundwater sources is below the Agency's level of
concern.  Since the estimates for concentrations in surface water and groundwater are below the
calculated acute DWLOC, the Agency concludes with reasonable certainty that exposure from
water will not result in an unacceptable acute risk.

       An acute aggregate assessment was only conducted for females 13-49 because this
population subgroup was the only group for which an endpoint was selected. Since the EDWC
is less then the acute DWLOC and acute dietary risk estimates are below  1% of the aPAD, acute
aggregate risk is not a concern.

       Chronic risks from drinking water exposures are not of concern.  The DWLOC calculated
to assess the surface water contribution to chronic (non-cancer) dietary exposure is a range from
1050  ng/L (for the U.S. general population) to 290 |J,g/L (infants <1 year). The surface water
EDWC (72.40 |J,g/L ) is less than the chronic DWLOC, indicating that chronic  exposure to 2,4-
DB in drinking water from surface water sources is below the Agency's level of concern.  The
groundwater EDWC (0.51 (ig/L ) is also less than the chronic DWLOC, indicating that chronic
exposure to 2,4-DB in drinking water from groundwater sources is below the Agency's level of
concern.  Since the estimates for concentrations in surface water and groundwater are below the
calculated chronic DWLOC, the Agency concludes with reasonable certainty that exposure to
2,4-DB from drinking water will not result in an unacceptable chronic risk.

       A chronic aggregate risk assessment was conducted for infants less than one year of age.
The chronic dietary exposure for this group,  the most highly exposed population subgroup, was
less than 2.2% of the cPAD from the DEEM model, and 1.8% of the cPAD from the Lifeline
model. Both the surface water and ground water EDWCs for this subgroup are below the
Agency's level of concern. Therefore, chronic aggregate risks are not of concern.
                    c.     Determination of Safety to Infants and Children

       EPA has determined that the established tolerances for 2,4-DB, with amendments and
changes as specified in this document, meet the safety standards under the FQPA amendments to
section 408(b)(2)(C) of the FFDCA, that there is a reasonable certainty of no harm for infants
and children. The safely determination for infants and children considers factors of the toxicity,
use practices, and environmental behavior noted above for the general population, but also takes
into account the possibility of increased dietary exposure due to the specific consumption
patterns of infants and children, as well as the possibility of increased susceptibility to the toxic
effects of 2,4-DB residues in this population subgroup.

       No Special FQPA Safety Factor is necessary to protect the safety of infants and children.
In determining whether or not infants and children are particularly susceptible to toxic effects
from 2,4-DB residues, the Agency considered the completeness of the database for
developmental and reproductive effects, the nature of the effects observed, and other
information. The FQPA Safety Factor has been removed (i.e., reduced to IX) for 2,4-DB based
on: (1) exposure databases are complete for 2,4-DB and 2,4-DB-DMAS and the risk assessment
for each potential exposure scenario includes all metabolites and/or degradates of concern and,
(2) the risk assessment does not underestimate the potential risk for infants and children.

                                           37

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                    d.     Endocrine Disrupter Effects

       EPA is required under the FFDCA, as amended by FQPA, to develop a screening
program to determine whether certain substances (including all pesticide active and other
ingredients) "may have an effect in humans that is  similar to an effect produced by a naturally
occurring estrogen, or other endocrine effects as the Administrator may designate." Following
recommendations of its Endocrine Disrupter Screening and Testing Advisory Committee
(EDSTAC), EPA determined that there was a scientific basis for including, as part of the
program, the androgen and thyroid hormone systems, in addition to the estrogen hormone
system. EPA also adopted EDSTAC's recommendation that EPA include evaluations of
potential effects in wildlife.  For pesticides, EPA will use FIFRA and, to the extent that effects in
wildlife may help determine whether a substance may have  an effect in humans, FFDCA
authority to require the wildlife evaluations. As the science develops and resources allow,
screening of additional hormone systems may be added to the Endocrine Disrupter Screening
Program (EDSP).

       When the appropriate screening and/or testing protocols being considered under the
EDSP have been developed, 2,4-DB and 2,4-DB-DMAS may be subject to additional screening
and/or testing to better characterize effects related to endocrine disruption.

                    e.     Cumulative Risks

       Risks summarized in this document are those that result only from the use of 2,4-DB and
2,4-DB-DMAS.  The Food Quality Protection Act (FQPA) requires that the Agency consider
"available information" concerning the cumulative effects of a particular pesticide's residues and
"other substances that have a common mechanism of toxicity." The reason for consideration of
other substances  is due to the possibility that low-level  exposures to multiple chemical
substances that cause a common toxic effect by a common toxic mechanism could lead to the
same adverse health effect as would a higher level  of exposure to any of the substances
individually.  Unlike other pesticides for which EPA has followed a cumulative risk approach
based on a common mechanism of toxicity, EPA has not made a common mechanism of toxicity
finding for 2,4-DB and 2,4-DB-DMAS.  For information regarding EPA's efforts to determine
which chemicals have a common mechanism of toxicity and to evaluate the cumulative effects of
such chemicals, see the policy statements released by EPA's Office of Pesticide Programs
concerning common mechanism determinations and procedures for cumulating effects from
substances found to have a common mechanism on EPA's website at
http ://www. epa. gov/pesticides/cumulative/.

              2.     Tolerance Summary

       Tolerances are currently established for residues of 2,4-DB and its metabolite 2,4-
dichlorophenoxyacetic acid (2,4-D) that is also a registered  active ingredient. Current tolerance
levels are set at 0.2 ppm in or on the following raw agricultural commodities: alfalfa, clover,
mint hay, peanut, soybean, soybean hay, and birdsfoot trefoil.

       The Agency has concluded that the residue to be regulated in plant and livestock
commodities is 2,4-DB per se, and that 2,4-D need not  be included in the tolerance expression.
2,4-DB parent appears as the major compound in many of the plant and livestock matrices,  and
the 2,4-D metabolite is present only at low levels.  Based on the Agency's decision and available

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residue field trial data for 2,4-DB, the tolerance for residues of 2,4-DB in plant commodities
should be expressed as follows "residues of 2,4-DB, both free and conjugated, determined as the
acid". The reassessed tolerances for plants are as follows: alfalfa, forage (0.70 ppm); alfalfa, hay
(2.0 ppm); clover, forage and clover, hay (to be determined due to insufficient data available);
peppermint, tops and spearmint, tops (0.20 ppm); soybean, seed (0.50 ppm); soybean, forage
(0.70 ppm); soybean, hay (2.0 ppm); peanut (0.05 ppm); trefoil, forage (0.70 ppm) and trefoil,
hay (2.0 ppm).

      As with plant tolerances, livestock tolerances should be expressed as residues of 2,4-DB,
both free and conjugated, determined as the acid. The appropriate tolerance for 2,4-DB is 0.05
ppm (LOQ) in the meat byproducts  of cattle, goats, hogs, horses, and sheep. There is no
reasonable expectation of the transfer of residues of 2,4-DB from foodstuffs to livestock meat,
fat, or milk based on adequate residue data; therefore the current use of 2,4-DB with respect to
these commodities should be classified as 40 CFR 180.6(a)(3).  Therefore, tolerances for
residues of 2,4-DB in milk and in meat and fat of cattle, hogs, horses, and sheep are not required.

       Sufficient data are available  to determine that residues of 2,4-DB do not significantly
concentrate in any peanut, soybean,  or mint processed food/feed item; thus tolerances are not
required for the processed commodities of these crops.

      Adequate tolerance enforcement methods are currently available.  2,4-DB is completely
recovered (>80%) by FDA MultiResidue Test Method 402 (PAM Vol I, updated 10/97).  The
Pesticide Analytical Manual (PAM) Vol. II, lists Method I for the enforcement of tolerances of
2,4-DB residues; this method is the PAM Vol.  I method for chlorophenoxy acid residues in
food.

      2,4-DB Task Force submitted GC/ECD (gas chromatography with electron-capture
detection) analytical methods that determine residues of 2,4-DB, 2,4-D, and 2,4-D phenol in
several plant and livestock commodities.  The methods were found to be adequate for data
collection.  If the submitted GC/ECD analytical method for plant commodities is proposed as a
2,4-DB tolerance enforcement method, then the method should be modified to include
determination of both free and conjugated 2,4-DB and an independent laboratory validation
(ILV) should be performed. If the GC/ECD method is proposed as the enforcement method for
determining 2,4-DB in livestock commodities,  independent laboratory validation of the method
also should be performed. Adequate method radiovalidation data have been submitted for
livestock commodities.
                                           39

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                   a.     Tolerances Currently Listed Under 40 CFR §180.331 and
                         Tolerance Reassessment
Table 19. Tolerance Reassessment Summary for 2,4-DB
Tolerances Listed Under 40 CFR § 180.331
Commodity
Alfalfa
Clover
Mint, hay
Current
Tolerance
(ppm)
0.2 (N)
0.2 (N)
0.2
Tolerance
Reassessment
(ppm)
0.7
2.0
TBD1
TBD1
0.2
Correct Commodity Definition/Comment
[alfalfa, forage}
Residues of 2,4-DB in/on alfalfa forage at 30 and 60
days PHI ranged from non-detectable (O.05) to 0.49
and non -detectable to 0. 14 ppm. Based on the
submitted field trials, the current tolerance of 0.2 (N)
should be increased to 0.7 ppm.
[alfalfa, hay}
The residues of 2,4-DB in/on alfalfa hay treated at
approximately 30 days PHI ranged from non-
detectable (<0.05 ppm) to 1 .7 ppm. Based on this
study the tolerance for alfalfa hay should be increased
to 2.0 ppm.
[clover, forage]
Data were submitted from four clover (crimson and
ladino) field trials conducted in CA (2) and OR (2).
Residues were non-detectable (<0. 10 ppm) in 4 clover
samples harvested 36-43 days following one post-
emergent broadcast application of 0.84-1.68 Ibs
a.e./A 2,4-DB. Additional field trials on clover forage
and hay are required at the maximum labeled rate with
a 60 day PHI. Ten additional trials are recommended
in the following regions: 1, 2, 4, 5 (3 studies), 6, 7, 8,
and 9. Alternatively, if a crop group tolerance for
Non-Grass Animal Feeds (Crop Group 18) is desired,
eight additional trials are recommended in the
following regions: 1, 2, 4, 5 (2 studies), 6, 7, and 8.
[clover, hay]
See above comment for clover forage.
[peppermint, tops]
Residues were non-detectable (<0.01 ppm) in 12
peppermint hay samples harvested 133-212 days
following one post-emergent application of 1 Ib a.e./A
2,4-DB (1.6X the proposed maximum label rate of
0.64 Ib a.e./A. A subsequent review of a SLN request
concluded that residues would not exceed the
established tolerance of 0.2 ppm in mint hay if a pre -
harvest interval of 90 days is observed following early
post -emergence application of the dimethylamine salt
to mint at rates up to 0.75 Ib a.i./A (0.64 Ib a.e./A).

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Peanut
Soybean
Soybean, hay
Trefoil,
birdsfoot

0.2 (N)
0.2 (N)
0.2 (N)
0.2 (N)
0.2
0.05
0.5
2.0
0.7
2.0
[spearmint, tops]
Residues were non-detectable (<0.01 ppm) in 6
spearmint hay samples harvested 133-212 days
following one post-emergent application of 1 Ib a.e./A
2,4-DB (1.6X the proposed maximum label rate of
0.64 Ib a.e./A). A subsequent review of a SLN request
concluded that residues would not exceed the
established tolerance of 0.2 ppm in mint hay if a pre -
harvest interval of 90 days is observed following early
post -emergence application of the dimethylamine salt
to mint at rates up to 0.75 Ib a.i./A (0.64 Ib a.e./A).
The current tolerance (based on combined residues of
2,4-DB and 2,4 -D for peanut nutmeat of 0.2 (N) ppm)
can be lowered to 0.05 ppm. Products labeled for use
on peanuts need to specify a minimum 60 day PHI.
[soybean, seed]
Since only minimal data were provided for soybean
hay at 60-day PHI, the Agency recommends that the
tolerance be based on a forage-to-hay dry -down
factor. Based on the 0.7 ppm tolerance for forage,
%DM values of 35% and 85% for forage and hay,
respectively, and a consequent dry -down factor of
2.4X, a tolerance of 2 ppm is appropriate for soybean
hay.
[trefoil, forage]
The submitted field trial data for alfalfa was translated
to trefoil.
[trefoil, hay]
The submitted field trial data for alfalfa was translated
to trefoil.
Tolerances To Be Proposed Under 40 CFR § 180.331
Commodity
Soybean,
forage
Cattle, meat
byproducts
Goat, meat
byproducts
Hog, meat
byproducts
Horse, meat
byproducts
Sheep, meet
byproducts
Current
Tolerance
(ppm)
None
None
None
None
None
None
Tolerance
Reassessment
(ppm)
0.7
0.05
0.05
0.05
0.05
0.05
Correct Commodity Definition/Comment
Residues in soybean forage following treatments at
maximum label rates are unlikely to exceed 0.7 ppm
(with a 60-day PGI)
The qualitative nature of residues in ruminants and
poultry is adequately understood based on studies in
dairy cows and laying hens.
1 TBD = To be determined, PGI = Pre-grazing Interval, PHI = Pre -harvesting Interval, N = Negligible
                                                    41

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                    b.     Codex Harmonization

       Currently there are no Codex MRLs established for 2,4-DB or 2,4-DB-DMAS.

       D.    Regulatory Rationale

       The Agency has determined that 2,4-DB and 2,4-DB-DMAS are eligible for
reregi strati on provided that additional required data confirm this decision and that the risk
mitigation measures outlined in this document are adopted, and label amendments are made to
reflect these measures.

       The following is a summary of the rationale for managing risks associated with the use of
2,4-DB and 2,4-DB-DMAS. Where labeling revisions are warranted, specific language is set
forth in the summary tables of Section V of this document.


             1.     Human Health Risk Management

                    a.     Dietary (Food) Risk Mitigation

       For all supported commodities, the acute and chronic dietary exposure estimates are
below the Agency's level of concern. Therefore, no risk mitigation measures are required to
address exposure to 2,4-DB residues in food.

                    b.     Drinking Water Risk Mitigation

       Estimated EDWCs are below the Agency's DWLOC for acute and chronic aggregate
risk. Therefore, no risk mitigation measures are required to address 2,4-DB and 2,4-DB-DMAS
exposure from drinking water.

                    c.     Residential Risk Mitigation

       2,4-DB and 2,4-DB-DMAS do not have any registered residential uses or use patterns
that would cause residential exposures.

                    d.     Occupational Risk Mitigation

                           i.      Handler Exposure

       Occupational risks from handler and applicator exposures were calculated for short-term
inhalation exposures and intermediate-term  combined dermal and inhalation exposures.
Standard assumptions and PHED unit exposure data were used. The maximum label rates were
used for short-term exposures and average rates were used for intermediate-term exposures. All
of the MOEs for short-term inhalation exceeded the target MOE of 100 with baseline respiratory
protection (i.e. no respirators worn) and were not of concern.  Intermediate-term handler
exposures are unlikely to occur because 2,4-DB is applied only once or twice per season.  All  of
the  intermediate-term MOEs exceeded the target MOE with baseline PPE and chemical resistant
gloves  for mixer/loaders and baseline PPE for applicators.

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       Currently, 2,4-DB labels require water-proof gloves instead of chemical resistant gloves.
Based on acute toxicity studies, the Agency is requiring that mixers and loaders wear gloves
made of chemically resistant material when handling 2,4-DB.

       Because the amine salt form of 2,4-DB is a severe eye irritant, protective eyewear should
be worn by early re-entry workers and a re-entry interval of 48 hours will be established for 2,4-
DB-DMAS products.

       In summary, to reduce worker exposure, the Agency has determined that the following
label changes for specific scenarios are appropriate and required for reregi strati on eligibility:

Mixers/Loaders/Applicators/Other Handlers (general): wear baseline (long-sleeve shirt, long
pants, shoes, socks, no respirator), plus chemical resistant gloves for mixing, loading, and
applying liquid formulations.

Flaggers: wear baseline (long-sleeve shirt, long pants, shoes, socks) for overhead exposure for
flagging aerial applications.

                            ii.      Post-Application Risk Mitigation

       Post-application exposure to re-entry workers is possible because 2,4-DB can be applied
foliarly to the top of most labeled  crops.  The exposures were assessed using the intermediate-
term dermal endpoint, standard assumptions and average label rates.  All of the MOEs are above
the target MOE of 100 on Day 0.  However, because the amine form of 2,4-DB is a Toxicity
Category I eye irritant, a 48 hour REI is required to protect re-entry workers.

              2.      Environmental Risk Management

       The Agency has concluded that 2,4-DB and 2,4-DB-DMAS present the greatest potential
risks to: (1) terrestrial non-target plants through spray-drift and runoff into adjacent areas where
these plants are present; (2) small  and medium size mammals through direct  application to
treated fields; (3) small and medium size birds through direct application to treated fields; and
(4) threatened  and endangered freshwater fish through  spray drift and runoff from use on alfalfa.

        The major contributing factor of risk associated with 2,4-DB and 2,4-DB-DMAS is
spray drift.  To mitigate risk associated with spray drift, the registrant has agreed to include
droplet size restrictions on 2,4-DB and 2,4-DB-DMAS labels. Labels must specify medium to
coarse droplet  size or a volume mean diameter of 300 microns or greater for  spinning atomizer
nozzles and prohibit fine sprays.  Additionally, for aerial applications, the boom length must not
exceed 75% of the wingspan or 90% of the rotor blade diameter to reduce spray drift.

              3.      Other Labeling Requirements

       In order to be eligible  for reregistration, various use and safety information will be
included in the labeling of all  end-use products containing 2,4-DB. For the specific labeling
statements and a list of outstanding data, refer to Section V of this RED document.
                                            43

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              4.      Threatened and Endangered Species Considerations

                     a.      The Endangered Species Program

       The Agency has developed the Endangered Species Protection Program to identify
pesticides whose use may cause adverse impacts on threatened and endangered and threatened
species, and to implement mitigation measures that address these impacts. The Endangered
Species Act requires federal agencies to ensure that their actions are not likely to jeopardize
listed species or adversely modify designated critical habitat. To analyze the potential of
registered pesticide uses that may affect any particular species, EPA uses basic toxicity and
exposure data developed for the REDs and then considers ecological parameters, pesticide use
information, geographic relationship between specific pesticide uses and species locations, and
biological requirements and behavioral aspects of the particular species. This analysis will also
consider the risk mitigation measures that are being implemented as a result of this RED.

       A determination that there is a likelihood of potential impact to a listed species may result
in limitations on use of the pesticide, other measures to mitigate any potential impact, or
consultations with the Fish and Wildlife Service and/or the National Marine Fisheries Service as
necessary.


                     b.      General Risk Mitigation

       2,4-DB  end use products (EPs) may also contain other registered pesticides.  Although
the Agency is not proposing any mitigation measures for products containing  2,4-DB or 2,4-DB-
DMAS specific to federally listed threatened and endangered species, the Agency needs to
address potential risks from other end-use products.  Therefore, the Agency requires that users
adopt all threatened and endangered species risk mitigation measures for all active ingredients in
the product. If a product contains multiple active ingredients with conflicting threatened and
endangered species risk mitigation measures, the more stringent measure(s) should be adopted.

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V.     What Registrants Need to Do

       The Agency has determined that 2,4-DB is eligible for reregi strati on provided that: (i)
additional data that the Agency intends to require confirm this decision; and (ii) the risk
mitigation measures outlined in this document are adopted, and (iii) label amendments are made
to reflect these measures.  To implement the risk mitigation measures, the registrants must
amend their product labeling to incorporate the label statements set forth in the Label Changes
Summary Table in Section B below (Table 23).  The additional data requirements that the
Agency intends to obtain will include, among other things, submission of the following:

       For 2,4-DB technical grade active ingredient products, the registrant needs to submit the
following items:

Within 90 days from receipt of the generic data call in (DCI):

       1.  completed response forms to the generic DCI (i.e., DCI response form and
       requirements status and registrant's response form); and

       2.  submit any time extension and/or waiver requests with a full written justification.

Within the time limit specified in the generic DCI:

       1.  cite any existing generic data which address data requirements or submit new generic
       data responding to the DCI.
Please contact Mika J. Hunter at (703) 308-0041 with questions regarding generic reregi strati on.
By US mail:
Document Processing Desk (DCI/SRRD)
Mika J. Hunter
US EPA (7508C)
1200 Pennsylvania Ave., NW
Washington, DC 20460
By express or courier service:
Document Processing Desk (DCI/SRRD)
Mika J.  Hunter
Office of Pesticide Programs (7508C)
Room 266A, Crystal Mall 2
1801 S.  Bell Street
Arlington, VA 22202
                                           45

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For end use products containing the active ingredient 2,4-DB, the registrant needs to submit the
following items for each product.

Within 90 days from the receipt of the product-specific data call-in (PDCI):

       1. completed response forms to the PDCI (i.e., PDCI response form and requirements
       status and registrant's response form); and

       2. submit any time extension or waiver requests with a full written justification.

Within eight months from the receipt of the PDCI:

       1. two  copies of the confidential statement of formula (EPA Form 8570-4);

       2. a completed original application for reregi strati on (EPA Form 8570-1). Indicate on
       the form that it is an "application for reregi strati on";

       3. five  copies of the draft label incorporating all label amendments outlined  in Table 23
       of this document;

       4. a completed form certifying compliance with data compensation requirements (EPA
       Form 8570-34); and

       5. if applicable, a completed form certifying compliance with cost share offer
       requirements (EPA Form 8570-32); and

       6. the product-specific data responding to the PDCI.

       Please contact Venus Eagle at (703) 308-8045 with questions regarding product
reregi strati on and/or the PDCI. All materials submitted in response to the PDCI should be
addressed as follows:

By US mail:                                    By express or courier service:
Document Processing Desk (PDCI/PRB)           Document Processing Desk (PDCI/PRB)
Venus Eagle                                    Venus Eagle
US EPA (7508C)                                Office of Pesticide Programs (7508C)
1200 Pennsylvania Ave., NW                    Room 266A, Crystal Mall 2
Washington, DC 20460                          1801  South Bell Street
                                               Arlington, VA 22202

-------
       A.    Manufacturing Use Products

             1.     Additional Generic Data Requirements
       The generic database supporting the reregi strati on of 2,4-DB has been reviewed and
determined to be substantially complete. However, the following additional data requirements
have been identified by the Agency as confirmatory and included in the generic DCI for this
RED. Additionally, responses to outstanding data requirements (as required in a previous DCI)
regarding spray drift and droplet size spectrum (guideline 201-1) are currently outstanding.
Table 20. Confirmatory Data Requirements for Reregistration
Guideline Study Name
Seedling Emergence: The Agency is requesting the entire
seedling emergence and vegetative vigor toxicity studies be
conducted using the TEP, in accordance with current
policy. Toxicity tests conducted with the TEP would allow
for the development of a more appropriate description of
the actual risk to non-target terrestrial plants.
Estuarine/Marine Fish Acute Toxicity test using 2,4-DB or
2,4-DB-DMAS.
Acute Estuarine/Marine Invertebrate test using 2,4-DB or
2,4-DB-DMAS
New OPPTS
Guideline No.
850.4100,
850.4150
850.1075
850.1025
Old Guideline No.
122-1 A, 122-1B
72-3 A
72-3 B
             2.     Labeling for Technical and Manufacturing Use Products

       To ensure compliance with FIFRA, technical and manufacturing use product (MP)
labeling should be revised to comply with all current EPA regulations, PR Notices and
applicable policies. The Technical and MP labeling should bear the labeling contained in Table
22 , Label Changes Summary Table.

       B.    End-Use Products

             1.     Additional Product-Specific Data Requirements

       Section 4(g)(2)(B) of FIFRA calls for the Agency to obtain any needed product-specific
data regarding the pesticide after a determination of eligibility has been made.  The Registrant
must review previous data submissions to ensure that they meet current EPA acceptance criteria
and if not, commit to conduct new studies. If a registrant believes that previously submitted data
meet current testing standards, then the study MRID numbers should be cited according to the
instructions in the Requirement Status and Registrants Response Form provided for each
product.
       A product-specific data call-in, outlining specific data requirements, accompanies this
RED.
                                           47

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              2.     Labeling for End-Use Products

       Labeling changes are necessary to implement measures outlined in Section IV above.
Specific language to incorporate these changes is specified in Table 21.

       Registrants may generally distribute and sell products bearing old labels/labeling for 26
months from the date of the issuance of this Reregi strati on Eligibility Decision document.
Persons other than the registrant may generally distribute or sell such products for 52 months
from the approval of labels reflecting the mitigation described in this RED. However, existing
stocks time frames will be established case-by-case, depending on the number of products
involved, the number of label changes, and other factors. Refer to "Existing Stocks of Pesticide
Products; Statement of Policy," Federal Register, Volume  56, No. 123, June 26, 1991.

                    a.     Label Changes Summary Table

       In order to be eligible for reregi strati on, amend all product labels to incorporate the risk
mitigation measures outlined in Section IV.  The following table describes how language on the
labels should be amended.

-------
Table 21.  Labeling Changes Summary Table
 Summary of Labeling Changes for 2,4-DB and 2,4-DB-DMAS
 Description
Amended Labeling Language
Placement on Label
 For all Manufacturing Use
 Products
"Only for formulation into an herbicide for the following use(s) [fill blank only with those uses
that are being supported by MP registrant]."
Directions for Use
 One of these statements may be
 added to a label to allow
 reformulation of the product for
 a specific use or all additional
 uses supported by a formu lator
 or user group
"This product may be used to formulate products for specific use(s) not listed on the MP label
if the formulator, user group, or grower has complied with U.S. EPA submission requirements
regarding support of such use(s)."

"This product may be used to formulate products for any additional use(s) not listed on the MP
label if the formulator, user group, or grower has complied with U.S. EPA submission
requirements regarding support of such use(s)."
Directions for Use
 Environmental Hazards
 Statements Required by the
 RED and Agency Label Policies
"Do not discharge effluent containing this product into lakes, streams, ponds, estuaries, oceans,
or other waters unless in accordance with the requirements of a National Pollution Discharge
Elimination System (NPDES) permit and the permitting authority has been notified in writing
prior to discharge. Do not discharge effluent containing this product to sewer systems without
previously notifying the local sewage treatment plant authority.  For guidance contact your
State Water Board or Regional Office of the EPA."
Precautionary
Statements
                                                                      49

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End Use Products Intended for Occupational Use
PPE Requirements Established
by the RED1
for Liquid
Formulations
"Personal Protective Equipment (PPE)"

"Some materials that are chemical-resistant to this product are (registrant inserts correct
chemical-resistant material). If you want more options, follow the instructions for category
[registrant inserts A,B,C,D,E,F,G, orH] on an EPA chemical-resistance category selection
chart."

"All mixers, loaders, applicators and other handlers must wear :
-long-sleeved shirt and long pants,
- shoes and socks, plus
-chemical-resistant gloves and chemical-resistant apron when mixing/loading, cleaning up
spills, cleaning equipment, or otherwise exposed to concentrate."

See Engineering Controls for additional requirements."
Immediately
following/below
Precautionary
Statements:  Hazards to
Humans and Domestic
Animals
Engineering Controls
"Pilots must use an enclosed cockpit in a manner that is consistent with the WPS for
Agricultural Pesticides [40 CFR 170.240(d)(6)]. Pilots must wear the PPE required on this
labeling for applicators."
Precautionary
Statements: Hazards to
Humans and Domestic
Animals

(Immediately following
PPE and User Safety
Requirements)
User Safety Requirements
"Follow manufacturer's instructions for cleaning/maintaining PPE. If no such instructions for
washables exist, use detergent and hot water. Keep and wash PPE separately fro m other
laundry."
Precautionary
Statements:  Hazards to
Humans and Domestic
Animals immediately
following the PPE
requirements

-------
User Safety Recommendations
"User Safety Recommendations

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

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

Users should remove PPE immediately after handling this product. Wash the outside of gloves
before removing. As soon as possible, wash thoroughly and change into clean clothing."
Precautionary
Statements under:
Hazards to Humans and
Domestic Animals
immediately following
Engineering Controls

(Must be placed in a
box.)
Environmental Hazards
"This chemical is toxic to fish. Do not apply directly to water, to areas where surface water is
present or to intertidal areas below the mean high water mark. Drift and runoff from treated
areas may be hazardous to aquatic organisms in neighboring issues. Do not contaminate water
when disposing of equipment washwaters. Do not contaminate water intended for irrigation or
domestic purposes. Do not apply when weather conditions favor drift from target area."

"Groundwater Contamination: Most cases of groundwater contamination involving phenoxy
herbicides such as 2,4-DB have been associated with mixing/loading and disposal sites.
Caution should be exercised when handling 2,4-DB pesticides at such sites to prevent
contamination of groundwater supplies.  Use of closed systems for mixing or transferring this
pesticide will reduce the probability of spills.  Placement of the mixing/loading equipment on
an impervious pad to contain spill will help prevent groundwater contamination."

" This chemical has properties and characteristics associated with chemicals detected in
groundwater. The use of this chemical in areas where soils are permeable, particularly where
the water table is shallow, may result in groundwater contamination.  Application around a
cistern or well may  result in contamination of drinking water or groundwater."
Precautionary
Statements
immediately following
the User Safely
Recommendations
Restricted-Entry Interval
(For 2,4-DB formulations)
"Do not enter or allow worker entry into treated areas during the restricted entry interval (REI)
of 12 hours."
Directions for Use,
Under Agricultural Use
Requirements Box
Restricted-Entry Interval
(For 2,4-DB-DMAS
formulations)
"Do not enter or allow worker entry into treated areas during the restricted entry interval (REI)
of 48 hours."
Directions for Use,
Under Agricultural Use
Requirements Box
                                                                      51

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Early Entry Personal Protective
Equipment established by the
RED.
(For 2,4-DB formulations)
For early entry PPE use the following:
"PPE required for early entry to treated areas that is permitted under the Worker Protection
Standard and that involves contact with anything that has been treated, such as plants, soil, or
water, is:
* coveralls,
* shoes plus socks
* chemical-resistant gloves made of any waterproof material."
Direction for Use
Agricultural Use
Requirements box
Early Entry Personal Protective
Equipment established by the
RED.
(For 2,4-DB-DMAS
formulations)
For early entry PPE use the following:
"PPE required for early entry to treated areas that is permitted under the Worker Protection
Standard and that involves contact with anything that has been treated, such as plants, soil, or
water, is:
* coveralls,
* shoes plus socks
* chemical-resistant gloves made of any waterproof material
* protective eyewear."
Direction for Use
Agricultural Use
Requirements box
General Application Restrictions
"Do not apply this product in a way that will contact workers or other persons, either directly or
through drift. Only protected handlers may be in the area during application."
Place in the Direction
for Use directly above
the Agricultural Use
Box.
Other Application Restrictions
(Risk Mitigation)
"Do not apply this product through any type of irrigation system."

"Do not use in or near greenhouse."

"Do not feed/graze soybean forage or harvest hay for 60 days following any 2,4-DB
application."
Directions for Use
Spray Drift
"SPRAY DRIFT MANAGEMENT"

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

"Apply only as a medium or coarser spray (ASAE standard 572) or a volume mean d iameter of
Directions for Use

-------
                                 300 microns or greater for spinning atomizer nozzles."


                                 "Apply only when the wind speed is 2-10 mph at the application site."



                                 Additional requirements for aerial applications:


                                 "The boom length must not exceed 75% of the wingspan or 90% or the rotor blade diameter."


                                 "Release spray at the lowest height consistent with efficacy and flight safety. Do not release
                                 spray at a height greater than 10 feet above the crop canopy."


                                 "When applications are made with a crosswind, the swath will be displaced downwind. The
                                 applicator must compensate for this displacement at the downwind edge of the application area
                                 by adjusting the path of the aircraft upwind."


                                 "Do not make applications into temperature inversions."


                                 Additional requirements for ground boom application:


                                 "Do not apply with a nozzle height greater than 4 feet above the crop canopy."
1 PPE that is established on the basis of Acute Toxicity of the end-use product must be compared to the active ingredient PPE in this document. The more
protective PPE must be placed in the product labeling.  For guidance on which PPE is considered more protective, see PR Notice 93-7.
 If the product contains oil or bears instructions that will allow application with an oil -containing material, the "N" designation must be dropped.
                                                                       53

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VI. APPENDICES
       55

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Appendix A. Table of Use Patterns for 2,4-DB




2,4-DB Acid
Site


Application
Timing
Formulation
[EPA Reg.
No.]


App. Type

App. Equip-
ment

Max.
Single
App. Rate
(ai)

Max. Numb.
App. Per
Season/Crop
Cycle

Max.
Number
App. Per
Year

Max.
Seasonal
Rate
(ai)

(PHI)
(PGI)
Pre-
feeding
Interval
Use Directions and
Limitations



Alfalfa
Foliar
















75% EC

[74530-15]

[71368-49]












Spray
Ground

Low Volume
Spray
(Concentrate')
Aerial










1.51bsai/A
















NS
















NS
















NS
















30 day PGI

30 day Pre-
feeding
Interval.












Groundwater restriction. Do
not apply through any type of
irrigation system. Do not
apply directly to water, or to
areas where surface water is
present or to intertidal areas
below the mean high water
mark. Do not apply when
drift is likely to occur. Do not
contaminate water by cleaning
of equipment or disposal of
equipment washwaters. Do
not contaminate water, food,
or feed by storage or disposal.
Do not contaminate water
intended for irrigation or
domestic purposes.


-------
Site


Application
Timing
Formulation
[EPA Reg.
No.]


App. Type

App. Equip-
ment

Max.
Single
App. Rate
(ai)

Max. Numb.
App. Per
Season/Crop
Cycle

Max.
Number
App. Per
Year

Max.
Seasonal
Rate
(ai)

(PHI)
(PGI)
Pre-
feeding
Interval
Use Directions and
Limitations



Peanuts
Post-
emergence





75% EC
[74530-15]

[71368-49]



Low Volume
Spray
(Concentrate')
Aircraft

Spray
Boom-
sprayer
0.375 Ibs
ai/A





2






NS






NS






30 day PHI






See "alfalfa".
Do not feed treated hay or
vines to livestock.





Soybeans
57

-------
Site


Application
Timing
Foliar



















Pre -bloom
through
mid-bloom




Formulation
[EPA Reg.
No.]


75% EC

[74530-15]

[71368-49]















75% EC
[74530-15]
[71368-49]




App. Type

App. Equip-
ment

Directed
Spray
Sprayer

















Low Volume
Spray
(concentrate)
Aircraft

Broadcast
Boom-
sprayer
Max.
Single
App. Rate
(ai)

0.375 Ibs
ai/A


















0.2184 Ibs
ai/A




Max. Numb.
App. Per
Season/Crop
Cycle

1



















1




Max.
Number
App. Per
Year

NS



















NS




Max.
Seasonal
Rate
(ai)

NS



















NS




(PHI)
(PGI)
Pre-
feeding
Interval
60 day PHI



















60 day PHI




Use Directions and
Limitations



Groundwater restriction. Do
not apply through any type of
irrigation system. Do not
apply directly to water, or to
areas where surface water is
present or to intertidal areas
below the mean high water
mark. Do not apply when
drift is likely to occur. Do not
apply to sandy soils. Do not
contaminate water by cleaning
of equipment or disposal of
equipment wash waters. Do
not contaminate water, food,
or feed by storage or disposal.
Do not contaminate water
intended for irrigation or
domestic purposes. Do not
feed treated forage or hay to
livestock.
Groundwater restriction. Do
not apply through any type of
irrigation system. Do not
apply directly to water, or to
areas where surface water is
present or to intertidal areas
below the mean high water
mark. Do not apply when

-------
Site


Application
Timing
Pre -bloom
through
mid-bloom




Formulation
[EPA Reg.
No.]


75% EC
[74530-15]
[71368-49]




App. Type

App. Equip-
ment

Directed
Spray
Sprayer




Max.
Single
App. Rate
(ai)

0.375 Ibs
ai/A




Max. Numb.
App. Per
Season/Crop
Cycle

1




Max.
Number
App. Per
Year

NS




Max.
Seasonal
Rate
(ai)

NS




(PHI)
(PGI)
Pre-
feeding
Interval
60 day PHI




Use Directions and
Limitations



drift is likely to occur. Do not
contaminate water by cleaning
of equipment or disposal of
equipment wash waters. Do
not contaminate water, food,
or feed by storage or disposal.
Do not contaminate water
intended for irrigation or
domestic purposes.
59

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2,4-DB-DMA Salt (Acid Equivalents)
Site


Application
Timing

Formulation
[EPA Reg. No.]




App.
Type

App.
Equip-
ment
Max. Single
App. Rate
(ae)



Max. Number
App. Per
Season/
Crop
Cycle

Max. Number
of App. Per
Year



Max.
Seasonal
Rate
(ae)


(PHI)
(PGI)
Pre-
feeding
Interval

Use Diretions and
Limitations




Agricultural Fallow/Idle land
Post-
emergence






















25.9% EC
[51036-232]






















Spray
Aircraft,
Boom
Sprayer





















1.5 Ibs ae/A























NS























NS























NS























NS























Groundwater
restriction. Do not
apply through any
type of irrigation
system.
Conservation
Reserve Acres. For
terrestrial uses, do
not apply directly to
water or to areas
where surface water
is present or to
intertidal areas below
the mean high water
mark. Do not
contaminate water by
cleaning of
equipment or
disposal of
equipment wash
waters. This product
is toxic to fish. Do
not graze treated
areas or harvest for
forage or hay.

-------
Site
Application
Timing
Post-
emergence
























Formulation
[EPA Reg. No.]
25.9% SC/L
[42570-38]
























App.
Type
App.
Equip-
ment
Spray
Aircraft,
Boom
Sprayer























Max. Single
App. Rate
(ae)
1.5 Ibs ae/A

























Max. Number
App. Per
Season/
Crop
Cycle
NS

























Max. Number
of App. Per
Year
NS

























Max.
Seasonal
Rate
(ae)
NS

























(PHI)
(PGI)
Pre-
feeding
Interval
NS

























Use Diretions and
Limitations
Groundwater
restriction. Do not
apply through any
type of irrigation
system.
Conservation
Reserve Acres.
Do not apply directly
to water, or to areas
where surface water
is present or to
intertidal areas below
the mean high water
mark. Do not
contaminate water by
cleaning of
equipment or
disposal of
equipment wash
waters. This product
is toxic to fish. Do
not contaminate
water, food, or feed
by storage or
disposal. Do not
graze or harvest
cover crops.
61

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Site


Application
Timing

Formulation
[EPA Reg. No.]




App.
Type

App.
Equip-
ment
Max. Single
App. Rate
(ae)



Max. Number
App. Per
Season/
Crop
Cycle

Max. Number
of App. Per
Year



Max.
Seasonal
Rate
(ae)


(PHI)
(PGI)
Pre-
feeding
Interval

Use Diretions and
Limitations




Alfalfa
Early Winter





















Late Fall






23% SC/L

[71368-48]



















23% SC/L

[71368-48]




Spray
Fixed-
wing
aircraft,
Ground

















Spray
Fixed-
wind
aircraft,
Ground


1.4221bs
ae/A




















1.4221b
ae/A





NS





















NS






NS





















NS






NS





















NS






30-60 day
PGI.

30-60 day
Pre-
feeding
interval.















30-60 day
PGI.

30-60 day
Pre-
feeding
interval.
Groundwater
restriction. Do not
apply through any
type of irrigation
system. Do not
apply directly to
water, or to areas
where surface water
is present or to
intertidal areas below
the mean high water
mark. Do not
contaminate water.
Do not contaminate
water by cleaning of
equipment or
disposal of
equipment wash
waters. Do not
contaminate water,
food, or feed by
storage or disposal.
See "early winter"
alfalfa limitations.






-------
Site


Application
Timing

Post-
emergence

























Formulation
[EPA Reg. No.]




23% SC/L
[71368-48]





25.9% EC
[51036-232]


















App.
Type

App.
Equip-
ment
Spray
Aircraft,
Ground




Spray
Aircraft,
Boom-
sprayer
















Max. Single
App. Rate
(ae)



1.4221bs
ae/A





1.51bsae/A



















Max. Number
App. Per
Season/
Crop
Cycle

NS






NS



















Max. Number
of App. Per
Year



NS






NS



















Max.
Seasonal
Rate
(ae)


NS






NS



















(PHI)
(PGI)
Pre-
feeding
Interval

30-60 day
PGI.

30-60 day
Pre-
feeding
interval.
30-60 day
PGI.

30-60 day
Pre-
feeding
interval.













Use Diretions and
Limitations




See "early winter"
alfalfa limitations.





Groundwater
restriction. Do not
apply through any
type of irrigation
system. For
terrestrial uses, do
not apply directly to
water or to areas
where surface water
is present or to
intertidal areas below
the mean high water
mark. Do not
contaminate water by
cleaning of
equipment or
disposal of
equipment wash
waters. This product
is toxic to fish.
63

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Site


Application
Timing

Post-
emergence







Post-
emergence



Formulation
[EPA Reg. No.]




25.9% SC/L
[42750-38]

[2749-516]





26.2% EC
[71368-46]



App.
Type

App.
Equip-
ment
Spray
Boom-
sprayer,
Aircraft



Spray
Aircraft,
Ground
Spray
Aircraft,
Ground


Max. Single
App. Rate
(ae)



1.5 Ibs ae/A








1.51bsae/A




Max. Number
App. Per
Season/
Crop
Cycle

NS








NS




Max. Number
of App. Per
Year



NS








NS




Max.
Seasonal
Rate
(ae)


NS








NS




(PHI)
(PGI)
Pre-
feeding
Interval

30-60 day
PGI.
30-60 day
Pre-
feeding
interval.



30-60 day
PGI

30-60 day
PHI
Use Diretions and
Limitations




See "early winter"
alfalfa limitations.
This product is toxic
to fish.






See "early winter"
alfalfa limitations.




-------
Site
Application
Timing























Formulation
[EPA Reg. No.]
26.85% EC
[15440-32]





















App.
Type
App.
Equip-
ment
Spray
Ground,
Aircraft




















Max. Single
App. Rate
(ae)
1.5 Ibs ae/A






















Max. Number
App. Per
Season/
Crop
Cycle
NS






















Max. Number
of App. Per
Year
NS






















Max.
Seasonal
Rate
(ae)
NS






















(PHI)
(PGI)
Pre-
feeding
Interval
30-60 day
PGI.

30-60 day
Pre-
feeding
interval.
















Use Diretions and
Limitations
Groundwater
restriction. Do not
apply through any
type of irrigation
system. Do not
apply directly to
water, or to areas
where surface water
is present or to
intertidal areas below
the mean high water
mark. Do not
contaminate water by
cleaning of
equipment or
disposal of
equipment wash
waters. This product
is toxic to fish. Do
not contaminate
water, food, or feed
by storage or
disposal.
65

-------
Site
Application
Timing

Post-
emergence










Formulation
[EPA Reg. No.]

26.85% EC
[15440-34]










App.
Type
App.
Equip-
ment
Spray
Aircraft,
Ground










Max. Single
App. Rate
(ae)

1.71bsae/A










Max. Number
App. Per
Season/
Crop
Cycle

NS










Max. Number
of App. Per
Year

NS










Max.
Seasonal
Rate
(ae)

NS










(PHI)
(PGI)
Pre-
feeding
Interval

30-60 day
PGI.
30-60 day
Pre-
feeding
interval.









Use Diretions and
Limitations

Groundwater
restriction. Do not
apply through any
type of irrigation
system. Do not
apply directly to
water, or to areas
where surface water
is present or to
intertidal areas below
the mean high water
mark. Do not
contaminate water by
cleaning of
equipment or
disposal of
equipment wash
waters. This product
is toxic to fish. Do
not contaminate
water, food, or feed
by storage or
disposal.
Clover

-------
Site


Application
Timing

Formulation
[EPA Reg. No.]




App.
Type

App.
Equip-
ment
Max. Single
App. Rate
(ae)



Max. Number
App. Per
Season/
Crop
Cycle

Max. Number
of App. Per
Year



Max.
Seasonal
Rate
(ae)


(PHI)
(PGI)
Pre-
feeding
Interval

Use Diretions and
Limitations





Post-
emergence

















25.9% EC
[51036-232]

















Spray
Aircraft,
Boom-
sprayer
















1.5 Ibs ae/A


















NS


















NS


















NS


















60 -day
PGI
60 -day
Pre-
feeding
Interval













Groundwater
restriction. Do not
apply through any
type of irrigation
system. For
terrestrial uses, do
not apply directly to
water or to areas
where surface water
is present or to
intertidal areas below
the mean high water
mark. Do not
contaminate water by
cleaning of
equipment or
disposal of
equipment wash
waters. This product
is toxic to fish.
67

-------
Site
Application
Timing

Post-
emergence










Formulation
[EPA Reg. No.]

25.9% SC/L
[42750-38]










App.
Type
App.
Equip-
ment
Spray
Aircraft,
Boom-
sprayer










Max. Single
App. Rate
(ae)

1.5 Ibs ae/A










Max. Number
App. Per
Season/
Crop
Cycle

NS










Max. Number
of App. Per
Year

NS










Max.
Seasonal
Rate
(ae)

NS










(PHI)
(PGI)
Pre-
feeding
Interval

60 -day
PGI
60-day
Pre-
feeding
Interval









Use Diretions and
Limitations

Groundwater
restriction. Do not
apply through any
type of irrigation
system. Do not
apply directly to
water, or to areas
where surface water
is present or to
intertidal areas below
the mean high water
mark. Do not
contaminate water by
cleaning of
equipment or
disposal of
equipment wash
waters. This product
is toxic to fish. Do
not contaminate
water, food, or feed
by storage or
disposal.
Peanuts

-------
Site


Application
Timing

Formulation
[EPA Reg. No.]




App.
Type

App.
Equip-
ment
Max. Single
App. Rate
(ae)



Max. Number
App. Per
Season/
Crop
Cycle

Max. Number
of App. Per
Year



Max.
Seasonal
Rate
(ae)


(PHI)
(PGI)
Pre-
feeding
Interval

Use Diretions and
Limitations





Post- plant

























23% F1C
[51036-00231]
























Broadcast
Aircraft,
Boom-
sprayer

Spray
Aircraft,
Boom-
sprayer

















0.3938 Ibs
ae/A



0.2406 Ibs
ae/A



















NS




NS




















2




2




















NS




NS




















30-45 day
PHI



45 day
PHI



















Groundwater
restriction. Do not
apply through any
type of irrigation
system. For
terrestrial uses, do
not apply directly to
water or to areas
where surface water
is present or to
intertidal areas below
the mean high water
mark. Do not
contaminate water by
cleaning of
equipment or
disposal of
equipment wash
waters. This product
is toxic to fish. Do
not contaminate
water, food, or feed
by storage or
disposal. Do not
feed hay or vines to
livestock.
69

-------
Site
Application
Timing
Post-plant


























Formulation
[EPA Reg. No.]

23% SC/L
[42750-39]
























App.
Type
App.
Equip-
ment
Spray
Boom-
sprayer,
Aircraft
























Max. Single
App. Rate
(ae)
0.2406 Ibs
ae/A

























Max. Number
App. Per
Season/
Crop
Cycle
NS


























Max. Number
of App. Per
Year
2


























Max.
Seasonal
Rate
(ae)
NS


























(PHI)
(PGI)
Pre-
feeding
Interval
45 day
PHI

























Use Diretions and
Limitations
Ground-water
restriction. Do not
apply through any type
of irrigation system.
For terrestrial uses, do
not apply directly to
water or to areas where
surface water is present
or to intertidal areas
below the mean high
water mark. Do not
contaminate water by
cleaning of equipment
or to disposal or
equipment wash waters.
This product is toxic to
fish. Do not
contaminate water,
food, or feed by storage
or disposal. Do not feed
treated hay or vines to
livestock. Do not apply
directly to water, or to
areas where surface
water is present or to
intertidal areas below
the mean high water
mark. Do not
contaminate water.

-------
Site


Application
Timing

Post-plant


























Formulation
[EPA Reg. No.]




23% SC/L
[42750-39]





23% SC/L
[2749-126]



















App.
Type

App.
Equip-
ment
Broadcast
Aircraft,
Boom-
sprayer


Broadcast
Aircraft,
Ground

Spray
Aircraft,
Ground















Max. Single
App. Rate
(ae)



0.3938 Ibs
ae/A




0.2406 Ib
ae/A


0.3938 Ibs
ae/A
















Max. Number
App. Per
Season/
Crop
Cycle

NS




NS



NS

















Max. Number
of App. Per
Year



2




2



2

















Max.
Seasonal
Rate
(ae)


NS




NS



NS

















(PHI)
(PGI)
Pre-
feeding
Interval

30-45 day
PHI




45 day
PHI


30 day
PHI
















Use Diretions and
Limitations




Groundwater
restriction. Do not
apply through any type
of irrigation system.
For terrestrial uses, do
not apply directly to
water or to areas where
surface water is present
or to intertidal areas
below the mean high
water mark. Do not
contaminate water by
cleaning of equipment
or to disposal or
equipment wash waters.
This product is toxic to
fish. Do not
contaminate water,
food, or feed by storage
or disposal. Do not feed
treated hay or vines to
livestock. Do not apply
directly to water, or to
areas where surface
water is present or to
intertidal areas below
the mean high water
mark. Do not
contaminate water.
71

-------
Site


Application
Timing

Post-plant



















Formulation
[EPA Reg. No.]




25.9% EC
[51036-232]



















App.
Type

App.
Equip-
ment
Spray
Aircraft,
Boom-
sprayer
Broadcast
Aircraft,
Boom-

sprayer













Max. Single
App. Rate
(ae)



0.25 Ibs
ae/A

0.4 Ibs ae/A

















Max. Number
App. Per
Season/
Crop
Cycle

NS

NS

















Max. Number
of App. Per
Year



2

2

















Max.
Seasonal
Rate
(ae)


NS

NS

















(PHI)
(PGI)
Pre-
feeding
Interval

30-45 day
PHI

30-45 day
PHI
















Use Diretions and
Limitations




Groundwater
restriction. Do not
apply through any
type of irrigation
system. For
terrestrial uses, do
not apply directly to
water or to areas
where surface water

is present or to
intertidal areas below
the mean high water
mark. Do not
contaminate water by
cleaning of
equipment or
disposal of
equipment wash
waters. This product
is toxic to fish. Do
not feed hay or vines
to livestock.

-------
Site


Application
Timing


























Formulation
[EPA Reg. No.]




25.9% SC/L
[42750-38]























App.
Type

App.
Equip-
ment
Spray
Aircraft

Broadcast
Aircraft,
Boom-
sprayer

Spray
Boom-
sprayer














Max. Single
App. Rate
(ae)



0.4 Ibs ae/A







0.25 Ibs
ae/A















Max. Number
App. Per
Season/
Crop
Cycle

NS







NS
















Max. Number
of App. Per
Year



2







2
















Max.
Seasonal
Rate
(ae)


NS







NS
















(PHI)
(PGI)
Pre-
feeding
Interval

30-45
day PHI






45 day
PHI















Use Diretions and
Limitations




Groundwater
restriction. Do not
apply through any
type of irrigation
system. Do not
apply directly to
water, or to areas
where surface water
is present or to
intertidal areas below
the mean high water
mark. Do not
contaminate water by
cleaning of
equipment or
disposal of
equipment wash
waters. This product
is toxic to fish. Do
not contaminate
water, food, or feed
by storage or
disposal. Do not
feed treated hay or
vines to livestock.
73

-------
Site


Application
Timing



























Formulation
[EPA Reg. No.]





26.85% EC
[15440-34]























App.
Type

App.
Equip-
ment
Spray
Aircraft,
Ground

Broadcast
Aircraft,
Ground



















Max. Single
App. Rate
(ae)



0.275 Ibs
ae/A


0.45 Ibs/A





















Max. Number
App. Per
Season/
Crop
Cycle

NS



NS





















Max. Number
of App. Per
Year



2



2





















Max.
Seasonal
Rate
(ae)


NS



NS





















(PHI)
(PGI)
Pre-
feeding
Interval

45 day
PHI


30-45 day
PHI




















Use Diretions and
Limitations





Groundwater
restriction. Do not
apply through any
type of irrigation
system. Do not
apply directly to
water, or to areas
where surface water
is present or to
intertidal areas below
the mean high water
mark. Do not
contaminate water by
cleaning of
equipment or
disposal of
equipment wash
waters. This product
is toxic to fish. Do
not contaminate
water, food, or feed
by storage or
disposal. Do not
feed treated hay or
vines to livestock.

-------
Site


Application
Timing


























Formulation
[EPA Reg. No.]




26.85% EC
[15440-32]























App.
Type

App.
Equip-
ment
Broadcast
Aircraft,
Ground

Spray
Aircraft,
Ground


















Max. Single
App. Rate
(ae)



0.4 Ibs ae/A



0.25 Ibs
ae/A



















Max. Number
App. Per
Season/
Crop
Cycle

NS



NS




















Max. Number
of App. Per
Year



o
J



2




















Max.
Seasonal
Rate
(ae)


NS



NS




















(PHI)
(PGI)
Pre-
feeding
Interval

30-45 day
PHI


45 day
PHI



















Use Diretions and
Limitations




Groundwater
restriction. Do not
apply through any
type of irrigation
system. Do not
apply directly to
water, or to areas
where surface water
is present or to
intertidal areas below
the mean high water
mark. Do not
contaminate water by
cleaning of
equipment or
disposal of
equipment wash
waters. This product
is toxic to fish. Do
not contaminate
water, food, or feed
by storage or
disposal. Do not
feed treated hay or
vines to livestock.
75

-------
Site
Application
Timing
Ground-crack





















Formulation
[EPA Reg. No.]
25.9% EC
[51036-232]




















App.
Type
App.
Equip-
ment
Spray
Aircraft,
Boom-
sprayer


















Max. Single
App. Rate
(ae)
0.25 Ibs
ae/A




















Max. Number
App. Per
Season/
Crop
Cycle
NS





















Max. Number
of App. Per
Year
2





















Max.
Seasonal
Rate
(ae)
NS





















(PHI)
(PGI)
Pre-
feeding
Interval






















Use Diretions and
Limitations
Groundwater
restriction. Do not
apply through any
type of irrigation
system. For
terrestrial uses, do
not apply directly to
water or to areas
where surface water
is present or to
intertidal areas below
the mean high water
mark. Do not
contaminate water by
cleaning of
equipment or
disposal of
equipment wash
waters. This product
is toxic to fish. Do
not feed hay or vines
to livestock.

-------
Site
Application
Timing













Formulation
[EPA Reg. No.]
25.9% SC/L
[42750-38]











App.
Type
App.
Equip-
ment
Spray
Aircraft,
Boom-
sprayer











Max. Single
App. Rate
(ae)
0.25 Ibs
ae/A











Max. Number
App. Per
Season/
Crop
Cycle
NS












Max. Number
of App. Per
Year
2












Max.
Seasonal
Rate
(ae)
NS












(PHI)
(PGI)
Pre-
feeding
Interval













Use Diretions and
Limitations
Groundwater
restriction. Do not
apply through any
type of irrigation
system. Do not
apply directly to
water, or to areas
where surface water
is present or to
intertidal areas below
the mean high water
mark. Do not
contaminate water by
cleaning of
equipment or
disposal of
equipment wash
waters. This product
is toxic to fish. Do
not contaminate
water, food, or feed
by storage or
disposal. Do not
feed treated hay or
vines to livestock.
77

-------
Site
Application
Timing
Post-
emergence






















Formulation
[EPA Reg. No.]
23% SC/L
[71368-47]
[71368-48]






















App.
Type
App.
Equip-
ment
Spray
Aircraft,
Fixed-
wing
aircraft,
Boom-
sprayer


















Max. Single
App. Rate
(ae)
0.3828 Ib/A























Max. Number
App. Per
Season/
Crop
Cycle
NS























Max. Number
of App. Per
Year
2























Max.
Seasonal
Rate
(ae)
NS























(PHI)
(PGI)
Pre-
feeding
Interval
30 day
PHI






















Use Diretions and
Limitations
Groundwater
restriction. Do not
apply through any
type of irrigation
system. Do not
apply directly to
water, or to areas
where surface water
is present or to
intertidal areas below
the mean high water
mark. Do not
contaminate water by
cleaning of
equipment or
disposal of
equipment wash
waters. Do not
contaminate water,
food, or feed by
storage or disposal.
Do not contaminate
water. Do not feed
treated hay or vines
to livestock.

-------
Site
Application
Timing






















Formulation
[EPA Reg. No.]
25.9% EC
[51036-232]




















App.
Type
App.
Equip-
ment
Broadcast
Aircraft,
Boom-
sprayer

Spray
Aircraft,
Boom-
sprayer













Max. Single
App. Rate
(ae)
0.25 Ibs
ae/A




















Max. Number
App. Per
Season/
Crop
Cycle
NS





















Max. Number
of App. Per
Year
NS





















Max.
Seasonal
Rate
(ae)
NS





















(PHI)
(PGI)
Pre-
feeding
Interval
30-45 day
PHI




















Use Diretions and
Limitations
Groundwater
restriction. Do not
apply through any
type of irrigation
system. For
terrestrial uses, do
not apply directly to
water or to areas
where surface water
is present or to
intertidal areas below
the mean high water
mark. Do not
contaminate water by
cleaning of
equipment or
disposal of
equipment wash
waters. This product
is toxic to fish. Do
not feed hay or vines
to livestock.
79

-------
Site


Application
Timing





























Formulation
[EPA Reg. No.]




25.9% SC/L
[2749-516]



25.9% SC/L
[42750-38]





















App.
Type

App.
Equip-
ment
Broadcast
Aircraft,
Boom-
sprayer

Spray
Aircraft,
Boom-
sprayer



















Max. Single
App. Rate
(ae)



0.4 Ibs ae/A




0.4 Ibs ae/A






















Max. Number
App. Per
Season/
Crop
Cycle

NS




NS






















Max. Number
of App. Per
Year



2




2






















Max.
Seasonal
Rate
(ae)


NS




NS






















(PHI)
(PGI)
Pre-
feeding
Interval

30 day
PHI



30-45 day
PHI





















Use Diretions and
Limitations





Groundwater
restriction. Do not
apply through any
type of irrigation
system. Do not
apply directly to
water, or to areas
where surface water
is present or to
intertidal areas below
the mean high water
mark. Do not
contaminate water by
cleaning of
equipment or
disposal of
equipment wash
waters. This product
is toxic to fish. Do
not contaminate
water, food, or feed
by storage or
disposal. Do not
feed treated hay or
vines to livestock.
Do not contaminate
water.

-------
Site
Application
Timing

























Formulation
[EPA Reg. No.]

26.2% EC
[71368-46]






















App.
Type
App.
Equip-
ment
Broadcast
Aircraft,
Boom-
sprayer





















Max. Single
App. Rate
(ae)
0.4 Ibs ae/A
























Max. Number
App. Per
Season/
Crop
Cycle
NS
























Max. Number
of App. Per
Year
2
























Max.
Seasonal
Rate
(ae)
NS
























(PHI)
(PGI)
Pre-
feeding
Interval
30 day
PHI























Use Diretions and
Limitations
Groundwater
restriction. Do not
apply through any
type of irrigation
system. Do not
apply directly to
water, or to areas
where surface water
is present or to
intertidal areas below
the mean high water
mark. Do not
contaminate water.
Do not contaminate
water by cleaning of
equipment or
disposal of
equipment wash
waters. Do not
contaminate water,
food, or feed by
storage or disposal.
Do not feed treated
hay or vines to
livestock.
81

-------
Site


Application
Timing

Formulation
[EPA Reg. No.]




App.
Type

App.
Equip-
ment
Max. Single
App. Rate
(ae)



Max. Number
App. Per
Season/
Crop
Cycle

Max. Number
of App. Per
Year



Max.
Seasonal
Rate
(ae)


(PHI)
(PGI)
Pre-
feeding
Interval

Use Diretions and
Limitations




Peppermint
Early post-
emergence



















26.2% SC/L
[ID94001000]



















Spray
Sprayer



















0.75 Ibs
ae/A



















NS




















NS




















NS




















90 day
PHI



















Groundwater
restriction. Do not
apply through any
type of irrigation
system. Do not
apply directly to
water, or to areas
where surface water
is present or to
intertidal areas below
the mean high water
mark. Do not
contaminate water.
Do not contaminate
water by cleaning of
equipment or
disposal of
equipment wash
waters. Do not
contaminate water,
food, or feed by
storage or disposal.
Soybeans

-------
Site


Application
Timing

Formulation
[EPA Reg. No.]




App.
Type

App.
Equip-
ment
Max. Single
App. Rate
(ae)



Max. Number
App. Per
Season/
Crop
Cycle

Max. Number
of App. Per
Year



Max.
Seasonal
Rate
(ae)


(PHI)
(PGI)
Pre-
feeding
Interval

Use Diretions and
Limitations






Pre -emergence





















23% F1C
[51036-231]





















Spray
Aircraft,
Boom-
sprayer




















0.2188






















NS






















NS























NS





















60 day
PGI
60 day
PHI

60 day
Pre-
feeding
Interval














Groundwater
restriction. Do not
apply through any
type of irrigation
system. For
terrestrial uses, do
not apply directly to
water or to areas
where surface water
is present or to
intertidal areas below
the mean high water
mark. Do not
contaminate water by
cleaning of
equipment or
disposal of
equipment wash
waters. This product
is toxic to fish. Do
not contaminate
water, food, or feed
by storage or
disposal.
83

-------
Site


Application
Timing

Pre -emergence























Formulation
[EPA Reg. No.]





23% SC/L

[42750-39]




















App.
Type

App.
Equip-
ment
Spray
Aircraft,
Boom-
sprayer




















Max. Single
App. Rate
(ae)



0.2188























Max. Number
App. Per
Season/
Crop
Cycle

NS























Max. Number
of App. Per
Year



NS























Max.
Seasonal
Rate
(ae)


NS























(PHI)
(PGI)
Pre-
feeding
Interval

60 day
PGI

60 day
PHI

60 day
Pre-
feeding
Interval














Use Diretions and
Limitations




Groundwater
restriction. Do not
apply through any
type of irrigation
system. For
terrestrial uses, do
not apply directly to
water or to areas
where surface water
is present or to
intertidal areas below
the mean high water
mark. Do not
contaminate water by
cleaning of
equipment or
disposal of
equipment wash
waters. This product
is toxic to fish. Do
not contaminate
water, food, or feed
by storage or
disposal.

-------
Site


Application
Timing

Pre -emergence



















Formulation
[EPA Reg. No.]




25.9% EC

[51036-232]

















App.
Type

App.
Equip-
ment
Spray
Aircraft,
Boom
Sprayer
















Max. Single
App. Rate
(ae)



0.225 Ibs
ae/A


















Max. Number
App. Per
Season/
Crop
Cycle

NS



















Max. Number
of App. Per
Year



NS



















Max.
Seasonal
Rate
(ae)


NS



















(PHI)
(PGI)
Pre-
feeding
Interval

60 day
PGI

60 day
PHI

60 day
Pre-
feeding
Interval










Use Diretions and
Limitations




Groundwater
restriction. Do not
apply through any
type of irrigation
system. For
terrestrial uses, do
not apply directly to
water or to areas
where surface water
is present or to
intertidal areas below
the mean high water
mark. Do not
contaminate water by
cleaning of
equipment or
disposal of
equipment wash
waters. This product
is toxic to fish.
85

-------
Site


Application
Timing

Pre-emergence























Formulation
[EPA Reg. No.]




25.9% SC/L

[42750-38]





















App.
Type

App.
Equip-
ment
Spray
Aircraft,
Boom-
sprayer




















Max. Single
App. Rate
(ae)



0.225
Ibs ae/A






















Max. Number
App. Per
Season/
Crop
Cycle

NS























Max. Number
of App. Per
Year



NS























Max.
Seasonal
Rate
(ae)


NS























(PHI)
(PGI)
Pre-
feeding
Interval

60 day
PGI

60 day
PHI

60 day
Pre-
feeding
Interval














Use Diretions and
Limitations




Groundwater
restriction. Do not
apply through any
type of irrigation
system. For
terrestrial uses, do
not apply directly to
water or to areas
where surface water
is present or to
intertidal areas below
the mean high water
mark. Do not
contaminate water by
cleaning of
equipment or
disposal of
equipment wash
waters. This product
is toxic to fish. Do
not contaminate
water, food, or feed
by storage or
disposal.

-------
Site
Application
Timing
Pre -emergence





















Formulation
[EPA Reg. No.]


26.2% EC

[71368-46]

















App.
Type
App.
Equip-
ment
Broadcast
Aircraft,
Boom-
sprayer


















Max. Single
App. Rate
(ae)
0.225
Ibs ae/A




















Max. Number
App. Per
Season/
Crop
Cycle
NS





















Max. Number
of App. Per
Year
NS





















Max.
Seasonal
Rate
(ae)
NS





















(PHI)
(PGI)
Pre-
feeding
Interval
60 day
PHI




















Use Diretions and
Limitations
Groundwater
restriction. Do not
apply through any
type of irrigation
system. Do not
apply directly to
water, or to areas
where surface water
is present or to
intertidal areas below
the mean high water
mark. Do not
contaminate water.
Do not contaminate
water by cleaning of
equipment or
disposal of
equipment wash
waters. Do not
contaminate water,
food, or feed by
storage or disposal.
87

-------
Site


Application
Timing

Pre -emergence





Pre -emergence
















Formulation
[EPA Reg. No.]




26. 85% EC

[15440-32]

26.85% EC

[15440-34]
















App.
Type

App.
Equip-
ment
Spray
Aircraft,
Ground

Spray
Aircraft,
Ground
















Max. Single
App. Rate
(ae)



0.225 Ibs
ae/A


0.25 Ibs
ae/A

















Max. Number
App. Per
Season/
Crop
Cycle

NS



NS


















Max. Number
of App. Per
Year



NS



NS


















Max.
Seasonal
Rate
(ae)


NS



NS


















(PHI)
(PGI)
Pre-
feeding
Interval

60 day
PGI

60 day
PHI

60 day
Pre-
feeding
Interval














Use Diretions and
Limitations




Groundwater
restriction. Do not
apply through any
type of irrigation
system. For
terrestrial uses, do
not apply directly to
water or to areas
where surface water
is present or to
intertidal areas below
the mean high water
mark. Do not
contaminate water by
cleaning of
equipment or
disposal of
equipment wash
waters. This product
is toxic to fish. Do
not contaminate
water, food, or feed
by storage or
disposal.

-------
Site
Application
Timing


Pre -bloom








Pre -bloom

Pre -bloom



Formulation
[EPA Reg. No.]

23% SC/L
[71368-47]
[71368-48]








23% SC/L
[2749-126]
25.9% SC/L

[2749-516]

App.
Type
App.
Equip-
ment
Broadcast
Aircraft,
Boom-
sprayer,
Fixed-
wing
Aircraft







Broadcast
Boom-
sprayer
Broadcast
Aircraft,
Boom-
sprayer
Max. Single
App. Rate
(ae)

0.1751bs
ae/A









0.2188 Ibs
ae/A

0.1 82 Ibs
ae/A


Max. Number
App. Per
Season/
Crop
Cycle

NS









NS

NS



Max. Number
of App. Per
Year

NS









NS

NS



Max.
Seasonal
Rate
(ae)

NS









NS

NS



(PHI)
(PGI)
Pre-
feeding
Interval

60 day
PHI













Use Diretions and
Limitations

Do not apply directly
to water, or to areas
where surface water
is present or to
intertidal areas below
the mean high water
mark. Do not
contaminate water.
Do not contaminate
water by cleaning of
equipment or
disposal of
equipment wash
waters. Do not
contaminate water,
food, or feed by
storage or disposal.
Groundwater
restriction. Do not
apply through any
type of irrigation
system.




89

-------
Site


Application
Timing

Pre -bloom



Bloom

















Formulation
[EPA Reg. No.]




26.2% EC

[71368-46]

23% SC/L

[71368-46]




23% SC/L

[2749-126]
23% SC/L







App.
Type

App.
Equip-
ment
Broadcast
Aircraft,
Boom-
sprayer
Broadcast
Aircraft,
boom-
sprayer



Broadcast
Boom-
sprayer
Broadcast

Boom-

sprayer,
Fixed-
wing
aircraft
Max. Single
App. Rate
(ae)



0.1821bs
ae/A


0.2188 Ibs
ae/A
















Max. Number
App. Per
Season/
Crop
Cycle

NS



NS

















Max. Number
of App. Per
Year



NS



NS

















Max.
Seasonal
Rate
(ae)


NS



NS

















(PHI)
(PGI)
Pre-
feeding
Interval





60 day
PHI
















Use Diretions and
Limitations








Ground-water
restriction. Do not
apply through any type
of irrigation system.
Do not apply directly to
water, or to areas where
surface water is present
or to areas below the
mean high water mark.
Do not contaminate
water by cleaning of
equipment or disposal
of equipment wash
waters. Do not
contaminate water,

food, or feed by storage
or disposal. Do not
contaminate
water.


-------
Site
Application
Timing
Bloom











Formulation
[EPA Reg. No.]
25.9% SC/L
[2749-516]









26.2% EC
[71368-46]
App.
Type
App.
Equip-
ment
Broadcast
Aircraft,
Boom-
sprayer










Max. Single
App. Rate
(ae)
0.222 Ibs
ae/A











Max. Number
App. Per
Season/
Crop
Cycle
NS











Max. Number
of App. Per
Year
NS











Max.
Seasonal
Rate
(ae)
NS











(PHI)
(PGI)
Pre-
feeding
Interval
60 day
PHI











Use Diretions and
Limitations
Groundwater
restriction. Do not
apply through any
type of irrigation
system. Do not
apply directly to
water, or to areas
were surface water is
present or to
intertidal areas below
the mean high water
mark. Do not
contaminate water by
cleaning of
equipment or
disposal of
equipment wash
waters. Do not
contaminate water,
food, or feed by
storage or disposal.
Do not contaminate
water.

91

-------
Site
Application
Timing

Post-
emergence















Post-
emergence
Formulation
[EPA Reg. No.]
23% F1C

[51036-231]















23% F1C
[51036-231]
App.
Type
App.
Equip-
ment
Broadcast
Aircraft,
Boom-
sprayer















Directed
Spray
Band
Sprayer
Max. Single
App. Rate
(ae)
0.2188 Ibs
ae/A
















0.3938 Ibs
ae/A
Max. Number
App. Per
Season/
Crop
Cycle
NS



















Max. Number
of App. Per
Year
2



















Max.
Seasonal
Rate
(ae)
NS



















(PHI)
(PGI)
Pre-
feeding
Interval
60 day
PGI
60 day
PHI

60 day
Pre-
feeding
Interval











Use Diretions and
Limitations
Groundwater
restriction. Do not
apply through any
type of irrigation
system. For
terrestrial uses, do
not apply directly to
water or to areas
where surface water
is present or to
intertidal areas below
the mean high water
mark. Do not
contaminate water by
cleaning of
equipment or
disposal of
equipment wash
waters. This prodct
is toxic to fish. Do
not contaminate
water, food or feed
by storage or
disposal.

-------
Site
Application
Timing
Post-
emergence


















Formulation
[EPA Reg. No.]
23% SC/L

[71368-47]
[71368-48]

















App.
Type
App.
Equip-
ment
Directed
Spray
Low
Pressure
Ground
Sprayer















Max. Single
App. Rate
(ae)
0.3828 Ibs
ae/A


















Max. Number
App. Per
Season/
Crop
Cycle
NS



















Max. Number
of App. Per
Year
2



















Max.
Seasonal
Rate
(ae)
NS



















(PHI)
(PGI)
Pre-
feeding
Interval
60 day
PHI


















Use Diretions and
Limitations
Groundwater
restriction. Do
not apply
through any
type of
irrigation
system. For
terrestrial uses,
do not apply
directly to
water or to
areas where
surface water
is present or to
intertidal areas
below the
mean high
water mark.
Do not
contaminate
93

-------
Site


Application
Timing

emergence





















Formulation
[EPA Reg. No.]




23% SC/L
[42750-39]
[71368-47]
[71368-48]









23% SC/L

[42750-39]


25.9% EC

[51036-232]


App.
Type

App.
Equip-
ment
Broadcast
Boom-
sprayer
(only
42750-39)
Broadcast
Aircraft

Directed
Spray
Band
Sprayer
Directed
Spray
Low
Pressure
Ground
Sprayer
Directed
Spray
Band
Sprayer

Max. Single
App. Rate
(ae)



0.2188 Ibs
ae/A










0.3938
Ibs ae/A




0.4 Ibs ae/A




Max. Number
App. Per
Season/
Crop
Cycle


















NS




Max. Number
of App. Per
Year




















2




Max.
Seasonal
Rate
(ae)



















NS




(PHI)
(PGI)
Pre-
feeding
Interval

60 day
PHI

60 day
PGI
60 day
Pre-
feeding
Interv
al








60 day
PHI

60 day
PGI
Use Diretions and
Limitations





















Groundwater
restriction. Do not
apply through any
type of irrigation
system. For

-------
Site


Application
Timing

Post-
emergence














Post-
emergence


Formulation
[EPA Reg. No.]




25.9% EC
[51036-232]











25.9% SC/L

[2749-516]
25. 9% SC/L
[42750-38]


App.
Type

App.
Equip-
ment
Band
Treatment
Sprayer











Band
Treatment
Sprayer
Broadcast
Aircraft,
Boom
Sprayer
Max. Single
App. Rate
(ae)



0.225 Ibs
ae/A











0.225 Ibs
ae/A

0.225 Ibs
ae/A


Max. Number
App. Per
Season/
Crop
Cycle













NS






Max. Number
of App. Per
Year















2






Max.
Seasonal
Rate
(ae)














NS






(PHI)
(PGI)
Pre-
feeding
Interval

60 day
Free-
feeding
Interval










60 day
PHI

60 day
PGI*

60 day
Pre-
Use Diretions and
Limitations




terrestrial uses, do
not apply directly to
water or to areas
where surface water
is present or to
intertidal areas below
the mean high water
mark. Do not
contaminate water by
cleaning of
equipment or
disposal of
equipment wash
waters. This product
is toxic to fish.
Groundwater
restriction. Do not
apply through any
type of irrigation
system. Do not
apply directly to
water, or to areas
where surface water
95

-------
Site


Application
Timing







Post-emergence




Formulation
[EPA Reg. No.]




25.9% SC/L

[42750-38]
[2749-516]


26.2% EC
[71368-46]



App.
Type

App.
Equip-
ment
Directed
Spray
Low
Pressure
Ground
Sprayer
Directed
Spray
Low
Pressure
Ground
Sprayer
Max. Single
App. Rate
(ae)




0.4 Ibs ae/A




0.4 Ibs ae/A




Max. Number
App. Per
Season/
Crop
Cycle







NS




Max. Number
of App. Per
Year









2




Max.
Seasonal
Rate
(ae)








NS




(PHI)
(PGI)
Pre-
feeding
Interval







60 day
PHI




Use Diretions and
Limitations










Groundwater
restriction. Do not
apply through any
type of irrigation
system. Do not
apply directly to

-------
Site


Application
Timing




























Formulation
[EPA Reg. No.]




26.2% EC
[71368-46]
















26.85% EC

[15440-32]


26.85% EC
[15440-34]


App.
Type

App.
Equip-
ment
Band
Treatment
Sprayer
















Directed
Spray
Band
Sprayer

Directed
Spray
Band
Sprayer
Max. Single
App. Rate
(ae)



0.225 Ibs
ae/A

















0.4 Ibs ae/A




0.45 Ibs
ae/A


Max. Number
App. Per
Season/
Crop
Cycle



















NS








Max. Number
of App. Per
Year





















2








Max.
Seasonal
Rate
(ae)




















NS








(PHI)
(PGI)
Pre-
feeding
Interval



















60 day
PGI

60 day
PHI

60 day
Pre-
feeding
Use Diretions and
Limitations




water, or to areas
where surface water
is present or to
intertidal areas below
the mean high water
mark. Do not
contaminate water.
Do not contaminate
water by cleaning of
equipment or
disposal of
equipment wash
waters. Do not
contaminate water,
food, or feed by
storage or disposal.
Do not apply to
sandy soils. Do not
feed treated forage or
hay to livestock.
Groundwater
restriction. Do not
apply through any
type of irrigation
system. Do not
apply directly to
water, or to areas
where surface water
is present or to
97

-------
Site


Application
Timing

Post-
emergence




Foliar


















Formulation
[EPA Reg. No.]




26.85% EC

[15440-32]
26.85% EC

[15440-34]
23% SC/L
[2749-126]


















App.
Type

App.
Equip-
ment
Broadcast
Aircraft,
Ground
Broadcast
Aircraft,
Ground
Directed
Spray
Low
Pressure
Ground
Sprayer















Max. Single
App. Rate
(ae)



0.225 Ibs
ae/A

0.25 Ibs
ae/A

0.3938 Ibs
ae/A


















Max. Number
App. Per
Season/
Crop
Cycle







NS


















Max. Number
of App. Per
Year









2


















Max.
Seasonal
Rate
(ae)








NS


















(PHI)
(PGI)
Pre-
feeding
Interval







60 day
PHI


















Use Diretions and
Limitations










Do not apply to
water or to areas
where surface water
is present or to
intertidal areas below
the mean high water
mark. Do not
contaminate water.
Do not apply to
sandy soils. Do not
contaminate water by
cleaning of
equipment or
disposal of
equipments wash
waters. Do not
contaminate water,
food, or feed by
storage or disposal.
Do not feed treated
forage or hay to

-------
Site
Application
Timing


Formulation
[EPA Reg. No.]


App.
Type
App.
Equip-
ment

Max. Single
App. Rate
(ae)


Max. Number
App. Per
Season/
Crop
Cycle


Max. Number
of App. Per
Year


Max.
Seasonal
Rate
(ae)


(PHI)
(PGI)
Pre-
feeding
Interval


Use Diretions and
Limitations

livestock.
Spearmint
99

-------
Site


Application
Timing

Early Post-
emergence













Formulation
[EPA Reg. No.]




26.2% SC/L
[ID9400 10000]













App.
Type

App.
Equip-
ment
0.75 Ibs
ae/A













Max. Single
App. Rate
(ae)



Spray
Sprayer













Max. Number
App. Per
Season/
Crop
Cycle

NS













Max. Number
of App. Per
Year



NS













Max.
Seasonal
Rate
(ae)


NS













(PHI)
(PGI)
Pre-
feeding
Interval

90 day
PHI













Use Diretions and
Limitations




Ground-water
restriction. Do not
apply through any type
of irrigation system.
Do not apply directly to
water, or to areas where
surface water is present
or to intertidal areas
below the mean high
water mark. Do not
contaminate water by
cleaning of equipment
or disposal of
equipment wash waters.
Do not contaminate
water, food, or feed by
storage or disposal.
Trefoil

-------
Site


Application
Timing

Post-
emergence

















Formulation
[EPA Reg. No.]




25.9% EC
[51036-232]

















App.
Type

App.
Equip-
ment
Spray
Aircraft,
Boom
Sprayer
















Max. Single
App. Rate
(ae)



1.5 Ibs ae/A


















Max. Number
App. Per
Season/
Crop
Cycle

NS


















Max. Number
of App. Per
Year



NS


















Max.
Seasonal
Rate
(ae)


NS


















(PHI)
(PGI)
Pre-
feeding
Interval

NS


















Use Diretions and
Limitations




Groundwater
restriction. Do not
apply through any
type of irrigation
system. For
terrestrial uses, do
not apply directly to
water or to areas
where surface water
is present or to
intertidal areas below
the mean high water
mark. Do not
contaminate water by
cleaning of
equipment or
disposal of
equipment wash
waters. This product
is toxic to fish.
101

-------
Site
Application
Timing
Post-
emergence










Formulation
[EPA Reg. No.]
25.9%SC/L
[42750-38]









App.
Type
App.
Equip-
ment
Spray
Aircraft,
Boom
Sprayer









Max. Single
App. Rate
(ae)
1.5 Ibs ae/A










Max. Number
App. Per
Season/
Crop
Cycle
NS










Max. Number
of App. Per
Year
NS










Max.
Seasonal
Rate
(ae)
NS










(PHI)
(PGI)
Pre-
feeding
Interval
60 day
PGI
60 day
Pre-
feeding
Interval








Use Diretions and
Limitations
Groundwater
restriction. Do not
apply through any
type of irrigation
system. Do not
apply directly to
water, or to areas
where surface water
is present or to
intertidal areas below
the mean high water
mark. Do not
contaminate water by
cleaning of
equipment or
disposal of
equipment wash
waters. This product
is toxic to fish. Do
not contaminate
water, food, or feed
by storage or
disposal.

-------
     Appendix B. Table of Generic Data Requirements and Studies Used to Make the
                                 Reregistration Decision

Guide to Appendix B
       Appendix B contains listing of data requirements which support the reregi strati on for
active ingredients  within case #0196 (2,4-DB) covered by this RED. It contains generic data
requirements that apply to 2,4-DB in all products, including data requirements for which a
"typical formulation" is the test substance.

The data table is organized in the following formats:

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

       2.     Use Pattern (Column 4). This column indicates the use patterns for which the
data requirements  apply.  The following letter designations are used for the given use patterns.

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

3.     Bibliographic Citation (Column 3). If the Agency has acceptable data in its files, this
column list the identify number of each study. This normally is the Master Record Identification
(MRID) number, but may be a "GS" number if no MRID number has been assigned.  Refer to
the Bibliography appendix for a complete citation of the study.
                                          103

-------
New
Guideline
Number
Old
Guideline
Number
Requirement
Use
Pattern
Bibliographic Citation(s)
PRODUCT CHEMISTRY
830.1550
830.1600
830.1620
830.1670
830.1700
830.1750
830.1800
830.6302
830.6303
830.7100
830.6314
830.6304
830.6313
830.7000
830.7200
830.7300
830.75507
7560/757
0
830.6316
830.6317
830.7370
830.78407
7860
830.7950
830.6320
830.7050
61-1
61-2 A
61-2 B
61-2 B
62-1
62-2
62-3
63-2
63-3
63-18
63-14
63-4
63-13
63-12
63-5
63-7
63-11
63-16
63-17
63-10
63-8
63-9
63-20
None
Product Identity and
Composition
Description of
Starting Material
Description of
Production Process
Discussion of
Formation of
Impurities
Preliminary Analysis
Certified Limits
Enforcement of
Analytical Method
Color
Physical State
Viscosity
Oxidation/Reduction
Odor
Stability
pH
Melting Point
Density
Partition Coefficient
Explodability
Storage Stability
Dissociation
Constant
Water Solubility
Vapor Pressure
Corrosion
Characteristics
UV/Visible
Absorption
A,B
A,B
A, B
A, B
A,B
A,B
A, B
A, B
A,B
A,B
A,B
A, B
A, B
A, B
A,B
A,B
A, B
A, B
A, B
A, B
A, B
A, B
A,B
A, B
45770101, 45996901, 43119201, 43969501
(DMAS)
431192001, 45770101, 45996901, 431192,
43969501
45770102, 45996901, 431192, 43969501
45770103, 45996901, 431192, 43969501
45770105, 45996901, 431192, 43969505
45770104, 45770105, 45996901, 43969501
45770105, 45996901, 431192, 43969505
45996904
45996904, 431192, 43969504
43969504,
431192,43969504
45996904
45996904,431192
45996904,431192
45996904,431192
45996904, 431192, 43969504
45996904,431192
431192,43969504
431192
431192
45996904,431192
45996904,431192
431192,43969504
45996904,431192
ECOLOGICAL EFFECTS

-------
New
Guideline
Number
850.4100
850.4150
850.4230
850.2100
850.2200
850.2100
850.2200
850.2200
850.2300
850.3020
850.1075
850.1075
850.1010
850.1075
850.1025

Old
Guideline
Number
122-1A
122-1B
123-1
71-2
71-2B
71-1
None
None
71-4
141-1
72-1A
72- 1C
72-2A
72-3 A
72-3B

Requirement
Seedling Emergence
Vegetative Vigor
Early Seedling
Growth Toxicity
Avian Acute Dietary
Toxicity - Bobwhite
Quail
Avian Acute Dietary
Toxicity - Mallard
Duck
Avian Acute Dietary
Toxicity - Peking
Duck
Avian Acute Dietary
Toxicity - Pheasant
Avian Acute Dietary
Toxicity - Japanese
Quail
Chronic
Reproductive
Toxicity Study in
Birds
Honey Bee Acute
Contact Toxicity
Fish Toxicity
Bluegill
Fish Toxicity
Rainbow Trout
Invertebrate Toxicity
Daphnid
Estuarine/Marine
Fish Acute Toxicity
Test
Estuarine/Marine
Toxicity - Mollusk
Stonefly Acute
Toxicity
Use
Pattern
A,B
A, B
A,B
A,B
A,B
A,B
A,B
A, B
A, B
A,B
A, B
A, B
A,B
A, B
A,B
A, B
Bibliographic Citation(s)
41605401 (DMAS), 43359001 (DMAS)
Additional Data Required (see Tables 20 and
21)
41605401 (DMAS), 43359001
Additional Data Required (see Tables 20 and
21)
43054001 (DMAS)
108367 (DMAS), 126694 (DMAS), 41370103
(DMAS), 41370102
108368 (DMAS), 126695 (DMAS), Accession
# 22923
92162
Accession # 22923
Accession # 36935
Waiver submitted (Reserved)
Accession* 18842
40762602, 41407802 (DMAS)
40762601, 92168 (DMAS), 116347 (DMAS),
41370104 (DMAS)
41407801, 41642701 (DMAS)
Outstanding Study
Outstanding Study
40094602
105

-------
New
Guideline
Number
850.1075
850.1400
850.1075
850.1075
850.5400
850.3020
850.4400
Old
Guideline
Number
72-1A
72-4
72- 1C
72-1
122-2
141-1
122-2
Requirement
Fish Acute Toxicity-
Bluegill
Fish Early Life- stage
Toxicity Test
Fish Acute Toxicity-
Rainbow Trout
Fish Acute Toxicity-
Fathead Minnow
Algal Toxicity
Honey Bee Acute
Contact Toxicity
Aquatic Plant
Toxicity Test using
Lemna spp.
Use
Pattern
A,B
A,B
A,B
A, B
A, B
A, B
A, B
Bibliographic Citation(s)
Accession #s 50682, 03503, and RP24DBO;
MRID 54668 (DMAS)
Accession #s 50682, 03503, and RP24DB023
Accession #03503
41407803 (DMAS)
Accession* 18842
In Review
OCCUPATIONAL/RESIDUE EXPOSURE
NONE
NONE
201-1
202-1
Droplet Size
Spectrum
Drift Field
Evaluation
A, B
A, B
Data Gap
Data Gap
TOXICOLOGY
870.1100
870.1200
870.1300
870.2400
870.2500
870.2600
870.3100
870.3150
870.3200
870.3465
81-1
81-2
81-3
81-4
81-5
81-6
82-1A
82-1B
82-2
82-4
Acute Oral Toxicity-
Rat
Acute Dermal
Toxicity-Rabbit/Rat
Acute Inhalation
Toxicity-Rat
Primary Eye
Irritation-Rabbit
Primary Skin
Irritation
Dermal Sensitization
90-Day Feeding -
Rodent
90-Day Feeding -
Non-rodent
2 1 -Day Dermal -
Rabbit/Rat
90-day Subchronic
Inhalation Toxicity
Test-Rat
A, B
A,B
A,B
A, B
A, B
A, B
A, B
A,B
A,B
A,B
00128854, 0092159, 41224401 (DMAS)
0128854, 41224402 (DMAS)
41774001,41370101 (DMAS),
0128854, 00092160, 41958001 (DMAS)
0128854, 0250871 (DMAS)
43593904 (Under Review), 4396891 1
(DMAS) (Under Review)
00104739, 41775401 (DMAS)
00092165
44729501 (DMAS), 41551301, 41529901
(DMAS)
Study Waived

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New
Guideline
Number
870.7600
870.4100
870.4200
870.3700
870.3700
870.3800
870.4300
870.5140
870.5375
870.5550

870.7485

Old
Guideline
Number
85-3
83-1B
83-2B
83-3A
83-3B
83-4
83-5
84-2A
84-2B
84-2
84-4
85-1

Requirement
Dermal Penetration
Chronic Feeding
Toxicity - Non-
Rodent
Oncogenicity -
Mouse
Developmental
Toxicity - Rat
Developmental
Toxicity - Rabbit
2-Generation
Reproduction - Rat
Combined Chronic
Toxicity/
Carcinogenicity
Gene Mutation
(Ames Test)
Structural
Chromosomal
Aberration
Unscheduled DNA
Synthesis in
Mammalian Cells in
Culture
Other Genotoxic
Effects
General Metabolism
Characterization of
2,4-DB
Use
Pattern
A,B
A,B
A, B
A, B
A, B
A,B
A,B
A, B
A, B
A,B
A, B
A,B
A, B
Bibliographic Citation(s)
44729501 (DMAS)
42006301, 42384001
42387301, 40257502, 41936201
41382701, 41382702, 42536101 (DMAS),
42595201 (DMAS)
41529902, 41529903
40257503
40257501
40257504, 41256101 (DMAS)
40257506, 41224403 (DMAS)
40257507, 41358901 (DMAS)
41810701 (DMAS), 40257505
41981601, 44774101, 43830101 (DMAS)
44774102, 44774103, 44334701, 44334702,
44334703
ENVIRONMENTAL FATE
Non-
guideline
835.2120
835.2410
835.2370
835.4100
835.4200
835.4400

161-1
161-3
161-4
162-1
162-2
162-3
Non-guideline
Hydrolysis
Photodegradation -
Soil
Photodegradation -
Air
Aerobic Soil
Metabolism
Anaerobic Soil
Metabolism
Anaerobic Aquatic
Metabolism
A, B
A,B
A, B
A, B
A, B
A, B
A,B
37080
43991801, 41101101, 45512401, 41888001
41101103,41101104,42678401
41479702
41325501
41325501
43908301
107

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New
Guideline
Number
835.4300
835.2240
835.1230
835.1410
835.6100
NONE
Old
Guideline
Number
162-4
161-2
163-1
163-2
164-1
165-4
Requirement
Aerobic Aquatic
Metabolism
Aqueous Photolysis
Sediment and Soil
Adsorption/Des orpti
on for Parent and
Degradates
Volatility-Lab
Terrestrial Field
Dissipation
Bioconcentration in
Fish
Use
Pattern
A,B
A, B
A,B
A,B
A, B
A,B
Bibliographic Citation(s)
41325501, 43779601
41101102,42067801
41101105,41617201, 143294
Reserved
41325502, 44660502 (peanuts), 44660503
(soybeans), 44680701 (alfalfa)
Waived
RESIDUE CHEMISTRY
860.1000
860.1300
860.1300
860.1340
860.1340
860.1850
860.1380
860.1480
170-1
171-4A
171-4B
171-4C
171-4D
165-1
171-4E
171-4J
Background
Nature of Residue -
Plants
Nature of Residue -
Livestock
Residue Analytical
Method -plants
Residue Analytical
Method- An im al
Confined Rotational
Crop
Storage Stability
Meat, Milk, Poultry,
Eggs
Milk and the Fat,
Meat, and Meat
Byproducts of
Cattle, Goats, Hogs,
Horses and Sheep
Eggs and the Fat,
Meat, and Meat
Byproducts of
Poultry
A, B
A, B
A,B
A,B
A, B
A,B
A,B
A,B
44997903
42965901 (alfalfa), 43033901 (peanut),
43033803 (soybean), 42965901, 43033801,
43033803
43009801 (hen), 43033802 (goat)
43033801, 43358601, 43201701 (soybean),
43121801 (alfalfa), 43393301 (peanuts)
Additional Data in Review
44334704, 44546301, 44997901
Outstanding Study
43004301
44334705, 44997902, 43607001, 43607002
44997902, 44334705

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New
Guideline
Number
860.1500
860.1650
Old
Guideline
Number
171-4K
171-13
Requirement
Crop Field Trials
Analytical Reference
Standards
Use
Pattern
A,B

Bibliographic Citation(s)
43620301 (alfalfa), 00116018 (clover),
00102943 (mint), 43631201 (peanut),
43607001 (soybean)
Additional Data in Review
Outstanding Study
Processed Food/Feed
860.1520
171-4L
Processed Food
A,B
00102943, 00161196 (mint), 43621201
(peanut), 43607002 (soybean)
109

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Appendix C. Technical Support Documents

       Additional documentation in support of this RED is maintained in the OPP docket,
located in room 119, Crystal Mall #2, 1801 Bell St., Arlington, VA 22202.  It is open Monday
through Friday, excluding legal holidays, from 8:30 AM to 4:00 PM.

       The docket initially contained preliminary risk assessments and related documents as of
April 28, 2004.  Sixty days later the first public comment period closed. The EPA then
considered comments and revised the risk assessments.

       All documents, in hard copy form, may be viewed in the OPP docket room or
downloaded or viewed via the Internet at the following site: http://www.epa.gov/edockets

       These documents include:

1.      2,4-DB and 2,4-DB-DMA - Report of the Hazard Identification Assessment Review
       Committee, June 13, 2003

2.      2,4-DB [4-(2,4-dichlorophenoxy) butyric acid] and 2,4-DB dimethylamine salt:
       REVISED Product Chemistry and Residue Chemistry  Summary Documents for the
       Reregi strati on Eligibility Decision Document (RED), July 19, 2004

3.      2,4-DB and 2,4-DB-DMA Toxicology Chapter for RED, July 20, 2004

4.      2,4-DB Acute and Chronic Dietary Exposure Assessments for the Reregi strati on
       Eligibility Decision, July 13, 2004

5.      2,4-DB and 2,4-DB-DMA Human Health Risk Assessment, July 20, 2004

6.      HED's Response to Error Only Comments from 2,4-DB Task Force, July 20, 2004

7.      2,4-DB: Revised Occupational and Residential Exposure and Risk Assessment for the
       Reregi strati on Eligibility Decision (RED) Document, July 19, 2004

8.      Environmental Fate and Effects Division Revised Risk Assessment for 4-(2,4-
       dichlorophenoxy) Butyric Acid (2,4-DB) and Dimethylamine 4-(2,4-dichlorophenoxy)
       Butyrate (2,4-DB-DMAS) Reregi strati on Eligibility Document, December 13, 2004

9.      Review of 2,4-DB Incident Reports, May 11, 2004

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Appendix D.  Citations Considered to be Part of the Data Base Supporting the
              Reregistration Decision (Bibliography)

GUIDE TO APPENDIX D

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

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

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

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

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

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       b.     Document date.  The date of the study is taken directly from the document. When
the date is followed by a question mark, the bibliographer has deduced the date from the
evidence contained in the document. When the date appears as (1999), the Agency was unable
to determine or estimate the date of the document.

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

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

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

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

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

(4)    Volume Identification (Accession Numbers). The final element in the trailing
parentheses identifies the EPA accession number of the volume in which the original submission
of the study appears.  The six-digit accession number follows the symbol "CDL," which stands
for "Company Data Library."  This accession number is in turn followed by an alphabetic suffix
which shows the relative position of the study within the volume.
2,4-DB Bibliography
 MRID        Citation Reference
 00002865

              Osborne, W.W.; Rud, O.E.; Hams, C.; Hameed, K.M.; Pnstou, R.; Lambe, R.C.; Fox, J.A.; Sill,
              L.  (1976) Evaluation of Certain Herbicide-Nematicide Treatments on the Incidence of Peanut
              Pod Rot. (Unpublished study received Sep 28, 1976 under 400-130; prepared by Virginia
              Polytechnic Institute and State Univ., Dept.  of Plant Pathology and Physiology, submitted by
              Uniroyal Chemical, Bethany, Conn.; CDL:230405-W)


 00004463      National Weed Committee, Western Section, Canada (1967) 1967 Report of the Research
              Appraisal Committee for Western Canada. (Unpublished study received Nov 6, 1967 under 464-
              398; submitted by Dow Chemical U.S.A., Midland, Mich.; CDL:003622-H)
 00004484
              Leng, M.L. (1970) Summary Statement on Residue Studies with Phenoxy Herbicides in Forage

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               Grasses and Legumes. (Unpublished study received Jan 11, 1971 under 9F0761; prepared by
               Dow Chemical Co., submitted by National Agricultural Chemicals Association, Industry Task
               Force on Phenoxy Herbicide Tolerances, Washington, D.C.; CDL:091313-A)

00004488       Leng, M.L.  (1968) Metabolism in Animals,  (pp.  35-38 only; unpublished study received Jan
               11, 1971 under 9F0761; prepared by Dow Chemical Co., submitted by National Agricultural
               Chemicals Association, Industry Task Force on Phenoxy Herbicide Tolerances, Washington,
               D.C.; CDL:091313-F)

00004570       Ball, R.W.E.; Soundy, M. (1958) 2,4-DB and MCPB in Lucerne: Part I.  The Effect of 2,4-DB
               and MCPB on the Development of the Lucerne Plant. (Preprint, British Weed Control
               Conference, November, 1958; unpublished study received Dec 5, 1960 under 359-400; prepared
               by May & Baker, Ltd., Agricultural and Horticultural Research Station, Eng., submitted by
               Rhone-Poulenc, Inc.,  Monmouth Junction, N.J.; CDL:023310-C)

00004571       Ball, R.W.E.; Wilson, C.W.  (1958) 2,4-DB and MCPB in Lucerne-Part III-The Effects of MCPB
               and 2,4-DB on Established Lucerne. (Preprint, British Weed Control Conference, November,
               1958; unpublished study received Dec 5, 1960 under 359-400; prepared by May & Baker, Ltd.,
               Agricultural and Horticultural Research Station, Eng., submitted by Rhone-Poulenc, Inc.,
               Monmouth Junction, N.J.; CDL:023310-D)

00004661       Leng, M.L.  (1968) Review on the Metabolism of Phenoxy Compounds in Plants and Animals.
               Summary of studies 092090-B through 092090- AF. (Unpublished study received Sep 16, 1968
               under 8F0676; submitted by Dow Chemical U.S.A., Midland, Mich.; CDL:092090-A)

00004662       Shaw, W.C.; Hilton, J.L.; Moreland, D.E.; Jansen, L.L.  (1960) Herbicides in plants. Pages 119-
               125,130-133, In The Nature  and Fate of Chemicals Applied to Soils, Plants, and Animals.
               Washington, D.C.: U.S.  Agricultural Research Service.  (ARS 20-9; also in unpublished
               submission received Sep 16, 1968 under 8F0676; submitted by Dow Chemical U.S.A., Midland,
               Mich.; CDL: 092090-B)

00004664       Swanson, C.R. (1965) Chlorinated phenoxyacetic and phenoxypropionic acids. Pages 9-16,26-
               36, In Metabolic Fate of Herbicides in Plants. Washington, D.C.: U.S. Agricultural Research
               Service.  (Crops Research, ARS 34-66; also in unpublished submission received Sep 16, 1968
               under 8F0676; submitted by Dow Chemical U.S.A., Midland, Mich.; CDL:092090-D)

00004685       Linscott, D.L. (1964) Degradation of 4-(2,4-Dichlorophenoxy)-butyric acid 4-

               (2,4-DB) in plants. Journal of Agricultural and Food Chemistry 12(1):7-10.  (Also in
               unpublished submission received Sep 16,  1968 under 8F0676; submitted by Dow Chemical
               U.S.A., Midland, Mich.; CDL:092090-AD)

00004701       Bache, C.A.; Hardee, D.D.; Holland, R.F.; Lisk, D.J.  (1964) Absence of Phenoxyacid herbicide
               residues in the milk of dairy  cows at high feeding levels. Journal of Dairy Science
               XLVII(3):298-299. (Also in unpublished submission received Sep 12, 1968 under 8F0676;
               submitted by Dow Chemical U.S.A., Midland, Mich.; CDL: 092980-O)

00004702       Bache, C.A.; Lisk, D.J.; Wagner, D.G.; Wagner, R.G. (1964) Elimination of 2-

               Methyl-4-chlorophenoxyacetic acid and 4-(2-Methyl-4- chlorophenoxybutyric) acid in the urine
               from cows.  Journal of Dairy Science XLVII(l):93-95. (Also in unpublished submission
               received Sep 12, 1968 under 8F0676; submitted by Dow Chemical U.S.A., Midland, Mich.;
               CDL:092980-P)

00004706       Gutenmann, W.H.; Hardee, D.D.; Holland, R.F.; Lisk, D.J. (1963) Disappearance of 4-(2,4-
               Dichlorophenoxybutyric) acid herbicide in the dairy cow. Journal of Dairy Science
               XLVI(9):991-992.  (Also in  unpublished submission received Sep 12, 1968 under 8F0676;
               submitted by Dow Chemical U.S.A., Midland, Mich.; CDL: 092980-U)

00004710       Lisk, D.J.; Gutenmann, W.H.; Bache, C.A.; Warner, R.G.; Warner, D.  G.  (1963) Elimination of
               2,4-D in the urine of steers fed 4- (2,4-DB) or 2,4-D.  Journal of Dairy Science XLVI(12): 1435-
               1437. (Also In unpublished  submission received Sep 12, 1968 under 8F0676; submitted by Dow
               Chemical U.S.A., Midland, Mich.; CDL: 092980-Y)
                                                113

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00004717       Gutenmann, W.H.; Lisk, D.J. (1963) Rapid determination of 4(2,4-DB) and a metabolite, 2,4-D,
               in treated forage by electron affinity spectroscopy.  Journal of Agricultural and Food Chemistry
               11(4): 304-306. (Also in unpublished submission received Sep 12, 1968 under 8F0676;
               submitted by Dow Chemical U.S.A., Midland, Mich.; CDL:092980-AI)
00004718       Hagm, R.D.; Lmscott, D.L.  (1965) Determination of 4-(2,4-Dichlorophenoxy)-
               butyric acid (2,4-DB) and 2,4-Dichlorophenoxyacetic acid (2,4-D) in forage plants. Journal of
               Agricultural and Food Chemistry 13(2): 123 -125. (Also in unpublished submission received Sep
               12, 1968 under 8F0676; submitted by Dow Chemical U.S.A., Midland, Mich.; CDL:092980-AJ)
00004725       Stanley, C.W. (1966) Derivatization of pesticide-related acids and phenols for gas
               chromatographic determination. Journal of Agricultural and Food Chemistry 14(3):321 -323.
               (Also in unpublished submission received Sep 12, 1968 under 8F0676; submitted by Dow
               Chemical U.S.A., Midland, Mich.; CDL:092980-AQ)
00004772       Menzie, C.M. (1966) Metabolism of pesticides.  Pages 61-69,  In Special Scientific Report-
               Wildlife No. 96.  By U.S. Fish and Wildlife Service.  U.S.  Dept. of the Interior. (Also in
               unpublished submission received Oct 19, 1971 under 8F0676; submitted by National Agricultural
               Chemicals Association, Industry Task Force on Phenoxy Herbicide Tolerances, Washington,
               D.C.;CDL:091183-N)

00004784       Chipman Chemical Company, Incorporated. (1967) Summary  of Available Acute Toxicity Data
               on a Bromoxynil octanoate/MCPA Isoocty Ester Formulation as Compared with Bromoxynil and
               MCPA: SR/3/67.  (Unpublished study received Mar 10, 1967 under 359-601; submitted by
               Rhone-Poulenc, Inc., Monmouth Junction, N.J.; CDL:023320-D)
00009580       Chilcote, D.O.; Phillips, J.C.; Frakes, R.V. (1976) Growth Regulators and Seed Yield in Alfalfa.
               (Unpublished study received Mar  4, 1976 under 6F1752; submitted by Uniroyal Chemical,
               Bethany, Conn.; CDL:095528-C)

00009581       Oregon State University, Crop Science Department (1972) Influence of Selected Growth
               Regulators on Alfalfa Seed Yield  and Yield Components. (Unpublished study received Mar 4,
               1976 under 6F1752; prepared in cooperation with Southern Oregon Experiment Station,
               submitted by Uniroy al Chemical, Bethany, Conn.; CDL:  095528-E)

00009654       Corbin, F.T.  (1972) Interaction Effects of Pesticides on Peanuts.  (Unpublished study received
               Feb 13, 1974 under 400-103; prepared by North Carolina State Univ., Agricultural Experiment
               Station, submitted by Uniroyal Chemical, Bethany, Conn.; CDL:028581 -T)
00010033       Bondarenko, D.D.; Dowler,  et al.  (1956) Herbicides on Soybeans. (Unpublished study received
               Feb 18, 1963 under 524-104; submitted by Monsanto Co., St. Louis, Mo.; CDL:003949-K)
00011970       Currey, W.L.; Peters, R.A. (1968) Control of yellow rocket (Barbarea vulgaris) and other
               broadleaf weeds associated with established alfalfa.  Northeastern Weed Science Society
               Conference Proceedings :455-458. (Also in unpublished submission received Aug 30, 1973
               under 4F1428; submitted by E.I. du Pont de Nemours  & Co., Inc., Wilmington, Del.;
               CDL:093806-Q)
00011990       Santelmann, P.W.  (1968) Weed Control in Alfalfa.  (Unpublished study received Aug 30, 1973
               under 4F1428; prepared by Oklahoma State Univ., submitted by E.I. du Pont de Nemours & Co.,
               Inc., Wilmington, Del; CDL:093806-AL)
00012077       Appleby, A.P. (1972) Winter Herbicide Applications for Broadleaf Weed Control in Established
               Mint.  (Unpublished study received Dec 3, 1975 under 6F1713; prepared by  Oregon State Univ.,
               Farm Crops Dept., submitted by E.I.  du Pont de Nemours & Co., Inc., Wilmington, Del.;
               CDL:095184-S)
00012297       Evans, J.O.; Woods, C.R. (1969)  Control of Shepherd's Purse Mustard in Established Alfalfa,
               1969-Smithfield.  (Unpublished study received Dec 5,  1972 under 352-317; prepared by Utah
               State Univ., submitted by E.I. du Pont de Nemours & Co., Wilmington, Del; CDL:002966-G)
00012303       Evans, J.O.; Woods, C.R. (1969) Control of Annual Weeds in Established Alfalfa with
               Herbicides-1969.  (Unpublished study received Dec 5,  1972 under 352-317;  prepared by  Utah
               State Univ., submitted by E.I. du Pont de Nemours & Co., Wilmington, Del; CDL:002966-M)
00012319       Evans, J.O.; Woods, C.R. (1969)  Control of Winter Annual Weeds in Established Alfalfa, 1969.
               (Unpublished study received Dec  5, 1972 under 352-317; prepared by  Utah State Univ.,

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               submitted by E.I. du Pont de Nemours & Co., Wilmington, Del; CDL:002966-AC)
00012320       Evans, J.O.; Woods, C.R.  (1969) Weed Control in Established Alfalfa, 1969Mendon, Utah.
               (Unpublished study received Dec 5, 1972 under 352-317; prepared by Utah State Univ.,
               submitted by E.I. du Pont de Nemours & Co., Wilmington, Del; CDL:002966-AD)
00012323       Evans, J.O.; Woods, C.R.  (1969) Annual Weed Control in Established Alfalfa by Herbicides,
               1969-Wellsville, Utah. (Unpublished study received Dec 5, 1972 under 352-317; prepared by
               Utah State Univ., submitted by E.I. du Pont de Nemours & Co., Wilmington, Del.;
               CDL:002966-AG)
00012324       Evans, J.O.; Woods, C.R.  (1969) Control of Annual Weeds in Established Alfalfa, 1969-Benson,
               Utah. (Unpublished study received Dec 5, 1972 under 352-317; prepared by Utah State Univ.,
               submitted by E.I. du Pont de Nemours & Co., Wilmington, Del; CDL: 002966-AH)
00012635       Counce, R.W.  (1969) Summarization of Forage and Weed Control Specialist Survey (Alfalfa
               Herbicides). (Unpublished study received Oct  1, 1969 under OF0892; submitted by Geigy
               Chemical  Corp., Ardsley, NY.; CDL:093189-C)
00014443       Appleby, A.P.  (1973) Postemergence Herbicide Applications for Broadleaf Weed Control in
               Established Peppermint. (Unpublished study received Dec 3, 1975 under 6F1713; prepared by
               Oregon State Univ., Farm Crops Dept., submitted by E.I. du Pont de Nemours & Co., Inc.,
               Wilmington, Del; CDL:095184-T)
00017870       Frans, R.E. (1963) Weed Control and Yield of Soybeans].  (Unpublished study received Apr 9,
               1965 under 352-199; prepared by Univ. of Arkansas,  submitted by E.I. du Pont de Nemours &
               Co., Wilmington, Del; CDL:028551-G)
00018057       Currey, W.L.  (1973) Tank Mixtures of 2,4-DB and Lorox for Weed Control in Soybeans: 1973
               Evaluations of Field Size Experiments.  (Unpublished study including letter dated Dec 28, 1973
               from W.L. Currey to James D. Riggleman, received Mar 20, 1974 under 264- 164; prepared by
               Univ. of Florida, Cooperative Extension Service, submitted by  Union Carbide Agricultural
               Products Co., Ambler, Pa.; CDL:221913-A)
00018058       Rogers, R.L. (1973) Tank Mixture of Linuron + 2,4-DB as a Post- emergence Directed Spray in
               Soybeans]. (Unpublished study including letter dated  Dec 4,  1973 from R.L.  Rogers to J.D.
               Riggleman, received Mar 20, 1974 under 264-164; prepared by  Louisiana State Univ.,
               Agricultural Experiment Station, Plant Pathology Dept., submitted by Union Carbide
               Agricultural Products Co., Ambler, Pa.; CDL:221913-C)
00018151       Grossman, R.D.; Renkoski, M.; Puletz, E.E.; et al.  (1978) Lorox 4L: Experimental Use Permit
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00018284       E.I.  du Pont de Nemours & Company (1972) Data Supporting the Use of Lorox Linuron Weed
               Killer plus Butyrac 175 as  a Tank Mixture as a Directed Postemergence Spray To Control
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00018782       Santelmann, P.W.; Chandler, M.  (1968) Postemergence Herbicides in Soybeans-
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                                                115

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               Co., Washington, D.C.; CDL:093569-F)

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00027005       University of Wyoming, Agricultural Experiment Station (1967) Wyoming Weed Control: Guide
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                                                117

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00027944       Horn, G.C.  (1960) Chemicals Control Weeds in Your Turf |.  (Unpublished study received Mar
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                                                119

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              A)

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                                                121

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00115132       Reagan, E.; Becci, P. (1982) Acute Dermal Toxicity Study in Rabbits: RESCUE: FDRL Study
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40015601       Ivett, J. (1986) Clastogemc Evaluation of 2,4-DB Tech 98.03% in an in vitro Cytogenetic Assay:
               Measuring Chromosomal Aberration Frequencies in  Chinese Hamster Ovary (CHO) Cells: Final
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40125500       FBI/Gordon Corp. (1987) Submission of Product Chemistry Data in Support of Application for
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40125502       Goff, U. (1987) Trimec 901 Liquid Weed & Feed 20-0-0: Formal Report of Analysis for N-
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40257500       Union Carbide Agricultural Products Co., Inc. (1987) Submission of Chronic Toxicology Data
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40257501       Mackenzie, K.  (1987) Lifetime Dietary Combined Chronic Toxicity and Oncogenicity Study in
               Albino Rats with 2,4-DB: Laboratory Project No.  HLA 6158-103. Unpublished study prepared
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40257502       Mackenzie,  K.  (1987) Lifetime Dietary Oncogenicity Study in Albino Mice with 2,4-DB:
               Laboratory Project ID: HLA 6158-104.  Unpublished study prepared by Hazleton Laboratories
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40257503       Bottomley, A.; Bowman, A.; Offer, J.; et al. (1986) 2,4-DB- Effect on Two  Generations of the
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40257504       Jagannath, D. (1987) Mutagemcity Test on 2,4-DB Technical 98.03% ... in  the Ames
               Salmonella/Microsome Reverse Mutation Assay: HLA Study No.: 9360-0-
               401TR. Unpublished study prepared by Hazleton Laboratories America, Inc. 32 p.
40257505       Young, R.  (1987) Mutagenicity Test on 2,4-DB, Technical ... in the CHO/HGPRT Forward
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               Laboratories America, Inc. 35 p.

                                                 123

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40257506       Ivett, J. (1987) Mutagenicity Test on 2,4-DB Tech 98.03% in an in vitro Cytogenic Assay
               Measuring Chromosomal Aberration Frequencies in Chinese Hamster Ovary (CHO) Cells: HLA
               Study No.  9360-0-437.  Unpublished study prepared by Hazleton Laboratories America, Inc.  30
               P-
40257507       Cifone, M. (1987) Mutagenicity Test on 2,4-DB Technical, 98.03% in the Rat Primary
               Hepatocyte Unscheduled DNA Synthesis Assay: HLA Study No. 9360-0-
               447.  Unpublished study prepared by Hazleton Laboratories America, Inc.  24 p.
40295900       Union Carbide Agricultural Products Co., Inc.  (1987) Submission of Chemistry Data in Support
               of 2,4-DB Technical Acid.  Transmittal of 3 studies.
40295901       A.H. Marks and Co. (1987) A.H. Marks 2,4-DB Technical Acid: Product Identity and
               Composition: (Supplemental Data for May  1985 Report): Document No. 1.  Unpublished
               compilation,  lip.
40295902       A.H. Marks and Co. (1987) A.H. Marks 2,4-DB Technical Acid: Analysis and Certification of
               Product Ingredients: (Supplemental Data for May 1985 Report): Document No.  2. Unpublished
               study. 32 p.
40295903       A.H. Marks and Co. (1987) A.H. Marks 2,4-DB Technical Acid: Physical and Chemical
               Properties: (Supplemental Data for May 1985 Report): Document No. 3. Unpublished study. 3
               P-
40709200       AH Marks & Co.  Ltd.  (1988) Submission of Chemistry Data in Support of Marks DB Technical
               Acid.  Transmittal of 1 study.
40755600       Gilmore, Inc. (1988) Submission of Chemistry Data to Support the Registration for Buxatone
               2E.  Transmittal of 1 study.
40755601       Fisher, R.  (1988) Product Chemistry Buxatone 2E|. Unpublished study  prepared by Gilmore,
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40762600       EPA (1988) Submission of Documents Received from the RD PM for Addition to the Amchem
               Technical 2,4-DB Registration Standard. Transmittal of 2 studies.
40762601       McCann, J. (1976) Biological Report of Analysis of Amchem Technical 2,4-DB: Rainbow Trout
               (Salmo gairdneri): Static Jar Test 928. Unpublished study prepared by Terrestrial and Aquatic
               Biology Laboratory. 2 p.
40762602       McCann, J. (1976) Biological Report of Analysis of Amchem Technical 2,4-DB: Bluegill
               (lepomis macrichirus): Static Jar Test 938.  Unpublished study prepared by Terrestrial and
               Aquatic Biology Laboratory. 1 p.
40977800       Cedar Chemical Corp.  (1989) Submission of Chemistry Data in Support of 2,4-
               DB Reregistration Standard. Transmittal of 6 studies.
40977805       Bellet, E. (1989) Product Chemistry for 2,4-DB Acid Technical: Typical Physical Properties|.
               Unpublished study prepared by Cedar Chemical Corp. 6 p.
40977806       Bellet, E. (1989) Product Chemistry for Butoxone: Typical Physical Properties . Unpublished
               study prepared by Cedar Chemical Corp. 6 p.
41101100       Rhone-Poulenc Ag Co. (1989) Submission of Data To Support Registration of 2,4-DB:
               Environmental Fate Studies. Transmittal of 5 studies.
41101101       Rustum, A. (1988) Hydrolysis of Carbon 14|-2,4-DB in Buffered Aqueous Solutions: Laboratory
               ID: HLA 6015-395. Unpublished study prepared by Hazleton Laboratories America, Inc.  77 p.
41101102       Rustum, A. (1988) Artificial Sunlight Photodegradation of carbon 14|-,4 DB in a Buffered
               Aqueous Solution: Project ID: HLA 6015-396.  Unpublished study prepared by Hazleton
               Laboratories America, Inc.  146 p.
41101103       Saxena, A. (1988) Artificial Sunlight Photodegradation of carbon 14|-2,4-DB on Soil: Project
               ID: HLA 6015-397. Unpublished study prepared by Hazleton Laboratories America, Inc.  90 p.
41101104       Saxena, A. (1988) Artificial Sunlight Photodegradation of carbon 14|-2,4-DB in Soil: HLA
               6015-397.  Unpublished study prepared by Hazleton Laboratories America, Inc. 39 p.
41101105       Rustum, A. (1987) The Adsorption and Desorption of carbon 14| -2, 4-DB on Representative
               Agricultural Soils: Project ID: HLA 6015-394.  Unpublished study prepared by Hazleton
               Laboratories America, Inc.  59 p.
41148200       2,4-DB Task Force (1989) Submission of Product Chemistry Data in Support of 2,4-DB
               Registration Standard. Transmittal of 1 study.
41148201       Hardwick, F. (1988) Product Chemistry for Marks DB Technical Acid.  Unpublished study
               prepared by A H Marks & Co. Limited. 24 p.
41224400       Rhone-Poulenc Ag Co. (1989) Submission of Toxicity Data in Support  of Registration Standard

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               of 2,4-DB DMA.  Transmittal of 3 studies.
41224401       Rush, R. (1989) Acute Oral Toxicity Study of Butyrac 200 in Rats: Study No.  3147.42.
               Unpublished study prepared by Springborn Life Sciences, Inc.  78 p.
41224402       Rush, R. (1989) Acute Dermal Toxicity Study of Butyrac 200 in Rabbits: Study No. 3147.43.
               Unpublished study prepared by Springborn Life Sciences, Inc.  30 p.
41224403       Murli, H. (1989) Butyrac 200: In in vitro Cytogenetic Assay Measuring Chrorrosomal
               Aberration Frequencies in Chinese Hamster Ovary (CHO) Cells: Study No. 10814-0-437.
               Unpublished study prepared by Hazleton Laboratories America, Inc. 29 p.
41256100       Rhone-Poulenc Ag. Co. (1989) Submission of Mutagenicity Data in Support of 2,4-DB
               Registration Standard.  Transmittal of 1 study.
41256101       Lawlor, T.; Haworth, L. (1989) Mutagenicity Test on Butarac 200 in the AMES
               Salmonella/Microsome Reverse Mutation Assay: HLA Study No.  10814-0-401.  Unpublished
               study prepared by Hazelton Laboratories America, Inc. 35 p.
41318503       Langvoigt.  (1989) Analysis of DD/Df in 2,4-DB Acid for A.  H. Marks. Unpublished study
               prepared by Chemserv Analytik.  lip.
41325500       Rhone-Poulenc Ag Co. (1989) Submission of Environmental Fate Data in Support of 2,4-DB
               Registration Standard.  Transmittal of 2 studies.
41325501       Saxena, A.  (1989) Aerobic and Aerobic/Anaerobic Soil Metabolism of Carbon- 14|-2,4-DB in a
               Sandy Loam Soil: Lab  Project Number: HLS/6015/398. Unpublished study prepared by
               Hazleton Laboratories Americas, Inc.  108 p.
41325502       Noms, F.  (1989) A Small Scale Field Soil Dissipation Study with 4-(2,4-
               Dichlorophenoxy)Butyric Acid (2,4-DB) the Active Ingredient of Butyrac Brand Herbicide: Lab
               Project Number: 40643. Unpublished study prepared by Rhone-
               Poulenc Ag Co.  in cooperation with A & L Eastern Agricultural Laboratories,  Inc. and CYAL.
               100 p.
41337500       Aceto Agricultural Chemicals Corp.  (1989) Submission of Data in Support of Data Call-in
               Notice for Analytical Chemistry Data on Polyhalogenated Dibenzo-
               p-dioxins/Dibenzofurans in 2,4-Dichloro- phenoxybutyric Acid and Its Salts and Esters (2,4-DB).
               Transmittal of 1 study.
41337501       Baldi, A.  (1989) Determination of Dioxins and Dibenzofurans in Chlorophenoxy Alkanoic
               Acids: Protocol and Preliminary Analysis.  Unpublished study prepared by Aceto Agricultural
               Chemicals  Corp.  13 p.
41358900       Rhone-Poulenc Ag Co. (1990) Submission of Data To Support Registration of 2,4-DB: DMA
               Mutagenicity Study.  Transmittal of 1  study.
41358901       Cifone, M.  (1989) Mutagenicity Test on Butyrac 200 in the Rat Primary Hepatocyte
               Unscheduled DNA Synthesis Assay: Lab Project Number: 10814/0/447.  Unpublished study
               prepared by Hazleton Laboratories America, Inc.  22 p.
41370100       Rhone-Poulenc Ag Co. (1990) Submission of Data in Support of 2,4-DB Registration Standard:
               Acute Inhalation and Avian/Fish Toxicity Studies. Transmittal of 4 studies.
41370102       Pederson, C. (1989) 2,4-DB Technical Acid: 21-Day Acute Oral LD50 Study in Bobwhite
               Quail: Final Report: Lab Project ID: # 89 QD 132. Unpublished study prepared by Bio -Life
               Associates, Ltd.  33 p.
41374900       2,4-DB Task Force (1990) Submission of Chemistry Data in Support of 2,4-DB Registration
               Standard List A.  Transmittal of 1 study.
41374901       Pesselman, R. (1989) Octanol/Water Partition Coefficient Determination of 2,4-
               DB Acid: Final Report: Lab Project Number: HLA 6001 - 397.  Unpublished study prepared by
               Hazleton Laboratories America, Inc.  44 p.
41381400       2,4-DB Task Force (1990) Submission of Product Chemistry Data to Support the 2,4-DB
               Registration Standard.  Transmittal of 1 study.
41381401       Hardwick,  F. (1988) Product  Chemistry for Marks DB Technical Acid. Unpublished study
               prepared by A.H.  Marks & Co., Ltd. 24 p.
41382700       2,4-DB Task Force (1990) Submission of Final Report of Rat Teratology in Support of 2,4-DB
               Registration Standard.  Transmittal of 2 studies.
41382701       Henwood,  S. (1990) Teratology Study with 2,4-DB Acid in Rats: Final Report: Project Number:
               HLA 6224-143.  Unpublished study prepared by Hazleton Laboratories America, Inc. 221 p.
                                                 125

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41382702       Kenwood, S. (1990) Range-Finding Teratology Study with 2,4-DB Acid in Rats: Final Report:
               Lab Project Number: HLA 6224-142. Unpublished study prepared by Hazleton Laboratories
               America, Inc.  90 p.
41402200       2,4-DB Task Force (1990) Submission of Product Chemistry Data in Support of the 2,4-DB
               Registration Standard. Transmittal of 16 studies.
41402201       Pesselman, R.  (1989) Munsell Color Determination of 2,4-DB Acid: Lab Project Number: HLA
               6001-391. Unpublished study prepared by Hazleton Laboratories America, Inc. 20 p.
41402202       Pesselman, R.; Semann, T. (1989) Physical State Determination of 2,4-DB Acid: Lab Project
               Number: HLA 6001 -402.  Unpublished study prepared by Hazleton Laboratories America, Inc.
               19p.
41402203       Pesselman, R.  (1989) Odor Determination of 2,4-DB Acid: Lab Project Number: HLA 6001-
               392.  Unpublished study prepared by Hazleton Laboratories America, Inc.  22 p.
41402204       Pesselman, R.; August, J.  (1989) Melting Point/Melting Range Determination of 2,4-DB Acid:
               Lab Project Number: HLA 6001 -394. Unpublished study prepared by Hazleton Laboratories
               America, Inc.  22 p.
41402205       Pesselman, R.  (1989) Solubility  Determination of 2,4-DB Acid: Lab Project Number: HLA
               6001-396. Unpublished study prepared by Hazleton Laboratories America, Inc. 52 p.
41402206       Pesselman, R.  (1989) Vapor Pressure Determination of 2,4-DB Acid: Lab Project Number: HLA
               6001-406. Unpublished study prepared by Hazleton Laboratories America, Inc. 33 p.
41402207       Pesselman, R.  (1989) Dissociation Constant Determination of 2,4-DB Acid: Lab Project
               Number: HLA 6001 -408.  Unpublished study prepared by Hazleton Laboratories America, Inc.
               33 p.
41402208       Pesselman, R.  ; Woosencraft, J.  (1989) pH Value Determination of 2,4-DB Acid: Lab Project
               Number: HLA 6001 -410.  Unpublished study prepared by Hazleton Laboratories America, Inc.
               23 p.
41402209       Pesselman, R.  (1989) Stability Determination of 2,4-DB Acid: Lab Project Number: HLA 6001 -
               404.  Unpublished study prepared by Hazleton Laboratories America, Inc.  26 p.
41407800       2,4 DB-acid Task Force (1990) Submission of Aquatic Toxicity and Phytotoxicity Data in
               Support of Registration of 2,4 DB Products. Transmittal of 3 studies.
41407801       McNamara, P. (1990) 2,4 DB-acid- Acute Toxicity to Daphnids (Daphnia magna) during a 48-
               hour Flow-through Acute  Exposure: Final Report: Lab Report # 89-7-3031; Study #
               10566.0289.6125.115. Unpublished study prepared by Springborn Laboratories, Inc.,
               Environmental Sciences Div. 39 p
41517000       A.H. Marks (1990) Submission  of Product Chemistry Data in Support of Registration of Marks
               DB Technical Acid. Transmittal of 4 studies.
41517001       Pesselman, R.  (1989) Vapor Pesselman Determination of 2,4-DB Acid: Lab Project Number:
               6001-406. Unpublished study prepared by Hazleton Laboratories America, Inc. 33 p.
41517002       Pesselman, R.  (1989) Dissociation Constant Determination of 2,4-DB Acid: Lab Project
               Number: 6001 -408. Unpublished study prepared by Hazleton Laboratories America,  Inc.  26 p.
41517003       Pesselman, R.  (1989) Octanol/Water Partition Coefficient Determination of 2,4-
               DB Acid: Lab Project Number: 6001 -397. Unpublished study prepared by Hazleton Laboratories
               America, Inc.  44 p.
41517004       Pesselman, R.  (1989) Stability Determination of 2,4-DB Acid: Lab Project Number:  6001-404.
               Unpublished study prepared by Hazleton Laboratories America, Inc. 26 p.
41529900       Rhone-Poulenc Ag Co.  (1990) Submission of Data To Support 2,4 DB Registration Standard:
               Toxicology Studies. Transmittal of 3 studies.
41529901       Henwood, S. (1990) 3-Week Dermal Toxicity Study with 2,4-DB Amine in Rabbits:  Final
               Report: Lab Project Number: HLA 6224-140.  Unpublished study prepared by Hazleton
               Laboratories America, Inc. 255 p.
41529902       Henwood, S. (1990) Teratology  Study with 2,4-DB Acid in Rabbits: Final Report: Lab Project
               Number: HLA 6224-145.  Unpublished study prepared by Hazleton Laboratories America, Inc.
               137 p.
41529903       Henwood, S. (1990) Range-finding Teratology Study with 2,4-DB Acid in Rabbits: Lab Project
               Number: HLA 6224-144.  Unpublished study prepared by Hazleton Laboratories America, Inc.
               96 p.
41551300       Rhone-Poulenc Ag Co.  (1990) Submission of Toxicity Data in Support of 2,4-DB Registration
               Standard. Transmittal of  1 study.

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41551301       Kenwood, S. (1989) 3-Week Dermal Toxicity Study with 2,4-DB Acid in Rabbits: Final Report:
               Lab Project Number: HLA 6224-139. Unpublished study prepared by Hazleton Laboratories,
               Inc. 233 p.
41582900       2,4-DB Task Force (1990) Submission of product chemistry data to support the registration
               standard for 2,4-DB. Transmittal of 2 studies.
41582901       Pesselman, R.  (1990) Determination of Boiling Point/Boiling Range of 2,4-DB Acid: Lab
               Project Number: HLA 6001 -488. Unpublished study prepared by Hazleton Labs America,  Inc.
               23 p.
41582902       Pesselman, R.  (1990) Density/Specific Gravity Determination of 2,4-DB Acid: Lab Project
               Number: 6001 -489.  Unpublished study prepared by Hazleton Labs America, Inc. 23 p.
41593700       Rhone-Poulenc Ag Co. (1990) Submission of Supplemental Raw Data for 2,4-
               DB Amine Registration Standard Requirements: Toxicology Studies. Transmittal of 4 studies.
41593701       Nachreiner, D.  (1989) Butryac 200 Acute Aerosol Inhalation Toxicity in Rats: Particle Size
               Distribution Data: Lab Project Number: 52-592. Unpublished study prepared by Rhone-Poulenc
               AgCo. 5 p.
41593702       Lawlor, T; Haworth, L. (1989) Mutagenicity Test on Butryac 200 in the Ames
               Salmonella/Microsome Reverse Mutation Assay: Material Composition Information: Lab Project
               Number: HLA 10814-0-401.  Unpublished study prepared by Hazleton Laboratories America,
               Inc. 6 p.
41593703       Murli, H. (1989) Mutagenicity Test on Butryac 200 in an in vitro Cytogenetic Assay Measuring
               Chromosomal Aberration Frequencies in Chinese  Hamster Ovary (CHO) Cells: Material
               Composition Information and Assay Historical Control Data: Lab Project No: HLA 10814-0-437.
               Unpublished study prepared by Hazleton Laboratory America, Inc. 23 p.
41593704       Cifone, M. (1989) Mutagenicity Test on Butryac  200 in that Rat Primary Hepatocyte
               Unscheduled DNA Synthesis Assay: Material Composition Information: Lab Project Number:
               HLA 10814-0-447.  Unpublished study prepared by Hazleton Laboratories America, Inc. 6 p.
41605400       Rhone-Poulenc Ag Co. (1990) Submission of Data To Support 2,4 DB Registration Standard
               Requirements: Toxicology Study.  Transmittal of  1 study.
41605401       Hoberg, J. (1990) 2,4 DB Amine-Determination of Effects on Seedling Germination, Seed
               Emergence and Vegetative Vigor of Ten Plant Species: Lab Project Number: 10566-0289-6130-
               610: 90-4-3280. Unpublished study prepared by Springborn Laboratories, Inc.  150 p.
41617200       Rhone-Poulenc Ag Co. (1990) Submission of Supplemental Data for 2,4-DB Acid Registration
               Standard: Adsorption/Desorption Study.  Transmittal of 1 study.
41617201       Rustrum, A. (1987) The Adsorption and Desorption of carbon 14|-2, 4-DB on Representative
               Agricultural Skillls: Desorption Coefficient Data:  Lab Project Number: HLA 6015-394.
               Unpublished study prepared by Hazleton Laboratories  America, Inc.  8 p.
41765500       2,4-D, MCPA Task Force (1991) Submission of Chemistry Data in Support of 2,4-DB Acid Data
               Call-in. Transmittal of 1 study.
41765501       Landvoigt, W.  (1990) Determination of Dioxins and Benzofurans in 2, 4-DB-
               Acid by GC/MS: Lab Project Number: AGRO USA0989. Unpub- lished study prepared by
               Chemserv Industrie Service Ges.m.b.H. 394 p.
41774000       Rhone-Poulenc Ag Co. (1991) Submission of Toxicity data in support of 2,4-DB Registration
               Standard. Transmittal of 1 study.
41774001       Nachreiner, D.; Burleigh-Flayer, H. (1990) 2,4-DB Acid: Acute Dust Inhalation Toxicity Test in
               Rats: Lab Project Number: 53-578. Unpublished study prepared by Bushy Run Research Center.
               27 p.
41775400       2,4-DB Task Force (1990) Submission of Data To Support 2,4-DB Registration Standard:
               Toxicology Study. Transmittal of 1 study.
41775401       Henwood, S. (1990) Subchronic Toxicity Study with Dimethylamine Salt of 2,4-
               DB: Final Report: Lab Project Number: HLA 6224-150.  Unpublished study prepared by
               Hazleton Laboratories America, Inc.  10 p.
41800800       A H Marks & Company Limited (1991) Submission of Product Chemistry Data to Support the
               Data Call-In of 2,4-DB.  Transmittal of 2 Studies.
41800801       Landvoigt, W.  (1990) Summary of Analysis of 2,4-DB Detailing the Levels of Substituted
               Dioxins and Benzfurans Found in the Samples. Unpublished study prepared by Chemserv
               Industrie Services Ges.m.b.H. 19 p.

                                                127

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41801102       Landvoigt, W. (1990) Determination of Dioxins and Benzofurans in 2,4-D, 2,4-
               DCP, MCPA, 2,4-DP, CMPP and 2,4-DPB by GC/MS: Lab Project Number: 40288.
               Unpublished study prepared by Chemserve Industrie Service Ges.m.b.H. 15 p.
41810700       Rhone-Poulenc Ag Co. (1991) Submission of Data To Support 2,4-DB Registration Standard:
               Toxicology Study. Transmittal of 1 study.
41810701       Young, R.  (1990) Mutagemcity Test on Butyrac 200 in the CHO/HGPRT Forward Mutation:
               Lab Project Number: 10814-0-435.  Unpublished study prepared by Hazleton Laboratories
               America, Inc. 31  p.
41888000       2,4-DB Task Force (1990) Submission of Data To Support Registration of 2,4-
               DB: Environmental  Fate (Chemistry) Study.  Transmittal of 1 study.
41888001       Ruzo, L.; Ewmg, A.  (1989) Determination of the pKA Value for 2,4- DB: Lab Project Number:
               167-1: 167. Unpublished study prepared by Pharmacology and Toxicology Research Lab.  24 p.
41890600       2,4-DB Task Force (1990) Submission of Data To Support Registration of 2,4-
               DB: Environmental  Fate Study. Transmittal of 1 study.
41890601       Ruzo, L.; Ewing, A.  (1989) Determination of the pKA Value for 2,4- DB (Environmental Fate
               Data): Lab Project Number: 167-1: 167.  Unpublished study prepared by Pharmacology and
               Toxicology Research Lab. 24 p.
41936200       Rhone-Poulenc Ag Co. (1991) Submission of Supplemental Data To Support 2,4-
               DB Registration Standard for 4 Companies: Toxicology Study.  Transmittal of 1 study.
41936201       MacKenzie, K.  (1987) Supplemental Raw Data: Lifetime Dietary Oncogenicity Study in Albino
               Mice with 2,4-DB: Lab Project Number: HLA-6158-104.  Unpublished study prepared by
               Hazleton Laboratories America, Inc. 9 p.
41981600       2,4-DB Task Force (1991) Submission of metabolism data to support the registration standard for
               2,4-DB. Transmittal of 1 study.
41981601       Gibson, N; Downs, J.; Krautter, G.  (1991) Absorption, Distribution and Elimination of (Carbon
               14) 2,4-DB in the Rat: Lab Project Number: PTRL RPT. #1243: PTRL PROJ. #325.
               Unpublished study prepared by PTRL East, Inc.  325 p.
42006300       2,4, DB Task Force  (1991) Submission of toxicity data in support of reregistration of 2,4-DB.
               Transmittal of 1 study.
42006301       Hamada, N.  (1990)  One-Year Oral Toxicity Study in Beagle Dogs with 2,4-DB Technical: Final
               Report: Lab Project  Number: 400-724. Unpublished study prepared by Hazleton Laboratories
               America, Inc. 572 p.
42045500       Agrolinz, Inc. (1991) Submission of product chemistry data in response to a data call-in notice
               for analytical data on poly - halogenated dibenzo -p-
               dioxins/dibenzofurans in 2,4-D acid and it's salts and esters. Transmittal of 1 study.
42045501       Landvoigt, W. (1990) Determination of Dioxins and Benzofurans in 2,4-D-Acid by GC/MS: Lab
               Project Number: AGRO USA0989.  Unpublished study prepared by Chemserv Industrie Service
               Ges.m.b.H. 473 p.
42065300       A.H. Marks & Co.,  Ltd.  (1991) Submission of Data in Response to Dioxin/Furan Data Call-in
               for 2,4-DB: Product Chemistry Studies. Transmittal of 8 studies.
42065301       Langvoigt, W. (1990) Calibration File Using TM1 to TM10: Product Chemistry: Lab Project
               Number: MARKS/0689.  Unpublished study prepared by Chemserv Industrie Service Ges.m.b.H.
               34 p.
42067800       2,4-DB TAsk Force (1991) Submission of environmental fate data to support the registration
               standard for 2,4-DB. Transmittal  of 1 study.
42067801       Obrist,  J. (1989) Artificial Sunlight Photodegradation of (Carbon 14) 2,4-DB in a Buffered
               Aqueous Solution: (Supplement to MRID 41101102): Lab Project Number HLA 6015-396.
               Unpublished study prepared by Hazleton Labs America, Inc. 39 p.
42384000       2, 4-DB Task Force  (1992) Submission of Toxicity Data in Support of Reregistration for 2, 4-DB
               Technical Acid. Transmittal of 1  study.
42384001       Hamada, N.  (1992) One Year Oral Toxicity Study in Beagle Dogs with 2,4-DB Technical:
               Pathology Report- Addendum No.  1 to the Final Report: Lab Project Number: 400-724.
               Unpublished study prepared by Hazleton Washington, Inc.  47 p.
42387300       2,4-DB Task Force (1992) Submission of toxicity data to support registration of 2,4-DB
               Technical Acid. Transmittal of 1  study.
42387301       Tisdale, M. (1985) Four Week Range-Finding Study in Mice with 2,4-DB Technical: Addendum
               to MRID 40257501: Lab Project No. 6158-102.  Unpublished study prepared by Hazleton

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               Laboratoies America, Inc.  247 p.
42558000       A H Marks & Co Ltd (1992) Submission of product chemistry data in support of registration
               standard for 2,4-DP.  Transmittal of 1 study.
42558001       Varcoe, F. (1992) Analysis of Poly chlorinated Dibenzo-p-Dioxins and Polychlorinated
               Dibenzofurans in R(+)2-(2,4-dichlorophenoxy)propionic acid: Final Report: Lab Project
               Number: 21918R: Unpublished study prepared by Triangle Laboratories, Inc.  1171 p.
42595200       2,4-DB Task Force (1992) Submission of toxicity data in support of reregistration of Butyrac
               200.  Transmittal of 1 study.
42595201       Rodwell, D.  (1991) Teratology Study in Rats with Butyrac 200: Final Report: Lab Project
               Number: 3147.54.  Unpublished study prepared by Springborn Labs, Inc. 265 p.
42678400       2,4-DB Task Force (1993) Submission of environmental fate data in support of the 2,4-DB.
               Transmittal of 1  study.
42678401       Lawrence, B.; Mobley, S.; Kesterson, A. (1993) Soil Surface Photolysis of (carbon 14)2,4-DB in
               Artificial Sunlight: Lab Project Number: 729: 1499. Unpublished study prepared by PTRL East,
               Inc. 69 p.
42965900       2,4-DB Task Force (1993) Submission of Residue Chemistry Data for (carbon 14)-2,4-DB Acid
               in Support of Reregistration. Transmittal of 1 Study.
42965901       O'Neal, S. (1993) Metabolic Fate and Distribution of (carbon 14)-2,4-DB Acid  in Alfalfa: Lab
               Project Number: 1529: 682.  Unpublished study prepared by PTRL East, Inc.; 2,4-DB Task
               Force. 144 p.
43004300       2,4-DB Task Force (1993) Submission of Metabolism Data for 2,4-DB in Support of
               Reregistration.  Transmittal of 1  Study.
43004301       O'Neal, S.; Johnson, T.  (1993) A Confined Rotational Crop Study with (carbon-
               14)-2,4-DB Using Carrots (Daucus carota), Lettuce (Lactuca sativa), and Barley  (Hordeum
               vulgare): Lab Project Number: 508: 1522: EF-90-320. Unpublished study prepared by Pan-
               Agricultural Labs., Inc.;  Pharmacology & Toxicology Research Lab; PTRL East, Inc.  310 p.
43009800       2,4-DB Task Force (1993) Submission of Metabolism Data in Support of 2,4-DB Reregistration.
               Transmittal of 1  Study.
43009801       Krautter, G.  (1993) The Metabolism of  (carbon 14)2,4-DB in Laying Hens Following Oral
               Administration for 3 Consecutive Days:  Lab Project Number: 607: 1557. Unpublished study
               prepared by PTRL East,  Inc. 146 p.
43033800       2,4-DB Task Force (1993) Submission of Residue Data in Support of 2,4-DB Registration
               Standard. Transmittal of 3 Studies.
43033801       Moore, P. (1993) Residue Method for the Determination of Dichlorophenoxybutyric Acid (2,4-
               DB), Dichlorophenoxyacetic Acid (2,4-D), and Dichlorophenol (2,4-D Phenol) from Soybeans:
               Lab Project Number: 568:  1559. Unpublished study prepared by PTRL East, Inc. 59 p.
43033802       Krautter, G.  (1993) The Metabolism of  (carbon 14)2,4-DB in Lactatmg Goats Following Oral
               Administration for 3 Consecutive Days:  Lab Project Number: 606: 1561. Unpublished study
               prepared by PTRL East,  Inc. 156 p.
43033803       O'Neil, S. (1993) Metabolic Fate and Distribution of (carbon 14)-2,4-DB Acid in Soybeans: Lab
               Project Number: 1551: 683.  Unpublished study prepared by PTRL East, Inc.  188 p.
43033900       2,4-DB Task Force (1993) Submission of Environmental Fate Data for 2,4-DB in Support of
               Registration Standard. Transmittal of 1  Study.
43033901       O'Neal, S. (1993) Metabolic Fate and Distribution of (carbon-14)-2,4-DB Acid  in Peanuts: Lab
               Project Number: 1547: 681.  Unpublished study prepared by PTRL East, Inc.  186 p.
43095500       A.  H. Marks & Co., Ltd.  (1994) Submission product chemistry data in support of registration
               for 2,4-DB Acid. Transmittal of 8 studies.
43095501       Dyer, I.  (1993) DB Acid (TGAI): Product Chemistry: Lab Project Number:
               AHM/EPA/93/ID/02. Unpublished study prepared by A.H.  Marks and Co.  Ltd. 49 p.
43095502       Dyer, I.  (1993) Beginning Materials - Data  Sheets from Suppliers (DB Acid): Lab Project
               Number: AHM/EPA/93/ID/02. Unpublished study prepared by A. H.  Marks and Co. Ltd. 92
               P-
43095503       Dyer, I.  (1993) A H Marks' Standard Analytical Methods (DB Acid): Lab Project Number:
               AHM/EPA/93/ID/02. Unpublished study prepared by A. H. Marks and Co. Ltd.  31 p.
                                                 129

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43095504       Dyer, I.  (1993) DB Acid Statistical Analysis of QC Data (12 Month Period to July 1993): Lab
               Project Number: AHM/EPA/93/ID/02.  Unpublished study prepared by A. H. Marks and Co.
               Ltd. 20 p.
43095505       Sydney,  P. (1993) 2,4-DB: Preliminary Product Analysis: Final Report: Lab Project Number:
               AMS/045: 93/AMS045/0885. Unpublished study prepared by Pharmaco-LSR Ltd. 77 p.
43095506       Dyer, I.  (1993) Confirmation of Identity of Impurity Standards by GC-MS: Lab Project Number:
               ID/93/2. Unpublished study prepared by A. H. Marks & Co.  Ltd.  28 p.
43095507       Cowlyn, T.  (1993) 2,4-DB Acid: Determination of Physico-Chemical Properties: Final Report:
               Lab Project Number: AMS/039: 93/AMS039/0554. Unpublished study prepared by Pharmaco-
               LSR Ltd. 67 p.
43095508       Dyer, I.  (1993) Investigation of Unidentified Impurities in DB Acid (TGAI): Lab Project
               Number: ID/93/5.  Unpublished study prepared by A H Marks & Co. Ltd. 32 p.
43119200       Cedar Chemical Corp. (1994) Submittal of Product Chemistry Data in Support of Reregistration
               of 4-(2,4-dichlorophenoxy) butyric acid (2,4-DB).  Transmittal of 1 study.
43119201       Bernard, M.  (1994) Product Chemistry: Manufacturing and Analytical Data for Butoxone 7500
               Herbicide. Unpublished study prepared by Cedar Chemical Corp. 44 p.
43121800       The 2,4-DB Task Force (1994) Submittal of Residue Analytical Method Data in Support of
               Registration Standard for 2,4-DB. Transmittal of 1 study.
43121801       Howard, J. (1994) Residue Method for the Determination of Dichlorophenoxybutyric Acid (2,4-
               DB), Dichlorophenoxyacetic Acid (2,4-D) and Dichlorophenol (2,4-D Phenol) from Alfalfa: Lab
               Project Number: 724: 1578.  Unpublished study prepared by PTRL East, Inc. 53 p.
43201700       2,4-DB Task Force (1994) Submission of Residue Analytical Method in Support of 2,4-DB
               Registration Standard. Transmittal of 1 Study.
43201701       Howard, J. (1994) Residue Method for the Determination of Dichlorophenoxybutyric Acid (2,4-
               DB), Dichlorophenoxy acetic Acid (2,4-D), and Dichlorophenol (2,4-D Phenol) from Soybean
               Processed Fractions: Lab Project Number: 568: 1593.  Unpublished  study prepared by PTRL
               East, Inc. 91 p.
43225600       2,4-DB Task Force (1994) Submission of Residue Chemistry Data for 2,4-DB in Support of
               Reregistration.  Transmittal of 1 study.
43225601       Howard, J. (1994) Residue Method for the Determination of Dichlorophenoxybutyric Acid (2,4-
               DB), Dichlorophenoxy acetic Acid (2,4-D) and Dichlorophenol (2,4-D Phenol) from Alfalfa
               Meal: Lab Project Number: 724: 1602.  Unpublished study prepared by PTRL East, Inc.  43 p.
43358600       2,4-DB Task Force (1994) Submittal of Analytical Method Data in Support of Registration
               Standard for 2,4-DB. Transmittal of 1 study.
43358601       Howard, J. (1994) Residue Method for the Determination of Dichlorophenoxybutyric Acid (2,4-
               DB), Dichlorophenoxy acetic Acid (2,4-D) and (inert ingredient) from Soybeans:  Lab Project
               Number: 568: 1559. Unpublished study prepared by PTRL East, Inc. 64 p.
43359000       2,4-DB Task Force (1994) Submittal of Tier II Non-Target Plants Testing Data in Support of
               Registration Standard for 2,4-DB DMAS. Transmittal of 1 study.
43359001       Hoberg,  J. (1994) 2,4-DB Amine- Determination of Effects on Seedling Germination, Shoot
               Emergence and Vegetative Vigor of Ten Plant Species: Supplement: Lab Project Number: 90-4-
               3280: 93-6-4820. Unpublished study prepared by Springborn Laboratories, Inc.  94 p.
43459000       2,4-DB Task Force (1994) Submission of Residue Data in Support of FIFRA 6(a)(2) for 2,4-DB.
               Transmittal of 1  Study.
43459001       Otten, R. (1994) Letter sent to Office of Pesticide Programs dated November 15, 1994:
               (Notification that 2,4-DB and/or its metabolites are detectable in crop by-
               products used as livestock feed). Prepared by 2,4-DB Task Force. 1 p.
43593900       Cedar Chemical Corp. (1995) Submission of Toxicity Data in Support of the Registration of
               Butoxone 7500.  Transmittal of 4 Studies.
43593901       Mallory, V.  (1994) Acute Exposure Oral Toxicity With Butoxone 7500 (in Rats): Lab Project
               Number: PH 402-CC-001-94: 2063: PH402-CC-001-94. Unpublished study prepared by
               Pharmakon Research Int'l, Inc. 169 p.
43593902       Mallory, V.  (1994) Acute Exposure Dermal Toxicity With Butoxone 7500 (on Rabbits): Lab
               Project Number: PH 422-CC-001-94: PH422-CC-001-94: 2060.  Unpublished study prepared by
               Pharmakon Research Int'l, Inc. 69 p.
43593903       Nachreiner, D.  (1995) Butoxone 7500: Acute Dust Inhalation  Toxicity  Study in Rats: Lab
               Project Number: 94N1479. Unpublished study prepared by Pharmakon Research Int'l, Inc. 41 p.

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43593904       Armondi, S. (1994) Delayed Contact Hypersensitivity in Guinea Pigs (Buehler) With Butoxone
               7500: Lab Project Numbers: PH 424-CC-001-94: PH-424: 2069. Unpublished study prepared by
               Pharmakon Research Int'l, Inc.  118 p.
43599000       Cedar Chemical Corp. (1995) Submission of Toxicity Data in Support of Application for
               Registration of Butoxone 7500.  Transmittal of 2 Studies.
43599001       Mallory, V.  (1994) Primary Eye Irritation with Butoxone 7500 (in Rabbits): Lab Project
               Number: PH 421-CC-001-94. Unpublished study prepared by Pharmakon Research
               International, Inc. 35 p.
43599002       Mallory, V.  (1994) Primary Dermal Irritation Study with Butoxone 7500 (in Rabbits): Lab
               Project Number: PH 420-CC-001-94. Unpublished study prepared by Pharmakon Research
               International, Inc. 31 p.
43931800       Aceto Agricultural Chemicals Corp. (1996) Submission of Product Chemistry Data in Support of
               the Registration Standard for 2,4-DB. Transmittal of 1 Study.
43931801       Murray, W.  (1996) Analysis of Poly chlorinated Dibenzo-p-Dioxins and Polychlorinated
               Dibenzofurans in 2,4-Dichlorophenoxybutyric Acid (2,4-DB): Final Report: Lab Project
               Number: 33611. Unpublished study prepared by Triangle Labs, Inc. 921 p.
44064800       A H Marks Co., Ltd.  (1996) Submission of Product Chemistry Data in Support of the
               Registration of DB Acid.  Transmittal of 1 Study.
44064801       Dyer, I. (1995) DB Acid- Product Chemistry: Storage Stability: Final Report: Lab Project
               Number: AHM/EPA/93/ID/02.  Unpublished study prepared by A H Marks and Co., Ltd. 25 p.
44334700       2,4-DB Task Force (1997) Submission of Product Chemistry and Residue Data in Support of the
               Registration Standard for 2,4-DB. Transmittal of 5 Studies.
44334701       King, D. (1996) Characterization of 2,4-Dichlorophenoxybutyric Acid (2,4-DB), 2,4-
               Dichlorophenoxyacetic Acid (2,4-D) and 2,4-Dichlorophenol (2,4-D Phenol): Lab Project
               Number: 1013:  1885. Unpublished study prepared by PTRL East, Inc. 28 p.
44334702       King, D. (1997) Characterization of 2,4-Dichlorophenoxybutyric Acid (2,4-DB): Lab Project
               Number: 1066: 1923. Unpublished study prepared by PTRL East, Inc. 29 p.
44334703       King, D. (1997) Characterization of 2,4-DB Glycine Conjugate: Lab Project Number: 1024:
               1921. Unpublished study  prepared by PTRL East, Inc. 29 p.
44334704       Howard, J. (1997) Development and Validation of Analytical Methodology for the Analysis of
               2,4-Dichlorophenoxybutyric Acid (2,4-DB) in Beef Tissues and Milk: Lab Project Number:
               1000:1905.  Unpublished study prepared by PTRL East, Inc.  110 p.
44334705       Krautter, G.  (1997) Magnitude of the Residue in Meat and Milk from Dairy Cows Treated with
               2,4-Dichlorophenoxybutyric Acid (2,4-DB): Lab Project Number: 993: 1930. Unpublished study
               prepared by PTRL East, Inc.  237 p.
44462200       A.H. Marks &  Co., Ltd.  (1991) Submission of Product Chemistry Data in Support of the
               Application for Reregistration of the 2,4-DB Containing Product Marks DB Technical Acid.
               Transmittal of 11 Studies.
44462201       Landvoigt, W.  (1990) Summary of Analysis of 2,4-DB: Detailing the Levels of Substituted
               Dioxins and Benzfurans Found in the Samples: Lab Project Number: MARKS 0689.
               Unpublished study prepared by Chemserv Industrie Service Ges.m.b.H. 23 p.
44462202       Landvoigt, W.  (1990) Determination of Dioxins and Benzofurans in 2,4-D, 2,4-
               DCP, MCPA, 2,4-DP, CMPP and 2,4-DPB by GC/MS: Lab Project Number: 40288.
               Unpublished study prepared by Chemserv Industrie Service Ges.m.b.H.  19 p.
44462203       Landvoigt, W.  (1990) Calibration File Using TM1  to TM10:  (2,4-DB): Lab Project Number:
               MARKS 0689.  Unpublished study prepared by Chemserv Industrie Service Ges.m.b.H.  34 p.
44462204       Landvoigt, W.  (1990) Analysis of DD/DF in 2,4-DB Acid for A.H. Marks: Lab Project
               Number: KNR. 2954379  S: KNR. 2954382 S: KNR. 2954381 S.  Unpublished study prepared
               by Chemserv Industrie Service Ges.m.b.H. 81 p.
44462205       Landvoigt, W.  (1990) Analysis of DD/DF in 2,4-DB Acid for A.H. Marks: Lab Project
               Number: KNR. 2954379: MARKS 0689: AM 50288. Unpublished study prepared by Chemserv
               Industrie Service Ges.m.b.H. 63 p.
44462206       Landvoigt, W.  (1990) Analysis of DD/DF in 2,4-DB Acid for A.H. Marks: Lab Project
               Number: KNR. 2954380: MARKS 0689: AM 50288. Unpublished study prepared by Chemserv
               Industrie Service Ges.m.b.H. 62 p.
                                                131

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44462207       Landvoigt, W. (1990) Analysis of DD/DF in 2,4-DB Acid for A.H.  Marks: Lab Project
               Number: KNR. 2954381: MARKS 0689: AM 50288. Unpublished study prepared by Chemserv
               Industrie Service Ges.m.b.H. 62 p.
44462208       Landvoigt, W. (1990) Analysis of DD/DF in 2,4-DB Acid for A.H.  Marks: Lab Project
               Number: KNR. 2954382: MARKS 0689: AM 50288. Unpublished study prepared by Chemserv
               Industrie Service Ges.m.b.H. 67 p.
44462209       Landvoigt, W. (1990) Analysis of DD/DF in 2,4-DB Acid for A.H.  Marks: Lab Project
               Number: KNR. 2954383: MARKS 0689: AM 50288. Unpublished study prepared by Chemserv
               Industrie Service Ges.m.b.H. 65 p
44462210       Landvoigt, W. (1990) Analysis of DD/DF in 2,4-DB Acid for A.H.  Marks: Lab Project
               Number: KNR. 2954384: MARKS 0689: AM 50288. Unpublished study prepared by Chemserv
               Industrie Service Ges.m.b.H. 70 p.
44462211       Landvoigt, W. (1990) Analysis of DD/DF in 2,4-DB Acid for A.H.  Marks: Lab Project
               Number: KNR. 2954385: MARKS 0689: AM 50288. Unpublished study prepared by Chemserv
               Industrie Service Ges.m.b.H. 70 p.
44546300       2,4-DB Task Force (1998) Submission of Residue Data in Support of the Reregistration of 2,4-
               Dichlorophenoxybutyric Acid.  Transmittal of 1 Study. Transmittal of 1  Study.
44546301       Howard, J. (1998) Development and Validation of Analytical Methodology for the Analysis of
               2,4-Dichlorophenoxybutyric Acid (2,4-DB) in Poultry Tissues and Eggs: Lab Project Number:
               1001: 1982. Unpublished study prepared by PTRL East, Inc. 83 p.
44660500       2,4-DB Task Force (1998) Submission of Environmental Fate Data in Support of the
               Reregistration of 2,4-DB Acid and DMA salt.  Transmittal of 3 Studies.
44660501       Howard, J. (1998) Developmental and Validation of Analytical Methodology for the Analysis of
               2,4-Dichlorophenoxybutyric Acid (2,4-DB), 2,4-
               Dichlorophenoxyacetic Acid (2,4-D) and 2,4-Dichlorophenol in Soil: Lab Project Number: 999:
               2008. Unpublished study prepared by PTRL East, Inc.  83 p.
44660502       White, J.; Taulbee, L.; Horn, W. et al. (1998) Terrestrial Dissipation of 2,4 Dichlorophenoxy
               Butyric Acid Applied to Peanuts: Lab Project Number: 1007: 2010.  Unpublished study prepared
               by PTRL East, Inc. and Hickey's Agri-Services Laboratory, Inc.  1007 p.
44660503       White, J.; Taulbee, L.; Horn, W. et al. (1998) Terrestrial Dissipation of 2,4 Dichlorophenoxy
               Butyric Acid Applied to  Soybeans: Lab Project Number: 1008: 2007:. Unpublished study
               prepared by PTRL East, Inc. and Easton Agri-
               Consulting, Inc.  526 p.
44680700       2,4-DB Task Force.  (1998)  Submission of Environmental Fate Data in Support of the
               Reregistration of 2,4-Dichlorophenoxy Butyric Acid. Transmittal of 1 Study.
44680701       White, J.; Horn, W.; Johnson, T. (1998) Terrestrial Dissipation of 2,4-
               Dichlorophenoxy Butyric Acid Applied to Alfalfa: Lab Project Number:  1009: 2004.
               Unpublished study prepared by PTRL East, Inc., A.C.D.S. Research, Inc., and A & L Great
               Lakes Laboratories, Inc.  395 p.
44729500       2,4-DB Task Force (1999) Submission of Toxicity Data in Support of the Reregistration of 2,4-
               DB. Transmittal of 1  Study.
44729501       Thornley, K.  (1998) (Carbon-14)-2,4 DB-DMA: Dermal Absorption in the Rat: Final Report:
               Lab Project Number:  1149/22-D1141. Unpublished study prepared by Covance Laboratories
               Limited. 306 p.
44774100       2,4-DB Task Force (1999) Submission of Toxicity and Product Chemistry Data in Support of the
               Reregistration of 2,4-Dichlorophenoxybutyric Acid.  Transmittal of 3 Studies.
44774101       Gibson, N; Marsh, J.; Johnson, T.; et al.  (1999) Absorption, Distribution and Elimination of
               (Carbon 14) 2,4-DB in the Rat: Addendum 1: Structural Confirmation of a 2,4-DB Rat
               Metabolite: Lab Project Number: 325: 2014: HPLC10. Unpublished study prepared by PTRL
               East, Inc.  103 p.
44774102       King, D.  (1998) Characterization of (carbon 14) 2,4-Dichlorophenoxybutyric Acid (2,4-DB):
               Lab Project Number:  1170: 2023: 170A.  Unpublished study prepared by PTRL East, Inc.  33 p.
44774103       King, D.  (1998) Characterization of (carbon 12, 13, 14) 2,4-
               Dichlorophenoxybutyric Acid (2,4-DB): Lab Project Number: 1167:2024: 167A.  Unpublished
               study prepared by PTRL  East, Inc.  34 p.
44997900       2,4-DB Task Force (1999) Submission of Product Chemistry and Residue Chemistry Data in
               Support of the Reregistration of 2,4-DB.  Transmittal of 3 Studies.

-------
44997901      Howard, J. (1999) Radiovalidation of the Analytical Methodology for the Analysis of 2,4-
              Dichlorophenoxybutyric Acid (2,4-DB) in Beef and Poultry Tissues, Milk and Egg: Lab Project
              Number: 1129:2039. Unpublished study prepared by PTRL East, Inc. 59 p.  {OPPTS
              860.1300}
44997902      Gibson, N. (1999) Magnitude of the Residue in Meat and Eggs from Laying Hens Treated with
              4-(2,4-Dichlorophenoxy) butyric Acid (2,4-DB): Lab Project Number: 994: 2060: 091598A.
              Unpublished study prepared by PTRL East, Inc. 195 p. {OPPTS 860.1480}
44997903      King, D. (1999) Characterization of 4-(2,4-Dichlorophenoxy)-3-hydrobutyric Acid: Lab Project
              Number: 1203: 2043. Unpublished study prepared by PTRL East, Inc. 36 p.
45512400      2,4-DB Task Force (2001) Submission of Environmental Fate Data in Support of the
              Reregistration for 2,4-DB. Transmittal of 1 Study.
45512401      Ruzo, L.; Ewing, A.  (2001) Determination of the (pKa) Value for 2,4-DB: Lab Project Number:
              167-1: 167W. Unpublished study prepared by Pharmacology and Toxicology Research
              Laboratory West, Inc. 24 p.
45515600      Nufarm, Inc.  (2001) Submission of Product Chemistry Data in Support of the Amended
              Registration of 2,4-DB Technical.  Transmittal  of 5 Studies.
45515601      Mahlburg, W.  (2001) 2,4DB Product Identity and Composition: Lab Project Number: 2001-3A.
              Unpublished study prepared by Nufarm B. V. 63 p.  {OPPTS 830.1550, 830.1600, 830.1620,
              830.1670,830.1750,830.1800}
45515602      Comb, A. (2000) 2,4DB (Pure Grade) Physico-Chemical Properties: Lab Project Number:
              NUF026/003211.  Unpublished study prepared  by Huntingdon Life Sciences Ltd.  86  p. {OPPTS
              830.6302, 830.6303, 830.6304, 830.7200, 830.7300, 830.7950, 830.7840, 830.7550, 830.7370}
45515603      Comb, A. (2000) Physico-Chemical Properties: 2,4-DB (Technical Grade): Lab Project Number:
              NUF025/003040.  Unpublished study prepared  by Huntingdon Life Sciences, Ltd.  39 p.
              {OPPTS 830.6302, 830.6303, 830.6304, 830.7840, 830.6315}
45515604      Comb, A. (2000) Physico-Chemical Properties (EPA Additional Tests): 2,4-DB (Technical
              Grade): Lab Project Number: NUF027/003039. Unpublished study prepared by Huntingdon Life
              Sciences, Ltd.  24 p.  {OPPTS 830.6313, 830.7000, 830.7300}
45515605      Grienberger, G. (2000) Tetra- To Hepta-Chlorinated Dioxins and Furanes in Seven Batches of
              Technical 4-(2,4-Dichlorophenoxy)Butanoic Acid (2,4-DB): Lab Project Number: NUFARM-
              1199-24DB: 60288.  Unpublished study prepared by Institut fur Industrie - und Umweltanalytik.
              193 p. {OPPTS 830.1700}
45515606      Mahlburg, W.  (2001) Supplemental Data for 2,4-DB (Technical Grade) Five-
              Batch Analysis: Lab  Project Number: NUF/024: 2001-4A.  Unpublished study prepared by
              Huntingdon Life Sciences, Ltd.  and Nufarm, Inc. 33 p. {OPPTS 830.1700}
45523100      Nufarm Inc. (2001) Submission of Product Chemistry Data in Support of the Amended
              Registration of Aceto Agricultural Chemical's 2,4-DB Technical. Transmittal of 1  Study.
45523101      Como, A. (2000) 2,4-DB (Technical Grade) Five Batch Analysis: Lab Project Number: NUF
              024: NUF024/004072. Unpublished study prepared by Huntingdon Life Sciences Ltd. 52 p.
              {OPPTS 830.1700}
45596900      Atanor S.A. (2002) Submission of Product Chemistry and Residue Data in Support of the
              Registration of Atanor Technical 2,4-DB Acid.  Transmittal of 4 Studies.
45596901      Kay, I; Kellogg, M.  (2002) Product Identity and Composition, Description of the Materials
              Used, Description of the Production Process, Discussion of the Formation of Impurities, and
              Certified Limits for Technical 2,4-DB: Lab Project Number: AT-20011. Unpublished study
              prepared by Atanor S.A.  98 p. {OPPTS 830.1550, 830.1600, 830.1620, 830.1670 and
              830.1750}
45596902      Tiernan, T. (2001) Determination of the Content of Tetra-Through Octachlorinated CDDs/CDFs
              and Substituted 2,3,7,8-TCDDs/TCDFs: Lab Project Number: AT-20012.  Unpublished study
              prepared by Wright State University. 203 p.  {OPPTS 860.1700}
45596903      Colin, T. (2001) Preliminary Analysis of Technical 2,4-Dichlorophenoxybutyric Acid: Lab
              Project Number: 427 SOI: 239P17.  Unpublished study prepared by EPL Bio-Analytical Services
              (EPL-BAS). 62 p. {OPPTS 830.1700}
                                                133

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 45596904       Claussen, F. (2002) Determination of the Color, Physical State, Odor, Stability to Elevated
                Temperatures, pH, UV/Visible Absorption, Melting Point, Bulk Density, Dissociation Constant,
                Partition Coefficient, and Solubility of Technical 2,4-Dichlorophenoxybutyric Acid: Lab Project
                Number: 427S02: 239P18. Unpublished study prepared by EPL Bio -Analytical Services (EPL-
                BAS). 63 p. {OPPTS 830.6302, 830.6303, 830.6304, 830.6313, 830.7000, 830.7050, 830.7200,
                830.7300, 830.7370, 830.7550/830.7570, and 830.7840}
 45770100       A.H.  Marks and Company Ltd.  (2002) Submission of Product Chemistry Data in Support of the
                Amended Registration of 2,4-DB Technical Acid.  Transmittal of 5 Studies.
 45770101       Hale, M. (2002) DB Technical:  Product Chemistry: Product Identity and Composition: Lab
                Project Number: USA/DB/DBVOL1.  Unpublished study prepared by A.H. Marks and Co. Ltd.
                14 p.  {OPPTS 830.1550}
 45770102       Hale, M. (2002) DB Technical:  Product Chemistry: Description of Production Process: Lab
                Project Number: USA/DB/DBVOL3.  Unpublished study prepared by A.H. Marks and Co. Ltd.
                64 p.  {OPPTS 830.1620}
 45770103       Hale, M. (2002) DB Technical:  Product Chemistry: Discussion of Formation of Impurities: Lab
                Project Number: USA/DB/DBVOL4.  Unpublished study prepared by A. H.  Marks and Co.
                Ltd. 16 p.  {OPPTS 830.1670}
 45770104       Hale, M. (2002) DB Technical:  Product Chemistry: 5 Batch Analysis Study Report: Lab Project
                Number: USA/DB/DBVOL5: 98/0055: 94/37/EC.  Unpublished study prepared by A.H.  Marks
                and Co. Ltd. 146 p.
 45770105       Hale, M. (2002) DB Technical:  Product Chemistry: Preliminary Analysis, Certified Limits,
                Enforcement Analytical Method: Lab Project Number: USA/DB/DBVOL6. Unpublished study
                prepared by A.H. Marks and Co. Ltd. 39 p. {OPPTS 830.1700, 830.1750, 830.1800}
 45775000       A.H.  Marks and Company Ltd.  (2002) Submission of Product Chemistry Data in Support of the
                Application for Amended Registration of 2,4-DB Technical Acid. Transmittal of 1 Study.
 45775001       Hale, M. (2002) DB Technical:  Product Chemistry: Lab Project Number: USA/DB/DBV/VOL2.
                Unpublished study prepared by A.H. Marks and Company. 139 p. {OPPTS 830.1600}
 46395401       Pigott, G. (2004) Request for a  Waiver for a 2,4-DB Avian Reproduction Study. Project
                Number: DBTF/102604/1. Unpublished study prepared by 2,4-DB Task Force. 5 p.
 46395402       Pigott, G. (2004) Request for a  Waiver for a 28-Day Inhalation Toxicity Study in Rats with 2,4-
                DB. Project Number: DBTF/102504/01. Unpublished study prepared by 2,4-DB Task Force.  6
                P-
2,4-DB-DMAS Bibliography
 MRID         Citation Reference
 00004446      Palmer, J.S.  (1972) Toxicity of 45 Organic Herbicides to Cattle, Sheep, and Chickens. By U.S.
               Agricultural Research Service. Washington, D.C.: U.S.  Dept.  of Agriculture, (pp. 1-10,38
               only; Production research report no.  137; also in unpublished submission received on unknown
               date under 9F0761; submitted by Dow Chemical U.S.A., Midland, Mich.; CDL:092001-B)

 00004456      Bendixen, W.E. (1972) MCPA& 2,4-DB Trials-1972. (Unpublished study received Feb 10,
               1976 under 6E1746; prepared by  Univ. of California, Agricultural Extension Service, submitted
               by Inter-regional Research Project No.  4, New Brunswick, N.J.; CDL: 095368-F)
 00004570      Ball, R.W.E.; Soundy, M. (1958) 2,4-DB and MCPB in Lucerne: Part I. The Effect of 2,4-DB
               and MCPB on the Development of the Lucerne Plant. (Preprint, British Weed Control
               Conference, November, 1958; unpublished study received Dec  5, 1960 under 359-400; prepared
               by May & Baker, Ltd., Agricultural and Horticultural Research Station, Eng., submitted by
               Rhone-Poulenc, Inc., Monmouth  Junction, N.J.; CDL:023310-C)

 00004718      Hagm, R.D.; Lmscott, D.L. (1965) Determination of 4-(2,4-Dichlorophenoxy)-
               butyric acid (2,4-DB) and 2,4-Dichlorophenoxyacetic acid (2,4-D) in forage plants. Journal of
               Agricultural and Food Chemistry 13(2): 123 -125. (Also in unpublished submission received Sep

-------
               12, 1968 under 8F0676; submitted by Dow Chemical U.S.A., Midland, Mich.; CDL:092980-AJ)

00024300       Keaton, J.A.; Rud, O.E. (1971) Balan 1.5LC as a Pre-plant Application for the Control of Fall
               Panicum in Peanuts Grown in Southeastern United States. (Unpublished study received Feb 28,
               1972 under 1471 -55; prepared in cooperation with Virginia Polytechnic Institute and State Univ.,
               Tidewater Research Station, submitted by Blanco Products Co., Div. of Eli Lilly and Co.,
               Indianapolis, Ind.; CDL: 006293-A)

00027005       University of Wyoming, Agricultural Experiment Station (1967) Wyoming Weed Control: Guide
               1967.  Laramie, Wyo.; UW, AES. (Bulletin 442R; pp.  5,7 only; also in unpublished submission
               received Oct 2, 1967 under 8F0643; submitted by Stauffer Chemical Co., Westpoint, Conn.;
               CDL:091116-AV)

00027413       McCarty, M.K.; Sand, P.P. (1961) Chemical weed control in seedling  alfalfa.  III. Effect of
               some herbicides on five varieties.  Weeds 9(1): 14-19. (Also  in unpublished submission received
               May 11, 1961 under 464-164; submitted by Dow Chemical U.S.A., Midland, Mich.;
               CDL:003434-A)

00027414       Kerkin, A.J.; Peters, R.A.  (1957) Herbicidal effectiveness of 2,4- DB, MCPB, Neburon and
               other materials as measured by weed control and yields of seedling alfalfa and birdsfoot trefoil.
               Pages 128-138, In Proceedings of the Northeastern Weed Control Conference; Jan 1957.  N.P.
               (Also in unpublished submission received May 11, 1961 under 464-164; submitted by Dow
               Chemical U.S.A., Midland, Mich.; CDL:003434-B)

00027416       Wells, W.E.; Peters, R.A.  (1959) Yields of legume -forage grass mixtures as affected by several
               herbicides applied alone and in combinations during establishment. Pages 188-199, In
               Proceedings of the Northeastern Weed Control Conference; Jan 1959.  N.P.  (Also in
               unpublished submission received May 11, 1961 under 464-164; submitted by Dow Chemical
               U.S.A., Midland,  Mich.; CDL:003434-E)

00028785       Warden, R.L.; Camery; Yahnke; et al. (1963) Performance Data and Recommendation.
               (Unpublished study received Feb 20, 1963 under 464-164; prepared in cooperation with Univ. of
               Minnesota, Southwest Experiment Station, Dept.  of Agronomy and others, submitted by Dow
               Chemical U.S.A., Midland, Mich.; CDL:003439-A)

00029328       Flanagan, T.R.; MacCollom, G.B. (1964) Herbicide effects on hay and seed production in birds
               foot trefoil.  Proceedings of the Northeast Weed Control Conference 18:315-318.  (also In
               unpublished submission received Jul 22, 1971 under 464-164; submitted by Dow Chemical
               U.S.A., Midland,  Mich.; CDL003455-B)

00030555       Monsanto Company (1979) Effectiveness Data: Summary and Conclusions. (Unpublished study
               received Mar 25,  1980 under 524-308; CDL:242070-A)

00037368       Mitchell, C.B.; McLane, S.R.; Buchannan, D.; et al. (1973) Summary  and Justification: Butyrac
               175 use as a Herbicide in Peanuts. (Unpublished study received May 2, 1973 under 264-164;
               prepared in cooperation with Auburn Univ.  and others, submitted by Union Carbide Agricultural
               Products Co., Ambler, Pa.; CDL:002130-A)

00037369       Mitchell, C.B.; Dryden, B. (1971) Pre and Post-emergence Trials on Soybeans Using Amiben
               and 2,4-DB|.  (Unpublished study received May 2, 1973 under 264-164; submitted by Union
               Carbide Agricultural Products Co., Ambler,  Pa.; CDL:002130-B)

00037370       Frans, R.E.; Staton, H.C.;  Mitchell, W.H.; et al. (1972) Summary: Butyrac and Linuron Tank
               Mixtures for Postemergence Weed Control in Soybeans. (Unpublished study received Jun 7,
               1973 under 264-164; prepared in cooperation with Univ. of Arkansas, Agricultural Experiment
               Station and others, submitted by Union Carbide Agricultural Products  Co., Ambler, Pa.;
               CDL:002131-A)

00041270       State Weed Control Specialists of New England (1966) 1966  Chemical Weed Control for Field
               and Forage Crops. N.P. (Incomplete; also in unpublished submission received Oct 2, 1967
               under 8F0643; submitted by Stauffer Chemical Co., Westport, Conn.; CDL:091116-BB)
                                                135

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00041381       Hull, R.J.; Wakefield, R.C. (1958) The effect of selected herbicides- alone and in combination-
               onthe establishment of legume seedlings. Pages 168-176, In Proceedings of the Northeastern
               Weed Control Conference; Jan 1958.  N.P.  (Also in unpublished submission received May 11,
               1961 under 464-164; submitted by Dow Chemical U.S.A., Midland, Mich.; CDL:003434-C)

00054353       Mobay Chemical Corporation (1979) Supplement to Synopsis of the Effects of Sencor on the
               Environment. Summary of studies 243067-B through 243067-AA. (Unpublished study received
               Aug 14, 1980 under 3125-314; CDL:243067-A)

00054668       Davis, J.T.; Hardcastle, W.S.  (1960) Biological assay of herbicides for fish toxicity. Weeds
               7:397-404.  (Also in unpublished submission received Aug 26, 1977 under 4581-EX-30;
               submitted by Pennwalt Corp., Philadelphia, Pa.; CDL:231831-J)

00059783       Rhone-Poulenc Chemical Company (1958) Efficacy of Buxtone for Seed Legume Crops|.
               (Unpublished study received Dec 9, 1958 under 359-358; CDL:230486-A)

00061007       Fertig, S.N.; Loos, M.A.; Gutenmann, W.H.; et al. (1964) Formation of 2,4-D in 4-(2,4-DB)-
               treated timothy, birdsfoot trefoil, and sterile pea plants.  Weeds 12(2): 147-148.  (Also In
               unpublished submission received May 15, 1967 under 8F0670; submitted by National
               Agricultural Chemical Association, unknown location; CDL: 091172-AH)

00064252       Rhone-Poulenc Chemical Company (1972) Efficacy of Preemergence Herbicides on Peanuts,
               Alfalfa and Other Grasses]. (Compilation; unpublished study, including published data, received
               Sep 5, 1967; Sep 11, 1967; May 12, 1961; under 359-358; CDL: 221533-A)

00078452       Marchio, J.L.; Spurlock, O.L. (1981) Letter sent to Stan Harrison dated Jan 20, 1981 ? Analyses
               for nitrosamine|.  (Unpublished study, including letter dated Sep 18, 1980 from J. Kruzynski to
               S.L. Harrison, received Jun 24, 1981 under 264-

               47; submitted by Union Carbide Agricultural Products Co., Inc., Ambler, Pa.; CDL: 245309-A)

00085405       Wisconsin Alumni  Research Foundation (1958) Assay Report: W.A.R.F. No.  8100601 through
               8100604. (Unpublished study received Feb 16, 1962 under unknown admin, no.; submitted by
               Rhone-Poulenc Chemical Co., Monmouth Junction, N.J.; CDL: 108728-A)

00089920       Palmer, J.S.  (1972) Toxicity of 45 Organic Herbicides to Cattle, Sheep, and Chickens.  By U.S.
               Agricultural Research Service, Veterinary Sciences Research Div.  USARS. (Pages 1-10,38
               only; production research report no.  137, Mar; published study; CDL :090866-D)

00092158       Hazleton Laboratories, Incorporated (1970) Full Reports of Investigations Made with Respect to
               the Safety of the Pesticide Chemical: (2,4-DB)|. Summary of studies 090849-B through 090849-
               L.  (Unpublished study received Dec 16, 1970 under 1F1089; submitted by Rhodia, Inc., New
               Brunswick, N.J.; CDL: 090849-

               A)
00092164       Holsing, G.C.; Voelker, R.W., Jr.  (1969) Final Report: Three-week Repeated Dermal
               Application-Rabbits: Project No. 656-111. (Unpublished study received Dec 16, 1970under
               1F1089; prepared by TRW, Inc., submitted by Rhodia, Inc., New Brunswick, N.J.; CDL:090849-
               G)

00092168       Syracuse University Research Corporation (1970) Report on the Acute Toxicity of Butoxone
               Amine, Butoxone Ester and Cantrol to the Fathead Minnow (Pimephalespromelas Rafmesque)
               and the Rainbow Trout (Salmo gairdneri).  (Unpublished study, including published data,
               received Dec 16, 1970 under 1F1089; submitted by Rhodia, Inc., New Brunswick, N.J.;
               CDL:090849-L)

00094409       Snow, E.A.;Bouw, R.M. (1974) Letter sent to E.E. Chambers dated Jun 28, 1974:
               Compatibility of tank mixed enide SOW with 2,4-DB.  (Unpublished study received Aug 1, 1974
               under 1023-23; submitted by Upjohn Co., Kalamazoo, Mich.; CDL:005407-B)

00102622       Davis, J.; Hardcastle, W. (1959) Biological assay of herbicides for fish toxicity. Weeds 7:397-
               404. (Also In unpublished submission received Jul 18, 1972 under 2E1221; submitted by U.S.
               Dept. of the Army, Washington, DC; CDL:091051-L)

00105875       Rhodia, Inc. (1978) Results of N-Nitroso Contaminant Analysis. (Unpublished study received
               Jun 26,  1978 under 359-677; submitted by Rhone-Poulenc, Inc., Monmouth Junction, NJ; CDL:

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              237357-A)
00108367      Fink, R.  (1974) Final Report: Eight-day Dietary LC50- Bobwhite Quail: Butyrac 175|: Project
              No.  113-105. (Unpublished study received Apr 17, 1974 under unknown admin, no.; prepared
              by Truslow Farms, Inc., submitted by Union Carbide Agricultural Products Co., Inc., Research
              Triangle Park, NC; CDL:131724-A)
00108368      Fink, R.  (1974) Final Report: Eight-day Dietary LC50- Mallard Ducks: Butyrac 175|: Project
              No.  113 -106. (Unpublished study received Mar 20, 1974 under unknown admin, no.; prepared
              by Truslow Farms, Inc., submitted by Union Carbide Agricultural Products Co., Inc., Research
              Triangle Park, NC; CDL:131724-B)
00116018      Rhodia, Inc. (1972) Study: 4(2,4-DB) Residues in Selected Crops .  (Compilation; unpublished
              study received May 31, 1972 under 1F1089; CDL:090848-A) Kalamazoo, MI; CDL:091649-I)
00116347      Syracuse Univ.  Research Corp. (1970) Report on the Acute Toxicity of Butoxone Amine,
              Butoxone Ester and Can-Trol to the Fathead Minnow (Pimephales promelasRafinesque) and the
              Rainbow Trout (Salmo guairdneri). (Unpublished study received on unknown date under
              1F1051; submitted by Rhodia, Inc., New Brunswick, NJ; CDL: 091885-1)

00122805      Cannelongo, B.; Sabol, E.; Sohz, D.; et al.  (1982) Rat Acute Oral Toxicity: Alanap/2,4 DB|:
              Project No. 2716-82.  (Unpublished study received Nov 3, 1982 under 5905-464; prepared by
              Stillmeadow, Inc., submitted by Helena Chemical Co., Memphis, TN; CDL:249111 -A)
00122806      Thomas, E. (1966) Letter sent to G.  Downard dated Nov 23, 1966 Inert ingredients of Swift's
              Gold Bear M40W Chlordane 40W|. (Unpublished study received Feb 17, 1967 under 557-492;
              submitted by Estech, Inc., Chicago, IL; CDL:129595-A)

00123293      Cannelongo, B.; Sabol, E.; Sohz, D.; et al.  (1982) Rabbit Acute Dermal Toxicity: Alanap/2,4
              DB|: Project No.  2717-82.  (Unpublished study received Nov 3, 1982 under 5905-464; prepared
              by Stillmeadow, Inc.,  submitted by Helena Chemical Co., Memphis, TN; CDL:249111-B)
00123294      Maedgen, I; White, D.; Cannelongo, B. (1982) Rat Acute Inhalation Toxicity: Alanap/2,4 DB|:
              Project No. 2720-82.  (Unpublished study received Nov 3, 1982 under 5905-464; prepared by
              Stillmeadow, Inc., submitted by Helena Chemical Co., Memphis, TN; CDL:249111 -C)
00124083      Cannelongo, B.; Sabol, E.; Soliz, D.; et al.  (1982) Rabbit Eye Irritation: Alanap/2,4 DB|: Project
              No.  2718-82. (Unpublished study received Nov 3, 1982 under 5905-464; prepared by
              Stillmeadow, Inc., submitted by Helena Chemical Co., Memphis, TN; CDL:249111 -D)

00124084      Cannelongo, B.; Sabol, E.; Sohz, D.; et al.  (1982) Rabbit Skin Irritation: Alanap/2,4 DB|: Project
              No.  2719-82. (Unpublished study received Nov 3, 1982 under 5905-464; prepared by
              Stillmeadow, Inc., submitted by Helena Chemical Co., Memphis, TN; CDL:249111 -E)
00124089      Union Carbide Agricultural Products Co., Inc. (1982) Chemical Study: Amine 2,4,5-T|.
              (Compilation; unpublished study received Dec 21, 1982 under 264-86; CDL:249117-A)
00125617      Rhodia, Inc. (1972) 2,4-DB: Residues in Clover and Other Subjects]. (Compilation; unpublished
              study received 1972 under 1F1089; CDL:093401-A)

00125618      Rhodia, Inc. (1970) The Name, Chemical Identity, and Composition of the Pesticide Chemical:
              2,4-DB|. (Compilation; unpublished study received Dec 16, 1970 under 1F1089; CDL:093401-
              B)
00126694      Ross, D.; Burroughs, S.; Roberts, N.  (1974) The Acute Toxicity (LC50) of Mecoprop
              Formulated to Japanese Quail: BTS63/74875.  (Unpublished study received Apr 1, 1983 under
              2217-EX-3; prepared by Huntingdon Research Centre, Eng., submitted by FBI- Gordon Corp.,
              Kansas City, MO; CDL :071502-

              B)
00126695      Ross, D.; Burroughs, S.; Roberts, N.  (1974) The Acute Toxicity (LD50) of Mecoprop
              Formulated to Mallard Duck: BTS64/74664.  (Unpublished study received Apr 1, 1983 under
              2217-EX-3; prepared by Huntingdon Research Centre, Eng., submitted by FBI Gordon Corp.,
              Kansas City, MO; CDL:071502-C)
                                                137

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00129638       Myers, R.; Coleman, J.; Mika, E.; et al. (1983) Butyrac 200: Acute Toxicity and Irritancy
               Studies: Rats, Rabbits]: Project Report 45-109.  Rev.  (Unpublished study received Jul 28, 1983
               under 264-105; submitted by Union Carbide Agricultural Products Co., Inc., Research Triangle
               Park, NC; CDL:250871-A)
00130609       Weatherholtz, W.; Gluck, S.; Rendon, F.; et al. (1983) Twentyone-day Eye Irritation Study in
               Monkeys: Butyrac 200: Project No. 400-686. Final rept.  (Unpublished study received Jul 28,
               1983 under 264-105; prepared by Hazleton Laboratories America, Inc., submitted by Union
               Carbide Agricultural Products Co., Inc., Research Triangle Park, NC; CDL:250871-B)

00132034       Interregional Research Project No.  4 (1980)  The Results of Tests on the Amount of 2,4-DB
               Residues Remaining in or on Oats, Including a Description of the Analytical Method Used.
               (Compilation; unpublished study received Oct 13, 1983 under 4E2982; CDL: 072030-A)
00136914       Wisconsin Alumni Research Foundation (1958) Assay Report: W.A.R.F.  Nos.  8100599,
               8100600.  (Unpublished study received May  27, 1966 under 359-349; submitted by Rhone-
               Poulenc, Inc., Monmouth Junction, NJ; CDL:003120-A)
00136915       Rhone-Poulenc, Inc. (1958) Efficacy of 4(2,4-DB) Dimethylamine and Other Herbicides].
               (Compilation; unpublished study received Dec 9, 1958 under 359-
               401; CDL:003121-A)
00149391       Myers, R.  (1984) Butyrac 200: Acute Percutaneous Toxicity Study: [Rabbits]: Project Report
               47-155. Unpublished study prepared by Union Carbide Corp. 10 p.
40755900       Gilmore, Inc.  (1988) Submission of Product Chemistry Data to Support the Registration of
               Buxatone 200.  Transmittal of 1 study.
40755901       Fisher, R.  (1988) Product Chemistry: (Butaxone 200). Unpublished study prepared by Gilmore,
               Inc. 4 p.
40774100       H.R.  McLane, Inc.  (1988) Submission of Product Chemistry to Support the Registration for
               Turf Pride 10-10-10 Lawn Food with Triamine. Transmittal of 1 study.
40774101       Mclane, H.  (1988) Product Specific Data: Turf Prode 10-10-10 Lawn Food with Triamine.
               Unpublished study prepared by Howard Fertilizer Co. 4 p.

40817900       Aceto Chemical Co., Inc. (1988) Submission of Chemistry Data in Support of 4-
               (2,4-Dichlorophenoxy butyric acid) dimethylamine salt. Transmittal of 1 study.
40817901       Baldi, A.  (1987) 2,4-DB 175; 4-(2,4-Dichlorophenoxy butyric acid dimethylamine salt.: Product
               Chemistry.  Unpublished study prepared by Laboratory of the Government Chemist.  46 p.
40866300       Gilmore Inc. (1988) Submission of Chemistry Data in Support of Buxatone 200.  Transmittal of
               1 study.
40866301       Fisher, J.  (1988) Buxatone 200: ... Product Chemistry: Description of Beginning Materials and
               Manufacturing Process.  Unpublished compilation prepared by Gilmore Inc. 6 p.
40977800       Cedar Chemical Corp. (1989) Submission of Chemistry Data in Support of 2,4-
               DB Reregistration Standard. Transmittal  of 6 studies.
40977801       Bellet, E.  (1989) Product Chemistry for Butoxone 200: Typical Physical Properties!
               Unpublished study prepared by Cedar Chemical Corp. 6 p.
40977803       Bellet, E.  (1989) Product Chemistry for Butoxone SB: Typical Physical Properties|.
               Unpublished study prepared by Ceder Chemical Corp. 6 p.
41370100       Rhone-Poulenc Ag Co. (1990) Submission of Data in Support of 2,4-DB Registration Standard:
               Acute Inhalation and Avian/Fish Toxicity Studies. Transmittal of 4 studies.
41370101       Nachreiner, D.  (1989) Butyrac 200: Acute Aerosol Inhalation Toxicity Test in Rats: Lab Project
               ID: 52-592. Unpublished study prepared  by Bushy Run Research Center. 35 p.

41370103       Pedersen, C. (1989) Butyrac 200: 8-Day Acute Dietary LC50 Study in Bobwhite Quail: Final
               Report: Lab Project ID: # 89 QC 130; HLA 6012-273. Unpublished study prepared by Bio-Life

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               Assocciates, Ltd. and Hazleton Laboratories, America, Inc. 71 p.
41370104       Sousa, J.  (1989) 2,4-DB Amine Acute Toxicity to Rainbow Trout (Oncorhynchus mykiss) under
               Flow-through Conditions: Final: SLS Report # 89-6-3003; Study 1056.0289.6126.108.
               Unpublished study prepared by Springborn Laboratories, Inc.  Environmental Sciences Div. 39
               P-
41402200       2,4-DB Task Force (1990) Submission of Product Chemistry Data in Support of the 2,4-DB
               Registration Standard.  Transmittal of 16 studies.
41402210       Pesselman, R. (1989) Physical State Determination of 2,4-DB Dimethylamine Salt: Lab Project
               Number: HLA 6001 -403. Unpublished study prepared by Hazleton Laboratories America, Inc.
               20 p.
41402211       Pesselman, R. (1989) Odor Determination of 2,4-DB Dimethylamine Salt: Lab Project Number:
               HLA 6001-393.  Unpublished study prepared by Hazleton Laboratories America, Inc. 22 p.
41402212       Pesselman, R.; August, J. (1989) Boiling Point/Boiling Range Determination of 2,4-DB
               Dimethylamine Salt: Lab Project Number: HLA  6001 -395.  Unpublished study prepared by
               Hazleton Laboratories America, Inc.  24 p.

41402213       Pesselman, R. (1989) Solubility Determinaion of 2,4-DB Dimethylamine Salt: Lab Project
               Number: HLA 6001 -399. Unpublished study prepared by Hazleton Laboratories America, Inc.
               41 p.
41402214       Woosencraft, J.; Pesselman, R. (1989) Dissociation Constant Determination of 2,4-DB
               Dimethylamine Salt: Lab Project Number: HLA  6001 -409.  Unpublished study prepared by
               Hazleton Laboratories America, Inc.  28 p.
41402215       Pesselman, R. (1989) pH Value Determination of 2,4-DB Dimethylamine Salt: Lab Project
               Number: HLA 6001 -401. Unpublished study prepared by Hazleton Laboratories America, Inc.
               25 p.

41402216       Pesselman, R. ; Woosencraft, J. (1989) Stability Determination of 2,4-DB Dimethylamine Salt:
               Lab Project Number: HLA 6001 -405.  Unpublished study prepared by Hazleton Laboratories
               America,  Inc. 26 p.
41407800       2,4 DB-acid Task Force (1990) Submission of Aquatic Toxicity and Phytotoxicity Data in
               Support of Registration of 2,4 DB Products.  Transmittal of 3 studies.
41407802       Sousa, J.  (1990) 2,4 DB Amine- Acute Toxicity to Bluegill (Lepomis macrochirus) under Flow-
               through Conditions: Final Report: Lab Report #  89-6-
               3059; Study # 10566.0289.6126.105.  Unpublished study prepared by Springborn Laboratories
               Inc., Environmental Sciences Div. 38 p.

41407803       Giddings, J. (1990) 2,4-DB Amine- Toxicity to  the Freshwater Green Alga Selenastrum
               capncornutum: Final Report: Lab Report # 90-1- 3196; Study  # 10566-0289-6129-430.
               Unpublished study prepared by Springborn Laboratories, Inc., Environmental Sciences Div. 29
               P-
41460400       2,4-DB Task Force (1990) Submission of Product Chemistry Data in Support of the 2,4-DB
               Registration Standard.  Transmittal of 1 study.
41460401       Pesselman, R. (1989) Munsell Color Determination of 2,4-DB, Dimethylamine Salt: Lab Project
               Number: 6001 -398. Unpublished study prepared by Hazleton Laboratories America, Inc. 20 p.
41958000       Cedar Chemical  Corp.  (1991) Submission of toxicity data in support of registration of Butoxone
               200. Transmittal of 1 study.
41958001       Mallory, V. (1991) Primary Eye Irritation Study: Lab Project  Number PH 421-
               CC-001 -91. Unpublished study prepared by Pharmakon Research International, Inc. 31 p.
42120500       Cedar Chemical  Corp.  (1991) Submission of product chemistry data to support the me-too
               product registration for Butoxone 7450.  Transmittal of 1 study.

                                                 139

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42120501       Bernard, M.  (1991) Manufacturing and Chemistry Data for Butoxone 7450.  Unpublished study
               prepared by Cedar Chemical Corp.  8 p.
42569300       2,4-DB Task Force (1992) Submission of product chemistry to support registration standard of
               2,4-DB. Transmittal of 4 studies.

42569301       McDaniel, R.; Weiler, D. (1987) Vapor Pressure Determination of 2,4-
               Dichlorophenoxybutyric Acid dimethylamine Salt: Lab Project Number: 8710006. Unpublished
               study prepared by Rhone-Poulenc Inc.  8 p.

42569302       McDaniel, R.; Weiler, D. (1987) Design and Validation of High Flow Apparatus for Vapor
               Pressure Determination: 2,4-Dichlorophenoxybutyric Acid dimethylamine Salt: Lab Project
               Number: 8710020. Unpublished study prepared by Rhone-Poulenc Inc.  20 p.
42569303       Helfant, L.; Lowder, J.  (1987) Concentration of 2,4-Dichlorophenoxybutyric Acid
               dimethylamine Salt in Deionized Water: Lab Project Number: 87080. Unpublished study
               prepared by Rhone-Poulenc Inc.  9 p.
42569304       Rhone-Poulenc Inc. (1988) Mass Transfer Considerations in the Use of the Gas Saturation
               Method for Vapor Pressure Determination- 2,4-
               Dichlorophenoxybutyric Acid dimethylamine Salt: the Attainment of Test Compound Saturation
               of the Carrier Gas at High Flow Rates.  Unpublished study prepared by Rhone-Poulenc Inc. 22
               P-
42626700       Cedar Chemical Corp. (1993) Submission of product chemistry data in support of the
               registration of 2,4-DB Amine Concentrate.  Transmittal of 1 study.
42626701       Bernard, M.  comp. (1992) Product Chemistry: Manufacturing and Analytical Data for 2,4-DB
               Amine  Concentrate.  Unpublished compilation prepared by Cedar Chemical Corp. lip.
42741500       2,4-DB Task Force (1993) Submission of Product Chemistry Data in Support of Registration
               Standard for 2,4-DB Dimethyl Amine Salt (DMAS). Transmittal of 1 Study.
42741501       Andrews, K.  (1993) Dissociation of 2,4-DB Dimethyl Amine Salt (DMAS) in Water: Lab
               Project Number: SC920205. Unpublished study prepared by Battelle Columbus Operations.  60
               P-
43002600       Albaugh, Inc. (1993) Submission of Product Chemistry Data in Support of Application for
               Registration of 2,4-DB 1.75 and 2,4-DB 2.   Transmittal of 1 Study.
43002601       Haefele, L. (1993) Product Specific Chemistry for 2,4-DB  1.75: Final Report: Lab Project
               Number: 93-ALBG-001.  Unpublished study prepared by AC RN Labs.  37 p.
43002700       Albaugh, Inc. (1993) Submission of Product Chemistry Data in Support of Application for
               Registration of 2,4-DB 1.75 and 2,4-DB 2.   Transmittal of 1 Study.
43002701       Haefele, L. (1993) Product Specific Chemistry for 2,4-DB 2: Final  Report: Lab Project Number:
               93-ALBG-002. Unpublished study prepared by AC RN Labs. 37 p.
43033800       2,4-DB Task Force (1993) Submission of Residue Data in Support of 2,4-DB Registration
               Standard.  Transmittal of 3 Studies.

43033803       O'Neil, S.  (1993) Metabolic Fate and Distribution of (carbon 14)-2,4-DB Acid in Soybeans: Lab
               Project Number: 1551: 683. Unpublished study prepared by PTRL  East, Inc.  188 p.

43054000       2,4-DB Task Force (1993) Submission of hazard to non-target plants data in support of
               registration standard for 2,4-DB DMAS. Transmittal of 1 study.
43054001       Hoberg, J.  (1993) 2,4 DB Amine- Determination of Effects on Seed Germination and Seedling
               Emergence of Several Plant Species: Supplemental Report:  Lab Project Number: 93/6/4820:
               10566/0289/6130/610: 90/4/3280. Unpublished study prepared by Springborn Labs,  Inc. 93 p.
43393300       2,4-DB Task Force (1994) Submission of Residue Data in Support of 2,4-DB Registration
               Standard.  Transmittal of 1 Study.

43393301       Howard, J. (1994) Residue Method for the  Determination of Dichlorophenoxybutyric Acid (2,4-
               DB), Dichlorophenoxy acetic Acid (2,4-D) and (inert ingredient) from Peanuts: Lab Project

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               Number: 753: 1621. Unpublished study prepared by PTRL East, Inc.  71 p.

43607000       2,4-DB Task Force (1995) Submis sion of Residue Data in Support of FIFRA 6(a)(2) and
               Registration Standard for 2,4-DB. Transmittal of 2 Studies.

43607001       Johnson, T.  (1995) Field Crop Residue Study with 2,4-DB Applied to Soybeans (Raw
               Agricultural Commodities): Lab Project Number: 568: 1641. Unpublished study prepared by
               PTRL East, Inc.  624 p.

43607002       Johnson, T.  (1995) Field Crop Residue Study with 2,4-DB Applied to Soybeans (Processed
               Food/Feed): Lab Project Number: 568: 1669.  Unpublished study prepared by PTRL East, Inc.
               213 p.

43620300       2,4-DB Task Force (1995) Submission of Residue Data in Support of FIFRA 6(a)(2) and
               Registration Standard for 2,4-DB. Transmittal of 1 Study.

43620301       Johnson, T.  (1995) Field Crop Residue Study with 2,4-DB Applied to Alfalfa (Raw Agricultural
               Commodities and Processed Commodities): Lab Project Number: 724: 1678: DB-92-93-CA-01.
               Unpublished study prepared by PTRL East, Inc. 769 p.

43621200       2,4-DB Task Force (1995) Submission of Residue Data in Support of FIFRA 6(a)(2) and
               Registration Standard for 2,4-DB. Transmittal of 1 Study.

43621201       Johnson, T.  (1995) Field Crop Residue Study with 2,4-DB Applied to Peanuts (Raw Agricultural
               Commodities and Processed Commodities): Lab Project Number: 753: 1706: DB-93-AL-01.
               Unpublished study prepared by PTRL East, Inc. 617 p.

43830100       2,4-DB Task Force (1995) Submission of Metabolism Data in Support of the Registration
               Standard for 2,4-DB. Transmittal of 1  Study.

43830101       Krautter, G.; Gibson, N; Marsh, J.  (1995) The Disposition and Metabolism of (Carbon 14)-2,4-
               DB Dimethylamine Salt in the Rat: Lab Project Number: 576: 1840. Unpublished study prepared
               by PTRL East, Inc.  117 p.

43968900       A.H.  Marks and Company Ltd. (1996) Submission of Product Chemistry and Toxicology Data
               in Support of the Application for Registration of 2,4 -DB DMA 246. Transmittal of 11 Studies.

43968901       Dyer, I. (1996) 2,4-DB DMA 246- Product Chemistry: Final Report: Lab  Project Number:
               AHM/EPA/96/ID/01. Unpublished study prepared by A.H. Marks and Company, Ltd. 35 p.

43968902       Dyer, I. (1996) 2,4-DB DMA 246- Beginning Materials: Data Sheets and  A H Marks' Purchase
               Specifications: Lab Project Number: AHM/EPA/96/ID/01.  Unpublished study prepared by A.H.
               Marks and Company, Ltd. 39 p.

43968903       Dyer, I; Rowley, R.; Branwell, M. (1996) A H Marks' Standard Analytical Methods (for 2,4-
               DB DMA 246): Lab Project Number: ADM/EPA/96/ID/01.  Unpublished study prepared by
               A.H.  Marks and Company, Ltd.  17 p.

43968904       Hersey, R. (1995) DB DMA 246 g/1 AI- Determination of Physical-Chemical Properties: Lab
               Project Number:  95/0007. Unpublished study prepared by A.H. Marks and Company, Ltd. 52
               P-
43968905       Dyer, I. (1996) 2,4-DB DMA 246 Product Specification (MSDS) (Provisional).  Unpublished
               study prepared by A.H.  Marks and Company, Ltd.  8 p.

43968906       McRae, L. (1995) 2,4-DB DMA 246 g/1: Acute Oral Toxicity to the Rat: Lab Project Number:
               AHM 87/952450/AC. Unpublished study prepared by Huntingdon Life  Sciences Ltd. 24 p.

43968907       McRae, L. (1996) 2,4-DB DMA 246 g/1: Acute Dermal Toxicity to the Rat: Lab Project
               Number: AHM 88/952358/AC.  Unpublished  study prepared by Huntingdon Life Sciences Ltd.
               16p.

43968908       Jackson, G.  (1996) 2,4-DB DMA 246 g/1: Acute Inhalation Toxicity in Rats 4-

               Hour Exposure: Lab Project Number: AMH 92/953096. Unpublished study prepared by
               Huntingdon Life Sciences Ltd. 49 p.
                                                141

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43968909       Parcell, B.  (1996) 2,4-DB DMA 246g/l: Eye Irritation to the Rabbit: Lab Project Number: AHM
               90/952726/SE.  Unpublished study prepared by Huntingdon Life Sciences Ltd.  17 p.
43968910       Parcell, B.  (1996) 2,4-DB DMA 246g/l: Skin Irritation to the Rabbit: Lab Project Number: AHM
               89/952371/SE.  Unpublished study prepared by Huntingdon Life Sciences Ltd.  15 p.

43968911       Rees, P. (1996) 2,4-DB DMA 246g/l: Delayed Contact Hypersensitivity Study in the Guinea-
               Pig: Final Report: Lab Project Number: AMS/047: 95/AMS047/1030. Unpublished study
               prepared by Huntingdon Life Sciences Ltd.  26 p.
43969500       A.H. Marks and Company, Ltd. (1996) Submission of Product Chemistry and Toxicology Data
               in Support of the Application for Registration of MARKS 2,4-
               DB DMA 500.  Transmittal of 10 Studies.
43969501       Dyer, I.  (1995) DB DMA 500- Product Chemistry: Final Report: Lab Project Numb er:
               AHM/EPA/95/ID/03.  Unpublished study prepared by A H Marks and Company, Ltd. 36 p.
43969502       A H Marks and Company, Ltd. (1995) DB DMA 500- Beginning Materials: Data Sheets and A
               H Marks' Purchase Specifications: Lab Project Number: AHM/EPA/95/ID/03.  Unpublished
               study. 30 p.
43969503       A H Marks and Company, Ltd. (1995) A H Marks' Standard Analytical Methods: (DB DMA
               500): Lab Project Number: AHM/EPA/95/ID/03. Unpublished study.  29 p.
43969504       Hersey, R.  (1994) DB DMA 500 g/1 AI- Determination of Physical-Chemical Properties: Lab
               Project Number: 94/0005. Unpublished study prepared by A H Marks and Company, Ltd.  54 p.
43969505       McRae, L.  (1995) 2,4-DB DMA 500 g/1: Acute Oral Toxicity to the Rat: Lab Project Number:
               AHM 83/952437/AC: AHM 83.  Unpublished study prepared by Huntingdon Life Sciences Ltd.
               23 p.
43969506       McRae, L.  (1996) 2,4-DB DMA 500 g/1: Acute Dermal Toxicity to the Rat: Lab Project
               Number: AHM 84/952357/AC: AHM 84. Unpublished study prepared by Huntingdon Life
               Sciences Ltd. 17 p.

43969507       Jackson, G.  (1996) 2,4-DB DMA 500 g/1: Acute Inhalation Toxicity in Rats 4-
               Hour Exposure: Lab Project Number: AHM 91/953103: AHM 91.  Unpublished study prepared
               by Huntingdon Life Sciences Ltd. 43 p.

43969508       Parcell, B.  (1996) 2,4-DB DMA 500g/l: Eye Irritation to the Rabbit: Lab Project Number: AHM
               86/952725/SE: AHM 86.  Unpublished study prepared by Huntingdon Research Centre Ltd.  16
               P-
43969509       Parcell, B.  (1996) 2,4-DB DMA 500g/l: Skin Irritation to the Rabbit: Lab Project Number: AHM
               85/952370/SE: AHM 85.  Unpublished study prepared by Huntingdon Life Sciences Ltd.  15 p.
43969510       Rees, P. (1996) 2,4-DB DMA 500g/l: Delayed Contact Hypersensitivity Study in the Guinea-
               Pig: Final: Lab Project Number: AMS/046: 95/AMS046/1029: 95/1029. Unpublished study
               prepared by Huntingdon Life Sciences Ltd.  31 p.
43969900       A.H. Marks and Co.  Ltd.  (1996) Submission of Product Chemistry Data in Support of the
               Application for Registration of MARKS 2,4-DB DMA 1.75. Transmittal of 1 Study.
43969901       Dyer, I.  (1996) 2,4-DB DMA 1.75- Product Chemistry: Summary Report: Lab Project Number:
               AHM/EPA/96/ID/02.  Unpublished study prepared by A H Marks and Co.  Ltd. 27  p.
43991200       A.H. Marks and Co.  Ltd.  (1996) Submission of Product Chemistry Data in Support of the
               Application for Registration of MARKS 2,4-DB DMA 500. Transmittal of 1 Study.
43991201       A H Marks and Co.  Ltd.  (1995) DB DMA  500 Product Specification (Provisional): Lab Project
               Number: 5152.  Unpublished Study.  9 p.
43991800       A.H. Marks and Co.  Ltd.  (1996) Submission of Environmental Fate Data in Support of the
               Application for Registration of MARKS 2,4-DB DMA 2. Transmittal of 1 Study.

43991801       Andrews, K. (1993) Special Study: Dissociation of (2,4-)DB DMAS in Water: Final Report: Lab
               Project Number: SC 920205.  Unpublished study prepared by Battelle Columbus Operations. 60

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43995900


43995901



44729500

44729501



45735300


45735304

46395501
P-
A.H. Marks and Co. Ltd.  (1996) Submission of Product Chemistry Data in Support of the
Application for Registration of MARKS 2,4-DB DMA 500.  Transmittal of 1 Study.
Andrews, K. (1993) Special Study: Dissociation of DB DMAS in Water: Final Report: Lab
Project Number: SC 920205: 24DBDMAS.WK1: DBCOND.WK1. Unpublished study prepared
by Battelle Columbus Operations. 60 p.

2,4-DB Task Force (1999)  Submission of Toxicity Data in Support of the Reregistration of 2,4-
DB.  Transmittal of 1 Study.
Thornley, K. (1998) (Carbon-14)-2,4 DB-DMA: Dermal Absorption in the Rat: Final Report:
Lab Project Number: 1149/22-D1141.  Unpublished study prepared by Covance Laboratories
Limited. 306 p.

A.H. Marks and Company Ltd.  (2002) Submission of Product Chemistry and Toxicity Data in
Support of the Application for Registration of Sodiu m MCPB Herbicide.  Transmittal of 6
Studies.
Bass, R. (2000) Thermal Stabilty of Butoxone: Final Report: Lab Project Number: 00/0101.
Unpublished study prepared by A H Marks and Company Limited.  79 p.
Mattock, S.  (1999) 2,4-DB Sodium 400 g/L: Toxicity to Lemna minor: Final Report. Project
Number: 785/61-D2145, 785/61. Unpublished study prepared by Covance Laboratories, Ltd. 34
P-
                                                143

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Appendix E. Generic Data Call-In

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145

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147

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Appendix F. Product Specific Data Call-In

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149

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151

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153

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155

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157

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159

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161

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163

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165

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Appendix G.  Batching of 2,4-DB and 2,4-DB-DMAS Products for Meeting Acute Toxicity
Data Requirements for Reregistration

       In an effort to reduce the time, resources and number of animals needed to fulfill the
acute toxicity data requirements for reregi strati on of products containing 2,4-DB as the active
ingredient, the Agency has batched products which can be considered similar for purposes of
acute toxicity. Factors considered in the sorting process include each product's active and inert
ingredients (identity, percent composition and biological activity), type of formulation (e.g.,
emulsifiable concentrate, aerosol, wettable powder, granular, etc.), and labeling (e.g., signal
word, use classification, precautionary labeling, etc.).  Note that the Agency is not describing
batched products as "substantially similar" since some products within a batch may not be
considered chemically  similar or have identical use patterns.

       Using available information, batching has been accomplished by the process described in
the preceding paragraph.  Not with-standing the batching process, the Agency reserves the right
to require, at any time, acute toxicity data for an individual product should the need arise.

       Registrants of products within a batch may choose to cooperatively generate, submit or
cite a single battery of six acute toxicological studies to represent all the products within that
batch.  It is the registrants' option to participate in the process with all other registrants, only
some of the other registrants, or only their own products within a batch, or to generate all the
required acute toxicological studies for each of their own products.  If a registrant chooses to
generate the data for a batch, he/she must use one of the products within the batch as the test
material. If a registrant chooses to rely upon previously submitted acute toxicity data, he/she
may do so provided that the data base is complete and valid by today's standards (see acceptance
criteria attached), the formulation tested is considered by EPA to be similar for acute toxicity,
and the formulation has not been significantly altered since submission and acceptance of the
acute toxicity data.  Regardless of whether new data is generated or existing data is referenced,
registrants must  clearly identify the test material by EPA Registration Number. If more than one
confidential statement of formula (CSF) exists for a product, the registrant must indicate the
formulation actually tested by identifying the corresponding CSF.

       In deciding how to meet the product specific data requirements, registrants must follow
the directions given in the Data Call-In Notice and its attachments appended to the RED.  The
DCI Notice contains two response forms which are to be completed and submitted to the Agency
within  90 days of receipt.  The first form, "Data Call-In Response," asks whether the registrant
will meet the data requirements for each product. The second form, "Requirements Status and
Registrant's Response," lists the product specific data required for each product, including the
standard six acute toxicity tests. A registrant who wishes to participate in a batch must decide
whether he/she will provide the data or depend on someone else to do so.  If a registrant supplies
the data to support a batch of products, he/she must select one of the following options:
Developing Data (Option 1), Submitting an Existing Study (Option 4), Upgrading an Existing
Study (Option 5) or Citing an Existing Study (Option 6). If a registrant depends on another's
data, he/she must choose among: Cost Sharing (Option 2), Offers to Cost Share (Option 3) or
Citing  an Existing Study (Option 6).  If a registrant does not want to participate in a batch, the

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choices are Options 1,  4, 5 or 6.  However, a registrant should know that choosing not to
participate in a batch does not preclude other registrants in the batch from citing his/her studies
and offering to cost share (Option 3) those studies.

        Twenty one products were found which contain 2,4-DB as the active ingredient. These
products have been placed into eight batches and a "No Batch" category in accordance with the
active and inert ingredients and type of formulation.
$
No Batch:  Each product in this Batch should generate their own data.
NOTE: The technical acute toxicity values included in this document are for informational
purposes only.  The data supporting these values may or may not meet the current acceptance
criteria.
Batch 1

EPA Reg. No.
2749-93
15440-20
19713-124
46146-01
% Active Ingredient
98.0
96.0
98.0
97.0
Batch 2

EPA Reg. No.
71368-49
74530-15
% Active Ingredient
75.0
75.0

Batch 3

EPA Reg. No.
15440-32
15440-34
% Active Ingredient
26.85
26.85

Batch 4

EPA Reg. No.
71368-46
71368-48
% Active Ingredient
26.2
26.2
                                           169

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Batch 5

EPA Reg. No.
42750-38
51036-232
% Active Ingredient
25.9
25.9

Batch 6

EPA Reg. No.
2749-516
71368-33
% Active Ingredient
25.9
25.9
Batch 7

EPA Reg. No.
42750-39
51036-231
74530-17
% Active Ingredient
23.0
23.0
23.0
Batch 8

EPA Reg. No.
2749-126
71368-32
% Active Ingredient
23.0
23.0

No Batch

EPA Reg. No.
15440-33
71368-47
% Active Ingredient
49.2
23.0

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Appendix H. List of All Registrants Sent the Data Call-In
                                         171

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173

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Appendix I.  List of Available Related Documents and Electronically Available Forms
Pesticide Registration Forms are available at the following EPA internet site:
http://www.epa.gov/opprd001/forms/.

Pesticide Registration Forms (These forms are in PDF format and require the Acrobat reader)

Instructions

       1.     Print out and complete the forms. (Note: Form numbers that are bolded can be
             filled out on your computer then printed.)

       2.     The completed form(s) should be submitted in hardcopy in accord with the
             existing policy.

       3.     Mail the forms, along with any additional documents necessary to comply with
             EPA regulations covering your request, to the address below for the Document
             Processing Desk.

       DO NOT fax or e-mail any form containing 'Confidential Business Information' or
'Sensitive Information.'

If you have any problems accessing these forms, please contact Nicole Williams at (703) 308-
5551 or by e-mail atwilliams.nicole@epamail.epa.gov

       The following Agency Pesticide Registration Forms are currently available via the
internet at the following locations:
8570-1
8570-4
8570-5
8570-17
8570-25
8570-27
8570-28
8570-30
8570-32
8570-34
8570-35
8570-36
Application for Pesticide Registration/Amendment
Confidential Statement of Formula
Notice of Supplemental Registration of Distribution of
a Registered Pesticide Product
Application for an Experimental Use Permit
Application for/Notification of State Registration of a
Pesticide To Meet a Special Local Need
Formulator's Exemption Statement
Certification of Compliance with Data Gap Procedures
Pesticide Registration Maintenance Fee Filing
Certification of Attempt to Enter into an Agreement
with other Registrants for Development of Data
Certification with Respect to Citations of Data (in PR
Notice 98-5)
Data Matrix (in PR Notice 98-5)
Summary of the Physical/Chemical Properties (in PR
Notice 98-1)
http://www.epa.gov/opprd001/forms/8570-l.pdf

http://www.epa.gov/opprd001/forms/8570-4.pdf
http://www.epa.gov/opprd001/forms/8570-5.pdf

http://www.epa.gov/opprd001/forms/8570-17.pdf

http://www.epa.gov/opprd001/forms/8570-25.pdf

http://www.epa.gov/opprd001/forms/8570-27.pdf

http://www.epa.gov/opprd001/forms/8570-28.pdf

http://www.epa.gov/opprd001/forms/8570-30.pdf

http://www.epa.gov/opprd001/forms/8570-32.pdf

http://www.epa.gov/opppmsdl/PR Notices/pr98-
5.pdf
http://www.epa. gov/opppmsdl/PR Notices/pr98-
5.pdf
http://www.epa.gov/opppmsdl/PR Notices/pr98-
l.pdf

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8570-37
         Self-Certification Statement for the Physical/Chemical
        Properties (in PR Notice 98-1)
http://www.epa.gov/opppmsdl/PR Notices/pr98-
                                                   l.pdf
Pesticide Registration Kit
www.epa.gov/pesticides/registrationkit/.

Dear Registrant:

       For your convenience, we have assembled an online registration kit that contains the
following pertinent forms and information needed to register a pesticide product with the U.S.
Environmental Protection Agency's Office of Pesticide Programs (OPP):
       1.
       2.
             The Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) and the Federal
             Food, Drug and Cosmetic Act (FFDCA) as Amended by the Food Quality
             Protection Act (FQPA) of 1996.
             Pesticide Registration (PR) Notices

                    83-3 Label Improvement Program—Storage and Disposal Statements

                    84-1 Clarification of Label Improvement Program

                    86-5 Standard Format for Data Submitted under FIFRA
             a.

             b.

             c.

             d.
                    87-1 Label Improvement Program for Pesticides Applied through
                    Irrigation Systems (Chemigation)

             e.     87-6 Inert Ingredients in Pesticide Products Policy Statement

             f      90-1 Inert Ingredients in Pesticide Products; Revised Policy Statement

             g.     95-2 Notifications, Non-notifications, and Minor Formulation
                    Amendments

             h.     98-1 Self Certification of Product Chemistry Data with Attachments (This
                    document is in PDF format and requires the Acrobat reader.)

       Other PR Notices can be found at http://www.epa.gov/opppmsdl/PR Notices.

       3.     Pesticide Product Registration Application Forms (These forms are in PDF format
             and will require the Acrobat reader.)

             a.     EPA Form No.  8570-1, Application for Pesticide
Regi strati on/Amendment

             b.     EPA Form No.  8570-4, Confidential Statement of Formula

             c.     EPA Form No.  8570-27, Formulator's Exemption Statement

             d.     EPA Form No.  8570-34, Certification with Respect to Citations of Data
                                          175

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             e.     EPA Form No.  8570-35, Data Matrix

       4.     General Pesticide Information (Some of these forms are in PDF format and will
             require the Acrobat reader.)

             a.     Registration Division Personnel Contact List

             b.     Biopesticides and Pollution Prevention Division (BPPD) Contacts

             c.     Antimicrobials Division Organizational Structure/Contact List

             d.     53 F.R. 15952, Pesticide Registration Procedures; Pesticide Data
                    Requirements (PDF format)

             e.     40 CFR Part 156, Labeling Requirements for Pesticides and Devices (PDF
                    format)

             f     40 CFR Part 158, Data Requirements for Registration (PDF format)

             g.     50 F.R. 48833, Disclosure of Reviews of Pesticide Data (November 27,
                    1985)

       Before submitting your application for registration, you may wish to consult some
additional sources of information. These include:

       1.     The Office of Pesticide Programs' Web Site

       2.     The booklet "General Information on Applying for Registration of Pesticides in
             the United States", PB92-221811, available through the National Technical
             Information Service (NTIS) at the following address:

                    National Technical Information Service (NTIS)
                    5285 Port Royal Road
                    Springfield, VA 22161

       The telephone number for NTIS is (703) 605-6000.  Please note that EPA is currently in
the process of updating this booklet to reflect the changes in the registration program resulting
from the passage of the FQPA and the reorganization of the Office of Pesticide Programs. We
anticipate that this publication will become available during the Fall of 1998.

       3.     The National Pesticide Information Retrieval System (NPIRS) of Purdue
             University's Center for Environmental and Regulatory Information Systems. This
             service does charge a fee for subscriptions and custom searches. You can contact
             NPIRS by telephone at (765) 494-6614 or through their Web site.

       4.     The National Pesticide Telecommunications Network (NPTN) can provide
             information on active ingredients, uses, toxicology, and chemistry of pesticides.
             You can contact NPTN by telephone at (800) 858-7378 or through their Web site:
             ace.orst.edu/info/nptn.

       The Agency will return a notice of receipt of an application for registration or amended
registration, experimental use permit, or amendment to a petition if the applicant or petitioner

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encloses with his submission a stamped, self-addressed postcard. The postcard must contain the
following entries to be completed by OPP:

                    Date of receipt
                    EPA identifying number
                    Product Manager assignment

       Other identifying information may be included by the applicant to link the
acknowledgment of receipt to the specific application submitted. EPA will stamp the date of
receipt and provide the EPA identifying File Symbol or petition number for the new submission.
The identifying number should be used whenever you contact the Agency concerning an
application for registration, experimental use permit, or tolerance petition.
To assist us in ensuring that all data you have submitted for the chemical are properly coded and
assigned to your company, please include a list of all synonyms, common and trade names,
company experimental codes, and other names which identify the chemical (including "blind"
codes used when a sample was submitted for testing by commercial or academic facilities).
Please provide a CAS number if one has been assigned.
                                          177

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